ML20041C318

Answers to 820210 Seventh Set of Interrogatories.Certificate of Svc Encl

ML20041C318
Person / Time
Site:	Comanche Peak
Issue date:	02/25/1982
From:	Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
NUDOCS 8203010159
Download: ML20041C318 (11)

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APPLICANTS' ANSWERS TO CASE'S SEVENTH SET OF INTERROGATORIES

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c. Applicants are not recuired to notify the Board of such matters at this c. hase o f the croceedinc. . . A =.li-c=. . s a a c h ' _ic_ a_ d ' ^ .i .n .# o .- .. '.k.a.

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R203010159 820225 h 60 PDR ADOCK 05000445 C PDR

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o Further, Applicants are under an obligation to notify -

the Board of changes in the schedule 'for completion -

of Comanche Peak since such changes could affect the ' ,

Board's schedule for the hearings on the remaining , ,

issues., Matters af fecting scheduling are not jnyol. bed' '

in this case. See response to Interrogatory-l.x. '

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d. No. .See re'sponses to Interrogatories 1. f-1.i.

r e.- 'Not applicable.-

f. No NRC personnel participatedfin the October 12-14,

! 1981 survey. One individual from the NRC attended the exit meeting held upon completion of the survey.

g ., R.G. Taylor.

h. No NRC personnel participated in the January 18-22, 1982 resurvey. One individual from the NRC attended the exit meeting he:d upon completion of the survey.

i. L. Martin'.

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j. Applicants will respond to this request for production of documents pursuant to and on the schedule provided for in 10 C.F.R. 5 2.741(d).

k.-n. The following lists are believed to correctly and

, completely identify those persons who were involved in the ASME inspection, some to a more limited extent-than others. All of those who were involved were actually present during some portion of the inspection.

L'nless otherwise noted, the individuals listed are located at the following address: "

, P.O. Box 1001 Glen Rose, Texas 76043

k. Ronald G. Tolson

, Bob J. Murray

< John T. Merritt

, Gene-Crane Joe B. Georce -

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l. Ray"J. Vurpillat

• Danny W. Leigh Richard P. Negri

• William E. Baker Douglas'G. Frankum Bill R. Wilson

• James V. Hawkins Martin Raines

- John Patrick Clarke, III John Howard Morton, Jr.

James O. Ragan J. D. Martin George Richard Willis William O. Cromeans Charles A. Acchison Kenneth L. Liford

• Brown & Root, Inc.

P.O. Box 3 Houston, Texas 77001

m. Ronald G. Tolson Billy R. Clements

• Fred Burgess Bob J. Murray Thomas Brandt John T. Merritt David N. Chapman Gene Crane

• Texas Utilities Generating Co.

2001 Bryan Tower Dallas, Texas 75201

n. Ray J. Vurpillat

• Ronald C. Washington Richard P. Negri

• George Richard Willis Gordon R. Purdy Kenneth L. Liford John Patrick Clarke, III James Laurence Patton Douglas L. Sanders Harold Z. Goodson William E. Baker J.D. Martin Edward Paul Opelski William O. Cromeans Richard P. Baker James Richard Wheeler David R. Dodson Randall O. Taylor James O. Ragan Heyward A. Hutchinson Douglas G. Frankum Ronald Lynn Meissner Danny W. Leigh

• 3rown & Root, Inc.

( P.O. Box 3 l

Houston, Texas 77001

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o. Applicants will respond to this recuest for production of documents pursuant to and on the schedule provided I for in 10 C.F.R. 5 2.741(d).

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p. The following individuals representing ASMI were involved in both the October 12-14, 1981 survey and the January 18-22, 1982 resurvey, unless otherwise indicated.

Robert E. Tilton American Society of Mechanical William Osborne Engineers United Engineering' Center 345 East 47th Street New York, NY 10017 Robert Holt National Board of Boiler & Pressure Michael Sullivan vessel Inspectors (October survey only) 1055 Crupper Ave.

Columbus , OH 4 3229 Ron Howard Hartford Steam Boiler Inspection Joe Hair (October and Insurance Company survey only) 4151 Southwest Freeway, Suite 200 John Richardson Houston, TX 77027 (January survey only)

L.G. Schweiger sacramento Municipal Utility District 6201 S. Street P.O. Box 15830 Sacramento, CA 95813 Steven M. Mathews Texas Dept. of Labor and Standards E. O. Thompson State Office Building P.O. Box 12157 Austin, TX 78711

q. Applicants are not aware of any such documents.

r. No. Following the October 12-14, 1981 survey, Brown

& Root requested an opportunity to present information to ASME and the Subcommittee on Nuclear Accreditation in order to appeal the withdrawal of the certificates.

The certificates would have been extended pending the outcome of the appeal. However, upon learning that the resurvey was scheduled in the near future, Brown & Root decided to devote full attention to preparation for the resurvey. Accordingly, Brown & Root withdrew their recuest for an appeal and the certificates were not extended.

s. Neither Brown & Root and/or Texas Utilities representatives attended the meeting suggested in the December 17, 1981 letter from ASME. Accordingly, no written reports or information were presented.

t. The December 17, 1981 letter was not listed separately because of an oversight. The letter was included with all other documents provided CASE on February 8, 1982 in response to CASE's requests for production of documents.

u. Applicants timely will update their responses to CASE discovery concerning communications with ASME, including this Interrogatory, as appropriate.

v. Applicants are not aware of the meaning of the term "NV4200." Applicants speculate that the notation

! referrenced by CASE is actually "NX4200," which is a section of the ASME Soiler and Pressure vessel Code.

