ML20128C638

Third Suppl to 850301 Response to Case 850204 Request for Admissions Re NRC Technical Review Team Findings in Review of Const QA & QC Activities at Facility.Certificate of Svc Encl.Related Correspondence

ML20128C638
Person / Time
Site:	Comanche Peak
Issue date:	06/28/1985
From:	Berry G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
CON-#385-650 OL-2, NUDOCS 8507030642
Download: ML20128C638 (25)

Text

(gb 30 ELATED CORRESPONDM 1

June 28,1985 "[gcTED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

+85 Jill. -2 N0 :41 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETAk' 00CKETING & SERVICI In the Matter of )

TEXAS UTILITIES ELECTRIC Docket Nos. 50-445/2 COMPAflY, et al.

) 50-446/2

)

(Comanche Peak Steam Electric )

Station, Units I and 2) )

THIRD SUPPLEMENT TO NRC STAFF RESPONSE TO CASE'S REQUEST FOR ADMISSIONS

1. INTRODUCTION On February 4,1985, Intervenor Citizens Association for Sound Energy (CASE) filed a request for admissions in which it asks the Staff to aomit certain facts purportedly found by the Staff's Technical Review Team (TRT) during the course of its review and evaluation of Applicants' construction and quality assurance / quality control activities at Comanche Peak Steam Electric Station (CPSES). In its March 1, 1985 Response the Staff indicated that the TRT's findings and conclusions regarding the matters within its jurisdiction are set forth in applicable Supplemental Safety Evaluation Reports (SSERs). See Staff Response at 2-3. At the time the Staff's March 1 Response to CASE'S Admission requests was filed only the SSER concerning Electrical / Instrumentation and Test Program issues had been published. Subsequently, the Staff issued SSER No. 11, which addresses Quality Assurance / Quality control issues. Consequently, the Staff is now in a position to resnand to CASE admission requests

% fog % h [

n 8

~

. 34-85, 87-89,92-115, 117-122, 124-126 which relate to these matters. I/ -

The Staff's responses are set forth below.

II. NRC STAFF RESPONSE TO SPECIFIC ADMISSION REQUESTS

34. The TRT found, based on a review of about 200 fuel pool travelers, that the fuel pool travelers included irregularities such as:

1) There was apparently a routine practice during construction of the fuel pool that allowed craft personnel to complete a portion of the inspection report fonns prior to the actual inspection. Craft personnel entered the word " SAT", dated the entry, and left blank only the space for the QC inspector's signature. It appeared that the craft personnel were judging the inspection results prior to inspection.

2) The date accompanying the signature for visual examination of an inside weld was changed to a date that appeared to precede the examination.

3) Entries by the same inspector for two different inspections did not appear to match in that one entry appeared to be written by another person.

4) The procedure number for a dye penetrant inspection was changed by an insoector different from the one who conducted the inspection.

5) The date for a dye penetrant inspection was changed by an inspector other than the one who performed the inspection.

6) Fuel pool travelers were found with missing QC signoffs for fitup and cleanliness. No proof could be found that some of the required weld fitup and cleanliness inspections were ever performed.

-1/ The Staff's Response to CASE Admission Requests 1-13, 14-17, 18-27, and 28-33 were timely filed on March 1, April 4, and June 7, 1985, respectively. The Staff will respond to CASE Admission requests 86, 90, 91, 116, and 123 on July 1, 1985.

7) The TRT rtview disclosed the following irregu-larities with t?aveler entries in addition to those listed above:

(a) Date changes a'ter the fact (b) Signoffs for functions our of sequence

' (c) Corrections after the fact (d) Changes to first party inspector date signoffs (e) Missing signatures STAFF RESPONSE: Admit. See SSER 11 at pp. 0-199 thru 0-206.

35. The TRT found no basis or criteria for paint removal or identi-fication methodology of " worst case" pipe whip restraints which had received inadequate source inspections. This resulted from a TRT review of 17 NCRs issued involving weld defects.

