ML20084L507

Response to ASLB 840131 Memorandum Requesting Info Re Tdi Diesel Generators.Niether QA Aspects Nor Safety Aspects of Generators Are within Scope of Admitted Contention. Certificate of Svc Encl

ML20084L507
Person / Time
Site:	Comanche Peak
Issue date:	05/11/1984
From:	Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
OL, NUDOCS 8405140487
Download: ML20084L507 (23)

Text

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et UNITED STATES OF AMERICA S

O NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING B AR I4 /lg,.g In the Matter of

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Docket Nos. 50-445 TEXAS UTILITIES ELECTRIC

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50-446 oc.

COMPANY, et al.

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)

( Application for (Comanche Peak Steam Electric

)

Operating Licenses)

Station, Units 1 and 2)

)

APPLICANTS' RESPONSE TO JANUARY 31, 1984 BOARD MEMORANDUM REQUESTING INFORMATION CONCERNING DELAVAL DIESEL GENERATORS I.

Introduction In its Memorandum (Adequacy of Record:

Delaval Diesel Generators), dated January 31, 1984,

(" January 31 Memorandum"),

the Licensing Board expressed concern that the record on the quality assurance contention is inadequate without further-evidence about the a'dequacy of the quality assurance program at Comanche Peak in relation to Transamerica Delaval, Inc. ("TDI")

diesel generators.

Noting that the Intervenor presented testimony on the alleged inadequacy of quality assurance for welds on the diesel generators,1/ and that the Staff in a separate proceeding had raised questions of possible generic impact concerning TDI diesel generators,2_/ the Licensing Board

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CASE Ex. 667 at 14-16.

l 2_/

Citing Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant), LBP-83-80, 18 NRC at slip op. at 2-5 (December 23, 1983).

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.. requested that the Applicants and Staff file additional information on the TDI diesel generators at Comanche Peak.

Specifically, the Board seeks in' formation on (1) the adequacy of Applicants' QA program to detect design or construction problems in TDI diesel generators, (2) the frequency and seriousness of problems with the Comanche Peak diesel generators, and (3) the adequacy of the Comanche Peak diesel generators to assure public safety.

January 31 Memorandum at 1-2.

The Board stated that its questions on these matters are "directly related to an admitted contention and [the Board does] not consider it appropriate to declare this' to be a sua sponte issue. "

January 31 Memorandum at 2.

Applicants submit that neither the OA aspects nor the safety aspects of TDI diesel generators at Comanche Peak are within the scope of the admitted contention, and that the Licensing Board's observation quoted above is not sufficient to obviate the determination by the Board contemplated in the sua sponte rule, 10 C.F.R. 2.760a, as explained by the Commission in Texas Utilities Generating Co.

(Comanche Peak Steam Electric Station Units 1 & 2)), CLI-81-36, 14 NRC 1111 (1981).

In fact, the principal thrust of the testimony of Intervenor's witness related to her qualifications to perform certain inspections.

The witness merely mentioned in passing that she was performing the inspections as part of a reinspection effort on the skids and supports for the diesel generators, a reinspection effort

j i

' i initited by Applicants' on-site organization.

Further, the I

witness did not question the adequacy of the diesel generators.

CASE Exhibit 667 at 6-16.

The transformation of this narrow concern of the intervenor's witness into a broad inquiry into the adequacy of the entire QA program and diesel generators themselves constitutes an impermissible extension of the scope of the admitted contention.

Applicants, in the interest of i

expediting this proceeding, have chosen to provide a response to the Board's request for information.

However, in view of the number of issues yet to be litigated and the limited time in which to do so, Applicants are hopeful that the Board will refrain from so broadening the issues beyond those specifically raised by the intervenor.

Despite this decision to be responsive, Applicants continue to maintain that the Board is i

pursuing a matter outside of the scope of the admitted contention, and do not waive their right to pursue our position r

that the Board's inquiry constitutes the raising of a sua sponte issue.

II.

Discussion j

A.

Application of Sua Sponte Standard Under the procedural scheme laid out in the Commission's regulations, the Licensing Board in an operating license proceeding is to decide those issues that have been placed in controversy by the parties.

See 10 C.F.R. Part 2, Appendix A,

{ VIII(b); 10 C.F.R. 5 2.760a.

Additionally, in limited

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.. circumstances, the Licensing Board may sua sponte go beyond those issues introduced by the parties, but only upon a determination by that Board "that a serious safety, environmental, or common defense and security matter exists."

