ML20150D091
| ML20150D091 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/18/1988 |
| From: | Edgar G NEWMAN & HOLTZINGER, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bloch P, Johnson E, Jordan W, Mccollom K AFFILIATION NOT ASSIGNED, Atomic Safety and Licensing Board Panel, OAK RIDGE NATIONAL LABORATORY |
| References | |
| CON-#188-5915 OL, NUDOCS 8803230087 | |
| Download: ML20150D091 (40) | |
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Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing 1107 West Knapp Board Stillwater, Okalhoma 74075 U.S. Nuclear Regulatory Commission Elizabeth B. Johnson Washington, D.C.
20555 Oak Ridge National Laboratory P.O.
Box X, Building 3500 Dr. Walter H. Jordan Oak Ridge, Tennessee 37830 881 West Outer Drive Oak Ridge, Tennessee 37830 RE:
Texas Utilities Electric Company, et al.
Docket Nos. 50-445-OL and 50-446-OL
Dear Administrative Judges:
In accordance with the Board's request of August 8, 1986 Applicants herewith submit four additional chronologies of confirmed issues.
These chronologies were inadvertently cmitted from Applicants' final submittal made to the Board on February 29, 1988.
Sincerely yours, s
George L.
Edgar Enclosures i
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3 50
1 Conduct of the Containment Integrated Leak Rate Test (CILRT)
ISAP III.b History On page J-14, Item 3.2.3 of SSER-7 the NRC discussed the issues and concerns related to the conduct of the Containment Integrated Leak Rate Test and stated in part:
"The [TRT) found no safety significance for the allegatior.s in TP Category 3 (Containment Integrated Leak Rate Testing), but concluded that a generic problem could exist because when the CILRT leakage rate was calculated by a method different from that which was committed to in the FSAR, the FSAR had not been amended to reflect that change.
The TRT questioned the TUEC procedure for documenting and identifying FSAR deviations to the NRC.
In order to obtain an operating license for a water-cooled power reactor such as CPSES, it is necessary to demon-strate that the principal reactor containment building meets the leakage test requirements set forth in 10 CFR 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Reactors."
Appendix J requires preoperational testing of the overall leak tightness of the containment building (CILRT) and establishes acceptance criteria for the test.
The testing is conducted to assure that total leakage through all designated penetrations and building flaws, if any, does not exceed the value specified in Appendix J on the CPSES Technical Specifications.
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t Both 10 CFR 50, Appendix J and the CPSES Final Safety Analysis Report (FSAR) Amendment 12, October 1980, specify the use of the American National Standard Institute (ANSI)
N 45.4-19, "Leakage Rate Testing of Containment Structures of Nuclear Reactors," to carry out the test.
A later revision of the ANSI standard, ANSI /ANS 56.8, "Containment System Leakage Testing Requirement," prescribes essentially the same test procedure for the CILRT, but prescribes another method for calc 6tating the leakage rate.
The method used by Applicant for calculating the leakage rate, as reported to the NRC, was that found in ANSI /ANS 56.8-1981, which was not consistent with Applicants' FSAR commitment.
While this method differs from that prescribed in ANSI N45.4-1972, the leakage rate which tesulted from the use of the calculation method in ANSI /ANS 56.8-1981 would be essentially equivalent to the results which would be obtained using the method in ANSI N45.4-1972.
The TRT in its letter of September 18, 1984 expressed the concern that Applicant should have either used ANSI N45.4-1972, or provided the NRC with justification for using an alter-native calculation method to report the results of the CILRT.
This letter was the first indication of NRC concerns related to CILRT.
Further, the TRT was concerned that a generic problem might exist regarding procedures for documenting and identifying FSAR deviations to the NRC.
The need to address FSAR commitments related to the tee. ting program has been recognized since the inception of the CPSES Startup Frogram.
The first Unit 1
s preoperational test was started in July, 1982, and the applicable CPSES Startup Administrative Procedures regarding FSAR commitment compliance has been in place since 1979.
Although the CPSES Startup organization did not have a specific written admini-strative procedure for processing an FSAR change until after the TRT review, its established practice was to complete a standard FSAR Change Request form.
If the proposed change was accepted by CPSES, the information in the change request form was then incorporated into an FSAR Amendment which was forwarded to the NRC.
TUGCO believed this procedure adequately documented and identified FSAR deviations to the NRC.
Following notification by TRT of this issue on September 18, 1984, CPRT ISAP III.b (Conduct of the CILRT) was issued to address the TRT finding as stated in SSER No. 7 and undertook the actions required by the TRT therein.
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Gap Between Reactor Pressure Vessel Reflective L
Insulation and the Biological Shield Wall i
ISAP VI.a l
History l
At page K-180 of SSER-8, the TRT identified concerns regarding the gap between the Reactor Pressure Vessel Reflective Insulation (RPVRI) and the Biological Shield Wall.
The TRT concluded as follows:
"The TRT investigated an allegation that the Unit I reactor pressure vessel outer wall was touching the concrete biological shield wall.
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A TRT review of existing documentation and l
discussions with TUEC personnel indicated that this allegation was not factual.
A significant construction deficiency report, submitted pursuant to 10 CFR 50.55(e), on August 25, 1983, documented that unacceptable l
cooling occurred in the annulus between the RPVRI and the shield wall during hot func-tional testing, apparently because of the existence of an inadequately sized annulus l
gap and possibly because the presence of l
construction debris in the annulus.
TUEC corrected the situation by modifications to allow increased air flow for proper heat dissipation and by removal of the construc-tion debris.
TUEC representatives indicated that testing to verify the adequacy of the cooling flow will take place when additional hot functional testing is conducted.
I Information gathered by the TRT during the I
investigation indicated that a design change I
in the RPVRI support ring (i.e., locating the ring outside rather than inside the insula-tion) resulted in a limited clearance between the RPVRI and the shield wall.
The TRT review of the 50.55(e) report revealed the TUEC failed to:
(1) address the fundamental issue of the design change impact on annulus cooling flow, and (2) determine whether Unit 2 was similarly affected."
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f The history of this TRT issue can be traced to March, 1973 when Westinghouse issued the original specification for the RPVRI, Specification 676449, Revision 2, which required that the RPVRI structural steel support ring be contained inside the insulation.