STAFF RESPONSE: Admit only that CASE Admission Request 35 fairly reflects the contents of Part 2(B) of the enclosure of the TRT's January 8, 1985 letter to TUEC. See SSER 11 at 0-196.

36. The TRT found that although pipe support components had been previously inspected and accepted by TUEC Oc as rreeting the respective construction and installation requirements, of 42 pipe supports inspected, 46 deficiencies were identified.

STAFF RESPONSE: Admit. See SSER 11 at pp. 0-249 and 0-250.

37. The TRT found that TUEC did not report to the NRC, pursuant to 10 C.F.R. 50.55(e)(1), the omission of thread-locking devices in the Unit I nuclear safety systems and did not attempt corrective action until May 1984, when TUEC tested previously applied paint for thread-lock capability. That test was inconclusive, since it did not establish that

. the paint, an epoxy process, would reliably perform as an effective locking device under all service conditions and throughout the expected lifetime of the plant.

STAFF PESPONSE: Admit. See SSER 11 at p. 0-263.

38. The TRT found that TUEC could not identify to the TRT which paint was the subject of testing.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-260.

39. The TRT found that paint was applied to ASME code-controlled, NF hardware per specification 2323-AS-30 (non-Q) which required no inspection. (This issue appears to be generic for Unit 1.)

STAFF RESPONSE: Admit. See SSEP 11 at p. 0-259.

40. The TRT found that TUEC did not initiate an NCR, required by procedure, identifying _the widespread problem of missing locknuts; only a Request for Information was apparently generated which TUEC could not locate for the TRT.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-259, 263.

41. The TRT found that pipe support RC-1-901-702-C825 had a load bolt at a beam attachment which did not exhibit an approved locking device. (The bolt material type was SA-307 grade A.) The TRT found that pipe support CS-1-085-003-A42K had no approved locking device on the "special clamp" bolts, even though the design drawing for this clamp showed each bolt with a nut and a locknut.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

42. The TRT found that the baseplate for pipe support CC-X-039-006-F43R, located in the component cooling system, Room 249A, Fuel Handling Building, violated minimum ed;e distance criteria for bolt holes.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

43. The TRT found the horizontal member of Support CC-1-126-010-F33R was 3 inches lower at its centerline relative to the upper bolt-hole centerline than shown on the vendor-certified drawing.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

44. The TRT found that an excessive free gap existed between spherical bearing and washers on the sway strut asserrbly of support CC-1-126-015-F43R.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250,

45. The TRT found that other supports with similar bearing gap anomalies found in TRT's inspections were: RC-1-052-016-C41K, RC-1-052-020-C41K, and MS-1-416-001-533R.

STAFF RESPONSE: Admit with following clarification: Correct pipe support number is RC-1-052-015-C41K, not RC-1-052-016-C41K. See SSER 11 at p. 0-250.

46. The TRT found that the frequency of this type of procedure violation in the TRT's limited inspection suggests that this problem is generic for Unit 1.

STAFF RESPONSE: Admit that TRT found the frequency of this procedural violation to be " excessive." See SSER 11 at 0-263; see also 1_o, d at 0-250.

47. The TRT found paint contamination in the bearings of both snubber assemblies on component support SI-1-909-006-C41K that severely obstructed the bearing cavities and limited their movement.

STAFF RESPONSE: Admit. Correct support number, however, is SI-1-090-006-C41K. See SSER 11 at p. 0-250.

48. The TRT found that a similar condition exists on supports MS-1-416-002-533R.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

49. The TRT found that procedure QI-0AP-11.1-28, Revision 25, Attachment 29 permits less than full thread engagement in threaded plates. This allowance for less than full thread engagement is a potential violation of the ASME Code Section III, NF-7411; no code was invoked to set aside this procedure.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250, 262.

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50. The TRT found that sr#!Jer (shock arrester) adapter-plate bolt threads were insufficiently engaged in all four threaded holes of component support MS-1-416-002-S33R.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

51, The TRT found that a similar lack of full threaded engagement deficiencies on NF supports SI-1-090-006-C41K and CT-1-013-012-S32K.

