ML20128F585
| ML20128F585 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/01/1985 |
| From: | Berry G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-677 OL-2, NUDOCS 8507080282 | |
| Download: ML20128F585 (6) | |
Text
.
p m CORRESPOND W 1
,N July 1, 1985 ESCKE1ED UNITED STATES OF AMERICA USNac NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD %S In the Matter of
)
TIIGYSbRYvI~I
)
BRANCH TEXAS UTILITIES ELECTRIC
)
Docket Nos. 50-445/2 g_L COMPANY, e_t _al.
)
50-446/2
)
(Comanche Peak Steam Electric Station, Units 1 and 2)
FOURTH SUPPLEMENT TO NRC STAFF RESPONSE TO CASE'S REQUEST FOR ADMISSIONS I.
INTRODUCTION On February 4, 1985, Intervenor Citizens Association for Sound Energy (CASE) filed a request for admissions in which it asks the Staff to admit certain facts purportedly found by the Staff's Technical Review Team (TRT) during the course of its review and evaluation of Applicants' construction and quality assurance / quality control activities at Comanche Peak Steam Electric Station (CPSES).
In its March 1, 1985 Response the Staff indicated that the TRT's findings and conclusions regarding the matters within its jurisdiction are set forth in applicable Supplemental Safety Evaluation Reports (SSERs). See Staff Response at 2-3.
At the time the Staff's March 1 Response to CASE'S Admission requests was filed only the SSER concerning Electrical / Instrumentation and Test Program issues had been published. Subsequently, the Staff issued SSER No. 11, which addresses Quality Assurance / Quality Control issues. Consequently, 45 PDR D59
q the Staff is now in a position to respond to CASE admission requests 86, 90, 91, 116 and 123 which relate to these matters. 1/ The Staff's responses are set forth below.
II. NRC STAFF RESPONSE TO SPECIFIC ADMISSION REQUESTS
- 86. The TRT found inconsistency in the application of nuts for SA-325 bolts in that both standard and heavy hex nuts were used. No stipulation wat found which would permit the use of standard (non-heavy) hex nuts. This condition is a potential violation of the Material Speci-fication ASTM A325 (ASTM, Part 4-1974) paragraph 1.5, which provides that
" heavy hex structural bolts and heavy hex nuts shall be furnished unless other dimensional requirements are stipulated...." B&R Drawing No. FSE-000159, sheet 5824, 7 of 2, required the use of ASTM A325 bolts for cable tray hanger number CTH-5824.
STAFF RESPONSE:
Admit.
See SSER 11 at p. 0-257, n.*** and,part4.C.5(p.0-298).
- 90. The TRT found that deficiency reporting procedure CP-EP-16.3 appeared to relate only to craft and engineering personnel and was not directed to noncraft and nonengineering personnel who may have knowledge of reportable items.
Procedure CP-EP-16.3 indicated that the applicable j
manager was responsible for documenting and reporting Deficiency and
-1/
CASE Admissions, 34-85, 87-89,92-115, 117-122, and 124-126 also relate to QA/QC matters. The Staff filed its responses to these requests on June 28, 1985.
4 Disposition Reports (DDRs); but there were no checks or balances to ensure that a manager or a designated substitute would process a DBR.
STAFF RESPONSE:
Deny.
Subsequent to the issuance of the January 8,1985 letter, the TRT " learned that [ deficiency reporting procedure CP-EP-16.3] was not the appropriate procedure for 10 C.F.R.
S 50.55(e) reportability in the area of document control." See SSER 11 at 0-65, n.*.
The TRT's assessment of TUEC's procedures for reporting deficiencies pursuant to 10 C.F.R. 6 50.55(e) is discussed in SSER 11 at i
0-65-67.
- 91. The TRT found that TUEC did not consider the CYGNA audit findings regarding the document control center as appropriate for formal reporting to the NRC pursuant to 10 C.F.R. 50.55(e), as required by procedure CP-EP-16.3, " Control of Reportable Deficiencies."
STAFF RESPONSE:
Deny that CP-EP-16.3 is the applicable procedure for reporting deficiencies pursuant 10 C.F.R. 5 50.55(e). See SSER 11 at
- p. 0-65, n.*.
The TRT's assessment of TUEC's procedures for reporting deficiencies pursuant to 10 C.F.R. Q 50.55(e) is discussed in SSER 11 at 0-65-67.
