ML20052F170

Statement of Matl Fact as to Which There Is No Genuine Issue in Support of Summary Disposition of Citizens Assoc for Sound Energy Contention 5 Re Qa/Qc.Certificate of Svc Encl

ML20052F170
Person / Time
Site:	Comanche Peak
Issue date:	05/10/1982
From:	DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20052F140	List: ML20052F139 ML20052F144 ML20052F149 ML20052F151 ML20052F153 ML20052F155 ML20052F162 ML20052F170
References
NUDOCS 8205120192
Download: ML20052F170 (6)

Text

. _.

6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION C/ETE~  ; n n-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'82 MM 11 A9 :33 In the Matter of ) CFriCr ~~ E ^PE ' *

) DOCB F igrgE im TEXAS UTILITIES GENERATING ) Docket NoE7"50-445 anc.

COMPANY, et al.

) 50-446

)

(Comanche Peak Steam Electric ) (Application *for Station, Units 1 and 2) ) Operating Licenses)

STATEMENT OF MATERIAL FACTS AS TO WHICH.THERE IS NO GENUINE ISSUE TO BE HEARD Pursuant to 10 CFR S2.749 (a), Applicants hereby set forth a statement of material facts as to which there is no genuine issue to be heard:

QA/OC' Organization At Comanche Peak j/ 1. Applicants have established a QA/QC program during the construction phase at Comanche Peak which assigns OA/QC functions among TUGCO/TUSI,. Gibbs & Hill, Inc., the

! Architect-Engineer, Brown & Root, Inc., the Construction

! Manager / Constructor and Westinghouse Electric Corporation, the. nuclear steam supply system supplier. Affidavit of i David N. Chapman at 2-3.

I I 2. TUGCO, as the lead applicant, has ultimate responsibility l

for quality assurance activities at Comanche Peak. TUSI l

is designated by TUGCO to have the~ authority to conduct the required support activities for implementation of the QA 0$O$$$$)$,

PDR l

4

, program at the site. Affidavit of David N. Chapman at 3-4.

3. Interfaces among participating organizations in the QA program have been established for QA functions at Comanche Peak. Affidavit of David N. Chapman at 9.

Satisfaction of 10 CFR Part 50, Appendix'B Criteria

4. The QA program at Comanche Peak establishes procedures and requirements to address each of the criteria set forth in 10 CFR Part 50, Appendix B. Affidavit of Antonio Vega at 2.

5. The CFCES QA program is' described in the CPSES Quality Assurance Plan, attached to the Affidavit of Antonio Vega, and the Final Safety Analysis Report ("FSAR"), admitted as Applicants' Exhibit 3 in this proceeding. Affidavit of ,

Antonio Vega at 2.

Disposition of NRC' I&E Reports

6. All but two matters raised in I&E Reports as " unresolved ,

items," or in Notices of Violation and Deviation which are cited by CASE as pertinent to Contention 5 have been

, resolved and that resolution verified by the NRC Staff.

Affidavit of Susan L. Spencer at 4.

l l 7. The resolution of those matt'ers has been in subsequent I I&E Reports or ib SER Supplement No. 1, S 8.4.4, p. 8-1.

I Affidavit of Susan L. Spencer at 5.

8. The unresolved matters involve a failure to follow certain l

l procedures for the inspection of coatings, and a concrete_

pour on Unit 1 dome. Affidavit of Susan L. Spencer at 5.

t l

I n

+

8'

9. The unresolved matters concerning the procedures for the -

inspection of coatings has been the subject of ongoing corrective actions by the Applicants and is subject to verification by the NRC Staff. Applicants have revised their procedures to assure that this type of problem does not recur. Affidavit of Susan L. Spencer at 12-13.

10. The unresolved mJtters concerning the concrete pour on the Unit 1 dome will be the subject of resolution following completion of stancard Structural Integrity Tests on porn -

primary reactor containments of Units 1 and 2. Affidavit of Susan L. Spencer at 9-11. The only item raised by the NRC Staff concerning Quality Assurance with respect to .

this matter has been closed-out. Affidavit of Susan L.

Spencer at 11.

11. Two other issues raised by CASE, involving honeycombing in the Unit 2 steam generator compartment and placement of the Unit 2 reactor vessel,;.have been resolved and the resolution verified by the NRC Staff. Affidavit of Susan L. Spencer at 5-9.

Brown & Root ASME Certificates of Authorization for Comanche l Peak

12. Each matter raised by the ASME Survey Team at the October 12-14, 1981 survey of the Brown & Root ASME QA .

) -g- -

Program at Comanche Peak was addressed and corrective action taken by Brown & Root. Affidavit of R. J. Vurpillat at 2.

13. Brown & Root has taken measures to assure that matters identified by the ASME Survey Team will not recur. Affi-davit of R. J. Vurpillat at 2.

14. Brown & Root has taken corrective actions in response to the findings of the ASME Survey Team at the January 18-20, 1982 resurvey and the Authorized Nuclear Inspector has verified completion of these items. Affidavit of R. J. -

Vurpillat at 17.

15. The Brown & Root ASME Certificates of Authorization for ,

Comanche Peak were reissued on March 15, 1982. Affidavit of R. J. Vurpillat at 20.

16. Each of the actions taken by Brown & Root in response to l' the ASME Survey Team findings at both the October 12-14, 1981 survey and the January 18-20, 1982 resurvey resolved i those findings satisfactorily. Affidavit of Roger F. Reedy l

at'28.

l

17. Brown & Root has demonstrate'd to the proper authorities (ASME and the Authorized Inspection Agency) implementation of an appropriate QA program for ASME Code work up to the present time. Affidavit of Roger F. Reedy at 28.

i 1

t L

'O a

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

)

TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, et al.

) 50-446

)

(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)

CERTIFICATE OF SERVICE

-m-

" I hereby certify that copies of the foregoing

" Applicants' Motion for Summary Disposition of CASE's Contention 5 ," in the above-captioned matter were served upon the following persons by overnight delivery (*) or by deposit in the United States mail, first class postage prepaid this 10rd day of May, 1982: .

• Marshall E. Miller, 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

• Dr. Kenneth A. McCollom '

• Marjorie Ulman Rothschild, Esq.

Dean, Division of Engineering Office of the Executive Architecture and Technology Legal Director Oklahoma State University U.S. Nuclear Regulatory Stillwater, Oklahoma 74074 Commission

- Washington, D.C. 20555

~ E EDr.

4/(2 - Richard Cole, Member-Atomic Safety and Licensing David J. Preister, Esq.

Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548 Capitol Station

-Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory .

Commission Washington, D.C. 20555

1.0 2 --

• Mrs. Juanita Ellis Mr. Scott W. Stucky President, CASE Docketing & Service Branch 1426 South Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20005 i

1 Y $. -

William A. Horin ,

f cc: Homer C. Schmidt

, Spencer C. Relyea, Esq.

1 i

l 3

a I

, . - , , . - - , - - - , , - - -,,c, -._ ,,,- ,- -

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