STAFF RESPCNSE: Admit. See SSER 11 at p. 0-250,

52. The TRT found that sight holes were present in the strut body to verify threaded rod engagement. The rod was not visible through the i sight hole for support RC-1-901-702-C825.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

53. The TRT found locking device deficiencies. An example was that sway strut No. AF-1-001-014-S33R had a broken cotter pin.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

54. The TRT found load sides of pipe clamp halves that were not parallel. An example is that clamp halves for pipe supports AF-1-001-S33R and AF-1-001-014-S33R were not parallel.

STAFF RESPONSF: Admit. SeeSSER11;atp.0-250.

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55. The TRT found pipe clearance outside of allowable tolerance violations. An example of is that pipe support CC-1-126-013-F33R exhi-

bited no clearance on top or bottom, while the hanger drawing called out 0" on the bottom and 1/16" on top.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

56. The TRT found that a similar problem existed for pipe support AF-1-001-702-S33R.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

57. The TRT found that pipe clamp locknuts were loose. An example was that a pipe clamp locknut for pipe support AF-1-035-011-S33R was founo lcose (less than finger-tight).

STAFF RESPONSE: Admit that the pipe clamp locknut for pipe support AF-1-035-011-S33R was found loose. See SSER 11 at p. 0-250.

58. The TRT found that pipe support CC-1-126-014-F43R exhibited angularity that exceeded requirements.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-250.

59. The TRT found that a similar problem existed with pipe support RC-1-052-020-C41R.

STAFF RESPONSE: Admit. Correct pipe support number, however, is RC-1-052-020-C41K. See SSEP 11 at p. 0-250.

60. The TRT found that snubber cold set (AC) dimension did not natch the design drawing. An example was that pipe support CS-1-085-4

F 003-A42K deviated by approximately 1" from the cold set dimension shown on the design drawing.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-251.

61. The TRT fcund that support configuration did not match the cesign drawing. An example was that pipe support snubber CT-1-005-004-522K was installed end-to-end opposite from the orientation shown on the drawing.

STAFF RESPONSE: A imi t. See SSER 11 at p. 0-251.

62. The TRT fo;nd that a similar problem existed with pipe support CT-1-013-010-522K, where dimensional discrepancies existed on the support drawing that detailed the orientation of the snubber.

STAFF RES,P0NSE: Admit. See SSER 11 at p. 0-251.

63. The TRT found that a component type /model number did not match the design drawing. An example was that model numbers of installed snubbers fer pipe support SI-1-090-006-C41K did not match the model number on the design drawing.

STAFF PESPONSE: Admit. See SSER 11 at p. 0-251.

64. The TRT found that a similar problem existed with pipe support RC-1-052-020-C41R.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-251.

65. The TRT found that weld data cards were missing QC initials for welds. An example was that support number CC-1-126-013-F33R had some welds performed with no CC inspector initials or signature on the corresponding blocks of the weld data card for that support inspection package.

STAFF RESPONSE: Admit that the weld data card (singular) was missing GC initials. See SSER 11 Attachment 3, p. 4.A.17.

66. The TRT found deficiencies in identification of materials and parts. An example was that a replacement part (sway strut eyerod) for pipe support CT-1-013-014-532R had no apparent material identification either on the hardware or in the documentation package for the support.

The Material Identification Loa (MIL) did not list any identification traceable to the origin of the replace part.

STAFF RESPONS,E_: Admit. See SSER 11 at p. 0-251.

67. The TRT found that a similar problen existed with pipe supports CI-1-126-012-F33R, CC-X-039-005-F43R, and AF-1-035-011-S33R.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-251.

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60. The TRT found a frequently occurring number of strut and snubber load pin spherical bearing clearance with washers that were

) excessive (Ref.QI-QAP-11.1-28,Sec.3.7.3.1Rev.25). (SeeAttach-i ment 2, Table 3 Summary of Additional TRT Inspections).

