ML20128A415
| ML20128A415 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/28/1985 |
| From: | Reynolds N, Wooldridge R, Woolridge R BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-631 OL, OL-2, NUDOCS 8507020669 | |
| Download: ML20128A415 (125) | |
Text
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DSLKETLD USN3C UNITED STATES OF AMERICA '85 JUN 28 PS:05 NUCLEAR REGULATORY COMMISSION LM BEFORE THE ATOMIC SAFETY AND LICENSINO[$0ARD Ci[In In the Matter of ) Docket Nos. 50-445-#
) 50-446-F, TEXAS UTILITIES ELECTRIC ) 50-445-2 and COMPANY, ET AL. ) 50-446-2 gg _g (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)
APPLICANTS' CURRENT MANAGEMENT VIEWS AND MANAGEMENT PLAN FOR RESOLUTION OF ALL ISSUES June 28, 1985 T 0507020669 850629
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00CKETED
'JSNRC UNITED STATES OF AMERICA '85 JIN 28 P5:05 NUCLEAR REGULATORY COMMISSION OFFICE OF SECRr_IA. -
r10C4EitNG A SEr"/li '
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ERANCH In the Matter of ) Docket Nos. 50-445-1
) 50-446-1, TEXAS UTILITIES ELECTRIC ) 50-445-2 and COMPANY, ET AL. ) 50-446-2
)
(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)
APPLICANTS' CURRENT MANAGEMENT VIEWS AND MANAGEMENT PLAN FOR RESOLUTION OF ALL ISSUES June 28, 1985
APPLICANTS' CURRENT MANAGEMENT VIEWS AND MANAGEMENT PLAN FOR RESOLUTION OF ALL ISSUES TABLE OF CONTENTS I. INTRODUCTION........................................... 1 II. B AC KG RO U N D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 III. CURRENT MANAGEMENT VIEWS............................... 5 A. StatusofPlant.................................. 6 B. Adequacy of the Record........................... 7 C. Responsibility, Performance and Compete nce o f Man ag eme nt . . . . . . . . . . . . . . . . . . . 9 D. Prior Management Actions......................... 12 IV. COMANCHE PEAK RESPONSE TEAM............................ 16 The Comanche Peak Response Team........................ 16 A. Introduct io n - Obj ect ives . . . . . . . . . . . . . . . . . . . . . . . . 17 B. CPRT Structure................................... 20 C. Pro g r a m Me t ho do lo g y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
- 1. The Issue-Responsive ISAP's................ 22
- 2. The self-initiated efforts................. 23
- 3. CPRT records............................... 24
- 4. Program interfaces......................... 25 D. Pr o g r a m O u t p u t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 E.
Conclusion:
CPRT................................ 27 V. PLAN FOR SPECIFICATION AND RESOLUTION OF DOCKET 1 ISSUES.................................. 27 A. Overview......................................... 27 B. Further Litigation of Outstanding Issues......................... 29
C. The Board's Required Finding:
Reasonable Assurance....................... 35 D. The NRC Staff's Responsibilities................. 39 E. S t a t us o f Is s u es . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 F. Spec i f icat io n o f Iss ues . . . . . . . . . . . . . . . . . . . . . . . . . . 43 G. Plan for Resolution of Pending Issues. . . . . . . . . . . . 45
- 1. Unresolved Issues.......................... 46
- a. welding issues....................... 47
- b. protective coatings.................. 48
- c. records / document control............. 52
- d. polar crane shims.................... 53
- e. oversight of CB&I and and N'3I activities............. 54
- f. traceabili / of materials........... 55
- g. walkdown r ins pections. . . . . . . . . . . . . . . 55
- h. unqualifies OA/QC supervisory personnel...................... 56
- 1. component modi fi cat ion car ds. . . . . . . . . 56
- j. reactor vessel mirror shield......... 57
- 2. TRT Findings............................... 57
- 3. Cygna Independent Reviews.................. 58
- 4. Pipe Support Design........................ 59 VI. PLAN FOR FURTHER PROCEEDING IN DOCKET 2................ 60 A. Issues Presented in Docket 2 Are Moot............ 62 B. Management Commitment to Quality................ 64 C. Docket 2 Technical Issues........................ 64
- 1. Liner Plate Travelers...................... 64
- 2. Standfor d/Neumeyer NCR. . . . . . . . . . . . . . . . . . . . . 67
- 3. Startup Test Engineering................... 68
- 4. Valve Discs................................ 69 VII. SUGGESTED ORDER IN WHICH ISSUES MAY BE RESOLVED.................................. 70 V I I I . C ON C LU S I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
June 28, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-445-1
) 50-446-1, TEXAS UTILITIES ELECTRIC ) 50-445-2 and COMPANY, ET AL. ) 50-446-2
)
(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)
APPLICANTS' CURRENT MANAGEMENT VIEWS AND MANAGEMENT PLAN FOR RESOLUTION OF ALL ISSUES I. INTRODUCTION On May 24, 1985, the Board issued Memorandum (Case Management Plan), in which the Board directed the Applicants to file, by June 15, 1985, a statement of " current management views" in accordance with the discussion in the Memorandum.1/ Memorandum at 3. The Board also directed the Applicants to file, promptly after relevant Staff documents became available, a plan for identifying, hearing, and resolving the outstanding issues in these proceedings, consistent with the discussion in the Memoran-dum. Memorandum at 5. Applicants submit herein both the requested Current Management views and the Management Plan.
1/ The Board subsequently extended the date for filing the current management views to June 28, 1985. Memorandum (Request for an Extension of Time) (June 12, 1985).
II. BACKGROUND The sole remaining contention in controversy in this pro-ceeding is Contention 5, regarding quality assurance ("QA"). On March 15, 1984, the Board issued Memorandum (Clarification of Open Issues), in which it set forth the status of specific issues in the proceeding under that contention. Those specific issues involved allegations of deficiencies in Applicants' QA program.2/
Many of the issues identified in the March 15, 1984 Memorandum have subsequently been addressed and some have been resolved by (
Board decision. The issues which have been decided relate to velding allegations.3/ In addition, by Federal Register notice dated April 5, 1984, a separate Licensing Board was " established
\
to preside over all allegations of intimidation and barassment."4/
As hearings continued on the remaining issues in Contention 5, several material developments resulted from the NRC Staff's continuing review of Comanche Peak which are significant for any plan for managing this proceeding. On September 18, 1984, the NRC Staff issued the first of three letters setting forth the results of an investigation of allegations (received by the Staff
-2/ Other issues relating to the adequacy of Applicants' QA program were resolved in the Board's initial decisions issued in July, September and October, 1983. See LBP 43, 18 NRC 122 (1983); LBP-83-60, 18 NRC 672 (1983); LBP-83-69, 18 NRC 1084 (1983).
3/ See Memorandum (Concerning Welding Issues), LBP-84-55, 20 NRC 1646 (1984).
-4/ " Establishment of Atomic Safety and Licensing Board to Preside in Proceeding," 49 Fed. Reg. 13613 (April 5, 1984).
3-primarily outside of the hearing framework) with respect to Comanche Peak.5/ This investigation was performed by the NRC Staff's Technical Review Team ("TRT"). The Staff letters documented the findings of the TRT with respect to allegations related to the compliance of structures, systems, or components with applicable construction, design, and inspection documentation and/or requirements, and the implementation and adequacy of aspects of the Comanche Peak QA program. The NRC Staff requested that Applicants submit a plan to address the TRT findings. Applicants were requested, inter alia, to investigate and ascertain the root causes of deficiencies and the generic implications of the findings for construction quality at Comanche Peak, and to implement appropriate corrective actions.g/
5/ These letters were dated September 18 and November 29, 1984, and January 8, 1985. The NRC subsequently issued Supplemental Safety Evaluation Reports ("SSER's")
providing additional discussion of its findings. These SSER's were issued January (SSER 7), February (SSER 8),
April (SSER 10), and May 1985 (SSER 11).
s/ As the NRC stated in the January 8, 1985, letter to Applicants:
This program plan shall: (1) address the root cause of each finding and its generic implications on safety-related systems, programs, or areas, (2) address the collective significance of these deficiencies, and (3) propose an action plan from TUEC that will ensure that such problems do not occur in the future.
The Staff added:
. . . your examination of the potential safety implications of the TRT findings should include, but not be limited to the areas or activities selected by the TRT.
By letters dated October 8 and November 21, 1984, and April 23, 1985, Applicants transmitted to the NRC Staff a draft program plan and certain issue-specific action plans for NRC review.
These plans set forth the actions Applicants intend to take in response to TRT findings. Final program plans relating to TRT findings and additional issue-specific action plans will be submitted within the next few days. These action plans are being developed and implemented by the Comanche Peak Response Team
("CPRT"), which is described in detail in Section IV, below.
Applicants established the CPRT, which is comprised of third-party experts with extensive experience in the design and construction of nuclear power plants, to address the TRT's findings and to probe well beyond those findings by developing and implementing a program to identify and correct deficiencies in safety-related structures, systems, and components.
On April 26, 1985, Applicants submitted to the Licensing Board a proposed mechanism to define specific hearing issues and to establish procedures for resolving those issues. The proposal noted that one effect of the of the CPRT effort will be to render unnecessary (or at least have an impact upon) further consideration of certain previously admitted issues. Applicants proposed to submit a detailed plan identifying issues and a procedure for their resolution following issuance of the Staff's SSER on QA/QC, The Board has requested that Applicants advise the Board and parties as to the status of issues which remain open in these
I proceedings, and suggest the order for the resolution of any outstanding issues.
The Board also called for Applicants to submit the views of current management with respect to several questions.
See Memorandum (Case Management Plan) (May 24, 1985),
at 2-3.
Applicants present their response to these Board requests.
III. CURRENT MANAGEMENT VIEWS .
Applicants herein respond to the Board's request for the views of current management. We consider the request to be in the nature of other Board inquiries into matters of interest to I
it (see, e.g.,
Memorandum (Adequacy of Record: Delaval Diesel Generators) (January 31, 1984)). Specifically, the Board has asked for management's views of the status of the plant, the adequacy of the record, the responsibility, performance, and competence of management, and current management's view of prior management actions. .
We address each issue in order. We also discuss " current uncertainties" related to each issue.
We initially note that the SSERs and Board notifications
- ontaining transcripts of NRC Staff meetings, as referred to in
- he Board's Memorandum, are not now formally before this Board.
(t this date, no offer of proof, no supporting testimony and no ,
letermination of relevancy to the outstanding contention has been tade with respect to that material.
While statements in some of he transcripts may be viewed as support for an allegation that adverse plant conditions" exist at Comanche Peak, a Board
finding to that effect would not be appropriate at this time.
Indeed, the Board has acknowledged the need to await Applicants' response to the Staff's findings before reaching conclusions regarding the implication of those findings for the issues in the proceeding (see Memorandum (Motion for Evidentiary Standard)
(March 12, 1985), at 2).
The correctness of this view is confirmed by the fact that most of the findings issued by the Staff's TRT have made no determination whatever of safety significance.7/ We ask the Board to recognize that our response is somewhat circumscribed by the timing of the request, in light of the above, and the present status of the ongoing studies.
A. Status of Plant Management be:. eves that Comanche Peak is generally well designed and constructed. As the result, however, of perhaps the most intensive investigation ever directed to a nuclear facility, discrepancies have been identified which are of concern to Applicants.
Applicants are carefully and thoroughly addressing these problems. Applicants will take corrective action where necessary. For exinple, Applicants have already ordered the modification or replacement of a number of pipe supports and 7/
~ An example is found in SSER Number 10 wherein the TRT investigated four hundred concerns, found only sixty to be completely or partially substantiated, found that all but 8 vere not safety-related, and upon review, found only five issues from those 8 concerns to have any potential safety significance. It is yet to be determined whether any of those safety. Se five actually do have an effect on plant SSER Number 10 , page N-17, para. 3.4.
expect that other modifications will be required. Applicants will perform reanalyses of major segments of the piping and support system before operation of the plant. Applicants have discovered and are addressing discrepancies in other areas.
In sum, Applicants recognize that plant design and construction have not been error-free. Preliminary indications from the comprehensive Comanche Peak Response Team effort to this point, however, reflect few safety-significant deficiencies.
Applicants fully expect that other deficiencies will be identified, given the scope and depth of Applicants' reinspection and corrective action program. These will also be analyzed and corrected.
TUGCO management is not satisfied with the status of the plant and would not proceed to operate it, even if authority were to be granted, until all of the outstanding concerns have been addressed, their safety significance determined, generic implications and collective significance considered, and necessary corrective actions have been completed.
B. Adequacy of the Record In its Memorandum, the Board referred to the Applicants' plan approved by this Board in early 1984.8/ Since that plan was presented and approved, NRC Staff has completed a comprehensive inspection under the direction of the Office of Nuclear Reactor 8/ See also discussion, infra (Section V.B.) regarding Board inquiry as to the appropriateness of further litigation (Memorandum at 2, n.2).
8-Regulation. In many respects, these new tindings reflect conclusions different from those made by the NRC Staff as a result of its earlier inspections. Presumably, some or all of the facts underlying the latest findings and conclusions will be offered into evidence at some point in this proceeding. The Rules of Practice will afford Applicants an opportunity to meet such of these facts as are admitted into evidence. In any event, at the direction of the NRC Staff, Applicants are addressing those concerns at this time. Applicants' management has assembled a highly qualified team, not only to address these concerns but also to initiate other review and reinspection efforts. To the extent the effort of this highly qualified team bears on the contention before this Board, it should become a part of the hearing record before this Board. In foregoing context, and in the above described setting, the current state of the record is clearly " inadequate."
One of the " current uncertainties" is whether there may be a need to update or correct, rather than add to, the existing record. As discussed in Applicants' Management Plan, infra, Applicants will withdraw the outstanding Motions for Summary Disposition regarding pipe support design upon a determination by the Board that the extensive CPRT efforts to assess the adequacy of pipe support design have become the proper focus of Board attention for this issue. Further, some opinions (those of Cygna, for example) have changed, based upon more detailed information as subsequent extensive examinations have taken
place. Applicants are not now certain whether, or the extent to which, these circumstances may give rise to a need to correct the record.
As further discussed, infra, Applicants believe that a number of previous issues have become moot or irrelevant. As the Board determines that issues addressed in the present record will need to be addressed by this Board in its final decision, it will be necessary to re-examine the relevant record in the light of developments over the last twelve months, and supplement or correct the record as necessary.
C. Responsibility, Performance and Competence of Management As earlier reported to this Board,9/ there have been a number of changes in the company's nuclear management over the last few months. Enclosed is an excerpt from an Amendment (No. 55) to Applicants' FSAR, which will be formally submitted to the NRC in the next few days. The Amendment reflects the detailed background of the individuals currently comprising Applicants' management, together with an appropriate description of (and a chart reflecting) the current nuclear organization.
Applicants are most fortunate to have employed Mr. William G.
Counsil and Mr. John W. Beck in permanent key management areas in ,
Applicants' nuclear program.10/ Further, Applicants have 9/ See March 21, 1985, April 5, 1985, and June 12, 1985, letters to the Board from Applicants' counsel.
10/ See FSAR Amendment enclosed. For a further discussion of TFootnote 10 continued on next page)
installed a new QA management team under Mr. Beck that we believe is highly qualified to serve the project.11/ TUGCO has modified its nuclear organization to be fully responsive to all concerns, to complete construction, and to efficiently operate the plant when licensed in full compliance with NRC requirements. All of the individual management changes have resulted in additions of persons with substantial nuclear experience who have had no previous involvement with any area which has been a subject of controversy in these licensing proceedings.
In addition, over the last several months Applicants have initiated a number of new programs to emphasize more fully to all employees at the job site this management's commitment to quality and safety as a first priority. These initiatives include: the institution of the "Safeteam" program; high level management meetings with Quality Control inspectors and craft supervisors to encourage quality construction and the reporting of all safety concerns; new training programs; and new methods for encouraging employee involvement in'the development of clear, understandable, and accurate procedures. Applicants have also developed a program (through policy letters and meetings on-site) to re-emphasize to all craft employees their individual responsibility to report safety concerns and specifically to remind and re-(Footnote 10 continued from previous page) their background and management philosophy, see Transcript of NRC/TUGCO meeting of June 13 and 14, 1985, pp. 7-12 and pp. 26-29.
--11/ See FSAR Amendment enclosed for a description of their background and qualifications.
i 11 -
instruct craft supervisors of their obligation to encourage their workers in this regard.
TUGCo believes its current management is highly qualified to complete construction and operate the facility. Applicants have brought to Comanche Peak persons with substantial reputations for competence, integrity, demonstrated commitment to safety, and responsiveness to regulation. In response to the Board's specific question, management is not presently aware of any member of the current nuclear management which in its view is not
" competent to continue." In addition, the members of the Applicants' CPRT and its Senior Review Team ("SRT") are extremely knowledgeable in their areas of expertise. All enjoy excellent reputations for ability and integrity and are fully committed to objectivity in their review. Applicants will present the identities and qualifications of the CPRT and SRT members to the Board in the CPRT Program Plan, to be filed within the next few days.
Applicants' current management, coupled with the assistance from the CPRT/SRT members, can, should, and, we believe, will, provide the NRC, this Board, and the public with reasonable assurance that all concerns will be fully addressed and resolved and that Comanche Peak will be completed and operated safely by a highly qualified team of officers and employees.
12 -
D. Prior Management Actions Current management recognizes, based upon the Staff's TRT efforts and preliminary indications from Applicants' CPRT efforts, that further inspection or analysis, or both, of many portions of the plant is necessary to evaluate indicated design or construction discrepancies. We discuss the portions of the plant now in question, and our plans to address all issues, in the Management Plan. At this time, management believes that it would be premature to assess " prior management actions" until Applicants' plan to address the issues has been implemented and some results are available for evaluation. Only then will management know the extent to which safety-significant deficiencies may exist in the plant or whether other discrepancies exist that, while not safety-significant, indicate a trend that should have been detected. And only then will management learn the root cause of any deficiencies, a key ingredient in any meaningful evaluation of prior management actions, including the management level at which such problems should have been detected and corrected.
