ML20138P548

Response to Applicant 851112 Changes to Affidavits in Support of Applicant Motion for Summary Disposition.Extent & Specificity of S&W Responses Unclear.Some Aspects Not Yet Addressed by Applicant.Certificate of Svc Encl

ML20138P548
Person / Time
Site:	Comanche Peak
Issue date:	12/19/1985
From:	Ellis J Citizens Association for Sound Energy
To:
Shared Package
ML20138P551	List: ML20138P548 ML20138P555 ML20138P563
References
CON-#485-589 OL, NUDOCS 8512260161
Download: ML20138P548 (6)

Text

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12/19/85 UNITED-STATES OF. AMERICA NUCLEAR REGULATORY COPNISSION BEFORE THE TOMIC SAFETY- AND' LICENSING BOARD C

'l Docket Nos.-50-44

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In the Matter of~

l and 50-44 5O AII 11 (TEXAS: UTILITIES ELECTRIC -l

. COMPANY, et al,. .i . .

GFFicE cc gggggg A!

{ (Application for eiKUM & SEPvtr" f

(Camanche Peak. Steam Electric. l Operating License) URANCH Station Units 1.and 2); {

CASE'S RESPONSE TO APPLICANTS' 11/12/85 CHANGES

~TO AFFIDAVITS IN SUPPORT OF. APPLICANTS' MOTIONS FOR

SUMMARY

DISPOSITION On November- 18,-1985,. CASE' advised the Board Chairman and-Applicants' counsel: Mr. Wooldridge (and NRC Staff counsel Mr. Treby a few days later) that CASE wanted to respond in writing to Applicants' changes flied November 112,-1985, to their affidavits-in support of their Motions for Summary Disposition." There were no objections, and this is CASE's response /1/. 1

' CASE's" response is primarily in:the form of the attached Affidavit of CASE Witness-Jack Doyle in Response to' Applicants' Changes in Affidavits Attached

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to Thelr:-1984 Motions for Sununary . Disposition; this response should be

- considered 'in-conjunction with the responses to the individual Motions for Summary Disposition already filed by CASE.

. There are also a few additional comments for the Board's consideration.

Applicants state in many cases that Stone & Webster will address the issue

'in question. However, it is still not clear that Stone & Webster will be address 1'ng.the specific issues which have been raised by the

./1/; Additional response may be appropriate following discovery; however, CASE Witness ~ Jack Doyle wanted to go ahead and get the attached information into the hands of the Licensing Board as soon as possible for its consideration.

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8512260161 851219 PDR ADOCK 05000445

. G PDR

'icr . ' . , .

x Walsh/Doyle allegations, the exact manner in which such issues will be addressed the extent of such-addressing, etc. Further, it is not clear whether, and in what manner, the root causes and generic implications of such.lssues will be addressed by Stone & Webster. We will be pursuing these matters further in disecvery in the near future.-

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Applicants have not clarified or.made any corrections to their affidavits supporting their motions for summary disposition concerning

- quality assurance for design, or safety factors (see footnote 3, pages 2 and 3 of Applicants' affidavit). CASE does not (as Applicants state they do) interpret the Board's Order to be limited to information presented in the affidavits which was derived from tests and analyses performed for the express purpose of addressing the issues in this proceeding. Clarification is needed from the Board as to the scope of its Intention in this regard, and if Applicants'Linterpretation is incorrect, the Board should order Applicants to also address any clarifications or changes to their affidavits in support of their motions for summary disposition concerning quality assurance for design, and safety factors.

We also call the' Board's attention to the fact that there are some aspects of the issues in question which Applicants have not addressed, regarding which CASE relles on our original responses to Applicants' Motions for Summary Disposition. Regarding generic stiffness (pages 27 and 28),

Applicants utilized generic deflection, not generic stiffness in support design; Applicants still seem not to have understood one of CASE's primary.

concerns -- that Applicants were mixing apples and oranges apparently 2

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.a.  ;,: , -

?without even realizing it. ' And, regarding Richmond inserts (pages 57 and 58

--of Applicants' affidavit), it is not clear.which equation. Stone & Webster-Is going to-use.'

