ML20206S184

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Interrogatories & Request for Documents Re Walsh/Doyle Allegations.Certificate of Svc Encl.Related Correspondence
ML20206S184
Person / Time
Site: Comanche Peak  
Issue date: 06/30/1986
From: Ellis J
Citizens Association for Sound Energy
To:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
CON-#386-845 OL, NUDOCS 8607070305
Download: ML20206S184 (35)
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Text

{{#Wiki_filter:h2 pTED CORRES$ 6/30/86 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I In the Matter of I Docket Nos. 50-445 00gKETEO gpC i and 50-446 TEXAS UTILITIES ELECTRIC i COMPANY, et al. I (Application for an L.3 gj ;16 gJ l (Comanche Peak Steam Electric i Operating License) Station, Units 1 and 2) 1 0FFICE OF SECRETARY 00CKETING & SERVICf.~ BRANCH CASE'S 6/30/86 INTERROGATORIES AND REQUEST FOR DOCUMENTS Pursuant to the Rules of Practice, CASE (Citizens Association for Sound Energy) requests responses to the interrogatories below and production of the sought-after documents n/. Unless a different schedule is adopted by the Board, CASE expects responses to these interrogatories and/or requests for document production as required under 10 CFR 2.740b(b) and 2.741(d) (i.e., not later than 14 days for responses to interrogatories and 30 days for responses to requests for documents). Instructions 1. Each interrogatory or document request should include all pertinent information known to Applicants (including the Minority Owners), their officers, directors, or employees, their agents, advisors, or counsel. " Employees" is to be construed in the broad sense of the word, including specifically Brown & Root, Gibbs & Hill, Ebasco, Cygna, Stone and Webster, H/ These interrogatories are identical to those flied in the companion Construction Permit Application proceedings: 6/9/86 Joint Intervenors' 2nd Set of Interrogatories and Request for Documents, and 6/18/86 Joint Intervenors' 4th Set of Interrogatories and Request for Decuments. Also see last paragraph of this pleading. k.07070305860630 ^ - 6 ADOCK 0500o443 Q g PDR f) J

r a 41 II Evaluation Research Corporation, TERA, any consultants, subcontractors, and anyone else performing work or services on behalf of the Applicants or their agents or subcontractors. 2. Each answer should indicate whether it is based on the personal knowledge of the person attesting to the answer and, if not, on whose personal knowledge it is based. 3. The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, audits, slides, internal memoranda, informal notes, handwritten notes, tape recordings, procedures, specifications, calculations, analyses, and any other data compilations from which information can be obtained. 4. As to each document provided, Applicants shall consider that providing the document constitutes an admission of its authenticity or, pursuant to 10 CFR paragraph 2.742(b), the basis for refusing to so admit. 5. Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory. Do not combine answers. 6. These interrogatories and requests for documents shall be continuing in nature, pursuant to 10 CFR 2.740(e) and the past directives of the Licensing Board. Supplementation shall be made at least every two months to avoid resubmittal of these interrogatories. 7. For each item supplied in response to a request for documents, j identify it by the specific question number to which it is a response. If the item is excerpted from a document, identify it also by the name of the document. 1 j 2 i

f g -1 1 Interrogatories 1. Identify all listings, reviews, diagnoses, evaluations, consultant reports, in-house audits, handwritten notes, or other documents which list, itemize, and/or summarize what have come to be commonly known as the Walsh/Doyle Allegations. Also identify the document which Applicants consider to be the document which identifies all of the Walsh/Doyle allegations and the document which best summarizes them (if these are not the same document, please so state and identify both specifically). 2. What was the source of each item listed in response to question 1 above, and who was the author of each (give name, title, company organization, and date at the time each was authored or revised)? 3. For each item listed in your response to question 1, to what organization and/or individuals (identify name, title, organization) involved in the reinspection effort was each item given? Include specifically in your answer: (a) whether or not each was given to Stone & Webster, Gibbs & Hill, TERA /TENERA, ERC, and/or other organizations working within or with the CPRT; and (b) what was the extent.of the information with which each organization or individual was provided (were they given only the summary document itself; were they given the underlying transcripts of hearings, documents, pleadings, Board Orders; etc.; if they were given more than just the summary document itself, what other documents were they given). 4. How was the scope of each organization's and/or individual's review determined, and who (name, title, organization) made the determination in each case? 3 /

5. When did Applicants first receive notice of each of the issues covered by the Walsh/Doyle allegations? In what format was such notification made (a specific document, verbal communication between specific individuals, etc.); identify specifically for each Walsh/Doyle issue. 6. What generic problems have been identified regarding pipe supports during the period of the Stone & Webster reinspection (by Stone & Webster or by others) which Applicants consider might~be associated with the Walsh/Doyle allegations? 7. What other generic problems regarding pipe supports have been identified during the period of the Stone & Webster reinspection (by Stone & Webster or others) which Applicants consider to be unassociated with the Walsh/Doyle allegations? 8. In view of Applicants' current position, what issues contained in the Walsh/Doyle testimony or allegations would now be considered by Applicants to be (or to have been) reportable potentially reportable under 50.55(e)? Of those items listed in your response, which of them did Applicants consider to be actually reportable under 50.55(e) and (if different) which of them did Applicants actually report under 50.55(e). 9. Have any new procedures been introduced for consideration in the analysis of integral attachments to pipe runs (as used in-anchors, for example)? Provide complete and specific details. 10. Have any of the reanlyses of pipe runs introduced support loads which, although less than the previous loads, still would require redesign of the supports? Why? Provide complete and specific details. 4 l

r-1 11. What, if any, new methodology and/or procedures are being used by Stone & Webster for the Richmond anchor / tube assembly analysis that were not used originally? Has there been an introduction of new bolt material for any of the Richmond threaded rods (or is all of the material still A307 or A36 steel)? What is the justification for this? Provide complete and specific details.

12. What, if any, generic type (s) of supports have Applicants requested be redesigned without further attempts at qualification (for example, have Applicants told Stone & Webster on cinched-up U-bolts, replace them all; or on unstable box frames, replace them all; 1.e., don't try to go through and analyze them or anything, just replace them)? In each such instance, what was the reason or justification for this? Provide complete and specific details.
13. Please refer to the attached 5/19/86 DALLAS MORNING NEWS article and answer the following questions:

(a) Is it correct that in the first 3-1/2 months of 1986, Applicants reported 31 potentially serious safety problems, compared with 54 reported for all of 1985? If this statement is incorrect, please correct and clarify it. Were these all potentially reportable items under 10 CFR 50.55(e)? If not, please explain. (b) Is it correct that Applicants filed 5,207 nonconformance reports (NCR's) in the first three months of 1986, compared to a total of 7,669 for the entire twelve month period of 1985? If this is not correct, please correct and clarify it. Please explain the reason for the relatively large number of NCR's so far in 1986. 5 L

r I i 13 (continued): (c) Please estimate the percentage of NCR's filed during 1985 and during 1986 which resulted from problems identified by the CPRT and/or Stone & Webster reinspection efforts, as opposed to the percentage which resulted from efforts by others. (d) (1) What is the number of pipe supports on which NCR's were written in 1985? in 19867 (ii) If this information is not available in this form, how many NCR's were written on pipe supports in 19857 in 19867 (iii) How many of such NCR's were written due to potential or actual problems in design? (e) (1) What is the number of pipe supports which had potential 50.55(e) reports written against them? What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (ii) If this information is not available in this form, how many potential 50.55(e) reports were written on pipe supports in 1985? in' 1986? What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (iii) How many of such 50.55(e) reports were written due to potential or actual problems in design of pipe supports?. Identify the specific report numbers and provide a general description of the problem. (iv) Which of the 50.55(e) reports in (iii) above were determined to actually be reportable? 14. What is the percentage complete of Unit 1 of Comanche Peak? What is the percentage complete of Unit 27 Please explain exactly what you. mean by the percentage complete. 6 i

s 1 I 1 I l 15. How many individuals (including workers, inspectors, consultants, etc.) are currently working onsite at Comanche Peak?' How many individuals (including workers, inspectors, consultants, etc.) are currently 4 working offsite (such at at Gibbs & Hill's offices in New York, etc.) on Comanche Peck?

