ML20134H329
| ML20134H329 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/19/1985 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-329 OL, NUDOCS 8508280369 | |
| Download: ML20134H329 (71) | |
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WTED CORRESP0hd 8/19/85 00LEETED UstGC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'85 MG 26 P12:18 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l
Docket Nos. 50-445Cf77ict er stcRETAoi l
and 50-446 00CKETit4G & SERVlfd.
BRAHM TEXAS UTILITIES ELECTRIC l
COMPANY,'et al.
l l
(Application for an (Comanche Peak Steam Electric l
Operating License)
Station, Units 1 and 2)
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CASE'S OFFER OF PROOF OF LACK OF INDEPENDENCE OF APPLICANTS' LATEST PLAN (CPRT PLAN)
In previous pleadings, CASE has expressed its conviction and. concern that Applicants' most recent iterative get-well plan did not have the independence necessary to resolve the Board's (and CASE's) concerns about the manner in which Comanche Peak has been designed and constructed n /. We discuss them briefly here.
As we indicated in our previous pleadings, we suspected that there is no_ independence criteria for the CPRT effort such as the independent protocol-controlled effort applied to Cygna Energy Services' activities or the criteria suggested by the Licensing Board in its 12/28/83 Board. Order (Quality Assurance for Design) (page 73). As we stated in our 8/14/85 First critique (excerpted from pages 33-34):
n/ See: CASE's 7/29/85 Initial Response to Applicants' 6/28/85 Current Management Views and Management Plan for Resolution of All Issues (page 5 continued on top of page 6, last sentence of top paragraph on page 12, middle paragraph on page 16.
See also: CASE's First Critique of Applicants' Comanche Peak Response Team (CPRT) Plan (attached to CASE's 8/14/85 letter to the Licensing Board), pages 32 through 34.
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.~ CASE submits that such independence criteria did not exist at the time the CPRT members were employed, nor does it exist today (unless it has been provided to the NRC during a secret meeting to which CASE was not privy). This basic and fundamental failure by Applicants and the NRC Staff has allowed the entire CPRT reinspection effort to-become-influenced by the same mindset and outlook which has led to the current indeterminate condition of Comanche Peak. CASE submits that, at this point in time, it is too late to instill true independence into the CPRT reinspection effort.
For this reason, CASE has no confidende in the results -- whatever they may be claimed to be... " (Emphasis in the original.)
. This reinspection relies in part upon either the Applicants' employees or sub-contractors; however, the Applicants cannot be expected to supply self-incriminating evidence which could keep them from obtaining an operating license. There is a special relationship which exists between the Applicants and their sub-contractors. This special relationship precludes true independent activity on the part of such sub-contractors. The Applicants have, on at least one occasion,_
argued that this special relationship exists -- the Lipinsky portion of these hearings (Docket -2)."
CASE now has documented evidence that our concerns regarding lack of independence of the CPRT effort had good basis. On 8/14/85, CASE received from Applicants on discovery copies of contracts "between Texas Utilities Generating Company and organizations performing services for the CPRT" /2/,
We discuss in the following key portions of some of those contracts.
Had we had any remaining doubts about the lack of independence of the CPRT effort, the contracts would have removed them. As can be readily seen, the j
wording of the contracts makes it impossible for true independence to be l
l achieved and maintained while at the same time honoring contractural obligations.
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/2/ Copies of the cover letter from Applicants to CASE were sent to the Service Lists in both Dockets; however, only CASE (in both Dockets) and
.the NRC Staff are shown to have also received the attachments.
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TENERA DIVISION OF TERA CORPORATION (John C. Guibert, Frank Dougherty, Howard A. Levin)
Tenera is a division of the organization from which John Beck was hired in April of 1984, to serve in his present position as Vice President of TUCCO with responsibility for nuclear licensing, nuclear fuels, and quality assurancef3/. Tenera is providing at least three individuals who are in very key positions in connection with the CPRT effort: John C. Guibe-t, Frank Dougherty, and Howard A. Levin.
Mr. Guibert was and is a member of the CPRT Senior Review Team (SRT).
The SRT, consisting of four members (plus one ex-officio member), is tl'e
" governing body" of the CPRT; the Chairman is John Beck. 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. f 4,/.
It is obvious that the concept of independence is one of the primary requisites for the SRT.
A second person supplied by Tenera is Frank Dougherty, who was and is a member of the SRT Support Group. He is Design Adequacy Manager and has the responsibility for coordination and management of the five areas associated with the Design Adequacy Review Team. f5/.
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/3/ See FSAR page 13.1-16, Amendment 55, July 19,1985; and 2/7/85 NRC Staff / Applicants / CASE meeting transcript, page 16, lines 15-17.
f4/ See Applicants' 6/28/85 Current Management Views and Management Plan for Resolution of All Issues, pages 20 and 21.
i f5/ See page 16 of 58 of Appendix A, Rev. O, II. A, of Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Revision 2, June 28, 1985 (CPRT Plan).
See also attached Tenera contract No. CPF-21079, Supplement No. 1, 2/5/85, page 3.
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A third person supplied by Tenera is Howard Levin, who is the Design Adequacy Program Review Team Leader, and was and is the CPRT Review Team Leader for the resolution of Civil / Structural, Mechanical, and Miscellaneous Activities. He reports to the Senior Review Team (SRT).
It is his responsibility to seg to the accomplishment of the design adequacy review team objectives, subject only to the direction of the SRT. f6/
The independence of the CPRT and the SRT is of paramount importance to make a determination as to whether or not Comanche Peak has been constructed and designed such that the public health and safety will not be endangered, whether or not the plant has benefited from an adequate QA/0C program, or to achieving any other objective deemed appropriate by the Licensing Board.
As will be demonstrated in the following, this desired and necessary independence is lacking. CASE has maintained that there is a special relationship which exists between contractor and sub-contractor (which the Applicants have also argued in the Lipinsky portion.of the hearings). And this will be partially demonstrated by the following quotes from contracts received from the Applicants on discovery:
TENERA DIVISION OF TERA CORPORATION P. O. CPF-21079 Original Contract dated 9/13/84 "Tenera shall provide assistance... in completing the necessary licensing actions... to achieve full power licensing..."
(Emphasis added.)
f6/, See Attachment 8, Appendix A, Rev. O, II. A, of Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Revision 2, June 28, 1985 (CPRT Plan).
See also attached Tenera contract No. CPF-21079, Supplement No. 1, 2/5/85, page 3.
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" Scope of Services.
" Identification of licensing issued (sic - assume should be issues).
. " (Emphasis added.)
" Participation in the development of a licensing strategy..."
(Emphasis added.)
" Assistance in the execution of... licensing actions.
" Formal and informal interfacing with the NRC Staff on behalf of TUGC0.
" (Emphasis added.)
" Interfacing with other... parties... to meet licensing objectives" (Emphasis added.)
" Intended Use:
" Licensing
" Provide assistance in completing... actions for CPSES tc1 achieve full power licensing." (Emphasis added.)
Contract Dated 2/5/85, Supplement No. 1:
"... Task No. 1 - General Licensing Support
. description... remain unchanged... work is performed at the direction and request of Mr. Beck."
(Emphasis added.)
These quotes indicate how the contract between Tenera and the Applicants has been structured to assure that Tenera employees must support the licensing activity, with an overall objective of obtaining an operating license, if they are to meet their contractural obligations. This is in direct conflict with the implied objective of the CPRT Plan of assuring safety.
Additionally disturbing is the fact that Applicants' John Beck and Tenera's Howard Levin had a working relationship with one another established at Midland, as can be noted from the following quotes:
"MR. BECK:
Mr. Levin in his consulting practice most recently served as a project manager for the Midland Independent Design and Construction Verification Program; which, incidentally, I served on 5
when I was with TERA Corporation [ parent company of Tenera] as a principal in charge of this effort."
-- from Transcript of 2/7/85 NRC Staff / Applicants / CASE meeting, Tr. page 18, line 23, through page 19, line 3 At Comanche Peak, as at Midland, Howard Levin is once again reporting to John Beck, but with an important difference. At Midland, they both clearly represented the same interests. At Comanche Peak, their actions should be completely independent. Obviously, this would be most difficult, if not impossible, to achieve -- no matter how well-intentioned they might be.
The previous facts are of significant concern in and of themselves and could jeopardize the effectiveness of the entire CPRT effort. Already it is obvious that the desired independence does not exist.
However, the Tenera connection does not end here. Literally every so-called " third party" individual associated with the design ciequacy program is an employee of Tenera. These people are:
H. Levin, J. Honekamp (who reports to H. Levin), F. Dougherty (who also reports to H. Levin), and the following (who report to F. Dougherty):
C. Mortgat, T. Snyder, F. Schofer, M. Jones, and E. Blackwood -- as may be noted from the following chart from the CPRT Plan.
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ATTACilMENT 8 CPRT DESIGN ADEOllACY PROGRAM ORGANIZATlON g ;y g w? 5
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" 2' MECHANirAL ELECTRICAL.1&C PROGRAMMATIC /
y, CIVIL /STRt>CitJRAL PIPitlG/St PPORTS SYSitMS SYSTFMS CENERic cm COODDINA TOR COORDINAT OR At O COMPONrNTS Ato COMPONEt3TS IMPLICATIONS 3.y COOltDitlA T OR COORDINATOR COORDINATOR o
C. Mor egot T. Snyder F. Schof er M. Jones C. Blockwood
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=g Tif.CO St PPORT STAI A wFBSTER TlIGrO 9 PPORT TUCCO St PPORT Tt IGCO St PPORT 5 PORTS COOllDitlAlOR COORDINATOR COORDINATOR COORDitlATOR PI,PI R. Hooton F. Mniklesi W. Vogelsong J. Resting E.Siskin
These lower level Tenera people must surely feel the underlying and perhaps unexpressed pressure which cannot help but exist under a contract worded such as this.
In the real world, one cannot expect or hope for true independence on the part of these individuals when they are all so closely intertwined, no matter how well-intentioned they may be.
Independence cannot and does not exist under such circumstances.
EVALUATION RESEARCH CORPORATION (ERC)
(John L. Hansel)
Another key individual in the CPRT effort is John L. Hansel of Evaluation Research. Corporation, the Review Team Leader for QA/0C, reporting to the Senior Review Team (SRT). As with Tenera, the contractural obligations imposed by Applicants upon the organization by which !!r. Hansel is employed make it totally impossible for him to achieve true independence while at the same time abiding by the contract. The following quotes from the Evaluation Research Corporation (ERC) contracts will demonstrate this point:
EVALUATION RESEARCH CORPORATION (ERC)
P. O. CPF-21635 Original Contract dated 11/14/84 "Mr. John L. Hansel will be.
. Review Team Leader for 0A/0C and will report to.
(SRT)... to work within the TUCCO organization and utilize existing personnel as much as possible and feasible.
. his efforts are to be conducted in such a manner that he is able to provide an independent assessment and evaluation of this overall ef fort."
(Emphasis added.)
" Review the Program Plan, NRC correspondence and other related material to sufficiently understand the issues... assure that the approach.
is effective.
Provide TUGC0 with any recommendations for
[
improvement.
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" Keep the Senior Review Team apprised... via periodic meetings and formal reports. A final report will be prepared by ERC upon completion of the project.
"ERC will conduct audits and perform surveillance.
. to provide assurance that the project is being conducted in accordance with the plan and that the plan.
. will satisfy the TUGC0 objectives. The audits and surveillance activity will be kept at a minimum, and will only be conducted at the direction of Mr. Hansel.
. tailored in a manner that will allow Mr. Hansel to speak authoritatively on key aspects of the program." (Emphasis added.)
"If required, Mr. Hansel will testify for TUGC0... before the Atomic Safety & Licensing Board.
"ERC will recommend the use of independent inspectors on a case by case basis when directed by the SRT... In all cases, TUGC0 approval will be obtained prior to engagement..." (Emphasis added.)
Contract dated 3/20/85, Supplement No. 1 /7/:
. to amend service period & fee schedule.
" Amended Service Period "ERC personnel shall be available onsite November 8, 1984 and extend through December 31, 1985, with an option for TUCCO to renew.
~" Job statt-up (on or before 4/1/85) - Due to need to proceed with work and existing contractural obligations, the above overtime rates apply.
." (Emphases added.)
As may be noted from the underlined portions, Mr. Hansel's contractural obligations jeopardize his independence. TUCCO objectives -- not safety objectives -- must be satisfied. TUGCO's present organization and personnel are to be relied upon -- unless the SRT specifically directs otherwise in each instance.
Mr. Hansel is to testify for TUGC0 -- and for no other purpose.
Here again, no matter how well-intentioned one might be, it would be impossible to achieve the goals of independent assessment and evaluation
/7/ We note that CASE did not receive page 4 of this document.
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while complying with the other restrictions built into this contract. The preceding is especially disturbing when considered in light of other statements made during the 6/13/85 NRC Staff / Applicants meeting /8/.
Essential independence has not and cannot be achieved.
In addition, we call the Board's attention to the comments of Ms.
Billie Garde during the 6/13/85 NRC Staff / Applicants meeting /9/:
"MS. CARDE: My fifth point, again, went to Mr. Hansel.
Some of the things that you said, I'm very concerned that you're relying on your Braewood (sic - should be Braidwood) work. Because I have just done a little stint of Braewood (sic) work myself, and I'm sure, as you're aware, that ERC did not find a lot of problems. Then the NRC did find a lot of problems.
"The reinspection program was stopped. There's pending enforcement action. And now the Braewood (sic) program is again essentially on track. But I think there was (sic) some programmatic deficiencies at Braewood (sic) which I don't want you to repeat here. And I'm i
concerned that that's going to happen.
1 "And I'm also concerned that if you say it's not going to happen, that you explain why,~ you know, the same type of program is acceptable without making some kind of changes."
I STONE AND WEBSTER ENGINEERING CORPORATION (SWEC)
One of the areas of most concern to CASE has to do with Stone and L
Webster's evaluation (and possible destruction and redesign) of pipe l
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/8/
See 6/13/85 Transcript, Volume II, Afternoon Session, pages: 155, lines 17 through 25; 158, line 10, through 159, line 20; 161, lines 11-17;.
167, lines 6 through 12; 168, lines 22 to 25; 195, lines 1 through 4; 195, line 17, through 198, line 21; 199, line 24, through 200, line 5; 201, line 10, through 202, line 1; 231, lines 20 through 22; 249, line 5, through 250, line 6.
/9/ See Transcript of 6/13/85 NRC Staff / Applicants meeting, Volume II, Afternoon Session, page 291, line 12, through page 292, line 2.
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o su'pports, as discussed in previous pleadings /10/. We will not repeat all our comments here, but incorporate them herein by reference.
As with the other contracts discussed herein, the terms and conditions imposed by Applicants in these contracts make it impossible to achieve true independence, as demonstrated by the following quotes:
STONE AND WEBSTER ENGINEERING CORPORATION P. O. CPF-12658-S Original Contract dated 7/22/85
"... for technical engineering services in support of...
(TUGCO)['s]... (CPSES) project
"... perform pipe stress and pipe support qualifications in order to address technical concerns on the piping and pipe support designs.
"Upon initiation.
. work shall proceed without hold points for approval by outside parties.
If new technical issues are raised.
SWEC shall address them in parallel...
" Complete implementation of this scope of work shall demonstrate the technical adequacy of the piping and pipe support designs at (CPSES).
." (Emphasis added.)
