ML20238A753

Responses to Consolidated Intervenors (870619) Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence

ML20238A753
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1987
From:	Eggeling W ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	CONSOLIDATED INTERVENORS
References
CON-#387-4242 CPA, NUDOCS 8708210073
Download: ML20238A753 (46)

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i Filed: August 14 N1987 w

UNITED STATES OF AMERICA

• I NUCLEAR REGULATORY COMMISSION '87 AUG 17 All :01 i

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before the

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ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) j l

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TEXAS UTILITIES ELECTRIC COMPANY, )

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! et al,

) Docket No. 50-445-CPA l

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(Comanche Peak Steam Electric )

Station Unit'1) i

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RESPONSES 1 l

TO CONSOLIDATED INTERVENERS'(6/19/87) i l INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 CFR 2.740b(b), the Applicants 2 hereby i

1 These responses are timely by virtue of extensions f of time agreed upon between counsel and representatives for the parties and the Board's previously' announced acceptance of such consensual restructuring of discovery schedules.

2 TU Electric, as Project Manager, has canvassed its own records and corporate knowledge in order to respond to the Interveners' interrogatories. It has as well inquired of each of the Minority Owners, seeking from them any factual  :

information they may have that should be considered by the

. Project Manager in preparing the Applicants' responses to these interrogatories. The Minority owners have responded in various ways, ranging from prolix proposals (or demands) for the advancement of specific substantive answers and objections, to prefunctory " instructions" that TU Electric object to the interrogatories in their entirety.

After analysis of and reflection upon the Minority owners' submissions, TU Electric has concluded it is unable

'to advance or sponsor the submission of their proposed answers and objections. Its inability to do so is based upon {

the combined effect of several factors including: that it )

does not have sufficient belief in the truth of the factual l matters asserted therein to conclude that the proposed 1 answers are properly responsive to the questions (gf Fed. R. l Civ. P. 11); and, that it lacks sufficient information j necessary to satisfy itself and its attorneys that the l l

8708210073 870014 PDR ADOCK 05000445 50 ) i G PDR  ;

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4 respond to the Interrogatories and Request for Production of Documents dated June 19, 1987.

GENERAL OBJECTIONS The Applicants have disregarded the instructions contained in the " Instructions and Definitions to the extent that same are inconsistent with the Rules of Practi.ce. \'

With respect to interrogatories or requests for production which would implicate or require disclosure of work done or being done by the Comanche Peak Response Team j i

objections sought to be advanced are valid and meritorious.

These obstacles to accepting for submission the Minority owners' proposed inputs have been compounded by TU Electric's conclusion that many of the proposed answers appear unresponsive to the questions actually asked (and irrelevant '

to the sole admitted contention in this proceeding). This {

leads to the conclusion that the Minority Owners' position is  ;

for a purpose other than to fulfill their obligation to make 1 complete and truthful discovery imposed by the Rules of Practice.

The Minority Owners have been advised of TU Electric's decision and told that if they have a legitimate basis for submitting information, allegations or claims in response to 4

I the Interveners' interrogatories, they are obliged to do so themselves -- through their own counsel and in papers signed by their own representatives in accordance with the Rules of l

Practice.

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It is TU Electric's general understanding -- based upon the Minority Owners' responses to its questions -- that the Minority Owners profess to have no factual information regarding any causes for delay in the construction of Unit 1 of CPSES other than that which is also already possessed by the Project Manager -- with the possiole exception of some (

opinions being developed by their experts in the Texas state l court litigation between the Owners and claimed by them to be privileged from disclosure and further stated by them to be limited in basis to the factual material available from l I

public sources and plant records and personnel. Inasmuch as l all that material was drawn upon for the answers prepared by TU Electric, it is thus currently believed that the answers l herein are properly derived from the entire universe of I historical factual knowledge responsive to the Interrogatories.

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("CPRT"), the Applicants object to producing any such j i

information or documents which are the subject of work which

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is not yet complete but remains "in process." With respect i l

to work which is the subject of a completed and published Results Report, the documents responsive to the Interveners' {

1 discovery requests will be made available in accordance with l the previous arrangements for inspections of the CPRT Central i Files.

INTERROGATORIES ,

Question No. 1 Consolidated Interveners have alleged (Amended l Contention 2) that:  !

The delay in construction of Unit 1 was I caused by Applicants' intentional l l

conduct, which had no valid purpose and l was the result of corporate policies l which have not been discarded or  !

repudiated by Applicants.

With regard to that allegation, please specify all instances of any Applicant's " intentional conduct" of i which you are aware that would support the allegation.

a. Identify all person (s) who engaged in this intentional conduct.

b. Specify the date(s) the conduct took place.

c. Explain precisely how the conduct caused a delay in ccustruction of Unit 1.

d. Cite all documents that support your answers to 1.a., b., and c. above.

Besconse:

Applicants are not aware of any instance of intentional conduct which would support the quoted allegation.

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D Question No. 2:.

What do you know that will shed light on the purpose of Applicant's " intentional c'onduct"?

a. State all facts of which you are aware that illustrate that there was no valid purpose for such conduct.

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b. Identify all persons who have knowledge of.the facts described in your answer to 2.a.

Resoonse:

Not Applicable.

Question No. 3:

List all the' policies of which you are aware that caused or contributed to delay in completion of construction of Unit 1. With respect to each policy,

a. Identify the person (s) who formulated or promulgated each policy. y

b. Specify, with as much precision as possible the-date(s) upon which policy was formulated or promulgated.

c. Specify when each policy was first implemented. j

d. How was each policy implemented?

Obiection:

• Applicants object to Interrogatory No. 3 to the extent, if any, that it seeks information concerning any policies other than those approved by the Applicants for governance of design and/or construction of Unit 1, on the ground that any other policies are irrelevant to the scope of Interveners' sole admitted contention and that as phrased said Interrogatory is overbroad, unduly burdensome and oppressive I

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-and not reasonably' calculated to lead to.the discovery of admissible-evidence.

Resoonse:

Without waiving the foregoing objection, but on the _{

contrary expressly preserving and relying upon the same, Applicants are not aware of any such policies.

Question No. 4:

Identify each of the person (s) who are or were at supervisory level or above at the plant for any Applicant,. contractor, subcontractor, or consultant  !

after February, 1985 who is/are. listed in the answer to Interrogatory 3 above, and list all positions held by such person (s), by whom he/she was employed, and the dates of such employment since February, 1985.

Resoonse:

Not Applicable.

Question No. 5:

Identify any action taken or not taken by any Applicant that is relevant to determining whether any of the ,

policies. referred to in the answer to Interrogatory 3 have been discarded and repudiated.- For each action or non-action identified,

a. Identify the person (s) who took or failed to take the action.

. b. State when the action or non-action occurred.

c. Cite all documents that make reference to the action (s) or non-action (s).

Resoonse:

Not Applicable.

Question No. 6:

Describe each and every instance of which you.are aware in which any Applicant has refused to take positive action to reform the Unit 1 QA/QC program. For each instance,

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a. Define-precisely the positive action that was refused.

-b. Identify the person (s) who deliberately refused to take positive action.-

., c. Identify the date on which the deliberate ly- refusal took place,

d. Describe the manner in which the refusal was '

made manifest.

e. Cite all documents that refer or relate to the refusal.

Resconse:

Applicants are aware of no instance where they " refused" to take positive action when it was determined that such action was warranted to correct a valid deficient condition.

To the extent that CPRT may evaluate the. adequacy of modifications to the CPSES QA/QC program, the results are or will be contained in the CPRT Central File upon publication of the relevant results reports.

a. Not Applicable.

b. Not Applicable. I

c. Not Applicable. .

d. Not Applicable.

e. Not Applicable.

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1 Ouestion No. 7:

Describe all criticism (s) of the Unit 1 QA/QC program of which you are aware, including the QA/QC program of all contractors, subcontractors, consultants, and vendors. I For each criticism, l i

a. State the source of the criticism. I I

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b. Indicate the date(s) the criticism was made,

c. State whether and how the criticism was communicated to each Applicant.

d. Identify the person (s) to which the criticism was communicated.

e. State the date(s) on which the criticism was  ;

communicated to each Applicant. l i

f. Cite all documents that indicate the existence of the criticism and all documents that indicate i that the criticism was communicated to each 1 Applicant.

l Obiection: 1 Applicants object'to Interrogatory No. 7 on the ground i that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

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ResDonse:

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond'that no specific listing or compilation of {

l such criticisms has been prepared. Applicants will, however, '

produce for inspection by Interveners written assessments of aspects of the Unit 1 QA/QC program, some of which may contain programmatic criticisms such as are requested by this interrogatory. These documents (which are listed on Attachment A) may also include instances of specific deficiencies /nonconformances which are not considered

. programmatic criticisms.

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l 1 Ouestion No. 8:

List every instance of which you are aware where any Applicant has failed to correctly apply fundamental engineering principles. For each such instance,

a. Specify which fundamental engineering principle was not correctly applied.

b. State the source (s) from which the engineering l principle in question is derived.

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c. Identify the person (s) who failed to apply the i principle correctly and the date on which the incident occurred.

d. Cite all documents which document or support your description of the instance.

Obiection:

1 Applicants object to Interrogatory No. 8 on the ground I that the phrase " fundamental engineering principles" is vague {

l and ambiguous. l Resoonse:

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, and on the assumption that " fundamental engineering principles"

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refers to the basic laws of engineering such as F=ma, E=mc , 2 Newton's Laws, etc., Applicants are aware of none.

Ouestion No. Q:

List each design not typical for nuclear plants then l seeking or already having received construction permits that any Applicant failed to properly identify in the PSAR. For each of these " unique designs," explain the basis for your conclusion that it was/is not typical. j

Response

None. l l

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Question'No. 10 : .

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i List every aspect of the plant of which you are aware that was constructed before its design was completed.

For each aspect, state any. principle or requirement of which you are aware which dictates or dictated any different sequence of design and construction from.that employed.

Resoonse:

None. For the construction process to begin and proceed, aspects'of the design must be complete. This does not mean-that every aspect of the entire plant design is complete at the beginning of const,ruction. Construction is

. initiated utilizing completed drawings which have been approved and issued for construction. During.the construction process, including subsequent verification / inspection efforts, changes to-the design may be necessitated due to many factors such as revised-loadings, interferences in the field, etc. This design change process i is a controlled part of the quality program and does not mean j that the design was not considered complete when construction began. The drawings, plus approved design changes continue 'l' to constitute a complete design. Applicants are not aware of any requirement dictating any different sequence than the one employed.