Consistent with procedure, Westinghouse issued drawings for Construction regarding its plan for constructing the support ring.
However, in the drawing issued for Construction the support ring is shown to exist outside the boundary of the insulation.
No design change document or revision to the Westinghouse specification relative to location of the support outside the insulation boundary has been identified.
This deviation from the Westinghouse specification was not communi-cated as a deviation to Gibbs & Hill, and no evaluation was done to consider the impact of the outside support ring on air flow and cooling efficiency between the reactor pressure vessel and the biological shield wall.
In April, 1983, TUGCO Startup identified inadequate l
cooling in the reactor cavity during Hot Functional Testing (HFT) and recorded it as a test deficiency (TDR-908).
A meeting was held at CPSES on April 20, 1983, to discuss TDR-908 and appro-priate disposition.
Design Change Authorization DCA-17,367 was issued on May 16, 1983, to identify action taken to resolve TDR-908.
A retest of air flow and cooling efficiency was conducted with unsatisfactory results.
On May 26, 1983, TDR-1221 was issued regarding the deficiency identified during the retest.
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t On July 28, 1983, TUEC orally reported the test deficiency to the NRC.
On August 25, 1983, TUEC initiated its formal report of the test deficiency as a 50.55(e) item by submitting an interim report (TXX-4033).
This was followed by submittal of another interim report (TXX-4042) on September 6, 1983.
On September 26, 1983, TUEC submitted its completed 50.55(e) report (TXX-4054) regarding the deficiency.
Westinghouse issued Field Change Notice (FCN) TBXM-10,609 on September 27, 1983, which documented the unacceptable air flow restraint and cooling efficiency condition.
Westinghouse issued procedure MP2.7.1/TBX-3 on October 1, 1983, which described the following equipment modifications to be made:
(1) drilling holes in the support channel to facilitate air flow; and (2) installation of a flow restrictor at the top of the reactor vessel insulation (FCN TBXM-10,612).
Westinghouse completed hole drilling in the support channel between October 4 and October 14, 1983.
Installation of the flow restrictor and BMI tube vertical restraints were com-pleted the week of October 24, 1983.
Confirmatory air flow tests were completed during the week of October 31, 1983, with accept-able results.
On November 18, 1983, Westinghouse transmitted a letter to TUGCO which summarized the efforts undertaken to correct the reactor cavity cooling problem.
(Westinghouse Letter, 11/18/83, WPT-6789, Puryear to Merritt).
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Following notification by TRT of their concern regarding the RPVRI on November 29, 1984, TUEC formed the CPRT and issued ISAP VI.a (Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall) to address the TRT finding.
The Results Report for ISAP VI.a was published on April 27, 1987.
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Nonconformance and Corrective Action System ISAP VII.a 2 History TRT letter of January 8, 1985 identified specific weaknesses in the CPSES Nonconformance and deficiency reporting system.
The TRT found that:
"The TUEC procedure for preparation and processing of NCR's did not contain explicit instructions for handling voided NCR's.
"NCRs were used as a tracking document to record removal of a part from equipment on a permanent equipment transfer rather than for reporting a nonconforming condition; such usage of the NCR was not defined in proce-dures.
"There was an inconsistency between para-graphs 2.1 and 3.2.1 in procedure CP-QP-16.0.
Paragraph 2.1 required all site employees to report nonconformances to their supervisor or to the site QA supervisor, while paragraph 2.1 required persons other than QA or QC personnel to submit a draft NCR to the Paper l
Flow Group.
"The NCR term had no form number or revision I
date to indicate that the form was being adequately controlled.
i "There were two versions of the TUEC NCR form one with and one without a space for the Authorized Nuclear Inspection (ANI) review.
l "The NCR form had no space to identify the cause of the nonconformance and the steps taken to prevent its recurrence.
"The NCR form had no provisions for quality assurance review.
"The TRT found approximately 40 different forms (other than NCRs) for recordirq deficiencies.
Many of these forms end reports were not considered in trending nonconformance conditions.
. "The TRT notes that TUEC did not initiate an NCR identifying the widespread problem of missing locknuts:
only a Request for Field Information was generated.
"Deficiency reporting procedure CP-EP-16.3 appeared to relate only to Craft and Engi-neering personnel and was not directed to noncraft and nonengineering personnel who may have had knowledge of reportable items.
Procedure CP-EP-16.3 indicated that the applicable manager was responsible for documenting and reporting Deficiency and Disposition Reports (DDRs); but there were no checks or balances to ensure that a manager or a designated substitute.vuld process a DDR.
"Other external source issue documents such as the Construction Adequacy Team (CAT) report, the Management Analysis Company (MAC) report, NRC Region IV Reports (RIVIR), and allegations as reported in Safety Evaluation Report Supplements (SSERs) elaborate on weaknesses in the NRC system."
The January 8, 1985 TRT letter, identified the following issues related to Applicant's Corrective Action activities:
"Repetitive NCRs were issued that identified the need to retrain construction personnel in the requirements and contents of QA procedures.
One corrective action request (CAR) dealing with inadequate construction training and records remained open for one year.
The identical problem was identified j
in a subsequent CAR, which still had not been closed at the time of the TRT onsite review.
"The Brown & Root corrective action system was generally ineffective and was bypassed by the Brown & Root QA Manager, as exemplified in the following instances:
"There were no definitive instructions to describe the types of problems that required corrective action.
Minimal procedural
instructions resulted in corrective action decisions frequently being left to the judgement of the QA Manager.
"Since June, 1983, Brown.& Root had issued no Corrective Action Requests (CARS), and was substituting memos and letters of concern for this function.
This shortcut had become a regular method of operation and appeared to bypass the CAR system.
"The TUEC corrective action system was poorly structured and ineffective in that:
"Controlling procedures were brief and general.
"There was no translation of FSAR require-ments on trending and no details on how trend analyses were to be accomplished.
"Quarterly reports were not issued in a timely manner.
"The method of categorizing problems by building did not assure meaningful. trend analysis.
"A 1984 CAR Report identified three items requiring action; however, none had been taken.
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"CAR 029 was used as a vehicle for a specific disposition rather than for generic l
action as intended by the CAR system."
"Other external source issue documents such as the CAT report, the MAC report, RIVIRs, and allegations as reported in SSERs elabo-rate on weaknesses in the Corrective Action system."