16. What is the total estimated cost per day for Comanche Peak at

^" this time (including labor, interest on money borrowed, insurance, etc.)? 17. How many large bore (4" and over) pipe supports are in Unit 1 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2, (c) l Class 3, (d) Class 5? I j 18. How many small bore (under 4") pipe supports are in Unit 1 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2,-(c) l Class 3, (d) Class 5? 19. How many large bore (4" and over) pipe supports are in Unit 2 of I l Comanche Peak? Of this tctal, how many are-(a) Class 1, (b) Class 2, (c) Class 3, (d) Class 5? 20. How many small bore (under 4") pipe supports are in Unit 2 of Comanche Peak? Of this total, how many are (a) Class 1, (b) Class 2, (c) Class 3, (d) Class 57

21. The attached 5/19/86 DMN article states that:

"The latest estimate released by the utility [of pipe supports in Unit I which would have to be removed or modified at Comanche Peak]. indicates 3,700 supports -- more than 40 percent --- will be affected. Utility officials said 1,000 supports need minor work, 1,700 pipe supports must be re-designed and modified, and another 1,000 supports must be torn down." i Are these statements correct? If not, please correct and clarify the i statements. What quantity and what percentage are in Unit 1, and what 7-k g y_o.., ..m.- y

s 21 (continued): ( quantity and what percentage are in Unit 27 What is the breakdown of the 4,700 (or whatever the correct number 1s) pipe supports as to class (for example, Class 1: so many minor, so many redesigned, and so many rip out; Class 2, the same; Class 3, the same; Class 5, the same). In your response, also identify which are large bore and which are small bore. 22. Is Stone & Webster performing a 100% reinspection of all large bore pipe supports? Of all small bore pipe supports? Please provide complete details. 23. In Stone & Webster's reinspection and/or reanalyses, have they discovered any generic or potentially generic problems in addition to those covered by the Walsh/Doyle allegations? If so, provide specific and complete details. 24. In Stone & Webster's reinspection and/or reanalyses, have they discovered information and/or documentation which confirms any of the Walsh/Doyle allegations? If so, provide specific and complete details. 25. Is Stone & Webster specifically addressing each of the Walsh/Doyle allegations? If not, what is the justification for not doing so? If so, specifically how is Stone & Webster addressing each of the Walsh/Doyle allegations? Exactly what is Stone & Webster's mandate: Does it include addressing only the Walsh/Doyle allegations specifically? Are they supposed to just tear out whatever is questionable and put up what is already known and acceptable in the industry, but without ever addressing specifically whether or not the Walsh/Doyle allegations were correct or the root causes and generic implications of same? Please provide specific details. 8 a w

( S 26. Have Applicants cr any of their consultants come across anything that is going to necessitate a change in their FSAR commitments? Have Applicants deviated, or requested or received permission to deviate, from current industry codes and NRC regulations. If so, specifically in what way (what have they asked for, do they know of any that they're going to have to ask for)? Provide specific details. 27. Please provide a brief history of what Applicants' conclusions were as to the adequacy of the pipe supports at Comanche Peak and the validity of the Walsh/Doyle allegations. Specifically includeLin your answer: (a) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Mark Walsh as of August 1982 (following the testimony of CASE Witness Mark Walsh in July 1982)? (b) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of_the Walsh/Doyle allegations as of October 1982 (following the deposition / testimony of CASE Witness Jack Doyle in September 1982)? (c) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the Walsh/Doyle allegations-as of June 1983 (following hearings in May 1983)? (c) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the Walsh/Doyle allegations as of September 1983 (following the filing of Proposed Findings of Fact by the parties)? 9

9 t 27 (continued): (d) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle after receipt of the Licensing Board's 12/28/83 Memorandum and Order (Quality Assurance for Design)? (e) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle after receipt of the Licensing Board's 2/8/84 Memorandum and Order (Reconsideration Concerning Quality Assurance for Design)? (f) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle following the April 1984 hearings on pipe support issues? (g) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle following receipt of CASE's responses to Applicants' Motions for Summary Disposition which were filed in mid-1984? (h) What were Applicants' conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of Walsh/Doyle following receipt of Cygna's 2/19/85 letter in which it changed its position on stability of pipe supports? (1) What are Applicants' current conclusions as to the adequacy of Comanche Peak pipe supports and the validity of the allegations of 4 Walsh/Doyle (not the conclusions which Applicants expect to arrive at in the future, but your current conclusions)? 10

27 (continued): (j ) Have Applicants finally realized that they have problems with the adequacy of the pipe supports at Comanche Peak? If so, when and how did Applicants finally realize they actually did have such problems? (k) Who (name, title, organization) made the determinations discussed in your responses to (a) through (j) preceding? 28. What methodology and procedures are being used by Stone & Webster for analysis of multiple struts and snubbers at pipe support points? Provide specific details. 29. What methodology and procedures are being employed by Stone &- Webster to address variations of actual vs. generic stiffness for pipe supports? Provide specific details. 30. Is there any portion of the NRC Staff's SIT Report with which Applicants had previously agreed but no longer believe is accurate or correct? If so, please identify each such portion and give specific details. 31. How many individuals with Stone & Webster are working on the pipe support effort: (a) in total; (b) onsite; (c) offsite? 32. (a) How many individuals who are currently or were employed by Stone & Webster during the period August 1985 through June 1986 were former employees of NPS Industries, ITT Grinnell, Texas Utilities Electric Company or one of its affiliated companies, Gibbs & Hill, or any other of Applicants or their agents, and worked at any time previously on the Comanche Peak project (either onsite or offsite)? 1 11

l 32 (continued): (b) Provide a listing of all such individuals, along with details regarding the dates they originally worked for the companies in question, the dates they were hired by Stone & Webster for their assignment to the reinspection / reanalysis effort at Comanche Peak, their current job title and status, and if they are no longer employed at Comanche Peak, their last known address and telephone number. 33. (a) What engineering changes have Applicants made to assure that the same individuals who were responsible for design errors are~ not still at Comanche Peak and are not still making design errors? Give complete and specific details. (b) How many engineering management personnel who were working in any engineering management positions during 1982 through 1985 have been replaced and no longer work at Comanche Peak in any capacity? Provide the names of all such engineering management personnel, and their last known address and telephone number. (c) How many engineering personnel who were employed at Comanche Peak during 1982 through 1985 have been switched from one engineering position to another (such as from working on pine supports to working on 1 cable tray supports)? Provide complete and specific details, including each individual's name, past job position and duties, and present job position and duties. (d) Provide the name of each of the individuals identified in your response to (c) above who have been, or are currently, working on the reinspection effort; also state (if not already stated in (c) above) the j specific nature of each individual's duties regarding the reinspection. 1 12 6

o 34. (a) Which organization and/or individuals in the reinspection effort are addressing Walsh/Doyle allegations other than pipe supports (such as the design of the upper lateral support)? (b) What have been the results of their efforts to date? Provide complete and specific details.