Question No. 11: l' List every section of 10 CFR Part 50, Appendices A and B, that any Applicant has not complied with. For each  !

section cited, j l

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a. Explain the precise manner in which the

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Applicant failed to comply with the specified section.

b. State the date(s) on which the failure to comply took place.

c. Identify the person (s) who failed to comply,

d. Cite all documents that document or support the conclusion that the Applicant failed to comply with j the specified section.

Obiection:

Applicants object to Interrogatory No. 11 on the ground that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery cf admissible evidence.

Response

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants are aware of no instances where they have not i complied with 10 CFR Part 50, Appendix A. Applicants' method of compliance is documented in FSAR Section 3.1 and the NRC Staff's evaluation is documented in the Safety Evaluation Report and Supplemental Safety Evaluation Reports. Documents l l

that identify noncompliance with 10 CFR Part 50, Appendix B l l

are contained in Attachment A provided in response to l Interrogatory No. 7, above. No other evaluations or analyses sufficient to compile listings such as are requested by this question have been prepared. Also, Applicants refer Interveners to " Response tc Board Concerns" dated 10/8/86, Appendix B.

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To the extent that TU Electric's compliance with 10 CFR Part 50, Appendices A or B is assessed by the CPRT, the j results are or will be contained in the CPRT Central Files.

Applicants not aware of any other instances which could be claimed to be responsive to the question as understood.

Question No. 12:

List every instance of which you are aware where any Applicant failed to promptly identify design deficiencies, obiection:

Applicants object to Interrogatory No. 12 on the ground that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Response

Without waiving the foregoing objection, but on the  !

contrary expressly preserving and relying upon the same, and on the understanding that this interrogatory seeks identification of any instance where any Applicant failed to report known design deficiencies in accordance with 10 CFR 50.55(e), Applicants refer Interveners to the January 8, 1985 TRT letter and to Attachment B, which identifies specific NRC Inspection Reports, which record any instance wherein the NRC believed TU Electric has failed to report promptly in accordance with 10 CFR 50.55(e). TU Electric's acceptance or rejection of these beliefs are as documented in the responses to the reports. The subject of deportability is discussed w.

further in CPRT Results Report VII.a.2. Applicants are not aware of any other instances which could be claimed to be responsive to the question as understood.

Question No. 13:

List every instance of which you are aware where any Applicant failed to correct design deficiencies.

Response:-

Applicants are aware of none. Applicants have corrected or are in the process of correcting any valid known design deficiencies. To the extent that the adequacy of TU Electric's corrective action program is assessed by the CPRT, the results are or will be contained in the CPRT Central Files.

Question No. 14:

List every instance of which you are aware where any Applicant deliberately refused to take positive action to correct deficiencies in design, constructica, or QA/QC procedures or implementation. 3 I

l Resconse See Response to Interrogatory No. 6, above.

Question No. 15:

List all criticisms of the Unit 1 QA/QC program (including the QA/QC program of any contractors, subcontractors, consultants, and vendors) of which you are aware that have not been thoroughly evaluated in a timely manner and/or for which appropriate corrective actions were not timely taken by any Applicant. For l each of these criticisms, I

a. Identify the source of the criticism.

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b. Identify the date the criticism was made.

c. Describe when and how the criticism was l communicated to the Applicant. l

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d. Cite all' documents which support the existence of the criticism and all documents indicating that the criticism was reported to_the Applicant, l

e. Describe and explain the basis for your ,{

, conclusion that the criticism was not thoroughly i evaluated in a' timely manner and/or that corrective  !

actions were not timely taken. I Was the action or inaction described in 15.e.

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deliberate? If so, state any reason for such deliberate action or inaction of which you are aware, and identify the person (s) who took or '

refused to take the~ action.

Obiection:

Applicants object to Interrogatory No. 15 on-the ground <l that it is overbroad, unduly burdensome and not reasonably.

calculated to lead'to the discov<ary of admissible evidence.

1 Resoonse:  !

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W1thout waiving the foregoing objection, but on the contrary expressly preserving and relying upon.the same, Applicants respond that they are aware of no specific -

regulatory requirements concerning a time frame for evaluating " criticisms" or implementing stated l corrective actions, other than 10 CFR 50.55(e). Applicants refer the I i

Intervenor to TXX-6435 dated May 13, 1987, to the NRC which I identifies instances within the 50.55(e) progr$m for which '

corrective actions were not completed by the dates previously committed. Insofar as TU Electric's corrective action program imposes restrictions concerning tibe frames,

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instances where commitments are not met would be documented I as part of the corrective action proc'ess (e.g., in audit 0 i

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a reports, corrective action requests). Applicants have not performed an evaluation to compile such a listing. The documents identified on Attachment A, including follow-up l documents as appropriate are available for Interveners j inspection and analysis. To the extent that the adequacy of \

TU Electric's corrective action program is assessed by the CPRT, the results are or will be contained in the CPRT l

Central Files.

Question No. 16:

Identify all criticisms of the design of Unit 1 of which I you are aware that have not been thoroughly evaluated in .

a timely manner and/or for which appropriate corrective  !

actions were not timely taken by any Applicant. For each such criticism, I

a. Identify the source of the criticism.

b. Identify the date the criticism was made.

c. Describe when and how the criticism was comniunicated to the Applicant.

d. Cite all documents which support the existence of the criticism and all documents indicating that the criticism was reported to the Applicant, )

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e. Describe and explain the basis for your conclusion that the criticism was not thoroughly evaluated in a timely manner and/or that corrective actions were not timely taken. I Was the action or inaction described in 16.o.

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deliberate? If so, state any reason for such deliberate action or inaction of which you are aware, and identify the person (s) who took or refused to take the action.

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O Response: ,

See objection and response to Interrogatory No. 15, above.

1 Question No. 17:

List every warning of which you are aware by independent e

auditors of the existence of policies or practices at Unit 1 which were not in compliance with NRC requirements or accepted practice. ]

Obiection: 1 j

Applicants object to Interrogatory No. 17 on the ground 1

that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Response

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond that no evaluation sufficient to compile a listing such as this question seems to request has been undertaken. Applicants refer Interveners to Attachment A hereto which contains document types and Applicants'

" Response to Board Memorandum of 8/8/86 (Assistance to the Board)" (10/8/86), Appendices B and C.

Question No. 18:

List every warning you are aware by the NRC of the (

existence of policies or practices at Unit 1 which were not in compliance with NRC requirements or accepted practice. i Resoonse:

Interpreting said Interrogatory to call for identification of instances of noncompliance with applicable l

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l NRC requirements, Applicants provide herewith Attachment B, a listing of items of noncompliance identified by the NRC in l Inspection Reports for Unit 1.

l Question No. 19:

List every warning of which you are aware by the Atomic Safety and Licensing Board of the existen~ce of policies or practices at Unit 1 which were not in compliance with NRC requirements or accepted practice.

Obiection:

Applicants object to Interrogatory No. 19 on the grounds that to the extent that if any such " warnings" were ever issued (a proposition with which Applicants do not agree) they would be matters of public record and Interveners are as capable of identifying them as are Applicants. The interrogatory is therefore overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Ouestion No. 20:

List every instance of which you are aware where any Applicant, in the face of any warning listed in answer to Interrogatories 17 - 19 above, refused to make the appropriate and/or' recommended changes. For each such instance,

a. Identify the person (s) who refused to make the change.

b. State the date of the refusal.

c. Cite all documents that refer or relate to the refusal.

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Obiection:

Please see objections to Interrogatories 17 and 19, above.

Response.

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond that they are aware of no instances where they have refused to make changes necessary to correct valid deficient conditions. Upon determination of a deficiency's validity, TU Electric determines a course of action necessary to correct a deficiency which may include recommended /

actions. If another course of action is deemed more appropriate,-however, then the recommended changes are not implemented. Applicants are required, by law and their own commitment to quality, to address and resolve known deficient

, conditions. They do however retain the prerogative to determine the appropriate actions to be taken. To the extent additional information responsive to this question has been or will be generated by CPRT, the results are or will.be l contained in the CPRT Central File. '

Ouestion No. 21:

List every instance of which you are aware where any Applicant has refused to address and correct design deficiencies. For each such instance,

a. Identify the person (s) who refused to make the '

correction.

b. State the date of the refusal.

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refusal.

Cite all documents that refer or relate to the Resoonse:

See response to Interrogatory No. 6, above.

Question No. 22:

List all the deficient conditions at Unit 1 of which you are aware that were not detected until June, 1984.

. Obiection:

Applicants object to Interrogatory No. 22 on the ground that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Response

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants refer Interveners to Attachment A, provided in response to Interrogatory No. 7, above, which includes

- documents that identify deficient conditions that were detected after June 1984. Applicants also refer Interveners to " Applicants Supplement to Their Answers to CASE's Interrogatories to Applicants (11/15/85)" dated 1/3/86. In addition, the following documents are responsive to this interrogatory:

Construction Deficiency Reports (CDR)

Work Requests Issue Resolution Reports (IRR)

Programmatic Deviation Reports (PDR)

Review Issues Lists (RIL)

Vendor Documentation Deviation Reports (VDDRs) operations Drawing change Requests Vendor Nonconformance Reports i

Contractor Deficiency Paper (generated under their own QA programs Ouestion No. 23:

List all the original judgments made by any Applicant of which you are aware that allowed deficient conditions at Unit 1 to exist and continue, and identify the person (s) who made each such judgment.

Response

Applicants are aware of no judgments that allowed a deficient condition to exist and to continue to exist once the deficient condition was identified. As stated previously, Applicants have corrected or are in the process of correcting known, valid deficiencies. To the extent that this will be evaluated by CPRT, the results are or will be contained in the CPRT Central Files.

Question No. 24:

Identify each and every CPRT judgment on the safety significance of a deficiency (as defined in the CPRT Program Plan) that was made by TUEC personnel.

Response

i None. '

Ouestion No. 25:

Identify each and every CPRT judgment on the safety I' significance of a deviation (as defined in the CPRT Program Plan) that was made by TUEC personnel.

Response

None.

Question No. 26:

Identify which CPRT reinspection are being conducted without couplying with Appendix B.