Nevertheless, it is not premature for current management to share some general observations with the Board that may bear on past performance. The Comanche Peak plant is the first nuclear project undertaken by Applicants. The management team that guided this project from its inception was composed of dedicated individuals with strong engineering credentials, much of which has been earned in the design, construction, and operation of
fossil-fueled generating plants. Texas Utilities has enjoyed a long history of excellence in the generation of electric energy at low cost and with high reliability. It has experienced substantial success in implementing new technologies, such as pioneering the development of large lignite-fuel generating plants. The Company has maintained an excellent safety record, which it prizes, for many years.
Applicants also believe that its management has always been committed to constructing and operating a safe plant. While there may have been isolated situations that could have been handled better from the standpoint of employee relations and comt nications,12/ Applicants see no evidence that prior mani ement directed or condoned any systematic discouragement of inst 'ctors to do their jobs. To the contrary, Applicants believe, the present record reflects that inspectors have been and are encouraged to report nonconforming conditions.
Applicants believe that the description of prior " Management Style at CPSES" presented in the report prepared by EG&G Idaho, Inc.,13/ is in several respects a fair appraisal, although it is diff. cult to generalize in the context of a ten-year construction effort involving thousands of managers and employees and many 12/ An example of which is management's over-reaction to the "T-Shirt incident." See e.g., Tr. 15236-7, 15289 (September 11, 1984).
~~13/ " Comanche Peak Steam Electric Station Alleged Climate of Intimidation," EG&G Idaho, Inc. (September 1984) ("EG&G Report"), forwarded to the Board by NRC Board Notification 84-157 (September 17, 1984).
management decisions. EG&G utilized the information available to it and " compared impressions" to develop its characterization of Applicants' management. EG&G found a basically conservative management style with an emphasis on error prevention and adherence to preset procedures. The atmosphere was found to be
" task-centered," with accomplishment of the objective (getting the job done) being "the most important priority (which) consumes much of the attention of supervisory personnel." EG&G Report at
- 38. These are observations that seem to apply to Comanche Peak, as they most likely would apply at many large construction sites.
In our view, these observations do not, standing alone, reflect adversely on prior management.
On the other hand, EG&G found the atmosphere to be " tense and stressful due to the complexity of schedules and interfaces which tend to be potentially conflictful." Id. While we believe that this is inevitable to some extent, we acknowledge that it is clearly less than the optimum. EG&G !aund that management had "little tolerance for ambiguity or for the questioning of supervisory demands." EG&G also found that communications were primarily downward and afforded "very little opportunity for interaction" and "little tolerance for deviating from information communicated downward." Id. at 38-39. Our current view is that these findings, (if confirmed as a result of the CPRT efforts to determine the root cause of construction or design discrepancies, and this Board's review thereof), while clearly overgeneralized, reflect a management style that has not been ideal for handling
employee relations in the complex world of nuclear power today.
However, we have no basis upon which to conclude that Applicants' prior management was not fully committed to the quality of construction and safe operation of the plant.
i One of the lessons learned by the nuclear industry in recent years is that successful nuclear utilities generally are those staffed with individuals experienced in nuclear power, including construction, operations and regulatory activities. This has not been lost on Applicants, and the recent addition of managers with substantial nuclear experience in programs with broad-based success in all facets of the industry reflect that the lesson has been learned. Further, Applicants are intent on further staffing their nuclear organization with personnel with more experience in the nuclear power industry.
It remains to be seen whether (and if so, to what extent) prior management actions were affected by its more limited background in nuclear power and its regulation 1_4/ and to what extent, if any, such resulted in any materially adverse effect on the quality of construction or the adequacy of the design of Comanche Peak. Again, determinations of root causes for any major deficiencies found should shed light on that issue.
Applicants are filing herein their complete Management Plan for this proceeding. The CPRT Program Plan and the Specific
--14/ For instance, the failure to disclose the 1978 audit report prepared by MAC, is an indication of the lack of appreciation of nuclear power regulation. See letter dated June 12, 1985, to this Board regarding this matter.
1 Action Plans which have been developed to address individual issues will be forwarded in the next few days. Applicants believe that from such filings this Board will recognize current management's commitment to a safe plant, Applicants' villingness to cooperate fully with the regulatory process, Applicants' willingness to address, assess, and disclose adverse conditions and their root causes, and Applicants' willingness to take all reasonable corrective actions necessary to assure safe plant operation.
IV. COMANCHE PEAK RESPONSE TEAM Applicants' Plan for resolution of issues in this proceeding is founded in large measure on the extensive reviews now being conducted by the Comanche Peak Response Team. Applicants will demonstrate in their Plan (see Sections V and VI, infra) that the proper focus for resolution of issues in both dockets should be the CPRT effort. First, however, we present a description of the CPRT program. A complete description is presented in the CPRT program and action plans to be submitted within a few days.
The Comanche Peak Response Team The Comanche Peak Response Team is a comprehensive, self-directing effort the purpose of which is, and the result of the efforts of which will be, to address and resolve, from a fresh perspective, all of the issues raised by any source relating to the quality of construction or the adequacy of design at Comanche Peak. By its definition, the CPRT effort will include (but not
be limited to) all of the issues presently admitted for litigation in the proceeding before this Board. What follows is a brief summary of such massive effort.
A. Introduction - Objectives The CPRT was created initially to prepare and present the Applicants' response to the NRC Staff's TRT assessments (which consisted of a number of specific quality of construction concerns). Since that time the CPRT effort has evolved in a number of ways.
First, the scope has expanded. In addition to the TRT concerns, the CPRT charter was expanded to include quality of construction and construction QA/QC issues raised by additional sources; today the list includes, in addition to the TRT, these ASLB proceedings on the CPSES operating license ("ASLB"), the NRC Staff's Supplemental Safety Evaluation Reports ("SSER's") and its Construction Assessment Team (" CAT') and Special Investigation Team (" SIT") reports, certain Inspection Reports issued by NRC's Region IV ("RIV's"), and the Cygna Independent Assessment Program
("IAP"). (Collectively these are referred to in the CPRT Program plan as the " External Sources" and the specific issues they raise as the " External Source issues.") Thereafter, the charter was expanded again to include quality of design issues raised by the same external sources (or to which the CPRT might be lead in the source of investigating external source generated quality of construction issues). Finally, the charter was expanded to
include a mandate of assuring TUGCO management of the safety of the plant, regardless of the extent to which issues might have been raised by external sources.
At the same time the composition of CPRT has evolved.
Initially, a CPSES project effort with some input from third-l party experts, CPRT today is primarily a third-party effort in the sense that all evaluations are either performed by or overviewed by third-party experts.
As set forthiin the governing CPRT Program Plan, CPRT has been charged with responding to and resolving the TRT and ASLB issues and remaining open SSER, CAT, SIT, certain RIV and IAP issues, and with advising Applicants' management whether there is reasonable assurance that CPSES can be operated safety. To discharge this mission, the Program Plan sets forth three objectives.
irst, the CPRT WIll evaluate each of the specific External s
Source issues relating to either, quality of installed hardware or design adequacy. It will determine the nature of any safety significant deficiencies and the corrective actions necessary to resolve them. This component of the Program will. lead to reasonable assurance that there are no undetected and uncorrected 1 safety significant deficiencies associated with any of the External Source issues.,
Second, the CPRT will determine the root cause of each found safety significant deficiency (or trend of non-safety significant deviations) and analyze the generic implications of each root
< 1 s
i,
cause in order to determine the extent of any additional construction or design efforts that might be deficient for the same reasons. This component of the Program will lead to the conclusion that there is reasonable assurance that there are no undetected and uncorrected safety significant deficiencies associated with any of the same causes of any deficiencies found to be associated with the External Source issues.
It should be noted that these two components of the Program are complementary and each has the potential for expanding the other. The evaluation of root cause and generic implications may lead to additional areas of the construction or design process requiring evaluation, and the evaluation of found safety significant deficiencies (or trend of non-safety significant deviations) may lead to the establishment of additional root causes and potential generic implications. Similarly, the evaluation of specific deficiencies may lead to the expansion of programmatic issues and the evaluation of programmatic root causes may lead to the expansion of the review of specific hardware or design activities.
The sum of these two components will fully resolve each of the External Source issues and it will fully bound the safety significant implications of any identified or found deviation associated therewith. It will also permit the CPRT to make statements about the adequacy of the CPSES construction QA/QC program and the adequacy of the CPSES design.
As a third component, added for additional confidence, the CPRT will also conduct self-initiated evaluations of the quality of CPSES construction and the adequacy of CPSES design. In the construction area, this effort involves a sample reinspection of all of the construction activities and processes employed in the construction of the safety significant aspects of the plant. In the design area, this effort involves a detailed design review of such scope that, when completed and aggregated with the other design reviews conducted, the results will be extrapolatable to all of the design criteria, disciplines, processes, and organizations involved in the design of the safety significant aspects of the plant. This third component will permit the conclusions reached as a result of the first two components to be extended to the entirety of the safety significant plant and will lead to the conclusion that there are no undetected and uncorrected safety significant deficiencies at CPSES, regardless of the extent to which quality of construction or design adequacy may have been challenged by the External Source issues.
l l B. CPRT Structure The " governing body" of CPRT is the Senior Review Team l
l ("SRT") consisting of five members. The Chairman is Mr. John Beck, Vice President of TUGCO and the corporate officer charged with overall licensing responsibility. Mr. Beck joined TUGCO in April of 1984, having had significant experience in the design, construction, and operation of nuclear units in the~New England
area. The balance of the SRT members are senior third-party consultants whose specific credential.s will be described in the CPRT Program Plan. The primary function of the SRT is to set CPRT objectives and standards, see to it that the standards are met, and see to it that the persons executing the program have the expertise and resources necessary to the task.
Beneath the SRT are Review Teams also led by third parties, that perform the various required activities. The two largest (in terms of scope) are the Quality of Construction and Construction QA/QC Review Team and the Design Adequacy Review Team; in addition, there are a number of specific review teams constituted to deal with certain discrete TRT issues. Each review team is headed by a third-party review team leader whose responsibility is to see to the accomplishment of the review team objectives, subject only to the direction of the SRT. Where a review team's scope includes more than one issue, the issues are headed by issue coordinators who report to the review team leader.
The " constitution" of the CPRT is the CPRT Program Plan.
Appendices A and B to the Plan are the Quality of Construction and Construction QA/QC and the Design Adequacy Program Plans, respectively; other appendices contain the issue specific action l
l plans and certain implementing standards of generic implications (e.g., sampling procedures). The specific tasks to be accomplished are contained in the issue specific action plans l ("ISAP's"), which collectively comprise Appendix C to the program
l 1
l I
4 plan and in the discipline specific action plans (DSAP's) attached to the design adequacy program plan. In the TRT area there is one ISAP per TRT issue; in the QA/QC area the ISAP's are categorized as either issue-responsive or self-initiated; and in the Design Adequacy area the DSAP's are organized in accordance
- with the design disciplines involved.
C. Program Methodology
! 1. The Issue-Responsive ISAP's For the ISAP's that respond to specific External Source issues, the Program Plans describe and the ISAP's reveal a range of evaluative approaches. Selection of an approach depends on the nature of the specific issue being responded to. In general,
. however, the methodology will result in: identification of the issue in technical terms; identification of all deviations; and evaluation of the deviations for safety significance, leading to l an identification of deficiencies. Corrective action to resolve deficiencies will be determined. In addition, root cause will be
! established for all deficiencies that have a root cause, and the generic implications of all root causes will be determined.
As used in the CPRT Program Plan, the term " deviation" refers to a discrepancy between a found condition and either a drawing or specification (in the quality of construction area).
t
" Deficiency" refers to a deviation that, if uncorrected, would I
lead to the failure of a safety system or component to perform its intended function. (In making safety significance l determinations, no credit is taken for system redundancy.)
\ l One approach bears special mention, however: the Design Adequacy Program Plan (Appendix A to the CPRT Program Plan) ;
recognizes that it may be more efficient for a given design area !
l to be completely reanalyzed than it is to address specific issues. It also recognizes that proceeding directly to hardware modifications may be expedient and less costly than the analyses required to demonstrate conclusively either that the original hardware is qualified or that it is not. It has already been determined to employ this approach in the case of large bore piping and pipe supports, and TUGCO has retained the firm of Stone & Webster Engineering Corporation to perform a complete piping and pipe support reanalysis. The CPRT Design Adequacy Program's root cause and generic implications programs will insure that any generic implications for other design areas of any deficiencies in the original design process in this area will be captured, evaluated and corrected.
- 2. The self-initiated efforts The self-initiated effort in the quality of construction area is a sample re-inspection of essentially the entirety of the safety significant hardware in the plant. Population of hardware representing various types of construction activities will be determined, from which a random sample will be drawn from each population and another sample will be drawn from a subset of the population determined on an engineering basis to be more important to safety. The sample items will be inspected to
J criteria concurred in by the Design Adequacy Review Team and the analysis of any deviations for safety significance will be reviewed and concurred in by the Design Adequacy Review Team.
Both samples will be at the 95% confidence /95% conformance level.
Deviations constituting either safety significant deficiencies or trends of potentially adverse non-safety significant deviations will be evaluated by third party experts with SRT oversight for root cause and generic implications, and the potential generic implications will be pursued through a number of techniques including additional reinspections. The result of this work will be a global reassurance of no undetected safety significant hardware deficiencies; while the effort is undertaken primarily so that CPRT can provide assurance to TUGCO management, it will upon implementation resolve any issue that has been raised about the quality of CPSES construction.
The'self-initiated effort in the design adequacy area is similarly global. Here a complex four-step process is used to select a set of systems for detailed design review and then to confirm that the selected set (supplemented as necessary by other design reviews) envelopes all of the design processes, disciplines and organizations involved in the design of safety significant CPSES systems, structures and components.
- 3. CPRT records The Program Plan details the records and filing systems required to be maintained. When taken together with the Program
l Plan and the Results Reports, the effort will produce a result that is comprehensive, complete, and in auditable form.15/
- 4. Program interfaces Within the CPRT structure, the Program Plan calls for SRT oversight of all activities. Close contact is maintained between the Quality of Construction Review Team and the Design Adequacy Review Team. Each reviews the ISAP's and the results of the other to ensure that potential design issues uncovered during the QA/QC investigation are referred to the Design Adequacy Review Team and likewise the Design Adequacy Review Team findings in the QA/QC area vill be referred to those investigating QA/QC. The Design Adequacy Review Team reviews the determination of inspection criteria for the self-initiated QA/QC reinspections and in the evaluations of safety significance of found QA/QC deviations; this ensures that the criteria and evaluations are consistent with the design of the plant and with'any changes in design or design bases or margins that may evolve out of the Design Adequacy effort. The QA/QC Review Team performs any inspections requested by the Design Adequacy Review Team to ensure that all inspections are consistently performed and controlled and that they are all performed by qualified i
inspectors.
15/ Applicants are presently developing the means by which the Intervenor can, without first requesting formal discovery, and while the program is being implemented, have convenient access (in Dallas) to such records.
i
26 -
-There are numerous interfaces between the CPRT third-party )
l organizations and the CPSES project and its consultants. In the I first instance, the CPSES project assembles any records and documents required for CPRT evaluation, and provides support in the performance of inspections. Where the project is itself involved in the rework of the facility (such as in the case of those pipe supports the modification or replacement of which is currently underway), the CPRT maintains contact to ensure that l
l i
actual "as built" conditions are used in design reviews. Where the project or its direct consultants are involved in reanalysis and redesign work (such as in the pipe support area), the CPRT overviews the activities and must ultimately concur in the results reached.
D. Program Outputs Each ISAP and DSAP will produce a Results Report, which will at a minimum identify the found safety significant deficiencies, their resolution,ls/ any root cause(s) and generic implications and their resolution, and any recommendations for programmatic improvements to abate the potential for recurrence.
In both the quality of construction and design adequacy areas, the results of the various activities will then be collectively evaluated to ensure that no potentially safety significant trends implicit in the collective data, but not 11/ Specific procedures and requirements for closure of an issue are detailed in the action plans.
1 l
I l
apparent from the activity specific results, are not overlooked.
These collective evaluations will be separately reported in Collective Evaluation Reports.
Finally, in each of those areas a Summary Report will be prepared summarizing the results of the efforts and demonstrating the fulfillment of the objectives of the Program.
E.
Conclusion:
CPRT When it is completed, the CPRT effort will have addressed and resolved every issue that has been raised concerning Comanche Peak, including those now before this Board. The effort will present a fresh perspective that is competent and comprehensive.
It is the Applicants' intention that those portions of the CPRT end products that relate to issues before the Board will be offered into evidence. This proffer will cover, and we believe resolve, any issue which remains before the Board.
V. PLAN FOR SPECIFICATION AND RESOLUTION OF DOCKET 1 ISSUES A. Overview In order to resolve the quality assurance contention in this proceeding, any management plan must address two types of issues. First, there are the issues which have been previously identified in the proceeding and which remain pending. The status of these issues must be reevaluated in
light of the material developments of the TRT and the CPRT.17/
Second, there may be issues which spring from the Applicants' plan to verify quality by the CPRT. These issues, related to the programmatic implications of the pending issues in the proceeding, must first be specified by the Intervenors. In sum, the issues should now focus the proceeding upon the adequacy of the CPRT to resolve
- previously identified deficiencies, to address programmatic j implications, and to thereby provide the Board with the
- necessary reasonable assurance as to the integrity of the plant. To address both categories of issues, Applicants plan for this proceeding involves the following basic elements
- 1. Resolution of pending hearing issues previously identified by the Board,
- a. Many, if not all, of these issues are being addressed by the Applicants through the CPRT corrective action program.
Thus, for hearing purposes, resolution of the specific matter will necessarily be superseded by the CPRT program.
Any programmatic implications will be " folded" into the process described in point 2, below.
. b. Final resolution of specific l technical issues may involve L only minor procedural correc-tive measures. Confirmation of 17/ The Board's questions regarding implications for continued litigation are discussed in Section V.B., infra.
I l
implementation of such correc-tive measures may properly be l left to the Staff. !
- 2. Specification by the Board (based upon input from the Intervenor) of other TRT/CPRT issues that have a ,
direct bearing on Contention 5.
- a. On such specified issues, the Board must hear evidence in order to determine whether or not it can make the necessary
" reasonable assurance" determination. Ultimate resolution of some confirmatory matters may be left to Staff where appropriate.
- b. All matters with respect to the TRT and CPRT not so specified should remain solely within the purview of the Staff for resolution.
Several principles of law underlie the suggestions made by the Applicants in this plan. First, Applicants will address the question of its right to "relitigate" issues before this Board.
