ML20238A120
| ML20238A120 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/31/1987 |
| From: | Morell K HERON, BURCHETTE, RUCKERT & ROTHWELL, TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC. (FORMERLY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20238A063 | List: |
| References | |
| CPA, OL, NUDOCS 8709090140 | |
| Download: ML20238A120 (77) | |
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' UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION BEFORE TPE ATOMIC SAFETY AND LICENSING BOARD 87 AUS 31 P4 :02 tr; ..
00Ct! e , ;
In the Matter of )
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TEXAS UTILITIES ELECTRIC ) Dockets No. 50-445-OL COMPANY, et al. ) 50-446-OL
) 50-445-CPA (Comanche Peak Steam Electric )
Station, Units 1 and 2) )
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RESPONSE OF TEX-LA ELECTRIC COOPERATIVE -
OF TEXAS INC. TO THE MOTION OF !
BRAZOS ELECTRIC POWER COOPERATIVE, INC.
FOR DECLARATORY ORDER On August 14, 1987, Brazos Electric Power Cooperative, I Inc. ("Brazos"), a license applicant and minority owner of the Comanche Peak Steam Electric Station ("CPSES"), filed a motion before this Board seeking an order declaring either that (a) the Boston law firm of Ropes & Gray continue fully to represent Brazos in these proceedings, or (b) Ropes & Gray be permitted formally to withdraw from representation of Brazos. If Ropes &
Gray is allowed to withdraw, Brazos also seeks the right to obtain independent counsel in these proceedings without fear of retaliatory legal action by Texas Utilities Electric Company
("TU Electric"), the majority owner of CPSES.
Tex-La Electric Cooperative of Texas, Inc. (" Tex-La"),
another minority owner of CPSES, is appearing specially herein 8709090140 070031 PDR ADOCK 05000445 O PDR
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a through the undersigned counsel. Tex-La has been represented in these licensing proceedings by the attorneys responsible for prosecuting the operating license application on behalf of all the joint owner-applicants. With respect to this matter, however, neither TU Electric nor the lead licensing counsel, Rop 9s & Gray, have acceded to Tex-La's request that this response to Brazos' Motion be filed on behalf of Tex-La, thereby necessitating a special appearance by the undersigned counsel.
Tex-La supports Brazos! motion. The conduct of counsel for TU Electric has placed all of the minority owners in the horns of a dilemma. On the one hand, they fully recognize their independent responsibilities to this Board. On the other hand, they know that if they take action to meet those responsibilities in good faith, they risk legal action against them by TU Electric. For Tex-La, and perhaps other minority owners, the matter is now especially urgent because it believes that pending discovery requests filed by the interveners in this action require the production of documents which TU Electric has refused to produce either on grounds of ;
relevance or attorney-client privilege.
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Prior to'1987, both Ropes & Gray and its predecessor as lead licensing counsel, Worsham, Forsythe, Sampels &
Wooldridge, had represented all of the Comanche Peak applicants t l
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before this Board. ~ Sgg Brazos' Motion at 5-9.
minority owners successfully moved to di After the squalify Worsham, Forsythe in related litigation in Te xas State court,l/ Ropes &
Gray began taking the extraordinary sented only TU Electric and that the miy position that it repre-nority owners, by
} designating TU Electric as the proje pursuant to the Joint Ownership Agre:;2ect manager of. Coman waived their right to be represented i. nt for the project,had h counsel, either jointly with TU Electrin this proceeding by any present position of Ropes & Gray and TU Elc or independently. The that the minority owners are repre ectric appears to be Electric, with Ropes & Gray in tu sented at the NRC only by TU and assisting TU Electric in its reprern representing TU Electri owners, but with Ropes & Gray not itselfsentation of the minori y minority owners directly. representing the Gray, while in form appearing notOne effect Ropesof& this is that owners, performs many of the functionsto represent the minority substance (at times indirectly, through TUof their attorney in without apparently viewing itself b Electric), but fiduciary constraints that normallyound by the ethical and attorney-client relationship with the miwould attend a direct nority owners.
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Cooperative, Texas, Texas Electric v. Utilities Co Inc. et al.
District, Tex-La Electric Dallas County, Texas., No. 86-6809, A-14th Judicial
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o before this Board. See Brazos' Motion at 5-9. After the minority owners successfully moved to disqualify Worsham, Forsythe in related litigation in Texas State court,l/ Ropes &
Gray began taking the extraordinary position that it repre-sented only TU Electric and that the minority owners, by designating TU Electric as the project manager of. Comanche Peak pursuant to the Joint Ownership Agreement for the project, had waived their right to be represented in this proceeding by any counsel, either jointly with TU Electric or independently. The present position of Ropes & Gray and TU Electric appears to be that the minority owners are represented at the NRC only by TU Electric, with Ropes & Gray in turn representing TU Electric and assisting TU Electric in its representation of the minority owners, but with Ropes & Gray not itself representing the minority owners directly. One effect of this is that Ropes &
Gray, while in form appearing not to represent the minority owners, performs many of the functions of their attorney in substance (at times indirectly, through TU Electric), but without apparently viewing itself bound by the ethical and fiduciary constraints that normally would attend a direct attorney-client relationship with the minority owners.
1/ Texas Electric Utilities Co. v. Tex-La Electric foop'erative, Texas, Inc. et al., No. 8f-6809, A-14th Judicial District, Dallas County, Texas.
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u Unfortunately, TU Electric's view that the minority owners are essentially non-parties to this proceeding stands in sharp contrast to this Board's view of the matter. In its Memorandum and Order of May 4, 1987, this Board held that the minority owners have an obligation "to provide accurate, relevant, and complete information to both the staff of the Commissien and to this Board" wnich cannot be negated by contractual arrangement. Slip Op. at 4 (internal quotations omitted). The minority owners, the Board continued, were ,
independently " responsible for assuring the completeness of our factual record and the adequacy of factual responses to discovery" and they were obligated to transmit to the Board any differing views concerning factual matters, "without threat of legal action." Texas Utilities must not interfere with "the independent responsibility" of the minority owners to this Board. Slip op, at 4-5, As participants in this proceeding, Tex-La and the other minority owners obviousJy have the right to be represented by counsel -- be it Ropes & Gray, as in the past, or independent counsel of their choice if Ropes & Gray refu.ses to continue in that capacity. See 10 C.F.R. S 2.713(b). So long as both Ropes & Gray and TU Electric continue in their present posture, such representation is an impossibility. See Brazos' Motion at 12-16.
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4 For Tex-La, recent events now have sharply focused the issue. On June 19, 1987, the interveners submitted interroga-tories and document requests to Tex-La and the other minority owners. (Exhibit A) Significantly, Ropes & Gray, although
?nchewing any attor.ney-client relationship with Tex-La, accepted service of this document for Tex-La, and requested for Tex-La an extension of time within to file a response. On July 2, 1987, TU Electric requested Tex-La to gather informa-tion in connection with this response. (Exhibit B) On August 4, 1987, counsel for Tex-La submitted to Ropes & Gray Tex-La's proposed response to this discovery request which,
. among other things, identified five documents in Tex-La's possession which it believed to be responsive to intervenor's request. Tex-La also agreed to make additional responsive documents available to interveners should such additional o
documents be revealed during discovery. (Exhibit C)2/ On August li, 1987, Ropes & Gray rejected Tex-La's esponse and, two days later, filed a response on behalf of " applicants" in which it refused even to identify the dccuments brought to its attention by Tex-La. (Exhibits D and E.)
2/ The document referred to in Exhibit C as having been sub-mitted to Ropes & Gray as part of Tex-La's proposed response to interveners' discovery request has been deleted from this fil-l ing. Although that document was obtained by Tex-La from TU Electric during the cou'rse of document disecvery in the Texas state court litigation concerning the CPSES, TU Electric's litigation counsel subsequently informed Tex-La that the docu-ment had been inadvertently produced and requested its return.
TU Electric's claims of privilege for this anc other documents are currently pending before the Court of Appeals for the Fifth Supreme Judicial District of Texas at Dallas in Texas Utilities _ i Electric Company v. The Honorable John McClellan Marshall, l Cause No. 05-87-00887-CV, filed August 12, 1987. )
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19 Ropes & Gray's conduct has placed Tex-La in an untenable position. If Ropes & Gray is not Tex-La's licensing U '
. counsel but represents only TU Electric, Tex-La, if it finds .l itself in disagreement with Ropes & Gray's position on dis-covery,'cannot,_under this Board's May 4 order, simply accede to Ropes & Gray's and TU Electric's views on the matter and refuse to identify the documents in question. Yet, if Tex-La persists in meeting its independent obligations to this Board, it ris'ks. continued threats by counsel or TU Electric that its actions are somehov " impeding" the licensing process. Under these circumstances,'it is particularly appropriate for this .i Board to clarify the relationship between-Ropes & Gray and the minority owners, and either affirnt that an attorney-client relationship exists, with all attendant. fiduciary requirements, !