Resoonse:

l None. As stated within Appendix G of the CPRT Program i

Plan the ERC-Simco Management Program plan for the QA/QC l Review Team (MP Plan) Revision 7, Section 8.0, Insoection, "The inspections conducted by the QA/QC Review Team are not l inspections for acceptance of hardware and do not, therefore, fall under the requirements of 10 CFR Part 50, Appendix B or the TU Electric QA Program." Inspections are performed to the requirements of the MP Plan to " ensure high quality standards in accordance with the SRT's and TUGCO Management's expectations and commitments to quality," (Appendix G, paragraph E), which Applicants believe are compliant with all applicable criteria of 10 CFR Part 50, Appendix B.

Question No. 27:

l Do you believe that any of these CPRT reinspection are {

required to comply with Appendix B and, if so, which '

ones? If not, why not? In what way do these reinspection fail to comply with Appendix B?

Response

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See response to Interrogatory No. 26, above.

Ouestion No. 28.

State each and every way in which CPRT reinspection are impossible of trending.

Response

Interpreting the Interrogatory as asking which, if any, CPRT reinspection results are impossible of trending,

' Applicants state that trending of CPRT reinspection results 1

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.is possible, and the trending analysis is being conducted in accordance with the CPRT Program. The results of this  ;

trending analysis are or will be contained within the CPRT Central File.

Ouestion No. 29: 1 j

State each and every way in which CPRT reinspection are impossible of documentation.  ;

Resoonse:

Documentation of the CPRT reinspection is possible and

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is being conducted in accordance with the CPRT program and implementing procedures and instructions. The documentation is or will be contained in the CPRT Central File.

Question No. 30:

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State each and every way in which CPRT reinspection are impossible of verification.

Resoonse:

Verification of CPRT reinspection is possible and is being accomplished in accordance with CPRT program and implementing procedures / instructions. The results of the verification efforts are or will be contained in the CPRT Cen' tral File.

Question No. 31:

a. How many individuals who are currently or were formerly employed by Stone & Webster during the period June, 1986 through the present were former employees of i NPS Industries, ITT, Grinnell, Texas Utilities Electric Company, or one of its affiliated companies, Gibbs and Hill, or any other of the Applicants or their agents, and worked at any time previously on the Comanche Peak project (either onsite or offsite)?

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b. Provide a list of all such individuals, along with l details of the dates they originally worked for the companies in question, the dates they were hired by Stone & Webster for their assignment to work on Comanche Peak, their current job title and their last known address and telephone number.  !

Obiection:

Applicants object to Interrogatory No. 31 to the extent i

it seeks information concerning Stone & Webster personnel not "

employed at Unit 1 during the relevant time period, on the ground that such information is irrelevant to the subject matter of this proceeding and the Interrogatory as phrased accordingly is overbroad, burdensome and oppressive and not l l

reasonably calculated to lead to the discovery of admissible evidence.

Resconse:

Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond that this information is being compiled by Stone & Webster and will be transmitted under separate cover upon completion.

Question No. 32:

a. How many individuals who are currently or were employed by Applicants or any of their consultants, contractors, subcontractors, or any other companies working on reinspection / reanalysis effort and/or the corrective actions resulting from such effort, during the period lugust, 1985 through the present, were former employees of NPS Industries, ITT, Grinnell, Texas Utilities Electric Company or one of its affiliated companies, Gibbs and Hill, or any other of the Applicants or their agents, and worked at any time i previously on the comanche Peak project (either onsite {

or offsite)? '

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b. Provide a list of all such individuals, along with details of the dates they originally worked for the companies in question, the dates they were hired for their assignment to work on Comanche Peak, by whom they were hired, their current job title and status, and, if they are no longer employed at Comanche Peak, their last ,

'known address and telephone number. )

l Obiection: l i

Applicants object to Interrogatory No. 32 on the ground that as phrased it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. For example, as of August 6, 1987, Applicants l

employ at least 9,758 individuals directly or indirectly to \

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work on Comanche Peak through more than 8 major engineering organizations or subcontractors, Resconse:

Without waiving the foregoing Objection, but on che )

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contrary expressly preserving and relying upon the same, a' Applicants respond that the information sought is being compiled for those individuals from TU Electric, SWEC, Impell and Ebasco. The results will be transmitted under separate cover upon completion.

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1 RESPONSE TO REOUEST FOR PRODUCTION OF DOCUMENTS Applicants object to producing the documents purportedly designated in the Interveners' 6/19/87 discovery request on the grounds: that said request fails to identify the j documents sought with reasonable particularity as required by I the Rules of Practice; that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence; and, that it improperly seeks to require the disclosure of documents protected against such discovery by the attorney / client privilege, the l attorney work product privilege, or the other privileges afforded trial preparation materials. Applicants further

)

object to being required to produce the original of any f documents properly discoverable under the request on the ground that such a request is overly broad, unduly burdensome and not reasonably calculated to lead to the cincovery of admissible evidence.

Applicants will produce for inspection and copying, at the offices of TU Electric, 400 North Olive Street, Dallas, Texas, or at the CPSES jobsite, Glen Rose, Texas, at a time to be mutually agreed upon by counsel or other representatives of the parties, copies or originals, as  !

I appropriate, of any document specifically referred to or referenced in the foregoing responses, including the Attachments incorporated by reference therein, upon specific  !

i l

)

a

advice by the Interveners of which such documents they wish I to inspect. -Applicants will also produce the CPRT Working f Files and the CPRT Central Files in the-manner and at the times previously offered in. response to other discovery j requests. l l }iQTION FOR PROTECTIVE ORDER To the extent required by the Commission's Rules of Practice, the Applicants move for the entry of a protective order in accordance with the foregoing objections and 1 l

responses which are subject thereto. 1

-TEXAS UTILITIES ELECTRIC COMPANY For t Owners of PSES

^

William S. Eggeling- 8 Deborah S. Steenland ROPES & GRAY  !

225 Franklin Street l Boston, Massachusetts 02110  !

Attorneys for Texas Utilities i Electric Company )

As To Objections: e- .  ? '

William S. Egcjel i

-AUG 14 '57'16:21 L[ CENSE TUGC0 FAGE.OE j I.

1.

l

.i SIGNATURES l l

I,. Susan S. Palmer, being first duly sworn, do depose and L l say that I am a Project Manager for TU Electric, that I am  !

familiar with the information contained in the " Answers to '

consolidated Interveners' Interrogatories Request. to Production of Documents (6/17/87)", that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are i based on information that is available to Texas Utilities but not within my personal knowledge, as to which I, based on such information, believe them to be true.

f ~C.. .

3 '

i, a  :

p. #p- b,,} Q

/ ,, ' 9

, Susan S. Palmer Sworn to before me 'his

/4/,TA, day of Augus- 1987:

W b. Llo)

Notal'1 Public My Comission expires: 6-T-89 a

.Paga NO. l' ATTACHMENT A-08/14/87 DOCUMENTS WHICH MAY CONTAIN CRITICISMS OF THE UNIT 1 QA/QC PROGPAM 7.001 S & L REPORT: "SELF-INITIATED EVAL. OF DESIGN &

CONSTRUCTION OF CPSES" 7.002 LOBBIN REPORT: " REVIEW OF QA PROG. FOR THE DESIGN AND CONSTRUCTION OF CPSES" 7.003 B &'R MONTHLY CONSTRUCTICrl PROGRESS REPORTS 7.004 SER AND ALL SSERS

.7.005 QA SERVICES ENGINEER, STAFF REPORT ON FSAR COMPLIANCE VERIF.  !

PROG. FOR .VARIOUS SY'!TEMS 7.006 NRC INSPECTION REPOE2S 7.007 TUGC0 QA AUDIT REPOLTS 7.008 COPY OF KAHLER/SPANG,l.ER/KEELEY QC INSPECTOR INTIMIDATION REPORT 7.009 SPECIAL REVIEW TEAM REPORT' 7.010 GROUP AUDIT REPORTS 7.011 QUARTERLY QA TREND REPORTS 7.012 CPSES FSAR VERIF. ACTIVITIES STATION SERVICE WATER SYSTEM

SUMMARY

REPORT 7.013 FSAR COMPLIANCE VERIFICATION STATION SERVICE WATER PRELIMINARY SYSTEM ASS. REPT.

7.014 PRELIMINARY SYSTEM ASSESSMENT REPORT FSAR COMPLIANCE OF l SERVICE WATER SYSTEM 7.015 FSAR COMPLIANCE-VERIFICATION PROG. STATION SERVICE WATER SYSTEM ASS. REPT..

7.016 MONTHLY ACTIVITY REPORT FOR B&R QA ACTIVITIES ON CPSES.

7.017 QA SERVICES SURVEILLANCE MONTHLY ACTIVITY REPORTS

.7.018- SITE SURVEILLANCE MONTHLY ACTIVITY REPORTS 7.019 CORRECTIVE ACTION REPORT 7.020 BROOKMAVEN NATIONAL LAB REPORT ON PROTECTIVE COATINGS 7.021 SOUTHERN ENGINEERING REPORTS FOR TEX-LA AND BRAZOS i 7.022 . COPY OF 1978 MAC REPORT ON QA 7.023 WESTINGHOUSE PMG AUDIT (10-81) 7.024 EMER$0N CONSULTANTS FINAL REPORT OF 4/79 & 80 SAMPLING STUDIES 7.025 CYGNA IAP REPORT 7.026 SIT REPORT 7.027 SALP REPORTS 7.028 TRT REPORTS I 7.029 NRC TREND ANALYSES l 7.030 ASME SURVEY DOCUMENTATION 7.031 CAT REPORT '

7.032 EG&G REPORT 7.033- DUKE POWER REVIEW OF TUGC0 NUCLEAR ENGINEERING 7.034 EBASCO ANALYSIS OF QA RECORDS MANAGEMENT SYSTEMS l 7.035 1985 INPO CONSTRUCTION PROJECT EVALUATION 7.036 NATIONAL BOARD OF BOILER AND PRESSURE VESSEL INSPECTORS AUDITS 7.037 HARTFORD STEAM POILER INSPECTION AND INSURANCE COMPANY j AUDITS 7.038 REQUEST FOR INFORMATION/ CLARIFICATION 4 7.039 CORRECTIVE ACTION REQUEST

Pago No. 2

~08/14/87 DOCUMENTS WHICH MAY CONTAIN CRITICISMS OF THE UNIT 1 QA/QC PROGRAM 7.040 SURVEILLANCE REPORTS / DALLAS & SITE

~7.041 EXIT INTERVIEWS 7.042 AUDITS BY MAJOR ENGINEERING ORGANIZATIONS, AND SITE .

i' CONTRACTORS AND SUBCONTRACTORS 7.043 SIS REPORTS BY HARTFORD 7.044 7.045 SIGNIFICANT DEFICIENCY ANALYSIS REPORTS SAFETEAM REPORTS

7.046 i QA INVESTIGATIONS (QAI'S) 7.047 . HOT LINE INVESTIGATIONS 7.048 SECURITY INVESTIGATIONS 7.049 )

7.050 PIPE SUPPORT ENGINEERING REPORT (BY EDS)

DEFICIENCY REVIEW REPORT j 7.051 SN'S 7.052 CREW AUDIT REPORTS 7.053 MAC REPORTS OF BROWN $ ROOT l

7.054 i REPORT ON STONE & WEBSTER REPORT ENGINEERING CORPORATION'S  !