Second, Applicants recognize that in order for the Board to resolve the QA issue favorably, it must find " reasonable assurance" that the plant has been properly designed and built.
Third, a discussion of the respective roles of the Licensing Board and the NRC Staff in reviewing operating license applications is felt necessary.
B. Further Litigation of Outstanding Issues Concerning the implications of continued litigation,
in footnote 2 of its Memorandum of May 24, 1985, this Board stated:
The parties should address the implications of the Board's previous view that "We anticipate that the next round of hearings should be the last. At some point, prolongation of hearings would represent a denial of due process to one or.more of the parties. We encourage the parties to present their evidence and to prepare their required Proposed Findings with care, being sure to present a reasoned basis for the decision sought from the Board." LBP-84-10, 19 NRC 509 at 531 (1984)
One clear " implication" of the view taken in the context of that portion of the footnote quoted above is that no further hearings should be held unless and until everyone is fully ready.
Applicants certainly concur with this and believe that Applicants' Management Plan set forth herein, if adopted, will l provide the " reasoned basis" for decision sought by the Board.
However, the above-referenced footnote, did not end there.
This Board went on to say:
Note that we referred to " hearings" in that decision but that the Applicants' summary l_ disposition motions, filed pursuant to its Plan, were given the status of Written Filings, from which the Board was authorized to reach a determination without any formal hearings, unless the Board, in its discretion, chose to hold hearings. LBP-84-25, 19 NRC 1589, 1591 (1984).
As will be evident from this Management Plan, it is the Applicants' intention to withdraw its already-on-file motions for summary disposition regarding pipe support design upon a determination by the Board that the proper focus for resolution of the issues addressed by these motions is the reanalyses to be
performed by Stone & Webster, subject to CPRT oversight. It might be argued that the immediately above-quoted language implies that Applicants are required to " live or die" with the present motions regardless of such efforts as the CPRT may put j forth. Such an argument, however, is invalid.
It is important to focus on events described herein which have intervened since the issuance of the above-quoted and referenced orders in 1984: the NRC Technical Review Team, not even formed at the time Applicants presented their plan to
! respond to this Board's December 28, 1983 Memorandum and order (Quality Assurance for Design),18/ has conducted extensive J
l inspections and assessments of the quality of work at CPSES and has investigated numerous allegations that were unknown to the Applicants when such plan was presented. Cygna has since I directed Applicants' attention to issues which have implications for the adequacy of support designs, and the CPRT, formed originally to resolve TRT concerns, has now had its role considerably expanded to include resolution of outstanding design i issues.19/ All of these events bear upon some or all of the
- motions on file. Should any TRT finding or new allegation l (" newly discovered evidence") be submitted into evidence by any party, and we assume that some, at least, will be, the Applicants clearly must have the opportunity and right to respond thereto.
18/ LBP-83-81, 18 NRC 1410 (1983).
i
--19/ See discussion regarding adequacy of the record,Section III.B, supra, and discussion of the role of the TRT, l Section IV.A., supra.
I r
I
-.v.v.-_,-.., n , . - . _ . . , , . - - . -
, - - , _ _ . _ ,_ . _ , , _ ---..,n_--._ - - - , - . , ,. -
In addition,- clear and recent NRC precedent exists for consideration of reinspection and corrective action programs to supplement an existing record. See Section V.C., infra.
Furthermore, a perception that Applicants desire to relitigate discrete technical issues would be incorrect. In particularly, it is not the purpose of Applicants' Management Plan to introduce new evidence, in addition to that contained in its summary _ disposition motions, in order to challenge the Intervenor on those technical issues. The Management Plan -- and l the CPRT effort -- are predicated upon the philosophy of l
comprehensively examining issues and concerns, and assessing those matters collectively to provide assurance as to the quality
- of the plant and its design. An example of the philosophy is the complete reanalysis of Class 2 and 3 piping and pipe supports by l' Stone & Webster. Concerns regarding the existing design program
- raised by Messrs. Walsh and Doyle will be addressed concurrently with related concerns and findings raised by other sources (e.g.,
Cygna). The objective of the CPRT with respect to such concerns is to assure that their examination provides a comprehensive assessment of the adequacy of plant design. To the extent particular concerns are most effectively addressed by assuming l
their correctness (and either including them in new analyses or l
directing modifications), they will be so addressed. This, by no means, is another " bite at the apple".
! Even assuming, as cannot be properly done here, that the circumstances described above do not justify the presentation of
. _ , , _ _ _ , . . _ _ _ , , , . - . . - , _ _ , . . . ~
further proof, and prescinding from the question (discussed below) of whether such an approach would be in accordance with law, there would be, to borrow a phrase from this Board, "no sense to it." LBP-84-10, 19 NRC at 530. It is "not . . .
logical or proper to close down a multi-billion-dollar nuclear plant because of a deficiency of proof." Id. In point of fact extended hearings do nothing to cause an intervenor any recognized legal harm. The expense of continued Aitigation is not recognized as legal harm in NRC practice and certainly cannot constitute an invasion of a constitutionally protected due process right.
The only " dismissal with prejudice" recognized in NRC regulations is that permitted under 10 C.F.R 52.107(a) which l
permits a dismissal with prejudice of an application as to which a request for withdrawal has been made by the applicant. Even in that situation, the rule is that the dismissal should be with prejudice only where legal harm has been suffered by an I
intervenor. Philadelphia Electric Company (Fulton Generating Station, Units 1 and 2), ALAB-657, 14 NRC 967, 974 (1981). In that context it has been specifically held that the fact that a dismissal without prejudice might require an intervenor to engage in future litigation does not constitute harm.
That kind of harm -- the possibility of future litigation with its expenses and uncertainties
-- is precisely the consequences of any dismissal without prejudice. It does not provide a basis for departing from the usual rule that a dismissal should be without prejudice.
Puerto Rico Electric Power Authority (North Coast Nuclear Plant, Unit 1), ALAB-662, 14 NRC 1125, 1135 (1981).
Obviously, the Applicants have no intention of withdrawing this operating license application and thus the reach of 10 C.F.R. 52.107(a) is not an issue here. Moreover, because this is an operating license proceeding, the fact is there never can be a bar to the utility taking corrective measures in response to whatever concerns exist and "trying again", however, many times it takes. When the Atomic Energy Act of 1954 was enacted both the House and Senate stated, in commenting upon Section 185:.
Section 185 permits the Commission to issue construction permits to applicants for a production or utilization facility, describes the terms of the construction permit and requires the issuance of a license if the construction is carried out in accordance with the terms of the construction permit.
S. Rep. No. 1699 83d Cong., 2d Sess. at 28; H. Rep. No. 2181 83d Cong., 2d Sess, at 28 (emphasis added).
In short, once a utility satisfies the NRC that the plant has been built properly, the OL must issue. Indeed in an uncontested case, the application may on numerous occasions be found wanting by the Staff and the OL withheld until the fixes necessary to enable the Director to make the findings are made. Should the result be different simply because an intervenor and a hearing board are involved? To ask the question is to answer it. Indeed as the Byron Licensing Board observed in withholding l
authorization of an operating license in Commonwealth Edison Co.
(Byron Nuclear Power Station, Units 1 and 2), LBP-84-2, 19 NRC 36 (1984):
4 i-The Board withholds authorization for an operating license for the Byron Nuclear Station because of inadequacies in Applicants' quality assurance program. The application is therefore denied. It is not within our jurisdiction to foreclose further proceedings on the application . . .
i Id. at 278 (emphasis added).
In describing the reach of our order, we have avoided describing it as'res judicata or collateral estoppel with respect to quality assurance issues because neither concept, as ordinarily understood captures our intent.
Neither concept neatly fits the unusual 4 situation to be found in the continuum of a licensing proceeding with-many aspects. We do j not foreclose future proceedings on the
- quality assurance issue and have no l Jurisdiction to do so.
J Id. at 279-80 (emphasis added).
{
For all of these reasons, it is entirely appropris e and i
l indeed necessary that Applicants be fully afforded the I opportunity to address all concerns which have been raised which
. relate to Contention 5 so that Applicants can properly meet their burden of proof.
Reasonable Assurance C. The Board's Required Finding:
[ Under the Atomic Energy Act, 42 U.S.C. 55 2133(d) cnd 2232(a), and the Commission's regulations, 10 C.F.R. 5 50.57(a),
the Licensing Board must authorize issuance of an operating l,
l license for Comanche Peak if it finds, with respect to the issues in controversy, reasonable assurance that the facility can be operated without endangering the public health and safety, see Power Reactor Development Co. v. International Union, 367 U.S.
i
396, 407 (1961); Maine Yankee Atomic Power Co. (Maine Yankee Atomic Power Station), ALAB-161, 6 AEC 1003, 1004 (1973), aff'd sub nom., Citizens for Safe Power, Inc. v. NRC, 524 F.2d 1291 (D.C. Cir. 1975). As the Appeal Board observed in Union Electric Company (Callaway Plant, Unit 1), ALAB-740, 18 NRC 343, (1983),
reasonable assurance does not require a demonstration of error-free construction:
In any project even remotely approaching in magnitude and complexity the erection of a nuclear power plant, there inevitably will be some construction defects tied to quality assurance lapses. It would therefore be totally unreasonable to hinge the grant of an NRC operating license upon a demonstration of error-free construction. Nor is such a result mandated by either the Atomic Energy Act of 1954, as amended, or the Commission's implementing regulations. What they require is simply a finding of reasonable assurance that, as built, the facility can and will be operated without endangering the public health and safety. 42 U.S.C. SS 2133(d), 2232(a); 10 C.F.R. S 50.57(a)(3)(i).
ALAB-740, 18 NRC at 346.
The Appeal Board also addressed in ALAB-740 the standard governing litigation of QA contentions. The Appeal Board defined the scope of inquiry as first, whether "all ascertained 1
construction errors have been cured" and second, whether, despite the correction of construction errors, " legitimate doubt (is raised] as to the overall integrity of the facility and its safety-related structures and components." Callaway, ALAB-740, 18 NRC at 346; see also Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2), ALAB-756, 18 NRC 1340, 1345 (1983).
s NRC operating license proceedings focus on specific l allegations placed into issue by the parties. If those issues identify individual discrepancies, that when viewed overall, raise " legitimate doubt" with respect to "overall integrity of the facility", applicants must meet a burden of dispelling that doubt. However, it is obviously impractical to present evidence on the design and construction of every item in a nuclear power plant in order to satisfy the Callaway test.
In cases where, as here, the adequacy of the QA program has been hotly contested, it has been held that applicants may rely on various design and construction verification efforts in order to dispel any " doubt" as to the adequacy of the facility. See Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 &
2), ALAB-770, 19 NRC 1163-70, 19 NRC 1169-70 (1984) (holding that applicants could use evidence of various remedial programs to meet their burden of proof oa specific quality assurance issues).
Verification efforts " substitute for, and supplement" the QA program in order to provide the Board with reasonable assurance that the plant can operate safely. See Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 & 2), ALAB-763, 19 NRC 571, 576 (1984).
For example, in Byron, the Licensing Board was not satisfied with the evidence on several issues raised under the umbrella quality assurance contention. The Appeal Board specifically remanded the case to the Licensing Board in order to take evidence of remedial programs designed to address those matters l
l
1 and eliminate any programmatic doubts. Byron, ALAB-770, 19 NRC at 1175-79. In Diablo Canyon, individual design discrepancies placed the adequacy of an even larger portion of the design QA program into serious doubt. Under those circumstances, the Commission obtained sufficient confidence of adequate design based upon applicants' design verification effort and remedial program. The ultimate conclusion remained the same: in view of the issues in question, there existed reasonable assurance that the plant was properly designed and built. The Appeal Board wrote:
[W]e must independently determine whether the verification programs and their results placed before us in the reopened operating license proceeding are sufficient to verify the adequacy of the Diablo Canyon design. To do this, the applicants' efforts must be measured against the same standard as that set forth in the Commission's quality assurance criteria, 10 C.F.R. Part 50, Appendix B: whether the verification program provides " adequate confidence that a (safety-related] structure, system, or component will perform satisfactorily in service." If the applicant's verification efforts meet this standard, then there will be reasonable assurance with respect to the design of the Diablo Canyon facility that it can be operated without endangering the health and safety of the public.
ALAB-763, 19 NRC at 578.20/
~~20/ Applicants' counsel in that case acknowledged that there were deficiencies in design QA at Diablo Canyon. However, counsel further noted, and the Appeal Board agreed, there was "no sense in litigating" design QA. The issue for subsequent hearings was whether the proposed independent design verification program and corrective action l organization could reasonably assure the correctness of (Footnote 20 continued on next page)
l I
In sum, it is clear from Callaway, ALAB-740, that where the parties have placed individual QA discrepancies in issue, the Board must verify either that the claimed deficiency does not exist, or if it does, that appropriate corrective measures will be taken prior to operation.21/ In addition, the Board must assess whether it has sufficient confidence that, based on the QA program at the plant and the Applicants' remedial verification efforts, the plant has been properly designed and built.
D. The NRC Staff's Responsibilities A licensing board's review of an operating license application does not have the same scope as the NRC Staff's review of the application. The licensing board must, prior to authorizing issuance of a license, resolve issues placed in controversy between the parties, pursuant to 10 C.F.R. 5 2.714(a). Wisconsin Electric Power Co. (Point Beach Nuclear Plant, Unit 2), CL1-73-4, 6 AEC 6,7 (1973). In addition, the Board may raise and resolve new issues sua sponte, pursuant to 10 C.F.R. 5 2.760a, upon making the requisite findings of serious safety significance. See, e.g., Texas Utilities Generating Co.
(Comanche Peak Steam Electric Station, Units 1 & 2), CLI-81-36, (Footnote 20 continued from previous page) the Diablo Canyon design. Order (unpublished), at 5-6 (August 16, 1983).
--21/ The extent to which the Board may leave for Staff confirmation the satisfactory completion of corrective
- measures with respect to issues in controversy in this I proceeding is discussed in Section V.D., infra.
l 14 NRC lill, 1113 (1981). The Board, however, is simply not l endowed with the resources or the expertise to replace the large body of Staff experts dedicated to protecting public health and safety through inspections and safety evaluations. The Appeal !
Board has noted that "an operating license board is neither required nor expected to pass upon all the terms which the staff
- must consider and resolve before it approves a license."
I Consolidated Edison Co. of New York, Inc. (Indian Point, Units 1, 2, & 3), ALAB-319, 3 NRC 188, 190 (1976); see also Cincinnati Gas and Electric Co. (William H. Zimmer Nuclear Power Station, Unit l
i 1), CLI-82-20, 16 NRC 109, 114 (1982) (additional views of J
Commissioners Ahearne and Roberts).
l l- Moreover, many confirmatory or procedural aspects of contested hearing issues may properly be left to the.NRC Staff for resolution outside of the hearing process. It is clearly '
established that an issue may be delegated to the Staff if the material questions in controversy can be resolved based on the l
l existing record, and the remaining matter can be resolved by the Staff without an exercise of discretion. See, e.g., Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-83-57, 18 NRC 445, 519 (1983), aff'd, ALAB-788, 20 NRC 1102, 1171 (1984). Specifically, confirmatory analyses, tests, inspections, and the like may be relegated to disposition by the NRC Staff outside of the hearing context. See, e.g., Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit 1), ALAB-729, 17 NRC 814, 885-87 (1983). These confirmatory review matters to be
-.-m-e---, s e- -
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l l l undertaken by the Staff involve no decisional responsibility, and l
l would merely serve to verify the conclusion arrived at by the l
l Board based upon the evidence of record. If events do not turn l
out as expected, the Staff will be well aware and is obliged to
! assure that appropriate action is taken.
E. Status of Issues We believe that the Board's current responsibility in this proceeding is to evaluate the status of issues in the proceeding in light of the developments of the TRT and the plans for the CPRT. Clearly issues which are moot should be left behind, and the focus of the litigation shifted to address areas now relevant to the Board's required findings. Generally, "a case is moot when the issues are no longer ' live' . . . ." Powell v.
McCormack, 395 U.S. 486 (1969). The Commission (and, by extension, the Board) may, in its discretion, invoke the mootness doctrine and refuse to address issues that have been mooted by subsequent events. See Local 8-6, Oil, Chemical & Atomic Workers
- v. Missouri, 361 U.S. 363, 368 (1960); Alton & Southern Railway Co. v. International Association of Machinists & Aerospace Workers, 463 F.2d 877 (D.C. Cir. 1972); Puerto Rico Electric Power Authority (North Coast Nuclear Plant, Unit 1) ALAB-605, 12 NRC 153 (1980). In essence, the Board may, in the sound exercise e
of its discretion, decline to decide factual and legal issues if the decision is unnecessary to its ultimate resolution of the proceeding, and in particular if a given issue or issue has been i
l _
overtaken by subsequent events.22/ The Appeal Board has held that such discretion is inherent to the authority of an NRC l
adjudicatory board. North Coast, supra, ALAB-605. In this respect, the mootness doctrine closely relates to the Board's exercise of "its administrative discretion'in deciding how . . .
it may best proceed to develop the needed evidence and how its prior decision should be modified in light of such evidence as develops." FPC v. Transcontinental Gas Pipe Line Corp., 423 U.S.
326, 333 (1976). Accord, Vermont Yankee Nuclear Power Corp. v.
NRDC, 435 U.S. 591, 543-44 (1978).
In this case, as in Byron, Applicants intend to demonstrate, based upon the QA program and subsequent trification efforts, that there is reasonable assurance that C .nanche Peak has been l
l correctly designed and built. To paraphr.se the Appeal Board in Diablo Canyon, ALAB-763, the rea'l issue in this proceeding therefore has moved beyond the question of what specific QA lapses or construction deficiencies may have existed at Comanche Peak. The issue now is whether Applicants can demonstrate that its QA program, supplemented by the CPRT results, assures that all construction errors found are correct <_d and confirms the adequacy of the plant. See Diablo Canyor., ALAB-763, 19 NRC at 576.
--22/ See, e.g., Public Service co. of Oklahoma (Black Fox Station, Units 1 and 2), ALAB-723, 17 NRC 555, 556 (1983);
Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), ALAB-697, 16 NRC 1265, 1269 (1982).
For purposes of this proceeding the relevant inquiry has 1
moved to the second prong of the Callaway standard: the Board must consider.the overall effectiveness of the QA program and Applicants' remedial verification efforts, in light of the specific problems and concerns previously identified. Following the model provided by Byron, ALAB-770, this Licensing Board must hear evidence on the CPRT efforts in order to determine whether those efforts, in conjunction with the QA program, provide reasonable assurance as to the adequacy of design and construction of Comanche Peak.