'ar parmit Tex-La and the other minority owners to act independently without fear of reprisal by TU Electric.
Respectfully submitted, William H. Burchette' '
Foster De Reitzes Karl Morell Heron, Burchette, Ruckett
& Rothwel1 ]
Suite 700 1025 Thomas Jefferson St., N.W.
Washington, D.C. 20007
(.202) 337-7700 Attorneys Appearing Specially for Tex-La Electric Cooperative of Texas, Inc. ,
Dated: August 31, 1987
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CERTIFICATE OF SERVICE e
I, Karl Morell, one of the attorneys making a special 1 appearance for Tex-La Electric Cooperative of Texas, Inc.,
hereby certify that on August 31, 1987, I made service of the withi~n Notice of Special Appearance and Response to Motion for Declaratory Order by mailing copies thereof, postage.prepa d,T'X
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to: /- p un AUG31737"[3I Peter B. Bloch, Esquire Mr. James E. Cummiris' S s /
Chairman Resident Inspector f" ,f Administrative Law Judge Comanche Peak S'.E.S. ,,g Atomic Safety and Licensing c/o U.S. Nuclear Regulato'ry>
t' Board Commission U.S. Nuclear Regulatory P. O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge GAP-Midwest Office 881 W. Outer Drive 104 E. Wisconsin Ave. - B Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 i Commission Washington, D.C. 20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P. O. Box 12548 U.S. Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C. 20555 l
g Anthony Roisman, Esquire Mr. Lanny A. Sinkin Suite 600 Christic Institute 1401 New York Avenue, N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp .
Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory
. Commission ,
Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Erquire Administrative Judge Office of the Executive !
Oak Ridge National Laboratory Legal Director '
P. O. Box X, Building 3500 U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C. 20555 i
Nancy H. Williams Robert A. Jablon f 2121'N. California Blvd. Spiegel & McDiarmid Suite 390 1350 New York Ave., N.W.
Walnut Creek, CA 94596 Suite 1100 Washington, D.C. 20005 l Mr. W. G. Counsil William W. Vernon Executive Vice President Blake Tartt Texas Utilities Generating Co. Fulbright & Jaworski {
Skyway Tower, 25th Floor 1301 McKinney Street i 400 N. Olive Street Houston, TX 77010 Dallas, Texas 75201 Mr. Thomas G. Dignan, Jr.
Ropes & Gray !
22S Franklin Street Boston, MA 02110 Karl More11 '
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UNITED STATES NUCLEAR REGULATORY COMMISSION ;
Before the Atomic Safety and Licensina Board .
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In the Matter of )
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TEXAS UTILITIE$ ELECTRIC COMPANY, ) Dkt. No. 50-445-CPA-et_al..', 1
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(Ccmanche Peak Steam Electric Station )
Unit 7.) )
CONSOLIDATED INTERVENERS' INTERROGATORIES AND REQUEST FOR PRODUCTION'OF DOCUMENTS TO APPLICANT TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC. (6/19/97L Instructions and Definitions Please respond to the.following interrogatories and requests.
for procuction of documents within the time limits specified by the NRC regulations and pursuant to the requirements of those regulations.
For purposes of this document, the following definitions and guidelines for clarifying answers are upplicable:
"Act Applicant" means any of ths owners of Comanche Peak Steam Electric Station and seeks information about the Applicant answering the question and the other Applicants to the extent the Applicant answering the question has any relevant information l
about other Applicants. Each Applicant should provide a separate answer as to documents requested and as to any written answer.
If an answer is piovided by TUEC on behalf of any other Applicant and that answer does not fully reflect the information or opinions possessed by the other Applicant, that Applicant should
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(-) 0v provide a. supplemental answer within ten days of the filing of l l
TUEC's answer.
1 Whenever reference is made to a phrase in quotation marks, the Applicant answering should indicate what it is assuming the phrase means in ansuuring the question. Disagreeing with a part or all of'the phrase should not preclude providing an answer based on any part of the phrase the answering Applicant finds acceptable. i Kpterrocatories:
Consolidated Interveners have alleged (Amended Contention 2) that:
The delay in construction of Unit 1 was caused by Applicants' intentional conduct,
. which had no valid purpose and was the result of ccrporate policies which have not been discarded or repudiated by Applicants.
- 1. With regard to that allegation, please specify all ins inces of any Applicant's " intentional conduct" of which you are aware that would support the allegation.
- a. Identify all person (s) who engaged in this intentional c*nduct.
- b. Specify the date(s) the conduct took place.
- c. Expikin precisely how the conduct caused a delay in construction of Unit 1.
i d. Cite all documents that support your answers to l 1.a., b., and c. above.
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2.c What do you know that will shed light on the' purpose of
- Applicant's " intentional conduct?"
'a. State all facts'of which you'are aware that illustrate that there was no valid purpose for such conduct.
- b. Idantify all persons who have knowledge of the facts described in your answer to.2.a. l 3.- List all the. policies of which you are'awkre that i I
caused or contributed to delny in. completion of construction of
' Unit 1. With respect to each policy,
- a. Identify the person (s) who formulated or q promulgated each policy.
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.b. Specify, with as much precision as possible the date(s) upon which policy was formulated or promulgated.
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- c. Specify when each policy was fir.st implemented. ,
1 d, How was each policy implemented?
- 4. Identify each of the person (s) who are or ware at 1 supervisory level or above at the plant for any Applicant, contractor,-subcontractor, or consultant after February 1985 who is/are listed'in the answer to Interrogatory 3 above, and list all positions held by such person (s), by whom he/she was employed, and the dates of such employment since February 1985.
- 5. Identify any action taken or not taken by any Applicant that'is relevant to determining whether any of the policies referred to in the answer to Interrogatory 3 have been discarded and repudiated. For each action or non-action identified,
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Q)' U a.. Identify the person (s) who took or failed to take the action. !
- b. State when the action or non-action occurred.
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- c. Cite all documents that make reference to the action (s) or non-action (s).
- 6. Describe each and every instence af which you ara aware
'in,which any Applicant has refused to take positive action to-reform the Unit 1 QA/QC program. For each instance,
- a. Defins precisely the positive action that was refused.
- b. Identify the person (s) who deliberately refused to take positive action.
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- c. Identify the date on which the deliberate refusal took place.
- d. Describe the manner in which the refusal was made j manifest.
- e. Cite all documents that refer or relate to the refusal.
- 7. Describe all criticism (s) of the Unit 1 QA/QC program of which you are aware, including the QA/QC program of all contractors, subcontractors, consultants, and vendors. For each criticism, l
- a. Sta'te the source of the criticism. I
- b. Indicate the date(s) the criticism was made.
- c. State whether and how the criticism was communicated to each Applicant. 1
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- 4. Identify the person (s) to which the criticism was !
i communicated.
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- e. State the date(s) on which the criticism was
[~ communicated to each Applicant.
- f. Cite all documents that indicate the existence of the criticism and all documents that indicate that the criticism l
was communicated to each Appligant. j i
- 8. List every instance of which you are aware where ahy Applicant has failed to correctly apply fundamental engineering principles. For each such instance, I
- a. Specify which fundamental engineering principle '
was not correctly applied.
- b. State the source (s) from which the engineering principle in question is derived.
- c. Identify the person (s) who failed to apply the principle correctly and the date on which the incident c4: curred.
- d. Cite all documents which document or support your description of the instance.
- 9. List each design not typical for nuclear plants than seeking or already having received construction permits that any Applicant failed to properly identify in the PSAR. For each of i i
these " unique designs," explain the basis for your conclusion that it was/is nht typical.
- 10. List every aspect of the plant of which you are aware that was constructed before its design wa.s ecmpleted. For each aspect, state any principle or requirement of which you are aware l
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which dictates or. dictated any different sequence of design and-construction from'that employed.
- 11. List every section of 10 CFR Part 50, Appendices A and B, that any Applicant has not contplied with. For each section cited, ac Explain the precise manner in which the Applicant
' failed to corply with the specified section. i
- b. State the date(s) on which the failure to comply took place. !
- c. Identify the person (s) who failed to comply.
- d. Cite all documents that document or support the conclusion that the Applicant failed to comply with the specified section. .
- 12. List every instance of which you are aware where any Applicant failed to promptly identify design deficiencies. 1
- 13. List every instance of which you are aware where any )
Applicant failed to correct design deficiencies. j l
- 14. List every instance of which you are aware where any l Applicant deliberately' refused to take positive action to correct deficiencies in design, construction, or QA/QC procedures or-implementation.