35. Provide answers to each interrogatory and document request contained in the following pleadings in the Comanche Peak operating license proceedings (Docket 50-445 and 50-446): CASE's 1/17/85 First Set of Interrogatories Re: Credibility; CASE's 2/4/85 Second Set of Interrogatories Re: Credibility; CASE's 2/25/85 Third Set of Interrogatories Re:

Credibility; CASE's 2/25/85 Fourth Set of Interrogatories Re: Credibility; and CASE's 3/4/85 Fifth Set of Interrogatories Re: Credibility. (See clarifying statement under Request for Documents which follows.) 36. How and by whom was the decision made to utilize the Motions for Summary Disposition which were flied by Applicants in mid-1984? Was this an engineering decision, a management decision, or what? Specifically how, when, and by whom was the decision made to withdraw the Motions for Summary Disposition? Was this an engineering decision, a management decision, or what? Was there any discussion (verbally, taped, or in writing) regarding whether or not it was cheaper to litigate the problems than it would be to go out there and actually redesign and reconstruct the problem areas of the plant? Were there any time estimates, schedules, etc.? Provide complete and specific details. 37. Have Applicants changed their FSAR commitments regarding pipe support design during the time 1983 through the current time? Have Applicants, during the time 1983 through the current time, deviated, or 13

o 37 (continued): requested or received persmission to deviate, from then-current industry l codes and then-current NRC regulations? If so, specifically in what way (what did they request, what were they given permission to do, etc.). Provide specific details.

38. When did Applicants first. receive notice that there were problems with the design of the cable tray supports at Comanche Peak? In what format was such notification made (a specific document, verbal communication between specific individuals, etc.)? Was such notification received prior to the testimony of, and cross-examination by, CASE Witness Mark Walsh in the May 1984 operating license hearings? Provide complete and specific details.
39. What generic problems have been identified regarding cable tray supports between May 1984 and the current time which Applicants consider could have first been pointed out by CASE Witness Mark Walsh?
40. What generic problems have been identified regarding cable tray supports between May 1984 and the current time which Applicants consider to be unassociated with problems pointed out by CASE Witness Mark Walsh?

41. In view of Applicants' current position, what issues contained in the May 1984 testimony of, or cross-examination by, CASE Witness Mark Walsh would now be considered by Applicants to be (or to have been) reportable or potentially reportable under 10 CFR 50.55(e)? Of those items listed in your response, which of them did-Applicants consider to be actually reportable under 50.55(e) and (if different) which of them did Applicants actually report under 50.55(e)? 42. Please refer to the attached 5/19/86 DALLAS MORNING NEWS article and answer the following questions: 14

42 (continued): (a) Is it correct that all cable tray supports in Unit 1 are being examined for design problems? What is the status of cable tray supports in Unit 2; are they all being examined for design problems? If the answer to either is no, please explain and clarify. If the answer to either is yes, what have been the results of such examination? (b) How many cable tray supports are there in Unit I? How many in Unit 27 Are all of them considered to be safety-related; if not, how many are considered to be safety-related, and how many are considered to be in some other category (please specify)? (c) How many of the cable tray supports have been checked against design drawings to date? How many have received a preliminary design review? Are final reports complete on any to date? Give complete and specific details. (d) Please state whether or not the following statements in the attached DMN article is correct: " Utility officials have said the supports, instead of being individually designed, were built according to ' cookbook' designs borrowed from technical manuals that underestimated stress on the supports. Because many cables already have been installed, the utility may face the complicated task of rebuilding or tearing out supports without damaging the cables." If the statements are not correct, please discuss and elaborate on how they are incorrect and give correct complete and specific details. (e) Is it correct that all conduit supports in Unit 1 are being examined for design problems? What is the status of conduit supports in Unit 2; are they all being examined for design problems? If the answer to either is no, please explain and clarify. If the answer to either is yes, what have been the results of such examination? 15

o 42 (continued): (f) How many conduit supports are there in Unit I? How many in Unit 2? Are all of them considered to be safety-related; if not, how many are considered to be safety-related, and how many are considered to be in some other category (please specify)? (g) How many of the conduit supports have been checked against design drawings to date? How many have received a preliminary design review? Are final reports complete on any to date? Give complete and specific details. (h) Please state whether or not the following statement in the attached DMN article is correct and applies also to conduit supports: " Utility officials have said the supports, instead of being individually designed, were built according to ' cookbook' designs borrowed from technical manuals that underestimated stress on the supports." If the statement is not correct, please discuss and elaborate on how it is incorrect and give correct complete and specific details.

43. What, if any, generic type (s) of cable tray supports have Applicants requested or ordered be redesigned without further attempts at qualification? In each such instance, what was the reason or justification for this? Provide complete and specific details.
44. What, if any, generic type (s) of conduit supports have Applicants requested or ordered be redesigned without further attempts at i

qualification? In each such instance, what was the reason or justification for this? Provide complete and specific detr> a. 45. (a) What is the number of cable tray supports on which NCR's were written in 19857 in 19867 l 16

i 45 (continued): (b) If this information is not available in this form, how many NCR's were written on cable tray supports in 1985? In 19867 4 (c) How many of such NCR's were written due to potential or actual problems in design? 46. (a) What is the number of conduit supports on which NCR's were written in 1985? in 19867 ) (b) If this information is not available in this form, how many NCR's were written on conduit supports in 1985? in 19867 (c) How many of such NCR's were written due-to potential or actual problems in design? 47. (a) What is the number of cable tray supports which had potential 10 CFR 50.55(e) reports written against them? What is the number of such potential 50.55(e)'s which Applicants finally determined were a actually reportable? (b) If this information is not available in this form, how many a potential 50.55(e) reports were written on cable tray supports in 19857 in ] 19867 What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (c) How many of such 50.55(e) reports were written due to potential or actual problems in design of cable tray supports? Identify the specific report numbers and provide a general description of the problem. (d) Which of the 50.55(e) reports in (c) above were determined to j actually be reportable? 17

j 48. (a) What is the number of conduit supports which had potential 10 CFR 50.55(e) reports written against them? What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (b) If this information is not available in this form, how many 1 potential. 50.55(e) reports were written on conduit supports in 19857. In 19867 What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (c) How many of such 50.55(e) reports were written due to } potential or actual problems in design of conduit supports? Identify the } ] specific report numbers and provide a general description of the problem. ] (d) Which of the 50.55(e)' reports in (c) above were determined to actually be reportable? 49. Answer question 26 with regard to cable tray supports (if you had originally answered it only with regard to pipe supports).

50. When did Applicants first receive notice that there were problems with the design of the supports for heating, ventilation, and l

air conditioning (HVAC) at Comanche Peak? In what format was such i j notification made (a specific document, verbal communication between - specific individuals, etc.)? Provide complete and specific details.