F. Specification of Issues As in Byron, Applicants are entitled to present evidence from the CPRT in order to meet their burden of proof (i.e., of l demonstrating " reasonable assurance") and to respond to any evidence offered on TRT findings. Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 & 2), ALAB-770, 19 NRC 1163, 1169-l 70 (1984). The principal focus of this proceeding should now l
become the adequacy of those remedial efforts.
The Appeal Board in Diablo Canyon required Intervenors to submit specific contentions regarding the verification efforts, asserting how those efforts were insufficient to provide the required reasonable assurance. See Diablo Canyon, Order (unpublished) (July 6, 1983). The Appeal Board wrote that, although 10 C.F.R. 5 2.714(b) did not apply to the reopened proceeding, specification of issues was necessary "both as a
+ ,.
matter of our management to ensure the proceeding remains closely focused as well as a matter of fairness to the applicant in preparing its case." Diablo Canyon, Order (unpublished), at 6-7 (August 16, 1983).23/ After Intervenors proposed issues, the Appeal Board explicitly ruled on admissibility of each proposed issue by deciding whether the issue was adequately particularized and supported by "the critical facts upon which [intervenors]
base their claims." Diablo Canyon, Order (unpublished), at 2
( Abgus't - 26, 1983). The Appeal Board thus played an active role in specifying and focusing proposed iss'ues by rejecting or requiring redrafting of any issue not properly drafted. Id. at 2-3.
Applicants submit that a similar procedure should be followed l ,
! in this proceeding. Applicants begin the, process in Section G
. below by discussing the status of pending issues in this ,
i proceeding and how'those issues are being addressed by the CPRT.
In light of this discussion, Intervenors shou'ld submit a list alleging, with basis and specificity, its specific charges for further proceedings. The list should assert those specific
< aspects of the CPRT which Intervenors wish to challenge as being insufficient to provide the Board with adequate confidence.
Specifically, Intervenors should either reframe pending issues to challenge the manner in which the CPPT program is claimed to be insufficient to address a specific unresolved deficiency 23/ The specific issues admitte'd for hearing by the Appeal Board are listed in Appendix A to ALAB-763. See Diablo Canyon, ALAB-763, 19 NRC at 621.
-- w-,-um >r-w=-*- tw'+ - r- -rt-m-w- +-31 - -- r-~~r-y g 4 - -'-'-,w-w ey y ~ - -
<mey
l previously in issue, or otherwise assert how that program is insufficient to address the implications of those previously identified deficiencies.
As in Diablo Canyon, refocusing of existing issues (or specification of new issues arising out of the CPRT plan to -
address implications of existing issues) is necessary both as a matter of case management and for procedural fairness to the Applicants. First, by following this procedure the Board can assure that the remaining hearings focus upon matters related to its required determination, i.e., whether the remedial measures dispel legitimate doubt as to the overall integrity of the facility. Second, by specifying issues the Board can assure that remaining hearings focus on issues placed into controversy by the parties. Third, this procedure lends itself to expeditious consideration of Intervenors' objections by Applicants. For example, if specific objections are presented by Intervenors, such objections would be susceptible to stipulation or other resolution without hearing. Finally, the sooner specific concerns are identified, Applicants can more readily address those concerns by specifically including them within the scope of the CPRT efforts at an early stage.
G. Plan for Resolution of Pending Issues As discussed above, in order to make the requisite finding (pursuant to the Atomic Energy Act and Commission regulations) that with respect to the issues in controversy there is l
l
reasonable assurance thatiComanche Peak can be operated safely, the! Board must first find that "all ascertained construction errors have been cured." Callaway, ALAB-740, 18 NRC at 346.24/
In this proceeding there are several sources of specific concerns which could be indicative of deficiencies in the quality assurance program which warrant or may warrant Board findings that corrective measures have been taken in accordance with the above standard. Specifically, the set of issues which remains unresolved from the Board's March 15, 1984 Memorandum 3
(Clarification of Open Issues), some of the related individual findings made by the TRT, and the results of the Cygna review constitute the scopb of matters as to which Board findings may be i c
' required. ,With respect to the unresolved, previously-admitted issues,, Applicants set forth below the particular issues and the i
m,ethod by which we propose each issue be resolved. Regarding the TRT findings and the Cygna review, Applicants also address below their status in this proceeding. <
l l
- 1. Unresolved Issues There are several issues identified by the Board in the March 15, 1984 Memorandum as to which there has been no ultimate i
24/ This determinati.on is separate from the evaluation of the implications of any errors which may be tied to deficiencies in the quality assurance program. That latter determination focuses on the question of whether there is adequate confidence "as to the overall integrity of the facility and its safety-related structures ard comp'on'ents." -Id. That inquiry is addressed in the context of the CPRT and the issues specified with respect to that effort, as discussed in the preceding.section. .
.._ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _L__._
i disposition. Many of these issues have since been addressed by Applicants in submittals to the Board. In addition, some of these issues were also considered by the TRT and are being addressed by Applicants in their response to the TRT findings.
Other issues have been incorporated in the CPRT efforts, independently of whether the matter was also reviewed by the TRT.
In order to resolve these issues, there must be a determination a~s to whether the present record is adequate.to reach a decision with respect to each issue or, alternatively, whether Applicants' actions in connection with the CPRT program are adequate by themselves (effectively rendering consideration of previous submittals unnecessary) to resolve the issue.
Applicants set forth below their recommendations as to how each issue should be resolved. When the CPRT Program and action plans are filed, Applicants will provide to the Board and parties a chart which identifies each issue, its relation to a TRT concern, and specifically where the CPRT plan addresses it. We preliminarily include below pertinent references to the SSER's and the CPRT ISAP's.
- a. welding issues There are two issues which remain open with respect to the welding allegations litigated in this proceeding. These concern the adequacy of Applicants' practice with respect to the docu-mentation of repairs to misdrilled holes and the adequacy of Applicants' practice regarding preheating material to be welded.
In both instances, the Board has indicated that ongoing Staff reviews of these matners would be considered.25/ The result of Staff's further investigation of the practice relating to welding of misdrilled holes is set forth in SSER 10. Therein the Staff requests that Applicants modify a'previously submitted plan to address this issue (SSER 10 at N-18). The preheat issue is to be
! addressed in a later SSER (see SSER 10 at N-34). Welding issues raised by the TRT are being addressed by the CPRT (see, e.g.,
ISAP's V.d., VII.c.).
Applicants propose that further consideration, if any, of these issues focus exclusively on the adequacy of the applicable CPRT actions. Consistent with the procedure discussed above for identifying future issues in the proceeding, the intervenor should specify whether, and if so in what respect and on what basis, it considers those actions to be inadequate to resolve the above issues. Absent identification of a specific issue regarding Applicants' program the Board should close the record on these issues.
- b. protective coatings The Board resolved several protective coatings issues in its initial decisions. Applicants submitted motions for summary disposition as to the few specific technical issues which remained open. The Board deferred action on these motions in an 25/ Memorandum (Concerning Welding Issues), LBP-84-55, 20 NRC 1646, 1690 (1984).
l October 10, 1984, Memorandum,26/ indicating that it would await '
the issuance of the final report by the Brookhaven consultants hired by the Staff to review Applicants' coatings program. In addition, other technical concerns regarding coatings were collaterally raised in Docket 2. The NRC Staff subsequently issued SSER 9, presenting the Staff's report regarding its investigation of the allegations originally investigated by Brookhaven and the results of a staff evaluation of the safety classification of protective coatings.
In SSER 9, the Staff concluded that "a total failure of protective coatings inside the containment building would not adversely affect the perform ace of post-accident fluid systems" (SSER 9, p. 1-1). According /, the SSER concluded that it was appropriate to declassify th protective coatings, and that technical problems with coatings lack safety significance.(id.):
[A]ny deficiencies which might result in coating failures would not result in or contribute to causing, or increasing the consequences of, any design basis accident; for this reason, it is not necessary that coatings be qualified.
From the above, it is clear that all technical issues regarding protective coatings now reflected in this record are moot. As the SSER notes with respect to each of the technical allegations that it examined, none of the substantiated l
l I
~~26/ By Memorandum issued October 10, 1984 (Memorandum (CASE's j Motion Regarding J.J. Lipinsky)), the Board deferred I action on coatings issues pending issuance of the TRT l report on coatings allegations.
l
deficiencies in documentation or hardware has any safety significance. Given the declassification of coatings, the following technical issues, identified in both dockets, are moot:
Paint quality and programmatic issues identified in Lipinsky Trip Report. The merits of the Lipinsky issues are also addressed in Applicants' motions for summary disposition, filed on September 28, 1984, in Docket 1. Applicants will withdraw that motion upon a determination of mootness.
Qualification of reactor core cavity coatings. Aside from approving the dequalification of all coatings, the TRT also approved Applicants' basis for disposition of NCR-C-83-00461, which stated that these coatings would not affect the operation of post-LOCA fluid systems. The TRT " concurred with this reasoning and confirmed it by an examination of the reactor core cavity. Because of the physical configuration of the reactor core cavity and its location in the plant, failed and flaked-off coatings would not flow out of this area during a LOCA" (SSER 9,
- p. M-61). This issue is thus moot.
Use of cigarette filters in spray guns. The TRT concluded that this practice lacked safety significance: "The TRT considers that the procedures provide generally acceptable methods for a properly trained inspector to identify and verify correction of such defects in the applied coating which might result from the use of inadequately clean compressed air" (SSER 9, p. M-95).
l l
l i
Use of detergent to clean coated surfaces. The TRT concluded that this practice lacked safety significance: "The TRT reviewed the cortents of the disinfectant, and determined that it was a detergent which would have no adverse effect upon the finish coat if the coating was thoroughly rinsed after its use. The TRT found no fault with the governing procedures or with the i
l disposition of NCR-C-83-01694" (SSER 9, p. M-87).
Maximum roughness of surface profile. Applicants submitted a motion (June 25, 1984) for summary disposition of the allegation that industry standards and the Comanche Peak specification require a 3 mil maximum surface profile, but that the procedures did not specify such a maximum profile. The TRT did not evaluate the allegation. The issue is moot in light of coatings declassification, and Applicants will withdraw the motion upon a determination of mootness.
Coatings on Westinghouse components. Applicants submitted a motion (September 5, 1984) for summary disposition of the allegation that coatings on Westinghouse components inside containment lacked integrity. The TRT did not evaluate the allegation. In light of the TRT finding that the failure of all coatings inside containment would have no safety significance, the issue is moot. Applicants will withdraw the motion upon a determination of mootness.
Near-white blast. Applicants submitted a motion (May 14, 1984) for summary disposition of an allegation that for a three-month period during late 1982, Comanche Peak procedures did not
\
include a requirement that steel substrate surfaces be cleaned to a "near white blast" condition. The TRT did not evaluate this issue. In light of the declassification finding, the issue is moot, and Applicants will withdraw their motion upon a determination of mootness.
- c. records / document control The Board posed several questions with respect to the document control program at Comanche Peak in its January 30, 1984, Memorandum (Records Retrieval). The Board's concerns involved specific questions relating to the adequacy of Applicants' system for utilizing " deficiency records" (Memorandum (Records Retrieval) at 1). The Board's concern also extended to " design-deficiency" documentation (Memorandum (Records Retrieval) at 5). Applicants submitted a response to those questions in a report filed on June 29, 1984. There has been no Board action on Applicants' response.
A significant portion of the TRT investigation necessarily involved the review of Applicants' documentation practices in the many areas reviewed. The TRT also specifically examined Applicants' document control program, including " design-deficiency" documentation (see, e.g., SSER 11, Category 2, p. 0-45 et seq.). These findings and their implication for other areas, will be addressed by the CPRT (see, e.g., ISAP Items VII.a.2, VII.a.3.). In addition, to the extent TRT findings address other documentation practices, Applicants' CPRT response will also address those findings and their implications.
l Applicants submit that the review of documentation activities through the TRT, and the CPRT, has been and will be more comprehensive than the relatively narrowly focused questions of the Board- . -Applicants propose, therefore, that further consideration of this topic relate to the adequacy of the CPRT l
s program to identify and resolve issues previously raised regarding documentation. Specific issues with respect to those activities should be identified in accordance with the procedures discussed above. Absent identification of specific issues relating to Applicants' program, the Board should close the record on these issues.
l
- d. polar crane shims The Board requested in its March 15, 1984 Memorandum (at 6) that Applicants provide to CASE information relating to the evaluation of the shims for the polar crane rail. The Board added that whether it pursued the issue further would depend on whether CASE presented an affidavit presenting a genuine issue of material fact. Applicants submitted the requested information on April 9, 1984. CASE has not presented any pleading in response to Applicants filing, as required by the Board. CASE's failure to submit a response to the Board constitutes a waiver of the
1 l
- i issue.27/ Accordingly, Applicants submit that this issue should be closed.28/
- e. oversight of CB&I and NPSI activities In its Memorandum (Clarification of Open Issues), the Board left open (at 12-13) the implications of two NRC inspection reports which concerned Applicants' oversight activities of two vendors, Chicago Bridge & Iron and NPSI.29/ The TRT also examined allegations regarding the adequacy of welds on vendor supplied restraints (see SSER 10, Mechani' cal and Piping Category 47; SSER 11 QA/QC Category 7, AQ-20). The CPRT will address TRT findings and their implications. Further consideration of this topic should, therefore, focus on the CPRT plan and be conducted, if at all, in'accordance with the procedures described 27/ In effect the Board placed a burden of going forward on this issue on the Intervenor. A failure to meet that burden should result in waiver or default of the issue.
See, e.g., Detroit Edison Company (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-709, 17 NRC 17 (1983) (a failure to file proposed findings when directed to do so l
constitutes a default); Pacific Gas & Electric Company
! (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-
! 781, 20 NRC 819 (1984) (exceptions to an initial decision that are not briefed on appeal are deemed waived).
28/ Applicants note that the TRT also investigated allegations regarding the polar crane shims and the CPRT will, of course, be addressing the TRT findings (see ISAP VI.6.).
~~29/ Applicants also submitted, in response to informal requests by the Board, information relating to the disposition of weld defects on the " George Washington Bridge," a pipe restraint fabricated by Chicago Bridge &
Iron (see Applicants' letters of April 16 and June 28, 1984). The Board has not indicated whether further information was needed to answer its questions.
.- - _ - ~ - _ _ _._ . _
previously. Absent identification of specific issues, the Board should close the record on these issues.
- f. traceability of materials In its Memorandum (Clarification of Open Issues) the Board requested (at 10-11) that Applicants submit affidavits regarding an allegation concerning " reverse classification" of materials.
Applicants filed the requested information on April 12, 1984; The Board also stated in its Memorandum that CASE may pursue this topic further (by an additional filing or request for limited discovery), if it wished to demonstrate that there was a specific allegation which warranted Board consideration. CASE never filed such a document. In view of CASE's failure to pursue this the Board should declare that further consideration of the issue has been vaived.30/
- g. walkdown reinspections The Board left open in its Memorandum (Clarification of Open Issues) (at 9, 19) consideration of the Staff final walkdown inspections in connection with an issue arising in the CAT Report concerning undocumented removal of cable trays. The Staff's and CPRT inspections of the plant in connection with the TRT review are more comprehensive than would have been involved in the
~~30/ Applicants note that the TRT reviewed allegations regarding material traceability in SSER 10 (Mechanical and Piping Category 33) and SSER 11 (QA/QC Category SE). The CPRT will also address such TRT findings and their implications (see, e.g., ISAP Item VII.a.1).
Staff's walkdowns. Applicants submit that nothing would be gained by further pursuing the walkdown issue.
- h. unqualified QA/QC supervisory personnel The Board left open two concerns regarding the qualification of QA/QC supervisory personnel in its Memorandum (Clarification of Open Issues) (at 12). The TRT evaluated the qualifications of QA/QC personnel (see, e.g., SSER 7 (Electrical Instrumentation Category 6); SSER 11 (QA/QC Categories 4 and 7)). Applicants will respond to the TRT findings through the CPRT (see, e.g.,
ISAP Item I.d.1). Applicants submit that further pursuit of this issue should fos us on the CPRT program and, to the extent demonstrated re evant, Applicants' changes in management.
Accordingly, th Board should declare that further pursuit of the topic be conducted in accordance with the procedures described above.
- i. component modification cards This matter, which concerns the incorporation of component modification cards into design documentation, was identified as an open issue from the CAT report in the Board's Memorandum (Clarification of Open Issues) (at 15). As previously discussed (see item c, supra), the TRT evaluated the document control processes with respect to design change documentation.
Applicants will be addressing those findings through the CPRT.
Accordingly, further consideration, if any, of this topic should
focus on the CPRT effort and be conducted in accordance with the procedures described above. .
- j. reactor vessel mirror snield This topic was left open by the Board in its Memorandum (Clarification of Open Issues) (at 17), pending receipt of the Staff's response to a Board inquiry. This topic has now been addressed by the TRT (see SSER 8, Misc. Category 2) and will be evaluated by Applicants in the CPRT review (see ISAP Item VI.a.).
Accordingly, further consideration, if any, of this topic should focus on the CPRT effort and be conducted in accordance with the procedures described above.
- 2. TRT Findings Applicants address below the status in this proceeding of individual allegations investigated by the TRT.
It is neither appropriate nor practical for the Board to re-review each of the allegations investigated by the TRT. As a practical matter, a licensing board simply does not have the resources or expertise to re-investigate each of those allegations. See Zimmer, supra, CLI-82-20, 16 NRC at 114.
Clearly, the expertise and capability to assure that specific deficiencies identified in investigating individual allegations are appropriately corrected rests with the NRC Staff.31/
~~31/ See also Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2), ALAB-678, 15 NRC 1400, 1420 at n.36 (1982).
In short, the Board should not pursue independently individual allegations investigated by the TRT. This is not to say, however, that the TRT findings and Applicants' responses may i
not be considered. In the context of determining the adequacy of
, the CPRT assessment of the generic inplications of previously l
l raised matters, the TRT findings and CPRT's resolution thereof is appropriately considered. This would facilitate the Board's addressing the ultimate " reasonable assurance" determination.
Identification of specific issues relevant to this inquiry should follow the procedures discussed previously.