STAFF RESPONSE: Admit. See SSER 11 at p. 0-253.

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69. The TRT found a frequently occurring number of strut and snubber load pin locking devices (cotter pins or snap lock rings) which were damaged or missing.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-253.

70. The TRT found a frequently occurring number of pipe clamp halves on load side which were not parallel.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-253.

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71. The TRT found a frequently occurring number of bolts threaded into tapped holes of snubber adapter plates that had less than full thread engagement.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-253.

72. The TRT found that a frequently occurring number of "Hilti Kwik" bolts (concrete expansion anchors) as installed did not nieet minimum effective embedment criteria.

l j STAFF RESPCNSE: Admit. See SSER 11 at p. 0-253.

73. The TRT frequently found that locking devices for threaded l

l fasteners were missing or of a non-approved type.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-253.

74. The TRT found undersize welds on electrical conduit supports and cable tray hangers. An example of undersize welds was that three or fourweldsonconduitsupportC120-21-104-3(cablespreadroom)were

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undersized. The required weld size was 1/4" at all weld joints, while the measured weld size was 7/32" to 5/32" for the full lengths of three  :

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, out of the four welds.

STAFF RESPONSE: Admit. Correct pipe support number, however, is ,

i C120-21-19_4-3. See SSER 11 at 0-257. (

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] 75. The TRT found that cable hanger CTH 5824 (Containment Building) i i had 13 undersize welds. The all-around welds on the six horizontal beams q should be 1/4" in size, according to details L1 and L2 on Drawing FSE- ,

00159, sheet 5824, 1 of 2. The measured size of these welds was 3/16" to 3 5/32" at each connection.

STAFF RESPONSE: Admit that the TRT found 12 undersize welds on t CTH-5824. See SSER 11 at 0-157 and Attachment 3, p. 4.C.1.

76. The TRT found that support IN-SP-7b exhibited undersize welds measuring 7/32" to 5/32" instead of the required 1/4".

STAFF RESP 0NSE

Admit. See SSER 11 at p. 0-257 and Attach-

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} ment 3, p. 4.C.1.

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I 77. The TRT found misplaced welds on hangers. An example was on hanger CTH-6742, where the TRT found that two structural welds were made  ;

j in the wrong direction. The 3/16" shop welds which join MK-10 and MK-11 i

! were made horizontally instead of vertically, as shown on drawing FSE-00159, sheet 6742. QC Inspection Report ME-!-0024909, dated February 16, 1984, accepted all inspectable attributes as satisfactory i

l prior to the TRT inspection.

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- - , - - - . + - , - - - . _ . - . . . _ _ _ _ . - . . . _ _ _ - . . _ _ _ _ _ _ _ - _ _ _ _ _ _ - - - - _ - - . . _ _ _ _ _ - _ _ _ - - -

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STAFF RESPONSE: Admit that problems listed in CASE Admission

Pecuest 77 was found only on hanger CTH-6742. See SSER 11 at 0-257 and Attachment 3, p. 4.C.2.

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l 78. The TRT found unauthorized configuration changes on cable tray I

hanger CTH 5824 (Containment Building) which had been fabricated to I include 40 more stiffeners and 80 more welds than required or shown on drawing FSI-00159, sheet 5824, 2 of 2, Detail L2. Inspection Report j

l ME-1-0006155 verified final OC inspection and acceptance on January 3, 1

l 19E4 l STAFF RESPONSE: Admit. See SSER 11 at p. 0-257 and Attach-l ment 3, p. 4.C.3.

i

79. The TRT found that cable tray hanger CTH-6742 (Auxiliary Lailding), Clip, HK-12, should be 6" x 6" x 3/4" angle stock in I

accordance with FSE-00159, sheet 6742. The actual flange thickness of MK-12 was 3/8".

l STAFF PFSPONSE: Admit. See SSER 11 at p. 0-257 and Attach-l

{ ment 3, p. 4.C.3.