. Gibbs and 11111 - SWEC Letter of Agreement pertaining to their activities in suport of TUCCO's CPSES project is attached hereto.
and forms an integral part of this purchase order."
/11/
Contract dated 8/12/85 - Supplement No. I
"... B.
... to restate the ' Scope of Work'... and make corrections.
/10/ See: CASE's 7/29/85 Initial Response to Applicants' 6/28/85 Current Management Views and Management Plan for Resolution of All Issues, last paragraph on page 5 continued on page 6, last paragraph on page 13 through first full paragraph on page 15, middle paragraph on page 16, and first paragraph on page 21; see also CASE's 8/14/85 Motion for Immediate Board Order for Applicants to Preserve Evidence.
/11/ This Letter of Agreement was not attached to CASE's copy of the contract, nor were any of the other attachments referenced in the various contracts.
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"... ' Scope of Work, General' Section as stated on pages 1 and 2 is hereby deleted.
' Scope of Work, General' is restated as follows:
. shall demonstrate the technical adequacy of the piping and pipe support designs.
(Emphasis added.)
As stated previously, the terms and conditions imposed by Applicants in the contract with Stdne & Webster make it impossible to assure true independence while still complying with contractural obligations -- however well intentioned one might be.
Should the current piping and pipe support designs at Comanche Peak prove inadequate, Stone and Webster's mandate and contract do not call for them to so advise the Applicants (or the Licensing Board) -- to the contrary (as will be discussed in more detail in CASE's 8/19/85 Offer of Proof in Support of Motion to Preserve Evidence, being sent at the same time as this pleading), their contract is worded such that they will avoid confirming that the current pipe supports' designs are inadequate.
Based upon what is presently known regarding the current pipe support designs, considered in conjunction with the specific wording stated above and elsewhere in the contracts, there is an extremely good probability that many of the pipe supports will be removed and replaced with new di Signs.
This makes CASE's request for the Board to order Applicants to preserve physical (as well as documentary) evidence even more urgent /12/.
/12/ See CASE's 8/14/85 Motion for Immediate Board Order for Applicants to i
to Preserve Evidence. See also CASE's 8/19/85 Offer of Proof in l
Support of Motion to Preserve Evidence, being sent at the same time as this pleading.
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The wording of the contract also makes even more alarming the statements made by Ed Siskin of Stone and Webster, the Piping and Pipe Supports Program Manager, during the 6/14/85 NRC Staff / Applicants meeting
/13/:-
(Following a discussion regarding the possible use of code cases):
"MR. SISKIN:
I'm aware th'ey're being processed.
But I'm also aware that we're under an extremely tight constraint. We want to get this work done."
(Emphases added.)
(Following a discussion regarding the possibility of changing supports which took more time to analyze than to just change them out):
"MR. SISKIN:... Mr. [ William G.] Counsil (new TUCCO Executive Vice-President] has been very explicit about getting the thing done properly, but getting it done quickly as well."
(Emphases added.)
It is apparent that, consciously or subconsciously, Mr. Siskin is already feeling the pressure (which in this instance even appears to have been verbally expressed).
It is obvious that no matter how well intentioned one might be, under such circumstances and such contractural language, true independence would be difficult if not impossible to attain and maintain.
CASE also calls the Board's attention to the following discussions during recent NRC Staff / Applicants meetings, which also are cause for concern. There was much confusion and discussion during the /14/85 meeting l
regarding exactly what Stone and Webster was going to be doing regarding the piping and pipe supports, as well as exactly what Ebasco was going to be doing regarding the cable tray supports /14/.
/13/ See Transcript of 6/14/85 NRC Staff / Applicants meeting, Volume II, Afternoon Session, page 192, lines 4 through 6, and page 195, lines 17 through 19.
/14/ See Transcript of 8/14/85 NRC Staff / Applicants meeting, Volume II, Afternoon Session, page 171, line 24, through page 175, line 14.
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Another area of concern for CASE has to do with the individuals with whom Stone and Webster will be working.
Mr. Siskin has stated that Stone and Webster's efforts were going to be overviewed by Cibbs & Hill (the architect of record), and by the Applicants (the project), in particular by Mr. John C. Finneran, who works for Mr. Joe George.
Mr. Siskin stated that he reports directly to Mr. William Counsil and that his (Mr. Siskin's) project manager reports to Mr. George and his project (Applicants) /15/.
Apparently the " third party" oversight is to be provided by Mr. Levin of Tenera, and by Robert L. Cloud Associates. CASE has shown herein that Tenera does not have contractural independence; we will be investigating the independence of Robert L. Cloud Associates through discovery.
CASE was and is especially concerned about the involvement of Mr.
Finneran regarding pipe supports (as well as of Dr. Iotti regarding cable tray supports), and we were quick to point this out to the Applicants and the NRC Staff /16/.
It appears that the Applicants and NRC Staff have not heeded and answered our concerns.
As we stated on 6/14/85, our concern is that Mr. Finneran and Dr. Iotti have both filed extensive affidavits in support of many of Applicants' Motions for Summary Disposition regarding pipe support and other issues.
They have been very close to these issues, to the point that they now have a vested interest in the outcome of any reinspections, reanalyses, conclusions, etc. which may flow from the CPRT efforts. CASE has strongly
/15/ See Transcript of 6/14/85 NRC Staff / Applicants meeting, Volume II, Afternoon Session, page 201, line 13, through 202, line 17.
/16/ See Transcript of 6/14/85 NRC Staff / Applicants meeting, page 248, line 19, through 249, line 4 14
questioned many of their statements in the affidavits, and the Board has yet to rule on whether or not some of those statements may even constitute material false statements.
It may be that these two gentlemen would be able to maintain their objectivity under these circumstances (and CASE does not want to speculate regarding this), but it would obviously be very difficult if not impossible.
In any event, their involvement at this point with the-CPRT efforts on both cable tray supports and pipe supports is very disturbing, and it robs the CPRT efforts of whatever remaining shread of independence might remain after all other factors discussed here (and perhaps yet to be brought to the Board) are taken into consideration.
EBASCO SERVICES, INCORPORATED Ebasco has been involved at Comanche Peak for some time. As discussed in the preceding section (pages 14 and 15) on Stone and Webster, it is Ebasco's Dr. Robert Iotti who has filed sworn affidavits in support of many of Applicants' Motions for Summary Disposition on pipe supports and other issues. This is important here because Ebasco (and Dr. Iotti in particular) are also intimately involved in the CPRT effort, as discussed during recent meetings between the NRC Staff and Applicants /17/.
It appears that Ebasco is going to be doing the " design basis activities" regarding cable tray and conduit supports, that they will identify modifications which need to be made, conduct design activitten required for those modifications, and may or may not do analyses.
/17/ See Footnote 15; see also Transcript of 6/14/85 NRC Staff / Applicants meeting, especially page 174, line 4, through 175, line 13.
(Note that Ebasco is spelled "Abasco" in the transcript.)
See also Figure VIII-2, Appendix C, of CPRT Plan.
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CASE is very concerned about Ebasco's involvement in the CPRT efforts in regard to the cable tray supports, and (as we did regarding Mr. Finneran) 4 we have been quick to point this out to the Applicants and the NRC Staff (see Footnote 16).
It appears that the Applicants and NRC Staff have not heeded and answered que concerns once again.
Applicants have not claimed that Ebasco is independent, and the Ebasco contracts bear out their total lack of independence, as can be seen from the following excerpts:
l EBASCO SERVICES, INCORPORATED contract dated 5/11/84 /18/
"... established to provide TUCCO with various services, to be 1
defined by TUGCO, to support the... (CPSES)... for... (1) year... from January 1, 1984 and extending through December 31, 1984 "Ebasco shall provide field service personnel as required by TUCCO to provide services for the followingt l
" Scope of Services
. 2.
Consulting for ASLB activities specifically concerning the Walsh/Doyle allegations.
"3.
Consulting for other various ASLB activities...
"4.
Censulting for TUCCO nuclear Itcensing.
. 8.
Consulting for piping thermal expansion monitoring program...
" Initiation of Services
" Additional services... on a case-by-case basis by written supplement.
" Control and Approval "Ebasco will function in cooperation with and subject always to 4
j the direction and control of TUCCO's authorized officers or TUCCO's designated representatives, and will consult with TUCCO in l
advance of important decisions..." (Emphases added.)
P
/18/ This is the earliest dated contract supplied to CASE 1 however, we believe there are earlier contracts between Applicants and Ebasco. We will be pursuing this on discovery.
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CASE has quoted excerpts from some of the contracts. We are attaching copies of the actual contracts for Tenera, Evaluation Research Corporation, i
and Stone & Webster, which we believe are more than adequate to prove our poicts. There are still other matters which have been raised by documents recently received on discovery which are potentially just as disturbing.
CASE will be exploring these through follow-up discovery and presenting additional documents in a more comprehensive package and at an appropriate j
time later. The information discussed herein, however, was of such l
importance to any consideration by the Board of the CPRT Plan that CASE believed it vitally important to get at least some of it into the Board's i
hands immediately.
i It should be understood that CASE does not mean to impune the integrity I
of the participants in the the CPRT etfort. However, we maintain that (for l
the reasons discussed in detail herein) it is now too late for the outside consultants Applicants have hired to become truly independent.
Even were all of the contracts to be completely rewritten, with proper and sufficient independence criteria plainly stated therein, these organizations and j
individuals already know what the utility wants and expects of them.
It is
)
too late to say, " Forget what you just read and what you have been told, and i
do this instead." They already have their marching orders -- to get i
1 Comanche Peak licensed.
l' There is no wording in any of the contracts which even suggests that what is desired is a truly independent assessment of safety. Safety is not one of the criteria set forth in the contracts. To the contrary, what g 4
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built into the contracts, forming an integral part of them, is to obtain an operating license for the Applicants.
The Applicants' carefully worded but extremely misleading phraseology implies (although it does not actually state) that their " third party" reinspection ef forts
- offer independence /19/. As we have now proved, this is not the case -- the Board must view the Applicants' CPRT Plan (at best) as nothing more than yet another effort by Applicants (rather than an independent effort), without any semblance of independence. Their third party review must be equated to what it really ist a review by TUGC0 itself which only implies, but does not deliver, independence.
It is important for the Board to take note that the contracts discussed herein and the approach taken by Applicants has occurred under Applicants' new management. These are the people who will be around and in charge for the long haul and after the plant goes into operation. New TUCCO Executive Vice President William Counsil has specifically stated that he plans to be
/20/, and it is to be assumed (based on what is presently known) that many
/19/ Generally Applicants do not actually claim independence (see, for instance, Transcripts of recent meetings:
7/13/85, Vol. I, Morning Session, page 14, line 23, through page 15, line 8; page 16, lines 4-8; page 53, lines 8-20; page 78, lines 13-18; page 87, lines 11-14; page 115, linen 13-23; and 7/14/85, Vol. I, Horning Session page 43, line 23, through page 44, line 2.
. with few exceptions where they seem to be claiming independence, at least to some extent:
7/13/85. Vol. I, Morning Session, page 73, line 17, through page 74, line 1; page 86, lines 14-21; and 7/13/85, Vol. II, Afternoon Session, page 246, line 9, through page 247, line 1.
/20/ See Transcript of 6/14/85 NRC Staff / Applicants meeting, Volume II, Atternoon Session, page 260, lines 21-23.
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W of the same individuals who have been at the plant for years, who have been involved with making Comanche Peak the plant it is today, and who are currently involved with the CPRT effort, will also be around for the long haul and during operation.
In CASE's 8/15/85 Proposal Regarding Design / Design QA Issues, CASE urged that the Board require Applicants to inform the Board exactly what their intentions are regarding Cygna's role in the design review of Comanche Peak /21/. CASE's concern is well founded. During the 6/13/85 NRC Staff / Applicants meeting, (although the discussion was not too clear) there were disturbing indications that Cygna is somehow going to feed their concerns into the CPRT program, turn them over to the CPRT for further development and resolution, then reappear to approve the resolution suggested by the CPRT, which Cygna would then include in its Thase 4 Report, thereby presenting to the Board the same identical solution as the CPRT will present in its report. This means that Cygna will essentially stop working on the issues now before them.
Nor will they determine the root causes of l
identified problems, whether or not they are programmatic in nature, nor determine the optimum resolution in Cygna's judgement. Cygna will be presented with the CPRT's resolution and will be put in the position of either accepting or rejecting, not determining for themselves the optimum i
l l
/21/ See CASE's 8/15/85 Proposal Regarding Design / Design QA Issues in Response to Applicants' 6/28/85 Current Management Views and Management Plan for Resolution of All Issues, page 4, item 8.
19
solution. Nor will either the CPRT or Cygna follow through on the implementation of any suggested remedies /22/.
What appear to be negotiations between Cygna and the Applicants (CPRT) regarding these matters may also have jeopardized the independence of Cygna.
There are indications that there will be frequent discussions and/or meetings between the CPRT and Cygna regarding these matters /23/. And during the 6/14/85 meeting, there were indications that there had already been considerable discussion between IUGC0 and "the independent assessment program personnel" (Cygna) /24/.
As the Board is well aware, telecoms, transcripts, or other memorialization is supposed to be employed for any such discussions or meetings.
The dates of the contracts are further evidence of Applicants' misrepresentations to the Board and CASE. As can be seen, Tenera's initial contract was dated 9/13/84, and Evaluation Research Corporation's (ERC's) initial contract was dated 11/14/84.
In ERC's Supplement No. I to their contract, Applicants initiated overtime due to the need to proceed with work and existing contractural obligations on or before 4/1/85. A substantial
/22/ See Transcript of 6/13/85 NRC Staff / Applicants meeting, Volume I, Morning Session, page 66, line 2, through 68, line 24.
See also Transcript of 6/14/85 NRC Staff / Applicants meeting, Volume I, Morning Session, page 14, line 21, through page 17, line 20.
/23/ See Transcript of 6/13/85 NRC Staff / Applicants meeting, Volume I, Morning Session, page 66, line 2, through 68, line 24.
/24/ See Transcript of 6/14/85 NRC Staff / Applicants meeting, Volume II, Afternoon Session, page 169, lines 2 through 7.
20
v.
O amount of work has been ongoing for an appreciable length of time.
Applicants have apparently already been hard at work on this effort and much has apparently already been done.
At the same time Applicants were telling the Licensing Board that they needed more time to get their new attorneys up-to-speed.
CASE continues to contend that harm has come to CASE because CASE's Motions for Summary Disposition have not been answered by either Applicants or NRC Staff in a timely fashion, nor have Applicants or NRC Staff answered CASE's responses to Applicants' Motions for Summary Disposition. Nevertheless, Applicants have found sufficient time to conceive, contract for, and work overtime on the CPRT Plan. This work was conceived as long ago as October 5, 1984 (as documented in Item II.a Appendix C, of CPRT Plan). Because of these developments, CASE is now of the opinion that Applicants in fact never had any intention of responding on the Motions for Summary Disposition, but instead to rely on arguments of mootness to circumvent the agreed-upon process.
CASE notes that the attached and referenced contracts were received on 8/14/85, the day after the NRC Staff released (in Dallas) their Staff Evaluation of the CPRT Plan. CASE suspects that the NRC Staff had not reviewed those contracts at the time the Staff issued its Evaluation.
CASE is perplexed that the NRC Staff does not appear to be requiring the same protocol and independence criteria for Comanche Peak as they have for other plants throughout the country in similar circumstances.
21
e e CASE is concerned that some top level NRC Staff personnel have convictions which may influence the proposed reinspection effort. CASE would like to call the Board's attention to the following statement by Mr.