- 3. Cygna Independent Reviews The results of the independent reviews conducted by Cygna remain open for consideration in this proceeding. Phases 1 and 2 of the Cygna review, performed at the request of the NRC Staff, were partially litigated in several hearing sessions in February, April, and May, 1984. Yet to be presented are the Staff's and Applicants' positions on that review. Cygna's review in Phases 3 and 4 was initiated by Applicants in connection with their Plan to resolve design-related allegations. Neither phase has been litigated. The Phase 3 report has been issued. There remain, however, several open issues from each phase of Cygna's review.
These issues were listed by Cygna in their Review Issues List, transmitted by letter dated April 23, 1985.
In order to respond to the questions and concerns related to i
design, including those raised by Cygna, Applicants have included
s within the scope of the CPRT a plan to address design issues.
This plan, the CPRT Design Adequacy Program, will address the Cygna findings. Further, Applicants will ask Cygna to express its view as to whether or not the CPRT design adequacy plans, if properly implemented, will satisfy any unresolved concerns which it has. The principal focus of this proceeding with respect to the Cygna review should, therefore, be the adequacy of Applicants' plan to resolve issues raised by Cygna. Specific issues regarding Applicants' response to the Cygna review should be specified in accordance with the procedures described previously.
- 4. Pipe Support Design Applicants filed sixteen motions for summary disposition relating to specific allegations regarding pipe support designs and the quality assurance program for piping and cupport design.
The intervenor responded to each of the motions. Although the Staff formally responded to only one motion, it has met several times with Applicants and the intervenor to discuss its position on the motions. In view of the numerous questions posed by the Staff and intervenor with respect to the motions, and additional findings by Cygna relating to aspects of piping and support design, Applicants have established a program to address comprehensively all outstanding questions. This comprehensive program, which includes a complete reanalysis of class 2 and 3 large bore and piping and supports, will effectively moot
Applicants' motions. Consequently, Applicants intend upon a determination of mootness to withdraw those motions. Any future examination of the adequacy of piping and support designs should properly focus on the CPRT Design Adequacy Program. Questions relating to the sufficiency of that program to assure that piping and supports have been adequately designed should be presented in accordance with the procedures described previously.
VI. PLAN FOR FURTHER PROCEEDING IN DOCKET 2 Hearings in Dot.xet 2 commenced with evidentiary depositions in July, 1984, anc. were discontinued in January, 1985, at Applicants' request. Approximately 13 witnesses have testified for Intervenor, numerous witnesses have testified for Applicants (several more than once), and the Board has called several additional witnesses. Numerous documents have been admitted into evidence, and tens of thousands of pages of additional documents have been produced by the parties in response to discovery requests.
In its current state, the record reflects two distinct categories of issues. The parties and Board have generally described the first issue as whether a pervasive atmosphere of harassment, intimidation, or threats of and against QC inspectors existed at Comanche Peak during all or a part of the period during which the plant was constructed. The Intervenor apparently hoped to prevail on one or both of two theories: that harassment or intimidation of QC Inspectors was so pervasive that
l the quality of the hardware is in question, or that facts in the record reflected such a lack of management commitment to quality that Applicants may not rely on an effective, functioning QA program under Appendix B to provide the requisite public health and safety assurance.
The second category of issues ('many of which have been addressed over Applicants' objection and all of which are collateral at best to testimony of a particular claim of harassment) includes discrete technical allegations raised by witnesses called by Intervenor or the Board. By " technical," we mean allegations of deficiency in hardware or in documentation.
, Technical allegations regarding the following appear in the record:
o Protective coatings o Liner plate documentation o Stanford /Neumeyer NCR o Startup Test Engineering o Valve Discs The NRC Staff's Technical Review Team examined virtually all, if not all, of the technical allegations raised by witnesses in this docket.32/ The TRT's findings are reported in Supplemental Safety Evaluation Reports 7 through 11. As further discussed 32/
-~ In addition, the Staff established a panel of senior Staff personnel to review the record in Docket 2, including the report of the Staff's consultant (EG&G), and to formulate the Staff's position on whether a pervasive atmosphere of harassment existed.
62 -
below, the TRT findings and, most importantly, Applicants' proposed responses to those findings, form the principal bases for Applicants' suggestion of mootness in this docket.
In Applicants' view, the Board consideration of the record in light of the foregoing principles should cause it to declare issues currently presented in this proceeding moot.
A. Issues Presented In.
Docket 2 Are Moot 1
As noted above, the record reflects two distinct cate-gories of issues. One category consists of the identifica-tion of various technical issues; the second relates to the actual subject-matter of the Docket 2 hearings, i.e.,
whether a climate of harassment or intimidation existed at Comanche Peak such that quality control inspectors did not perform their jobs. Intervenors have approached the second of these issues without regard to the existence -- or non-existence -- of defects in documentation or hardware.
For the reasons that follow, Docket 2 is moot in its l
entirety.33/ Technical issues identified in Docket 2 will be addressed by Applicants' CPRT efforts, and in any event, properly belong in and will be resolved in Docket 1. As to 33/ Although we suggest that all issues in Docket 2 are now rendered moot or irrelevant, such suggestion should by no means be interpreted as suggesting that Applicants believe that there is any merit whatever in the claims of the Intervenor therein. The record to date, we believe, clearly demonstrates that there existed no pervasive climate or atmosphere of harassment or intimidation of quality control inspectors at Comanche Peak.
the principal issue, any documentation or hardware defects that could have been caused by harassment or intimidation of QC inspectors -- assuming that it took place at all -- will also be addressed by the CPRT efforts.
Should the Board continue to litigate this issue to conclusion and conclude in Intervenor's favor (an assumption made solely for the purposes of determining mootness), the consequence of such a finding would be to bring into question the state of the hardware at the plant. The question would then be whether Applicants can show, by reinspection, verification, and, as necessary, corrective ac ion, that they have constructed Comanche Peak correctly.
Th Commission itself endorsed such a concept respecting the Di blo Canyon plant; as described by the Appeal Board:
[W]e would take our lead from the Commission and permit the applicant's various verifica-tion efforts "to substitute for, and supple-ment, the applicant's design quality assurance program in order to demonstrate that the Diablo Canyon plant is correctly designed."
ALAB-763, 19 NRC at 576, quoting Commission Order of August 16, l 1983 (unpublished), at 5.
Thus, to further devote the resources of the Board and the parties to the general issue of harassment and intimidation would be fruitless. Applicants, as described above, have already initiated a comprehensive reinspection, verification and corrective action program which fully addresses the quality of hardware and plant design. Applicants' reinspection program will nc provide the basis on which the Board may judge plant quality.
As the Appeal Board observed in Diablo Canyon:
[T]he real issue * *
- has, in effect, moved beyond the question of what deficiencies existed in the applicant's Diablo Canyon design quality assurance program to the question whether the applicant can demonstrate that (its verification efforts] verify the correctness of the Diablo Canyon design.
ALAB-763, 19 NRC at 576, quoting Commission Order of August 16, 1983 (unpublished), at 6.
B. Management Commitment to Quality The same reasoning applies equally to the question of management's commitment to quality. The ultimate question is the potential effect on the plant if any such attitudes are assumed
< to have existed. That question will be fully resolved through the comprehensive CPRT efforts. In addition, substantial changes in personnel have been implemented, as discussed under current Management Views, supra. One consequence of such changes is that this Board can be assured that even if any attitudinal deficiencies are considered to have existed, historically, they are no longer relevant to any finding required of this Board.
C. Docket 2 Technical Issues For various reasons, Applicants believe that all technical issues identified in Docket 2 are moot or otherwise irrelevant.34/
- 1. Liner Plate Travelers t
34/
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Protective coatings issues that arose in Docket 2 are addressed earlier in this submittal (see Section.V.G.1.b.,
supra).
The parties adduced testimony and evidence regarding docu-mentation deficiencies for welds on the liner plate for the Unit 2 reactor refueling cavity and the transfer canal. Applicants presented testimony that, because these welds are designed, literally, only to hold water and are not structural welds, they are not safety-related and need not have been subjected to Category 1 QA/QC requirements in the first place.
! In SSER 10, the TRT agreed that the liner plate is not i safety-related (p. N-282):
1 The liners for the spent fuel pools, transfer canal, and reactor refueling cavities are not required to be seismic category I because damage or loss of the plate would not result in a significant loss of water since the concrete cavity structure would withstand the effects of a safe shutdown earthquake without significant damage. The primary purpose of the plate is to provide a smoother and less permeable surface which is easy to decontaminate; and also provide a construction form for the cavity. The liners do not provide any structural integrity to the concrete structure. Therefore, the concrete structure is the only concern from a seismic standpoint and not the liner plate.
Despite the fact that neither the Commission's regulations nor the ASME Boiler and Pressure Vessel Code mandate any requirements for liner plate, a footnote to the Comanche Peak FSAR and a provision of the plant specification impose Appendix B requirements on the fabrication and installation of the liners (see SSER 10, p. N-272). Accordingly, the TRT also examined the liner plate documentation for deficiencies. In SSER 11, TRT l l
concluded that there are deficiencies in the documentation, ;
principally in the travelers (SSER 11, p. 0-206):
s The TRT concludes that there are record anomalies apparent in the liner plate travelers which are not adequately explained on the face of the travelers (e.g., date changes), which violate procedures (e.g.,
failure of transfer sign-off from chits to travelers daily), and which employ inadequate procedures (i.e., confusion over the use of the five-line traveler).
The TRT attributed these defects to " poor practices and inadequate inspection forras" (SSER 11, p. 0-205), phenomena that Applicants have acknowledged in testimony before the Board. The TRT concluded that (SSER 11, p. 0-206):
The QC documentation relating to the liner plate welds did not meet the standards expected of an effective QA/QC program, or the standards required by Gibbs & Hill specification 2323-SS-18, and 10 C.F.R. 50 Appendix B.
In response to the TRT evaluation, Applicants have designed an action plan that will review liner plate documentation, evaluate the reviews to identify root causes and generic implications for other plant areas, and recommend necessary corrective actions (see ISAP VII.a.8).
In light of these developments, Applicants suggest that the issues currently reflected in the record regarding liner plate are no longer relevant. The TRT has confirmed deficiencies in liner plate documentation. Applicants will propose a program of reverification, identification of root causes for identified deficiencies, and corrective action. Nothing will be gained, and the resources of the parties will be lost, by further argument.
)
- 2. Stanford /Neumeyer NCR On the merits, the TRT's investigation and conclusion have rendered this technical issue irrelevant. Supplement 10 to the Comanche Peak SER reports the TRT's exhaustive investigation of this allegation. The TRT "could find no violation to B&R procedure or to ASME Code requirements in this weld repair process" (SSER No. 10, p. N-48). Moreover, in connection with its investigation the TRT conducted a comprehensive review of Weld Data Card and Repair Process Sheet generation, and found no discrepancies. Among the TRT's specific findings:
o "The TRT found that the weld inspection program was acceptable and consistent with the applicable code requirements and that the WT inspections were in addition to the inspections required by the Codes" (SSER 10, p. N-49).
o "In a 100% review of the weld documentation for the auxiliary feedwater system, the TRT found no instance where a WT holdpoint was assigned in lieu of a QC holdpoint" (id.).
o "In a Unit 2 walkthrough inspection, the TRT found that the data packages checked contained all the required documents, logs, and reports, and were adequately maintained at each welder's work station" (id.).
o "After an extended review of the procedure for generating WDCs and establishment of holdpoints, the TRT found (the relevant procedure] to be consistent with the applicable requirements of the ASME B&PV Code, Section 111" (id.).
These findings leave nothing to be litigated further. Should the Intervenor disagree, we believe it is appropriate to require it to specify any remaining contested issue it believes should be litigated with the issues it specifies for litigation in Docket 1.
- 3. Startup Test Engineering In its Memorandum dated October 1, 1984, in Docket 1, the Board identified two technical concerns raised by Witness F's testimony: whether Applicants documented apparent deficiencies in the ferroresonant transformer alarm circuit in a timely manner; and whether Applicants should have documented the deficiencies in an NCR, instead of (as happened) in a Test Deficiency Report. These issues are before the Board in Docket 1, and technical resolution is neither required nor appropriate in Docket 2.
Witness F also alleged that certain cable separation requirements of Comanche Peak Specification 2323 ES-100 conflict i with the requirements of IEEE Standard 384, as augmented by Reg.
Guide 1.75, to which Applicants are committed by the FSAR. In Supplement 7 to the SER, the TRT reported the conclusion of its comprehensive evaluation of the plant's cable separation criteria and hardware. The TRT confirmed Witness F's allegation in part, and noted certain other cable separation deficiencies, as well (SSER No. 7, pp J-37-44).
As a result of the TRT findings, Applicants will reinspect all panels containing redundant safety-related and non-safety-related conduits, identify all inconsistencies with relevant separatien criteria, and either rework deficient conduits, or demonstrate the acceptability of such conduits by analysis.
Applicants will also perform certain other reviews and analyses required by the TRT.
__,.--m-._--., , , , , . - . , , , , , - - _ _ _ _.,--re- ~_y - -, , - - - - . - - . _
In view of the reinspection program to be undertaken by Applicants, further litigation on the merits of Witness F's cable separation allegation would be fruitless.
4.
Valve Discs Linda Barnes, an ASME document reviewer, testified that the valve disc number on a repair traveler that she reviewed differed f rom the number listed on the code data report. The TRT investigated the allegation, and found that the discrepancy was a recording error, that the error " appeared to be an isolated case", and that " additional checks and balances in the mechanical equipment valve (MEV) traveler system help to maintain traceability, even if a record error occurs in the inprocess paperwork" (SSER 11, p. 0-125). The TRT concluded (id.):
The allegation that valve disc numbers on travelers differed from those on data reports was substantiated. However, the TRT staff finds that this mismatch was only a recording error and has confirmed that the material removed from the valves was identical to the material reinstalled. Hence, the repair traveler system assures parts traceability.
In light of the TRT finding, Applicants suggest that this technical issue is moot. Again, should CASE disagree with the TRT finding, then it should specify any remaining cor. tested issue in this regard for resolution in Docket 1. ,
1 In summary, Applicants believe that the record now reveals, and if completed, will clearly show, that no climate of harassment or intimidation of QC inspectors existed or now exists at Comanche Peak. The reinspection, reanalysis and corrective
\
action programs currently underway under the CPRT will serve to resolve any questions about the quality and safety of the plant -
- the ultimate question in this Docket as well as in Docket 1.
VII. SUGGESTED ORDER IN WHICH ISSUES MAY BE RESOLVED In the Board's Memorandum of May 24, 1985, Applicants were requested to "suggest the order in which the issues may be resolved . . . ." Memorandum at 3.
Regarding Docket 2, we believe that no further issues remain i
for consideration. Should the Board disagree, in whole or in part, Applicants see no reason to await CPRT results in order to complete the record on whether or not an atmosphere of harassment, intimidation or threats of QC inspectors existed at Comanche Peak. Accordingly, if in ruling on Applicants' Management Plan 35/ the Board finds that any issue remains for litigation within the limited scope of such Docket, we propose that a Docket 2 Prehearing Conference be held shortly thereafter to rule on contested discovery requests, and to set schedules for the completion of discovery, the filing of Staff testimony as well as Applicants' rebuttal, and for a hearing on the remainder of evidence to be presented in such docket. Applicants believe it is reasonable to expect that all further hearings in Docket 2 be completed by the Fall of 1985.
35/ A proposed schedule for such action is set forth, infra.
k
l l Concerning the resolution of Docket 1 issues, Applicants propose a schedule for consideration by the Board and parties.
This schedule recognizes:
- 1. The need for discovery on remaining issues by all j parties, but likewise considers that substantial l information already has been and shortly will be l available to both the Intervenor and the NRC Staff concerning the TRT findings, the CPRT effort, and the current Cygna issues.
l 1
- 2. That a number of issues, generic in nature, regarding the nature, scope and organization of the CPRT effort, as well as issues that arise out of a number of specific Results Reports on discrete TRT issues, need not await i
the final outcome of the reinspection and corrective action program and can be heard in the interim.
l 3. The importance of managing the hearing process such that
! it will not unduly delay plant operation once necessary corrective actions have been taken, and l 4. Tnat completion of all aspects of the CPRT effort will not occur before the end of this year.
Bearing these in mind, Applicants suggest the following regarding Docket I:
- 1. CASE responds to this Management Plan by July 26, 1985.
- 2. The NRC Staff responds to this Management Plan by August 2, 1985.
- 3. On or about August 8, 1985, a:Prehearing Conference be held to discuss the Plan, (if the Board believes that a conference will be helpful to it).
- 4. On or about August 16, 1985, the Board formally express its decision regarding the Management Plan.
- 5. Assuming Applicants' Plan is approved (at least in substantial part), CASE file its specification of remaining issues (as described in the Plan, suora), by September 16, 1985.
- 6. Applicants respond to CASE's proposed Specification of Issues by September 26, 1985.
- 7. The Staff files its response to (5) and (6) above by October 2, 1985.
- 8. On or about October 10, 1985 (again if desired by the Board), a Prehearing Conference to discuss and define issues which remain for resolution.
- 9. On or about October 18, 1985, this Board enters an order specifying issues which remain for litigation and the sequence for their litigation.
- 10. On November 8, Applicants file testimony and expected findings on CPRT issues to the considered at the commencement of hearings.
- 11. Hearings on issues commence on or about December 1, 1985, and continue until all issues have been resolved or until the Board reaches the point where all issues then ripe for consideration have been fully heard. As
\
to testimony not filed on November 8, but relevant to a remaining issue, Applicants will have the burden of filing their testimony and expected findings no fewer than 30 days before the Board takes evidence thereon.
Regarding discovery in Docket 1, CASE ~will be provided full access to relevant CPRT files. We believe it appropriate that any further discovery by CASE be permitted on all " generic" CPRT issues and. programs, as described earlier, commencing on July 1 and continuing through the end of August, 1985. Any further discovery on final Results Reports issued by the SRT should commence when the reports are filed with this Board and continue for 30 days unless extended by the Board for good cause shown.
This procedure should afford ample time for discovery and preparation for hearing on all remaining issues since this schedule calls for hearings not to commence until five months have elapsed from the filing of this Plan.