- 15. List all criticisms of the Unit 1 QA/QC program (including the QA/QC program of any contractors, subcontractors, l
consultants, and vendors) of which you are aware that have not i been thoroughly ev&luated in a timely manner and/or for which I
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Applicant. for each of these criticisms, l l l l a. Identify the source of the criticirm. j i
, b. Identify the date the criticism was made.
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- c. Describe when and how the criticism was 1 \
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- d. Cite all documents which support the existence of I
.the criticism and all documents indicating that the criticism was roported to the Applicant.
- e. Describe and explain the basis for your conclusion that the criticism was not thoroughly evaluated in a timely manner and/or that corrective actions were not timely taken,
- f. Was the action or inaction described in 15.e.
deliberate? If so, state any reason for such deliberate action or'ine: tion of which you are aware, and identify the person (s) who took or refused to take the action.
- 16. Identify al2 criticisms of the design of Unit 1 of which you are aware that have not been thoroughly evaluated in a timely manner and/or for which appropriate corrective actions were not timely taken by any Applicant. For each such criticism,
- a. Identify the source of the criticism.
- b. Identify the date the criticism was made,
- c. Describe when and how the criticism was communicated to the Applicant.
- d. Cite all documents whi.ch support the existence of
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the. criticism and all documents indicating that the criticism was reported to the Applicant.
- e. Describe and explain the basis for your conclusion that.the criticism was not thoroughly evaluated in a timely manner and/or that corrective actions were not timely taken.
- f. Was the action or inaction described in 16.e.
deliberate? If so, state any reason for cuch deliberate action or inaction of which you are aware, and identify the person (s) who took or refused to take the action.
- 17. List every warning cf which you are aware by independent auditors of the existence 6f policies or practices at Unit 1 which were not in compliance with NRC requirements or accepted practice.
- 18. List every warning you are aware by the NRC of the exiatence of policies cr practices at Unit 1 which were not in compliance with NRC requirements or accepted practice.
- 19. List every warning of which you are aware by the Atomic Safety and Licensing Board of the eylstence of policies or prautices at Unit I which were not in compliance ~with NRC requirements or accepted practice.
- 20. List every instance of which y.ou are aware where any Applicant. in the face of any warning listed in answer to Interrogatories 17'-19 above , refused to make the appropriate and/or recommended changes. Fo.i sach such instance,
- a. Identify the person (s) who refused to make the change.
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- b. State the date of the refusal.
c.- Cite all documents that refer or' relate to the- )
refusal.
- 21. List every instance of which you are aware where any Applicant has refused to address and correct design deficiencies.
For each such instance,
- a. Identify the person (s) who refused to make the correction.
- b. State the date of the refusal
- c. Cite all documents that refer or relate to the refusal.
- 22. List all the deficient conditions at Unit 1 of which
.you are aware that were not detected until after June 1984.
- 23. List all.the original judgments made by any Applicant of which you are aware that allowed deficient conditions at Unit 1 to exist and continue, and identify the person (s) who made each such judgment.
- 24. Identify each and every CPRT judgment on the safety significance of a deficiency (as defined in the CPRT PrograA L Plan) that was made by TUEC personnel.
- 25. Identify each and every CPRT judgment on the safety significance of a deviation (as defined in the CPRT Program Plan) that was made by TUEC personnel.
- 26. Identify which CPRT reinspection are being conducted without complying with Appendix B.
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- 27. Do you believe that any of these CPRT reinspection are required to comply with Appendix B and, if so, which ones? If i
not, why not? In what way do these reinspection fail to comply with Appendix B7
- 28. State each and every way in which CPRT reinspection are impossible of trending. j I
- 29. State each and Overy way in which CPRT reinspection !
are impossible of documentation.
- 30. State each and every way in which CPRT reinspection are impossible of verification.
- 31. a. How many individuals who are currently or were formerly employed by Stone & Webster during the period June 1986 through the present were former employees of NPS Industries, ITT, Grinnell, Texas Utilities Electric Company or one of its affiliated companies, Gibbs and Hill, or any other of the Applicants or their agents, and worked at any time previously on the Comanche Peak project (either onsite or offsite)?
- b. Provide a list of all such individuals, along with details of the dates they originally worked for the companies in question, the dates they were hired by Stone & Webster for their assignment to work on Comanche Peak, their current job title and status, and, if they are no longer employed at Comanche Peak, their last known address and telephone number.
- 32. a. How many individuals who are currently or were employed by Applicants or any of their consultants, contractors, subcontractors, or any other companies working on reinspection /
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l reanalysis effort and/or the corrective. actions resulting from such effort, during the period August 1985 through the present, I
were former efsployees of NPS Industries, ITT, Grinnell, Texas Utilities Electric Company or one of its affiliated companies, Gibbs and Hill, or any ot.her of the Applicants or their agents, and worked at any time previously on the Comanche Peak project I
(either onsite or offsite)?
- b. Provide a list of all such individuals, along with l
details of the dates they originally worked for the companies in question, the dates they were hired for their assignment to work )
on Ccmanche Peak, by whom they were hired, their current job title and status, and, if they are no longer employed at Comanche Peak, their last known address and telephone number.
Document Request Please provide, in Washington, D.C., or Dallas, Texas, the original of every document in your possession, or in the possession of any consultant, contractor, or subcontractor to you or your attorney (s), on which you relied or which you examined in preparing answers to these Interrogatories.
Respectfully submitted,
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4 ANTHONY Z. RC/ ISM N ' ,
1401 New pk Av nue, NW Juite 60 Washington,/'D.C. 20005 j (202) 628-3500 Counsel for Meddie Gregory
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@ President ,CASE )
1426 South Polk ,
Dallas, TX 75224 (214) 946-9446 )
Representative for CASE Date: June'19, 1987 l
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UNITED STATES NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of )
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TEXAS UTILITIES ELECTRIC COMPANY, ) Dkt. No. 50-445-CPA et al., )
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(Comanche Peak Steam Electric Station )
Unit 1) )
CT,RTIFICATE OF SERVICE I hereby certify that CONSOLIDATED INTERVENERS' INTERROGATORIES AND REQUEST FOR RODUCTION OF DOCUMENTS TO APPLICANT TEXAS UTILITIES ELECTRIC COMPANY (6/19/87); [same] TO APPLICANT BRAZOS ELECTRIC POWER COOPERATIVE; [same] TO APPLICANT TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC.; and (same] TO APPLICANT TEXAS MUNICIPAL POWER AUTHORITY were served today, June 19, 1987, upon the following by first class mail, postage prepaid, or by hand where marked with an asterisk (*), or by Federal Express where marked by two asterisks (=*).
Peter B. Bloch Administrative Judge U.S. Nuclear Regulatory Commission Washington, D.C. 20S55
- Dr. Kenneth A. McColloin 1107 West Knapp Stillwater, OK 74075 Dr. Walter H. Jor' dan 881 West Outer Drive Oak Ridge, TN 37830 Elizabeth B. Johnson Oak Ridge National Laboratory P.O. Box, Building 3500 Oak Ridge, TN 37830
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l U d Docketing and Service Section I Office'of the Secretary l
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U.S.-Nuclear Regulatory Commission Washington, D.,C. 20555 1
Geary S.'Mizuno, Esq.
Office of Executive. Legal Director U.S.-Nuclear Regulatory Commission '
Washington, D.C. 20555 Thomas G. Dignan, Jr.
Ropes & Gray 225 Franklin Street Boston, MA 02110 Juanita Ellis, President Citizens Association'for I Sound Energy 1426 South Polk Dallas, TX 75224 Billie P. Garde Government Accountability Project - Midwest Office 3424 North Marcos Lane Appleton, WI 54911 William Burchette Foster DeReitzes Heron, Burchette, Ruckert & Rothwell 1025 Jefferson Street, NW Suite 700 Washington, DC 20007 Robert A. Jablon Spiegel & McDiarmid 1350 New York Ave., NW Suite 1100 Washington, DC 20005 1 William W. Vernon Blake Tartt' Fulbright & Jaworski 1301 McKinney Street Houston, TX 77010
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EXHIBIT B o ;
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= = I TUELECTRIC a w. m July 2, 1987 Mr. E. L. Wagoner Texas. Municipal Power Agency P. O. Bcx 7000 Bryan, Texas 77805 Mr. R. E. McCaskill Brazos Electric Power Cooperative, Inc.
P. O. Box 2585 Waco, Texas 78702-2585 Mr. J. H. Butts Tex-La Electric Cooperative Of Texas, Inc.
P. O. Box 1623.
Nacogdoches, Texas 75961 RE: Texas Utilities Electric Company, et al.