10 C.F.R. $ 2.760a.

NRC i

Secretary's Memorandum, " Raising of Issues Sua Sponte in l

Adjudicatory Proceeding," June 30, 1981.

The action of the Licensing Board, calling for submissions concerning TDI diesel generators, does not fulfill the requirements of 10 C.F.R.

$2.760a, as amplified by the Commission in 1981, in Comanche Peak, supra.

The Commission there reversed the Licensing Board for retaining eight of the contentions of a dismissed intervenor without adequate justification, for this was beyond the power of the Licensing Board's sua sponte authority under 10 C.F.R. $ 2.760a.

Comanche Peak, CLI-81-36, 14 NRC at 1112.

The commission observed in that decision that "[t]he Board has confused its inherent power to shape the course of the proceeding.

. with its limited authority under 10 C.F.R. 2.760a to shape the issues of the proceeding."

Id. at 1113 (emph.nsis in original).

Although the Commission's language arosa in the <:ontext _ of an attempt by the Board to retain existing conterations, and in the case at bar the Board has characterized the TDI diesel generator issue as being "directly related to an admitted contention,"

January 31 Memorandum at 2, upon examination the underlying principle is equally applicable to the facts at issue.

-. The admitted contention on OA is, as follows:

"The Applicants' failure to adhere to the quality assurance / quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2 and'the requirements of Appendix B of 10 C.F.R. Part 50, and the construction practices employed specif!; ally in regard to concrete work, mortar alocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/QC) and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility.

As a result, the Commission cannot make the findings required by 10 C.F.R. $ 50.57(a) necessary for issuance of an operating

~

license for Comanche Peak."

Under the Licensing Board's rationale, almost any issue remotely related to quality assurance could be raised at the discretion.of the Board, It simply is not appropriate for any matter "related

.to" quality assurance to be raised by the Board and automatically incorporated within the scope of a broad quality assurance contention.

To do so would draw issues not raised by the Intervenor into the proceeding without any determination pursuant to 52.760a.

Surely this subverts the underlying rationale of the.

Commission's 1981 Comanche Peak decision.

Once again a Licensing Board in this proceeding is improperly attempting to shape the

' issues in the proceeding, as opposed to the course of the proceeding.

See Comanche Peak, CLI-81-36, 14 NRC at 1113.

It is the' prerogative of the parties, not the Board, to frame the l

_ _ ~ _.

i 1 j issues for litigation in this case.

It is important to note in 1his regard that the Intervenor has not raised any issue on the l

adequacy of the design for these diesel generators, let alone any issue on the technical adequacy of them to perform their intended

[

function.

Surely in that situation the Board should not do so.

l l

In this regard, the Point Beach decisions of the Appeal Board do not justify this type of inquiry by the Licensing Board.

The Board Chairman cited Point Beach during the recent hearings l

as suggesting "that the adequacy requirement is one in which the Board, looking at the record, has to decide for itself that there is sufficient technical information to decide about the safety of i

the plant based on the information before it."

Tr. 12,399-12,400.

The Board apparently arrived at this interpretation of j

its role and authority because the Appeal Board in Point Beach, although it found no error at the trial board level, nevertheless "went ahead and litigatad something new because they saw

[

someth,ing which was a concern to them Tr. 12,400.

However, an analysis of the Point Beach decisions and NRC T

regulations demonstrates that the Board's interpretation of its l

l role and authority is too expansive.

The principal point of departure is the respective roles of f

l the Licensing Board and the Appeal Board.

The Licensing Board is i

1 analogous to a trial court.

Its role in OL proceedings is to

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decide "the matters put into controversy by the parties to the

[

l proceeding 10 C.F.R. $2.760a.

The Board is to examine I

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_- _.. = _ _ _ _ _ _ _ _ _ _

j i f and decide matters not put into controversy by the parties "only l

where.[the presiding officer 3 determines that a serious safety, environmental, or common defense and security matter exists."

Id.

If such a determination is made, the presiding officer must

[

prepare a. memorandum to the Commission in which the matter is to be described and the basis - for the determination is to be i

explained.

NRC Secretary's Memorandum, supra.

l In contrast, while the Appeal Board has the same sua sponte authority as the Licensing Board, it also has the broader I

responsibility to review the entire record for matters of potential safety significance.