Harold Denton to CASE President Juanita Ellis to the effect that "we want to keep this [ reinspection effort) out of the hearings process as much as possible" (emphasis added) /25/.
CASE is of the opinion that any properly conceived, approved, and conducted reinspection effort must be considered to be a part of the hearings process.
Further, the information provided by CASE to the Board in the past couple of weeks offers strong support for CASE's position that it is imperative that the Board be responsible for any reinspection effort.
In particular (and especially in light of what has been revealed by these contracts), the personnel responsible for conceiving and conducting the actual reinspection should have direct contractural obligations with the Licensing Board, not with the Applicants.
Respectfully submitted, us~, Ma M
MEs.)~Juanita Ellis, President g(ASE (Citizens Association for Sound C
Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446
/25/ Mr. Denton's comment was made during lunch (with others present) during a site tour on which CASE accompanied him on May 23, 1985. The quoted portion is, we believe, accurate; certainly there is no question as to the substance of his comment.
22
-Pm s
Attachments (to Board, Applicants, NRC Staff, and Docketing and Service only)
Contracts: Tenera Division of Tera Corporation P. O. No. CPF-21079, dated 9/13/84 and Supplement No. 1, dated 2/5/85 Evaiuation Research Corporation P. O. No. CPF-21635, dated 11/14/84 and Supplement No. 1, dated 3/20/85 Stone and Webster Engineering Corporation P. O. No. CPF-12658-S, dated 7/22/85 and Supplement No. 1, dated 8/12/85 23
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DOLKETED UNITED STATES OF AMERICA 85 AUG 26 Pl2:19 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD GFFICE OF SECRt.I An '
00CXETING & SEPVir:f.
In the Matter of
}{
BRANCH
}{
TEXAS UTILITIES ELECTRIC
}{
Docket Nos. 50-445 COMPANY, et al.
}{
and 50-446 (Comanche Peak Steam Electric
}{
Station, Units 1 and 2)
}{
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Offer of Proof of Lack of Independence of Applicants' Latest Plan (CPRT Plan) have been sent to the names listed below this 19th day of August
,198 5,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
Federal Express where indicated by **
- Administrative Judge Peter B. Bloch
- Nichola3 S. Reynolds, Esq.
U. S. Nuclear _ Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036
- Judge Elizabeth B. Johnson Oak Ridge National Laboratory
- Geary S. Mizuno, Esq.
P. O. Box X Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclear Regulatory
- Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.
Architecture and Technology
- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814
- Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennen.ree 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
- * -Administrative Judge Herbert Grossman U. S. Nuclear Regulatory Commission
'4350 East / West Highway, 4th Floor Bethesda, Maryland 20814 I
<J o Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Mr. Robert Martin
- Anthony Z. Roisman, Esq.
Regional Administrator, Region IV Trial Lawyers for hablic Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr.,. Suite 1000 Washington, D. C.
20036 Arlington, Texas 76011 Mr. Owen S. Merrill Lanny A. Sinkin Staff Engineer 3022 Porter St., N. W.,
- 304 Advisory Committee for Reactor Washington, D. C.
20008 Safeguards (MS H-1016)
U. S. Nuclear Regulatory Commission Dr. David H. Boltz Washington, D. C.
20555 2012 S. Polk.
Dallas, Texas 75224 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Sampels William Counsil, Vice President
& Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 2500 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq.
Ropes & Gray Docketing and Service Section 225 Franklin Street (3 copies)
Boston, Massachusetts 02110 Office of the Secretary U. S. Nuclear Regulatory Commission Ms. Nancy H. Williams Washington, D. C.
20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Government Accountability Project San Francisco, California 1901 Que Street, N. W.
94111-5894 Washington, D. C.
20009 Mark D. Nozette, Counselor at Law Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson Street, N.
W.,
Suite 700 Washington, D. C.
20007 O Ua fUQ gifs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 1
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OWNER SHALL NOT BE ENTITLED TO X l-
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PAGE Oy o
P. O. NO. -
PURCHASE ORDER CONTINUATION SHEET ITEM WN NET TOTAL U/I DESCRIPTION NO.
WANTED UNIT PRICE
' ITEM PRICE 4
C. COMPREHENSIVE AUTOMOBILE LIABILITY 5100,000.00 BCDILY INJURY EACH PERSO41
$300,000.00 EACH OCCURRENCE PROPERTY DAMAGE'
$ 50,000.00 EACH OCCURRE' ICE D. EMPLOYER LIABILITY - $100,000.00 I
$1,000,000.00 E. EXCESS LIABILITY COMBINED SINGLE LIMIT SELLER SHALL FURNISH C5TI' ICATE OF THE FORE-F GOING INSURANCE TO BUYER, PROVIDING THIRTY (30) DAYS NOTICE SY REGISTERED MAIL T0 BUYER s
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MAIL CERTIFICATION TO:
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c' TEXAS UTILITIES GENERATING COMPANY P. O. BOX 1002 GLEN ROSE. TEXAS 76043 AlTH:' EXPEDITING DEPARTHENT
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BY T. V. EVANS AT WHICH TIME TERMS AND
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THE FOLLOWING DOCUMENTS ARE ATTACHED HERETO AND
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.e 9.n.z-FORM A PART OF THIS PURCHASE ORDER:
1)
TENERA PROPOSAL TR-84-4180.,
2)
. TERA CORPORATION FEES FOR PROFESSIONAL.
SERVICES. DATED AUGUST-30, 1984 3)
TERA CORPORATION CATEGORY AVERAGE PAYROLL.-
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PURCHASE ORDER CONTINUADON SHEET
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CPF-21079 AI*
! TEM QUANTITY UN DESCRIPTION-UNIT PRICE ITEM PRICE NO.
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RESUMES FOR DON X. DAVIS, JOHN GUIBERT AND HOWARD LEVIN.
INTENDED USE:
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LICEMSING PROVIDE ASSISTANCE IN COMPLETING THE NECESSARY LICENSING ACTIONS FOR CPSES TO ACHIEVE FULL POWER LICENSING.
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. b DIVISION OFTEXAS UTILITIES ELECudCCO:.M -c -
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w-ORIGINAL. ORDE.8 INCLVOING AMENO-r
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P.O. Box 1002. Glen Rose. Texas 76043 c'
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SMIPMENT PROM 8SEO SY
- ORIGINAL CONMR.4 Af TOM 2-5-85 1-2'-9230-940000-108 NOT APPLICA3LE
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. rTERERA CORPORATION. -
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'T l A DIVISION OF TERA CORPORATION NO CHANGES IN OR CANCELLATIONS OP-PURCHASE ORDERS WILL BE RECOGNIZED 0.
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MENT FORM ISSUED ONLY SY THE PUR.
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CHAslN O EPA R W ENT.
QTTN: JOHN C. GUIBERT
_j R 35381 CONFIRMED TO: JOHN C. GUIBERT 415-845-5200
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VENDOR WILL SIGN AND RETURN CARBON COPY OF THIS SUPPt.EMENT' h~~.
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THE PURCHASING DEPARTMENT H AS M ADE TH E FOLLOWING CH ANGES IN THE ABOVE NUMBERED PURCH ASE ORDER -
ITEM QUANTITY NET
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ISSUED T0-RESTATE THE " SCOPE OF SERVICES"
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TENERA CORPORATION TO CONTINUE ASSISTING THE--
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TEXAS UTILITIES GENERATINGr COMPANY (TUGCO)
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IN COMPLETING THE NECESSARY LICENSING ACTION FOR COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) 10 ACHIEVE FULL.PO.WER LICENSING.
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SCOPE OF SERVICES, c -.~ ~... - C ' Y :
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. GENERAL LICENSING SUPPORT
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4CCOMMODATE SMALL SUB-TASKS- (E.G., CONSULTATION
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(8171897-488f EX*1*T I j'~ j,Ml'/,,(,
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SUPPLF. MENT NO.
PURCHASECRDER SUPPLEMENT CONTINUATION SHEET CPF 21079 L
NET TOTAI.
ITEM QUANTITY UI DESCRIPTION UNIT PRICE -
ITEM PRICE NO.
WANTED
.t TASK NO. 2 - CYGNA RESPONSE' SUPPORT THERE ARE FOUR TOPICS RELATED TO THE CYGNA IDVP ON WHICH TENERA HAS BEEN PROVIDING MD CONTINUES TO PROVIDE SUPPORT TO TUGCO:
..c-o MASS PARTICIPATION o
GENERIC STIFFNESS -
o CABLE TRAYS / SUPPORTS o
CONDUITS / SUPPORTS.
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THE SCOPE OF TENERA. ACTIVITIES RELATED TO THIS TASK HAS INCLUDED THE FOLLOWING: -
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IDENTIFICATION AND ASSESSMENT OF OPTIONS
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FOR RESOLUTION OF CYGNA CONCERNS; J
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EVALUATIONS, MD ANALYSES DEVELOPED AS
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'I' TERFACE WITH NRC, CYGNA,'AND ASLS.
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TENERA'S ACTIVITIES RELATED TO THE MASS M.
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72 CABLE TRAYS, CONDUITS,' AND ASSOCIATED SUPPORTS'.. 7J-:F ARE CURRENTLY IN PROGRESS." IN ADDITION,'TENERA m '-
IS ASSISTING TUGC0 IN THE DEVELOPMENT OF THE SHORT TERM PROGRAM FOR THE PREPARATION OF THE SEISHIC. HARGIN SPECTRA REPORT.'
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TASK' NO. 3 - NRC-TRT RESPONSE SUPPORT-(SRT AND SRT SUPPORT GROUP)
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1984. :INITTIAL ACTIVITIES INCLUDED PROVIDING
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P. O. NO.
SUPPLEMENT NO.
PuncNass onoEn sUPPLEM ENT CONTINUATION SH EET CPF 21079 1
Ull
, DESCRIPTION UN RICE ITE. PR CE PRESENTATION OF.THE CPRT PROGRAM PLAN AND THE
)
ISSUE-SPECIFIC' ACTION PLANS FOR THE
?IVIL/ STRUCTURAL, ELECTRICAL, MD TESTING PROGRAMS AREAS.
SIMILAR ACTIVITIES WILL
'ONTINUE AS ADDITIONAL NRC-TRT ISSUES ARE C
PROVIDED TO TUGCO. MR. JOHN GUIBERT OF TENERA iAS SERVED MD WILL CONTINUE TO SERVE AS A
.4 EMBER OF THE CPRT SENIOR REVIEW TEAM.
EIMILARLY, HR. FRANK DOUGHERTY OF TENERA HA5 5ERVED AND WILL CONTINUE TO SERVE AS A MEMBER
)F THE SRT SUPPORT GROUP.
TASK N0; 4 - NRC-TRT RESPONSE SUPPORT (RTL AND
~
1TL SUPPORT STAFF FOR CIVIL / STRUCTURAL, 4ECHANICAL, AND HISCELLANE005 ISSUES THIS TASK COMENCED IN OCTOBER 1984, SUBSEQUENT TO HEETINGS WITH THE HRC STAFF RELATED TO
.1
.~
[lEVISION 0 0F THE CPRT PROGRAM PLAN AND ISSUE-SPECIFIC ACTION PLANS.. MR. HOWAPD LEVIN 0F TENERA HAS SERVED MD WILL CONTINUE TO SERVE
~
~ _;
s AS THE CPRT REVIEW TEAM LEADER FOR THE 3
tESOLUTION OF CIVIL / STRUCTURAL, HECHANICAL, MD l
IIISCELLANECUS ISSUES. ACTIVITIES UNDER THIS
(
TASK ARE THOSE NECESSARY FOR HR. LEVIN TO EXECUTE HIS RESPONSIBILITIES AS SET FORTH IN REVISION 10F THE CPRT PROGRAM PLAN IN C
JD(ECUTING THESE RESPONSIBILITIES, NR. LEVIN
~<
' WILL CONTINUE TO UTILIZE THE SERVICES OF e.-
OTHERS.. IT IS ANTICIPATED THAT CONTRACTUAL
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ARRANGEMENT FOR PERSONNEL FROH OTHER ORGANIZATION IDENTIFIED BY HR.. LEVIN TO WORK ON "HIS TASK WILL BE HANDLED SEPARATELY., 27.G.jf
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AMENDED FEE SCHEDULE. Q. -q. : r " ~ -
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TO THE TOTAL l
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ESTIMATED COST FOR SERVICES TO BE PERFORMED UNDER THIS PURCHASE ORDER CPF 21079.
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PREVIOUS TOTAL ORDER PRICE
.THIS SUPPLEMENT NO. 1 *
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SUPPLEMENT NO.
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l CPF 21079 1
NET TOTAL OhW y/t DESCRIPTION UNIT PRICE ITEM PRICE TE TENERACbRPORATIONSHALLINVOICETEXAS
~
UTILITIES GENERATING COMPANY BY IDENTIFYING PURCHASE ORDER SUPPLENENT HO. AND TASK NUMSER.
~
AMENDED SERVICE PERIOD THE ESTIMATED SERVICE PERIOD SHALL EXTEND-THROUGH HARCH 31, 1985.
EXPEDITERS AND INSPECTORS ARE ENTITLED TO ASK -
FOR AND RECEIV.E ANY INFORMATION PERTINENT TO THIS ORDER.
CONFIRMING TELEPHONE ORDER PLACED ON 2/5/85 BY PAUL DICKElis AT WHICH TIME TERHS AND CONDITIONS WERE VERIFIED. ANY CHANGE REQUIRES 3;
~
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2 ;TENERA CORPORATION PROPOSAL TR-85-5002 y.
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0ATED. JANUARY 2. 1985..
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EFFECTIVCCOVEMING THE ABOVEITEMS AS THOUGH REPEATEC HEREON.
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~ TEXAS 07ITIES GENERATING CO" PANY 7-
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c/o CCHAI:CHE PEAK STEAM ELECTRIC STATI0hih.C
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BILL WIfiSTON oupuc4TE CONFIlrED TO: EILL WIASTON (703) 979-E220 m v o -. = o w......... m.. m......... m. m...
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ITEM OCANTITY DESCRIPTION U/I N O.
MANTE.D UNIT PRICE ITEM PRICE THIS FURCHASE CRCER IS ISSUED TO SUPPORT COPA.iCHE PEAY. STEAM ELECTRIC STATICH (CPSES) IN SITE QA/CC PIVIEW.
EVALUATION RESEAo.CH CORFORATION (ERC) KILL BE RESPONSIBLE FOR THE FOLLOWIliG:
F.R. JOHN L. HANSEL WILL BE ASSIG!!ED AS THE REVIEW TEAM LEACER FOR OA/QC AND WILL REPORT TO THE SEi.10R REVIEW TEAM.(SRT). HE IS ALSO TO WCf.K WITHIN THE TUGC0 ORGAhI2ATION AhD UTILIZE EXISTIliG PERS05'iEL AS MUCH AS P0SSISLE ANO FEASIBLE.
h0 WEVER, HIS EFFCETS ARE TO BE C0hCUCTED IN SUCH A PA.NhER THAT hE IS ABLE TO PROVICE AN I!! DEPENDENT ASSESShENT A';D EVALUATION OF THIS O'iERALL EFFORT.
PEVIEW THE PROGRAM PLAh, het CORRESPONDENCE AND OTHER P. ELATED l',ATEk!Al. TO SUFFICIENTLY UNDERSTAND THE ISSUES TO BE RESQLVED.