EVALUATION (CPSES)

AND RESOLUTION OF GENERIC TECHNICAL ISSUES l 7.055 T-SHIRT REPORT )

7.056 t

OFFICE OF INVESTIGATION REPORTS 7.057 DALLAS CAR'S 7.058 OPERATIONS QA MONTHLY STATUS REPORTS 7.059 7.060 FINAL REPORT - DAMAGE ETUDY REVIEW (EBASCO)

REVIEW OF SUB COMPARTMENT PRESSURE / TEMPERATURE ANALYSIS (EBASCO) 7.061 4 UPS AREA AIR CONDITIONING SYSTEM - DAMAGE STUDY FIRE HAZARDS (EBASCO) i 7.062 ENFORCEMENT ACTIONS-7.063 7.064 SAFETY EVALUATION OF CPSES UNITS 1 & 2 U.S. AEC, 09/03/74 NRC ADVISORY COMMITTEE ON REACTOR SAFEGUARDS TO NRC CHAIRMA 7.065 PALLADINO

SUBJECT:

REPORT ON CPSES UNITS 1 & 2 REPORT BY DRESSEL BURNHAM LAMBERT INC. RE: A COMPARISON OF 7.066 NUCLEAR POWER PLANT PROJECTS USING NRC SALP REPORTS 7.067 NRC'S CASELOAD FORECAST TEAM STUDY OF CPSES DESIGN REVIEW AND QUALITY REVALIDATION REPORT BY TDI DIESEL GENERATOR OWNERS GROUP

'7.068 7.069 TUGCO QA MANAGEMENT REVIEW BOARD REPORTS (1979 SURVEYS)

STONE & WEBSTER POSITION PAPER ON VISUAL INSPECTION OF SUPPORT WELDS 7.070 THERM 0 LAG FIELD VERIFICATION WALKDOWN '

l 7.071 PLANT SURVEILLANCE REPORTS 7.072 EBASCO HVAC ASSESSMENT 7.073 NRC AUDITS OF VENDORS 7.074 G&H NY QUARTERLY QA TREND ANALYSIS 7 . 0*/ 5 10CFR PART 21 REPORTS 7.076 VENDOR SURVEILLANCE REPORTS 7.077 EVALUATION OF DAMAGE STUDY PROGRAM FOR CPSES-FIRE PROTECTION DESIGN, JET IMPINGEMENT ANALYSIS / PROTECTION DESIGN, CLASS 5 PIPE 7.078 LARGE BORE FIELD WALKDOWN REPORT

--__ _________________-______a

Pag 3 No. 3 08/14/87 DOCUMENTS WHICH MAY CONTAIN CRITICISMS OF THE UNIT 1 QA/QC PROGRAM l

l 7.079 CPPP-5 SMALL BORE WALKDOWN REPORT 7.080 7.001 PIPING AND SUPPORT SYSTEN ENGINEERING WALXDOWN FINAL REPORT PRE-INPO EVALUATIONS 7.082 SITE QA ACTIVITY

SUMMARY

7.083 -WEEMLY ACTIVITY REPORT 4

7.084 EXECUTIVE SUMMARIES BY LARRY PLATT FOR DCC 7.085 TNE INTERNAL SURVEILLANCE FOR ADHERANCE TO PROCEDURES 7.086 UNIT.1 & 2 LESSONS LEARNED 7.087 FIELD JOB ORDER LOG 7.088 EVALUATION OF IE BULLETINS, CIRCULARS, NOTICES APPLICABLE TO CPSES 7.089 EXPEDITING TRIP REPORTS' i

7.090 WESTINGHOUSE OWNERS GROUP REPORT 7.091 ASSESSMENT OF THE PRODUCTIVITY OF THE CABLE TRAY HANGER DESIGN VERIFICATION PROGRAM AT CPSES UNIT 2 7.092 CTH PROGRAM PRODUCTIVITY ANALYSIS - DUKE POWER l 7.092 PNG EXPEDITING, PURCHASING & SUBCONTRACTS WEEKLY STATUS

! REPORT 7.093 EDS REPORT ON OPERATIONS. QUALITY ASSURANCE PLAN 7.094 HUMAN FACTORS ENGINEERING EVALUATION OF CPSES U1 STEAM l

ELECTRIC CONTROL ROOM 7.095 NUMAN FACTORS ENGINEERING PRELIMINARY ASSESSMENT OF CP UNIT l 1 CONTROL ROOM 3 7.096 SCHEDULE ALERT REPORTS 7.097 OPERATING EXPERIENCE REPORT 7.098 I&E INFORMATION NOTICES 7.099 IEE CIRCULARS 7.100 GENERIC LETTER AND RESPONSES 7.102 INDEPENDENT SAFETY ENGINEERING GROUP FORMAL REPORTS 7.103 IE BULLETINS AND RESPONSES 7.104 INPO SIGNIFICANT OP. EXP. RPTS.

7.105 MAINTENANCE ACCESSIBILITY REPORT IDENTIFICATION OF PLAN DESIGN PROBLEMS 7.106 CONSTRUCTION DEFECT REPORTS 7.107 7.108 QUALITY SURVEILLANCE REPORTS (QSR'S)

SELECTED QUALITY . INTEROFFICE MEMOS 7.109' DEFICIENCY REPORTS (DR'S) LOG 7.110 CORRECTIVE ACTION REQUESTS (CAR'S) LOG 7.111 INPO EVALUATION REPORTS 7.112 REVIEW OF CPSES CONFIGURATION MANAGEMENT PROGRAM BY ROY WIGHT-ADVANCED SCIENCE AND TECHNOLOGY ASSOC., INC.

7.113 NWT, INC. REVIEW OF'TUGCO CHEMISTRY PROGRAM 7.114 VENDOR EQUIPMENT QUALIFICATION REPORT 7.115 7.116 EP DRILL AND EXERCISE REPORTS RADIO AND TELECOMMUNICATIONS EP INDEPENDENT REVIEW REPORT 7.117 INPO SIGNIFICANT EVENT REPORTS 7.118 UNIT REPORT1 SMALL BORE PIPING AND PIPE SUPPORT GENERIC ISSUES 7.119 7.120 UNIT 1 LARGE BORE PIPING AND FINAL REPORT  !

BNL REVIEW OF TUGCO CPSES UPPER LATERAL RESTRAINT BEAM -

STEAM OENERATOR i

l

'P;g3 No. \

4 1 08/14/87 DOCUMENTS WHICH MAY CONTAIN CRITICISMS OF THE UNIT 1 QA/QC PROGRAM 7.121 G&H CONTAINMENT MAT REPORT 7.122 LAW ENGINEERING TESTING COMPANY - CONTAINMENT #1 BASE MAT INVESTIGATION 7.123 BOSTON-BERGEN METAL PRODUCTS REPORT-REWORK OF THE POLAR 1 CRANE BRACKETS 7.124 MR. J BECK'S REPORT TO THE ORC CONCERNING THE CPSES i MANAGEMENT MEETING OF SEPTEMBER 13 AND 14 7.125 JOINT UTILITIES MANAGEMENT AUDITS (JUMA) 7.126 EDS REPORT "STARTUP PROGRAM EVALUATIONS 7.127 EDS REPORT " REORGANIZATION OF QA/ PROCEDURAL COVERAGE" 7.128 QA OVERVIEW COMMITTEE MEETING REPORTS

'.129 DIAGNOSTIC OF ENGINEERING AND CONSTRUCTION ORGANIZATION 11/19/79 BY MAC 7.130 ASLB TRANSCRIPTS 7.131 PUBLIC MEETING TRANSCRIPTS 7.132 INTERVENOR CORRESPONDENCE 7.133 NRC CORRESPONDENCE 7.134 RATE HEARING TRANSCRIPTS AND RELATED DOCUMENTATION 7.135 DOCS CONTAINED IN CPRT CENTRAL FILE (INCL. RESULTS RPTS, OQT RPTS, COLLECTIVE EVALUATION AND COLLECTIVE SIGNIFICANCE NOT YET ISSUED) 7.136 PROJECT STATUS REPORTS (NOT YET ISSUED) 7.137 LOBBIN REPORT " EVALUATION OF THE ORGANIZATION & PLANNING FOR STARTUP AND OPERATION OF CPSESH 7.138 7.139 REVIEW OF TUGC0 CORPORATE NUCLEAR ORGANIZATION (OPNS)

STOP WORK NOTICES 7.140 REPORTS AS DESCRIBED ON APPLICANTS' PROGRESS REPORTS 7.141 OPERATIONS QUALITY ASSURANCE ANNUAL REPORTS l

l l

1

a pm go,  ; ATTACHMENT B 00/11/81 GiEd NRC IE liEM3 1,15i $

I ITEM I NUMBER 11EM ut IR Tip! 9F DEStilfild t.LMi4!k :its I

445/7302 No PR90! DURE E![sts FOR IMPLEMENil U CRifERIA 445/73 V 0F02 VIOLATIOT '

446/1302 100FR50 APP.B 446/73 02 4 445/1302 N0 PROCEDUR8 FOR IMPLEMENilhG 000UMENT CONfR0L 445/73 02 V!OLAil0N 446/7302 446/13-02 445/1302 NO PROCEDURE FOR IMPLEMENi[NU CONIF.1L LF FURCHASED 445til-02 VIOLATION 446/1302 MATERIAL, EQUIPMENT AND SERVICES 446/73-02 1

445/7302 PROCllkEMENT PROCEDURE DOES N T ADDRESS IHE 445/73-02 Vl0LAll0N 446/7302 CUIDELINES IN DETERMINING THE ADEQUACY OF THE446/11 02

, l FROVISIONS OF ANSI N45.2 '

445/1301 QUAlltY SURVEILLANCE MEEilNGS NOT HELD AS REQUIRED 445/73 02 VI0i, Ail 0N 446/1302 Bf FSAR AND QA PLAN  !