(Comanche Peak Steam Electric Station, Unit 1)
NRC Docket No. 50-445-CPA Gentler.en:
You are by now presumably all aware that the Interveners in the above-captioned proceedings have propounded interrogatories to each of the Owners of CPSES and have purported to serve them upon each Owner individually. Inasmuch as they also served the same Interrogatories upon TU Electric, however, the apparent procedural errors in the Interveners-methodology would seem to be irrelevant.
TU Electric has requested that its counsel, Messrs. Ropes &
Gray, obtain an extension from the Interveners of the time required to respond to these interrogatories, Based upon preliminary con'versations , it is anticipated that such an extension will be granted.
t It is of course imperative that this additional time be used
}' profitably in order that Applicants' obligations under the NRC's Rules of Practice can be met. We therefore request that you begin immediately collecting and collating all information in
_~-m mm _m m __ o
.. your possession responsive to the Interrogatories. While we would expectthe
-coordinating shortly 'to announce our plans for receiving and transmission of that information, we would appreciate which may being advised promptly of any extraordinary problems have the effect of delaying your ability to present the information newly established. to us in sufficient time to meet the deadlines problems, please In the' event that you identify any such estimate of how long it in include your reports thereof a specific will take to have' the information available.
You may also be interested that TU Electric has asked its i attorneys to analyze the interrogatories and advise j it of possible objections or possible general ritles of interpretation which may -af fect the scope of the responses which have to be made to . the Interveners' requests. To the extent that their advice seems to picoduce any possible modifications in the Owners' obligations, we would expect to share the products of that advice with yott promptly.
ment of any individually-ba~ sed The identification and advance-objections, of course, remain your own obligation.
Very truly yours, g 4 ).1 2-hn W. Beck JWB:OT
/
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.- EXHIBIT C Hemn, Burchette, Ruckert&Rothwell 3 Suite 700 s== nso l 1025 'Ihomas Jefferson Street, N.W.
- Washingtor D.C. 20007
[Q cz ,3,,,
(916 % i42: l l
(202) 337-7700 gw$'3,3 '* 7 *"
j TWX 710-822 9270 Amm. TX 78701 i
($12) d99M l August 4, 1987 1
By Telecopier Mr. William'Eggeling Ropes & Gray 225 Franklin Street J Boston, Massachusetts 02110 i Re: In the Matter of TEXAS UTILITIES 4 ELECTRIC COMPANY, et al , ('omanche C Peak Steam, Electric Station, Unit 1),
NRC Docket No. 50-445-CPA
Dear Bill:
As General Counsel for Tex-La Electric Cooperative of Texas, Inc. (" Tex-La"), we have been asked by Mr. John Butts, Manager of Tex-La, to respond to the CASE interrogatories of June 19, 1987. Pursuant to the request of TU Electric, Tex-La's answers are being provided prior to the August-7, ;
response deadline so they can be integrated with the responses l of the other co-owners of the plant. Tex-La's answers are provided as an attachment to this letter. We are also enclosing a copy of one of five documents referred to in the answers. The remaining four documents are being expressed to you today from GDS Associates, Tex-La's engineering consultants. We will look to you to furnish t; hem to TU Electric as you deem appropriate. 1 Should you have any questions or comments regarding the. enclosed, please do not hesitate to contact us.
Very truly yours,
., )hl L"/ / k' l Foster De Reitzes I
i
.
- j i
4-RESPONSE OF TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC.
TO CONSOLIDATED INTERVENERS' INTERROGATORIES AND ]
, REQUEST FOR PRODUCTION OF DOCUMENTS (6/19/87) l
}
Interrogatories 1-23.
Except to the extent noted below, applicant Tex-La presently is not aware of any action or inaction by
~
any of the applicants, policies or judgments made by any of the applicants, or criticisms made of any of j c tbe applicants otner than those already identified by ]
the staff of the Nuclear Regulatory Commission ]
("NRC"), tne project manager, independent consultants selected by the project manager and retained by ]
1 applicants, former TU Electric employees, or the )
consolidated interveners themselves, which already are l matters of public record. Applicant Tex-La became aware of such instances at the time they were made public or thereafter. To list here all such instances in tne public record would require a search of tne entire operating license and construction permit dockets, a review of all hearing and deposition transcripts in tnose dockets, and weeks of compilation of this material. Accordingly, such interrogatories are overly burdensome. In addition, in light of the public nature of this information, the information would"be repetitive of knowledge already in the -
possession of interveners and the NRC. Tex-La objects .
to these interrogatories on these grounds.
To date applicant Tex-La has identified five documents that may be responsive to certain of the interrogatories and may have safety significance and I wnich, Tex-La believes are not currently a matter of )
puolic record. .Given the possible safety significance of the documents, applicant Tex-La believes it has an 3 '
independent obligation to turn these documents over to the NRC. However, as to one of these documents, TU I
Electric, in a July 7, 1987 letter to Brogos Electric Power Cooperative, Inc., threatened to sue Bragos it carries out its obligation to furnish this document to the NRC. Applicant Tex-La assumes that this threat would apply to it as well, and may apply also to other documents that Tex-La may believe itself obligated to I reveal to the NHC but which TU Electric may believe j need not be so revealed. Accordingly, Tex-La at this time has furnished the five identified documents to ;
i 1
i.
t1 Ropes n Gray. Such documents mayfbeifurnished to the NRC.by TU Electric. Alternatively,, Tex-La is prepared to furnish;such documents to the NRC, and to :
interveners, upon the withdrawal'by TU Electric of any j
' threat of litigation against Tex-La for so' revealing the' documents. i "
. Applicant Tex-La' presently is engaged in an extensive.
discovery effort of TU Electric documents in connection with Tex-La's Texas State Court-litigation against TU Electric. To:the extent-any additional non-public information responsive.to'these interrogatories is obtained in the course of such discovery (whether from documents or other information
.yet to be provided-by TU' Electric or from documents-or other information already provided by TU Electric but-not yet compiled and analyzed by Tex-La), Tex-La will provide such responsive information to consolidated interveners, provided: that. (a) .any such. information which is privileged in the Texas State Court litigation be provided to interveners pursuant to a protective order comparable to the protective order issued by the Atomic Safety and Licensing Board on March 12, 1987, and (b)' Tex-La'is not subjected to any threats.of. litigation from:TU Electric'for providing any such information.
Interrogatories 24-32 Applicant Tex-La, as a minority owner, is not responsible for CPRT judgments, reinspection, or the hiring of TU Electric or contractor personnel for the project.- These functions are the responsibility of the project manager. Applicant Tex-La has no knowledge of the subject matter of these i interrogatories and, accordingly, they are most appropriately answered by' applicant TU Electric.
l
. ~ _ - _ - _ - - . ._
EXHIBIT D
..U AUG 12 '87 17:26 ROPES GR/617-350-5051 PAGE.02 4
ROPES & GRAY 225 FRANKLIN $TREET DOSTON, MASSACHUSETTS o2llo IN Fn0VIDENCC IN WA&NINGTQN ftLEX NUhpCR 940519 ROPORALOR 85N 8001 TwCNf t-SECON D STREET, N W 33 RENNEDY PLAZA WA S H t h 0TO N, 0. C. 2 0 0 37 R4VIDENCEs H.L Of 903 TELEX NUptER 951973 ROPES CRAY SSN (202) 439-6600 *
{#Cl) 524-6400 TEkCCCPitRS: (617) 423 2377 . (stF) 423 784:
YELECOPIER:(401) 636-09:0 inttRNATIONAC($17) d23 6905 f ulf COPeCR'(202) 4891829 August 12, 1987 i
Foster De Reitzes, Esquire Heron, Burchette, Ruckert & Rothwell Suite 700 ,
1025 Thomas Jefferson Street, N.W.
Washington, D.C. 20007 Re: In the Matter of Texas Utilities Electric Company, et al., (Comanche Peak Steam Electric Station, Unit 11 NRC Docket No. 50-445-CPA _
Dear Foster We have been instructed by our client TU Electric to advise you that it has now completed its review' of the letter from Messrs. Heron, Burchetto, Ruckert & Rothwell dated August 4, 1987. and its enclosure -- which we understand to comprise Tex-La's proposed answers and objections to the Consolidated Interveners' (6/19/87) Interrogatories and Requests for Production of Documents. Upon consideration, the Project Manager has concluded that it will not be possible for it to submit these responses in the form proposed by Tex-La.
Tex-La's proposed response has been understood to be comprised of four logically severable elements. The first of these is Tex-La's report that it has no factual information responsive to the Interrogatories which is not already a matter of the public record in this case. The second is an assertion that any obligation to identify or list aspects of this record which may be responsive to the Interrogatories would be sufficiently burdensome as to transgress Tex-La's putative rights. With respect to th.s second element, Tex-La proposes that the interrogatories be objected to generally.
