ML20206H094

Permittees Further Responses to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence

ML20206H094
Person / Time
Site:	Comanche Peak
Issue date:	04/13/1987
From:	Eggeling W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	GREGORY, M.
References
CON-#287-3075 CPA, NUDOCS 8704150256
Download: ML20206H094 (6)

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3gg UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMISSION 00CP.ETED USNPC before the ATOMIC SAFETY AND LICENSING BOARD OFTICE P ': ,6t iM r DOCKE.Titri F iNir.l.

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In the Matter of )

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TEXAS UTILITIES GENERATING )

COMPANY et al. Docket No. 50-445-CPA

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(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

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PERMITTEES' FURTHER1 RESPONSES TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"

Pursuant to 10 CFR SS 2.740, 2.740b and 2.741, the Permittees respond herein to "Meddie Gregory's Interrogatories and Request for Production of Documents (Set 5)."

The Permittees have igncred the definitions and guidelines in the paragraphn labelled "a" through "e,"

inclusive, as contained in the document entitled "Meddie Gregory's Interrogatories and Request for Production of i

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By agreement of the pa: ties, the Permittees are continuing to respond to these Interrogatories as their

. investigation with regard to each issue is completed. ..

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4 Documnnts (Sat 5)," insofar as the sama aro contrary to tha Rules of Practice.

Interrogatory 1:

1 When did Applicants first receive notice of the issues identified by the NRC's TRT Reports and SSERs, and in- what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.)? .

Interrogatory 2:

For each item identified in Interrogatory 1, identify what response was taken to the problem and by whom.

Interrogatory 3:

If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion,"

identify the individuals or organizations who provided that opinion.

4 Interrogatory 4:

Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by others.

(For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?)

PERMITTEES' RESPONSES (TRT ISSUE: ANCHOR BOLTS IN THE STEAM GENERATOR UPPER SUPPORT BEAMS)

At page N-151 of SSER 10 dated April, 1985, the TRT found:

The absence of installation inspection records (for anchor bolts in the support beams) creates a potential safety and QA/QC concern, since these

bacma cro rcquired for ractraint of the SG [Starm Generator} during a seismic cnd pipo rupture event.

TUEC is performing a study to determine the actual installed bolt thread. Until this study is complete, this will remain an open item.

i Prior to March 20, 1984, the NRC's Region IV received an allegation that some anchor bolts holding the upper steam

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generator lateral supports in place were cut off and were incapable of securing the lateral supports in accordance .

with design. requirements. The NRC conducted an on-site investigation of CPSES between March 20, 1984, and May 18, 1984, and it was during this investigation that Permittees first became aware of the allegation and existence of any potential issue related to shortening of anchor bolts.

As a result of NRC investigation inquiries, the CPSES QA Manager requested the Assistant Project Manager to provide a response to the allegations concerning shortening of anchor bolts holding the upper steam generator lateral supports in place (TUQ-2037, 4/19/84).

On July 23, 1984, the results of the NRC inspection conducted from March 20 to May 9, 1984, were sent to TUEC.

NRC Inspection Report 50-445/84-12 stated that there was no technical merit or safety concern related to cutting the anchor bolts and further that no violation's or deviations were identified. Accordingly, TUEC believed any potential concern regarding shortening of anchor bolts to be resolved.

During its on-site review, however, the TRT reinvestigated the allegation of unauthorized anchor bolt shortening for the steam generator upper lateral support

bocma. As part of that invostigation TUCCO was rsquested to provida tha installation and Inspection Records for the subject beams. The records, however, could not be located in the permanent plant-records vault. Non-conformance Report, NCR-M-84-100384 was issued by TUCCO Quality Control to document the lack of Inspection Records. (NCR M 84-100384, 9/6/84). ,

In a TUGCO memo dated September 6, 1984, L.A. Kattness, Quality Engineer, offered a possible explanation for the lack of installation inspection records based on a lack of clarity in the division of responsibility between ASME and Non-ASME mechanical inspections. At the time the anchor bolt installation was performed, it was not clear as to which category this particular work belonged. A similar memo dated 9/19/84 sought to provide additional clarification.

On October 4, 1984, Gibbs and Hill was asked by TUGCO to '

determine the minimum thread engagement required (TWX-14, 964, 10/4/84) and an interim response was provided on October 17, 1984.

On November 29, 1984, the NRC letter to TUGCO formally confirmed the TRT concerns regarding improper shortening of anchor bolts. Following formation of the CPRT, ISAP V.b (Improper Shortening of Anchor Bolts in Steam Generator Upper Laterial Supports) was issued to address the TRT findings.

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CERTIFICATE OF SERVICE I, William S. Eggeling, hereby certify that on April 10, 1987, I made service of the within document by mailing copies thereof, postage prepaid, to: '

Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.

Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive Oak Ridge, Tennessee 3424 N. Marcos Lane 37830 Appleton, WI 54911 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.

Washington, D.C. 20555 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director U.S. Nuclear Regulatory 1426 S. Polk Street Dallas, Texas 75224 Commission Washington, D.C. 20555 hN mF- a wm: $ n?

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l Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station Austin, Texas 78711 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Anthony Roisman, Esquire Mr. Lanny A. Sinkin ,.

Suite 600 Christic Institute 1401 New York Ave., N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.

Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111

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