The Appeal Board derives its authority to do so based upon the Commission's delegation to the j

i Appeal Board "to exercise the authority and perform the review I

functions which would otherwise have been exercised and performed by the Commission.

10 C.F.R. $$2.785(a)-(c).

These regulations vest in the Appeal Board broad discretionary powers not enjoyed by Licensing Boards.

[

Those powers are exercised, for example, in the Appeal l

l Board's customary sua sponte review of licensing board decisions and the records underlying such decisions.

This review is a f

"long standing Commission approved appeal board practice I

undertaken in all cases, regardless of their nature or whether exceptions'have been filed."

Wisconsin Electric Power Corp.

f

.(Point Beach Nuclear Plant), ALAB-696, 16 NRC 1245, 1262, (1982).

i f

It is not comparable to but rather far broader than, the sua

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l

.. sponte authority of licensing boards prescribed in 10 C.F.R.

{2.7604, as clarified by the Commission in Comanche Peak, supra.

It was during this sua sponte review that the Appeal Board in Point Beach found two potential problems on which it sought additional information from the applicant.

Pojat Beach, ALAB-719, 17 NRC 387, at 395 (1983).

It is error for this Board to conclude, upon the basis of the Appeal Board's exercise of its broad discretionary powers in Point Beach, that this Board has a similar broad authority to delve into matters not raised by the parties.

The Appeal Board's action in Point Beach was not designed to (and did not) create a new " standard of adequacy" that licensing boards were instructed to apply.

Stated another way, the Point Beach decision in no way changed the role of the Licensing Board prescribed in 10 C.F.R.

{2.760a, as clarified by the Commission in Comanche Peak, supra.

Applicants submit, therefore, that the Board has misconstrued its authority and responsibility to pursue matters not specifically raised by the Intervenor.

This has led to numerous Board requests to Applicants (and of ten the Staff as well) for information and even. affidavits at times.

The instant request for information on TDI diesel generators is a case in point.

We ask the Board to adopt and apply Applicants' interpretation of the Board's limited authority to pursue matters not placed in controversy by the Intervenor.

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! l Further, the request of the Board for further submissions on TDI diesel generators is particularly inappropriate in light of the fact that the NRC Staff has already begun a broad independent review of this very issue, including the activities of the TDI l

owners' Group (of which Applicants are a member) that is, l

addressing the generic aspects of TDI diesel generators.

l B.

Adequac/ of QA Program to Detect

[

Design or Construction Problems l

in Delaval Generators Applicants' QA program at Comanche Peak has been developed i

1 and implemented to conform to the requirements of 10 C.F.R. 50, i

Appendix B.1/

The applicable portion of this regulation provides

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10 C.F.R. 650 Appendix 8, Criterion VII states:

" Measures

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shall be established to assure that purchased material, j

equipment and services, whether purchased directly or through contractors and subcontractors conform to the procurement documents.

These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or i

subcontractor, inspection at the contractor or subcontractor i

source, and examination of products upon delivery.

Documentary _ evidence that material and equipment conform to the procurement requirements shall be available at the nuclear powerplant or fuel reprocessing plant site prior to l

installation or use of such material and equipment.

This i

documentary evidence shall be retained at the nuclear powerplant or fuel reprocessing plant site and shall be sufficient to identify the specific requirements, such as t

codes, standards or specifications met by the purchased material and equipment.

The effectiveness of the control of quality by contractors and subcontractors shall be assessed-by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or i

services."

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.. for utility oversight of vendors' QA programs.

It does not require, however, that the utility perform duplicative QA efforts.

Applicants' QA evaluations prior to order placement and through its audit and inspection activities assure that the supplier has adequate and effective design and manufacturing controls in place that are effectively implemented.

Such controls are reviewed and are evaluated throughout the design and manufacturing process to assure the adequacy of the equipment as it is received and installed for uso.

The program, however, is not intended nor required to provide for a complete review and verification of details of the design.

That is a responsibility that is discharged by the vendor, in this case TDI, through the effective application of the design controls which Applicants have verified are in place.

The extent to Which the adequacy of design is verified by Applicants is through the vendor's testing and inspection of equipment prior to shipment.to Comanche Peak and through Applicants' extensive testing af ter installation, as discussed in Section C, herein.

Applicants' program comports with industry practice in placing ultimate reliance upon the vendor for proper design of components and equipment.

With respect to non-design problems, the term construction is assumed to encompass the manufacture of the equipment.