The third element is a collection of five documents which i Tex-La identifies as ones which" "may be responsive to certain ;
of the interrogatories . . . . The fourth element is Tex-La's proposal to offer to provide information to the interrogatorica in the future as Tex-La ray encounter it in connection with its efforts in the Texas state court litigation.
I
____________-__a
l AUG 12 '87 17:27 ROPES GR/617-350-5051 PAGE.03 ropes & GRAY Foster De Reitzes, Esquire August 12, 1987 The first element -- Tex-La's report of no responsive factual information -- is of course an input to TU Electric's responses on behalf of the Applicants inasmuch as it confirms that the information thu Project Manager has been able to gather through other means is indeed reflective of the universe of information currently available in response to the Intervonors' questions. This helps confirm that TU Electric has met its responsibility under 10 CFR 2.740bta),
("a party . . . shall furnish such information as is available to the party"). There is no requirement that the individual sources of such information, or lack of information, be identified howsver, so a Minority owner's negative report need not be specifically called out in the Applicants' responses.
None of the three remaining elements are believed to be properly includable in the response to be surmitted by the TU Electric on behalf of the Applicants. With regard to the second element, as we have explained previously, we can advance only such objections to discovery as: (1) are proper general challenges to improper interrogation (viz.
essentially objections to the question); (2) inay otherwise be legitimate and appropriate for all the Applic' ants; or (3) may present grounds for raising objections personal to the Project Manager in either its individual or representative capacities. Tex-La's proposed objections meet none of these criteria. Therefore, as before, Tex-La will have to advance such objection itself through Tex-La's attorneys. With regard to the third element in Tex-La's submission -- the five documents -- TU Electric'has concluded that they are not properly responsive to any of the Interrogatories or the concomitant Requests for Production. As we understand you know, moreover, TU Electric believes one of thoso documents ,
is protectod by the attorney / client privilege, and it has instructed us that it does not wish to waive its rights to such protection. Finally, with regard to Tex-La's offer to make information available in the future, our experience has l satisfied us that such undertakings are both gratuitous and j necessarily fraught with difficulties which make them !
extremely difficult to administer. They are moreover j i distinctly beyond the limitations placed upon the proper !
l imposition of unilateral discovery burdens by the Rules of !
l practice. Egg 10 CFR 2.740(e). Inasmuch as it is believed l 1
l t
)
______________.___.__U
o mes ss "er avsse meras eus37e menssas exes.se
.- Rc pto & G RAY Poster De Reitzes, Esquire August 12, 1987 )
that such an undertaking creates a significant potential for interfering with the efficient completion of the licensing effort, we will therefore not propose it.
Very truly yourg, 4 -f .
William S. Eggel g WSE/Ima Advance Copy Via Telecopier
.i
_ _ _ - _ _ _ _ _ _ - . _ _ - - - - _ - - . -_------a
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,' BOSTON, MASSACHUSETTS O2110 (6171 423 610 0 ,,,,,,,,,,3
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8001 TWC Niv 5ECOND ST ACET, at w
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August 14, 1987' -1 l.
iffice.of the. Secretary.
U.S. Nuclear Regulatory Commission i Washington,.D.C. 20555 ATTENTION: Docketing and Service Branch
.Re: Texas Utilities Electric Company et al.
Docket No.'50-445-CPA
Dear. Sir:
Pursuant-to the Commission's Rules and Regulations,
, .there is enclosed herewith for filing in the above-entitled matter one signed and two conformed copies'of " Applicants'
. Response to Consolidated Intervanors' ( 6/19/ 87 ) '
, : Interrogatories and Request for Documents" with certificate of Service attached.
Very t uly yours
--'l . i ;
William S. Eggel* ]
WSE/plw !
Enclosures ,
I cc: Certificate of Service 1
t
. - Filed: August 14, 1987 UNITED STATES OF AMERICA {
NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
~
) 5 In the Matter of )
)
TEXAS UTILITIES ELECTRIC COMPANY, ) Docket No. 50-44S-CPA et al, )
)
(Comanche Peak Steam Electric )
Station Unit 1) )
)
RESPONSES 1 TO CONSOLIDATED INTERVENERS'(6/19/87)
INTERROGATORIES AND REOUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 CFR 2.740b(b), the Applicants 2 hereby 1
These responses are timely by virtue of extensions of time agreed upon between counsel and representatives for the parties and the Board's previously announced acceptance of such consensual restructuring of discovery schedules.
2 TU Electric, as Project Han&ger, has canvassed its own records and corporate knowledge in order to respond to the Interveners' interrogatories. It has as well inquired of each of the Minority owners, seeking from them any factual information they may have that should be considered by the Project Manager Jn preparing the Applicants' responses to these interrogatories. The Minority Owners have responded in various ways, ranging from prolix' proposals (or demands) for the advancement of specific substantive answers and objections, to prefunctory " instructions" that TU Electric object to the interrogatories in their entirety.
After analysis of and reflection upon the Minority Owners' submissions, TU Electric has concluded it is unable to advance or sponsor the submission of their proposed answers and objections. Its inability to do so is based upon the combined effect of several factors including: that it does not have sufficient belief in the truth of the factual matters asserted therein to conclude that the proposed answers are properly responsive to the questions (gf Fed. R.
Civ. P. 11); and, that it lacks sufficient information necessary to satisfy itself and its attorneys that the l
L__ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
%e
- respond to the Interrogatories and Request for Production of l
. Documents dated June 19, 1987. 't GENERAL OBJECTIONS The Applicahta have disregarded the instructions )
i contained in the " Instructions and Definitions" to the extent i I
that same are inconsistent with the Rules of Practice.
With respect to interrogatories or requests for production which would implicate or require disclosure of i
work done or being done by the Comanche Peak Response Team objections sought to be advanced are valid and meritorious.
These obstacles to accepting for submission the Minority owners' proposed inputs have'been compounded by TU Electric's conclusion that many of the proposed answers appear ,
unresponsive to the questions actually asked (and irrelevant to the sole admitted contention in this proceeding). This leads to the conclusion that the Minority owners' position is for a purpose other than to fulfill their ooligation to make complete and truthful discovery imposed by the Rules of Practice.
The Minority owners have been advised of TU Electric's decision and told that if they have a legitimate basis for submitting information, allegations or claims in response to the Interveners' interrogatories, they are obliged to do so themselves -- through their own counsel and in papers signed by their own representatives in accordance with the Rules of Practice.
It is TU Electric's general understanding -- based upon the Minority Owners' responses to its questions -- that the Minority Owners profess to have no factual information rega-ding any causes for delay in the construction of Unit 1 of CPSES other than that which is also already pcssessed by the Project Manager -- with the possible exception of some opinions being developed by their experts in the Texas state court litigation between the owners and claimed by them to be privileged from disclosure and further stated by them to be limited in basis to the factual material available from public sources and plant records and personnel. Inasmuch as all that material was drawn upon for the answers prepared by TU Electric, it is thus currently believed that the answers he~ rain are properly derived from the entire universe of
' historical factual knowledge responsive to the Interrogatories.
-2 -
I
-___-__ ._. _ \
I
("CPRT"), the Applicants object to producing any such 1 l
information or documents which are the subject of work which i is not yet complete but remains "in process." With respect l
to work which is the subject of a completed and published Results Report, the documents responsive to the Yntervenors' discovery requests will be made available ira accordance with the previous arrangements for inspections of the CPRT Central Files..
INTERROGATORIES QRRa. tion No. 1:
Consolidated Interveners have alleged (Amended Contention 2) that:
The delay in construction of Unit 1 was caused by Applicants' intentional conduct, which had no valid purpose and was the result of corporate policies which'have not been discarded or repudiated by Applicants.
With regard to that allegation, please specify all instances of any Applicant's " intentional conduct" of which you are aware that would support the allegation.
- a. Identify all person (s) who engaged it, this .
intentional conduct. {
I
- b. Specify the date(s) the . : :t too) place. l I
- c. Explain precisely how the conduct caused a j delay in construction of Unit 1. {
l
- d. Cite all documents that support your answers to l 1.a., b,. , and c. above. J i
Resoonse:
Applicants are not aware of any instance of intentional 4
conduct which would support the quoted allegation.
-3 -
f
_ _ _ _ _ _ _ _ l
'd
. Qggstion-No. 2:
What do you know that will shed light on the purpose of Applicant's " intentional conduct"?
- a. State all facts of which you are aware that illustrate that there was no valid purpose for such conduct.
- b. Identify all persons who have knowledge of the facts described in your answer to 2.a.
Resconse:
Not Applicable.
Question No. 3:
List all the policies of which you are aware that causea or contributed to delay in completion of construction of i Unit 1. With respect to each policy, j
- a. Identify the person (s) who formulated or promulgated each policy.