51. What generic problems have been : Identified regarding HVAC supports (either design or construction) between May 1984 and.the current time.

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52. Please refer to the attached 5/19/86 DALLAS MORNING NEWS article and answer the following questions:

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52 (continued): (a) Is it correct that supports for HVAC "also face design problems, but that analysis and hardward inspection still is preliminary"? What is the status of HVAC supports in Unit 1 and in Unit 2; are they all being examined for design problems? If the answer to either is no, please explain and clarify. If the answer to either is yes, what have been the results to date of such examination? (b) How many HVAC supports are there in Unit I? How many in Unit 27 Are all of them considered to be safety-related; if not, how many are considered to be safety-related, and how many are considered to be in some other category (please specify)? (c) How many of the HVAC supports have been checked against design drawings to date? How many have received a preliminary design review? Are final reports complete on any to date? Give complete and specific details.

53. Please state whether or not the following statement in the attached DMN article is correct and applies also to HVAC supports:

" Utility officials have said the supports, instead of being individually designed, were built according to ' cookbook' designs borrowed from technical manuals that underestimated stress on the supports." If the statement is not correct, please discuss and elaborate on how it is incorrect and give correct complete and specific details.

54. Answer question 26 with regard to conduit supports (if you had originally answered it only with regard to pipe supports).
55. When did Applicants first receive notice that there were problems with the design of the control room ceiling at Comanche Peak? In what format was such notification made (a specific document, verbal i

19 . ~. - - - _

55 (continued): communication between specific individuals, etc.)? Do Applicants now consider that the allegation regarding the design of the control room ceiling had merit? Provide complete and specific details.

56. What generic problems have been identified regarding the design of the control room ceiling between May 1984 and the current time.
57. What is the status of the redesign and reconstruction of the control room ceiling? Are final reports complete to date? Give complete and specific details.
58. Answer question 26 with regard to the design of the control room ceiling (if you had originally answered it only with regard to pipe supports).
59. Are the statements in the attached DMN article correct:

"Overall, reinspection of existing construction is about 60 percent complete. But because procedures to check the design adequacy of the plant were not completed until January, inspection i of design work is only 20 percent to 25 percent complete, utility officials said." i If they are not correct, specify in what regard they are incorrect, and correct and clarify them. If they are totally or partially correct, what justification exists for proceeding with reinspection of construction prior to reinspection of design of each item? And what methodology, procedures, and checklists have been developed and are in use to assure that 1 construction which has already been reinspected will be reinspected should it be necessary because of redesign? 60. In the right-hand column of the attached DMN article, there is a discussion regarding supervisors imposing unrealistic production quotas, Provide the names, titles, and organizations of the individuals etc. m 20 1 e

60 (continued): Involved, state wl. ether or not each is still employed (and in what capacity) at Comanche Peak. What efforts have been made to assure that the work performed under the conditions in question have been reinspected and/or redesigned? Have there been any other similar incidents of harassment, intimidation, or imposition of unrealistic production quotas identified, either in the reinspection effort or as part of the Applicants' in-house efforts? Provide complete and specific details. 61. (a) Have any HVAC or HVAC-related items had potential 50.55(e) reports written against them? If so, specify each item and state what is the number of such items which had potential 50.55(e) reports written against them. What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (b) If this information is not available in this form, how many potential 50.55(e) reports were written against HVAC or HVAC-related items in 19857 In 19867 What is the number of such potential 50.55(e)'s which Applicants finally determined were actually reportable? (c) How many of such 50.55(e) reports were written due to potential or actual problems in design of HVAC or HVAC-related items? Identify the specific report numbers and provide a general description of each problem. (d) Which of the 50.55(e) reports in (c) above were determined to actually be reportable? 62. (a) Was there a potential 50.55(e) report-(or reports) written on the design of the control room ceiling? 21

o o 62 (continued): (b) If so, identify the specific report number (s) and provide a general description of each aspect of the problem (s). If not, why not? (c) If so, did Applicants determine that the problem (s) was actually reportable? (d) Which of the 50.55(e) reports in (c) above were determined to actually be reportable? 63. Please refer to questions 8, 13(e), 41, 47, 48, 61, and 62 above, all of which have to do with various aspects of 10 CFR 50.55(e) reportability. In each of the instances in your answers to those questions, also answer the following questions: (a) Who (name, title, organization, whether or not part of CPRT) discovered each reportable or potentially reportable item? I (b) Explain whether or not (and if so, explain how) each item was or is being fed into the CPRT effort. Please briefly track each item, explaining what steps each goes through, how it will be worked into the CPRT Plan, and how it will be handled by the CPRT. (c) For each of these items, please explain what has been done to date. Please supplement your response until all work on each item has been completed. 64. (a) Are all of the problems identified by Stone & Webster being fed back into the CPRT effort (or will they be)? (b) If so, explain specifically which items are or are not being fed back into the CPRT effort (and if so, explain how). Please briefly track each item, explaining what steps each goes through, how it will be worked into the CPRT Plan, and how it will be handled by the CPRT. O 22 ., ~,..

64 (continued): l i (c) For each of these items, please explain what has been done to date. Please supplement your response until all work on each item has been completed. (d) If the items under review by Stone & Webster are not being fed back into the CPRT effort, please explain exactly how such reinspections, audits, trending, determination of root causes and generic implications, I etc., will be handled. s

65. Question 22 asked questions regarding reinspections by Stone &

Webster. In addition, answer the following questions: ) (a) Is Stone & Webster performing a 100% reanalysis of all large bore pipe supports? Of all small bore pipe supports? Please provide-complete details. (b) Include in your answer to question 22 and (a) above whether l or not such reinspections and/or reanalyses apply only to Unit 1, to both Unit 1 and Unit 2, or explain whatever the case may be. t 66. (a) Break down your answers to questions 23, 24, 25, and 26 with t regard to Unit 1, Unit 2, or explain whatever the case may be. (b) Break down your answers to questions 23, 24, 25, and 26 with regard to small bore pipe supports and large bore pipe supports. 67. Have there been recent changes in Stone & Webster personnel (in addition to those discussed in your response to question 32), such as 4 extensive hiring from the Houston area or other areas, or additional hiring due to strikes, etc.? If so, please supply a summary of details regarding this. I 1 23 s an, . ~. - - -, n..

A l 67 (continued): (We are not at this time asking for details as extensive as a listing of the individuals involved, dates employed, etc.)

68. Do Applicants have any kind (including draf ts) of projection, analysis, estimate, schedule, etc., as to how much of the construction that has been performed, is currently being performed, or is anticipated will be performed is attributable to, or related to, design changes? What does j

If any such information exists, Applicants' trending show in this regard? identify it with reasonable specificity. l. l

69. Questions 6, 7, 23, 39, 40, 43, 44, 51, 56 (and perhaps others)

I used the word " generic": (a) In your responses to those questions, include a statement as j to whether each was/is generic to the nuclear industry or generic only to i Comanche Peak (i.e., is it a unique, novel, or unusual design). i (b) For each of the items'in your response to (a) above which are i designs which are unique, novel, or unusual only to Comanche Peak, where in Applicants' PSAR was each such item specified and discussed?