The author of that notation is unknown.

w. In accordance with Applicants' telephone conversation with CASE on February 19, 19 82, Applicants responi as follows:

Item (F) of the November 2 3, 1981 letter from ASME to R.J. Vurpillat o f Brown & Root re fers to the redesigned and refabricated supports referrenced in the October 26, 1981 news release. See responses to Interrogatories 13-16.

x. No.

2. TUGCO maintains ultimate control over Quality Assurance /

Quality Control at Comanche Peak. The interfaces between various organizations in the Comanche Peak project are

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described in Chapters 1 and 17 of the FSAR.

3. TUGCO has maintained ultimate control over Quality Assurance / Quality Control at Comanche Peak since October 17, 1974, concurrent with the issuance of the Limited Work Authorization.

4-6. Not applicable.

7. The ASME Boiler and Pressure Vessel Code requires that certain activities be performed only by holders of the NA and NPT stamps. Brown & Root is a holder of these stamps and performs those activities for the Comanche Peak project under their Quality Assurance Program. It was the Brown & Root QA Program that was the subject of the October 12-14, 1981 ASMI survey and the January 18-22, 1982 resurvey. Accordingly, ASME deals directly with

. Brown & Root on all matters regarding their QA Program and the NA and NPT stamps.

8. a,b. 'In accordance with Applicants ' telephone conversation with CASE on February 19, 1982, Applicants need not provide responses to these Interrogatories at this time.

c. Prior to November 6, 1981, Corporate Quality Procedures were issued and controlled individually. On November 6, 1981 these procedures / instructions were issued as a controlled manual. The first Corporate Quality Procedure was issrad on July 31, 1978.

d. In accordance with Applicants ' telephone conversation with CASE cn February 19, 19 82, Applicants need not provide a response to this Interrogatory at this time. Applicants note that in their August 11, 1980 response to Question 23 of CASE's First Set of Interrogatories to Applicants, CASE was provided the procedures which have now been superseded by the controlled manual.

9. a. The Brown & Root Quality Assurance Manual for Comanche Peak was first completed in written form in November 1976.

b. In accordance with Applicants ' February 19, 1982 telephone conversation with CASE, Applicants need not provide a response to this Interrogatory at this time.

10. No.

11. Not applicable.

12. There is no requirement that such audits be performed.

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13. The " problem" referred to in the Applicants ' news release of October 26, 1981 is a production problem, rather than a quality assurance problem. Nevertheless, Applicants respond as follows:

l Since October, 1981, nineteen (19) additional engineers have been hired to work on pipe support engineering.

These individuals had worked previously with Brown & Root at the South Texas Project. No new inspectors were hired specifically to work in the pipe support area.

14. Busby, Jimmie H. Gidwani, Manohar Sripadan, A.K. Barsoum, Moheb Ramos, Deogracias L. Dumapit, Ruben D.

Kumar, Vatsa N.S. Kaszubski, David J.

McAdams, Jimmie Patel, Ajit S.

Patel, Mahendra J. Fang, Jeffrey H.T.

Traveni, Paolo M. Kuloor, Nandkumar B.

Dillworth, Teresita B. Shafi, Mohamad A.

Racelis, Luis E. Kamal, Asad Sullivan, Timothy D.

The address for these individuals is:

Texas Utilities Services, Inc.

P.O. Box 1002 Glen Rese, Texas 76043

15. There are 207 pipe support engineers and approximately 75 drafting personnel currently working on pipe support engineering.

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16. Approximately 2500 pipe hangers remain to be ccmpleted for Unit 1 and shared f acilities of an approximate total of 8000 hangers. This figure includes all pipe support devices which are being redesigned and/or ref abricated.

Respecg&u ly s mitted, Nicholdy S. ,Reynolds j L)

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William A. Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.

Washington, D.C'. 20036 (202)857-9817 Counsel for Applicants February 25, 1982

STATE OF TEXAS )

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COUNTY OF DALLAS)

Homer C. Schmidt, being duly sworn, deposes and says:

That he is Manager, Nuclear Services, Texas Utilities Services Inc., and knows the contents of the foregoing Applicants' Answers to CASE's Seventh Set of Interrogatories; that the same is true of his own knowledge except as to matters therein stated on information and belief, and as to that, he believes them to be true.

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Homer C. Schmidt Subscribed and sworn to before me this ld. day of January 1982.

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Notary l

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r 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 and COMPANY, et al. ~

) 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 '

Answers to CASE's Seventh Set of Interrogatories ," 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 25th day of February, 1982:

Marsha.11 E. Miller, Esq. Chairman, Atomic Safety and Chairran, 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 Marjorie Ulman Rothschild, Esq.

Dr. Kenneth A. McCollom Office of the Executive Dean, Division of Engineering, Legal Director Architecture and Technology U.S. Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C. 20555 Dr. Richard Cole, Member David J. Preister, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548 Washington, D.C. 20555 Capitol Station Austin, Texas 78711 l Chairman, Atomic Safety and i Licensing Board Panel J. Marshall Gilmore, Esq.

U.S. Nuclear Regulatory 1060 W. Pipeline Road Commission Hurst, Texas 76053 Washington, D.C. 20555

Mr. Richard Fouke Mr. Chase R. Stephens 1669-B Carter Drive Docketing & Service Branch Arlington, Texas 76010 U.S. Nuclear Regulatory Commission

• Mrs. Juanita Ellis Washington, D.C. 20555 President, CASE 1426 South Polk Street Dallas, Texas 75224

• Overnight delivery b

William A. Horin cc: Eomer C. Schmidt Spencer C. Relyea, Esq.

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