- b. Specify, with as nach precision as possible the date(s) upon which policy was formulated or promulgated.
- c. Specify when each policy was first implemented.
l
- d. How was each policy implemented?
Obiection:
Applicants object to Interrogatory No. 3 to the extent, if any, that it seeks information concerning any policies other than those approved by the Applicants for governance of design and/or construction of Unit 1, on the ground that any ,
other policies are' irrelevant to the scope of Interveners' sole admitted contention and that as ' phrased said Interrogatory is overbroad, unduly burdensome and oppressive
-4 -
R' -
(:
4- and not reasonably calculated to lead'to the discovery o'f admissible evidence.
L Resoonse:
Without waiving the forsgoing objection, but on'the .
' contrary expressly preserving and relying upon the same, Applicants are not aware of any such policies.
l ouestion No. 4:
l-Idcetify each of the person (s) who are or were at supervisory level or above at the plant for any
, Applicant, contractor, subcontractor, or consultant l after February, 1985 who is/are listed in the answer to Interrogatory 3 above, and list all positions held by such person (s), by whom he/she was employed, and the dates of such employment since February, 1985.
Resconse:
Not Applicable,.
Question No. 5:
Identify any action taken or not taken by any Applicant that.is relevant to determining whether any of the policies referred to in the answer to Interrogatory 3 have been discarded.and repudiated. For each action or non-action identified,
- a. Identify the person (s) who took or failed to take the action.
- b. State when the action or non-action occurred.
- c. Cite all documents that make reference to the action (s) or non-action (s).
I Resoonse:
Not Applicable.
1 Question No. 6:
1' i Describe each and every instance of which you are aware in which any Applicant has refused to take positive action to reform the Unit 1 QA/QC program. For each i i instance, 1 ,
.?'
p..
l , a. Define precisely the positive action that was refused.
b.- Identify the person (s) who deliberately refitsed to take positive action. l
- c. Identify the date on which the deliberate refusal took place.
- d. Describe the manner in~which the refusal was made manifest.
- n. -Cite all documents that refer or relate to the refusal.
Resoonse:
Applicants are aware of no instance where they " refused" to take positive action when it was determined that such action was warranted to correct a valid deficient condition.
To Ehe extent that CPRT may evaluate the adequacy of modifications to the CFSES QA/QC program, the results are or-will be contained in the CPRT Central File upon publication of the relevant results reports. ,
i
- a. Not Applicable.
- b. Not Applicable. )
l
- c. Not Applicable. I
- d. Not Applicable. 1 I
- e. Not Applicable. )
1 Ouestion No. 7: l 1
Describe all criticism (s) of the Unit 1 QA/QC program of !
which you are aware, including the QA/QC program of all contractors, subcontractors, consultants, and vendors.
For each criticism,
- a. State the source of the criticism, i
s, b.- Indicate the date(s) the criticism was made.
l
- c. State whether and how the criticism was communicated to each Applicant.
.d. Identify the person (s) to which the criticism was communicated.
- e. State the date(s) on which the criticism was communicated to each Applicsnt.
- f. Cite all documents that indicate the existence of the criticion'and all documents that indicate that the criticism was communicated to each Applicant.
Obiection:
Applicants object to Interrogatory No. 7 on the ground that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.
ResDonse:
Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond that no specific listing or compilation of :
such criticisms has been prepared. Applicants will, however, produce for ir: pection by Interveners written assessments of aspects of the 'in2t i JA/QC program, some of which may contain programmatic criticisms such as are requested by this interrogatory. These documents (which are listed 'on Attachment A) may also include instances of specific deficiencies /nonconformances which are not considered programinatic criticisms.
-7 -
..,=-
45 -Question No. 8:- ,
4 cList every instance ~of:which you are aware.where any
~ Applicant has', failed to correctly apply' fundamental engineering principles. For each such instance,
- a. Spec.ify which fundamental' engineering principle
- was not' correctly applied.
- b. State'the source (s) from which the engineering principle in question is derived.
c... Identify.the person (s) who failed to apply the.
principle correctly and the date on which the incident occurred.
- d. Cite all documents which document or support your description of the instance.
9.hiestinn:
Applicants object to Interrogatory No. B on the ground that the phrase " fundamental engineering principles" is vague and ambiguous.
Resoonse:
Without waiving.the' foregoing objection, but on the contrary expressly preserving and relying upon the same, and on the assumption that " fundamental engineering principles" (
refers to the basic laus of Engineering such as F=ma, 8=mc 2, Newton's Iaws, etc., Applicants are aware of none.
Question Ng1_g:
l- List each design not typical for nuclear plants then seeking or already having received construction permits that any Applicant failed to properly identify in the PSAR. For each of these " unique designs," explain the basis for your conclusion that it was/is not typical.
Resoonse:
None.
2-____-______--
' '[ .
- Ouestion No. 10:
List every aspect of the plant of which you are aware that was constructed before its design was completed.
For each. aspect, state any principle or requirement of which you are aware which dictates or dictated any different sequence of design and construction from that employ'ed.
Response
None. For the construction process to begin and proceed, aspects of the design must be complete. This does not mean that every aspect of the entire plant design is i
complete at the beginning of construction. Construction is initiated utilizing completed drawings which have been approved and issued for construction. During the construction process, including subsequent verification / inspection efforts, changes to the design may be necessitated due to many factors such as revised-loadings, ;
interferences in the field, etc. This design change process is a controlled part of the quality prf> gram and does not mean that the design was not considered complete when construction began. The drawings, plus approved design changes continue to constitute a complete design. Applicants are not aware of j any requirement dictating any different sequence than the one employed. i i
I Question No, ll:
List every section of 10 CFR Part 50, Appendicos A and )
B, that any Applicant has not complied with. For each !
section cited, j l
- a. Explain the precise manner in which the )
)
_-_______.m . _ _ _ _ _ . _
I~
\
I Applicant. failed to comply with the specified ,
section,
- b. State the date(s) on which the failure to comply tock place.
- c. Identify the person (s) who failed,to comply. l
)
- d. Cite all documents.that document or support the conclusion that the Applicant failed to comply with j the specified section. j i
obiection:
Applicants object to Interrogatory No. 11 on the ground that it is overbroad, unduly burdensome and not reasonably l calculated to lead to the discovery of admissible evidence.
Response
Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants are aware of no instances where they have not j complied with 10 CFR Part 50, Appendix A. Applicants' nethod l of compliance is documented in FSAR Section 3.1 and the NRC Staff's evaluation is documented in the Safety Evaluation Report and Supplemental Safety Evaluation Reports. Documents that identify noncompliance with 10 CFR Part 50, Appendix B are contained in Attachment A provided in response to Interrogatory No. 7, above. No other evaluations or analyses .
1 sufficient to compile listings such as are requested by this 1 question have been prepared. Also, Applicants refer Interveners to " Response to Board Concerns" dated 10/8/86, Appendix B. 4 1
i
< To the extent that TU Elactric's compliance with 10 CFR i i
Part-50, Appendices A or'B is assessed by the CPRT, the results are or will be contained in the CPRT Central Files.
Applicants not aware of any other instances which could be claimed to be responsive to the question as understood.
Question No. 12:
List every instance of which you are aware where any Applicant failed to promptly identify design i
deficiencies.
obiection:
Applicants object to Interrogatory No. 12 on the ground that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.
Resoonse:
Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, and on the understanding that this interrogate ~cy seeks identification of any instance where any Applicant failed to report known design deficiencies in accordance with 10 CFR 50.55(e), Applicants refer Interveners to the January 8, 1985 TRT letter and to Attachment B, which identifies specific NRC Inspection Reports, which' record any instance wherein the NRC believed TU Electric has failed to report promptly in accordance with 10 CFR 50.55(e). TU Electric's acceptance or rejection of these beliefs are as documented in the responses to the reports. The subject of deportability is discussed
further in CPRT Results Report VII.a.2. Applicants are not aware of any other instances which could be claimed to be '
l responsive to the question as understood.
l Qggstion No. 13: l t
List every instance of which you are aware where any Applicant failed to correct design deficiencies.
i
Response
I Applicants are aware of none. Applicants have corrected i
or are in the process of correcting any valid known design To the extent that the adequacy of TU I deficiencies. i Electric's corrective action program is assessed by the CPRT, !
the results are or will be contained in the CPRT Central Files.