70. Questions 28 and 29 inquire about methodology and procedures which are being used by Stone & Webster regarding certain specific aspects of 4

design. (a) Is Stone & Webster, in its reanalyses and/or reinspection of ) pipe supports at Comanche Peak, employing methodology and/or-procedures f which differ from the methodology and/or procedures utilized by Applicants in their previous analyses or reanalyses, and/or inspections or 1 24 i 4

= 70 (continued): reinspections? Specifically state whether or'not each such different methodology or procedure is being utilized for an item which is one of the Walsh/Doyle allegations, and state which specific allegation is involved in each instance. (b) If the answer (s) to (a) above is yes, please provide a brief summary of the differences in each such instance. Include in your answer the reason for the differences in each such instance. 71. (a) Have Applicants (including the minor owners of Comanche Peak) or any of their consultants or agents attempted to ascertain what caused the problems in design at Comanche Peak (including reports, evaluations, or studies by consultants or others, investigations, etc., and including specifically any and all studies, reports, evaluations, etc., performed by or for Southern Engineering, or performed by or for any of the minor owners of Comanche Peak, and all relevant documents filed with the SEC and/or REA by Applicants and/or the minority owners). (b) If not, why not? (c) If so, what documents (as defined on page 2, item 3, herein, and including job or performance evaluations, checks of credentials, adequacy of credentials and training, etc.) existed in the past or currently exist regarding such attempt (s)? Our question should be answered regarding not only engineer 1ug personnel per se but also regarding anyone who made decisions which impacted design. List all such documents with reasonable specificity, including date, author (name, title, organization), purpose, etc. 25

71 (continued): (d) If any documents which might have been responsive to (a) through (c) above existed in the past but no longer exist, please explain with specificity and in detail the exact circumstances regarding each such document. (e) If so, what was/were the result (s) of such reports, evaluations, studies, etc.? (f). Either during the research for such reports, evaluations, i studies, etc., or in any other context, were there ever other individuals who expressed the same or similar concerns as the Walsh/Doyle allegations? (g) If the answer to (f) above is yes, please provide specific details regarding each such individual, including but not limited to: each I specific concern (s); the individual's name, title, and organization at the time; whether or not each such individual is still employed at Comanche Peak 1 (either onsite or offsite) and, if so, his/her current titic and organization; if any such individual is no longer employed at Comanche Peak (either onsite or offsite), such individual's last known address and telephone number; the time or time period (s) during which each such concern was raised; to whom each such concern was reported; the response of each such person to whom each such concern was reported; and Applicants' interim and final resolutions of each such concern. (f) What is Applicants' current evaluation of the competence of each (please specify by name) of Applicants' witnesses and/or affiants who. participated in hearings, evidentiary depositions, and/or affidavits I regarding motions for summary disposition regarding design matters? 26

e 71 (continued): (f) What is Applicants' current evaluation of the credibility of each (please specify by name) of Applicants' witnesses and/or affiants who participated in hearings, evidentiary depositions, and/or affidavits regarding motions for summary disposition regarding design matters? (g) Is it currently Applicants' belief that any or all (please-specify by name) of Applicants' witnesses and/or affiants.who participated in hearings, evidentiary depositions, and/or affidavits regarding motions for summary disposition regarding design matters were wrong in their testimony, evaluations, analyses, and/or engineering judgement? If so, please give full and complete details regarding each such Individual and his/her testimony / depositions / affidavits, along with a listing of relevant documents involved. (h) Do Applicants have any reason to believe that any or all of the minor owners of Comanche Peak disagree in any way with Applicants' evaluations in (e), (f), and/or (g) preceding? If so, state with reasonable specificity the reason for such belief and provide a listing of all i documents relating to such belief. (1) If, in any instance, Applicants currently question the competence, credibility, and/or testimony / depositions / affidavits of any of their witnesses or affiants, specifically what have Applicants done about each such instance? Provide a listing of all documents relating to each such response by Applicants. (j ) Please review your responses to (a) through (1) above. What is Applicants' current assessment of what your responses mean insofar as Applicants' ability to design, construct, and operate Comanche Peak? 27

e i 72. (a) CASE has not received anything to Cygna from Applicants or from Cygna in some time. What has Cygna been doing in the past 10 or 12 months or so? What is the current status of Cygna's review of Comanche Peak (including any time estimates of completion of reports, etc.)? (b) Have there been any contacts between Cygna and Applicants for which communications reports or other summaries have not been prepared? Or have there been such reports with which CASE has not been supplied? If the answer to either of these questions is yes, please list all such communications both to Cygna from Applicants and to Applicants or others from Cygna. (c) Provide a listing of all documents provided to Cygna by Applicants or others regarding Comanche Peak from the time Cygna first began its review of Comanche Peak, including the date on which Cygna received each document (similar to the computerized listing with which CASE was provided a year or so ago by Cygna, but updated). l 73. Has any independent organization reviewed the design of the buildings and all appertenances to the ba11 dings? If so, what organization specifically has done so? What were the results of their review? 4 74. Has the CPRT or any other organization of Applicants or their agents addressed items such as the following which were not specifically identified in the CPRT plan, by the NRC's TRT or Staff, or by external sources (including CASE)? (As one example of the type of thing we're ~ talking about: Has drainage plumbing been looked at closely? Are P-traps in place (which are above safety-related items which must work properly)? Has cast iron plumbing been used above safety-related items?) 28 3 g ~- wwr

-~_ _

75. Do you intend to call any witness (either in hearings, in evidentiary deposition, or as an affiant in a written filing) in any portion I

of the remainder of the operating license hearings? If the answer is yes, supply the following information regarding each such witness: j (a.) Name, address, end telephone number. i (b.) Organization, cuspany affi.'.lation, title, and a brief job description. (c.) A summary of his/her professional and educational background. I (d.) Any other information bear:ing on such individual's specific qualificatious to testify with respect to the specific issues regarding ] which such testimony will be given. j (e.) Is such individual testifying as an expert witness? If so, in what specific area (s) of expertise? (f.) The nature of the witness's testimony and a brief summary i l of such testimony. l j (g.) List or identify with speelficity any and all documents on i which such individual intends to rely,-or relles, in giving his/her j testimony. (h.) State whether or not such individual or an organization 1 i with which such individual is affiliated has conducted any research or made 1 + f any studies, calculations, reports, or other documents on which such 1 4 Individual intends to rely, or relles. l (i.) If the answer to h. above is yes, state briefly the scope i { and nature of such research or study. (j. ) If the answer to h. above is yes, provide details as to who (name, title, organization) requested such research or study. l 29

4 J 75 (continued): (k.) State whether or not such individual or an organization with which such individual is affiliated has conducted any research or made any studies, calculations, reports, or other documents on which such Individual does not intend to rely but which may be relevant to the matters j at issue in the construction permit proceedings. I (1.) Provide for inspection and copying any and all documents referenced in your responees to (a) through.(k) above. (m.)- Provide copies of each witness's testimony at least 14 days prior to hearings / evidentiary deposition (or whatever other time period the t Board shall order). J (n.) Provide for inspection and copying at least 14 days prior to hearings / evidentiary deposition (or whatever other time period the Board shall order) any and all documents on which the witness relied in such f testimony. 4 i Request for Documente. i 1 'f CASE requests that Applicants produce the original or copies of all documents in Applicants' (including the minority owners) or their agents' i I { custody, possession, or control that refer or relate in any way to documents Identified in or used for answering the interrogatories in this entire Set i of Interrogatories and Request for Documents as set forth in the preceding. i i t i And, more specifically: i 'I J (1) In regard to the preceding questions relating to items reportable or potentially reportable under 10 crR 50.55(e), please be sure to provide i I all documents that refer or relate in any way to your response, including I j but not limited to all logs of 50.55(e) items, notes of initial verbal 30 1