! 80. The TRT found Hilti anchor bolt installation deficiencies. An i

l exmplewasCTH-6742(AuxiliaryBuilding)anchorbolttorquewhichwas 1

not verified (paragraph 3.5 of the procedure).

j STAFF RESPONSE: Admit. See SSER 11 at p. 0-257 and Attach-ment 3, p. 4.C.3.

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81. The TPT found that Hilti bolts were not marked in accordance with Attachment 1 of the procedure on CTH-6742.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-257 and Attach-ment 3, p. 4.C.4

82. The TRT found that the length of the Hilti bolts was not verifiable (paragraph 3.2) on CTH-6742.

_ STAFF RESPONSE: Admit. See SSER 11 at p. 0-257 and Attach-ment 3, p. 4.C.4

83. The TRT found that five base platt bolt holes on CTH-5824 (Containment Building) had violated minimum edge distance -- edge distancecannotbelessthan!7/8"(Attachment 2oftheprocedure).

Actual distance was 1 5/8" to 1 3/8" from the nearest plate edge.

STAFF RE,SPONSE: Admit. See SSER 11 at p. 0-257 and Attach-ment 3, p. 4.C.4.

84 The TRT found that ONE Hilti bolt ON CTH 5824 was skewed to more than 15 degrees. (Maximumallowableskewwas6degreeswithout correctivebevelwashers(paragraph 3.1.2).

STAFF RESPONSE: Admit. See SSER 11 at p. 0-257 and Attach-mer.t 3, p. 4.C.4

85. TheTRTfoundthatHiltitorqueonhangerCTH-6741(Auxiliary Building) was not documented as bei.1g verified by QC (paragraph 3.5).

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STAFF RESPONSE: Admit. See SSER 11 at p. 0-257 and Attachment 3, p. 4.C.4

87. The TRT fourd that many problems indicative of inadequate drawing control existed at CPSES from September 1981 to April 1984 These problems had been identified prior to the TRT's evaluation by both TUEC and NRC Pegion IV audits and reviews.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-047-48 and Attach-cent 3 at p. 5.B.

08. The TRT found at least that between August 1983 and April 1984:

1) Drawings released to the field were not current.

2) Crawing and specification changes were not current.

3) Design documentation packages were incortplete.

4) The docurent control center did not provide the satellites with up-to-date drawings, component modification cards, design change authorizations and document revisions.

5) Drawings hanging from an open rack, which had no checkout control, were available to craft and QC personnel.

6) Design change logs were inaccurate.

7) Design documents were not always accounted for in the document control center.

8) Current and superseded copies of design documents were filed together,

9) Satellite distribution lists were inaccurate.

10) There were discrepancies between drawings contained in the satellites and those in the docun.ent control center.

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11) Sore drawings were missing from the satellite I files.

!?) Telephone requests for design documents resulted in f the issuance of documents that bypassed the controlled distribution system.

STAFF RESP 0fiSE: Admit that during its review of safety-related hardware design documents control for the period between August 1981 and l I

July 1904, the TRT found the deficiencies listed in paragraphs 1 through ,

12 of CASE Admission Request 88 "were of a recurring nature." See SSER j 11 at 0-098-091, i

89. The TRT found that the effects of document control inadequacies f prior to July 1984 have yet to be fully analyzed by TUEC. l STAFF RESPONSE: Admit. See SSER 11 at p. P-28.  !

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92. The TRT found that the document control center issued a l controlled copy stamp to the QC department to expedite the flow of hanger packages to the Authorized Nuclear Inspector. Methods for this kind of issuance and centrol of such stamps were not described in TUEC's  !

procedures. (

i STAFF RESPONSE: Admit. See SSER 11 at p. 0-83-84.

93. The TRT founc that 20 percert of the training records reviewed  !

contained no verification of education or work experience. I STAFF RESPONSE: Admit. See SSEP 11 at p. 0-109.