Question No. 14:
List every instance of which you are aware where any Applicant deliberately refused to take positive action to correct deficiencies in design, construction, or ,
QA/QC procedures or implementation. l J
t Response: l l
See Response to Interrogatory No. 6, above. l l
Ouestion No. 15: j List all criticisms of the Unit 1 QA/QC program I (including the QA/QC program of any contractors, l subcontractors, consultants, and vendors) of which you !
are aware that have not been thoroughly evaluated in a timely manner and/or for which appropriate corrective actions were not timely taken by any Applicant. For each of these criticisms, I
- a. Identify the source of the criticism.
i
- b. Identify the date the criticism was made.
l l c. Describe when and how the criticism was I communicated to the Applicant. !
l
t.J.
. - 3
- d. Cite all documents:which support the existence $
of the criticism and all documents indicating that I the criticism was 'caported to the Applicant, ;
I e4 Describe and explain the basis for your l conclusion that the criticism'was not. thoroughly ]
avaluated in a timely manner and/or that corrective j 1
actions were not timely taken. '
j
- f. 'Aas the action or inaction described in 15.e. j deliberate? If so, state any reason for such J deliberate action or inaction of which you are l aware, and identify the person (s) who took or {
refused to take the action. l j
pbiection:, i Applicants object to Interrogatory No. 15 on the ground ;
that it is overbroad, unduly burdensome and not reasonably calculated to lead to ths discovery of admissible evidence.
Resnongg:
Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond that they are aware of no. specific regulatory requirements concerning a time frame for evaluating " criticisms" or implementing stated corrective actions, other than 10 CFR 00.55(e). Applicants refer the Intervenor to TXX-6435 dated May 13, 1987, to the NRC which identifies instances within the 50.55(e) program for which corrective actions were not completed by the dates previously committed. Insofar as TU Electric's corrective action program imposes -restrictions concerning time frames, instances where commitments are not met would be documented as part of the corrective actica process (e.g., in audit
' L. 1 l
. ~ 0eports, corrective. sction requests) . Applicants havo'not performed an evaluation to compile such a listing, The l documents identified on Attachment A, including. follow-up documents as appropriate are available for Interveners inspection and analysis. To the-extent that the adequacy of TU Electric's corrective action program is assessed by the CPRT, the results are or will be contained in the CPRT Central Files, k
Ouestion No. 16:
Identify a11' criticisms of the design of Unit 1 of which you are aware that have not been thoroughly evaluated in a timely manner and/or for which appropriate corrective l actions were not timely taken by any Applicant. For i each such criticism,
- a. Identify.the. source of the criticism.
- b. Identify the date the criticism was made,
- c. Describe when and how the criticism was communicated to the Applicant.
- d. Cite all documents which support the existence of the criticism and all documents indicating that the criticism was reported to the Applicant. l I
i
- e. Describe and explain the basis for your conclusion that the criticism was not thoroughly evaluated in a timely manner and/or that corrective actions were not timely taken. l l
- f. Was the action or inaction described in 16.e. i deliberate? If so, state any reason for such deliberate action or inaction of which you are ,
aware, and identify the person (s) who took or j refused to take the action. j I
i 1
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y e t
- Response
See objection and rasponse to Interrogatory _No. 15, above.
Question No. 17:
t L Tcist'every warning of which you are aware by independent suditors 'of the existence of policies or practices at L Unit 1 which were not in compliance with NRC' I
requirements or accepted practice.
gbiection:
Applicants object to Interrogatory No. 17 on the ground that it is overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible ovidence. .
'Resoonse:
! Without waiving the foregoing objection, but on the I
l contrary expressly preserving and relying upon the same,
(
, Applic3nta respond that no evaluation sufficient to compile a
-listing such as this question seems to request has been l undertaken. Applicants refer Interveners to Attachment A hereto which contains document types and Applicants'
! " Response to Board Memorandum of G/8/86 (Assistance to the Board)" (10/8/86), Appendices B and C.
Question No. 18:
List every warning you are aware by the NRC of the existence of policies or practices at Unit 1 which were r not in compliance with NRC requirements or accepted practice.
f l
Resoonse:
Interpreting said Interrogatory to call for identification of instances of noncompliance with applicable 15 -
4 l
.i*-
s }
NRC requirements, Applicants provide herewith Attachment B,.a i
. listing of items of' noncompliance identified by the NRC in Inspection Reports for Unit 1. ;
i
.- Ouestion No. 19:
List every warning of which you are aware by the Atomic Safety and Licensing Board of the existence of policies or practices at Unit 1 which were not in compliance with NRC requirements or accepted. practice.
Obiection:
Applicants object to Interrogatory No. 19 on the grounds
-that to the extent that if any such " warnings" were ever issued (a proposition with which Applicants do not agree) they would be matters of public record and Interveners are as capable of identifying them as are Applicants. The l interrogatory is therefore overbroad, unduly burdensome and not reasonably calculated to lead tb the discovery of admissible evidence.
Question No. 20:
List every instance of which you are aware where any Applicant, in.the face of any warning listed in answer to interrogatories 17 - 19 above,, refused to make the appropriate and/or recommended changes. For each such instance,
- a. Identify the person (s) who refused to make the change.
- b. State the date of the refusal.
- c. Cite all documents that refer or relate to the refusal.
Obiection:
Please see objections to Interrogatories 17 and 19, above, ggsoonse:
Without vaiving the foregoing objection, but on the f contrary expressly preserving and relying upon the same, Applicants respond that they are aware of no instances where they have refused to make changes necessary to c6rtect valid deficient conditions. Upon determination of a deficiency's validity, TU Electric determines a course of action necessary to correct a deficiency which may include recommended actions. If another course of action is deemed more appropriate,.however, then the recommended changes are not implemented. Applicants are required, by law and their own commitment to quality, to address and resolve known deficient conditiona. They do however retain the prerogative to determine the appropriate actione to be taken. To the extent additional information responsive to this question has been -
or will be generated by CPRT, the results are or will be contained in the CPRT Central File, f Question No. 21:
List every instance of which you are aware where any Applicant has refused to address and correct design deficiencies. For each such instance,
- a. Idencify the person (s) who refused to make the correction.
- b. State the date of the refusal, f l
I I
-__ _- - - 1
[,.
o .
I l,
- c. Cite all documents that refer or relate to the !
l" refusal.
Rescorga:
See response to Interrogatory No. 6, above.
Question No. 22: ,
List all the deficient conditions at Unit 1 of which you are aware that were not detected until June, 1984.
l Qpiection.
Applicants object to Interrogatory No. 22 on the ground that it is 6verbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admiscible evidence.
Resuonse:
Without waiving the foregoing objection, but on the contrary exprecsly preserving and relying upon the sace, Applicants refer Interveners to Attachment A, provided in response to Interrogatory No. 7, above, which includes documents that identify deficient conditions that were detected after June 1984. Applicants also refer Interveners to 6 Applicants Supplement to Their Answers to CASE's Interrogatories to Applicants (11/15/05)" dated 1/3/86. In addition, the following documents are responsive to this interrogators l Construction Deficiency Reports (CDR)
Work Requests Issue Pesolution Reports (IRR)
Programmatic Deviation Reports (PDR)
Ruview Issues Lists (RIL)
Vendor Documentation Deviation Reports (VDDRs)
Operations Drawing Change Requests Vendor Nonconformance Reports
- 18 - ,
I m
l%
Contractor Deficiency Paper (generated under their own QA programs Ouestion No. 23:
List all the original judgments made by any Applicant of which you are aware that allcwed deficient. conditions at l
l Unit.1.to exist and continue, and identify the person (s)
I who made each such judgment.
Response
-Applicants are aware of no judgments that allowed a l deficient condition to exist and to continue to exist once the deficient condition was identified. As stated previously, Applicants have corrected or are in the process of correcting known, valid deficiencies. To the extent that this will be evaluated by CPRT, the results are or will be contained in the CPRT Central Files.
Qggstion No. 34:
Idantify each and every CPRT judgment on the safety
' significance of a deficiency (as defined in the CPRT Program Plan) that was made by TUEC personnel.
Rescongg:
None.
Question No. 25:
Identify each and every CPRT judgment on the safety f significance of a deviation (as defined in the CPRT Program Plan) that was made by TUEC personnel.
Egacense:
None.
Question No. 26: ,
i
L. !
l Identify which CPRT reinspection.are being conducted l' without complying with Appendix B.
Response
None. As stated within Appendix G of the CPRT Program Plan the ERC-Simco Management Program plan-for the QA/QC Review Team (MP Plan) Revision 7, Section 8.0, Inscection, l
"The inspections conducted by the QA/QC Review Team are not
~
inspections for acceptance of hardware and do not, therefore, fall under the requirements of 10 CFR Part 50, Appendix B or the TU Electric QA Program." Inspections are performed to the requirements of the MP Plan to " ensure high quality L . standards in ac'cordance with the SRT's and TUGCO Management's expectations and commitments to quality," (Appendix G, paragraph E), which Applicants believe are compliant with all applicable criteria of 10 CFR Part 50, Appendix B. 4 Ouestion No. 27:
Do you believe that any of these CPRT reinspection are required to comply with Appendix B and, if so, which ones? If not, why net? In what way do these reinspection fail to comply with Appendix B?