VIII. CONCLUSION Applicants intend and expect to resolve all outstanding issues before this Board through the comprehensive CPRT program and Management Plan described herein. It has been estimated that the CPRT effort will expend 750-1,000 man years of effort in reinspection, analysis, corrective action resolution, and root cause determination,31/ with the result that the quality and 3s/ See Transcript of meeting between NRC Staff and Applicant of June 13, 1985, Tr. 130-31.
safety of Comanche Peak will be reasonably assured. Applicants believe this program presents the most efficient and effective method to resolve the concerns at issue before this Board and, accordingly, respectfully request that this Management Plan be approved and implemented in these Dockets.
Respectfully submitted, C
/
g nr~~,.
Robert.A. Wooldridge N WORSHAM, FORSYTHE, SAMPELS
& WOOLDRIDGE 2500 - 2001 Bryan Tower k Dallas, Tex s 75201 [
(214) 7 8-9 65 b l ./
Nichola S./$eynolds William A. Hc rin David Re'pka BISHOP, LIESRMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 (202) 857-9817 Thomas G. Dignan, Jr.
Robert K. Gad ROPES & GRAY 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Counsel for Applicants June 28, 1985
F June 26, 1985 Attached is the updated Section 13.1 (Organizational Structure of Applicant) to the CPSES/FSAR. This update will be included in the upcoming FSAR Amendment 55.
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CPSES/FSAR 13.0 CONDUCTION OF OPERATIONS 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT Texas Utilities Electric Company (TUEC) is a subsidiary of Texas Utilities Company (TUCO): Texas Utilities Generating Company (TUGCO),
Dallas Power & Light Company (DP&L), Texas Electric Service Company (TESCO) and Texas Power & Light Company (TP&L) are divisions of TUEC. 49 TUGC0 has been designated by TUEC to coordinate the design, construction and operation of CPSES. These relationships are shown in Figure 13.1-1.
The Owners of CPSES are TUEC (87 5/6 percent), Texas Municipal Power Agency (TMPA) (6 1/5 percent), Brazos Electric Power Cooperative, Inc.
37 (BEPC) (3 4/5 percent) and Tex-La Electric Cooperative of Texas, Inc.
(Tex-La) (2 1/6 percent). .
The Lead Applicant is TUEC, which has been designated Agent _for CPSES by 4g the Owner Applicants. TUEC has corporate responsibility for the design, construction and operation of CPSES, which includes the functions of . .
procurement, fuel management and quality assurance.
49 TUGC0 has been designated by TUEC to furnish design, engineering, construction, licensing, operations, fuel management and engineering 6 technical support for CPSES.
13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION The management and technical support for CPSES is provided by personnel 49 from TUGCO.
13.1-1
)
CPSES/FSAR 13.1.1.1 Design and Operating Responsibilities The design and operating responsibilities can be divided into three categories: design and construction activities, preoperational activities and technical support for operation. The first two categories were implemented prior to the Construction Permit for CPSES.
The third was implemented prior to the initial testing program and will 49 continue throughout the life of the plant. A technical support organization in TUGC0 has been instituted at the plant site for the purposes of supporting start-up of both units and continuing technical 15 support during operations.
13.1.1.1.1 Design and Construction Activities The responsibility for facility design, design review, design approval 49 and construction management is assigned to TUGC0 Engineering. The 55 Quality Assurance Program is described in Section 17.1.
49 1. Responsibilities of TUGC0 Engineering: , ,
- a. Site-related engineering work - meteorology, geology, seismology, hydrology, demography, and environmental effects
- b. Design of plant and ancillary systems l
- c. Review and approval of plant design features i
- d. Site layout in respect to environmental effects and security I provisions
- e. Development of safety analysis reports, environmental reports and license applications
- f. Material and components specification review and approval l
l l
l 13.1-2 l
l CPSES/FSAR
- g. Procurement of materials and equipment
- h. Management and review of construction activities
- 2. Interrelations with contractors and suppliers - TUGC0 administers 49 the following contracts:
- a. Westinghouse Electric Corporation - to design, manufacture and deliver to the site two nuclear steam supply systems (NSSS)
- d. Freese & Nichols of Fort Worth, Texas - to design the Squaw
. Creek Dam and the SSI Dam, the reservoir and associated makeup systems, plus other facilities such as the railroad and access road.
- e. Mason-Johnston & Associates of Dallas, Texas - to provide geotechnical services
- f. Dames & Moore, Inc. of Los Angeles - to perform environmental studies and other related services 13.1.1.1.2 Preoperational Activities TUGC0 is responsible for the start-up testing activities which are those testing activities up to fuel load. These activities are performed by 49 the CPSES Startup Staff under the direction of the Manager, CPSES Startup.
13.1-3
CPSES/FSAR 49 1. Gibbs & Hill, Inc. under the direction of TUGC0 has developed and implemented operational design objectives. The CPSES Operating Staff has continually reviewed the CPSES design including the 49 Control Room layout and provided input for the CPSES design.
- 2. The management of CPSES has been assigned since the fourth quarter 25- 1973. Initial operating personnel were selected during the fourth
' quarter of 1976 and were immediately assigned to license training
' activities. Training for the CPSE3 Operating Staff is presented in Section 13.2. Station management and supervisory personnel have completed training as indicated in Section 13.1.3.2 and Section 13.2.
- 3. TUGC0 assigned a lead startup engineer during the third quarter ,
1975 to develop the startup testing program for CPSES. A startup '
49 testing schedule was completed in the fourth quarter 1976.
Administrative procedures for the implementation of the startup program were begun during the first half of 1976. A description of the CPSES startup and test program is presented in Se,ction , ,
14.2.
- 4. Development of station maintenance programs was initiated by the 49 Maintenance Superintendent, a position that has been filled since ,
the fourth quarter 1973. The Maintenance. Department organization is presented in Section 13.1.2.2.
- 5. Development of the Security plan began in the first quarter 1976.
The detailed Security Plan is submitted separately as stated in 15 Section 13.6.
?l9 ] 6. Since 1974, the development of the CPSES Emergency Plan was the responsibility of the Radiation Protection Engineer under the 25l -
supervision of the Engineering Superintendent. Effective March 49 1984, the Emergency Plan is the responsibility of the Emergency 13.1-4
CPSES/FSAR Planning Coordinator under the supervision of the Support Services 49 Superintendent.
A detailed development of the. Emergency Plan began in the second quarter 1975. The Emergency Plan is presented in Section 13.3.
TUGC0 has recognized the need for specialized expertise and advice in discharging its responsibilities for preoperational planning. As such, TUGC0 has retained various consultants to assist in the development and, in some cases, the implementation of various preoperational activities.
Some of the areas where TUGC0 has received consulting support are:
Startup and initial startup testing 49 1.
- 2. Security planning
- 3. Training
- 4. Records Management
- 5. Procedure development
- 6. -
Quality Assurance
- 7. Managed Maintenance , ,
- 8. Emergency Planning
- 9. Operations 49 13.1.1.1.3 Technical Support for Operations Technical services and backup support for CPSES are furnished by TUGCO. 49
{
Personnel.fre available who are competent in technical matters related to plant safety and other engineering and scientific support aspects. l o, l
In the event the staff needs assistance with specific problems, the services of qualified individuals will De engaged as appropriate.
13.1-5
CPSES/FSAR
- 1. The special capabilities that are available are:
6 a. Nuclear, mechanical, structural, electrical, thermal-hydraulic, metallurgical and materials, chemistry, and 49 instruments and controls engineering 6
- b. -Nuclear Safety
- c. Plant Chemistry
- d. Health Physics
- e. Fueling and refueling operations support
- f. Maintenance support 9 Licensing
- h. . Industrial Safety . . ..
13.1.1.2 ORGANIZATIONAL ARRANGEMENT 37 President - The President of TUGC0 has the overall responsibility for the design, construction and operation of CPSES. He provides technical direction and administrative guidance to the Executive Vice President.
Executive Vice-President - The Executive Vice President is responsible for the operation, engineering and construction of CPSES and is also 55 responsible for Quality Assurance during construction and operation. He provides technical direction and administrative guidance to the Vice President, Nuclear Operations; the Vice President, Engineering and Construction (CPSES Project General Manager); the Vice-President; and the Safeteam Manager.
13.1-6
CPSES/FSAR Manager, Safeteam - The Manager, Safeteam is responsible for managing-the Safeteam Program for the review and investigation of employee safety concerns. He is responsible for interviewing both departing employees and employees with concerns, maintaining the independence and 55 credibility of the program, and ensuring adequate responses are provided to employees with concerns. He also provides technical direction and administrative guidance to his staff.
The TUGC0 nuclear administrative organization is shown in Figure 13.1-2. 15 13.1.1.2.1 ORGANIZATION - TUGC0 VICE PRESIDENT, NUCLEAR OPERATIONS 55
- 1. Vice President, Nuclear Operations - The Vice President, Nuclear 49 Operations is responsible for the safe and efficient operation of CPSES. He has been given the requisite authority and support by 37 higher authority in the company to carry out these functions. He provides technical direction and administrative guidance to his staff which includes the Manager, Nuclear Operations; the Health Physics Supervisor; the Supervisor, Engineering and Administrative .
Services; and the Assistant Project General Manager - Unit 2. He 55 l is also responsible for establishing, implementing, and manning the Operations Review Committee in accordance with the requirements of the CPSES Technical Specifications.
i
- 2. Manager, Nuclear Operations,- The Manager, Nuclear Operations is responsible for plant operations, operations support, nuclear l37 l
training and support services. He provides technical direction 4g and administrative guidance in areas of his responsibility to his 15 l
staff, which includes the Manager, Plant Operations; the Superintendent, Operations Support; the Director, Nuclear Training; and the Superintendent, Support Services.
49 A. Manager, Plant Operations - The Manager Plant Operations is i responsible for the overall operation of CPSES which 13.1-7
CPSES/FSAR includes administration, operation, maintenance, 49 engineering, quality assurance, security, and fire protection. The CPSES Operating Organization is described in Section 13.1.2.
B. Superintendent, Operations Support - The Superintendent, Operations Support is responsible for providing offsite 37 engineering and technical support to CPSES Plant Operations.
~
His responsibilities include Project Management for plant modifications and design changes. He is also responsible for the Independent Safety Engineering Group and providing 49 Shift Technical Advisors to each operating shift. In addition, he is responsible for evaluating the Emergency 37 Preparedness of CPSES. He provides technical direction and administrative guidance in areas of his responsibility to 25 his staff, which includes the Technical Support Engineer and the Operations Support Engineer.
-55 -
- 1) Technical Support Engineer - The Technical S,upport , ,,
Engineer is responsible for offsite technical support to CPSES Plant Operations. This responsibility 49 includes project management activities associated with permanent plant modifications. He provides design change control by being the focal point within TUGC0 for CPSES design changes. Most detailed design work 55 is done by the Assistant Engineering Manager, including drawing updates, and then operationally reviewed by the Technical Support Engineer. The Technical Support Engineer coordinates with Plant Operations to assure that design changes are correctly 49 scheduled, procedure changes are made, training material is updated; interim drawings are provided to Operations Personnel, and final drawings are produced in a timely manner. The Technical Support Engineer 13.1-8
1 CPSES/FSAR also provides other general engineering support to 49 Plant Operations as requested. The Technical Support Engineer provides technical direction and administrative guidance to his staff of engineers.
25
- 2) Operations Support Engineer - The Operations Support Engineer is responsible for providing Shift Technical Advisors (STAS) to each operating shift in support of the Shift Supervisors. These STAS will meet the education, experience and training requirements of 46 NUREG-0737, October 31, 1980. At the time of initial fuel load of Unit 1, the necessary number of qualified STAS will be available to support the operations of CPSES.
25 The Operations Support Engineer is also responsible for the Independent Safety Engineering Review of Plant
. Operations. This function will be performed by the Independent Safety Engineering Group as described in FSAR Section 13.4.2.1.
The Operations Support Engineer is responsible for the development of Emergency Preparedness drill scenarios 49 specific to CPSES and for coordinating controllers during graded emergency drills.
C. Director, Nuclear Training - The Director, Nuclear Training is responsible for training activities at CPSES. He is responsible for planning and conducting operator training 15 and retraining as described in Section 13.2. The Director, Nuclear Training works with other station supervisors to identify, develop, and present specialty training for plant employees. The Director, Nuclear Training develops, coordinates, and arranges for the presentation of general l
13.1-9
CPSES/FSAR employee and contractor training and indoctrination.
15 Training documentation and records are the responsibility of the Director, Nuclear Training.
D. Superintendent, Support Services - The Superintendent, Support Services is responsible for providing public information/public relations, and emergency planning for CPSES and administrative support for TUGC0 Nuclear 49 Operations. His responsibilities also include maintaining liaison with Squaw Creek Park. He provides technical and administrative guidance in areas of his responsibility to his staff which includes the Emergency Planning Coordinator and the Public Information Specialists.
55 l
- 3. Health Physics Supervisor - The Health Physics Supervisor is responsible for the coordination and evaluation of the health 37 physics programs. In addition, he monitors the design and
- construction with respect to matters related to health physics and radiation protection. He also assists in the purchase and test :1g program for all radiological and radiation protection equipment The Health Physics Supervisor provides technical direction and 17 administrative guidance to his staff in the corporate health physics group.
- 4. Supervisor, Engineering and Administrative Services - The 38 Supervisor, Engineering and Administrative Services is responsible for technical and administrative support to the Vice President, Nuclear Operations. He also provides engineering staff support for the Operations Review Committee. He provides technical direction and administrative guidance to his staff.
55
- 5. Assistant Project General Manager - Unit 2 - The Assistant Project General Manager - Unit 2 reports to the Vice President, Nuclear Operations for start-up related activities. He provides technical 13.1-10
CPSES/FSAR direction and administrative guidance to his staff which includes 49 the Manager, CPSES Startup. The Assistant Project General Manager
- Unit 2 is also responsible for engineering and construction 55 activities as described in Section 13.1.1.2.2.
13.1.1.2.2 ORGANIZATION - TUGC0 VICE-PRESIDENT, ENGINEERING AND CONSTRUCTION 55
- 1. Vice-President, Engineering and Construction (CPSES Project 4g General Manager) - The Vice-President, Engineering and Construction is responsible for engineering, construction and j procurement activities described in Section 13.1.1.1.1. He provides technical direction and administrative guidance to the 55 Assistant Project General Manager - Unit 1; the-Assistant Project General Manager - Unit 2; and the Manager, Engineering. He is also responsible for management of the architect - engineer and the constructor of CPSES. 49
- 2. Assistant Project General Manager - Unit 1 and Unit 2 - The two ,
Assistant Project General Managers report to the Vice-President, Engineering and Construction for engineering and construction 55 related activities associated with C?SES. They provide technical direction and administrative guidance to their staffs based onsite.
The Assistant Project General Managers are responsible for:
- Construction of the plant
- Review and approval of plant design features l
- Site layout in respect to security provisions
- Material and components specification review and approval 49
- Procurement of materials and equipment The Assistant Project General Manager - Unit 2 is responsible for all start-up related activities as described in Section 55 13.1.1.2.1.
13.1-11
CPSES/FSAR
- 3. Manager, Engineering - The Manager, Engineering is responsible for the ongoing detailed engineering activities associated with completion of CPSES. The Manager, Engineering provides technical direction and administrative guidance to his staff, which includes the two Assistant Managers, Engineering.
A) Assistant Manager, Engineering - The Assistant Manager, Engineering is responsible for engineering services for CPSES. Present responsibilities include engineering and procurement of all Three Mile Island requirements, full responsibility for all engineering required to satisfy new licensing requirements, and review of startup test procedures and test data packages. He provides technical direction and administrative guidance to his staff.
B) Assistant Manager, Engineering - The Assistant Manager, Engineering is responsible for pipe support engineering, civil structural engineering, guidance to the G&H and Ebasco . -
55 Project Managers, and guidance for other architect engineering activities. He provides. technical direction and administrative guidance to his staff.
13.1.1.2.3 ORGANIZATION - TUGC0 VICE-PRESIDENT
- 1. Vice-President - The Vice-President is responsible for licensing, nuclear fuel, and quality assurance activities associated with CPSES. He provides technical direction and administrative guidance to his staff which includes the Manager, Nuclear Licensing; Manager, Nuclear Fuels; and the Director, Quality Assurance.
- 2. Manager, Nuclear Licensing - The Manager, Nuclear Licensing is responsible for licensing activities at CPSES. He is accountable for the management of the Nuclear Licensing Department. He 13.1-12
CPSES/FSAR provides administrative and technical licensing support to TUGC0 upper management and other CPSES project groups, and interfaces with the Nuclear Regulatory Commission on licensing matters pertaining to CPSES.
- 3. Manager, Nuclear Fuel Services - The Manager, Nuclear Fuel Services is responsible for the evaluation, procurement, management and planning for all activities associated with the nuclear fuel cycle.
- 4. Director, Quality Assurance - The Director, Quality Assurance is 55 responsible for the development of the Quality Assurance Program for TUGC0 nuclear power plant projects. He is al'o s responsible for assuring proper implementation of the QA Program. He assures ,
that the quality related activities performed by his department are conducted in accordance with the guidance contained in the QA Program. He has "stopwork" authority in the design, engineering, procurement, construction, startup, and operational phases of the .
CPSES project. He provides technical direction and administrative guidance to the Manager, Quality Assurance and the Manager, Quality Control.
A) Manager, Quality Assurance - The Manager, Quality Assurance is responsible for the development, implementation, and management of the internal audit program and the supplier audit program. In addition, he is responsible for the development of the required precedures and training programs for his staff, release inspections at vendors and for the corporate quality engineering effort.
B) Manager, Quality Control - The Manager, Quality Control is responsible for directing site construction related QA/QC activities. He is also responsible for the development of the required procedures and training programs for his staff.
13.1-13
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CPSES/FSAR 15 13.1.1.3 Qualifications of Management and Technical Support Personnel 55 13.1.1.3.1 TUGC0 Administrative Organization Qualifications Resumes of key managerial and technical support personnel currently 15 assigned are given below.
William G. Counsil - Executive Vice-President Education:
B.S. Engineering - U.S. Naval Academy, 1960 Experience:
1960 - Various duties in the U.S. Navy including five years aboard nuclear submarines in a number of engineering and management positions.
1967 - Joined the Millstone Point Company and became Operations Supervisor for Unit 1 of the Millstone Nuclear Power 55 Station. Responsible for operator training, preoperational and startup test programs, and commercial operation of the unit.