Applicants' QA evaluation, audit, testing and inspection program

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i outlined below is designed and implemented to assure vendor l

compliance with specification requirements and adherence to an approved QA program.

i 1.

Applicants' Vendor QA Program

-Applicants' QA program as it applies to components and

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equipment to be supplied to Comanche Peak by vendors spans the period from pre-award of the contract to the ultimate receipt, j

installation and testing of equipment at the site.

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The Vendor QA program entails several broad functions.

One t

is conducting a pre-award survey and audits of the vendor

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-organization and QA program.

This function is performed by the QA Services Group.

The second function is concerned with j

I inspection and testing of the hardware.

This task is performed i

by the Vendor Compliance Group and consists of witnessing tests, i

performing inspections, and authorizing the s,hipment of equipment i

from the vendor to the site.

A second inspection is performed by I

r QA/Qd personnel upon receipt at the site to assure that the equipment has arrived in proper condition.

The diesel generators are subjected'to extensive testing after installation to assure that they will perform their required function.

i

. Prior to award and during the life of a contract a series of i

pre-award evaluations and audits are performed by the QA Services Group.

The purpose of this program is to verify that the vendor has a program that complies with applicable regulatory

.(10 CFR 50, Appendix B) requirements and that this program is r-

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t effectively implemented.

The pre-award effort is conducted in accordance with instructions and procedures.

Specific procedures and instructions have been established to assist in the evaluation of vendors and in placing vendors on the Approved Vendors List (AVL).

If a potential vendor is determined to be deficient in one or more of these evaluated areas, the vendor is informed and given an opportunity to correct the deficiency.

Once a vendor is judged to be qualified pursuant to these procedures, it is approved and placed on the TUGCO AVL.

Following placement of a prospective vendor on the AVL and i

award of a contract, the vendor is subject to further audits by the QA Services Group.

The purpose of these audits as stated in

-the instruction is "to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance program have been developed, documented, and effectively implemented in accordance with specified requirements."d/

This purpose illustrates the distinction between the oversight provided by the utility's vendor QA program and the vendor's own QA program.

One of the major elements of the audit program is a detailed checklist which provides for observation and evaluation of attributes to be examined.

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DOI-C5-4.5, " Conduct of Vendor Audits."

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The Vendor Compliance Group witnesses tests and performs inspections of equipment being fabricated by vendors, pursuant to a witnessing trip procedure.

Prior to release of equipment to TUGCO from the vendor, the equipment is inspected pursuant to a final release and inspection procedure.

This procedure outlines the steps to be taken prior to authorizing the vendor to ship the equipment to the utility.

The procedure requires the preparation and use of very detailed inspection checklists.

Follow-up audits are performed as necessary to identify weaknesses in the vendor's OA program using information generated during release inspections.

Once equipment is received on site, it is subjected to further inspections as to delivered condition.

During installation QA/QC personnel perform additional inspections.

Further tests and inspections are performed by start-up personnel once'the equipment has been installed.

This results in the demonstration that the as-installed equipment fulfills its required function at the site.

Although this latter function is performed on-site by engineering and start-up personnel and not by personnel in the QA organization, it constitutes an inherent

" engineering QA function which is intended to detect and correct deficiencies on-site.

. 2.

Applicants' Vendor QA Program As Applied to TDI Diesel Generators The foregoing detailed the contextual and procedural aspects of Applicants' vendor QA program.

This section details the application of the program to the procurement of the TDI diesel generators.

Prior to contract issuance and the placing of orders for the diesel generators, Applicants participated in a pre-award audit conducted by the architect-engineer (A/E) Gibbs and Hill in which several programmatic weaknesses were identified.

These weaknesses were corrected by TDI as confirmed by subsequent audit by both the A/E and by Applicants' OA.

Minor deficiencies identified by the subsequent audit and compliance activities conducted throughout the course of the-procurement of these units were satisfactorily corrected by TDI.

Applicants' follow-up of all identified deviations assured that the units were built to specified requirements and/or approved design changes.

Prior to shipment of 'the diesel generators, source inspections were performed and test activities were witnessed by the Vendor compliance Group.

Very detailed release inspections l

l were conducted by Applicants' OA Vendor Compliance personnel.

In preparation for these inspections, specifications were broken down into checklists that were used to witness testing activities and to perform source inspections at the TDI facility.

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Inspections were performed Which included review of heat treatment records, nondestructive examination records, welding proceduresLand personnel records.