446/73-02 l

445/7302 l THE LICENSING AND RECORD RETENil0N PROCEDUR!S 445/i3 ONLY 02 'It0LAtt0N 446/7302 PARilALLY (MPLEMENTED

! 446/13-02 445/1302 THE DCC AND QA DEVIATION A0 MIN!STRAT!0N AND 445/73-02 Vl01Att0N 446/7302 INI!RFACE CONTROL FR0f'EDURSS Hof IMiliMENTED 446/13-02 445/1302 QUALITY SUR7FILLANCE ceMMITTEE HAS Noi RFVIEWiD 415/73 02 VleLAtt0N 446/1302 QAlQC FROGRAMS AS REQUIRED 446/73-02 )

445/7302 AUTHORITY DUTIES NOT DEFINED IN QA FLAN 445/73-02 Vl0LAtl0N 446/1302 446/13-02 445/1302 D00VMENTATION PERTAINING TO IMPLEMENTATION UF 445i13-02 'l10LATION 446/7303 PROCEDURES NOT AVAILABLB FOR REVEIW 446/13-07, 445/7302 I QA PLAN DOES NOT COMFli WiiH ANSI 445.2.ll 446/1302 4tSii3 v! 'IlvtA TION '

446/73 02 445/1302 R0CIDURES LACKING IN DEF al!.0 F ila niR1L 415ti3 02 Vlui.Ai!01 446/1302 dFONSIBILITIES 4 H l 73 -V, 445/1302 .

QUALin RELATED INSikurt!0iilaccF'.ms IRE U5ti3 C '10LAt10N ,

446/7302 INADEaVATE OR 'iFRE NOT Fbilf!b 4 W 7:: 02 445/7302 CONTROLLED CONDlil0NS V)I ALDRES5ED IN QA FLAN!15/73 02 'It0', A fl0 N 446/1302 446/73 02 1

O

Pale No. 2 00/11/07 4 9 5 'aC IE ITFMS LIST IIEM

[1FM NUN 3ER W IR HE OF t w R[FillN NPHR

IHM H5/i302 Q) PLAN DOES NOT ADDkESS CRA NES IN FRorVIEMENT 445tf3 42 Vi%ATION 446/7302 DOCUMENTS 446/73-02 H5/7302 h0 PROCF004E EllST! FOR CONTR01,0F REreRDS VRICH 446/1302 (15/73 02 V(ULAT[0N iHVE NOT BEiN MICR0 FILMED 446/73-02 445/1302 INADEQUATE FROCEDURE ADDRESSING QL'ALITT AL'IIS H5/73-02 7IOLATION 446,1302 446/73-02 445/7302 PS0CEDURE IN ORAFI STAGE ONLY 446/7302 H5/73 02 VIOLATION 446/13 02 445/7302 FR0CBDURES HAVE h0 AFFROVAL 5:CNAiiiRF, 446/7302 445/73-02 VIOLAtl0N 446/13-02 H5/7302 ALL AFPROVED FROCEDURES WERE NOT DISIRl!'JiED 445/73FOR USE 02 V[0LATION 446/7302

(< 446/13 02 445/1402 446/7402 (SIGNIFICANTFINDINGlCl4FR0CEDURES!!0NOTCONTAIN 445/7402 GTRER "

REQUIREMENTS OF ANSI STANDARDS 446/74-02 445/1402 (SIGNIFICANTFINDING)IHEClWPOLICTASSTATEDIN 4 45/7402 OTHER 446/7402 THEIR QA MANUAL DOES NOT COMMIT CAR TO REQUIREMENTS H6/74 02 IN AEC Gul0 LINES 445/7402 (SIGNIFICANTFINDINGlGiBQAFcLICVASDEFINEDIN H5/it 02 OTHER 446/1402 IHE(R QA MANUAL IS NOT CLEARLY DEFINITIV! 446/14-02 445/7403 (SIGNIFICANTFINDING)81RFR0CE0VRESNOTFULLY 445/74-03 OTHER 1

446/7403 (MPLEMBNTED  !'

446/14-03 445/7403 I (SIGNIFICANT FINDINGl FH s 4Al0C HGRAM REQUIRES 445/I M 3 OTHER 446/1403 M0RS SPECIFl0 DETAll,S OF INTERFACl W i I 446/H 03 RESPONSIBILITIES i

445/7403  !

(SIGNIFICANT FINDINGl CF8FS 4A FLAN %JiRES H 5;it 93 OTHER 446/1403 51PANDING TO INCLUDE St'RVilLLANCS ACil'ilTY OF 446/74-03 DAM )

i 05/7403  !

(SIGNIFICANT FINDING) QA FROGEAM Ri#1RFi AliDIT!cNAL 415174 03 OTHER 446/7403

[NF0 REGARDING [NTERFACING R!if. 44sli4 03 445/7403 (SIGNIFICANT FIN 0 LNG) Fei V iwi ' RE NNimitN1 M*,it-a oiHER 446/1403 0F AUDIIS' D(!CREPAhi IN SF.YFRAL A F'- it0 N S3  !

t 9

i Fato to, 3 08/11/81 CFVES !;EC lE [IEF.S LIST l ITEM ITEM NUMBER NRC IR ftFi 0F DESCRIFiiON TJ!GER liEM 445/140; (SIGNIFICANT flHDIN1) INSUFFICIENT! N RFfR UF F4NM lil-t3 diHER 846/7403 QA/QC FR0CEDURSS TO FACIL! TATE QA FROGRAM 446/1(-03 445/1505 (DEFlCIENCY)EXCAVATIONFRorIDUk!h0?OEV! LOPED 115 f5 45 otHER 446/1505 FRIOR TO COMMENCEMENT OF '40RK 446s75-05 445/1506 (INFRACTION)UNAUTHORIEEDINSEECTIONSBE!NG !45i15 06 OTHER 446/7506 FERFORMED 446/15-06 1:

445/7506 446/7506 (INFRACTION) INSFECTORS ARE NOT !NDEFENDENT 415/15-06OF UNDUE OTHER 1

e INFLUENCE i RESPONSIBILITIES FOR SfilEDULES446!75 1 COSTS 06 445/1506 i 446/f506 (lWFRACTION) (NSFECTION FROCEDURE NOT AVAILABLE 445/75 06 FOR OTHER REVHtv (CF-QCF 141 446/15-06 445/7503 CROUN0 VATER Vffil0RA4AL RATE 415/i5-03 V10LAT[0N 446/7508 446/75 08 f

,- 445/7510

', (INFRACT [0N) LACE OF ADH'RINCE 10 FR0CEDURE445/i5-10 OTHER 446/1510 REQUIREMENTS-CCNCRETE TRANSIT MII 446/15 10 445/7510  !

(INF8ACT[0NI LAci 0F A0!!ERFN:E to ikOCFDURE 415 15-l0 OlHER 446/1510 REQU(RENENTS-CONCRETSPLACEMENT 446/75 l0 445/1601 LACR OF QC PROCEDURES C0'if AINMENT I,[NER 446/7601 445/76 il 7[0LAt[CN 446/76 01 445/7601 DESIGN CHANGE CONTROL FRUCEDERAL 0!FICIENCY445/76 01 VIOLATION 446/1601 446/16 01 445/1601 LACK 0F QC Sl!RVE!LLANCE FRecitt;! ?? m .i 446/7601 1:5/76 01 Vf0LAr[0N 146/16 01 445/1601 t,ACK 0F F20CEDURES 446/7601 tl5/M 01 VlutATION 146/76 01 445/1601 EIAHINAtl0N AND REFAIR FRWiXE4L EIFlc!!Eff 145/IS 01 7!0LATICH -

446/1601 446/76-01 445/1607 WELDING Of .iAFETY RELAt!D ru?!0Ni m 446/t607 ll517607 VlutAi[0N i46/16-01 445/1608 LOCUMENT CONTE 0L 146/7608 4t!/76 02 710LATION (H/76 08 e

9

Fue No. 4 08/11/47 tTSES FAC lE li!M3 LIST ITEM (TEM NUMBER NRC (R iiiE 6F DESCRlFifM NUMBFR liEM 445/7608 TUSI QA 00CllMENTAT[0N OF SURVEILLANCE OF ActlVITIES 445/76 08 VIOLATICN 446/7608 446/76 08 445/1102 (INFRACTION} PROCEDURAL 445/77-02 OTHER 446/7702 INFRACTION CERTIFICATION / DOCUMENTATION OF 446/77-02 [NSFECTORS 445/7702 (INFRAcil0N)FR0CEDURALINFRACT!U!1SU3 CONTRACTORS 415/77 02 OillER 446/7107 FAILURE TO REFORT [ FEM 0F NONCOMPl[ANCE 446/77 02 445/7710 FAILURE TO PROVIDE WPS AT L9CAilcN VdERE WELDING IS 10 Yt0LAtt0N 445/77 416/7710 PERFORMED (CVCS) AUL BLOG. 446/77 10 445/7710 FAILURE TO REM 0VE WELD SURFACE FRIOR T0 FINALH5/7710 V10LAtl0h 446/7710  !

ACCEPTANCE (CHEM & VOL, CONTROL SYSTEM) 4(6/77-10 '

445/7805 FAILURE TO FOLLOV PIF8 FABRICAiluN FROCEDURES 445/78 05 Yl0LAf!0N 446/7805 446/78 05

• i' 445/7808 DEFICIENCY FAILURE TO MAINTAIN FLOV IN LOWER445/7A SQUAW 08 V[0LAT[0N

~~

446/1803 CREER 446/78-08 i

445/7811 FAILURE TO FOLLOW FIFl!IG (!!STALLAlld FR9CFDURES 415/18 11 Vl0LAfl0N 446/18ll 446/18 ll 445/7812 FAILURE 10 FULLOW WElfilW FR0rEiddES (2 eat:H! 145/i4-l2 Vl0LAfl0N 446/7812 FAILURE T0 CONTROL 1 TAG NONCONFORMING ITEMS ( EtCHI h

446/78 12 l

2 445/7813 FAILURE TO F0LLOV CONCRETE TESil M FRofEDURES445/78 13 VIOLATION 446/1813 i 446/78 13 445/7816 i FAILURE TO PROMFTLY REFORT A SIGNIFICANT OEFICIENCY 445/18-16 V10LAtl0N 446/1816 446/78 16 q

445/1818 FAILURE 10 FOLLOW VELDlM FROCE' G tES 445/78-18 VIOLAi[0N  !