1970 - Assigned position of Assistant Plant Superintendent for Millstone Units 1 and 2. Responsible for the commercial operation of Unit 1 and the preoperational and startup testing of Unit 2.
1974 - Assigned position of Plant Superintendent for Millstone Units 1 and 2. Responsible for the safe operation, maintenance, refueling, and overhaul of Units 1 and 2.
13.1-14
CPSES/FSAR 1976 - Assigned position of Project Manager of Millstone Unit 3.
Responsible for engineering, design, construction, and
. coordination of all activities internal to the company and with the engineer / constructor and nuclear steam system supplier.
1978 - Named Vice President - Nuclear Engineering and Operations of Northeast Utilities Service Company. Responsible for all technical support and nuclear safety associated with the operations of Northeast Utilities nuclear facilities.
1980 - Named Senior Vice President - Nuclear Engineering and Operations. Responsible for all technical support and nuclear safety associated with the operations of Northe,,st 55 Utilities nuclear facilities as well as the construction / engineering and preoperati. :al/startup testing of all new generation facilities.
1985 - Joined Texas Utilities Generating Compa y as Executive Vice-President, Nuclear.
Affiliations:
Atomic Industrial Forum: Nuclear Regulations Policy Committee Regionalization Subcommittee (Chairman)
Electrical Power Research Institute Nuclear Utility Backfit and Reform Group (Chai, man)
Nuclear Utility Fire Protection Group (Chairman) 13.1-15
CPSES/FSAR John W. Beck - Vice President Education:
B.S. Engineering Physics - University of Tulsa, 1964 M.S. Mechanical Engineering - Northeastern University,1970
~
Experience:-
1964 - Bettis Atomic Power Laboratory - Westinghouse operated government laboratory for PWR research and design for naval reactors.
1967 - Yankee Atomic Electric Company - Started as Engineer in core physics design and analysis. Coordinated licensing ,
activities for Maine Yankee nuclear power plant. Served as -
Assistant to the President of YAEC then as Reactor Engineering Manager. Final position held was Director of Engineering. , ,
1976 - Named Executive Vice President of Vermont Yankee Nuclear 55 Power Corporation.
1980 - Named Vice President of TERA Corporation for Southern and Southwestern Operations. Consulted for utilities and the nuclear industry in general engineering and the environment areas.
1984 - Named Manager, Nuclear Licensing for Texas Utilities Generating Company (served as Executive Assistant to the President of TUGC0 April to October).
1985 - Named Vice President, Texas Utilities Generating Company.
Areas of responsibility include nuclear licensing, nuclear fuels, and quality assurance.
13.1-16
CPSES/FSAR .
Joe B. George - Vice President, Engineering and Construction (CPSES Project General Manager)
Education: .
A.D. Arts - Ranger Junior College, 1955 8.S. Electrical Engineering - Texas Tech University, 1959 Experience:
1959 - Field Engineer, Texas Electric Scr,sce Company (TESCO) -
1963 - Odessa Station Distribution Superintendent, TESCO ,
1 1968 - Senior Engineer, TESCO 1971 - Manager, Distribution Planning, TESCO 1976'- Engineering Manager, Substation and Underground De, sign, . ,
TESCO 55 1977 - CPSES Nuclear Construction Manager, Texas Utilities Services Inc. (TUSI) 1977 - CPSES Project General Manager, TUSl 1980 - Vice-President, Engineering and Construction (CPSES Project General Manager), TUSI 1984 - Vice-President, Engineering and Construction (CPSES Project General Manager), Texas Utilities Generating Company Affiliations:
Registered Professional Engineer - Texas 13.1-17
s
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CPSES/FSAR -
Richard A. Werner - Manager, Safeteam Education:
B.S. Physics / Mathematics - East Texas State University - 1968 M.S. Nuclear Engineering - University of Missouri, 1975 -
Experience: .
1969 - Various duties in the U.S. Navy in the engineering _
department aboard nuclear submarmines.
1973 - Joined University of Missouri Research Reactor Facility as a Reactor Engineer. Responsible for supervision of ,
maintenance and facility design changes on the 10 MW thermal research reactor. Received AEC R0 license.
1975 - Joined Texas Electric Service Company (TESCO) es an Associate Nuclear Engineer at the Graham Power Pla,nt. , ,
55 1976 - Assigned as Associate Nuclear Engineer in the Information Department of TESCO. Performed energy issue research with emphasis on nuclear energy.
1977 - Assigned as a Nuclear Engineer in the Nuclear Division of Texas Utilities Services, Inc. (TUSI). Worked on preparation of OL application for CPSES, supervised the preparation of the ER(0LS) and various sections of the FSAR.
l 1980 - Assigned as Senior Nuclear Licensing Engineer for TUSI.
1983 - Assigned as Senior Nuclear Licensing Engineer for TUGCO.
1984 - Named Manager, Safeteam for TUGC0 l
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13.1-18
4 CPSES/FSAR -
James R. Wells - Director of Quality Assurance Education:
B.S. Civil Engineering - Georgia Institute of Technology - 1952 [
M.S. Civil Engineering - Georgia Institute of Technology - 1954 Experience:
1954 - Various duties in the U.S. Navy Civil Engineer. Corps.
Served as Public Works Officer and Resident Officer in charge of construction at Jacksonville, FL and Charleston, SC naval installations.
4 1957 - Joined Duke Power Company as an office engineer serving in -
capacities supporting the construction of fossil. fueled power plants. Responsibilities included both field and office engineering. , ,
1966 - Assigned position of Principal Field Engineer at the Oconee 55 N'u clear Station. Responsible for all construction engineering, Quality Assurance and Quality Control for the construction of Oconee Nuclear Station.
1971 - Assigned position of Assistant Project Engineer at the McGuire Nuclear Station. Responsible for overall management and coordination of all the construction activities at the McGuire Nuclear Station site.
1971 - Assigned position of Manager, Construction Services for Duke Power Company. Responsible for the management and I
coordination of the Construction Services Branch of the Construction Department which provided technical assistance to all company construction projects.
13.1-19
CPSES/FSAR 1974 - Assigned position of Corporate Quality Assurance Manager for Duke Power Company. Developed and managed the Quality !
Assurance Department for Duke Power. Included in this was l the design, construction, and operations Quality Assurance programs for seven nuclear units during construction and operational phases.
1982 - Assigned position of Assistant to the Vice President at the Institute of Nuclear Power Operations (INPO). Loaned by ,
Duke Power Company to INPO to develop the Construction ,
Project Evaluation Program - an industry program devoted to the upgrading of quality of construction of nuclear power
'YI plants. Participated in the evaluation of ten nuclear power I plants under various stages of design and construction.
1983 - Assigned position of '.ssistant to the Vice President of Duke Power Company for special assignments.
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55 1985 - Assigned position of 'lirector of Quality Assurance at Texas Utilities Generating Company. Loaned by Duke Power Company to manage the Quality Assurance Programs of TUGCO.
Affiliations:
Registered Professicnal Engineer: North Carolina, South Carolina Member: ASME, ASCE, ASTM, ANSI l
2 1
13.1-20
4 CPSES/FSAR . ;
David M. McAfee - Manager, Quality Assurance Education:
Completed two years of college education i
Experience: I 1967 - Supervisor, Quality Assurance, Avco Lycoming Corporation.
Responsible for managing and directing the Quality Data Analysis Department. Provided company management with information necessary to measure the adequacy and effectiveness of procurement, manufacturing, and quality ;
control programs.
}
5 1971 - Quality Assurance Engineer, WEDC0 Corporation. Responsible for performing periodic audits of field activities in all
- . areas of construction with emphasis in the mechanical, welding, and civil disciplines to ensure conformance with program requirements.
55 1973 - Project Quality Assurance Manager, Daniel Construction Company. Responsible for developing and executing a program of surveillances and audits to ensure that the project control program was being correctly developed, implemented, maintained, and documented in accordance with regulatory and design requirements.
1974 - Regional Manager, Quality Assurance, Daniel Construction Company. Responsible for managing the quality assurance activities for the construction of three nuclear power generating facilities. Administered audit and surveillance functions, analyzed the adequacy and effectiveness of the quality assurance programs, and implemented applicable NRC, ASME, and ANSI quality assurance program requirements.
13.1-21
CPSES/FSAR -
1977 - Director, Quality Assurance, Daniel Construction Company.
Responsible for managing the corporate quality assurance ,
operation to provide quality assurance services to all corporate organizations and Daniel projects.
1980 - Director, Quality Support Services, Daniel Construction Company. Responsible for managing the Quality Support i Services Division which consisted of the Quality Assurance l
and Quality Services Departments. Responsible for providing corporate and project QA plans, programs, and procedures; QA ;
audit systems; vendor surveillance systems; and data analysis systems.
1983 - Director, Process and Industrial Operations, Technical Services Division, Daniel Construction Company. Responsible -
55 for managing the Process and Industrial Operations Division which provides technical services, qualified personnel, and management services to all Daniel process and industrial , ,
projects.
f 1985 - Assigned position of Manager, Quality Assurance at Texas Utilities Generating Company. Loaned by Daniel Construction Company.
Affiliations:
Professional Engineer - California Member: Atomic Industrial Forum American Society for Quality Control 1
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i 13.1-22
CPSES/FSAR -
Phillip E. Halstead - Manager, Quality Control Education:
B.S. - Troy State University, 1973 Experience:
1971 - Concrete Inspector at Farley Nuclear Project for Daniel International Corporation. Responsible for the testing and '
inspection of concrete and the materials used to make Concrete.
1972 - Completed college degree.
1973 - Structural Inspector at Farley Nuclear Project for Daniel International Corporation. Responsible for the field inspection of construction activities related to structural and reinforcing steel, architectural, post-tension,ing, and , ,
formwork. 55 1974 - Senior Structural Inspector at Farley Nuclear Project for Daniel International Corporation. Responsibilities included the supervision and training of structural inspectcrs.
l .
1975 - Lead Structural Inspector at Farley Nuclear Project for Daniel International Corporation. Responsibilities included supervision of the structural section of the Civil QC Dapartment.
1976 - Assistant Project Civil QC Engineer at Farley Nuclear Project for Daniel International Corporation.
Responsibilities included coordinating and managing the activities of the Civil QC Department.
13.1-23
~
CPSES/FSAR -
1977 - Project Civil QC Engineer at Farley Nuclear Project for Daniel International Corporation. Responsibilities included j managing the activities of the Civil QC Department. .j i
1978 - Senior Civil Engineer in Technical Services Division of ]
Daniel International Corporation. Responsible for providing construction, construction engineering, and quality control technical services to four nuclear power projects as well as :
~
a number of conventional power and industrial facilities.
1982 - Project Quality Manager at Callaway Nuclear Project for :
Daniel International Corporation. Responsibilities included managerial, functional and administrative ~ roles for the i total operation of the Project Quality Organization. I Responsible for training, documentation, program implementation, coordination of quality activities, established comprehensive project audit program. -
' ' ~
55 1984 - Project Quality Manager in Technical Services Division of Daniel International Corporation. Served in capacity of Administrative Assistant to the Vice-President Construction at Wolf Creek Generating Station. Responsibilities included coordinating the resolutions of the Construction Self-Assessment Program quality audits and quality allegations and concerns.
l 1985 - Assigned position of Manager, Quality Control at Texas Utilities Generating Company. Loaned by Daniel 4 International Corporation.
Affiliations:
Member: American Concrete Institute i
ASTM 13.1-24 1 _ _ _ . _ _ _ -
o
?
r, Y g ,.
CPSES/FSAR -
-John S. Marshall - Nuclear Licensing Supervisor' _
, Education: '
B.S. - U.S. Naval Academy, 1964 Post-Graduate Education - Business and Management, s California State University, 1975-79 'l
. Post-Graduate Education - Management, University of Texas, 1980-83 i
j Experience:
g l 1964 - U.S. Navy Nuclear Suomarine Service. Qualified to supervise 1 operation of nuclear reactors ty examination, oral interview, and requisite experience. Extensive duties as a division officer in a submarine Engineering Department ,
supervising technicians and operators of a nuclear reactor. -
Participated in pre-ocerational testing, initial i
criticality, and' power range testing of a new submarine react 3r as an1 Engineering Officer of the Watch. Als -
-55 part' :1 pated in several extensive operational inspections of power plants.
1974 - Bechtel Power Corporation. Design and licensing of balance of plant systems for foreign and domestic nuclear power plants representing four domestic NSSS manufacturers.
Detailed shielding and design of equipment layout for ALAP.A.
Detailedpressuretransfentanalysis. NSSS interface definition. ,
1979 - Texas Utilities Services Inc. as a Nuclear Licensing Engineer.
l -1980 - Texas Utilities Services Inc. as Nuclear Licensing Supervisor.
l t .
i l
13.1-25
t CPSES/FSAR :~
1984 - Texas Utilities Generating Company as Nuclear Licensing Supervisor.
Affiliations:
.i Member of American Nuclear Society ,
Donald R. Woodlan - Nuclear Licensing Supervisor 3
Education:
B.S. Electrica1' Engineering and Mathematics, U.S. Naval Academy, a 1964-1968 ;
M.S. Electrical Engineering, Michigan State University, 1968-1969 1
l l Experience:
~
1968 - U.S. Navy as Division Officer, Department Head, Engineering Watch Officer, Ship Duty Officer: Nuclear powered , submarines , .,
(USS Jack and USS Sam Rayburn). Responsible for the 55 operation and maintenance of nuclear reactor and ships power plant; for the safe operation of the ship; and for the operation and maintenance of the weapons systems.
1975 - Cleveland Electric Illuminating Company as Operations Engineer, Ferry Nuclear Power Plant responsible for spare parts program, technical specifications, system operating description, and control panel layouts.
1979 - Texas Utilities Services Inc. as Senior Licensing Engineer, Comanche Peak Steam Electric Station. Responsiole for the I&C (Instrument and Control) and electrical aspects of licensing, and for electrical equipment environmental qualification.
13.1-26
CPSES/FSAR 1984 - Texas Utilities Generating Company as Senior Licensing Engineer: Comanche Peak Steam Electric Station.
Affilations: k Member of American Nuclear Society Member of Institute of Electrical & Electronic Engineers 55 Randall L. Janne - Panager, Nuclear Fuel Services Education:
B.S. Nuclear Engineering, Texas A&M University, 1975 M.E. Nuclear Engineering, Texas A&M University, 1976 D. Eng. Nuclear Engineering, Texas A&M Unfversity, 1978 Experience:
1976 - Teras Utilities Services Inc. as Nuclear Fuels Engi,neer. , ,,
Activities included analysis of nuclear fuel design, economic analysis of nuclear fuel cycle, accounting and SNM accountability, fuel-related design modifications and spent fuel storage.
1981 - Texas Utilities Services Inc. as Nuclear Fuels Supervisor.
Activities included uranium procurement, conversion, enrichment,, fabrication, analysis of nuclear fuel design, incore support of plant operations, accounting and SNM accountability, fuel-related design modifications and spent fuel storage. Technical advisor to Operations Review Committe.e.
1984 - Texas Utilities Generating Company as Nuclear Fuels Supervisor.
13.1-27
. e i
CPSES/FSAR 1985 - Texas Utilities Generating Company as Manager, Nuclear Fuel _
Services.
55 Affiliations:
Registered Professional Engineer in Texas Member'of American Nuclear Society ,
Associate Member of American Society of Mechanical Engineers James C. Kuykendall - Manager, Nuclear Operations g Education:
~
BSME - Southern Methodist University - 1949
.c 15 Experience:
1949
- Employed by Texas Electric Service Company at the Wichita Falls plant as a Student Engineer, progressing to Junior , ;
Engineer. EngagM primarily in training in power plant operation.
1951 - Assigned to the Leon Plant as Senior Engineer progressing to Assistant Plant Superintendent in charge of plant operation.
1957 - Assigned to the Morgan Creek plant as Assistant Plant Superintendent in charge of plant operations. Duties included review of design and construction of the 175 MW No.
5 unit and responsibility for operator training and initial startup of the unit.
1960 - Assigned to the Graham plant as Assistant Plant Superintendent in charge of plant operation. Duties included review of design and contruction of the 240 MW No.
1 unit, assisting with staffing of the plant and responsible for operator training and initial startup of the unit.
13.1-28
. e CPSES/FSAR 1963 - Assigned as Plant Superintendent of the Graham plant.
During this period the plant was expanded with the addition ,
of a 375 MW unit.
1971 - Assigned as Assistant to Manager of Production Services.
Duties consisted of assisting with consultative services to the seven power plants of the company.
l 1973 - Assigned as General Superintendent, Comanche Peak Steam Electric Station. _
1975 - Completed Westinghouse Initial Operator Training, Phases I, II, and III; received Westinghouse Senior ~ Reactor Operator 15 certification.
1980 - Assigned to present position of Manager, Nuclear Operations.
Activities: -
Registered Professional Engineer in Texas Member - American Society of Mechanical Engineers Member - American Nuclear Society Member - Edison Electric Institute - Nuclear Operations Committee 49 J. D. Edwards, Jr. - Health Physics Supervisor 17 Education:
BA - Math - Texas A&M University 16 MS - Human Relations and Management - Abilene Christian University - 1980 13.1-29
. i CPSES/FSAR Experience:
1966 - U.S. Army Engineer Reactor Group, Ft. Belvoir, Virginia.
Health Physicist and Shift Supervisor at Nuclear Power Plant (S M-1). Health Physics duties for both routine operations ,
and outages - operating pressurized water reactor:
- 1. Personnel dosimetry.
- 2. Area surveys, posting and access control.
- 3. Air and water sampling and radiological analysis.
- 4. Contamination control and decontamination.
- 5. Respiratory protection.
- 16
- 6. Radwaste packaging and shipment. '
- 7. Spent fuel packaging and shipment.
- 8. Radiation protection' instrument maintenance and calibration.
- 9. Primary and secondary chemistry including radiochemistry. , , ,,
1973 - Employed Texas Utilities Services, Inc. as Health Physicist 17 1980 - Transferred to Texas Utilities Generating Company as Health Physics Supervisor.
Activities:
16 Member - Health Physics Society l 25 Chairman - Edison Electric Institute Health Physics Committee Richard E. Kahler - Supervisor, Engineering and Administrative Services Education:
38 BSNE - Kansas State University - 1963 MSNE - Air Force Institute of Technology - 1969 l
t 13.1-30 e -
mg.-- -_-
m.r _, - - - - - _ - -.