The same January 8, 1985 TRT letter also discussed potential weaknesses in the TUEC 50.55(e) deficiency reporting system, which included the following:
l "There were potential weaknesses in the TUEC 10 CFR 50.55(e) deficiency reporting system.
Applicable procedures did not identify what types of deficiencies constituted significant
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. breakdowns in the QA program, nor how they should be evaluated for reportability to the NRC.
Evaluation guidelines for reporting hardware deficiencies lacked clarity and definitive instructions and the threshold for reporting deficiencies was too high.
Specific past and present construction deficiencies that were not reported by TUEC are listed in Sections 4, 5 and 11 (NRC January 8 letter).
"The TRT found examples in Unit 1 where deficiencies existed so that TUEC was in potential violation of the codes, procedures, guidelines and coinmitments concerning locking devices for threaded fasteners.
In spite of the req 11rements pursuant to 10 CFR 50.55(e),
TUEC did not report to the NRC the omission of the thread-locking devices in the Unit 1 nuclear safety systems and did not attempt corrective action until May 1984, when TUEC tested previously applied paid for thread-lock capability.
That test was inconclusive since it did not establish that the paint, an epoxy process, would reliably perform as an effective locking device under all service condLclons and throughout the expected lifetime of the plant.
Further, TUEC could not identify to the TRT which paint was the subject of testing.
"TUEC did not consider the Cygna audit findings regarding the DCC as appropriate for formal reporting to the NRC pursuant to 10 CFR 50.55(e), as required by procedure CP-EP-16.3, "Control of Reportable Deficiencies."
"TUEC failed to maintain material tracea-l bility for safety-related material and l
numerous hardware components.
This QA breakdown was identified in an ASME Code survey in October, 1981 yet was not reported to the NRC in accordance with the require-I ments of 10 CFR 50.55(e).
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"Other external source issue documents such as the CAT report, the MAC report, RIVIRs, and allegations as reported in SSERs elabo-rate on weaknesses in the 10 CFR 50.55(e)
Reportability system."
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. Because of the close interrelationship of TRT concerns involving the nonconformance systems, the corrective action systems, and the 10 CFR 50.55(e) reportability system, all TRT issues relative to each area were addressed in ISAP VII.a.2.
The history of each area of concern will be separately discussed.
Nonconformance Reoortino System The history of issues regarding systemic deficiencies in the nonconformance reporting system have their origin in the May 17, 1978 Management Analysis Company (MAC) Report.
That report, prepared for TUGCO, found that the dispositioning of nonconforming items did not always achieve the requisite review by appropriately qualified design personnel.
In addition MAC noted that the design change / design deviation program had been used to bypass the nonconformance reporting system.
In an internal TUGCO response to management dated 7/11/78, the report's conclusions were reviewed and corrective action was deemed unnecessary,.
On 8/25/78, NRC Inspection Report 78-12 noted that cable tray supports identified on a Nonconformance Report (NCR) were not adequately tagged and segregated.
This was cited as a violation of 10 CFR 50, Appendix B.
TUGCO's letter to the NRC (TXX-2881 dated 9/21/78), outlined both corrective and preventive actions in response to IR 78-12.
These actions included a review with field supervisory personnel of non-conformance reporting requirements found in CP-QAP-15.1 and additional training
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On November 6, 1978, TUGCO provided a supplemental response (TXX-2901) to the NRC findings in IR 78-12 explaining in greater detail TUGCO actions to avoid further non-compliances which included enhanced surveillance by Site QA.
The NRC issued Inspection Report 79-19 and a Notice of Violation on 8/10/79 citing TUGCO's fMilure to adequately disposition NCR E-lS70, and to identify and segregate nonconform-ing electrical cable.
TUGCO submitted a response to IR 79-19 on 9/27/79 (TXX-3049),
citing amendments to instructions and procedures and correction of improperly installed cables.
Also noted was that "added emphasis will be placed in the established ongoing site training program to assure that QC Supervisory personnel fully understand the need for proper identificatior. of nonconforming conditions and have a basic understanding of applicable QA criteria.
Brown and Root Quality Assurance Audit Report CP-16 (12/6/79) identified deficiencies in the NCR and Corrective Action (CA) program related to inadequate procedures for report-ing nonconformances and to the apparent failure of personnel to follow NCR/CA reporting procedures.
In March, 1980, Brown & Root Memo IM-18790 responded to the Audit CP-16 concerns.
While recognizing that the existing reporting system provided suffi-cient resolution, identification, correction and prevention of
. deficient conditions, Brown & Root specified changes in proce-dures to more adequately provide both corrective and preventive action.
In NRC Inspection Report 80-08 (4/13/80) and related Notice of Violation, TUGCO was cited for failure to follow procedures for reporting and repair of damaged electrical cable (Brown & Root Procedure 35-1195-EEI-13).
The original cable damage and repair shield was not reported via a Field Deficiency Report as required.
On May 14, 1980, TUGCO submitted a response to NRC Inspection Report 80-08 (TXX-3142) in which it outlined the corrective action that had been taken through replacement of all damaged cable and additional training stressing procedure compliance.
The NRC reported IR 80-08 closed on 6/17/80.
(NRC Inspection Report 80-11).
The NRC issued Inspection Report 80-22 on January 21, 1981, in which the results of its staff investigation during September and November, 1980, were released.
One of the allega-tions reviewed was that the Brown & Root QA department was not ensuring that corrective action was being taken regarding l
document nonconformances.
The NRC in IR 80-22 found this allegation to be unsubstantiated, so also was an associated allegation that a TUGCO QA auditor had instructed that waivers be prepared on nonconforming components.
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, On June 19, 1981, in its First Quarter Corrective Action Report (TUG-902), TUGCO Quality Engineering noted the use of safety-related field requisitions for ordering replacement materials which had been damaged in the field.
Investigation had determined that NCR's were not being issued in all cases.
TUGCO Audit TCP-25 identified one concern associated with a lack of procedures to resolve document deficiencies noted by a receiving inspector.
In the TUSI response to TCP-25 of 12/10/81, it was observed that the informal methods effectively used in resolving document deficiencies would be incorporated into written procedures (CP-EP-16.0).
This response was con-firmed as satisfactory on 1/14/81 (OTN-461).
On 12/9/81, TUGCO Audit TCP-28 identified a deficiency in the nonconformance reporting system whereby temporary waiver tags were not approved by appropriate personnel.