446/7818 415/15-13 '

4 445/7304 l FAILURE 70 FULLOW Af f R'Tl!? FI' CIWhs F0F. Malt:TBASCE 445/79-0( VIutAi[08 '

446/7904 0FEQUlFMENTINSTORACE 416/79 04 i

445/7906 FAILUF.E TO FOLLOW QC (M P!rifvN I M EDUhES 145/19-116 il0LAi[0N i 446/7906 446/1906 445/1306 (NONCOMPLI ANcE) REVIEW of class [E 9FMis (15/72 06 uTHER 446/7906 1 446/79-06 l

l 1

hie No. 5 08/II/87 JF553 SRC (E ITE:u 1.151 IIEM ITEM NUMBER W Fi iiFE OF DESCRlfila !1M3ER

liEM 445/7911 FAILURE TO IMPLEMENT TH! QA FROGRAN FOR C(Vil 445/79 11 V10LAtl0N 446/1911 CONSTRUCTION 446/19-11 445/1918 FAILURE TO CUNTROL GC [NSFECituli STAMP 446/7916 845/79-l3 Vt0LAtt0N l 446/7918 445/7918 FAILURE I0 TRAIN AND IN K CTRINAi! QC PERS.NNEL 445tf9-l! V[0LAil0N (46/1918 446/79-18 445/7918 RECORD OF INSPECTION 446/1918 445/19-18 V10LAtt0N

. 446/i9-18 415/1918 INSTALLAT[0N OF ELECTR! CAL COMF0NDIS 445/79-18 VIOLATION 46/7918 j 446/19-18 i

445/7919 l NONCONFORMANCE REPORT CORRECTIVE ACi[0N 445/79-19 VlCLATION 446/1919 )

446/19-19 4

445/7925 (INFRACi[0HIFAILURETOFOLLOVN9NCCNFORMANCE445/19 25 OTHER 446/1924 PROCEDUR!$ FOR ELECTRICAL CA8LE 446/79 24 445/1927 FAILURE to REVISE OBSOLEIE 4A FROCDURES 415/79 27 VIOLATION 446/7926 446/79-26 445/7927 FAILURE TO FOLLoi FR0CEMR2 FOR H0lSilE SAFEi! 445/79-17 VIOLATICH 446/1926 RELATED COMF0KSNTS 446/19 4 6 445/1928 FAILURE TO PR0 VIDE AFPROPR(ATE INSTRUCTIONSH5/73-28 fur Vl0LAT10N 446/1927 INSTALLATION OF ELECTRICAL FANil 446/79 27 .

445/1931 FAILURE TO F0LLOW VELD [NG FR1CEM EIS 446/1929 445/79 31 VIOLATION 446/19 29 445/B001 FAILURE TO PROVIDE [NSTRUCi[0N AND PROC D URES (45/40 0I Vl0LATION 446/8001 APPROPRIATE TO CIRCUMSTANCE 446/80 01 445/8003 FAILURE TO FOLLOV FROCEDURES FOR CARLE FULLING 445/80 03 V(0LAi[0N '

446/8001 416/80 03 445/B008 FAILURE TO FULLOW FR90E WRFS Fe: hEfrailNG AND 445 TAO-y! l[0LAtl0N H6/8008 REPAIR OF NMAGO ELEciR{rAL CAnLE 44030-03 44U3003 FAllME to itWET A SIGNIFirAU N5 V"T h'h  !!5tdu M Vl61. Ail 0H 446/8008 DEFICIEhCV 4H/;0 H

_ ___- -_ _-- - ---- --- ~ ~ ' ~ ~ '

I0 Fase No. 6 08/11/87

. I CFSES KRC !! liEMS LIST j

ITEM liEM NRC IR OFE CF NUMBER I 0!SCRIFil0N NUMBER I1EM l

l l

445/8003 GROUNDWATER WiiH0RAWAL RATES 446/8009 445i!0 03 V(0LAil0N 446/80 05 445/8011 FAILURE 10 FOLLOW P!Pl!;G INSTALLAil0N FR6CEDURES 446/8011 415/8011 ([0LAT[uN l 446/80 11 l

l 445/8013 I FAILURE 10 FOLLOW WELDING FROCEDURES 145/10-i3 VIOLATION 446/8013 446/80-13  ;

445/8013 FAILURE TO Ful,LOV ELECTRICAL INSFECTION PROCEDURE 445/6013 Y!0LAT[0N 446/8013 446/A013  !

i

. H5/8015

! FAILURF. TO FOLLOV CoriTRU:: TION FR0C!0'JRE REQU(RED 445/80-i5 BfYl0LAi!0N 446/8015 BRAWING (46/80-15 445/80lf FAILURE TO FOLLOW DRAWING FOR WSLD PREP DETAILS 415/80 17 VIOLATION H6/80lf 416/80 17 445/80l8 ,

FAILURE TO REFURT A SIGhlflCANT CONiiRl!CilnN 445/10 18 VIOLATION H6/8018 08FICLENCY 146/80-18 445/8023 FAILURE T0 F0ILOW FR0CED' IRE IN MAKING FULL 445/8013 VIOLAi!0N 446/8013 FENETRAT(09 WELOS 446/80 13 445/8101 FAILURE 10 f0LLOV PROCEDURES FOR FIPING INSTALLAft09 445/8102 VIOLAi[0N 06/8102 4H/81 02 445/8115 FAllME 10 FOLl,04 QA FRUCEDURIS FOR I.4E INSPECil0E 445/81-15 Vl0LAT[0H 446/8115 0F C0AT[NG (MISCELLANE003 STEEL,113L! TRAYS SUPPORT H6/81 15 OR P[FE S'JFPORTS) 445/8103 PROCUREMENT CONTRul3 115i83 33 Vl0LATION 446/8203 446/82 03 445/8211 V 02 FAILURE T0 FROFERLV IN00PIRINAi! Ahl' IRAIN FERSONNEL H!su-ll 'l[0LAT(0N PERFORMING ACTIV!i[ES AFFECilhG ',UAl.li7 H6/81-10 H5/82H FAILURE TO PERFCRM INSPECTIONS OF INiiALLATION H5/82 ll vlCLAil0N 446/8211 AC![V(TIES RELATED TO UNlt ! CONTAINMENT FOLAR CRANE 446/32 11 445/8225 CERTIFICATION OF INSFECioRS 445id2 25 Vl01,Atl0N H6mn Hon.n u _ _ _ _ _ _ _ _ _ _ _ _ _ _

Fl(4 NO. i i 08/11/97 ,

1 i

! lil! NRI' IE liiM5 L(if liEM NUMBER ITEM

!.RC IR

DESCRIH IVF2 0F

:::::::::::::::::.lus... : .:: :: .: :, :..:

!MBER liEX

. : : .:::::::: 1 445/8225 AUDITS OF NFS IllDUSTRIES AND CBt! k 446/8213  !

445182 25 VivtAt[0N 445/8225 446/8213 {

446/8tl3 CERilFICAi!0N OF 1%SFICt0RS 445/82 25 V!0LAt[0N 146/82-13 445/8225 AUDITS 446/8213 145/82-25 VIOLAt[0N 416/82 13 \

ll 445/8230 V 01 j FAILURE TO FOLLOV FROCEDUR!S 445/82-30 V!0LAt[0N

' 445/8303 V-01 I FAILURH 70 (MPLEM!NT A GA FROGRAM 0F FLOODLitS POLE ASSY'S FOR [HSTALLATION 445/83 03 VIOLATICN 416/83 01 445/8101 y 446/8304 FAILURS TO F0LLOV FROCEDURES {

445/83 07 VIOLATION  !

445/33 04 445/8308-V 01 I FAtl,URE TO ESVIEW CHANGES TO Al:PR0VED FROC500k!S 445/8318 V 01 445/83-08 V10LAtt0V 446/8312 V 01 LACK OF FROCEDURES, (NSTRUCil0NS 1 DC'S fur

[NSTALLAtl0N 0F MAJOR ITEMS 445/83 18 VIOLAt[0N 446181 12 445/8318 V-02 446/8312-V 02 FAILURE 10 FR1Vll!R myVATE MAINIH.AFE 4F FAT'l. (

EQUlP [N OUIN OR AREAS 415/83 19 Vl9UT[0S 446/83-12 H5/8316 V 03 446/8312-V03 FALLURE TO REMQVF. CBSOLETE D.iAVlhGi HtM s!RR ASE 415/83-18 Vl0LAtl0N 446/A3 12 445/8318 V-04 446/8312 V 04 FAILURE TO FR0V105 A054UATE C)STROL SVSTEM FABRICATION 445s43 18 VicLAi[0N Ci VE1TILAt[0N 446/83-12 445/8323 V 01 HAR0VARS fiEMS DEVIATS FR(M Suld ( KU$NIS 145/03 23 i[0L AINN '

445/8323-V-02 l

INADF90 ATE INSTAI.LAf(OS FR0CEDURES STRUT) 145/A. 23 Vt%AttcN (SEtsMIC SWA) 445/8340-V 01 FAILURE 10 F0LL04 FR)CIOURES {

- 145d3-43 /' (o!. A f t::S H5/8408-v01 c m ON cNIT i FulAR rRn E s w ;si i :_ e tc {

C 3 NECil0NS E!CEF.0 DESiCS s!;UIREMa ri lis,a e owla \

(WlH 04 i i

l I

l

)

l l

E __ ___ ___ m_ _ . _ _ --. -

Pata No. $

00/11/07 OSES WRC !! ITEMS LlS:

IISK ITEM SEC iR IV?E OF WUM8ER DHCRIFilM t VSER ll!M 445/8468 V 02 FAILURE 10 PERFORh INSFEttIONS 9F ACilVltES RELATED 445/84-08 VIOLATION TO Unit 1 MAIN COOLANT SYSTEM CROSSOVER LEG 446/84-04 RESTRAINT 3 4(5/B416 V 01 FAILURE TO PROPERLY INSPECT CABLE TRAY HANGE N 445/84-16 VIOLATION 445/8416 V-02 FAILURS 70 1R0V!03 C0NTROLLED IS$UANCE OF DESIGN 445/84 16 VIOLAf!0N DOCUMENTS AND CHANGES 445/8418 V 01 FAILURB TO FOLLOW PROCEDURES 445/84-18 Vl0LAT[0N 445/8418 V 02 FAILURE TO PROVIDE ADEQUATE TEST FRERE 4UISITES4(!/84 18 V!0LAtl0N (15/8421 V 01 PRCCEDURE VIOLATION $0P-501A 445/84 21 Vl0LATION 445/8421 V-02 STAatVP TEST FROCEDURE V10LATION (45/84 21 Vl0LATION

, 445/8422 V 01 FAILURS TO MAINTAIN R SITIVE FRES$URE ON ELECT 445/84-22 VIOLATION PENETRAtl0NS -

446/84-07

, 445/8422 V 02 Fall,URE TO NutlFY NiC AS REQUIRED BY 10cFR50.!!(e) 445/84 22 VIOLAf[0N 444/84-01 445/8422-V 03 FALLURE TO CBTAIN 'dORK AUTHORIZATION TO BR!AR145/84-22 i!ALS VIOLATION 446/84 07 i

445/8422-V 05 I FAILURE TO DOCUMENT THE AS BUlli CONFICURAt[0h 145/A4-22 VIOLATION '

446/14 07 445/8426-V 01 FAILURE 10 FR0 VIDE QC IN3FECiltN CRliSRIA 445/84 26 VIOLAt[0N l

445/84!6-V02 FAILORE TO PP0PERLY INSPECT 445/84 2f VIOLAt[0N 445/8429-V 01 FAILURE TO F0LLOW PROCEf/UEE MIN. AELD [UEEFASS 445/8423 Vl0LATION fthP.