116. The TRT found that the TUEC procedure for preparation and processing of NCRs did not contain explicit instructions for handling voided NCRs.
STAFF RESPONSE:
Admit with the following clarification: The TRT found TUGC0's procedures provided that voided NCRs be forwarded to the Paper Flow Group NCR Coordinator, "but gave the NCR Coordinator no I
,w-r
--~,,,.v.-.
additional instructions." SSER 11 at 0-162. The TRT also found, however, that this practice "has been corrected."
Id.
123. The TRT found approximately 40 different forms (other than NCRs) for recording deficiencies. Many of these forms and reports were not considered in trending nonconforming conditions.
STAFF RESPONSE:
Admit.
See SSER 11 at P-31.
Re pretfully submitted, i
Gregoryl lan rry b'
Counsel tar N Staff Dated at Bethesda, Maryland this 1st day of July, 1985
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g.
USMC In the Matter of
)
)
E JUL -5 P3:24 TEXAS UTILITIES ELECTRIC
)
Docket Nos. 50-445/2 COMPANY, et al.
)
50-446/gf? G 0F h 4,
(Comanche Peak Steam Electric
)
MSu'Cfi Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " FOURTH SUPPLEMENT TO NRC STAFF RESPONSE TO CASE'S REQUEST FOR ADMISSIONS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 1st day of July, 1985:
Peter B. Bloch, Esq., Chairman
- Mrs. Juanita Ellis Administrative Judge President, CASE Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Commission Dallas, TX 75224 Washington, DC 20555 Renea Hicks, Esq.
Dr. Kenneth A. McCollom Assistant Attorney General Administrative Judge Environmental Protection Division Dean, Division of Engineering P.O. Box 12548, Capital Station Architecture and Technology Austin, TX 78711 Oklahoma State University Stillwater, OK, 74078 Nicholas S. Reynolds, Esq.
William A. Horin, Esq.
Elizabeth B. Johnson Bishop, Libermars Cook, Administrative Judge Purcell & Reyriolds Oak Ridge National Laboratory 1200 17th Street, N.W.
P.O. Box X, Building 3500 Washington, DC 20036 Oak Ridge, TN 37830 Billie Pirner Garde Dr. Walter H. Jordan Citizens Clinic Director Administrative Judge Government Accountability Project 881 W. Outer Drive 1901 Que Street, N.W.
Oak Ridge, TN 37830 Washington, DC 20009 e
F-1 Herbert Grossman, Alternate Chairman
- Mr. Michael D. Spence, President Administrative Judge Texas Utilities Generating Company Atomic San ty and Licensing Board Skyway Tower U.S. Nuclear Regulatory Commission 400 North Olive Street, L.B. 81 Washington, DC 20555 Dallas, TX 75201 Ellen Ginsberg, Esq.*
Robert D. Martin Atomic Safety and Licensing Board William L. Brown, Esq.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Samples Lanny Alan Sinkin
& Wooldridge 3022 Porter Street, N.W., #304 2001 Bryan Tower, Suite 2500 Washington, DC 20008 Dallas, TX 75201 James T. McGaughy Mr. James E. Cummins Southern Engineering Co. of Georgia Resident Inspector / Comanche Peak 1800 Peachtree Street, N.W.
Steam Electric Station Atlanta, GA 30367-8301 c/o U.S. Nuclear Regulatory Commission P.O. Box 38 Atomic Safety and Licensing Board Glen Rose, TX 76043 Panel
- U.S. Nuclear Regulatory Commission William H. Burchette, Esq.
Washington, DC 20555 Mark D. Nozette, Esq.
Heron, Burchette, Ruckert Atomic Safety and Licensing Appeal
& Rothwell Board Panel
- Suite 700 U.S. Nuclear Regulatory Commission 1025 Thomas Jefferson Street, N.W.
Washington, DC 20555 Washington, DC 20007 Docketing and Service Section*
Anthony Z. Roisman, Esq.
Office of the Secretary Trial Lawyers for Public Justice U.S. Nuclear Regulatory Commission 2000 P Street, N.W., Suite 611 Washington, DC 20555 Washington, DC 20036 Joseph Gallo, Esq.
Isham, Lincoln & Beale Suite 8401120 Connecticut Avenue, N.W.
Washington, DC 20036 I
hh bst i GreVory A in 3el 'rf
~ b Counsel f NRC' Staff