ML20052A437

Tenth Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence

ML20052A437
Person / Time
Site:	Comanche Peak
Issue date:	04/20/1982
From:	Ellis J Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8204280332
Download: ML20052A437 (5)

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NUCLEAR REGULATORY COMMISSION BEFORE THE. ATOMIC SAFETY Af1D LICENSING BOARD In the Matter of I i

APPLICATION OF TEXAS UTILITIES I I

Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR and 50-446 I

AN OPERATING LICENSE FOR ~

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COMANCHE PEAK STEAM ELECTRIC I

+ s STATION UNITS #1 AND -2 (CPSES) I t I

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• 6- n ~3 CASE'S TEIITH SET OF I!ar:<ROGATOR!ES 3 AP027198& r TO APPLICA'iTS AIiD REQUESTS TO PRC / JOE .

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% s.t Pursuant tc 10 CFR 2.7h0b and 2 741, CASE (Citizens Association m.

Sound Energy), Intervenor herein, hereby files this its Tenth Set of Inter-regatcries to Applicants and Requests to Produce.

Please answer the folleving interrogatories in the manner set forth herewith:

1. Each interregatory should be answered fully in writing, under oath cr affir ction. .

2. Each interrogatory response should include all pertinent information known to Applicants, their officers, directors or employees, their agents, advisors cr counsel. Employees is to be construed in the bread sense of the verd, including specifice.lly Brown and Root, any censultants, and anyone else perfor=ing verk or services for Applicants.

3 Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrcgatory; do not ec bine ansvers.

4 Each request to produce applies te pertinent documents which are in the possession, custody or control of Applicants, their officers, directers, employees (as defined in 2. abcee), agents, advisors or counsel.

5 Identify the person providing each ansver, response, or document.

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These interrogatories and requests for docu=ents shall be continuing in nature, pursuant to 10 CFR 2 740(e) and the directives of the Board.

Because of the time restrictions under.which we are presently.

cperating, we request that supple =entatica be made on an expedited basis.

7 For each item supplied in response to request for docu=ents, identify it by the specific question number to which it is in response If .

the of the item is excerpted frc= c docu=ent, identify it also by the name document.

(rather than in reverse order).Please also provide the copies in the corr CASE'S INTERROGATORIES TO APPLICANTS AND REQUESTS All of the interrogatories and requests to produce in this set of interr ogatories pertain to CASE's Contentien 5:

Contention 5:

The Applicants' failure to adhere to the quality assurance quality centrol previsf ons required by the construction permits for Cc=anece Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50 l and the construction practices e= ployed, specifically in regard to concrete

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vork, mortar blocks, steel, fracture tcughness testing, expansion joints j place =ent of the reactor vessel for Unit 2, velding, inspection and testing

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s materials used, craft labor qualifications and verking conditions (as they "

=sy affect RA/QC, and training and crganization of OA/QC personnel, have raised substantial questions e.s to the adequacy of the const,ruction of the facility. r 10 CFR 50 57(a) necessary for issuance of an cperating l Peak.

y NOTE: In its 10/31/80 rulings, the Board construed Contention 5 to cover the inspection and Enforce =ent Reports identified by ACORN in it J 9 8/29/60OfferofProofinSupportofItsMotionforReconsideration of the QA-QC Contention. These I&E Reports dealt with: .

))j QA Program - Lack of Cc=pliance ~%

CA Program - Surveillance QA/QC Procedural Deficiencies _

Method of Identification and Control of Nonconfor=ance Subcontractors' Failure to Report Ite=s of Noncompliance Storage of Electrical Cc=ponents Failure

• o Follow Pipe Fabrication Procedures 1 Fotential Construction Deficiency Regarding Fossible Danage to @

Unit 1 Pressurizer -5 Failure to Follev Equipment Maintenance Instructions g

1. Have any pu=ps been ordered for the Co=anche Peak plant frc= Hayward Tyler Pu=p Cc=pany of Burlington, Vermont ? -

2. If the answer to 1. above ~ is yes, supply the following inf:r=ation:

a. *'ere

• any of the pu=ps found to be defective?

b. What specific tests vere run on the pu=ps to deternine whether er not they were defective?

c. Ecv many pumps were ordered for Co=anche Peak frc= this cc=pany?

d. Have any of the pumps been installed?

