ML20197C945
| ML20197C945 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/03/1986 |
| From: | Pigott D CYGNA ENERGY SERVICES, ORRICK, HERRINGTON & SUTCLIFFE |
| To: | |
| References | |
| CON-#486-1374 OL, NUDOCS 8611070149 | |
| Download: ML20197C945 (5) | |
Text
(3 "l 'i DOLKETED
%NRC Dated:
November 30$999W -4 A10 :39 6FFik Cr 2.
N3ti-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
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TEXAS UTILITIES ELECTRIC
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COMPANY, et al.
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Docket Nos. 50-445-OL
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50-446-OL (Comanche Peak
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Electric Station
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Units 1 and 2)
)
)
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CYGNA'S RESPONSE TO BOARD's MEMORANDUM (Questions About Cygna's Continuing Role)
On September 9, 1986, the Atomic Safety and Licensing Board (" Board") in the above-captioned action issued a request to Cygna that it inform the Board of its views concerning the current role of Cygna.
The filing deadline was on or before October 3, 1986.
An extension of this deadline to-November 4, 1986 was granted by the Board at the request of the Applicants.
Cygna hereby responds to the Board's Memorandum.
8611070149 861103 DR ADOCK 05000445 PDR
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o Cygna's investigations have been divided into four phases.
Final reports have been issued for Phases 1, 2 and 3.
Subsequent to the issuance of these reports, errata have been distributed to provide corrections and clarifications.
Further, on January 25, 1985, Cygna issued a letter summarizing the scope of additional anticipated report revisions with respect to the resolution and probable cause of previously issued observatio'ns as well as the final conclusions provided in each report.
These changes are due to:
- 1) information obtained through later reviews which affect the closure of earlier review observations;
- 2) conclusions affected by a cumulative effects assessment across all phases of the Independent Assessment Program (IAP);
and 3) commitments made to the Board and the NRC to address the root cause of Cygna's findings.1/
Cygna is currently reviewing the Comanche Peak Response Team (CPRT) Program Plan and Issue-Specific Action Plans, the
-1/
Cygna has made numerous commitments to assess cumulative effects and root cause which it intends to honor in the Phase 4 Report.
A listing of these commitments is as follows:
- 1) " Affidavit of Cygna Witness Nancy H.
Williams in Opposition to CASE's Third Motion for Summary Disposition,"
dated December, 1985, p.20; 2) NRC transcript of " Meeting with Cygna Energy Services on Comanche Peak Steam Electric Station, Independent Assessment Program (Phase 3),"-
January 10, 1985, pp.10-11; 3)
N.H. Williams (Cygna) letter to V.
Noonan (NRC), "Open Items Associated with Walsh/Doyle Allegations," Letter No. 84042.022, dated January 16, 1985; 4)
N.H. Williams (Cygna) letter to V. Noonan (NRC), " Status of IAP Conclusions," Letter No. 84056.050, dated January 25, 1986; 5) Transcript of Meeting between Cygna and CPRT, March 14, 1985, pp.15-22,49,68,82-96; 6) Transcript of meeting between Cygna and the NRC, April 26, 1985, pp.21-26,32,36,38,82,86-88;
- 7) N.H. Williams (Cygna) letter to W.G. Counsil (TUGCO),
" Review Issues List (RIL)," Letter No. 84056.095, dated November 26,1985.
2
O Stone & Webster piping and pipe support project procedures and, most recently, the " Evaluation and Resolution of Generic Technical Issues for Cable Tray Hangers," prepared by EBASCO and Impell.
A tentative public meeting schedule has been established to afford Cygna the opportunity to discuss its outstanding questions with the appropriate CPRT review teams.
After resolution of all outstanding issues, the Phase 4 report will be issued, currently scheduled for March 1987.
This report will fulfill Cygna's commitments with respect to its assigned tasks.
Cygna anticipates being' called upon to testify as 4
part of the ASLB proceedings.
Cygna also continues to be available to assume additional independent design review functions as may be-deemed necessary by TUGCO and the ASLB.
Cygna has reviewed " Applicants' Views Concerning the Present Role of Cygna".
Based on that review, Cygna considers the above-described activities to be consistent with Applicant's views.
DATED:
November 3, 1986.
Respectfully submitted, David R.
Pigott ORRICK, HERRINGTON & SUTCLIFFE 600 Montgomery Street San Francisco, CA 94111 (415)392-1122 l
/Jaal M
David R.
Pigott Attorney for Cygna Energy Services, Inc.
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1 DOLKETEC CERTIFICATE OF SERVICE T' *{
I, Khadija Grimes hereby certify that on k v b eY 1986, I made service of the within document by placing the same in the hands of Network Courier, charges prepaid Qiceptx.
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that, whereindicatedbyanasterisk,ordinaryfirstcIWE's'!yj(j~dCL mall used), to:
Peter B.
Bloch, Esquire Geary S.
Mizuno, Esquire Chairman Office of the Executive Administrative Judge Legal Director Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Maryland National Bank Bldg.
Commission 7735 Old Georgetown Road East West Towers Building Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814 Dr. Walter H.
Jordan Anthony Roisman, Esquire Administrative Judge Executive Director 881 W.
Outer Drive Trial Lawyers for Oak Ridge, Tennessee 37830 Public Justice 2000 P Street, N.W.,
Suite 611 Washington, D.C.
20036
- Chairman
- Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart A.
Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S.
Nuclear Regulatory Dallas, Texas 75224 Commission 7735 Old Georgetown Road Bethesda, MD 20814 l
I
- Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Div.
Board Panel t
P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Austin, Texas 78711 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 i
Dr. Kenneth A.
McCollom Mr. Lanny A. Sinkin l
Administrative Judge Christic Institute 1107 West Knapp 1324 North Capitol Street a
Stillwater, Oklahoma 74075 Washington, D.C.
20002 Ms. Billie Pirner Garde Mr. Robert D.
Martin Midwest Office Regional Administrator,.
3424 N.
Marcos Lane Region IV l
Appleton, WI 54911 U.S.
Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011
- Eliz'abeth.B. Johnson
- Mr. James E.
Cummins Administrative Judge Resident Inspector Oak Ridge National Laboratory Comanche Peak S.E.S.
P.O.
Box X, Building 3500 c/o U.S.
Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission P.O.
Box 38 Glen Rose, Texas 76043 Nicholas S.
Reynolds Robert A.
Wooldridge William A.
Horin WORSHAM, FORSYTHE,~ SAMPELS &
BISHOP, LIBERMAN, COOK
.WOOLDRIDGE 4
PURCELL & REYNOLDS 2001 Bryan Tower, Suite 2500 1200 Seventeenth Street, N.W.
Dallas,'TX 75201 Suite 700 Washington, DC 20036 Roy P.
Lessy, Jr.
Thomas G.
Dignan, Jr.
WRIGHT & TALISMAN, P.C.
R.
K. Gad III 1050 Seventeenth Street, N.W.
William S.
Eggeling l
Washington, DC 20036-5566 Kathryn A. Selleck ROPES & GRAY 225 Franklin Street Boston, MA 02110 1
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