TUGCO's Audit Report TCP-28 dated 1/7/82 reviewed specific corrective action taken by TUGCO including a review of all NCR's requesting a temporary waiver.
Preventive action was specified in TUQ-1027 to reorient appropriate personnel with the nonconformance procedures concerning signature authority on temporary waiver tags.
Corrective Action Request S-46, dated 1/15/82, noted that Component Modification Cards had been incorrectly used to resolve deficiencies instead of as prescribed by Nonconformance Procedure QI-QAP-16.1-2 and 16.6.3.
In response to CAR S-46,
. Field engineering personnel were informed of the QA Manual requirements for the documenting of nonconformance items and this instruction was confirmed in writing on 2/11/82.
During June, July and September, 1982, ASLB hearing transcripts reveal that issues related to the NCR process were explored in testimony presented covering the area of Quality Control / Quality Assurance at CPSES, (Hearing Transcript at pp. 1,676-1,680; 2,338-2,343; 2,389-2,601; and 4,551-4,558).
Also in September, 1982 Site Inspection Service 310 prepared by Hartford Steam Boiler (9/15/82) identified the improper use of Field Deficiency Reports (FDR) to document
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nonconforming conditions.
TUGCO's response of 10/7/82 including revising CP-QAP-16 to delete the option of utilizing FDR's for the reporting minor nonconforming conditions, a review of all FDR's for possible code violations and, if required, the issuance of NCR's.
Site Inspection Service 310 was closed on 12/14/82.
On September 17, 1982, TUGCO Audit Report TCP-48 noted that QA Procedure CP-QAP-16.1..
Rev. 11, "Control of Nonconform-ing Materials," did not provide for reporting of non-ASME related nonconformances yet Brown & Root QC personnel were reporting some l
1 non-ASME nonconformances in accordance with the procedure.
This inconsistency was addressed by Brown & Root on 10/20/82 through amendment of Procedure CP-QAP-16.1 to include nonconfornances associated with safety related Class 1, 2 and 3 activities.
This Audit was closed on 2/2/83 upon verification that corrective action was completed.
(2/2/83 Memorandum regarding TCP-48).
. Brown & Root Corrective Action Request S-50, dated 10/22/82, reviewed five NCR's which identified rework of noncon-forming items prior to completion of their disposition.
TUGCO provided a response to CAR S-50 on 11/3/82 and the CAR was verified as closed on 11/21/82.
TUGCO Audit Report TCP-57' dated 11/1/82 observed that the as-built verification group was not utilizing the NCR form to identify inconsistencies between design requirements an.' as-built conditions.
The auditors stated that their primary concern was the existence of technically inconsistent p'rocedural requirements and not inadequate implementation of the NCR program.
The TUGCO response advised that QI-QP-ll.13-1 had been revised to resolve the auditor's concerns.
The revision deleted the requirement that NCR's were to be generated during the QA as-built Survey and additional revisions provided for notation of inconsistencies in an alternative manner.
On 11/16/82 and 2/4/83, (TUQ-1472, TUQ-1546)
TUGCO QA/QC provided direction to inspection personnel on documenting nonconforming conditions utilizing inspection reports.
Inspec-tion personnel were required to report all discrepant conditions on an unsatisfactory Inspection Report in accordance with CP-CP-18.0 with the exception of material / items which are damaged after final QC acceptance.
Corrective Action Request CAR-20, issued on 3/18/83, identified numerous instances of defective circuit boards discovered during prerequisite or preoperational testing, none of
which had been documented by an NCR or Test Deficiency Report (TDR) (TUC 1585).
On March 20, 1983, TUGCO proposed corrective action through issuance of TDR-787 to evaluate all vendor repairs and modifications which may have been made on the defective boards and began immediately to document all circuit board failures in accordance with the TDR system specified in Procedure CP-SAP-16.
Preventive action included additional training for all Startup Testing Engineers associated with circuit card testing and pursuant to Startup Memo SU-83186 (3/17/83) to more clearly define Test Deficiency Reporting of unidentifiable or defective circuit cards.
Pursuant to TUGCO Memo TUQ-1740, the response to CAR-20 was deemed satisfactory and in 7/19/83 was closed.
On 6/9/83, Corrective Action Request CAR-029 was issue 6 when rewora on a nonconforming item (valve) was completed prior to disposition of the NCR and without removal of the hold tag by QC inspection prior to performance of rework. Since CAR-029 identified discrepancies in violation of TUGCO quality assurance procedures for the control of nonconformances, the TUGCO response TSU-83174 (6/27/83) specified corrective action to properly document the disassembly QC inspection and proper valve reassem-bly.
TSU-83174 also outlined preventive action involving reinstruction of System Test Engineers in applicable noncon-forming procedures.
The response to CAR-029 was considered satisfactory and closed on 7/1/83 (TUQ-1723).
. The NRC sent a Notice of Violation to TUGCO on 7/11/83 arising out of NRC Inspection Report 83-15/83-09.
The Notice of Violation resulted from an instance of base metal repair not having been documented on a NCR in violation of NRC procedure.
TUGCO responded on July 29, 1983, (TUG-1745) that the Notice of Violation had resulted in corrective action through the issuance of NCR-M-6611 (5/7/83) documenting the base metal repair and that all applicable documents have the NCR appropriately referenced.
TOGCO outlined corrective measures resulting from the Notice of Violation in a letter to the NRC (TXX-4020).
Due to a tren6 analysis identifying 62 NCR's issued for procedure violations which included failure to obtain authoriza-tion to perform work, failure to notify QC for hold points and for violation of QC hold tags.
Corrective Action Request CAR-032 was issued on 8/17/83.
Brown & Root's analysis of the violations noted in CAR-032 indicated that the problem was most prominent in the Electrical Department. Therefore, corrective and preventive action was focused primarily in that area.
Other areas were identified as being affected only on an isolated basis.
In a memo to TUGCO QA, the Brown & Root General Electrical Superintendent stated that disciplinary action would be taken if procedures were intentionally ignored or ignored due to negligence. Further, supervisors were reminded of their respon-sibility to make sure personnel were properly indoctrinated in procedural requirements.
On 10/24/83, this response to CAR-032 was determined to be acceptable (100-1839).