., e notifications to NRC Region IV, initial' written notifications to NRC Region IV, all follow-up notifications to NRC Region IV, all documents relating to the 50.55(e) item (including, if Applicants decided the item was not in fact reportable, all documents relating to and/or supporting that decision). (2) Provide copies of all NCR logs which CASE has not already received. Provide for inspection and copying all NCR's written since the beginning of the CPRT effort and Stone & Webster effort. (Please check with CASE's Mrs. Ellis for further details regarding which logs and NCR's we have l already received; we will work with you on this.) If a document has already been supplied by Applicants to CASE in another proceeding, Applicants can Identify with particularity the location of the document or answer by including the name of the document, page and line number, in which docket the document was produced, and the date it was produced. This does not apply if the answer previously provided was an objection or if the interrogatory has not yet been answered. In that case, Applicants must reassert the objection as applicable to this proceeding or answer the interrogatory. Respectfully submitted, Ai) .rs.) Juanita Ellis, President CASE (Citizens Assocjation for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 Co-Counsel for CASE Dated: June 30,1986 31 r

i =a-vag u s=- g M $N ja f 0$ WN i is 8 26 S COMANCHE PEAK'S 7 D2 I W 1 peg g i. Problems plague =ROUELEDSPRIN T = n m n 1,:9 i a,oc i E ,n .b.- o g p3a W"" 8 C, omanche ]i eak =4.sebimoncostestim 1 o u sa 4,d } mo -$ $m%. iraidderil j remspection plan _ __b_.y m m -.o. ~.d li p=e. -sed Cogtinsed from Page 13A. amined for design problems. To Msy 5: Hearing granted to cha!!engs l l , 3 W 6, E I D, E E in August. He is date, half the supports have been 2 construction permit extension Ml 6 3 g $ @b a5DMN ogI U0 g ;; ,a now planning a supplemental checked against design drawings. The Ihnas MomMg Nas kg a e v===4 e o budget request to extend the effort Only 800 have received a prelimi-5 E, g j,= g level inspectors to observe ccrrec-

  • *"4 S j g 5 j 1:

R E "at least through the end of the nary design reitew, and final re. tive work at the plant.Noonan said. O " 8, j yen." ports are not available. The trays Toplevel management also met gae 8, yoE !E $E* y, ! g, [A, R That indicates the plant proba-contain control and instrumenta-with inspectors to stress the impor. Q bg I 2E 2 o E a 3 (;$ I !2og 8 19ss.1{eanwhile, Unit 1 of the pir.nt tion of the plant. Utility cfficials precisely. bly.cannot begin operation before tion cable essential to safe opera-b tance of following instructions K' d Og oaagas e g e g,j::, has been 9, percent compiete for have said the 8UPPorts, instead of Noonan said utility actions ap. Q' =o$ d1 3 'E jg morelhan a year, and the second being individually designed, were pear to have a dE E O 'g aj,{g j$ jjg a,{ reicts unit is 81 percent complete. built according to " cookbook" de-6, quality of the inspections is improv-b*j g,,, and Cl3nsultants continue to work Morelhan 8,200 laborers, inspectors signs borrowed from technical O jE ing. 8,8 a O COh h a S t. E y " hu 2 on thg. project both on-and off-site. - on the supports. Because many l last o manuals that underestimated stress l e A major incident occurred late d jlSg S{$g@$g a Interest on money borrowed by the cables already have been installed, posed unrealistic production quotas [ g g n g o".g utility for the project, insurance the utility may face thecomplicated on rein pection teams, forcing nu- .,.4 and other costs are more than $1 task of rebuilding or tearing out merous mistakes that invalidated at Q 6=g g g 5 g (c 5 j t g8g75 6 million a day.That does not include supports withcut damaging the least three months of work on the ~ p g t labor costs. cables. .o., = M 0a C3 Q=do>7 plant'k cabig tray inspection pro-And reinspection is by no means ' sSupports for heating, ventilm-I n =kj 2 gram. The problems went unde. E A5 the project's only problem. tion and air. conditioning also face d 5d h o -{j o 8$ lg Tht' latest blow came early this design problems, but that analysis E tected because no audits or quality-1 g$ g @ g af N

  • e4 "do**

montir when the regulatory com. and hardware inspection still is 3 controlchecks were ordered for the "*3 "E d b $ j.g ~g h - E h mission slapped the utility with work. After the regulatory commis-i oY og y preliminary-6 $ 5370,600 in proposed fines. That to. Overall, reinspection of existing ston discovered the problems. ~ = j yj l$lg O Texas Utilities mat cment sus-SE E 8 f, " 6 tallscluded a $120.000 fine issued construction is about 60 percent u

  • *=d pended all reinspection work for 3 y, for4hfeeincidentsthatintimidated complete. But because procedures gd M

d two weeks, doubled the quality <on- , -O SS gtidlitycontml inspectors and to check the design adequacy of the n' = $ 3S f:g$ b B j g g g d cotift!"have prevented them from trol inspectors from six to 12, and g plant were not completed until Jan-g h,6 replaced both supervisors. E a d "" o jg ' finding safety problems at the nary, inspection of design work is gg g 3 g f _ eo .Itat incident contributed to a = plantrNotification came just days only 20 percent to 25 percent com- { after the utility had agreed to pay plete, utilityofficials said. 550,000 fine against the utility. .,q jd a.o W h ts u Q g9 g its first fine for a similar offense in sThe !!rst five of an estimated Q Mh$ k u8 S

  • 198f'~

a 52 "results reports" - the final o '.TM lion's share of the $370,000 Whether the plant receives a 11-product of the reinspection effort O ){$ $jj'ddbf~k ID. fines - $250,000 - was levied cense is closely tied to how convine-and a key to comanche Peak obtain-En U 0 aggngt the plant for " multiple fallt ing a job the utility's Comanche ing a license - already have cre-j L. E =H.g 2, g g VSV a Eac=- - - E ~ nres of its construction and qual-Peak Response Tesm does on the sted controversy. M 3 p o -s-r-gun

Ia .] ga" $h g ' struction and inspection of nuclear ter if the plant is ever to start opera-and Licensing Board, the regula-O e 8 ti. PowePlants, and for "significant tion. [g a ,S tory commission staff and Coman- = f lfla j" [Q weaknesses" in the plant's quality "If the CPRT (program plan) che Peak opponents alike for not 5 +J* g:; Programs. doesn't fly, then the plant won't being as thorough as anticipated. "ll g g ODd gi a g;j a 3 a. el 19 turn, that damaging news led fly, Noonansaid. The utility pledged to answer nu-i g2]h0d There is evidace that the re-ts1r g E g ; to a downgrading of Texas Utilities sponse team already has hit some Safety and Licensing Boa T merous questions raised by Atomic =g [S M *S 3