BASED ON THIS E!,0WLEDGE, ASSURE THAT THE AFPROACH C.UTLINED Iri THE PPC W P. PLAN IS EFFECTI'.'E.
j FFCV'LE TLGC0 klTH ANY RECC;xEiOAT10b5 FCF Ir.PROVEMENT.
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THE QA/0C TEAM WILL REQUIRE AN ACTIVE INTERFACE WITh ThE OTFER TEAMS TO REYiEW FlhD! HGS AhD GBSEF.YATIOhS, AND T0 EXChAhGE THOUGHTS CN L' HAT i
I ARE THE ROCT CA.USES OF PROELEP.S. THE Sic.E TYPE OF INTERFACE WILL BE REQUIRED TO DISCUSS GEhERIC ISSUES.
FULFILL ALL RESPONSIBILITIES OUTLINED ON PAGES 7 & 8 0F THE PF.GeRAN PLAN, AS WELL t.S OVERSEE A?iD PROY10E DIRECTI0t; TO THE ISSUE C00R31tiATORS.
KEEP THE SENIGR REVIEW TEAM APPRISED OF PROJECT STATUS ISSUES 4 AND C0riCERt.S. THIS WILL BE VIA PERICDIC MEETINGS AND FORF.AL REPORTS.
A FlhAL kEPORT WILL BE PREPAP.ED BY ERC UPON COMPLETI0ti 0F THE PROJECT.
ERC WILL CCf. DUCT AUDITS AhD PERFORM SURVEILLANCE OF VARIOUS ACTIVITIES TO PRCVIDE ASSURANCE THAT THE PROJECT IS BEIhG C0ti3UCTED Ito ACCORDA!;CE WITH THE PLAN At;D THAT THE PLAN,
- t. HEN COMPLETED, KILL SATISFY THE TUGC0 CSJECTIVES. THE AUDITS AND SURVEILLAhCE ACTIVITY WILL BE KEPT TO A MIfilP.UM, AhD kill OfeLY BE CUhDUCTED AT THE DIRECTION OF HR.
HANSEL.
THEY WILL DE TAILORED IN A HAtittER THAT WILL Akt0V VR. HANSEL TO SPEAA AUTh0kITATIVELY Ort XEY ASPECTS Of THE PROGRAl:.
IF F.EQUIRED, N:. HA?.SEL WILL TESTIFY ECH TL".C0 Ch TPIS EFF0'T l'EFCP.E ThE ATC.?.IC SAFETY $
LICESSIf6 ECAFD.
E'C WILL REC'.Y.' Et@ it;E USE OF II.' EFEh'sE'.T
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THE A80vt ITEMS AS THOUGH REPLATL3 HgRgcN.
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v ERC PERSOMhEL' SHALL' REPORT TO THE CPSES ASSIST'AhT GEHEFAL PROJECT MANAGER OR HIS DESIGMEE FOR ASSIGhMENTS.
ACTIVITIES AC ASSIGNMENTS SHALL EE FUhNISHED In STRICT C0 'PLIANCE KITH TUGCO' S CPSES PROJECT FROCEDURES AND QUALITY ASSURANCE REQUIREMENTS.
ERC SHALL SUBNIT PROPCSED CAtiDIDATES TO FULFILL
'!GRK REQUIRENEh'TS BY PROVIDIhG RESUMES IDENTIFYING PERSCNNEL QUALIFICATIONS, PROPOSED RATES, AND CLASSIFICATION.
TEP.MS AND CORDITIONS TERHS AND CCNDITIONS ON THE REFERSE SIDE OF THIS FURCHASE CRCER CPF 2163S 00 NOT APPLY.
TERMS AND C0h3ITIONS SFALL BE IN STP.ICT COMPLIANCE WITH THE ATTACHED C0CUMENT TITLED
" TERMS AhD CONDITIONS, COMANCHE PEAK STEAM ELECTRIC STATION SERVICE CONTRACT", DATED APRIL 12, 1984 (ATTACFr.ENT NO. 1)
SERVICE PEPIOD ERC PERSCh5EL SHALL BE AVAILASLE ONSITE NOVEMBER S. IoS4 AND EXTEND TO NGVEP.EER II, 1935, WITH OFT 10h FOR TUGC0 TO RENEL', CUT SUSJECT'TO THE TERMINAT!0?. CLAUSE In TFE TUGC0 TERMS AND CONCITIONS 00 Cur'ENT.
FEE SCFEDL'LC EP.C SMALL INYCICE TEXAS UTILITIES IL '.CC0 DANCE LI TH Tl E F0'.LC'<. D.G F1.TE S.
- .. TC/Ne C.J CCP.DITictes BMowN 0% THE FACE AND HCVEmSg Cr THE sisNED SHEET OF THis OmotR amt CFFCOTivt CCvtmi 40 THE ACCVC ITEMS AS THOUCH REPEATED HEREON.
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SERVICE CATEGORY RATE /HOURT?* _ RATE / HOUR r,..
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DEPUTY REVIEW TEAM LEADER
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CLERICAL SUPPORT u
TiiE ABOYE RATES FOR OVERTIME APPLY AFTER F0F.TY (40) HOURS HAVE E,EEN kORKED IN A GIVEN CALENDAR WEEK, SU!. LAY THROUGH SATURDAY, AND FOR ALL h0LICAY h0URS WORKED. HOURS kORX,ED WILL INCLUDE REASONABLE TFAVEL TI!!E FOR BUSINESS EUT WILL NOT IhCLUDE ROUTINE DAILY TFAVEL TO l'.D FROM THE JOBSITE.
ERC SPALL SU5ttIT WEEKLY TIME SHEETS TO TUGC0 CPSES PAhAGEP.ENT FOR APPROVAL.
ERC SHALL IDENTIFY PEoS0MiEL, CLASSIFICATI0h, AND FJTE WHEh INVOICING TUGCO.
EXPENSES SHALL EE INVOICED AT ACTUAL COST TO EVALUATIch REVIEW CORPOPATION /.MD SHALL CChPLY WITH COMNCHE PEAK TFAVEL POLICY AS FCLLC;:S:
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ACTUAL COST DUT h0T TO EXCEED TKENTY-FIVE ($25.00) 00LLAh5 FER CAY.
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THE ADOVE ITEM 5 AS THOUGH REPEATED HERtcN.
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4 EhTER.TAlfa'.E!!T - hCT P.EIM'dURSALLE EXPE! SES.
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MOTEL / HOTEL - ACC0!'F,00ATICNS SHALL EE IX GRANBURY, GLEN RCSE, OR CLEEURhE. OhtY.
PROPER DOCUMENTATION AhD RECEIFTS SPALL ACCOMPANY ALL INVOICES.
THE A30VE RATES ARE FIRH AhD NOT SUBJECT TG ESCALATION.
ERC 15 REQUIRED TO REFERENCE THIS FU9CbASE ORDER NU.S.BER ON ALL IhYOICES AND CCPr. ESP 0h0Ei4CE PERTAINING TO THIS PUP. CHASE ORLER.
THE ESTI!'.ATED TCTAL PURCH5SE AP.0llNT OF THIS FURCFASE CP. DER IS NOT TO EXCEED UULESS AUTH0k' ZED BY kRITTEN SUPPLEMENT TO TE S PURCHASE C.t. DER.
INSUPANCE PECLlrEuEhT5 I f f0P.E K0kX CAL CCME.'.CE, SELLER %ST FU'd:15::
TO BLYEk CCFPLETED CEhTIFICATE OF 1i."S'Lkt'.CE.
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PRINCIPAL ON WHOSE WORK EUYER IS ENGAGED,.
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THROUGHOUT'THE CURATION OF THE ABOVE SERVICES" A MINIMUM INSURANCE AS FOLLCMS:
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A. STATUTOP.Y WORKFEK'S COMPEKSAT10h.
B. COMPREHENSIVE GENERAL LIABILITY BODILY IhJUP.Y
- $300,000.00 EACH OCCURRENCE PEOPERTY DAMAGE
- 5100,000.00 EACH OCCURRENCE
- $100,000.00 AGGREGATE C. COP.FREHEhSIVE AUTCMOSILE LIAEILITT BCDILY INJURY
- $100,000.00 EACH PEP.50N
- $300,000.00 EACH OCCURREhCE FROPERTY CA? AGE
- S 50,000.00 EACH OCCURRE! ICE D. EMPLOYER LIABILITY - $100,000.00 E. EXCESS LIASI'LITY
- $1,000,000.00 CCF.21HED SINGLE LD'.lT SELLER 'SHALL TURhlSH CERTIFICATE OF THE FCRE-GOING ISSURECE TO BLYER, PkCVIDifiG TFIRTY (30) DAYS i:0TICE bY hEGISTEEED l'i.t. 70 iUVER AS TO CANCILt.ATIC's CR MATERI AL Ch/NCES.
!' AIL CERTIFICATICh TO:
TEXAS UTILITIES GE'iEPATil.G C0' FA'.Y D. O. ECX l'J0.l R F.M F.C T E, T E D5 7 0.* 3
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COATRACT TNDEMXITY AND H01.0 HARMt.ESS AGREEMEhT C0hTRACTOR FURTHER AGREES TO DEFEND, PkOTECT.
INDENNIFY, AND SAYE HARMLESS OWNER, ITS AGENTS.
SERVANTS, CFFICERS, DIF.ECTOP.S. AND EMPLOYEES, FRON' AhD AGAINST ALL C1. AIMS, EXPENSES, DEFAhDS, JUCEMENTS, AhD CAUSES OF ACTION OF EVERY KIND AhD CPARACTER FOR PER50hAL INJURY OR DEATH OR DAMAGE TO PROPERTY OF CONTRACTOR'S AGENTS, SERVAhTS, At.D EMPLOYEES, AS WELL AS THE AGENTS, SERVANTS, AhD EMPLOYEES OF CONTRACTOR'S SUBCONTRACTOR, VHETHER OR h0T ARIS1tiG FROH THE SOLE OR C0ri-CURRENT hEGLIGENCE OR FAULT OF OW::ER ITS AGENTS SERVANTS, OFFICERS. DIRECTORS, OR EFFLOYEES OR li.0EFEhDENT CONTRACTORS DIRECTLY RESP 0nS16LE TC OVSER ARISIhG OUT OF OR INCIDENT TO THE WORK TO BE PEkFORMED hEREUh0ER, lhCLUD1HG, BUT NOT LIMITED TO, (1) ANY CONDIT10h 0F THE PREMISES, (2) SEPAP. ATE OPERATIONS BEthG CONDUCTED ON THE PREPISES, OR (3) THE IMPERFECTICN, WHETHER LATE!iT OR PATENT, OF ANY PATERIAL OR EQU!FFENT l
FURfe!ShED BY OFNER.
THE CONTRACTOR SHALL DEFEND, FROTECT, th0EFNIFY, AND SAVE HARMLESS GVNER AND ITS OFFICERS.
DIRECTORS ACEKTS, SERVAhTS, AND EMPLOYEES FROM At!D AGAINST ANY AliD ALL CLAll'.S. EIFEi.SES, DEMANDS, JUDG*ENTS, AND CAUSES OF ACTIO!, OF EVERT KihD A!.D CRAFACTER WilATSOEVER ARISING lit FAVOR OF A!;Y PERSCh*0R EllTITY (OTHER THA;; ThE AGEhTS, SERV /NT S, ASC EhPLOYEES OF C0hTFACTOR OR OF CChTRACTOR'S SWCO'.TRI.CTOE, AS PROVIDED IN THE PARAGRAPH 1.r.FCIATELY ABCVE), thCLUDlhG SOT h0T LIMITED TC C:.Ali+1, DEdAt.CS, JUDGMENTS, CAUSES OF ACTION 07.
ACCCL'.T OF PERS0hAL !!.JLRIES OP DEATH, GF, CA.' AGE TO Pk'PERTY ARISit.', OUT OF OR 1:iC10El.T TO inE
'n0*K l'Er.FWED hE!:E'.!.D!b..
IT IS THE Cl. EAR AliD U:.!CL1','CCAL D.TI:.T OF TFE Fi.hTIES rELE10 it AT C0.i'. 4T0;'S CFL! RAT 0N TO !.r.Firi, FQ1f CT, A:.D EA',E ':.ly. LEES C',.hER hi ALL h E FULL h..D CC.TLETC l
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A.. T g tt-J A ND CONDITICNS S mo
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DEATH OR DAMAGE 'TO THE AGENTS.fSERVAh75. AND $,,.
s EMPLOYEES OF CONTRACTOR OR CONTRACTOR'S SUB CONTRACTOR.
OkHER SHALL NOT BE ENTITLED TO 4 INDEMh1FICATION FOR CLAIKS DEFANDS, EXPCHSESF JUDGMEh15. AND CAUSES OF ACTION RESULTitG FROM Oh5ER'S SOLE NEGLIGENCE.,,
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EXPEDITERS AND 1hSPECTOP.S ARE ENTITLED TO AIR FOR Aft 0 RECEIVE AftY INFORFATION PERT!hD4T TO THIS ORDER.
C0hFlp.%ING TELEPHONE ORDER PLACED ON 11-14-E4 BY PAUL DICKENS AT WHICH TIME TERh5 AhD C0hDITIOh5 kERE VERIFIED.
ANY CHANGE REQUIRES APPROYAL OF PERS0h PLACING ORDER. 00 NOT
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ATTACPFENT
- 1) "TERF.S AND CONDITIONS COPAhCHE FEAR. STEM ELECTRIC STATION SEF.VICE C0h' TRACT," LATED APRll 12, 1904.
REFEREhCE
- 1) EVALUATION RESEARCH CORPORATION (ERC)
LETTER DATED NCYC'.BER 2.1954.
- 2) ERC LILLlHO RATES O
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- .6. TEAMS el D CateOf f.0ted SHOWN 04 THE FACE AND Mtytnet OF THE SiONEC SNCCT OF THis 0 eDist eRE EFf tC?i%1 CG'# sill'80 THE ABOVE ITEMS At THOUCH MEPEATED HEREON.
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3 Tril5 PbRCP.ASE 0.'.0Co. SUPPLEMEhi KO.1 !$ 155tEL T0 A.$.EhD SEW!CE FEA100 f. FiE Sche 001.E AS FCLLOWS:
A).Eh0!D SE R'.'!CE PEP.!00 EEC persennel th:11 be availe:la cr. site havar.ber 3,1964 and extend tnreup tece.-ber
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but sub,)t.ct to the! ter:r.inaticn c1cuse in the TUGC0 Terr.s ced Cunditiens cectr ent.
Upen ex.treise cf rnrewal ertica ty TUCCO ERC shall prerptly rrovide a listing of service catepartes anc rat-s apolicable fnr the r+redal parted to La inc1W+d ir. *n a:wst et to the
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.A.AYlSION OF TEXAS UTIOTIES ELECTmd CO.., i' s.
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DEPUTY PRCJECT NAhAGER SEh!OR GUALITY EhGINE.tx IhSPECTOR 50FERV150R i
INSPECTOR 11 CLERICAL
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Job stcrt-up (Cn or befera 4/1/t'5) - Cut to need to p'o:t cd wit,h wrk nr! cit:the-un.r.tew.11 ebli atier s, the it. ve evertin.
I ptes arrly to ail prsornel ter enors,;..rkas 4::cve eight (d) hcurs a cay vd mr fir:7 (46:)
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J x _,tVISION OF TENAS IITiUTIES ELECTt J C6.1. '*
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above 'overtise,. rates ' apply 'af ter forty.(40)p....