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. During the period 1/24/83 through 3/3/83, the NRC's construction Appraisal Team (CAT) conducted its inspection of CPSES.
On 4/11/83, CAT issued its findings.
The CAT Report noted that nonconforming conditions identified relative to some safety-related hardware installations were not being properly documented, evaluated and dispositioned through the Corrective Action Program.
The NRC's Region IV conducted a follow-up inspection to the CAT appraisal during the period June 27 through September 16, 1983.
This inspection was documented in NRC Inspection Reports 50-445/83-16 and 50-446/83-12. In the IR, the NRC inspector noted that he was "unable to identify any area where a discrepancy, deviation, or nonconforming condition, once identified, regardless of method of documentation, that was not properly tracked, corrected and inspected".
The IR further stated that CAT potential findings regarding improper disposi-tions or nonconforming conditions, was addressed in the NRC follow-up inspection and was considered closed.
(NRC letter 10/3/83)
TUGCO Audit Report TCP-87 (12/27/83) was issued covering the construction /QC nonconformance and corrective action program.
The addit identified several program deficiencies including: (1) an NCR procedure which did not adequately describe control of deviation forms with generic NCRs; (2) several hold tag identification problems; and (3) on several instruments in the field, the actual installation was different than identified on NCRs applicable to these instruments.
TUGCO responded to
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. TCP-87 on 1/31/84, (TUQ-1933) explaining the bases for audit conclusions and citing corrective action where appropriate.
On May 3, 1984, (QTO-708) the TUGCO responses were evaluated and accepted.
1 In TUGCO Audit TCP-103 dated 6/4/84, TUGCO QA identi-fled an instance of failure to identify non-Class IE material as nonconforming in compliance with ANSI N45.2-1971, Section 16, "Nonconforming Items," and further that improper documentation was used to ellow installation of nonconforming items.
TUGCO's response of 6/21/84 (CPPA-39.92) and 6/27/84, (TUQ-2254) noted that all nonconforming materials had been replaced and appropri-ate documentation provided.
The-NRC's Special Review Team (SRT) conducted a review of CPSES during the period April 3-13, 1984.
One of the SRT findings (Item E.5(8)) identified two pipe supports which had not been installed as specified in detailed drawir.gs, yet had been inspected by QC without identification of the nonconformance.
The TUGCO response dated 9/7/84, (QBC 84) stated that appropriate NCR's had been issued following the SRT report (ECR 13.384 and NCR13.349) and that corrective action resolving both NCR's had been completed.
Additional emphasis was also placed on complying with procedures controlling disassembly of component parts (Procedure CP-CPM-6.10).
During July, 1984, TUGCO QA issued Audit TCP-105 (7/20/84) citing an instance where a nonconforming material condition had not been identified on an NCR.
The TUGCO letter TUQ-2298 (8/17/84) provided a QA response to TCP-105 i
-e,
. concerns which indicated an engineering evaluation had been performed and documented regarding the nonconformance, (CPP-2642) and that a Significant Deficiency Analysis Report (SDAR 80-1) had been prepared (OTN-984, 10/24/84).
The NRC issued Inspection Report 84-34/84-13 on 12/31/84 citing an SRT identified failure of QA inspection to identify nonconformances in support installations.
(NRC SRT Inspection:
8/26/84-10/20/84.)
On 1/8/85, the TRT notified TUGCO of the TRT findings with regard to the Nonconformance Reporting System.
Subse-quently, CPRT was formed and ISAP VII.a.2 (Nonconformance, Corrective Actions and 10 CFR 50.55(e)) was issued to respond to the TRT findings.
Corrective Action Proarams The CPSES Corrective Action Program (CA) was actually composed of two systems: The TUGCO CA and the Brown & Root CA.
These Corrective Action programs were used by Brown & Root and TOGCO to identify recurrent or significant conditions adverse to quality and to initiate corrective and preventive actions.
The TRT review determined that the CA procedures issued by Brown & Root and TUGCO to control their respective CA Systems contained provisions for performing both the trend analysis and the corrective action functions.
The Brown & Root procedures extended from mid-1975 to the present time.
TUGCO procedures
. were first issued in 1980 and also extend to the present time.
Prior to 1980, TUGCO utilized Brown & Root procedures for addressing corrective action concerns.
The history of issues related to CA Programs has its origin in the NRC's Construction Appraisal Team (CAT) Inspection Report of 4/11/83.
The CAT Report noted under the finding entitled "Design Change Controls and Corrective Action Systems" that contrary to 10 CFR 50, Appendix B and FSAR Sections 17.1.2 and 17.1.15, nonconforming conditions identified relative to some safety related hardware installations were not being properly documented, evaluated and dispositioned through the CA Program.
In addition, it is conceivable, based upon the evolutionary dichotomy of the tvo CA programs, that with respect to the Brown Root CA Program the history of CA issues can be traced to November 18, 1977, with the issuance of Site Surveillance Report G-062-77.
This report identified a number of deficiencies in compliance with the procedural requirements for Corrective Action Requests (CAR) including failure to follow-up action and/or verify corrective action and failure to comply with CAR reply due dates.
Brown & Root provided a response to the Site Surveillance Report on 12/9/77 (BRQ-0768) which included a reevaluation of the Brown & Root response to the potentially reportable event and instruction of personnel on nonconformance procedures.
Site Surveillance Report G-062-77 was closed on 12/30/77.
. On December 6, 1979, Brown & Root Audit Report CP-16 identified several concerns in the area of corrective action.
Specifically noted was a lack of site QA Manager review of numerous' corrective action documents and a failure to comply with procedures which required reports that summarized and trended nonconformance and corrective actions.
Brown & Root provided response to CP-16 on 3/20/80 which included changes in the responsibility of the site QA Manager and improvements in the CA reporting process related to procedures QAM 15.11, QAM 15.3 and CP-QAP-15.1.3.6.
Audit CP-16 was closed on 11/5/81.
(CPQ 0441)
The June and July 1982 ASLB Hearings transcripts reveal that issues related to the nonconformance program and corrective action program were discussed.
(Hearing Transcript pp. 727, 1676-1680).
As previcasly noted, the CAT Inspection Report was issued on 4/11/82.
The primary corrective action concern of the CAT report was that nonconforming conditions were being processed through various programs and were not being evaluated under the Corrective Action program.