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94. The TRT found that the results of Level I certification tests were used for some Level 11 certifications rather than the results of a  ;

i level !! test.

t STAFF RESPONSE: Admit. See SSER 11 at p. 0-109. }

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95. The TRT found that after failing a certification test, a candi- {

date could take the identical test again.  !

STAFF RESPONSE: Admit. See SSER 11 at p. 0-109. l

96. The IRT found that certifications were not always signed or  ;

i dated, t

. STAFF RESPONSE: Admit. See SSER 11 at p. 0-109,  !

97. The TRT found that White-out was used on certification tests.

STAFF PFSPONSE: Admit. See SSER 11 at p. 0-109. l t

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08. The TRT found that seven inspectors had questionable qualifications.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-109.  !

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l 99. The TRT found that there was no limit or control on the number [

of timer, an examination could be retaken. l t

STAFF RESPONSE: Admit. See SSER 11 at p. 0-108.

i 100. The TRT found that no 9uidelines were provided for the use of j waivers for on-the-job trainir.9 I

STAFF RESPONSE: Admit. See SSER 11 at p. 0-108.

i 101. The TRT found that in some cases recertification was accomp-l lished by a simple "yes" from a supervisor.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-108.

102. The TRT found that there was no formal orientation training for document control center personnel prior to August 1983.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-106.

103. The TRT found that the responsibility for administration of the non-ASPE training program was rot clearly assigned to a single individual or group.

_ STAFF RESPONSE: Admit. See SSER 11 at p. 0-108, 104. The TPT found that non-ASME personnel capabilities were loosely definedbylevels(1,!!,!!!).

STAFF RESPONSE: Admit. See SSER 11 at p. 0-108, 105. The TRT found that there were numerous additional problems in r non-ASME certification testing, such as: no requirement for additional training between a failed test and the retesti no tine limitation between a f ailed test and a retests two different scoring methods to grade a test -

and a retest; no guidelines on how a test question should be disquali-fled; no program for periodically establishing new tests except when t

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procedures changed; and no details on how the administration of tests should be monitored.

STAFF RESP 0f;SE: Admit. See $$ER 11 at p. 0-108, 106. The IRT fcund that the exemption provision in ANSI N45.2.6, which allowed substitution of previous experience or demonstrated capability, was the normal method for qualifying inspection personnel rather than the exceptional n:ethod.

STAFF RESP 0f1SE: Admit. See SSER 11 at p. 0-107-608.

107. The TRT four.d that installation of certain butt welded valves in three systems required removal of the valve bonnets and internals prior to welding to protect temperature-sensitive parts. The three systems involved were the spent fuel cooling and cleaning systems, the boron recycle system, and the chemical and volume control system. This installation process was poorly controlled in that disassembled parts were piled in uncontrolled arets, resulting in lost, damaged, or inter-changed parts. This practice created the potential for interchanging valve bonnets and internal parts having different pressure and tempera-ture ratings.

STAFFR[SP_0NSE: Admit. See $$ER 11 at p. 0-119.

108. The TRT fourd that the scrip and salvage pile in the fabrica-tion (fab) shop laydown yard was not identified and did not have restricted access.

l STAFF _ RESP 0NSE! Admit. See SSER 11 at p. 0-147.

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109. The TRT found that material requisitions prepared in the fab shop did not cortply with the applicable procedure. i STAFF RESPONSE: Admit. See SSER 11 at p. 0-146, 0-152.

110. The TRT found that the fab shop foremen were not familiar with procedures that controlled the work under their responsibility.

STAFF RESPONSE: Admit. See SSER 11 at p. 0-146.

111. The TRT found that fabrication and installation procedures did l not include information to ensure that BAR-fabricated threads conformed t

to design specifications or to an applicabic standard.

STAFF RESPONSE: Admit. See $$ER 11 at p. 0148.

112. The TRT found that indeterminate bulk materials that accumu-i lated as a result of site cleanup cperations were mingled with controlled safety and nonsafety material in the fab shop laydown yard.