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hcurs have been. worked in' a given calendar week, Lor.dey throuch Friday, except t.cn-exu:pt
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personnel who shalI be cecpensated in
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rate applies to hours worked on Saturdays.
'Sur. days, ard F.clidays.
Prestun ti e (4/1/85 - 12/31/05)- The premium ti:e applies to hcurs worked Saturdays, Sundays and helidays.
ERC shall provide sixty (60) days advance notice of any changes to the above rates and TUGC0 vritten approval of the changes vill be required pricr to implementation.
EP.C shall subciit semi-menthly activities rt;crtsato TUGC0 CPSES management for apprcycl.
ERC shall identify personnel by service category and rate when ir. voicing.
The initial invnice shall include ceptes of ERC time
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Subsequently ERC shall submit en a ponthly t.ests a listing of all perscerel workir.9 cn the project identified by billing,
} category, service category, and base h:urly irate.
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Dert Ter1 A!:ierre..t f <.:1s-Actuoi c:st t,ut ret to nee :d I
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It is EP.C policy' to' rrovide ' ne ' trip he:e (cr
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o one trip for spouse to site) for personnel on a'
,I continuous extended work day (over eight hours)/ work period (over three weeks) basis.
The purpose fer such trip (s) is to ensure raaximum efficiency and accurrey of essential personnel on the project under extensively stressful cenditions as follows:
ERC personnel will be allowed one trip hcme eiery three weeks on a rctational schedule basis such that a work force is maintained on-site during weeker.ds.
The Project Manager will have final approval rights for schedullrg th:.se trips in consideratier. of project needs.
All travol e g4nses asscciated with the trip home will be reimbursed in accordance with standard ERC practice.
If travel tine cccurs Mendey thrcuch Friday, the employee will be coepensated for thet time.
.hewever, the number of hours actually worked.
c cbined with the travel time hours will not be cecpensated for rcre than a normal workirg dty.
Travel time on Saturday or Sunday will r.ot be reimbursed.
Travel tine utill:cd en Mcnday tnreugh Friday will no,t execed four (4) hours cr.d part cf the normal worx week in acccrdarce with tnc liet tatiens stated e:riter.
/,11 travel tine tahr. during a normal wer6. der hill require specific atprevsl cf the Pryect j
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adequate' docur:entation to support all expenses -
. clairmd and expenses will be identified in an aggregate dollar ancunt on.a separate line ite;.
on each invoice.
Sube'.ission of receipts /docur.cntaticn are r.ot required to te subr.itted with each invcice.
Tt'GC0 reserves the right to provide local transportation and travel arrangernerts directly for ER,C (centra,ctor) persennel.
TUCCO shall have the right to audit the ex;ense reccrds specifically relating to perform.nce under this purchase order in ERC's centracts/ accounting offices at all reasonable tices during nemal werking hours.
The above rates are applicabic to this purchase crder for the period ending Decer.ber 31, 1985 and r.ot subject to change unless ERC provides sixty (CO) days advance notice of any change.
Such changes cmst be agreed to in writtrg by TUGC0 pricr to insoicing.
EVAll'ATION RESEAP.CH CGhP65AT!0h 15 EECU1 RED TO REFERENCE Th15 PUNCRASE ORDER NL'ESER ON ALL th'i0!CES AhD C0FRESTONDENCE PERTAlhl'iG TG in15 PURCHASE ORCER.
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lTHE EST!P'.ATED TOTAL PukCHASE A:'Ot.'hT OF Th15 irtinst.V 0;inf h Sut'PLEMENT ht"<!ER 1 IS U'iLESS AUTHOR!:E0 OY W ITTCt.
'SUPPLEFEhT TO Th!S PunCr/iSE Chue.
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CONFIR.MlHG TiLEFH0hE ORDER PLACED'ON 3-21-85N i BY PAUL 01CKEh5 AT kHICH T IFI TERF.S AN3 ' ' J".' b.'
4 CONDIT10P.S WERE VERIFIEO.
ANY CF.ANGE P.EQUIRES'
. APPROVAL OF PERSch PLACit.G ORDER.
DO t.0T i.
DUPLICATE.
FEFEr.E.NCE :
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ERC LETTER CATED 2/21/05 2)
EP.C A?DDED LETTER CATED 3/15/55 6
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A h t&Mut Area GGreDe tsC'st ta9ma 0.s TML F act A%Q MtytASE 08 TMt 8eO%80 GMLET OF TMf 8.OROtn SWP'btME'47 ant SPPEC?tvt C0vtNING TME ASOVE 11 EMS At THOW4M Rt*tATEC HERt084.
PURCHASNG COPY
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co r re m TEXAS UTILITIES GENERATING COMPANY i*
' A DIVISION OF TEXAS UTILITIES ELECTRIC CO. ' '
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c/o CDP.tiCHE PEAK STEA:1 ELECTRIC STATI0tl PURCHASE ORDER
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FM 201, GLEN ROSE, TEXAS 76043
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onicisat couria:.i41io 4 NOTIFICATION set.i. Td TEXAS UTILITIES GENERATING COMPANY y
P.O. BOX 1002. GLEN ROSE, TEXAS 76043 3,"),-(( d"*I*g'
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IIT)i"ANYCNIY"
SEE' FEE SCHEDULE"'R"D044 T-f"9'2'ld-330512-094 CPF-12653-S p STONEAfl0WESSTERENGINEERINGCORPORATg HOUSTON OPERATIONS CENTER
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16430 PARK TEll PLACE 0;'.*l;;*,,;"",5", *;t aa,='".a*;'7,;
""'*"""*a HOUSTON, TEXAS 77084 L_. ATTN: JIM MON 0HAN
.j PLEASE RENDER INVOICES IN DUPLICATE CONFIRMED TO: JIH NON0HAN 713-492-4230
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TOTA 1, NET 1 ITEM QUANTITY DESCRil' TION.
Ull UNIT PRICE ITEM PRICE NM WANTED THIS PURCHASE ORDER IS ESTABLISHED WITH STONE ANDWESSTERENGINEERINGCORPORATION(SWEC)FOR TECHNICAL ENGINEERING SERVICES IN SUPPORT OF TEXASUTILITIESGENERATINGCOMPANY'S(TUGCO)
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) g PROJECT LOCATED IN SOMERVELL COUNTY NEAR GLEN 7
ROSE. TEXAS..,,,
SCOPE OF WORK, GEflERAL SWEC SHALL FURNISH QUALIFIED PERSONNEL, EQUIPMENT, AND SOFTWARE AS REQUIRED TO PERFORM PIPE STRESS AND PIPE SUPPORT QUALIFICATIONS IN ORDER TO ADDRESS TECHNICAL CONCERNS ON THE' PIPING AND PIPE SUPPORT DESIGNS AT THE CPSES PROJECT.
UPON INITIATION OF Td!S SCOPE OF WORX, THE WORK SHALL PROCEED WITHOUT HOLD POINTS FOR APPROVAL BY OUTSIDE PARTIES.
IF NEW TECHNICAL ISSUES ARE RAISED IN THE AREA 0F PIPING AND SUPPORTS, SWEC SHALL ADDRESS THEM IN PARALLEL WITH THE REQUALIFICATION PRODUCTION EFFORT.
COMPLETE IMPLEMENTATION OF T1115 SCOPE OF WORK SHALL DEMONSTRATE THE TECHNICAL ADEQUACY OF THE PIPING AND PIPE SUPPORT DESIGNS AT THE C3 WICHE PEAK STEAM ELECTRIC STATION.
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AND PIPE SUPPORT QUALIFICATION
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PURCHASING COPY
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13 A rt 2 or PURCHASE ORDER CONTINUATION SHEET CPF-12658-5 DESCRIPTION UNIQCE
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Ull THIS EFFORT SHALL BE OVERVIEWED BY TUGC0 PROJECT MANAGEMENT ASSISTED BY R03ERT L. CLOUD ASSOCIATES, GIBBS & HILL, INC., AND C0HANCHE PEAK REVIEW TEAM (CPRT).
THIS OVERVIEW WILL NOT RELIEVE SWEC OF THE RESPONSIBILITY FOR FULLY QUALIFYING THE PIPING AND SUPPORTS IN THEIR FINAL H00!FIED CONDITION.
SCOPE OF UORK, SPECIFIC SWEC SHALL QUALIFY ALL ASME CLASS 2 AND 3 r
PIPING SYSTEMS AND SUPPORTS IN ACCORDANCE WITH APPROPRIATE PROCEDURES. PRACTICES, TECHNICAL TECHNIQUES AND CONTROLS.
SITE ACTIVITIES PERF024ED SHALL BE IN ACCORDANCE WITH GENERAL SITE POLICIES NiD GUIDELINES. THESE ACTIVITIES SHALL BE IN STRICT COMPLIANCE WITH THE SWEC QA PROGRe'M OR
'O SITE ENGINEERING PROCEDURES / INSTRUCTIONS '
PREPARED TO ACCOMf!00 ATE SITE ACTIVITIES.
THE SCOPE OF THE PIPING AND SUPPORT QUALIFICATION PROGRAM SHALL INCLUDE:
100%OFALLASMNCLASS2AND3 PIPING LARGER THAN 2 INCH.
(LARGEBORE) 100% OF ALL LARGE BORE SUPPORTS INCLUDING SUPPORT DESIGNS FOR CLASS 1 SYSTEMS.
REANALYSIS OF SMALL BORE (2"' AND UNDER)
PIPING AND SUPPORTS ON A SAMPLING BASIS TO
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VERIFY ADEQUACY.
VERIFICATION OF ALL STRUCTURAL AND SYSTEM INPUTS TO ENSURE COMPLETE INTEGRITY OF THE P! PING AND SUPPORT PROCESS.
VERIFICATION OF THE VALIDITY OF DATA PROV10E0 BY/TO OTHER DESIGN ENTITIES.
rs ALA. TERMS AND CortDITIONS SHOWN ON THE FACE AND REVERet OF HE ON SHE OF THIS ORDEM ARE EFFECTIVE COVERING O' f eetJ A CIMC (*m0V
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T DESCRIITION UNI PRICE IT RICE U/l A
THE ABOVE PROGRAM SHALL ADEQUATELY ADDRESS-C0.iCERNS RAISED INCLUDING THOSE BY THE NRC, CYGNA, AND CASE.
SWEC SHALL FOLLOW THE ACTION PLAN STATED BELOW IN ORDER TO ACCOMPLISH THE ABOVE STATED " SCOPE OF SUPPLY".
OUTLINE OF ACTION PLAN THE SWEC ACTION PLAN CONSISTS OF THE FOLLOWING SIX ELEMENTS:: -
1.
DEVELOPMENT OF COMANCHE PEAK STRESS AND PIPE SUPPORT DESIGN CRITERIA 2.
VERIFICATION OF AS-8UILT INFORMATION 3.
REVIEW AND VERIFICATION OF SYSTEN DESIGN INPUT, SEISMIC ACCELERATION AND FLUID TRANSIENTS 4.
VERIFICATION OF EXISTING PIPE SUPPORT DESIGN DOCUMENTS 5.
RESOLUTION OF SPECIAL TECHNICAL CONCERNS 6,
REANALYSIS OF PIPING SYSTEMS AND RE-EVALUATION OF PIPE SUPPORT DESIGNS. ANY MODIFICATIONS REQUIRED TO SUPPORTS SHALL BE COVERED IN THE REPAIR REPLACEMENT ACTIVITY OF ASME SECTION XI.
DETAILS OF EACH ELEMENT OF THE ACTION PLAN IS PROVIDED IN THE FOLLOWING SECTION.
ACTION PLAN DETAILS 1.
RESOLUTION OF SPECIAL TECHNICAL CONCERNS SPECIAL TECHNICAL CONCERNS AT THE C'PSES HAY BE SEPARATED INTO THREE CATEGORIES:
O
. Au. TERMS AND CONDitlONS SHOWN ON THE P ACE AN REVERSE OF HE SIGNE SHEE OF THis O otjocursms ccoy
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PURCHASE ORDER CONTINUATION SHEET /
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YANTy IT CE a.) TECHNICAL CONCERNS WHICH SHALL BE ADEQUATELY ADDRESSED BY EXISTING SWEC TECHNICAL PROCEDURES.
NO FURTHER ACTION IS REQUIRED SINCE REANALYSIS USING STANDARD SilEC
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PROCEDURES SHALL AUTOMATICALLY RESOLVE THESE TECHNICAL CONCERNS.
EXAMPLES OF THESE TECHNICAL CONCERNS ARE PIPING COMPUTER N0 DEL MASS POINT SPACING, CONSIDERATION OF PIPE SUPPORT HASS.SIGNIFICANT MODAL C0!iTRIBUTION, DAMPING VALUES, FRICTIONAL FORCES ON SUPPORTS,1.0 CAL STRESS, SKEWED FILLET WELDS AND ROTATIONAL RESTRAINT OF AXIAL SUPPORTS.
b.) TECHNICAL CONCERNS WHICH MUST BE ADDRESSED BEFORE THE INITIATION OF THE PIPING REANALYSIS EFFORT.
THESE ASE SPECIAL ISSUES WHICH WILL HAVE A SIGNIFICANT EFFECT ON THE OVERALL PIPE STRESS ANALYSIS EFFORT AND ARE CONSTRAINTS TO FINALIZING THE PIPING REANALYSIS.
EXAMPLES OF THESE CONCERNS ARE PIPE SUPPORT STIFFNESS, STABILITY OF PIPE SUPPORTS AND THE EFFECTS OF U-BOLTS ON LOCAL STRESSES.
SWEC SHALL ESTABLISH SPECIAL TASK FORCE (S)WITHEXPERIENCEDPIPESTRESS AND PIPE SUPPORT ENGINEERS TO ADDRESS THESE ISSUES.
THETASKFORCE(S)
SHALL REVIEW ALL PAST PROJECT EFFORTS EXPENDED FOR THE RESOLUTION OF THESE TECHNICAL CONCERNS AND RECOMMEND FURTHER ACTIONS TO CLOSE OUT THE RESOLUTION EFFORT. THE REVIEW AND RECONMENDATIONS SHALL INCLUDE DOCUMENT REVIEW AND FIELD WALKDOWN BY EXPERIENCED PIPE STRESS ENGINEERS TO IDENTIFY SUPPORTS WHICH ARE DIFFICULT TO QUALIFY, PHYSICAL REMOVAL OF THE PIPE SUPPORTS, IN-SITU OR LABORATORY O
Au.TEMMs AND CONolTIONe sHOWN ON THE PACE AND MEVERSE OF HE O
SHE OF THIS ORDER ARE EFFECTIVE COVERING PURCHASING COPY
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A DIVISION OF TEXAS UTILITIES ELECTRIC CO. -
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pp}'265b5 PURCHASE ORDER CONTINUATION $HEET I
DESCRIITION UN! RICE IT RICE
% ANT s
TEST / QUALIFICATION OF PIPE SUPPORTS, FURTHER ANALYSIS OR HARDWARE MODIFICATION. AS AN OPTION, SOME OF THE SUPPORTS IN QUESTION HAY BE IDENTIFIED BEFORE STRESS REANALYSIS AND AN ATTEMPT MADE TO DELETE THEM FROM THE COMPUTER MODEL IF ACCEPTABLE BY ENGINEERING JUDGMENT BY A TEAM OF EXPERIENCED STRESS ENGINEERS. UPON SUCCESSFUL COMPLET10ft 0F THE REANALYSIS, SUCH SUPPORTS MAY BE PHYSICALLY REMOVED.OR MODIFIED TO PROVIDE AN EXPEDITIOUS AND COST-EFFECTIVE RESOLUTION TO THE TECHNICAL C0flCERNS RAISED EVEN TH00GH THE ORIGINAL DESIGN MAY BE ACCEPTABLE.