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.In. addition to the preceding, we also' call the Board's attention to the

. attached DALLAS MORNING NEWS article dated today, regarding what CASE

' considers:to be new and significant information which-Is pertinent to the discussion ~'on page 17 of Mr. Doyle's attached 12/14/85 affidavit. The information In the article was made public on the first day _(yesterday) of a two-day NRC Staff / Applicants meeting, and the Board and parties will-have

" access to the transcript later. (As might be expected, CASE will also be pursuing these matters further on discovery.)

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Respectfully submitted, 2 f ~

ps.)JuaaltaEllis, President uSE (Citizens Association for Sound -

Energy) 1426 S. Polk-Dallas, Texas 75224 214/946-9446 l

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Cijr'lalla#jRoraingyrlu4 Thursday, December 19,1985 Faulty inspections found at Comanche Peak N plant By David Real units in areas under the supervi. were told to get four,"Counsilsaid.

staff writerof neNews sor's responsibility, Counsit said. He said quality suffered when An engineering supervisor who The other unit, scheduled to begin the engineering workers began set unrealistic quotas for inspec. Operations six months after its speeding up to meet the quota and tions has been dismissed from Co. twin, was not affected. The first did not double-check work per.

manche Peak and all work that he unit is scheduled to begin opera. formed by inspectors,as required.

supervised on cable-tray supports at tions in mid-1987. "That's where the breakdown oc.

the nuclear plant has been halted The inspection was designed to curred," Counsil said. "That was because of flaws, utility and federal verify that cable tray supports were wrong."

officials said Wednesdey. built according to design drawings, lie said that two other break.

A second supervisor also may be he said.The trays contain electrical downs occurred because the inspec.

dismissed, said Bill Counsil, execu. wiring that controls and monitors tions were not formally included in tivt vice president of Texas Utilities critical reactor equipment. In the surveillance activities and were Generating Co., which is responsi. worst example,a 12 inch wide cable never audited by quality assurance ble for building the plant. tray was incorrectly shown on inspectors.

Although three months' work drawings as 24 inches wide, he said. Counsit said he ordered the in. '

has been wasted because of the er. Thedrawings,onceverified,will spections be stopped immediately rors, Counsit said the impact on the be used in a computer program to when he learned of the NRC results plant's cost and schedule impact confirm that the plant has been de. on Dec. 3. He started work on an ac.

would beinsign!ficant. signed properly and will operate tion plan to respond to the prob.

Vince Noonan, Nuclear Regula. safely, lems, ordered a sampling program tory Commission project director An investigation ordered by in Unit 2 that confirmed the prob.

for Comanche Peak, said that fed. Counsil found that the supervisor lem was isolated to the supervisor eral regulators found 19 problems had reinterpreted work procedures in Unit 1, started rewriting proce.

in 32 cable tray supports that had to eliminate double checking of in. dures to avoid misinterpretation been approved by a utility contrac. spection results and had placed pro. and began retraining inspectors tor, Ebasco Services Inc., late last duction quotas oninspection teams. and engineers. Work on cable tray month. Teams had been ordered to com. supports should resume sometime

• There were a number of find. Piete inspections on four pipe sup. afterChristmas.hesaid.

ings that we felt the utility should Ports a day,Counsilsaid. Noonan said the whole incident

. have found before we found them,"- "I physically went out and raised concerns about the confi.

Noonan said, crawled many of those supports dence the NRC has in the utility, The problems were confined to myself and I don't see how you can but said the immediate action taken the first of the plant's two reactor do more than two a day- and they by Counsit was" gratifying."

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i 00CKETEc L'9Mic UNITED STATES OF AMERICA.