4 H/81 10 445/8431 V 05 Fall,ED 10 MAES CilANGES 10 ELM-M2 !N 44f/44 31 VIOLATICW STA-205, REV 2 445/843l V 07 FAILURE To FOLi#d W.cCEDUR U 4:5dt JI slui,AllcN (f5/8431 V 08 FAILGR TO FRiviH AHa"41R F;.9@RF8 145/44 31 VIOLAil0N t

. I P3(a ho. 3 08/11/81 rFSES tRC IE ttEMS L[ST 4 ITEM (TEM NUMBER  !.RC IR i)M 'JF DESCRIPTION

HUMBER liiM 445/8431 V 14 }

FAILVRE TO PROVIDE ADE10 ATE PROCMURSS 445/84 3l vt0LAil0N 445/8432 V 02 FAILURE TO ESTABLISH QA FR0CFDURES TO R!di'LARl,Y  !

448/8411-V 02 4451Ri 32 V!0LAil0N I REV!EW STATUS AND ADEQUACY OF C0!.STRUCil0N 446/84 11QA FROGRAM 445/8432 V 03 N

446/8H l V-03 FAILURE TO PROPERI.Y FLAN OR FR000CE EV[0ENCE 445/84 32OF V[0'st[0N PLAWWlWG FOR A COMPREHENSIVE AUDIT FR0 CRAM TO VERIFY 446/84-il COMPLIANCE WITH QA FR00 RAM )

i 445/8432-V 05 l 446/8411-V-05 FAILURE TO PROPERLY CERilFY A V!hDOR CoMr'LIANCE 445/84-32 VIOLAt[0N i

i

[N3PECf0R 4(6/84 11 415/8434 V 01 FAILURE OF INSFECi[0N TO [0hHilff NON CONFORMANCES 445/84-34 V(oLAt[0N

{

4(6/E4 13

~

, 445/8434 V-02 FAILURETONOTIFYNRCASREQUlREDBf10CFR50.55(el 445/84 34 VIOLAtl0N 4H/84 13 445/8440 y-01 FAILURE TO FOLLOV PROCEDURAL REyVIREMENTS FOR 445i84-40 Vl0LAi!CW ASSlGNING A Ut:14Us IDitlilFIER 70 A 100FE30.55f e) 15 4ti/84 (TEM 445/8445 V 02 FAILURE TO PROVIDE ADFQUATE FR0CEDURES445/84-45 APFR0PRIATE V10LAil0W TO CIRCUMSTANCES 445/8515 H 01 446/8512if01 (0EFICIENCilFAILUR!10CCMFLVW(i310CFR50.12taH3) 445/85-15 OTHER 446!85-12 445/8502 V-05 FAlLURE 10 FOLLOW PRESPRIM D FRergprag sg.cp. sap.45 00 AVI SYST 45/45 02 VIOLATION 445/8506 V 03 FA[L!!1! TO HUVIDE AN AL!WAIE FRUCE}UiE MAlkl!M!L'E l45 d5 06 Vl0LAi!0N DIV. (fR0CE WRE CRASCESI 445/A507 V 01 FAILERE to FRt!! PLY CCREEct A1 i!lt flFIF' FR0BLhM - 07 VIOLAt[0N 445/85 446/8505-V 01 Rf! DELTA POTENTI AL TRAS$FcPb URIPH) L'lSCt!.isCT 4H/85 05 CLIPS) 445/8507-V 02 FAILURE TO FOLL94 F W E A -

M, CA! ABRAiinS 446/9505 V 04 445/85 07 Vl(LAi[CK SCALE NOT 0)CUMEhiEl) Ni A ii>R im Si : LE) (M d5 05 t

]

1

f Fue Wo. 10 08/11/87 rFSES WRC [E (IEMS 1,IST ITEM ITEM NR1 IR TYft 0F NMBER DESCRIFi[UN Hl:MBER 11EM 445/8507 V 03 QC RECE!VING INSFECi[0X ACCEPTED 445/85 07 Vl0LATI0H '

OUT 0F-SFECIFICAf[0N SAFETY RELATED EQU[FMENT 446/85 05 H5/8501 V-04 CONCRETB TRUCK Mll!NG BLADE IkSPECil0N FROCEDURE 445/85 07 VIOLAi!0N H 6/8505 y-Ot VIOLATION (CCF10) 446/85-05 H5/8507-V 01 FAILURE TO FOLLOW PROCEDURE COMMERCIAL GROUT445/85-07 USFD Vl0LAtI0H

[N LIEU OF CLASS 'E' CONCRETE H6/85-08 445/8511-V-01 FAILUBE TO REPORT NONCONFORMING CONDif[0NS445/35-ll (FAILURE VIOLATION TOISSUEWCR) 446/85 05 445/8513 V-01 (NOV) FROCEDURE V[0LAf[UNS INCOMPLETE AND MISSING 445/85-13 Vl0LAtl0H CONDUlf (DENilFICAflog - QI-QF-il.3-8, H6/85 01 QI-QF II.1 13.7 445/8514-V-03

' AS BUILT DRAWINGS REVISED WiiH00f UPS REVIEW 445/85 14 V[0LATION 446/85-ll 445/8514-V 01 H10 CHEM rec 0RDS 445/85-14 VIOLATION H6/35-ll 445/SS14-V 01 FAILURE 10 IMPLEMENT fh00E'sCRFS F0R D':PL:MEH1 CONTROL 445/15 14 VIOLATION H6/8511-i 03 AND INVENIORY I46/85-11 445/8514d 04 FAILURE 10 COMPLY WlIH QI 'd -ll.;-25 415/85 14 V!0LAi[0N H6/85 ll HS/8515-H-02 lDEFICIENCT)DATADIDNOTCONIAlsTAG 445/85 15 OTHit U6/8512 H 01 06/85 lt 145/8515 H 13 (DEFICIENCYITSCMA'lAGERFAILED10R!i,[EVESHlFT 415/85-15 OTHER U 6/8511 'a 03 SUFV H O35 It 445/8515 H 04 IDEFICIENCY) Gl,EU ROSR N'.'T [M'! LED IN HFliERING HS/s5 15 OTHER 446/85111104 RECOMMEND.

H6t!5-It H5/8516 V 08 INADEQUATE ANALYSIS AND frere 0'.'is (N DCA 13343 (45/U-16 V!ulATION (10 85 l3 H5/85l6 V 13 FAILURE T0 ICENilFV UDERSI7.E VH.DS 145/85-16 V10LATIOS M 6iiS l!

I 1

I

f P4 2 No, 11 00/11/87 l'JS!i hkC IE ITEMS LIST ITIM llEM NUMBER HC[R MFE OF

[GSCRIPTION

EMBER liiM

: :: : ::: : ::: :: :.:  : ::::: :: : ::: l I

445/8516 V 14 NO DSSICN CllANGE DOCUMENTS APPROVlNGH5/85 MINIMUM BOLT 16 v10LAi!0N i

SPACING Vl0LAT(0N l 446/85 13 l 44'/8518 V 01 l CONDVIf HICES$lVELY LONG 445/85 14 Vl0LAtt0N 446/85-15 445/851t V-03 INSFECTORS NOT FR0FERLY CERTIFlB0 446/6615 V 02 445/85-18 VIOLAi!0N

{

446/85 l5  !

445/8518-VIl CABLE TRAIS NOT PROPisLY LAB 8tED Uh8518 Vl0LAT10X

' 4 H/85 l5 i 445/8518 V 15 l DES!CN CHANGE FR0CEDUR83 00 NOT FOLLOV 10 CFR, APPENDIl B, CRITERICH 3 445/85 18 V10LAilCH 4H/8515 {

j 445/8601-V 12 l fAllt!RE T0 [MPLEMENT FR0CE0VRES FOR HANDLING NON 445/86-01 Vl0LATION 446/8601 V 03 C0NFORMING MATER (ALS, PARIS. OR cuMFUNENTS l i 446/36 01

, 445/8601 V-14 l

' FAILtlRE TO PERFORM OR IMFLEMIRT FREiCRlBED 445/!6 FIELD 01 Vl0LAtl0N 446/8601 V 04 TEST OF CABLE REEL I 446/86 01 I 145/8603 V-02 FAILURE to TREND I 445/86 03 V!0LAfl0N H5/86-02 445/8603-V 04 DESIGN CHANGE AND NCR DISCR!PAhCf 445/86 03 VIOLATION 06/86-0t 445/8604 V 02 QUESfl0NS PERTAINING TO SNGINSERING ADEQUACY 445/86 04 VIOLATION 446/8603 V 02 FENCILLED (W ON DRAVINGS DISTRBUTIO 1006/8403 DCC TNE (EPAl 445/860by-03 1 H6/8603-V03 BRC PROCE0VRE 123 2286 FOR FIELD RiiORR HS/86-04 FAILUi! TO Vl0LATION IDEHilFY EPA'S AS NONCONf0RMING AND IMPLEMENT 4Hl86-03 CORRECTIVEACil0N I 445/8604 V 04 H6/8603 y 04 EQUlFMENT QUAllFICAfl0N Al'!WACY RFMb HR FlEL'1 IMi% 04 il0LAll0N REVORE OF CABLE SPLlCES ARE N0f CFN! RATED 446/86 03 445/8604 V 01 R80!!VlWG INSFECiluN, FAILUBE 10 CLFELi VliX 446/8603 V 07 M5/86 34 V (0.'. A T10!i FROCSDURS CF-QAP 7,2, R 3 (!PA'S RECEIVING 446t86-03 INSPEttl0!il H5/8604 V 08 FAILURE OF RECIEPT INSPECTION 10 IL % !Fi ! HH5/M 04 Vl0LAt[0!l 446/8603 V 0%

NONCONFOR1[WG CON 0ltl0MS VfiH REffECT TO IHlH REQU!R!D 03 STAGGERING OF CA!RE SFLlrE3 l

l l

l l

t b

P4e No. It 01/11/81 CPSES NRC !! liiMS LIS!