,c. ) TECHNICAL CONCERNS WHICH MUST BE RESOLVED BEFORE COMPLETION OF THE PIPE STRESS AND PIPE SUPPORT'
'REANLYSIS EFFORT.
THESE ARE TECHNICAL C0flCERNS WHICH SPECIFICALLY ADDRESS THE ADEQUACY OF THE SUPPORT DESIGNS. THEY GENERALLY 00 NOT HAVE SIGNIFICANT EFFECT ON TriE PIPE STRESS ANALYSIS EFFORT AND THEREFORE NEED NOT BE A CONSTRAINT TO THE INITIATION OF THE PIPE STRESS REANALYSIS EFFORT..HOWEVER, IT IS ANTICIPATED THAT SUBSTANTIAL TECHNICAL EXPERTISE IS REQUIRED TO RESOLVE THESE CONCERNS AND AN APPROACH SIMIL'AR TO THE ONE DESIGNED INITEMb.)AB0VESHALLBEUTILIZED TO RESOLVE THESE CONCERNS.
EXAMPLES OF THESE CONCERNS ARE: CINCHED U-BOLTS, WALL TO WALL SUPPORTS AND RICHMOND INSERTS.
2.
DEVELOPMENT OF COMANCHE PEAK PIPE STRESS' AND PIPE SUPPORT DESIGN CRITERIA (C0ltANCHE PEAKPROJECTPROCEDURE(CPPP-7),
t O
ALLTEnus ANo cONomONs sHOWN ON THE FACE AN MEVERSE OF THE G SHEE OF THis CRDER ARE EFFECTIVE COVERING PURCHA$ LNG COPY
TEXAS UTILITIES GENERATING DOMPA'NY
- P 2 2 '
A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
lyE 6
o, 13 N WE mER c NmmN surer CPF-1265 -S ThT U/1 DESCRllTION UNI PRICE IT RICE I
EXISTING SWEC TECHNICAL GUIDELINES AND PROCEDURES FOR PIPE STRESS ANALYSIS AND PIPE SUPPORT DESIGN SHALL BE INCORPORATED DIRECTLY OR BY REFERENCE INTO A SINGLE COMANCHE PEAK PIPE STRESS AND PIPE SUPPORT DESIGN CRITERIA DOCUMENT (CPPP-7).
RESOLUTIONS OF THE SPECIAL TECHNICAL CONCERNS IDENTIFIED IN ITEM 1 A30VE SHALL ALSO BE INCORPORATED AS THEY BECOME AVAILABLE. FURTHERMORE, RECENT CODE CASES AND INQUIRIES (E.G., CODE CASE N-411 ON DAMPING AND CODE CASE 413 ON MINIMUM WELD SIZE) MAY BE IMPLEMENTED IF NRC APPROVAL IS GRANTED AND IF THEIR IMPLEMENTATION IS CONSIDERED APPROPRIATE.
THIS DOCUMENT SHALL BE USED ON ALL PIPE STRESS REANALYSIS AND PIPE SUPPORT REEVALUATION ON THIS PROJECT. THE USE OF THIS CRITERIA DOCUMENT WILL ENSURE UNIFORMITY OF WORK AND TECHNICAL QUALITY.
}
VERIFICATION OF AS-BUILT INFORMATION 3.
SWEC SHALL PERFORM A SAMPLE VERIFICATION OF EXISTING AS-BUILT PIPING STRESS PACKAGE 4
DOCUMENTATION TO ENSURE THE VALIDITY AND COMPLETENESS OF THE PHYSICAL DIHENSIONS TO BE USED IN THE PIPE STRESS REANALYSIS.
EXECUTION OF THIS EFFORT SHALL FOLLOW THE FIELD WALKDOWN PROCEDURE CPPP-5 ESTABLISHED FOR THIS PROJECT. SAMPLE SIZE SHALL MEET 95/95 CONFIDENCE CRITERIA 0F MIL-STD 1050.
4.
REVIEW AND VERIFICATION OF SYSTEM DESIGN INPUT, AND SYSTEM FLUID TRANSIENTS SWEC SHALL REVIEW ALL ASME CLASS 2 AND 3 PIPING DRAWINGS TO ENSURE THAT ALL SUBSYSTEMS ARE EVALUATED.
SYSTEM DESIGN SPECIFICATIONS SHALL BE REVIEWED TO ENSURE THAT THE FSAR COMMITMENTS, THE PROPER OPERATING MODES, SYSTEH PRESSURE AND ALL TERMS ANO coNDITick's SHOWN ON THE FACE AND REVERSE OF HE SIGNED SHE OF THIS ORDER ARE EFFECTIVE COVERING PURCHASING COPY
.s rp = a 222 TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC CO. ~
7,,
18 dhPFj"5b5 PURCHASE ORDER CONTINUATION SHEET DESCRIITION UNI RICE ITE. RICE U/I
%A T TEMPERATURE AND THE APPROPR. ATE FLUID TRANSIENTS ARE CONSIDERED IN THE PIPE STRESS ANALYSES. AN ASSESSMENT SHALL BE MADE FOR EACH IDENTIFIED FLUID TRANSIENT TO DETERMINE ITS EFFECT ON THE PIPING.
NEW FLUID INDUCED FORCES SHALL BE GENERATED, IF REQUIRED, FOR THE PIPING ANALYSIS. TO THE EXTENT PRACTICA3LE, THE EFFECTS OF THE VARIOUS FLUID TRANSIENTS SHALL BE COMPARED AND ENVELOPED TO MINIMIZE THE PIPE STRESS REANALYSIS EFFORT.'
5.
VERIFICATION OF EXISTING PIPE SUPPORT DESIGN DOCU.ENTS M
EXISTING PIPE SUPPORT CALCULATIONS SHALL BE REVIEWED TO DETERHINE THEIR TECHNICAL ADEQUACY. ACCEPTABLE CALCULATIONS SHALL BE USED ON A LOAD' COMPARISON BASIS FOR THE FINAL PIPE SUPPORT DESIGN EVALUATION.AFTER O
COMPLETION OF THE PIPE STRESS REANALYSIS EFFORT.
6.
REANALYSIS OF PIPING SYSTEMS AND REEVALUATION OF PIPE SUPPORT DESIGNS PIPE STRESS REANALYSIS EFFORT SHALL FOLLOW PROJECT PROCEDURE CPPP-6 " PIPE STRESS ANALYSIS PROCEDURE FOR AS-BUILT ASME CLASS 2/3 PIPING SYSTEMS" AND CPPP-7 " ANALYSIS AND DESIGN CRITERIA FOR PIPE STRESS AND PIPE SUPPORT FOR ASME CLASS 2/3 PIPING SYSTEMS." THE ANALYSIS SHALL UTILIZE THE VERIFIED AS-BUILT AND SYSTEM DESIGN INPUT DIS"USSED IN ITEMS (3) and (4) AB0VE. NEW SEISMIC RESPONSE SPECTRA CONSISTENT WITH THE PRESSURE VESSEL RESEARCH COMMITTEE (PVRC) RECOMMENDED DAMPING VALUE (WRC-300 AND ASME CODE CASE N411) MAY ALSO BE USED.
WHENEVER JUDGED APPROPRIATE BY THE PIPE STRESS ENGINEER, PIPE SUPPORT OPTIMIZATION SHALL BE PERFORMED TO ELIMINATE UNNECESSARY SNU33ERS AND SUPPORTS WHICH iO -,-. - - -.. - -,,,, = =.,. =.. = =,.. - -, -. - -
I ouacussm cen
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22' TEXdS UTILITIES GENERATING CO31PA'NY T
A DWISION OF TEXAS UTILITIES ELECTRIC CO.~
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NRcwAsE R ER c NnNun N sucET PF565-S L
IQM Oh^yTI DESCRIPTION UNI RICE IT PRICE U/l ARE SU3 JECT TO THE SPECIAL TECHNICAL -
CONCERNS (E.G., STA3ILITY) DISCUSSED IN ITD1 lb.
THE RESULT OF THE PIPE STRESS AftALYSIS SHALL BE USED TO EVALUATE THE ADEQUACY OF THE SUPPORTS, PENETRATIONS A!iD EQUIPMENT N0ZZLES.
VALVE ACCELERATIONS SHALL.SE COMPARED TO THEIR QUALIFIED LEVEL TO ASSURE OPERABILITY.
THE NE',1 STRESS RESULTS SHALL ALSO BE EVALUATED FOR CONSISTENCY WITH THE DESIGNED POSTULATED PIPE BREAK LOCATI0its.
CLOSURE OF SWEC SCOPE OF WORK SWEC'S REANALYSIS EFFORT SHALL INCLUDE SENIOR MANAGEMENT REVIEW AND APPROVAL OF THE NEED FOR FURTHER REANALYSIS OR HARDWARE MODIFICATION.
UPON COMPLETION OF THE REQUALIFICATION EFFORT, A REPORT SHALL BE PREPARED COVERING:
WALKDOWNS e
PIPE STRESS REANALYSIS SUPPORT N0DIFICATIONS SUPPORTS ELIMINATED REQUALIFICATION EFFORT JUSTIFICATION FEE SCHEDULE SWEC SHALL INV0 ICE TUGC0 FOR THE ABOVE STATED SCOPE OF WORX ON A TIME AND MATERIALS BASIS IN ACCORDANCE WITH THE FOLLOWING:
O 4.LLTERMS AND CONDITIONS SHOWN ON THE P ACE AND REVERSE OF THE G
SHEET OF THIS ORDER ARE EFFECTIVE COVERING eU'tCua!NC COoY
TEXAS UTILITIES GENERATING COMPANY ex
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A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
9 13 pu 0,
PURCHASE ORDER CONTINUATION SHEET 4
U DESCRIITION UNI RICE IT CE w NT FIXED H90RLY CLASSIFICATION REPRESENTATIVE RATE /D0LLARS CODE J03 DESCRIPTION PEo sua A
DEPARTMENT MANAGER, S.
PROJECT MANAGER S
DIVISION ltANAGER, i
ASSISTANT !!ANAGER C
SR. CONSULTAiT, ASST DIVISION MGR.
D SUPERVISOR, I
I SR. TITLED ENGINEER E
TITLED ENGINEER, SR. PLANNING ENGINEER, SR. TITLED SCIENTIST F
ENGINEER, PLANNING ENGINEER, SR. LEAD DESIGNER,*SR. DESIGNER TITLED SCIENTIST G
Ef1GINEERING ASSOCIATE,
- DESIGNER O
H=
SR. DRAFTSMAN, l
EiiGINEERIi4G AIDE, ASSOCIATE SCIENTIST I*
- DRAFTER, SR ADi11NISTRATIVE AIDE TECHNICAL AIDE J*
JR. DRAFTER, AIDE, CLERK
- NON-EXEMPT PERSONNEL THE RATES LISTED ABOVE ARE FIRM THROUGH THE SEPTEMBER 1985 BILLING PERIOD; HOWEVER, EFFECTIVE WITH THE OCTOBER 1985 BILLING PERIOD AND EACH OCTOBER THEREAFTER THE RATES WILL BE SUBJECT TO AN ESCALATION ADJUSTMENT. TUGC0 SHALL BE NOTIFIED AT LEAST 30 DAYS IN ADVANCE OF THE EFFECTIVE DATE OF SUCH PROPOSED RATE ADJUSTi1ENT.
=
PROPOSED RATE ADJUSTiiENTS SHALL BE SU3 JECT TO REVIEW AND APPROVAL BY TUGC0 MANAGEMENT AND SHALL BE SU3 JECT TO NEGOTIATION BETWEEN SWEC AND TUGCO. MUTUALLY AGREED UPON RATE REVISI0iiS SHALL BE INCORP0ATED BY WRITTEN PURCHASE ORDER O
SUPPLEMENT TO THIS PURCHASE ORDER.
AI.L. TERMS AND CONDITIONS SHOWN ON THE FACE AND R ERSE OF HE GNED SHE OF THIS ORDER ARE EFF ECTIVE COVERING.
PURCHASING CCDY
'N= = ' 222 TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC CO. -
10 13 pre er CPF 1255,
EI DESCRIPTION UNIfP[CE IT CE N
% T THE ASOVE RATES INCLJDE SALARIES (INCLUDI:lG H0LIDAY Afl0 VACATION ALLOUA! ICES), FRINGE BEfiEFITS, OVERilEA3, EMPLOYER C3?iTRIBUTIONS REQUIRED BY LAW AND TAXES BASED ON THE SALARIES OR WAGES OF EMPLOYEES PERFORMIfiG THE SERVICES, WORKMEN'S COMPEilSATI0ri AND COMPREHENSIVE GENERAL LIABILITY INSURANCE PREMIUMS FOR PERSONNEL WORKING IN SWEC'S H0 rte OFFICE, AliD FEE, BUT 00 t10T INCLUDE EXPENSES.
THE AB0VE HOURLY RATES ARE FOR BOTH STRAIGHT
' TIME AND OVERTIME HOURS OF EXEMPT EMPLOYEES.
~
THE HOURLY RATES FOR NON-EXEMPT EMPLOYEES WILL BE DETERMINED AS FOLLOWS:
~
WORKING IN SWEC'S FACILITIES FOR ALL STRAIGHT TIHE AB0VE RATES FOR ALL OVERTIME WORKED IN EXCESS OF 40 HOURS PER
'ABOVE Kart.Y O
WEEK IN SWEC'S FACILITIES AND ON SHORT TERM TEHPORARY ASSIGNMENTS AWAY FROM SWEC'S FACILITIES, BUT Nei AT THE CPSES JOBSITE; AND ALL TIME WORKED ON SATURDAYS, SuflDAYS, AND SWEC RECOGNIZED HOLIDAYS.
s WORKING AT CPSES SITE FOR ALL STRAIGHT TIME
..._AB0VE_ RATES FOR ALL OVERTIME WORKED IN EXCESS OF 40 HOURS PER WEEK AB0VE RATES DURING REGULAR WEEK; IN EXCESS OF 32 HOURS PER UEEK DURI:lG UEEK CONTAINING ONE TUGC0 RECOGNIZED HDLIDAY; IN EXCESS OF 24' HOURS PER WEEK DURING WEEK CONTAINING TWO (2) TUGC0 RECOGNIZED HOLIDAYS.
O ALL TERMS AND CONORT.ONS SHOWN ON THE FACE AND REVERSE OF HL SIG SHE OF THIS ORDER ARE EFFECTIVE COVERING PU?CP AS!NG CCSY
'N= A 222 TEXAS UTILITIES GENERATING COMP NY A DIVISION OF TEXAS UTILITIES ELECTRIC CO.-
11 13 (gE Or pg}0g5-S N
P RcHast R En c NiinuArl N SHEET UII DESCRIPTION N
% T UNI P CE IT CE A DETAILED LIST OF *A' T0 "J" POSITI0ri CLASSIFICATION TITLES IS ATTACHED TO TdIS PURCHASE ORDER AS ATTACHMENT NUMBE NE.
NEW REVISIONS SHALL BE FURNISHED TO T ACCOUNTItiG AS THEY CortE INTO EFFE EXPENSES INCURRED FOR THE SENEFIT OF THE WORK, INCLUDING TRAVEL AfiD LIVING EXPENSES OF PERSONNEL AWAY FROM THEIR PLACE OF ASSIGNMENT WILL BE REIM3 URSA 3LE.