NUCLEAR REGULATORY COMMISSION.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DiC 24 A11:11 In the Matter ofc }{ 0FFEE OF 5Ec g ;33-

-}{ 00CHETUiG & SERvict' BRANCH TEXAS UTILITIES ELECTRIC- _}{ Docket Nos. 50-445-1

}{ and 50-446-1 COMPANY, et:al.

1(Comanche Peak Steam Electric -

}{

. Station,; Units 1 and 2) }{

CERTIFICATE OF SERVICE s

By my-signature below, I hereby certify that true and correct copies of

' CASE's Response to Applicants' 11/12/85 Changes to Affidavits in. Support of Applicants Motions for Sumary Disposition December ,19g5, have been'sent to the names listed below this 19th day of _

i: by:- Express Mail where indicated by

• and First-Class Mail'elsewhere.

=* Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

.U. S.-Nuclear. Regulatory Commission Bishop, Liberman, Cook, Purcell

& Reynolds 4350 East / West Highway, 4th Floor-

~Bethesda, Maryland -20814 1200 - 17th St., N. W.

Washington, D.C. 20036-

• Judge Elizabeth B. Johnson 10ak Ridge National Laboratory

• Geary S. Hizuno, 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 Carib Terrace Motel Board Panel 522 North Ocean Boulevard U. S. Nuclear Regulatory Commission Pompano Beach, Florida 33062 Washington, D. C. 20555 1

] =. *:.;

Renea Hicks, Esq.

Chairman- .

Assistant Attorney General

' iAtomic Safety and-Licensing Appeal

, Environmental Protection'. Division Board Panel- Suprese Court Building

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U. S. Nuclear Regulatory _ Commission l

. Washington, D. C. 20555 . Austin, Texas 78711 Anthony Z. Roissan, Esq.

Mr'. Robert Martin. . Trial Lawyers for Public-Justice Regional Administrator, Region IV 2000 P Street, N. W., Suite 611 U. S. Nuclear Regulatory Commission Washington, D. C. 20036-611: Ryan Plaza Dr., Suite 1000 Arlington. . Texas '76011 Mr. Owen S. Merrill Lanny A. Sinkin- ,

Staff Engineer Christic Institute Advisory Committee for Reactor 1324 North Capitol Street - Safeguards (MS H-1016)

-Washington, D. C. 20002 U. S. Nuclear Regulatory Commission

. Washington, D. C. 20555 Dr. David H. Bolts 2012'S. Polk- Robert A. Wooldridge, Esq.

Dallas, Texas 75224 Worsham, Forsythe,.Sampels

& Wooldridge William Counsil, Vice President 2001 Bryan Tower, Suite 2500 Texas Utilities Generating Company Dallas, Texas -75201 j Skyway Tower 400 North 011ve'St., L.B. 81 Thomas G. Dignan, Jr., Esq.

Dallas,' Texas 75201 Ropes & Gray

-Docketing and Service Section 225 Franklin Street Boston, Massachusetts 02110 (3 copies)

- Of fice of the Secretary 'Ms. Nancy H. Williams U. S. Nuclear Regulatory Commission Project Manager Washington, D. C. 20555 Cygna Energy Services 101 California Street, Suite 1000 Ms. Billie P.. Garde San Trancisco, California ,

~ Government Accountability Project '

94111-5894 1901 Que Street, N. W.

Washington, D. C. 20009 Mark D. Nozette, Counselor at Law Heron, Burchette, Ruckert & Rothwell Roy P. Lessy, Jr. 1025 Thomas Jef f erson Street, N. W. ,

Morgan, Lewis s Bocklus Suite 700 1800 M Street, N. w. Washington, D. C. 20007 Suite 700, North Tower Washington, D. C. 20036 2nm 6 ,

ffA i ,

(p.T Juanita Ellis, President GSE (Citizens Association for Sound Energy) j 1426 S. Polk Dallas, Texas 75224 214/946-9446 l

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