e. Describe the type of pu=ps and their cafety significsnee in the plant's systen.

f. Supply for copying and inspection all original docu=ents dealing with all pumps crdered for Cc=anhe Peak frc= Hayward Tyler Pu=p Cc=pany, including docu=ents dealing with inspecticas by Applicants cnd any of its e=ployees as well as by Hayward Tyler Pu=p Cc=pany, NRC reports en the cubject of Hayward Tyler pu=ps, cc..gressione.1 investigations regarding Hayvard Tyler pu=ps,- handwri ten notes,

, internal =c=oranda, and any other pertinent infor=nti:n known to

/.pplicants or their agents or employees.

g. If there is any other in23 rnation regarding Hayward Tyler Pu=p l Cc=pany's pu=ps which vere er vere suspected of beirq defective cf which Applicants, their agents or empleyces are avire but which they do not have in their possession, please advise vtit this in-l for=ation is and where we can obtain it.

l 3 Supply for inspection and copying the originals of all Nenconformance Reports not specifically requested in our previcus interr:gatories and requests to produce. (Include both TUGC0 and Brown and Ecst NCR's.) -

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4. Provide for inspectica and copying the originals of each End every Deficiency and Disposition Report (DDR).

5. Provide for inspection and copying the originals of each 3-d every Corrective Action Request (CAR).

! 6. Provide for inspection and copying the originals of ali ::icrete pour l packages. (NOTE: It is expected that this can be narrcas: considerably j cnce we have reviewed the documents previously requested.

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Provide

.(NOTE: for inspection and copying-the- _ originals of all weiding records reviewed the documents-'previously requested.).It is expected t .

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Have any Applicants? audits been performed on Brown and Root by 'anyone :ther than

.9.

If the answer original audits. to 8. is yes, please provide fo'r inspection a .d copying the Respectfully submitted, i

Ech N-g/s.) Juanita Ellis, President E

+GSE (Citizens Associatio . for. Sound Energy) '

1426 S. Polk Dallas. . Texas . 75224 -l 214/946-9446 -;

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UNITED STATES OF AMERICA NUCLEAR. REGULATORY COMMISSION ' m 7. " '

pu BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of 1 I

APPLICATION OF TEXAS UTILITIES I GENERATING COMPANY, ET AL. F09 AN Docket Mos. 50-445 I and 50-446 CPERATING LICENSE FOR COMA!1CHE I PEAK STEAM ELECTRIC STATION I UNITS #1 ANO 42 (CPSES) I CERTIFICATE OF SERVICE By of my signature below, I hereby certify that true and correct copics CASE's Tenth Set of Interrogatories to Applicants and Recuests to Produce have 1982, been by: sent to the names listed below this- 20 tn da,y of April Express Mail where indicated by

• and by tirst class ' rail elsewnere.

• Administrative Judge Marshall E. Miller David J. Preister, Esq.

"J. S. Nuclear Regulatory Co.nission Assistant Attorney Genert*.

Atomic Safety

~ tac hington ,

and, Licensing Board Panel Environmental Protection *.ivision C. C. 20555 P. O. Box 12548, Capitol Station '

Austin, TX 78711 4

• Or. Kenneth A. McCollom, Dean Civision of Engineering, Architecture, i and Technclogy

• i nlahc .? State '.niversity

illwater, Cklahoma 74074 j

• Cr. Fichard Cole, Member Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel

0. S. Nuclear Regulatory Cornission U. S. Nuclear Regulatory C:rmission U "aahington, D. C. 20555 Washington, D. C. 20555

• Nicholas S. Reynolds, Esq.

Lebsvoise S. Liberman Atomic Safety and Licensing Appeal Panel 1200 - 17th St. , 11. W.

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ashington, D. C. U. S. truclear Ecgulatory C:rnission .

20030 Washington, D. C. 20555

• Marjorie Ulman Rothschild, Esq. Docketing and Service Sect on

. ffice of Executive Legal Director . -

';. S. Nuclear I-m;ulatory Cornission Office of the Secretar/

Washington, D. C. U. S. Nuclear Fogulater/ 0 r. insion 20555 Washington, D. C. 2055E Au E 0X<,

V.s.) Juanit.a Ellis, Pres i'.cn t ASE (CITIZENS ASSOCIATICN TOR SOUND ENERGY)