ENTERTAINMENT IS NOT A REIM3URSABLE EXPENSE.
FOR THOSE EMPLOYEES ASSIGNED TO THE CPSES SITE, THE FOLLOWING EXPENSES WILL BE CHARGED:
1.
TRANSPORTATION AND EXPENSES TO THE J03 SITE SHALL BE REIMBURSABLE AT ACTUAL COSTS. THESE EXPENSES SHALL NOT EXCEED ONE WAY ECONOMY AIR FARE (AND GROUND TRANSPORTATION) OP. MILEAGE TO THE J03 SITE, PLUS MEALS, LODGING, PARKING AND TOLLS ENROUTE.
2.
EXPENSES AT SITE FOR MAXIMU!! 0F 21 DAYS FOR EMPLOYEES TO SETTLE-IN SHALL INCLUDE:
A.
FOOD ALLOWANCE - $25.00 PER DAY MAXIMUM.
B.
ONE ROUND TRIP ECONOMY AIR FARE TO AND FROM J03 SITE.
(IF EMPLOYEE DESIRES TO USE PERSONAL CAR OR DESIRES TO BRING PERSONAL CAR BACK TO SITE, THE EMPLOYEE WILL SE PAID 20t PER MILE VIA THE MOST DIRECT ROUTE.
IN ADDITION, FOR THOSE EMPLOYEES BRINGING PERSONAL CARS FROM NEW YORK, BOSTON, OR OTHER LONG DISTANCES, 2 DAYS PAY (16 HOURS MAXIMUM) WILL SE ALLOWED AND WILL BE EXEMPT FROM DAILY FOREMAN'S TIMESHEET REQUIREMENT.
C.
H0TEL/ MOTEL - ACTUAL CHARGES (ilVST BE COMPARABLE RATE OF GLEN ROSE, GRANSURY AND/OR CLEBURNE AREA.)
O ALL. TERMS AND CONDITIONS SHOWN ON THE FACE AND REVERSE OF THE G D SHEET OF THIS ORDER ARE EFFECTIVECOVERING F','oCH ASN9 CCoY
TEXAS UTILITIES GENERATING COMPANY
" " "o-2" A DIVISION OF TEXAS UTILITIES ELECTRIC CO. -
12,,
18 pE PURCHASE ORDER CONTINUATION SHEET whh U/I DESCRIPTION UN1' CE IT RICE D.
CAR RENTAL - ACTUAL CHARGE (ONE* CAR PER 3 PERSONS.) NOTE: RENTAL CAR SHALL iiOT EXCEED MID-SIZE OR ECDHOMY.
E.
INCIDENTAL EXPENSES - ACTUAL EXPENSES (SUCH AS REASONASLE TELEPHONE CALLS HOME,' LAUNDRY,ETC.)
3.
EXPENSES AT SITE AFTER SETTLING-IN PERIOD:
A.
PER DIEM ALLOWANCE * - $40.00 PER DAY, 7 OAYS PER WEEK, WHILE ON ASSIGNMENT ATSITE(INCLUDESTIMEDURING SICKNESS, VACATION, HEDICAL LEAVE, AND PERSONAL BUSINESS APPROVED BY TUGC0 AS SEING IN.ACCORDANCE WITH SWEC POLICIES.
- PER DIEH IS A FIXED RATE REIMBURSEMENT.FOR SUBSISTENCE 9
(INCLUDING MEALS, LODGING, I
TRANSPORTATION, AND INCIDENTALS).
PER DIEM SHALL BE PAID FROM THE CONCLUSION OF. TEMPORARY LIVING EXPENSES UNTIL COMPLETION OF ASSIGNMENT.
B.
TRANSPORTATION HOME - ONE ROUND TRIP ECONOMY AIR FARE TO AND FROM SITE EVERY 4 WEEKS (FIRST TRIP ELIGIBLE 4 WEEKS AFTER TRIP DURING SETTLING-IH PERIOD.
FOR THOSE WHO DRIVE PERSONAL CARS HOME WITHIN 300 MILES FROM THE JOBSITE, 20d PER MILE WILL SE ALLOWED.)
4.
THE CHARGES FOR EMPLOYEE TIME WILL STOP UPON SATISFACTORY C0l!PLETION OF THE EMPLOYEE'S SERVICES, HOWEVER, TUGC0 WILL PAY EXPENSES TO RETURN EMPLOYEE AND HIS BELONGINGS TO HIS REGULAR WORK LOCATION.
EXPENSES M'JST BE INCURRED WITHIN 15 DAYS OF TERMINATION OF THE EMPLOYEE'S SERVICES.
O ALL. TERMS AND CONDITIONS SHOWN ON THE FACE AND REVERSE OF THE SIGNED SHE OF THIS ORDER ARE EFFECTIVE COVERING DURCH ASING COPY
'[bar9222 TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
13,
18 CPFi55-S DESCRIPTION gggyhlCE IT CE U/I
%A ANY OTHER EXPENSES INCURRED THAT ARE DIRECTLY ASSOCIATED WITH THESE SERVICES, SUCH AS NONLCCAL C0:-iMUNICATION CHARGES, COMPUTER PROGRAMS LEASED SPECIFICALLY FOR THIS EFFORT, INTEROFFICE TRAVEL, POSTAGE, AND OTHER ITEMS OF A DIRECT NATURE WILL BE FOR TUGCO'S ACCOUNT AT ACTUAL COST. COMPUTER AND REPR0 GRAPHIC CHARGES WILL BE AT SWEC ESTABLISHED RATES IN EFFECT AT THE TIME OF USAGE. TYPICAL RATE SCHEDULES ARE INCLUDED AS ATTACHMENTS 2, 3, AND 4.
NEW REVISIONS OF THLIE RATE SCHEDULES SHALL BE FURNISHED TO TUGC0 ACCOUNTING DEPT. AS THEY COME INTO EFFECT.
TUGC0 SHALL BE INY0 ICED FOR ACTUAL HOURS BASED U?0N SWEC'S TIMESHEETS.
HOWEVER, IN ALL INV0 ICE ACTIVITIES RELATING TO ON-SITE WORK, THE TUGC0 DAILY FOREMAN'S TIMESHEET PREPARED AND APPROVED AT THE JOBSITE SHALL BE THE GOVERNING AUTHORITY. SWEC SHALL RECEIVE COPIES 0F SUCH TIMESHEETS UPON REQUEST AND BE GIVEN THE OPPORTUNITY TO REVIEW AND DISCUSS ANY DISCREPANCIES.
BILLING WILL BE MONTHLY AND DUE UPON RECEIPT OF THE INVOICE.
INVOICES FOR REIM3URSABLE EXPENSES SHALL BE SUPPORT BY ATTACHMENT OF COPIES OF RECEIPTS.
RECEIPTS FOR REASONABLE MEALS AND INCIDENTAL EXPENSES ARE NOT. REQUIRED.
SWEC IS REQUIRED TO REFERENCE THIS PURCHASE URDER HUMBER ON ALL INVOICES AND CORRESPONDENCE PERTAINING TO THIS PURCHASE ORDER.
IF, WITHIN THE FIRST 5 DAYS AN EMPLOYEE IS AT THE SITE THE EMPLOYEE IS DEEMED UNSATISFACTORY BY TUGC0 OR FAILS TO REPORT FOR WORK AT THE DESIGNATED TIME, TUGC0 WILL NOT BE CHARGED ANY EXPENSES FOR THE EMPLOYEE. HOWEVER, ALL HOURS WORKED SHALL BE PAID TO THE EMPLOYEE AT THE A30VE STIPULATED RATES.
I THE ESTIMATED TOTAL PURCHASE AMOUNT.OF THIS l
PURCHASE ORDER IS NOT TO EXCEED $.,,..........
l UNLESS AUTHORIZED BY WRITTEN SUPPLEMENT TO THIS PU 1ASE ORDER.
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PURCHASE ORDER CONTINUATION SHEET
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^fT UlI DESCRIPTION UNI PRICE ITE.
RICE TERMS AND CONDITIONS TERiiS AND CONDITIOiS STATED ON TriE REVERSE SIDE OF THIS PURCHASE ORJER 00 i40T APPLY. FOR TERMS AND CONDITIONS PURSUANT TO THIS PURCHASE ORDER REFER TO SERVICE AGREEMENT S-FN-HS-006 DATED NOVEH3ER 15. 1984, (ATTACHMENT NUMBER S TO THIS PURCHASE ORDER).
REPORTING REQUIREMENTS SWEC SHALL PARTICIPATE WITH TUGC0 IN A MONTHLY EXECUTIVE SUW:ARY MEETING TO PROVIDE COST AND SCHEDULE STATUS OF THE AB0VE STATED SCOPE OF
{
WORK.
i GIBBS AND' HILL - SWEC AGREEMENT GIB8S AND HILL - SWEC LETTER OF AGREEMENT PERTAINING TO THEIR ACTIVITIES IN SUPPORT OF TUGC0'S CPSES PROJECT IS ATTACHED HERETO AS ATTACHMENT NUMBER 6 AND FORMS AN INTEGRAL PART OF THIS PURCHASE ORDER.
VENDOR SERVICE QUALITY ASSURANCE REQUIREMENTS General Services procured herein shall be considered Nuclear Safety Related.
Strict compliance
.with referenced codes, specifications and re-quirements is mandatory.
Services shall be in accordance with the Vendor / Subcontractor's written Quality Assurance program confoming to the appitcable requirements of ANSI N45.2 and 10CFR50, Appendix 8 or ASME Section III (NCA-3800 or NCA-4000), subject to verification by Purchaser's Quality Assurance Departmnt.
Specifically, the following criteria shall be addressed;
~
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ALL TERMS AND CONDITIONS SHOWN ON THE FACE AND REVERSE OF HE GN SHEET OF THl3 ORDER ARE EFFECTlvt COVERING Ot ?Tt.J A C'h tC M OV
V 'h a 5222 TEXAS UTILITIES GENERATING COMPINY A DIVISION OF TEXAS UTILITIES ELECTRIC CO.-
Parc 15 Or-13 PURCHASE ORDER CONTINUATION SHEET 7CPF,12653-S E
Ull DESCRilTioN UNI RJCE IT RICE CRITERION I.
ORGANIZATION II.
QUALITY ASSURANCE PROGRA:t III.
DESIGN CONTROL IV.
PROCUREMENT DOCU: LENT CONTROL V.
INSTRUCTI0ilS, PROCEDURES AND DRAWINGS VI.
DOCUMENT CONTROL VII.
CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES XVI CORRECTIVE ACTION XVII.
QUALITY ASSURANCE RECORDS XVIII.
AUDITS ALL WORK SHALL BE CONDUCTED IN ACCORDANCE WITH rHE QA COMMITMENTS STATED IN CHAPTER 17.1 0F THE CPSES FINAL SAFETY ANALYSIS REPORT (FSAR).
.seller shall extend the Right-of-Access to the urchaser, his designated representative or
.)
.iuthorized regulatory agencies.
Such access shall include all facilities and records for che purpose of surveillance and Q/A audits. Seller shall establish provisions for imposing similar
]uality Assurance requirements to applicable sub-tier vendors.
]uality Assurance Program seller shall submit his Quality Assurance pro-Jram and any subsequent revisions to the Purchase' for review and documentation. (Uncontrolled copy shall be submitted with proposal and controlled
- opy upon receipt of purchase order).
In such cases where Seller has previously sub-aitted the current revision of his Quality 4ssurance Program for review and documentation for the scope of supply procured herein, the abov !
3aragraph shall not apply.
5eller shall agree to stop work at the request af Purchaser or his representative until reso-lution of any Quality Assurance / control discre-l
[
3ancy.
k
. ALL. TERMS AND CONDITIONS SHOWN ON THE PACE AND REVERSE OF THE SIGNED SHEET OF THIS ORDER ARE EFFECTIVE COVERING THE ABOVE ITEMS AS THOUGH REPEATED HEREON.
PURCHA$1NG COPY l
, '9 "o/* * "
TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC'CO.
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b"5bS PURCHASE ORDER CONTINUATION SHEET PF I
U/I DESCRIPTION T
UNI PRICE IT PRICE Nonconformaace Reporting
~
10CFR21 The provisions of 10CFR21 apply to this order and certain requirements must be met, e.g.:
21.6 Posting requirements 21.21 Notification of failure to conply or existence of a defect 21.31 Procurement documents 21.51 Maintenance of records A copy of any report furnished to the NRC of a potential deficiency /nonconformance in com-pliance with 10CFR21 concerning equipment or services intended for use in any Texas Utilities Company system nuclear power plant must be transmitted to Executive Vice President.
Operations (EVP/0PS) TUGC0 at the following address:
O Texas Utilities Generatiag Ccapany A Division of Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dalla's, Texas, 75201 Such report shall be furr.ished in the same nanner in which the report is furnished to the NRC.
THE ABOVE SERVICES ARE PROCURED FROM APPROVED FACILITY IN BOSTON, MASS.
APPROVE.
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1 A
7!/5 h
_n CPSES QUALITf ASSURANCE Q
/JATE' ILLEGAL ALIEN CONTRACTOR AGREES THAT IN PERFORMANCE OF SAID WORK, CONTRACTOR WILL NOT KNOWINGLY EMPLOY OR UTILIZE PERSONS WHO ARE NOT LEGALLY PERMITTED TO WORK IN THE UNITED STATES OF AMERICA.
CONTRACTOR FURTHER AGREES NOT TO LET ANY PORTI0?
ALL TERMS AND CONDITIONS SHOWN ON THE FACE AND R ERSE OF HE G
SHEC OF THIS CROER ARE EFFECTIVE COVERING PURCHASING CC'Y
s o E 225 TEXAS UTILITIES GERIERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC COJ 17 18 yE oF PF 6
-S PURCHASE ORDER CONTINUATION SHEET UNifPRICE I
% ANT DESCRIPTION IT CE OF SAID WORK TO SU3 CONTRACTORS WHO, IN PEK-FOR MNCE OF SAID WORK, KNOWINGLY EMPLOY OR UTILIZE PERSONS WHO ARE NOT LE3 ALLY PER:4ITTED TO WORK IN THE UNITED STATES OF ANERICA.
EXPEDITING ALL GOODS AND SERVICES FURNISHED UNDER THIS ORDER IMY BE EXPEDITED AT ALL TIMES AND PLACES INCLUDING THE PREMISES OF THE SELLER AND HIS SUPPLIERS, REGARDLESS OF TIER, EITHER BEFORE, DURING OR AFTER MANUFACTURE BY RE-PRESENTATIVES DESIGNATED BY THE OWNER. THE EXERCISE OF OR FAILURE TO EXERCISE THIS RIGHT TO EXPEDITE SHALL NOT RELIEVE THE SELLER OF HIS OBLIGATION TO FURNISH ALL GOODS AND SER-
^
VICES IN STRICT CONFORMANCE WITH ALL 0F THE TERMS OF THIS ORDER.
IF EXPEDITING IS PERFORMED ON THE PREMISES OF THE SELLER OR HIS SUPPLIERS, SELLER SHALL -
FURNISH WITHOUT ADDITIONAL CHARGES ALL REASON-ASLE FACILITIES AND ASSISTAriCE FOR THE I'
SAFETY AND C0tiVENIENCE OF THE OWNER'S REPRE-SENTATIVES IN THE PERFORMANCE OF THEIR DUTIES.