Inspectors also checked' the i

equipment against the appropriate drawings.

In addition to,

I documentation reviews at release inspections, documentation on required tests was examined during audits and by the architect / engineer as a result of' required submittals.

The pre-award survey, audits, tests witnessed, and release inspections on Comanche Peak diesel generator units and auxiliary equipment result in a high level of confidence that the L

requirements in-the specification and TDI design requirements are e

incorporated into the Comanche Peak diesel generators.

f The final level of review, accomplished on site by-QA/QC and l

engineering personnel, resulted in the identification and i

' correction of a deficiency in the construction of the auxiliary skids upon Which the diesel' generator auxiliary systems rest.

j Inspection-and-investigation resulted in a determination that the

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- welds on the. skids.were inadequate.

These deficiencies were

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t documented through the use of NCRs.

The inadequate skid welds j.

were detected and corrected by this process.

f C.

Adequacy of Comanche Peak Diesel Generators The Comanche Peak TDI diesel generators have already been tested and operated.

Observations made during testing and the need for corrective action are documented in test reports and, as

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necessary, nonconformance reports.

Routine observations of this type are expected during startup and testing of components and equipment.

They do not indicate serious deficiencies, but rather 1

attention to detail that is characteristic of the Comanche Peak startup program.

There were 37 diesel generator testing deficiencies reported from June, 1982, through November, 1983, and all have been addressed and successfully resolved.

One of the deficiencies detected with the diesel generator prior to j

preoperational testing was the inadequacy of the welds on.the auxiliary skids upon which the diesel generator auxiliary systems t

rest.

This was detected as a result of on-site, post-receipt engineering activities.

It was documented using a nonconformance 2

report and the skid connections were rewelded.

l The Comanche Peak diesel generators also are included in l

that category of TDI diesels (V-16 configuration) that have i

experienced certain generic deficiencies.

Some are documented in

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r 10 C.F.R. Part 21 reports.

These deficiencies comprise the list-l i

of'16 identified by the TDI Owners' Group, although not all 16 j

apply to the Comanche Peak diesels.

Those that apply have been

. detected during the disassembly and inspection of the Train A engine.

(The Train B disassembly and inspection began recently.)

Applicants are addressing these deficiencies as part'of their On the basis of i

test and inspection program described below.

testing and analyses to date, Applicants believe that none would l

have ' prevented the diesel generators from operating sufficiently l

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well to perform their function during emergency conditions.

Continued analyses as part of the TDI Owners' Group effort are ongoing.

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It should be noted that the serious failure (the cracked f

cranksha f t) encountered at Shoreham has not been found elsewhere.

This is ~ due to design differences which result in significantly j

lower crankshaft stress levels for the V-16 engines at Comanche j

Peak as compared to stress levels for the original crankshafts in l

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F the Shoreham in-line 8.. cylinder engines.

As a result of reports of piston skirt cracking in other TDI engines (documented in 10 C.F.R. 21 reports), Applicants decided, to be conservative, to replace all 32 of the pistons in both Unit a

1 diesel generators, although no specific deficiency had been detected at Comanche Peak.

In conjunction with this piston replacement effort, Applicants are par'ticipating in the TDI

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Owners' Group and conducting on the Comanche Peak diesels a detailed disassembly, inspection, component replacement (if 4

necessary), reassembly and testing program.

This testing and

' inspection program will provide reasonable assurance that the i

t diesels will perform their intended safety function.

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i Prior to this disassembly, each diesel was run for a r

significant period of startup testing, which included the NRC required preoperational tests and others.

The Train A diesel i

generator was operated for a total of 85.05 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at an average

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load of 4.346 MW, p'roducing a total of 369.6 MWh.

This testing i

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involved a total of 67 starts.

The Train B diesel generator was operated for a total of 84.70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> at an average load of 4.506 MW, producing a total of 381.7 MWh.

The Train B unit testing involved a total of 83 starts.

Required preoperational testing and surveillance was conducted in compliance with FSAR section 8.3, IEEE Standard 387-1977 ("IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations"), and Regulatory Guide 1.108 1

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(" Periodic Testing of~ Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants").

The required testing was successfully completed in March, 1983.

The Diesel Generator Requalification Program which is underway at this time will address the 16 generic issues identified by the Owners' Group.

These issues concern all component issues which have been identified in TDI's nuclear and nonnuclear diesel generator experience.