  • a j stock by the New York Jond-rating a

j pl. t sgR 8, g., m, g # : boddeofStandard & Poor's Corp. serious problems in implementing mm PeterBloch. Sgg q) d] a The project suffered another set, the plan. Noonan agreed that the reports 4 50 4 m: S' o, ad 'E.2 8 back when the U.S. Atomic Safety Disturbing flaws appeared in the are " sparse" and that the informa-and'ticensing Board granted Co-utility's reinspection program as tion they contain are the

  • bare min-manche Peak opponents a hearing early as tald. August, according to imum" that would be acceptable to onyhether Comanche Peak should regulatory comminnion inspection the Nuclear Regulatory Commis-1 b6gfented an extension of its con-reports reieased in the past few sion. He also admitted that the com-stfudilon permit The utility and months.

mission staff was *not overty the'tquistory commission staff ap-Monthly inspection results for happy",with some of the reports,al- ) peeled the decisionlast week. September, October and November though supporting documentatio, Abd the Soviet reactor accident - released publicly in December. contained in voluminous files i I at C5ernobyl, reawakening public March and April-indicated con-maintained by the utility is ex-co$ceta about the safety of nuclear sultants had made numerous mis-pected to satisfy most questions. 1 powtir, provided a catalyst for Dal. takes reinspecting construction But Comanche Peak opponent d las County Comm.matoner John work and sometimes worked from Billie Garde, who represents Dallas-i ~ Price tojoin the plant's opp, instructions that could be misinter' based Citizens Association for Wile {in a call for a complete rein. neints Preted. Sound Energy, said the accompany. E spntionof theGlenRosefacility-Inspectims representing more ing files do not contain the crucial sol 6sthing that utility officials said than 3.200 inspector-hours of work information needed to determine 4 3 could tioom the plant. Indicated that: the quality of the plant. M 5 A small but troubling percent- "Thisis our firstlook at what the .E aint's'ganwhile, the utility's consult. age of inspection errors had bean utility has been doing for the last d 5 continue to churn out evt. at dence of problems at Comanche committed byoutside consultants. year and a half, and it's pretty ap. 'e Peak. Noonan said inspectors became palling," she said.~rhe documenta-i = ) The design quality of the plant-concerned in November when the tion in the central files has just got 4 f firstshallenged by Comanche Peak number of faulty inspections bT huge gaping holes in it. The paper 2 oppobents in mid-1982 - still ap. utility consultants began to exceed trallis not there." 5 >I pears tobeits most severe problem: an acceptable 1 percent error rate Utility spokesman Dave Florelli "I 4 'm in October, utility officials es. and ellrbed to the 2 percent to 3 sold Ms. Carde's assessment " mis. a g tinisted 120 pipe supports of the Percent range, characterized" the condition of the 1 i g 9,000 supports in Unit I would have "We started getting concerned results reports. toibCremoved or modified at Co-becauseitwas gettingtobe what we "We feelthey are slot saore com- = 6e m&nche Peak. 'Ibe latest estimate call 'on the ragged edge,' and we plete than her comments would in- = 4 released by the utility indicates didn't want it to go any farther," dicate," Florelli said. "We feel that q 3,700 supports - more than 40 per-Noonan aald. "This program is the files do support the results re-e cent - will be affected. Utility offt-going to be long enough, and we Ports thoroughly and in sufficient g cialssaid 1,000 supports need minor don't need to find that it's starting detail" M acm work,1,700 pipe supports must be to get outof hand on us." . Said Ms.Carde:"The conclusions jii h re.dgigned and modified, and an-After the regulatory commission by the reinspection program are n Q othex,1,000 supporp must be torn notified utility executives, steps based on the same kind of missing

down, were taken to "re. tune" the rein-paper and missing supporting docu-

.p 411 4,500 cable tray and con-spection effort.he said. mentation that the plant itself is 3 g dult supportsin Unit I are being ex-One of the steps required higherw based on. / I

s-2:---g! 2$ =3g ya-- u83 W js2 a ga S0E CGMANCHE PEAK'S k , W '% IDi M p]i # P.roblems plague

  • m TROUBt.ED SPRING d

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  • ltI e m. r e

~ a m.i ""i m}gs.1 C. o. eg omanche. Pe. k = h00._,e.8m si O e d 19._mm a m 3 gm o g $ele MH Ireinspection plan p- -=,s._0,s 1._ e 1li - 'n _d ~ d a; = *...

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pl...i.g u

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  • i "at least through the end of the nary design review, and final re ~ tive work at the plant,Noonan said. 0 8.

8, r y5%d!2 j2*ykI That indicates the plant probe-contain control and instrumente Toplevel management also met b b$E3 o bly..cannot begin operation before tion cables essential to safe opm-with E=+ : - e to stress the impor-Q g5I3 D. O 33ag$3 b a I ) l g,H.g ~g 190s.3(eenwhile, Unit t of the plant. tion of the plant. Utility officials, p,,,,,c, ,"f following instructions K S o cg,,gy, bai lhan a year, and the second e== a pere ====plete for have said the supports, instead of m Noonan sold utility actions ap. Ql

  • ==4

..a g g g: gj more being individsally designed, were a M Sa year to have been effective, and the j refctalir unit is 81 percent complete. built according to " cookbook" de-U '1 kg

  • g E

a, u g,. Riorsthan 0,200 laborers, inspectors ' signs borrowed from technical quality of the inspections is improv-fEI@y 2 and ISasaltants continue to work ing. D Q *g I g h on thg. project botin on and off. site. +, manuals that underestimate a A madorincident occurredlate I"gg on the supports. Because many g jfaS E.,a kj # j ~b C laterest on snoney borrowed by the cables already have been installed, last year

  • hen two supervisors in.

C#) utill'g for the project, lasurance the utilitymay face the complicated posed unrealistic production quotas .] t and other costs are more than $1 ' task of rebuilding or tearing out on reinspection teams, forcing nu-I merous mistakes that tavalidated et g ga C million a day.That does notinclude supports without damaging the p S5 g g I g *g g g g y'.3 I . cables.. least three months of work on the c3 l laborcosts. g li e 3 > o t plant'k cabig tray inspection pro-M Ea I And reir_7 T- = is by no means ' sSupports for heating, ventila. e g",5 gram. The probletas went unde-es the project's onlyproblem. tion and airconditioning also face CY jd le Tht latest blow came early this, design problems, but that analysis tected because no audits or quality-o* I f$ g 1 g 1 controlchecks were ordered for the lg montir when the regulatory com. and hardware inspection still is work. After the regulatory commis-B ~ E 5 ' $370,600 la proposed fines. That to. g y 8 g j misstaa *l*PPed the utility with prelladnary. 6^$ sion discovered the problems, Overall, reinspection of existing Texas Utilities management sus. Q j2 E l 3 tal3iicinded a $120.000 noe issued construction is aboet 40 percent pended all reinspection work for g II 1

  • *=4

<g g for-thsee taridants thatlatimidated - complete. But becem procedures two weeks, doubled the quality.cnn-y 4 y ; geistity. control inspectors and tocheckthedesignadequacyof the g 33 jlIJg g l coaki'have prevented them from plant were not completed until Jan trol inspectors from six to 12, and I replacd both supervhors. 2 h 3 S1 3 find 8Eg a8<*tY Problems at the nary, "-,- f =- of design work is That incident contributed to a l. 'g y o g Ej plant 46ctift:stion came just days ' only 20 percent to 25 percent com-550,000 fine against the utility. g ~ after the utility had agreed to pay .,.4

