ML20207E564
| ML20207E564 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/12/1988 |
| From: | Brink B CITIZENS FOR FAIR UTILITY REGULATION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#388-6915 CPA, OL, NUDOCS 8808180087 | |
| Download: ML20207E564 (2) | |
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g;9/5 CITIZENS FOR FAIR UTILITY REGULATION
.".*i.:E' MC 7600 Anglin Drive Fort Worth, Texas 76119 88 RE 15 A10:07 817-478-8850 Grr:a GOCKi a.
..;ud 9FANt" August 12, 1988 Chairman ASLB Panel U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Re: In the matter of TEXAS UTILITIES ELECTRIC COMPANY, et.al., Docket Nos. 50-445-OL, 50-446-OL and 50-445-CPA
Dear Chairman,
Enclosed you will find a correction to petition filed with you on August 11, 1988 by Citizens for Fair Utility Regulation titled, "REQUEST FOR HEARING AND PETI-TION FOR LEAVE TO INTERVENE.
On page 6 of the petition, a sentence was inadvertantly left out of the wording of original Contention 5, now re-l numbered Contention 1.
Please substitute the enclosed cor-l rected page 6 with the correct wording of the contention.
l Thank you.
Sine rely,
//$ h B,ttyBr{ ink Director, CFUR cc Office of the Secretary Docketing and Service Branch U.S. Nuclear Regulatory Commission l
Mr. William G. Counsil
)
Texas Utilides Electric Company I.
8808180087 880812 gDR ADOCK 05000445 PDR 0g
The applicant's failure to adhere to the quality assurance / quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requirments of Appendix B of 10 CFR part 50, and the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, materials used, craft labor qualifica-tions and working conditions (as they may affect QA/QC) and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility.
As a result, the Commission cannot make the findings required by 10 CFR S 50.57(a) necessary for the issuance of an operating license for Comanche Peak. (CFUR 4-A-Acorn 14-CASE 19, Joint Contention.)
CFUR believes that current NRC inspection reports out-lined in this petition will show serious QA/QC deficiencies still exist.
Ironically, while the NRC's Comanche Peak Review Team (CPRT) concludes, in the Joint Stipulation, that "the current programs for design, construction, assurance of quailty, and testing of CPSES are adequate", NRC inspectore, in two lengthy reports attached to this petition and summarized in Section 3, show just the opposite.
Factors Governing Late-Filed Petitions Section 2.714(a) (1) of the regitiations provides that nontimely filings will not be entertained absent a determina-tion by the licensing board that the petition should be granted based upon a balancing of the following five factors:
(i) Good cause, if any, for failure to file on time (ii) The availability of other means whereby the petitioner's interest will be protected; I
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