CPSES/FSAR -
Experience:
1952 - Variety of assignments in the field of flight operations.
1963 - Student, 0IC, Nuclear Power Plant Course (Army), Fort Belvoir, VA 1964 - Assistant Officer in Charge, PM-1 Nuclear Power Plant, ,
Sundance, Wyoming. Directed routine plant operation for a 1-1/4 megawatt electrical PWR nuclear power plant.
1965 - Chief, Nuclear Power Branch, Headquarters, 10th Air Force, 38 Richard Gebaur AFB, Missouri. Provided staff supervision and technical guidance on operation of the PM-1 Nuclear ,
Power Plant. -
1969 - Staff Safety Officer, Office of the Assistant Director for Safety and Reliability, Space Nuclear Systems Divi,sion, ,,
USAEC. Managed AEC sponsored studies on safety aspects of
! manned and unmanned space nuclear power applications.
1972 - Chief, Scientific and Technical Liaison Division; (1973)
Chief, Programs Divisions, Office of Director of Science and Technology, Headquarters Air Force Systems Command; (1977)
Chief, Budget and Operations, Advisory Group for Aerospace 49 Research and Development, NATO. Provided staff level management of a variety of assignments within the field of Aerospace Research and Development (Technology Transfer, Financial Management, Office Administration).
1980 - Senior Engineer, Texas Utilities Generating Company 38 1982 - Supervisor, Engineering and Administrative Services, Texas Utilities Generating Company.
13.1-30a
- . = - .
, e n s
CPSES/FSAR -
Activities: 'i 38 g Registered Professional Engineer in Texas -
R. Ted Jenkins - Superintendent, Operations Support t
i Education: ..
BSME - University of Texas - 1972
~
Experience: l 1972 - Employed by Dallas Power & Light as Results Engineer and stationed at the Parkdale Steam Electric Station. i l Responsibilities included equipment performance testing, '
evaluation of test results, and recommendations of
- preventive maintenance and system improvement.
15
- , . a 1973 - Transferred to the Lake Hubbard Steam Electric Station.
Responsibilities included development and implementation of a performance test program to increase the efficiency, l
l availability and. reliability of plant equipment and systems.
Participated in startup of the 515 MW gas fired No. 2 unit and contributed to the refining of the computer monitoring and control system.
1974 - Assigned to the position of Results/ Test Engineer for the Comanche Peak Steam Electric Station.
1976 - Completed Westinghouse Initial Operator Training, Phase I.
i 1980 - Assigned to present position of Superintendent, Operations 49 Support. Responsibilities include technical support to Plant Operations in the areas of design change control, 4
13.1-30b
CPSES/FSAR .
licensing and general engineering. Responsibilities also include review of Plant Operations activities through the Independent Safety Engineering Group and providing qualified 49 engineers to serve as Shift Technical Advisors.
1981 - Completed Westinghouse Senior Reactor Operator's Certification.
l i
C. L. Turner - Director, Nuclear Training 15 Education:
l49 Navy Nuclear Power Training - 1967 B.A. - Biology - North Texas State University - 1974 B.A. - Math - North Texas State University - 1975 Experience:
1963 - Undergraduate Teaching Assistant at North Texas State University, Biology Department-performed duties as Laboratory Instructor and Classroom Instructor.
j 1964 - Undergraduate Research Assistant at North Texas State 15 University, Biology Department-performed undergraduate i research and studies in Water Chemistry Laboratory.
1969 - Assigned to operational nuclear surface ship, USS Enterprise
- (CVAN-65) as Reactor Plant Electrician. Served as Leading Electrical Watch, Group Electrical Supervisor and Training Division Instructor.
1976 - Employed by Westingnouse Electric Corporation, Westinghouse Nuclear Training Center as Instructor. Employed as Classroom Instructor, Simulator Instructor, Senior Phase i
13.1-30c
. ~
CPSES/FSAR -
Instructor, Senior Reactor Operator (Nuclear Training Reactor), and Training Systems Coordinator. Responsible for training and instruction in Reactor Theory, Reactor Systems, ,
Reactor Operation, and Administration. Supervised and coordinated licensed training and licensed activities for the 10 KW Nuclear Training Reactor.
1978 - Licensed by U.S. Nuclear Regulatory Commission as Senior g
Reactor Operator for Zion Generating Station Unit 1 and Unit 2 (S0P-3176) and as Senior Reactor Operator for the ,
Westinghouse Nuclear Training Reactor (50P-3176-1).
1979 - Employed by the Texas Utilities Generating Company as Training Supervisor for the Comanche Peak Steam Electric ,
Station. -
1980 - Assigned to present position of Director, Nuclear Training.
Activities:
Member - American Nuclear Society Tom L. Gosdin - Superintendent, Support Services 49 Education:
BSAE - Texas A&M University - 1967 Experience:
1967 - Employed by Exxon USA in the Industrial Business Department, Marketing Technical Services.
1978 - Employed by TUGC0 as CPSES Public Information Coordinator.
13.1-30d
. a CPSES/FSAR 1984 - Assigned to present position of Superintendent, Support Services.
49 Activities:
Registered Professional Engineer in Texas.
Harold J. Cheatheam - Technical Support Engineer Education:
BSEE - Texas Tech University, Lubbock, Texas - 1967 Experience:
1966 - Employed by Litton Industries, Lubbock, Texas, as Electronic Test Technician to test and troubleshoot electronic component cards for Naval Guidance Systems. 46 ,
1967 - Employed by Pan American Petroleum Corp., Odessa and Fort Worth, Texas, as Petroleum Reservoir Engineer with primary duties to evaluate well performance and recommend well j treatments to increase productivity.
l 1969 - Employed by Dallas Power & Light Company, Power Plant Department as Associate Engineer in the System Protection and Testing Division. Duties included recommending power plant, transmission line and distribution substation protective relay settings.
l 1975 - Employed by Texas Utilities Generating Company as Electrical l
- Startup Engineer at Martin Lake Steam Electric Station.
Primary duties included initial testing, troubleshooting, making design changes, and energizing the plant electrical systems for Units 1 and 2.
l 13.1-30e
CPSES/FSAR 1978 - Assigned to Comanche Peak Steam Electric Station as Startup ,
Engineer. Promoted to Startup Electrical Group Leader l responsible for scheduling, prerequisite testing and preoperational testing of CPSES Unit No. 1 electrical systems. )
46 1983 - Assigned to Comanche Peak Steam Electric Station as.
Technical Support Engineer.
Activities: i Registered Professional Engineer in Texas.
Michael J. Riggs - Operations Support Engineer Education:
BSNE - Texas A&M University - 1974 . . -
Experience:
1974 - Employed by General Electric Corporation and assigned to startup engineering on Carolina Power & Light's Brunswick 49 Steam Electric Plant. Participated in Reactor Initial Operation Testing.
1975 - Received GE Senior Reactor Operator Certification on Dresden Nuclear Power Station Units 2 & 3 in Morris, Illinois.
Assigned as training instructor at GE BWR training center.
1976 - Assigned to Georgia Power Company's E.I. Hatch Nuclear Generating Plant as a Startup Preoperational Test Supervisor. Responsible for system test procedure l preparation, acceptance testing, preoperational testing and l
13.1-30f
. ~
CPSES/FSAR test documentation. Also, GE Operations Shift Supervisor for reactor hydro and recirc vibration testing.
1978 - Received 2nd GE Senior Reactor Operator Certification on E.I. Hatch plant in Baxley, Georgia.
49 1978 Employed by Texas Utilities Generating Company as startup engineer at CPSES.
1981 - Assigned to present position of Operations Support Engineer responsible for CPSES Shift Technical Advisors, Independent Safety Engineering Groups, Emergency preparedness, drill scenario development, and Industry Operating Experience Review Program. ,
John T. Merritt Jr. - Assistant Project General Manager - Unit 2 55 Education: , , ,,
BSCE - Texas Tech University - 1966 Experience:
1963 - Dave Johnson SES & Morgan Creek SES - Ebasco as Cadet i
engineer. Summer employment responsible for civil field l work including inspections and surveying. 37 1966 - U.S. Army Missile & Material Command Restone Arsenal, Alabama. Civil engineer responsible for developing test
[ programs including conducting research and development tests on prototype missile systems.
1968 - Big Brown SES - Texas Utilities Services Inc. Office
- engineer responsible for establishing the necessary support for a field construction office which included purchasing i
13.1-30g
CPSES/FSAR .
I
~
reports, schedules drawing control and civil field activities. l 1972 - Martin Lake SES - Texas Utilities Services Inc. Resident Engineer responsible for providing field engineering, planning, scheduling and interface control with the architect-engineer for four 750 MW Lignite fired units including establishing the mining support facilities and transportation.
1977 - Comanche Peak SES - Texas Utilities Services Inc. Resident 37 Manager responsible for developing, staffing and controlling the necessary activities to support construction of Comanche Peak. This included field engineering, purchasing, construction, scheduling, planning and project controls.
- 1979 . Comanche Peak SES - Texas Utilities Services Inc.
Engineering & Construction Manager responsible for all , ,
engineering and construction activities for this two unit site.
1982 - Comanche Peak SES - Texas Utilities Generating Co. assigned to Manager, CPSES Startup.
1984 - Comanche Peak SES - Texas Utilities Generating Co. assigned 49 to present position of Assistant Project General Manager 55 -Unit 2.
Affiliations: Registered Professional Engineer in Texas Member - American Society of Civil Engineers 4
13.1-30h i
. ~
CPSES/FSAR Richard E. Camp - Assistant Project General Manager - Unit 1 Education:
BSME, Virgina Polytechnic Institute, 1968 Part-time Graduate Study, University of Washington Extension, Richland, Washington, 1974-1975 Experience:
1968 - Brown Engineering Company, Test Programs Division Engineer responsible for development of equipment qualification and acceptance test requirements, surveillance of test activities and review of test results.
1969 - USS Enterprise - Newport News Shipbuilding & Drydock Company, Reactor Plant Test Group. Test engineer
~
- responsible for performance of equipment and system operational and acceptance tests during cold and hot , ,
functional test conditions and power ascension.
55 1970 - USS Nimitz - Newport News Shipbuilding & Drydock Company, Nuclear new Design Department. Test engineer responsible for preparation and review of test specifications, test procedures and operating instructions for the ship's acceptance test program.
1972 - Cooper Nuclear Station - Burns & Roe, Inc. Senior Startup Engineer responsible for coordination and supervision of craft and operations personnel during conduct of construction and preoperational tests of secondary and primary plant systems.
1974 - WPPSS Nuclear Unit No. 2 - Burns & Roe, Inc. Startup Operations Manager responsible for staffing and supervision 13.1-301
e .u i
g M
' CPSES/FSAR
.:I i
i
- s
- of Burns & Roe, Inc. startup engineers assigned to the ]
development of system descriptions, operational design .}
reviews, preoperational test specifications and procedures, ,
Final Safety Analysis Report, test schedules and i!
1 installation contract test requirements. q l
! 1975 ' Comanche Peak SES - Impell Corporation. Lead Startup 55
. . da j
^
Engineer /Startup Manager responsible for all preoperational , :)
test activities for the two unit site. l b
1985 - Comanche Peak SES - Impell Corporation. Assistant Project Il i
General Manager - Unit 1.
]'i Richard D. Calder - Assistant Manager, Engineering ! '
, .v i
Education: l a
l BSNE - Texas A & M University, 1970 i MSNE - North Carolina State University, 1972 , -
i Experience:
1971 - Texas Utilities Services Inc. as Fuels Engineer, assisting
1972- Texas Power & Light Co. as Engineer for System Planning, responsible for the implementation of a computerized l
! electrical demand program and a system programmer for i
j engineering related programs.
1973 - Texas Utilities Services Inc. as Engineer and Nuclear Fuels Supervisor responsible for the evaluation, procurement, f
j management and planning for all activities associated with the nuclear fuel cycle. During this period of time, he l
1 i 13.1-30j
I CPSES/FSAR completed phase I, II and III of the Westinghouse Operator's Training Program and was certified as a Senior Reactor .,
Operator. '
1980 - Texas Utilities Services Inc. as Manager of Technical 15 Support, responsible for Technical Support to TUGC0 and to 1 engineer and procure all Three Mile Island requirements plus full responsibility for all engineering required to satisfy ,
licensing requirements. .
4 1982 - Texas Utilities Services Inc. assigned to position of k Manager, Nuclear Engineering.
49 f 1984 - Texas Utilities Generating Co. as Manager, Nuclear Engineering.
~
1985*- Texas Utilities Generating Co. as Assistant Manager, 55 Engineering. , .
Activities:
Registered Professional Engineer (Texas)
Member - American Nuclear Society Associate Member - Sigma Xi Larry M. Popplewell - Assistant Manager, Engineering Education: ;
BSEE - Southern Methodist University - 1962 MBA - East Texas State University - 1981 55 j Experience:
1 1962 - Continental Electronics, Dallas - Electrical Engineer.
Design responsibilities for control and power circuits for 13.1-30k
CPSES/FSAR i
high power radar systems connected with the Nike-Zeus and ,
Altair Systems. -
1968 - Sigma Systems, Inc., Dallas - Electrical Engineer. Design ,
responsibilities on medical electronic systems. ,
1970 - Texas Power & Light - Electrical Engineer - Engineering Office. Responsible for electrical design on switchyards, ,
economical dispatch systems and control systems on gas / oil ,
fired power plants.
1971 - TUSI - Electrical Engineer - Field Construction Office. ,j 1150 MW lignite fired power plant construction management j responsibilities.
1973 - TUSI - Electrical Engineer - Engineering Office. Electrical -
- design and engineering responsibilities on 3000 MW lignite fired power plant. - - -
55 1975 - TUSI - Project Engineer - Engineering Office. Technical responsibilities for 3000 MW lignite fired power plant.
1978 - TUSI - Project Manager - Engineering Office. 3000 MW lignite burning power plant; engineering design and budget control responsibilities.
1979 - TUSI Project Electrical Engineer. Responsible for the on-site electrical engineering and construction support at ;
I Comanche Peak Steam Electric Station.
4 1984 - TUGC0 Project Electrical Engineer.
1985 - TUGC0 as Assistant Manager, Engineering.
> \
l 13.1-301 l
. v CPSES/FSAR Affiliations:
Registered Professional Engineer - Texas Charles E. Scott - Manager, CPSES Startup Education: l BSEE - New Mexico State University - 1972 Experience:
1970 - Houston Lighting and Power. Employed as a Co-op Engineer in !
Distribution / Substation Engineering.
1971 - El Paso Electric. Employed as a night dispatcher at Mesilla -
Valley Service Center.
i 1973 - Dallas Power and Light. Operating Division and Constructi.,n . _
Coordination. Associate Engineer responsible for coordinating various phases of distribution construction. 55 j
1975 - Texas Utilities Generating Company Big Brown SES Power.
Employed as a power engineer providing technical and administrative assistance in all areas of operation for 2
-575 MW Lignite-fired generating units.
1977 - Monticello SES - Electrical Startup Lead. Responsible for testing, troubleshooting and initial operation of all plant electrical systems, precipitator and scrubber for 750 MW lignite-fired generating unit.
1978 - Comanche Peak SES - Electrical Startup. Initial testing and operation of electrical systems, plant equipment and final walkdown of all plant electrical turnovers, i
13.1-30m l
i-
o * .
1 CPSES/FSAR ,
-l 1980 - Assigned position of Maintenance Engineer at CPSES Plant :
Operations. Responsible for technical direction for the f
maintenance organization, direction of contractors and {
developing and coordinating plant outages. .
1982 - Assigned position of Electrical Maintenance Engineer at CPSES. Accountable for all phases of electrical maintenan:e 55 including developing and implementing the Meter and Relay program. >
1985 - Named as Manager, CPSES Startup. ,
s
- O 9 % 49 4
i 13.1-31
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-445-1,
) 50-446-1, TEXAS UTILITIES ELECTRIC ) 50-445-2 and COMPANY, ET AL. ) 50-446-2
)
(Comanche Peak Steam Electric ) ( Application for Station, Units 1-and 2) ) Operating Licenses)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Current Management Views and Management Plan For Resolution of All Issues" in the above-captioned matter was served upon the following persons by express mail (*) or deposit in the United States mail, first class, postage prepaid, or by hand delivery
(**) on the 28th day of June,1985.
. ** Peter B. Bloch, Esquire Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Appeal Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory i
Commiss ion Commission Washington, D.C. 20555 Washington, D.C. 20555
- Dr. Walter H. Jordan Mr. William L. Clements 881 West Outer Drive Docketing and Service Oak Ridge, Tennessee 37830 Branch U.S. Nuclear Regulatory
- Dr. Kenneth A. McCollom Commission Dean, Division of Washington, D.C. 20555 Engineering, Architecture and Technology **Stuart A. Treby, Esquire Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555
, . Chairman, Atomic Safety
- Elizabeth B. Johnson and Licensing Board Oak Ridge National Panel Laboratory U.S. Nuclear Regulatory Post Of fice Box X Commission Building 3500 Washington, D.C. 20555 Oak Ridge, Tennessee 37830 Robert D. Martin Renea Hicks, Esquire Regional Administrator, Assistant Attorney General Region IV Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 611 Ryan Plaza Drive Capitol Station Suite 1000 Austin, Texas 78711 Arlington, Texas 76011
- Mrs. Juanita Ellis Lanny A. Sinkin President, CASE 3022 Porter Street 1426 South Polk Street Suite 304 Dallas, Texas 75224 Washington, D.C. 20008 l
Nancy Williams Ms. Billie P. Garde Cygna Energy Services, Inc. Citizens Clinic Director 101 California Street Government Accountability Suite 1000 Project San Francisco, CA 94111 1555 Connecticut Avenue, N.W.
Suite 202 Washington, D.C. 20036
- Herbert Grossman, Esquire ** Ellen Ginsberg, Esquire Alternative Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
. . ** Anthony 2. Roisman, Esquire Mr. James E. Cummins Trial Lawyers for Public Resident Inspector /
Justice Comanche Peak Electric Suite 611 Station 2000 P Street, N.W. c/o U.S. Nuclear Regulatory Washington, D.C. 20036 Commission P.O. Box 38 Glen Rose, Texas 76043 Joseph Gallo , Esquire Isham, Lincoln & Beale Suite 840 1120 Connecticut Avenue, N.W.
Washington, D.C. 20036
.h William A. Horin cc: John W. Beck Robert A. Wooldridge, Esq.
L