  • S R,

g plate utilityofficialssaid, W 0 I l Q a$ a$j% aThe first five of an estimated i a lts first fine for a misaltar offense in i e 8 .E a 52 "results reports" _ the final O ises.- j product of the reinspection effort '1 lio Whether the plant receives a 11 and a ke' y to Comanche Peak obtain-kg g 4 p. 4 in,,H,,s _n's share of the $370,000 gEy.6.ga - y2 .2se,000_ was ievied conseis cia.eiyisedic ho convinc-i g b, *' 8 aggaqt the plant for" multiple fall ing a job.the utility's ra==mache.,ing a iicense _ aiready have cre-g 8 g g e,,,,,,,,,y, ! ~ M k . M ~ l Ml CsaERIR

eg$ m, c-j$,,Ij.ww-g-te_aumL.yt_uTouw ht-v~as1LU u w the five reports released 12 m15 .f. }, (:. D was lusued for repeated violations must felthfully follow its 12-pound, April have been questioned by the M M ci u y wg 8 ofIkequiremenin for design, con-4 tach-thick program plan to thelet* chairman of the U1 Atomic Safety N j j$& g - struction and inspection of Enclear ter if the plant is ever to start opera-cad Licensing Board, the reg 11a-u O .a l o h g % s ' Power plants, and for "significant aes tion. tory commission staff and Coman-3g g S j"I +=3

  • y g weaknesses" in the plant's quality "If the CPRT (program plan) che Peak opponents alike for not Cd ~ A a ga* Programas.

doesn't fly, then the plant won't 3 being as thorough as anticipated. W 2 30d gl -ly turn, that damaging news led fly "Noonan said. The utility pledged to answer nu. N.ts 5 J! U 8 -

to a< downgrading of Texas Utilities There is evidence that the re-T3*%P. Il i S

"!! stock by the New York bond-rating sponse team already has hit some merous questions raised by Atomic @fgh jlh S Safety and Licensing Board chair-boude of Standard & Poor's Corp. serious problema in implementing A g man Peter Bloch. t ga .a En j g # t Thd project suffered another set-the plan. Noonan agreed that the reports CQ k a: S' a, 3 8, 8 %.5 8 back when the U1 Atomic Safety Disturbing flaws appeared in the are " sparse" and that the informa-and'I:lcensing Board granted Co-utility's reinspection program as tion they contsin are the" bare min-mancna Peak opponents a hearing early as mid-August, according to imum" that would be acceptable to onwhether Comanche Peak should regulatory commission inspection the Nuclear Regulatory Commis-be grainted an extension of its con-reports released in the past few sion. He also admitted that the com-stfu4 tion permit. The utility and months. mission staff was "not overty tho'rquistory commission staff ap. Monthly inspection results for happy" with some of the reports, al-g pedled the decision last week. Septen:ber October and November though support)ng documentation Ah8 the Soviet reec'.or accident - released publicly in December, contained in voluminous files l st Cflernobyl, reawakening public March and April -indicated con-maintained by the utility is ex-concern about the safety of nuclear sultants had saade numerous mis-pected to satisfy most questions. power, provided a catalyst for Dal, takes reinspecting construction But Comanche Peak opponent las County Commissioner John work and sometimes worked from Billie Garde, who represents Dallas-Wile {la a call for a complete rein-Price to join the plant's oppo-instructions that could be misinter-based Citizens Association for g nents Preted. Sound Energy, said the accompany-sput1* n of the Glen Rose fac!!!ty-Inspections representing more ing files do not contain the crucial o solkething that utility officials said than 3.200 inspector-hours of work information needed to determine coyld ticom the plant. indicated that: thequalityof theplant. ti m A small but troubling percent- "This is our first look at what the ant's'tanwhile, the utility's consult. continue to churn out evt. age of inspection errors had been utility has been doing for the last a g dence of problems at Comanche committed by outside consultants. year and a half, and it's pretty ap-Peak. Noonan said inspectors became palling," she said. "The documenta- ^) The design quality of the plant-concerned in November when the tion in the central files hasjust got j first shallenged by Comanche Peak number of faulty inspections by huge gaping holes in it. The paper oppchents la mid-1932 - still ap. utility consultants began to exceed trailis not there." pears tobeits mostsevere problem: an acceptable 1 percent errer rate Utility spokesman Dave F orelli am in October, utility officials es, and citabed to the 2 percent to 3 said Ms. Carde's assessment " mis. e tinisted 120 pipe supports of the Percent range. characterized" the condition of the ["b j 9,000 supports in Unit 1 would have "We started getting concerned results reports. c 19 to b6: removed or modified at Co. teceaseit was getting tobe what we "We feel they are slot more com. eu manchr. Peak. The latest estimate call 'on the ragged edge,' and we plete than her comments would in-CP re:etsed by the utility indicates didn't want it to go any farther-dicate," Florelli said. "We feel that 3,790 supports - more than 40 per. Noonan said. "This program is the files do support the results re-cent - will be effected. Utility offi-going to be long enough, and we Ports thoroughly and in sufficient cials said 1,000 supports need minor don't need to find that it's starting detail." ,c, work,1,700 pipe supports must be to get out of hand on us." . Said Ms.Carde: The conclusions h re<lesigned and modified, and an-After the regulatory commission by the reinspection program are p yd otba.I.1,000 seg must be torn notified utility executives, steps based on the same kind of missing

down, were taken to "re tune" the rein-paper and missing supporting docu-g 3 411 4,500 cable troy and con-spection effort.he said.

mentation that the plant itself is g dust supports in Unit 1 are being ex. One of the steps required higher-based on. i Y l 1

@gRitF.SP0yDENC1 UNITED STATES OF AMERICA DOCMETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD g JL -3 ng:;g In the Matter of }{ CMTfug[hhg' TEXAS UTILITIES ELECTRIC Docket Nos. 50-445 COMPANY, et al. }{ and 50-446 BRANCH (Comanche Peak Steam Electric }{ Station, Units 1 and 2) }{ d CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 6/30/86 INTERROGATORIES AND REQUEST FOR DOCUMENTS have' been sent to the names listed below this 30th day of June ,198 _6, 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 Atomic Safety & Licensing Board & Reynolds Washington, D. C. 20555 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. McCollon Commission 1107 West Knapp Street Washington, D. C. 20555 Stillwater, Oklahoma 74075 Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1

F es0 e l l 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 Public 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. Herman Alderman 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. Boltz 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 3200 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq. Ropes & Gray heketing 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 1555 Connecticut Avenue, N.W., 94111-5894 Suite 202 Washington, D. C. 20009 Mark D. Nozette, Counselor at Law Roy P. Lessy, Jr. Heron, Burchette, Ruckert & Rothwell Morgan, Lewis & Bocklus 1025 Thomas Jefferson Street, N. W., 1800 M Stre.et, N. W. Suite 700 Suite 700, North Tower Washington, D. C. 20007 Washington, D. C. 20036 Jn LJ s.) Juanita Ellis, President ASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2 i 1 l}}

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