CONFIRMING TELEPHONE ORDER PLACED ON 7/22/35 BY FRED ST0BAUGH AT WHICH TIME TERMS AtiD CONDITIONS WERE VERIFIED. ANY CHANGE REQUIRES APPROVAL OF PERSON PLACIHG ORDER. -DO NOT DUPLICATE.
REFERDCE STONE AND WEBSTER LETTERS W.0. 537.336.1 DATED 6/19/85 AND 7/16/85 ATTACHMENTS:
- 1. EXHIBIT B, SHEC " PERSONNEL CLASSIFICATION SYSTEM (PS-GTM071) DATED 10/12/84.
- 2. EXHI3IT C, SUEC " COMPUTER CHARGES" DATED 1/24/85 ALL TERMS AND CONDITIONS SHOWN ON THE FACE AND REVERSE OF THE G
SHE OF THIS ORDER ARE EFFECTIVE COVERING P'Jec AP'G COPY
F i.;,
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- a222 TEXAS UTILITIES GENERATING COMP NY
- A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
18,
18 g,,,
s)CPF5255-5 f"
PURCHASE ORDER CONTINUATION SHEET ITEM QUANTITY U/l DESCRIPTION NET TOTAL NO. -
WANTED UNIT PRICE ITEM PRICE
- 3. EXHIBIT D, SWEC "SILLING RATES FOR COMPUTER GRAPHICS, SWEPS, AND MICR0 COMPUTERS dDATED 3/26/85
- 4. EXHIBIT E, SWEC "REPROGRAPHICS RATE SCHEDULE" DATED 12/24/84
- 5. SERVICE AGP.EEMENT NO. S-FN-dS-006 DATED 11/15/84
- 6. GISSS AND HILL, INC.-SWEC LETTER OF AGREBIENT DATED 7/11/85 D
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ALLTERMS AND CONDITIONS SHOWN ON THE FACE AND REVERSE OF THE SIGNED SHEET OF THIS ORCER ARE EFFECTIVE COVERING THE ABOVE ITEMS AS THOUGH REPEATED HEREON.
tt tVU AC'U1 Pov
TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTTLITIES ELECTRIC CO.
?
Fl"lN AL GOE] INCLUDIN1 AMEND.
i MENTS LY ?J Evi!US SUP LEMENTS PURCHASE ORDER SUPPLEMEN ADDtTION SY TH15 $UPPLEMENT DEDUCTION BY THIS SUPPLEMENT P.O. Box 1002, Glen Rose, Texas 76043 F.O.B.
suppLautNT MuseetR TO NOT APPLICABLE 1
CPF 12658-S oaTE AccoUur so.
SHIPMENT, PRCMISED BY oniosNAL conrutasarion
" " " ^ "
- 8-12-85 1-2-9210-330512-094 NOT APPLICABLE X
FSTONE&WEBSTERENGINEERINGCORPORATION7 no esauces,u o, c,ncett,7,oy, o, 7
HOUSTON OPERATIONS' CENTER gac",^5cVTHO Ei E$' N 'TsE u" d'E.
o 16430 PARK TEN PLACE MENT roRu issVEo oNLv av THE PUR.
"" *5'"
^"'"'"'-
HOUSTON, TEXAS 77084
[_ ATTN: JIM MONAHAN
_]
R 38044-A CONFIRMED TO: JIMMONAHAN(713)492-4230 THE PURCH ASING DEPARTM ENT HAS MA ETH FO'.
NGC NGES IN TH A VE NU MB ERED PUROH ASE CRDER ITEM OUANTITY NET TOTAL U/I DESCRIPTION NO.
WANTED UNIT PRICE ITEM PRICE THIS PURCHASE ORDER SUPPLEMENT NUMBER 1 TO PURCHASE ORDER CPF 12658-S IS ISSUED TO STONE &
WEBSTER ENGINEERING CORPORATION (SWEC) TO RESTATE THE " SCOPE OF WORK"; AMEND AND CLARIFY THE " FEE SCHEDULE"; AND MAKE CORRECTIONS TO SUBJECT PURCHASE ORCER AS STATED BELOW:
A.
NAME CHANGE,
ANY REFERENCE MADE IN THE ORIGINAL PURCHASE ORDER TO SWEC AS " STONE AND WEBSTER ENGINEERING CORPCRATION" IS CORRECTED BY THIS PURCHASE ORDER SUPPLEMENT TO READ " STONE & WEBSTER ENGINEERING CORPORATION".
B.
SCOPE OF WGP,K, GENERAL THE "SCCPE OF WORK, GENERAL" SECTION AS STATED ON PAGES 1 AND 2 IS HERESY DELETED.
" SCOPE OF WORK, GENERAL" 15 RESTATED AS l
FOLLOWS:
i SWEC SHALL FURNISH QUALIFIED PERSONNEL, ECUIPMENT, AND SCFTkARE AS REQUIF.ED TO l
PERFORM PIPE STRESS AhD PIPE SUPPORT Lasept as terca aruer.ded, dus Supplement carrics forth and precnes su Ternas and Coeliuons of the origu:d Turchase Order and previor.s Scpple:cen:
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SUPPLEMENT NO.
PURCHASE ORDER SUPPLEMENT CONTINUATION SHEET CPF 12658-S 1
UNihftICE U/I DESCRIPTION ITE PR CE wN QUALIFICATIONS IN ORDER TO ADDRESS TECHNICAL CONCERNS ON THE PIPING AND PIPE SUPPORT DESIGNS AT THE CPSES PROJECT, COMPLETE IMPLEMENTATION OF THIS SCOPE OF WORK SHALL DEMONSTRATE THE TECHNICAL ADEQUACY OF THE PIPING AND PIPE SUPPORT DESIGNS AT THE COMANCHE PEAK STEAM ELECTRIC STATION.
UPON INITIATION OF THIS SCOPE OF WORK, THE WORK SHALL PROCEED WITHOUT HOLD POINTS FOR APPROVAL BY OUTSIDE PARTIES.
SITE ACTIVITIES SHALL BE PERFORMED IN ACCORDANCE WITH GENERAL SITE POLICIES AND GUIDELINES. THESE ACTIVITIES SHALL BE IN STRICT COMPLIANCE WITH THE SWEC QA PROGRAM OR SITE ENGINEERING PROCEDURES /
INSTRUCTIONS PREPARED TO ACCOMMODATE SITE ACTIVITIES.
THIS EFFORT SHALL BE OVERVIEWED BY TUGC0 PROJECT MANAGEMENT, COMANCHE PEAK RESPONSE TEAM (CPRT), AND OTHER ORGANIZATIONS AS MAY BE DIRECTED BY TUGC0 PROJECT MANAGEMENT. THIS OVERVIEW WILL NOT RELIEVE SWEC 0F THE RESPONSIBILITY FOR FULLY QUALIFYING THE PIPING AND SUPPORTS IN THEIR FINAL MODIFIED CONDITIONS.
C.
SCOPE OF WORK, SPECIFIC THE " SCOPE OF WORK, SPECIFIC" SECTION AS STATED ON PAGES 2 AND 3 IS HEREBY DELETED.
l
" SCOPE OF WORK, SPECIFIC" IS RESTATED AS FOLLOWS:
SWEC SHALL QUALIFY ALL ASME CLASS 2 AND 3 PIPING SYSTEMS AND SUPPORTS FOR CPSES UNITS 1 AND 2 IN ACCORDANCE WITH APPROPRIATE PROCEDURES, PRACTICES, TECHNICAL TECHNIQUES, AND CONTROLS.
THE SCOPE OF THE PIPING AND SUPPORT QUALIFICATION PROGRAM SHALL INCLUDE THE FOLLOWING SPECIFIC TASKS.
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SUPPLEMENT NO.
PURCHASE ORDER SUPPLEVENT CONTINUATION SHEET CPF 12658-S 1
UNI % ICE
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U/I DESCRIPTION ITD P CE TASK 1 - 100% OF ALL ASME CLASS 2 AND 3 PIPING LARGER THAN 2 INCH.
(LARGEBORE)
TASK 2 - 100% OF ALL LARGE BORE SUPPORT DESIGNS FOR CLASS 1 SYSTEMS.
TASK 3 - 100% OF ALL CLASS 2 AND 3 SMALL BORE (2" AND UNDER) PIPING. UNIT 1 PIPING AND SUPPORTS WILL BE QUALIFIED ON A SAMPLING BASIS.
TASK 4 - VERIFICATION OF SEISMIC STRUCTURAL MODELS AND SYSTEM INPUTS TO CONFIRM THE STRUCTURAL INTEGRITY OF THE PIPING AND SUPPORT SYSTEMS.
CLASS 1 SUPPORTS IN UNIT 2 ARE INCLUDED IN THIS SCOPE.
TASK S - VERIFICATION OF THE VALIDITY OF DATA PROVICED BY/TO OTHER DESIGN ENTITIES.
TASK 6 - ASLB HEARING SUPPORT AS REQUIRED BY TUGC0 PROJECT MANAGEMENT.
THE AB0VE SCOPE OF WORK SHALL ADEQUATELY ADDRESS CONCERNS RAISED BY THE NRC, CYGNA, AND CASE.
D.
REFER TO SUBJECT PURCHASE ORDER AND DELETE PAGES 3, 4, 5, 6, 7, AND 8 THROUGH THE SECTION TITLED " CLOSURE OF SWEC SCOPE OF WORK" IN THEIR ENTIRETY.
E.
REFER TO SUBJECT PURCHASE ORDER, SECTION TITLED " FEE SCHEDULE", PAGE 9. LAST PARAGRAPH, LINE 5 WORD READING "INCORP0ATED" AND CORRECT TO READ
" INCORPORATED".
F.
REFER TO SUBJECT PURCHASE ORDER, SECTION TITLED " FEE SCHEDULE", PAGE 10 SUBSECTION TITLED " WORKING IN SWEC'S FACILITIES" AND REPLACE WITH THE FOLLOWING:
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TEXAS UTILITIES GENERATING COMPANY 2
A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
=.1a t 4 or 6 P.O. N O.
SUPPt.EMENT NO.
PURCHASE ORDER SUPPLEMENT CONTINUATION SHEET CPF 12658-S 1
U/I DESCRIPTION UNI RICE ITE CE b
WORKING IN SWEC'S FACILITIES FOR ALL STRAIGHT TIME AB0VE RATES FOR ALL OVERTIME WORKED 1.50 TIMES IN EXCESS OF 40 HOURS AB0VE RATES (UN'.ESS ADJUSTED FOR HOLIDAYS, VACATION, OR EXCUSED ABSENCE TIME) PER i
WEEK, IN SWEC'S FACILITIES AND ON SHORT TERM TEMPORARY ASSIGNMENTS AWAY FROM SWEC'S FACILITIES, BUT NOT AT THE CPSES JOBSITE; AND ALL TIME WORKED ON SATURDAYS, SUNDAYS, AND SWEC RECOGNIZED HOLIDAYS.
G.
REFER TO SUBJECT PURCHASE ORDER, SECTION TITLED " FEE SCHEDULE", PAGE 10 SUBSECTION TITLED " WORKING AT CPSES SITE". AND REPLACE WITH THE FOLLOWING:
WORKING AT CPSES SITE FOR ALL STRAIGHT TIME AB0VE RATES FOR ALL OVERTIME WORKED IN 1.50 TIMES EXCESS OF 40 HOURS (UNLESS AB0VE RATES ADJUSTED FOR HOLIDAYS, VACATION, OR EXCUSED ABSENCE TIME) AND FOR ALL TIME WORKED ON SATURDAYS, SUNDAYS AND TUGC0 RECOGNIZED HOLIDAYS.
H.
REFER TO SUBJECT PURCHASE ORDER, PAGE 10, AND ADD THE FOLLOWING:
s AL6 TERMb AND CONDIT ONS OV N O THE ACE AND AEVER E Or THE 5 GNED HE TOF 5 QRDER SUPPLEMENT ARE VEN00R' COPY
t rdm a ora TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
6 c.zac 5 OF P.O. NO.
SUPPLEMENT NO.
PURCHASE ORDER SUPPLEMENT CONTINUATION SHEE T CPF 12658-S 1
UNIhRICE i
Ull DESCRIPTION IT CE ADJUSTMENT FOR HOLIDAYS, VACATIONS AND EXCUSED ABSENCE TIME FOR OVERTfME DETERMINATIONS FOR THE PURPOSE OF DETERMINING THE NUMBER OF HOURS WORKED IN ANY WEEK, AB0VE WHICH THE FOREGOING OVERHEAD MULTIPLIER WILL BE APPLIED, A DEDUCTION FROM 40 HOURS WILL BE MADE AT THE RATE OF 8 HOURS PER DAY FOR EACH DAY NOT WORKED DUE TO PAID HOLIDAY, VACATION, OR EXCUSED ABSENCE.
FOR ONE SUCH DAY IN A WEEK, OVERTIME WILL START AT 32 HOURS; FOR TWO SUCH DAYS IN A WEEK, 0VERTIME WILL START AT 24 HOURS; FOR THREE SUCH DAYS IN A WEEK, OVERTIME WILL START AT 16 HOURS; AND SO ON.
I.
REFER TO SUBJECT PURCHASE ORDER, PAGE 12, ITEM 3.A AND ADD THE FOLLOWING NOTE OF CLARIFICATION:
NOTE:
PERSONNEL THAT DO NOT HAVE A LEGITIMATE DUAL RESIDENCE STATUS IN ACCORDANCE WITH IRS REQUIREMENTS, WILL NOT RECEIVE PER DIEM.
J.
REFER TO SUBJECT PURCHASE ORDER, PAGE 13, UNDER SECTION TITLED " FEE SCHEDULE",
PARAGRAPH 3. LINE 2. AND CHANGE THE WORD
" SUPPORT" T0 " SUPPORTED".
K.
REFER TO SUBJECT PURCHASE ORDER, PAGE 13, UNDER SECTION TITLED " FEE SCHEDULE" PARAGRAPH S, LINE 6. AND CHANGE THE WORD
" EMPLOYEE" TO "SWEC".
L.
REFER TO SUBJECT PURCHASE ORDER, PAGE 13, UNDER SECTION TITLED " FEE SCHEDULE" AND ADD THE FOLLOWING:
6 GONDIT CNS %HOWN ON THE F ACE AND AE ER E OF THE 5 GNED SHE T OF T 5 ORDER SUPPLL?tLNT ARE VENDOR' COPY
s..:
TEXAS UTILITIES GENERATING COMPANY Fo = = a 22 A DIVISION OF TEXAS UTILITIES ELECTRIC CO.
i I: ucE 6 OF 6 P.O. N O.
SUPPLEMENT NO.
PURCHASE ORDER SUPPLEMENT CON THUATION SHEET CPF 12658-S 1
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$1 gas U/1 DESCRIPTION A
p SWEC SHALL IDENTIFY ON ALL INV0 ICES SUBMITTED TO TUGC0 WHETHER CHARGES INV0 ICED ARE FOR UNIT 1 OR UNIT 2.
I SAFETY RELATED REQUIREMENTS QA/QC Requirements listed on the original pur-chase order and subsequent supplements remain in effect and apply to supplement No. 1 APPROVED:
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CPS W QUALITY ASSURA CE DATE A CONFIRMING TELEPHONE 0 ER PLACED ON 8-12-85 BY F. ST0BAUGH AT WHICH TIME TERMS AND CONDITIONS WERE VERIFIED. ANY CHANGE REQUIRES APPROVAL OF PERSON PLACING ORDER.
DO NOT DUPLICATE.
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