The Brown & Root Memo of 5/3/83 concluded that responsive measures to CAT had already been taken and that the CA programs were in compliance with FSAR commitments and regulatory requirements.
NRC Inspection 83-23 was conducted between May 23, 1983 and June 10, 1983.
It concluded with the issuance of a citation as a result of the alleged inadequacy of Quality Control proce-dures applicable for the installation and inspection of NPSI i
. seismic sway strut jam nuts to ensure snugness.
A Brown & Root memo dated 8/19/83 outlined the procedures applicable to tight-ening of jam nuts and concluded that revisions to procedural checklists QC N-5 of CP-QAP-12.1 and QC Component Support Checklist of CP-QAP-12.1 should adequately prevent recurrence of the problem noted in the citation.
TXX-4031 dated 9/24/83 provided the TUGCO response to Inspection Report 83-23.
TUGCO Audit TCP-87 was issued on 12/27/83 and identi-fled a deficiency in the Corrective Action program.
The audit concluded that corrective action procedure did not adequately provide a mechanism to document corrective action related requests, responses, and follow-up.
The audit report noted that documentation practice itself was in effect, but that the practice had not been defined procedurally.
On 1/31/84, TUQ-1933 provided the TUGCO comments on Audit TCP-87.
This response was reviewed by TUGCO QA and accepted based on the review of CP-OP 17.01. Rev. 3, as adequately addressing FSAR requirements.
On 3/14/84, this issue was closed. (OTQ-642)
NRC Inspection 84-03/84-01 identified as an unresolved item that "CAR procedure could be improved and better defined in the area of independent reviews, immediate attention to specific matters, follow-up and distribution to upper management."
In TUQ-1966 issued on 3/14/84, TUGCO stated that revisions to CP-QP-17.0 would be made to improve distribution of CAR documenta-I
19 -
tion.
Subsequent to this response, the NRC issued a letter on 4/23/84 closing the unresolved item of NRC Inspection 84-03/84-01.
On 7/23/84, NRC Inspection Report 84-12/84-06 reviewed documentation associated with Significant Deficiency A:.alysis Reports including compliance with NRC requirements for reporting, corrective action, appropriate evaluation and timeliness for reporting and completion of documentation.
The documentation was found to meet all requirements.
On 1/8/85, the TRT notified TUGCO of the TRT findings with regard to Corrective Action Programs.
Subsequently, CPRT was formed and ISAP VII.a.2 (Nonconformance, Corrective Actions and 10 CFR 50.55(a)) waa issued to respond to the TRT findings.
10 CPR 50.55(e)
The history of potential deficiencies in the 50.55(e)
Reporting System com.nences with the issuance on April 2,1980 of RRC Inspection Report 80-08 and Notice of Violation.
The NRC's Notice of Violation cited TUGCO's failure to report a significant construction deficiency in that they failed to provide interim or a final report on concrete honeycomb investigations and evalua-tions conducted during the period December, 1979 to April, 1980.
On April 21, 1980, TUGCO provided a response to the NRC (TXX-3129) in which it noted, contrary to the NRC Notice of Violation, the Resident Inspector (Region IV) had received information verbally during the period for which the deficiency had been
O identified.
Corrective steps outlined included a review of 10 CFR 50.55(e) requirements for written reports, clarification of the requirement at a meeting with NRC personnel and discussion of the requirements with appropriate personnel (TXX-3129).
NRC Inspection Report 80-11 issued on 6/17/80 closed the Notice of Violation reported in IR 80-08.
On 6/15/80, TUGCO issued Memo TUQ-716 indicating a need for supervisory personnel to repeat indoctrination efforts on procedures followed in reporting significant construction deficiencies, CP-QP-15.1, Rev. 3, with particular emphasis on timeliness of reporting.
The ASLB Hearings of 7/27/83 contain testimony touching upon the reporting of items under 10 CFR 50.55(e).
(Hearing Transcript pp. 2,338-2,243; 2,389-2,601).
Related issues were also noted in the ASLB transcript for hearings on 6/16/83.
(Hearing Transcript pp. 8,532-8,569.)
The NRC Inspection keport 84-03/84-01, dated 2/14/84, noted as a finding that nonconformance reporting procedures did not discuss review of NCRs for possible escalation to 50.55(e).
The TUGCO response of 3/14/84 (TUQ-1965) stated that CP-QP-16.0 would be revised to incorporate evaluation of NCRs for potential escalation of 50.55(e).
The NRC Inspection Report 84-22/84-07 (10/11/84) and related Notice of Violation cited the fact that between February and May,1983 TUGCO identified a common failure in three out of four of Unit 1 safety-related inverters that necessitated a t
. modification to the ferroresonant output transformer in each of the inverters, but the failures were not reported to the NRC until February of 1984.
TUGCO answered Notice of Violation 84-2/84-07 on November 9, 1984 (TXX-4354). The' response contained a chronological schedule of the events explaining TUGCO's proce-dural response to the deficiency including the January 16, 1984 Deficiency Report (SDAR CR-84-04). It was stated that the particular issue identified in the Inspection Report was con-trolled in accordance with the CPSES program for identification and resolution of deficiencies observed in the construction and testing phase.
On April 2, 1986 the NRC notified TUGCO that no further response to Inspection Report No. 84-22 was required.
On 1/8/85, the TRT notified TUGCO of the TRT findings with regard to 50.55(e) reporting.
Subsequently, CPRT was formed and ISAP VII.a.2 Nonconformance, Corrective Actions and 10 CFR 50.55(e) was issued to respond to the TRT findings.
The Results Report for ISAP VII.a.2 was published on 6/8/87.
3 Hilti Anchor Bolt Installation ISAP VII.b.4 Historv On Pages 0-293'and 0-298 of SSER-11 dated May, 1985 NRC concerns regarding conformity of Hilti~ anchor bolt installation on' pipe supports and electrical raceway supports to the require-ments of QI-QP-ll.2-1, Installation of Hilti Drilled-In Bolts, were described as follows:
Cable Scread Room 133 Insoections "Hilti Kwik bolts (concrete expansion anchors) as installed did not meet minimum effective embedment criteria (Reference QI-QP-ll.2-1, Section 3.5.1., Revision 16)."
Three of the twenty-four bolts inspected did not meet the minimum embedment requirements.