The specific components to be subjected to independent design review and inspection as a part of this effort are:

l.

Turbocharger 2.

Cylinder Block 3.

Connecting Rods 4.

Cylinder Heads 5.

Jacket Water Pump 6.

Crankshaft l

7.

Pistons

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. 8.

Connecting Rod Bearing Shells 9.

Cylinder Head Studs 10.

Engine Base and Bearing Caps 11.

Push Rods t

12. -

, Wiring and Terminations 13.

Rocker Arm Capscrews 14.

Airstart Valve Capscrew h

15.

Fuel Oil Injection Tubing 16.

Cylinder Lining In addition to the generic component design review and inspections, virtually all of the remaining components in the Comanche Peak diesels will undergo design review or quality revalidation, or both, in accordance with Owners' Group criteria.

Quality revalidation will consist of a review of component documentation (including material test reports, nondestructive examination reports, vendor and subvendor records, etc.) to insure the presence of important attributes in.the selected engine components.

Design review will be performed to ensure that the component designs are adequate to perform their intended function under all loading conditions.

Where acceptable documentation does not exist for a selected component, the presence of important quality attributes will be verified by tests and/or inspection by the Owners' Group.

1

e: Following the detailed inspection program underway at Comanche Peak, the two diesel generators will be reassembled and the preoperational testing repeated.

This post-reassembly testing will entail:

1.

Functional testing of the main diesel generator' starting and control circuits; 2.

A 24-hour test run for each engine.

Two hours of this test run will*be'at 110% of rated load and the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> will be at 100% of rated load; 3.

Load acceptance and stability testing to ensure proper sequencing and operation'and correct voltage and frequency under load; Diehelgeneratorreliabilitytestingbyperformanceof 4.

at least 23 consecutive engine starts without failure for each engine.

5.

Torsiograph testing on one engine crankshaft to provide torsional stress data while the engine operates and thereby to confirm crankshaft stress analyses.

As a result of this test, disassembly, inspection,

correction, reassembly and retest program, there will be

' reasonable assurance that the Comanche Peak diesel generators will perform their intended function and the public health and safety will be protected.

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. l The Board is on the mailing list and has been receiving

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Board Notifications of the TDI Owners' Group meetings and activities.

These Board notifications clearly indicate that this is a generic matter which is being addressed in detail by the NRC Staff.

The Owners' Group submitted the TDI Diesel Generators Owners' Group Program Plan to the NRC Staff on March 2, 1984.

The Program Plan was forwarded to all Boards as part of the Board Notification 84-051.

TUGCO submitted the Comanche Peak Steam Electric Station Requalification Program Plan to the NRC on April 30, 1984.

Thus, TUGCO, as a member of the Owners' Group, is actively participating in the resolution of this issue.

Respect 11 submitted, h

Nichola%[S. {R4ynolds

BISHOP, sIBllR4AN, COOK, PURCE EYNOLDS 1200 Se nte nth Street, N.W.

Washing n,

D.C.

20036 (202) 857-9817 Counsel for Applicants l

May 11, 1984 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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)

TEXAS UTILITIES ELECTRIC

)

Docket Nos. 50-445 and COMPANY, _et _al.

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50-446 (Comanche Peak Steam Electric

)

(Application for Station, Units 1 and 2)

)

Operating Licenses)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' e

Response to January 31, 1984, Board Memorandum Requesting Information Concerning Delaval Diesel Generators" in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid, this lith day of May, 1984:

1 I

Peter B.

Bloch, Esq.

Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S.

Nuclear Regulatory U.S.

Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Mr. William L.

Clements Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission l

Washington, D.C.

20555 Dr. Kenneth A. McCollom Dean, Division of Engineering Architecture and Technology Stuart A.

Treby, Esq.

Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S.

Nuclear Regulatory Mr. John Collins Commission Regional Administrator, Washington, D.C.

20555 Region IV U.S.

Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive U.S.

Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C.

20555 L

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, Renea Hicks, Esq.

Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O.

Box 12548 Capitol Station Ellen Ginsberg, Esquire Austin, Texas 78711 Atomic Safety and Licensing Board Panel Lanny A.

Sinkin U.S.

Nuclear Regulatory 114 W. 7th Street Commission Suite 220 Washington, D.C.

20555 Austin, Texas 78701 Nicho s S}

Reynolds cc:

Homer C. Schmidt Robert Wooldridge, Esq.

David R.

Pigott, Esq.

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