IfiM ITEM NRC [R tiFE 1F NUMBER DESCRIPt[0N NUMBER ITEM 445/8604 V 12 ACCIFTANCE BT 90 0F INSTALLED CCHFI@ Rail 0NS 445/86 0( VIOLAtt0N CONTRARYTOORAWINGS(CABLSSUPPORTASSEMBLIRS) 446/86 03 445/8604V13 FAILURE TO FERFORM REQUIRED SEAL.ING OPERAr[0NS, 445/8604 VIOLAricN EPA'S TO JUNCTION B01 446/86 03

)

445/8604 V 15 FAILURI TO ACCOMPLISH INSTALLAI[0N IN ACC0~ DANCE 445IB6 04 VIOLATISH WITH PRESCRIBED INSTRUCTIONS (IE 14 SL'FFORTS) 446/86-03 445/8607 V 11 TEMPORARY MODIFICAfl0N TAGS NOT USED IN ACCORDANCE 445/86-07 Vl01.Afl0N VITH CP SAP 13 445/86 05 145/8601-V 02 DBSicN CALCULAtl0NS Bf TN8 AS PR0Vl0ED WERE 445/8607 VIOLATIOW UXAPPROVED AND INCOMPLSTS 446/86 0!

445/8601 V 04 DESIGN CRANGES WERS NOT SUBMlffED TO THE 445/86 07 VIOLAT(0H

'. ORGANIZAtl0W THAT PERF0EMED THE ORIGINAL DSSIGN 446/86 FOR 05 RSVIEW AND APPROVAL 445/8601-V-10

' TERMINAL ilLOCKS IN FANEL CPI ECFERNOT l 145/86 07 Vl0LATION s

IDENTIFIED 446/86 05 445/8601-V-t!

DESIGN DRAllNGS NUT APFROF3lATELY REVIIWED FOR 445/86-07 VIOLAT!0N ACCURACT 446/46 05 445/8601-V 24 CORi!CilVE ACil0N REFORT CLOSED FRIOR TO CcMPLEt[0W 445/86 07 vl0LATION OF CORRECilVE ACil0N 446/86 05 445/8608-V 01 FAILURE T0 FULLY AUDli IHE BtR ASM!/4A FR0 CRAM 445/86 08 VIOLAtl0N (46/8606 V Ol 446/86 06 445/8608 V 02 INADia0 ATE DOCUMENTS IN AUDli Rifosi! 445/8608 VIOLATION 446/8606 V-02 CP-18,CP 21,CP 24,CP 27 446/36 06 445/8608 V 03 INADi40ATR 000VMENTAtl0N IN Ain!i WokiS PP 18 TWkV itS/H H Vl01.A r[0N 446/a606 V 03 CP 31 146ds si 445/8608 V-08 AUDIT DiFICID CY N0.1 uF iG C0 A 5 ;I iCF-51 VAS 446/8606 V 10 (i5/s6-08 vl0LAil0H  !

!MFR0FhRLY CLUSED WT 416/86d6 445/8614-V41 FAILURE T0 li?NTIFY. TAG. HG:iuAiE i EUuat itS/li it vl0LAttcN N0NC0NF0kMING II!MS 446/86 11 i

t Q _ _ _ -

4 ,

Os .[

, r Pale No.- 13 08/11/87-t CHES NRC IE ITEMS List f

ITSM lii3  !!RC (R " 11P! 0F 3 NUMBER DESCRIPi!Nl NUMBER [1EM

.::::::::::::::::::::::  ::::::::: :::::::::: )

3 445/8614sV03:

Ql-QP'S FOR CABLE TRAf Ali0 CABLE TRAI INSIALLAtl0N 445/86 14 Vl0LAtt0W 446/8611 V 10 INSPECfl0NS 00 NOT ADDRESS IN PROCESS CONTROLS 446/86-llFOR TH8 0 RILLING OF H0LES (N CABLE TRAIS TO ACCOMODAIB ti RAPS 445/8615V06' LACE OF UNlt i PFC PROCEDURES TO CONTROL DESIGN (45/8615 VIOLATION OOCUMENTS ISSUED FOR ElfiNDED PERl005 446/86 11

,; 445/8615-V01 l LACK OF PROCEDURE TO CONTR0L FAB Sil0P ITEM 445/86-15 Vl0LAff0N 446/86tt V 07 l TRACBASILITY

.c 446/8612 e -;

445/8615V08 LACK 0F PROCEDURAL, INSTR (ICTION RELATIVE TO VRITTEN 446/8612 V 08 445/86-15 VIOLATION REQUEST TO FAB SHOP '{

446/86 It

)

445/8620 V 03a FAILURS 70 (NCLUDE WORK PROCEDURE REFERENCE, REY.

. 146/8617V03a ( MIA6 i.0 V(0LATION L8 VEL OF DRAWING, SPEC. OR PROCEDURE ON TRAVELERS 446/86 17  !

-i - -

445/8620V03b TRAVELERS FOR WORK ON NSSS EQVIPMENT 0!D !;0f INCLUDH

.*{j,;

446/8617V03b THESICWATURSOFWESilNCHOUSB 445/H tu Vl0LAT[0W 446/86 11 445/8620V-04a MISSING OR-INADEQUATE WORK OPFRATIOli.0N TRAVELERS 445/A6 20 VIOLATION 446/8617 V 04a FOR SAF8tf !!UECil0N SYSTEM ACCl;MULATOR TANIS 446/86-17 445/8620V04b MISSING OR INADfQUATE WORK OPERAil0NS ON TRAVELERS 445/8620 VlulATION

'446/8611 V 04b FOR INSTALLING CLASS lE SWITCHES 446/86 11 445/8620 V 0$a TRAVELER RIVISED AFTER APPROVAL Asb No k!VISloN 445/H 10 Vt0LAtt0N (46/8617V05a NUM8ERS OR 0!SCRIPTION OF CHANGES 446/86 li 445/8621V01 i SAFEff VALV8 DISCS 00 Not HAVP. PROPER CERTS. 1445/36-!1 VIOLATION 446/8610 V 03 SHIPPlWG/R805(PTINSPECfl0HSN0fPERFORM!D 446/86 10 1 445/86ttV04 IMPROPER HYDR 0 DOCUMH!iTAf[UN ON IIT GalhWEL 4(5/86 VALVI  !! Yl0LAtl0N SONNETS 446/8610 445/8612 V 16 i PIPEIMPROPERLYSTORIOOU1SIDEWAR!HuuS!C(N 445/86-22 Vl0LAll0S 446/8620V07 VIOLATION OF MCP 10 446/8610 '

-445/8626 V 02 CABl,E PULLIN1 R0PSS REMAINING IN MiUIT A:iD CARLE 1 RAY 445/ H 26 Vl0L4tl0N H6IM tt H5/8626V08 BSC VEL 0sR PERFORMANCE QUALIFICA!l09 h!CcRL'S4H/H ;6 V10LattgN 446/3622 V 05 H6/86 21 i

a b _

i Para h. 14 08/ll/87 ,

. )

CFSES NRC IE ITEMS LIST ITEM ITEM

, NUMBER M0 IS iilt 0F

[43cR!FiIcN  !;UM3!R  ! [E'i i

445/4631-V 01 DISF0S!0N OF hC8 N 43-10ll23,'LAll UF [CA (35UtNCE 1 445t46 11 'i!0LAtl0W AND LACE OF RT FILM T0 $UFFORT EVALVAi!0N 446/86 25 445/8602 V 01 SECUllTY IS$VE l 445/85 02 V!0LAtl0W

{

445/8602 V 02 SECURiff ($ SUE  !

445/86-02 Vl0LAft0N 445/8101-V-01 FAILURS TO N0f!F) NRC FER FROVISIONi 0F 10CFR50.55e 05/87 07 vluLATION 446/8706 V OL 446/8706 f

I 445/8707-V 02 i NCR PROCRAM & PROCEDURES INADEQUAT8 TO IMPLEMENT 445/81-07 VIOLATION CRlTERION IV 0F AFP. 8, 100FE50 h 445/8706 0

9 4

4 4

a i

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C 0 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

e-ih$p0 CERTIFICATE OF SERVICE

'87 AU317 All :02 L

.I, William S. Eggeling, hereby certify that on August 14, {

-1987, I made service of " Applicants' Responses to Chs,olidatedy (

I blo'.

Interveners' (6/19/87) Interrogatories and Request for Documents" t f

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.

q Atomic Safety and Licensing c/o U.S. Nuclear Regulatory j 1

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 GAP-Midwest Office 881 W. Outer Drive 104 E. Wisconsin Ave. -B l

Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 l

Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel ,

U.S. Nuclear Regulatory  :

Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. _ 20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire Assistant Attorney General Atomic Safety and Licensing j Environmental Protection Division P. O. Box 12548 Board Panel U.S. Nuclear Regulatory l Capitol Station Commission l

Austin, Texas 78711  !

Washington, D.C. 20555 j I

l 4

l l

l 1

L- . _ _ _ _

o I Anthony'Roisman, Esquire Mr. Lanny A. Sinkin Suite 600 Christic Institute 1401 New York Avenue, N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 Dr. Kenneth A. McCollom l Administrative Judge Mr.. Robert D. Martin l Regional Administrator 1107 West Knapp Region'IV I

Stillwater, Oklahoma 74075 {

U.S. Nuclear Regulatory  ?

Commission Suite 1000 611 Ryan Plaza Drive 1

Arlington, Texas 76011 '

Elizabeth B. Johnson Geary S. Mizuno,. Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P. O. Box X, Building 3500 Oak Ridge, Tennessee U.S. Nuclear Regulatory 37830 Commission Washington, D.C. 20555 Nancy H.. Williams 2121 N. California Blvd.

Suite 390 Walnut Creek, CA 94596 William S. Egge g

)g i

L - _

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