Electrical Raceway Sunoort Insoections "CTH-6742 (Auxiliary Building) anchor bolt torque was not verified (caracraoh 3.5 of the procedure).
Hilti bolts were not marked in accordance with Attachment 1 of the procedure, nor was the length of these bolts verik able j
(paracraoh 2.3).
"CTH-5824 (Containment Building) bav. plate bolt holes had violated minimum edge distance
-- edge distance cannot be less thar. 1 7/8" (Attachment 2 of the procedure).
Act ual distance was 1 5/8" to 1 3/8" f rom ti.e nearest plate edge. This condition affected five of the eight Hilti anchor bolt holes in the base plates for this hanger.
"One Hilti bolt was skewed to more than 15 l
degrees.
Maximum allowable skew was 6 degrees l
without corrective bevel washers (paracraoh 3.1.2).
j "The Hilti bolt torque on this hanger CTH 6741 l
(Auxiliary Building) was not documented as being verified by QC (paragraph 3.5).
l l
O Cor.cerns that a systematic problem related to various aspects of Hilti anchor bolt installation can be traced to the time period between November, 1979 and December, 1980.
It was during this period of construction activity at CPSES that four Significant Deficiency Analysis Reports (SDAR's) were issued by TUGCO identifying potential deficiencies involving Hilti bolts.
These four SDAR's were documented as follows:
SDAR 79-08 November 7, 1979 Separation Between Embedded Anchors and Expansion Anchor Bolts SDAR 80-05 July 1, 1980 Hilti Bolts In Area With Two (2) Inch Topping SDAR 80-10 September 30, 1980 Hilti Bolts For Conduit Supports SDAR 80-12 December 16, 1980 Reduced Performance of One (1) Inch Diameter Hilti Kwik Anchor Bolts Through early 1978, the vast majority of expansion anchor applications at CPSES were temporary or for construction use only.
Consequently, there were no comprehensive procedures or quality programs for these anchors and a variety of manu-facturers' bolts were being used.
On March 28, 1978, Gibbs &
Hill issued Specification 2323-SS-29, "Installation and Testing of Drilled-In Expansion Bolts," to TUSI for their review and comment.
Having reviewed this and other design documents, TUSI
, returned the specification and stated that expansion anchors would be furnished per the data in the design documents and procured from Hilti, Inc. as a sole source.
Brown & Root then developed a quality control program and procedure for the installation of the anchors in conjunction with the manu-facturer's instructions (Instruction 35-1195-CEI-20 dated 06/01/78, "Installation of Hilti Drilled-In Bolts").
During the next six months, various correspondence was exchanged between Hilti, Inc., Brown & Root, Gibbs & Hill and TOGCO regarding specific aspects of Hilti bolt installations.
Included in this exchange was information providing clarification on such items as torque values, anchor spacing, rethreading (Hilti Letter VBR-8962 dated 09/25/78); a general outline of Hilti bolt installation requirements (Hilti Letter of 09/25/78);
request for clarification of information regarding installation of Hilti bolts (Brown & Root Letter, QCEE 37 dated 11/17/78);
details for the spacing requirements of Hilti to Hilti and Hilti to Richmond Insert (TUGCO Letter CPPA-00398 dated 12/01/78); and request for confirmation of the guidelines to be used in installing Hilti bolts near unused holes (Brown & Root Letter BRV-8894 dated 01/17/79).
On 01/18/79, TUGCO memo TUQ-595, generated the initial issuance of QI-OP-ll.3-13, "Inspection of Hilti Drilled-In Bolts" which replaced the criteria in Brown & Root Instruction 35-1195-CEI-20 regarding inspection.
Shortly thereafter, the issuance of the aforementioned SDAR's predicated specific action and response
. on behalf of various parties associated with the use of Hilti Bolts at CPSES.
Those actions, as per the respective SDAR, were provided as follows:
SDAR 79-08 This report was initiated on 11/07/79 by TUGCO QA upon the discovery that the requirements pertaining to the minimum spacing of Hilti bolts to other concrete inserts was deleted from Specification 35-1195-CEI-20, ("Installation of Hilti Drilled-In Bolts").
This could cause a possible reduction in anchor bolt capacity.
The problem created by this deletion, however, had been corrected in June, 1979 as verified by transmittal TXX-3125 dated 04/21/80 to the NRC from TUGCO.
The problem therefore applied to the time span of September, 1978 to June, 1979 commencing in September, 1978 when Hilti, Inc. provided to Brown
& Root clarification on torque values, anchor spacing, re-threading, and other installation requirements. (VGR-8962 dated 09/25/78).
A survey of all building areas at CPSES was performed to identify locations of Hilti bolts violating the revised separation criteria in accordance with Instruction 35-1195-CEI-
- 20. The results of this survey were furnished to the design groups for their evaluation and action.
Rework "as-required" was to be implemented by these respective groups.
Subsequently, the final report on SDAR 79-08 was initiated by TUGCO (CPP-5150, dated 06/15/81).
This report provided a description of the deficiency, its safety implication, corrective actions taken, and resolution of discrepancies.
l
. SDAR 80-05 This report was initiated on 07/01/80 by TUGCO QA and stated that the anchor bolt design as presented by Revision 5 to Instruction 35-1195-CEI-20 was inconsistent in accounting for the two inch architectural concrete topping.
(Revision 5 to the anchor bolt installation procedure was issued on 01/10/80 and added a section addressing the embedment depth calculation in areas with two inch concrete topping).
CPP-273 dated 07/03/80 documented pull-out tests of Hilti bolts installed in an area with two inch topping. Likewise, a report on core drilling samples (CPP-277 dated 07/14/80) taken at the site of the pull-out tests verified that topping / slab separation was apparent.
Accordingly, TUGCO issued TXX-3171, dated 08/08/80, to the NRC which reported the deficiency as required by 10 CFR 50.55(e).
On 08/22/80, CPP-291 was generated l
by TUSI Project Civil Engineering.
CPP-291 requested a survey and evaluation, by all departments involved, of all Hilti bolts in areas with two inch architectural concrete.
Following appro-priate evaluations and revisions by the respective departments, i
l the final report on SDAR 80-05 was issued by TUGCO (CPP-10950) on 06/26/81.