STArF RESP,0 HSE:

S Admit. See $$ER 11 at p. 0 147 113. The TRT found that site survoillance of material storage was not docurrented.

STAFF RESP 0NtE: Admit. See $$ER 11 at p. C 147-140.

!!4. The TRT found that work in the fab shop was performed in I response to memos and sketches instead of hanger packages, travelers, and controlled drawings.  !

STAFF RESPONSE: Admit. See SSER 11 at p. 0-147.

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l 115. The TRT observed that not all snubbers were wrapped with l

protective covering when welding was being done in close proximity to l them. This practice was a violation of B&R procedure Cp-Cpt!-14.1, which t

required protection of installed equipment during welding.

ST_AFF Rt!PONSE: Admit. See SSER 11 at p. 0 158.

i l l l  !!7. The TRT found that NCPs were used as a tracking document to l

record rwoval of a part from equipment on a permanent equipment transfer l

l rathe than for reporting a nonconforming condition; such usage of the l

1 NCR was not defined in procedures.

• STArr RFsr0NSE: Admit. See SSER 11 at p. 0 164.  ;

. l l t 110. The TRT found that there was an inconsistency between para-l graphs P.1 ano 's.t.1 in procedure CP-QF-16.0. Paragraph 2.1 required all !

! l site u ployees to report nonconformances to their supervisor or to the i I

site OA supervisor, while paragraph 3.2.1 required persons other than QA or (C personnel to submit a draf t NCR to the Paper flow Group.  !

,5,TfffRitr0N,0,Et Admit. See 55Ep 11 at p. 0 164  !

119. The TRT found that the NCR form had no form number or revision l l date to indicete that the form was being adequately controlled, j STArf Pf trof.$Es Admit. See 55ER 11 at p. 0 165.

l l 170. The TRT Founo that there were two versions of the TUTC hCR form, one with and one without a space for the Authorized Nuclear Inspection (Ah!) review. ,

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STAFF RESPONSF: Ader.i t . See SSEp !! at p. 0-165.

121. The TRT found that the NCR form hJd no space to identify the

l cause of the nonconforrance and the steps taken to prevent its l

! recurrence, f,TArF RESP 0h5E: Admit. }g $$[R 11 at p. 0 105. l I

l 122. The TRT found that the NCR form had no provision for quality assurance review.

STAFF RESPONSE Admit. Sen SSER 11 at p. 0-165.

l 124. The TRT found the inaterial traceability was adequate for those (

33 pire supports, with the enception of four material identification i dist.repancies out of 33 pipe supports checked (as noted in sectinn 4 on j asbuiltinspections). [

l 5fAFF pr$PONSE: Admit. }n $$tR 11 at pp. 0 240 and 0 251. l l

t l i

l 125. Tbc TRT found that TilEC failed to maintain materiel l

traceability f(r safety related material and nutterous hardware i corrpenents.

plMr Fr$PON$rt Admit 45 clarified in $5ER !! at 0176.  !

126. The TAT found that a QA breakd0wn in material trace #tiility Nintenance for safety related rnatorial and hardware cornponents wan l t

reported to T0rc in an ASPE Code survey in Dr.tober 1901 yet was not  !

I e

i

reported to the NRC in accordince with the requirements of 10 C.F.R. 50.55(c).

STAFF RESPONSE: Admit. See SSER 11 at p. 0-176.

regpctfullysubmitted. [

\

regory ry p Counsel ir ' Staff j 0.ited et Pothesda, Faryland this 28th day of June, 19I15 I

l l

I

r_ - - - - - - - - - - - - - - - - - - - - -. -- - - - - - - - -- - _---------------_---- - -- - _ - - --

p g.ocoto p e @

UNITED STATES OF AMERICA h0 CLEAR REGULATORY COMMISSI0s 00LgEift gc REFORETHEAT0fff'SAFETYANDLICENSINGBOARD

'85 JA. -2 A10 :41 In the Matter of l OFFV or St.uet tav TEXAS UTILITIES ELECTRIC Docket Nos. 50-445/2 00CdimG ?. SE AvKI  ;