Accordingly, on 01/25/82, the NRC responded to TUGCO that the item "Embedment of Anchor Bolts Through Floor Topping" was considered closed. (NRC Letter of 1/25/82 RE:
50-445/50-446).
l 1
. SDAR 80-10 This report was initiated on 09/30/80 by TUGCO QA following notification from Brown & Root that an allegation had been received from a site employee regarding the altering of Hilti Kwik bolts.
Verbal notification of the issuance of this SDAR was provided to the resident NRC Inspector on 10/01/80.
In response to the SDAR, TUGCO submitted interim reports to the NRC on October 21, 1980, January 12, 1981, April 15, 1981 and a final report on December 4, 1981.
This final report TXX-3442, provided a discussion of corrective actions that were developed as part of the evaluation of deficiencies resulting from unauthorized field modifications of Hilti Kwik concrete anchor bolts during installation.
The report provided a Summary of Ultrasonic Testing (UT) that was performed on Hilti bolts to establish that their actual installed lengths were consistent with a code letter designation on the end of the bolt and in compliance with design requirements.
Of the approximately 50 anchor bolts which were examined, two were identified by UT as being shorter than required.
l The report went further to explain that in order to ascertain whether additional problems existed with Hilti bolts, Brown & Root had instituted a detailed UT Program which was performed by the Brown & Root Quality Engineering Group. The program consisted of a statistically sound sampling program for those Hilti bolts installed according to functional craft disciplines.
In conclusion, the report stated that Brown & Root i
. construction management, as part of their corrective action, emphasized to the craft personnel that any unauthorized modifi-cation or alteration to permanent plan components would result in disciplinary action.
Accordingly, on 1/25/82, the NRC closed this SPAR by letter addressed to TUGCO Management.
SDAR EQ-12 This report was initiated on 12/16/80 by TUGCO QA following a change by Hilti, Inc. in the design values (tensile strength) of its one inch diameter anchor bolt.
A subsequent review by all appropriate construction departments was initiated, including evaluation to determine if the change in design values was reportable under the provisions of 10 CFR 50.55(e).
In addition, various communications were exchanged between TUGCO, Gibbs & Hill and Hilti, Inc. regarding this matter during the*next two months, including a meeting on 01/15/81 between the three parties and TUSI.
The results of this exchange was a transmittal by Gibbs & Hill (GTT-7748 dated 04/23/81) to TUGCO which provided a recommendation on the use of reduced capacities for one inch diameter Hilti Kwik bolts.
Following this submittal, a response from the TUGCO Project Engineer CPPA-9678 dated 05/01/81) indicated that based on the input from Gibbs & Hill, closure of SDAR 80-12 is recom-mended, since designs completed to date were acceptable "as is."
On 8/31/81, via letter TXX-3398, TUGCO notified the NRC that it had been concluded that the design changes in the tensile strength of one inch Hilti bolts were not a significant defi-
4 0 ciency under the provisions of 10 CFR 50.55(e) and therefore was not reportable.
A response from the NRC was received by TUGCO (Region IV Inspection Report 445/81-14, 446/81-14) on October 30, 1981, stated that the matter was considered closed.
On 01/08/85, however, following an on-site audit by the NRC TRT, TUGCO was advised by an NRC letter of specific defi-ciencies regarding Hilti anchor bolt installation.
Following formation of the CPRT, an Issue-Specific Action Plan, ISAP VII.b.4, Hilti Anchor Bolt Installation, was issued to address the TRT finding related to deficiencies in Hilti anchor bolt installations.
The Results Report for ISAP VII.b.4, Hilti Anchor Bolt Installation, was published on 6/8/87.
l l
l i
i
-o 00LKEiED UNITED STATES OF AMERICA NUCLEAR REGULATORY COM g S g jg p4'QQ before the FFICE of :. hat i Ad i d'Q]EUVICI-ATOMIC SAFETY AND LICENS In the Matter of
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I,
Thomas A.
Schmutz, hereby certify that the foregoing Final Submittal of Chronologies was served this 18th day of March 1988, by mailing copies thereof (unless otherwise indicated),
first class mail, postage prepaid to:
- Peter B.
Bloch, Esquire
- B.
Pa u *. Cotter, Jr.,
Esq.
Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing l
Board Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 I
- Alan S. Rosenthal, Esq.
Assistant Director for l
Chairman Inspection Programs Atomic Safety and Licensing Comanche Peak Project Division Appeal Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission P.O.
Box 1029 Washington, D.C.
20555 Granbury, TX 76048
- /
Asterisk indicates service by hand or overnight courier.
i
s..
-e 0 *Juanita Ellis Robert D.
Martin President, CASE Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S.
Nuclear Regulatory Commission William R.
Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000
& Rothwell Arlington, Texas 76011 Suite 700 1025 Thomas Jefferson St.,
N.W.
Dr. Kenneth A. McCollom Washington, D.C.
20007 Administrative Judge 1107 West Knapp
- William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C.
20555 Suite 1250 1050 Connecticut Ave.,
N.W.
- Billie Pirner Garde Washington, D.C.
20036 Government Accountability Project
- Janice E. Moore, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S.
Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C.
20555 Susan M. Theisen, Esquire Assistant Attorney General
Environmental Protection Suite 600 Division Washington, D.C.
20005 P.O. Box 12548 Austin, Texas 78711-1548 Lanny A.
Sinkin Christic Institute Robert A. Jablon, Esquire 1324 North Capitol Street Spiegel & McDiarmid Washington, D.C.
20002 1350 New York Avenue, N.W.
Washington, D.C.
20005-4798 Nancy Williams CYGNA Energy Services, Inc.
- Elizabeth B.
Johnson 2121 N. California Blvd.
Oak Ridge National Laboratory Suite 390 l
P.O.
Box X Building 3500 Walnut Creek, CA 94596 l
Oak Ridge, Tennessee 37830 l
David R.
Pigott
- Dr. Walter H.
Jordan Orrick, Herrington & Sutcliffe 881 West Outer Drive 600 Montgomery Street Oak Ridge, Tennessee 37830 San Francisco, CA 94111 1
i
-Q
'^9 _'
3-
- Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels &
Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201
- W. G. Counsil
. Executive Vice President Texas Utilities Electric -
Generating Division 400 N. Olive, L.B.
81 Dallas, Texas 75201 w-Tliomas A.
Schmutz f
i Dated:
March 18, 1988 I
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