BRANCH C0f'PANY, el al,. 50-446/2 i

(Coranche Peak Steam E1cetric Station,!! nits 1 and 2)  ;

l CERTIF! RATE OF SERVICE 1 hereby certify that copies of " THIRD SUPPLEMENT TO NRC STAFF PESPONSE TO CASE'S PEQUEST FOR ADMISSI0f:S" in the above captioned proceeding have been served on the following by dero $f t in the United States mail, first class, or, as indicated by an asteritk through deposit in the Nuclear Pegulatory Consnissier's internal rail system, this 28th day of June,1985:  ;

Peter B. Dioch, Esq., Chairman

• Mrs. Juanita Ellis Administrative Judge President CASE Atonic Safety and Licensing Peard 1476 South Polk Street lI.S. NucIcar Regulatory Commission Dallas,TX 75224 Washington, DC 20555 '

Ree,sa Hicks Esq.

Dr. Ver.neth A. McCollom Assistant Attorney General Administrative Judge Environtrental Protection Division Dean, Division of Engincoring P.O. Box 12548, Capital Station Architecture and Technology Austin, TY 78711 Oklahoma State University Stillwater,OK, 74070 Nicholas S. Reynolds, Esq.

William A. Horin, Esq.

Elfrabeth D. Johnson Bishop Liberman, Cook, Administrative Judge Purcell & Reynolds 0a6 Pidge National Laboratory 1200 17th Street, N.W.

P.O. Box X, Cuilding 3500 Washington,DC 20036 Da> Ridge, TN 37030 Dillie Pirner Garde Dr. Walter H. Jordan Citizens Clinic Director Administrative Judge Government Accountability Project 881 W. Outer Drive 1901 Ouc Street, N.W.

Oak Ridge, TN 370JO Pashington, DC 20009 i

4

, Perbert Grossman, Alternate Chairman

• Mr. Michael D. Spence, President Administrative Judoc Texas Utilities Generating Company Atenic Safety and Licensing Board Skyway Tower U.S. Nuclear Regulatory Ccmissinn 400 North Olive Street, L.B. 81 Vcshington, DC 20555 Oa11as, TX 75201 Filen Ginsberg, Esq.* Robert D. Partin Atonic Safety and Licensing Board William L. Brown, Esq.

U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 011 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 Robert A. Vooldridge, Esq.

Forsham, Forsythe, Sanples Lanny Alan Sinkin A Wooldridge 3022 Porter Street, N.W., #304 P001 Pryan Tower, Suite 2500 Washington, DC 20008 Dellas, TX 75201 James T. McGaughy Mr. James E. Cumins Southern Engineering Co. of Georgia Pesident Inspector / Comanche Peak 1800 Peachtree Street, N.W.

Steam Electric Station Atlanta, CA 30367-8301 c/o U.S. Nuclear Regulatory Comission P.O. Fox 3P Atomic Safety and Licensing Board Glen Rose, TX 76043 Panel

• U.S. Nuclear Pegulatory Comissien Pf111am H. Burchette, Eso. Pashington, DC 20555 Park D. Nozette, Esc.

Peron, Purchette, Ruckert Atomic Safety and Licensing Appeal

& Rotixell Doarc' Panel

• Suite 700 U.S. Nuclear Regulatory Comission 1025 Thomas Jefferson Street, N.W. Washington, DC 20555 Vashington, DC 20007 Docketing and Service Section*

Anthony 7. Roisman, Esq. Office of the Secretary Trial Lawyers for Public Justice U.S. Nuclear Pegulatory Comission 2000 P Street, N.W., Suite 611 Washington, DC 20555 Washington, PC 20036 Joserb Gallo, Esq.

Ishan, Lincoln & Cecle Suite 0401120 Conrecticut Avenue, N.W.

Vashington, DC 20036 l 0

_b .- p.

irrgory /l an.I rry Counsel fr NI Staff l