Resoonse:
See-response to Interrogatory No. 26, above.
Ouestion No. 28:
State each and every way in which CPRT reinspection are impossible of trending.
Resoonse:
Interpreting the Interrogatory as asking which, if any, CPRT reinspection results are impossible of trending, Applicants state that trending of CPRT reinspection results
- 20 -
- j is p,ossible, and the trend 5ng analysis is being conducted in The results of this cecordance with the CPRT Program. ,
trending analysis are or will be contained within the CPRT l j
Central File.
Ouestion No. 29:
State each and every.way in which CPRT reinspection are impossible of documentation.
Resoonse:
Documentation of the CPRT reinspection is possible and is being conducted in accordance with the CPRT program and implementing procedures and instructions. The documentation is or will be contained in the CPRT Central File.
Question No. 30:
State each and every way in which CPRT reinspection are impossible of verification.
Response
Verification of CPRT reinspection is possible and is being accomplished in accordance with CPRT program and implementing procedures / instructions. The results of the verification efforts are or will be contained in the CPRT Central File.
Question No. 31:
- a. How many' individuals who are currently or were formerly employed by Stone & Webster during the period June, 1986 through the present were former employees of l
NPS Industries, ITT, Grinnell, Texas Utilities Electric l Company, or one of its affiliated companies, Gibbs and i
Hill, or any other of the Applicants or their agents, and worked at any time previously on the Comanche Peak project (either onsite or offsite)?
1
s 4
- b. Provide,a list of'all such individuals, along with details of the dates they originally worked for the companies in question, the dates they were hired by Stone & Webster for their assignment to work on comanche Peak, their current job title and their last known address and telephone number, obiection:
Applicants object to Interrogatory No. 31 to the extent it seeks information concerning Stone & Webster personnel not employed at Unit 1 during the relevant time period, on the ground that such information is irrelevant to the subject matter of this proceeding and the Interrogatory as phrased accordingly is overbread, burdensome and oppressive and not reasonably calculated to lead to the discovery of admissible evidence.
Resconse:
Without waiving the foregoing objection, but on the l contrary expressly preserving and relying upon the same, i Applicants respond that this information is being compiled by Stona & Webster and will be transmitted under separate cover I I
upon completion.
Question No. 32:
I
- a. How many individuals who are currently or were I
employed by Applicants or any of their consultants, contractors, subcontractors, or any other companies l working on reinspection / reanalysis effort and/or the ,
corrective actions resulting from such effort, during i the period August, 1985 through the present, were former employees of NPS Industries, ITT, Grinnell, Texas i Utilities Electric Company or one of its affiliated ,
companies, Gibbs and Hill, or any other of the l l Applicants or their agents, and worked at any time l f previously on the Comanche Peak project (either onsite l or offsite)?
L 1
i
[.-
(. .
- b. Provide a list of all such individuals, along with l
details of the dates they originally worked for the L companies in question, the dates they were hired for their assignment to work on Comanche Peak, by whom they were hired, their current jcb title and status, and, if their last they are no longer employed at Comanche Peak, known address and telephone number.
Obiection:
Applicants object to Interrogatory No. 32 on the ground that as phrased it is overbroad, unduly burdensome and not reasonably calculated tu lead to the discovery of admissible For example, as of August 6, 1987, Applicants evidence.
employ at least 9,758 individuals directly or indirectly to work on Comanche Peak through more than 8 major engineering organizations or subcontractors.
Response
Without waiving the foregoing objection, but on the contrary expressly preserving and relying upon the same, Applicants respond that the information sought is being compiled for those individuals from TU Electric, SWEC, Impell and Ebasco. The results will be transmitted under separate cover upon completion.
9 l
l
- - - - - - - - .__-___...___J
y I
l l EESPONSE TS_ REQUEST FOR PRODUCTION OF DOCUMENTS l Applicants object to producing the documents purportedly l designated in the Interveners' 6/19/E7 discovery request on i c the grounds: that said request fails to identify the u
documents sought with reasonable particularity as required by the Rules of Practice; that it is overlyLbroad, unduly burdensome and not reasonably calculat(d to lead to the t
. discovery of admissible evidence; and. .that it improperly seeks to r0guire tho disclosure of documents protected
~
agcinst such discovery by the attorney / client privilege, the sttorney work product privilege, or the other privileges Applicants further l
' afforded trial preparation materials.
object to being required to produce the original of any docunents properli discoverable under the esquest on the grednd that such a requeot is everly broad, unduly burdensome I
> ahd not reasonably calculated to lead to the discovery of ,
a'dmisulble evidence.
Applicants will produce far inspection and copying, at the offices of TU Electric, 400 North Olive Street, Dallas, Texas, or at the CPSES fjobsite, Glen Rose, Texas, at a time to be mutually agreed upon'by counsel or other representatives of the parties, copies or criginals, as appropriate, of any document specifically referred to or referenced J,n the foregoing responses,. including the Attsch.t>ents incorporated by reterence therein, upon specific t
~ ~ ~ ~ ~ - - - - _ - . . _ _ _ _ - - - _
. I
- advice by the Interveners of which such documents they wish to inspect. Applicants will also produce the CPRT Workina Files and the CPRT Central Files in the manner and at the times previously offered in response to other discovery .
i '
requests.
MOTION FOR PROTECTIVE ORDER To the extent required by the Commission's Rules of Practice, the Applicants move for the entry of a protective order in accordance with the foregoing objections and responses which are subject thereto.
TEXAS UTILITIES ELECTRIC COMPANY For t Owners of PSES
/ '
William S. Eggeling Deborah S. Steenland ROPES & GRAY 225 Franklin Street Boston, Massachusetts 02110 l Attorneys for Texas Utilities i Electric Company 4
As To Objections '
fr )
William S. Eggel )
)
- . 3 :& !? 1s: 21
- EnEE T .n c ; -
4
- - 5E . cs
, 1 SIGNATURES I, Susan S. Palmer, being first duly sworn, do depose and say that I am a Project Manager for TU Electrie, that I am f amiliar with the information contained in the " Answers to Consolidated Interveners' Interrogatories Request to Production of Documents (6/17/87)", that.I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are based on information that is available to Texas Utilities but not within my personal knowledge, as to which I, based on'such information, believe them to be true.
sj,
~-. ~ . .
? 1
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P, ' ..~.*:-
?
b .1}l a w 4 Susan S. Palmer i
Sworn to before me this
/4.tA. day of August, 1987:
b %
Nota d Public
[-
l My Comission expires: 5-7-19 I
L___--_-__------------------
7 pg gg :1 ATTACHMENT A
..- DOCUMENTS WHICH MAY CONTAIN CRITICISMS m
0F THE UNIT 1.QA/QC' PROGRAM (7.001' S'& L REPORT: "SELF-INITIATED EVAL. OF DESIGN &
L .
CONSTRUCTION OF'CPSES"
.7.002 LOBBIN REPORTt- " REVIEW OF QA PROG. FOR THE DESIGN AND CONSTRUCTION OF CPSES" 7.003 3 E.R MONTHLY CONSTRUCTION PROGRESS' REPORTS 7.004 SER AND ALL SSERS 7.005 'QA SERVICES ~ ENGINEER. STAFF REPORT ON FSAR COMPLIANCE VERIF.
PROG.-FCR VARIOUS SYSTEMS 7.006 NRC INSPECTION REPORTS 7.007 TUGC0 QA' AUDIT REPORTS 7.008 COPY: 0F KAHLER/SPANGLER/KEELEY QC. INSPECTOR INTIMIDATION REPORT 7.009 SPECIAL REVIEW TEAM REPORT 7.010 GROUP AUDIT REPORTS 7.011- QUARTERLY QA TREND REPORTS
,7.012 'CPSES FSAR VERIF. ACTIVITIES STATION SERVICE WATER SYSTEM
SUMMARY
REPORT
-7.013 FSAR COMPLIANCE VERIFICATION STATION SERVICE' WATER PRELIMINARY. SYSTEM ASS. REPT.
7.014 PRELIMINARY SYSTEM ASSESSMENT REPORT FSAR COMPLIANCE OF SERVICE WATER SYSTEM
-7.015 FSAR COMPLIANCE VERIFICATION PROG. STATION SERVICE WATER SYSTEM ASS. REPT.
.7,016 MONTHLY ACTIVITY REPORT FOR B&R QA ACTIVITIES ON CPSES.
7.017 QA SERVICES SURVEILLANCE MONTHLY ACTIVITY REPORTS 7.018 SITE SURVEILLANCE MONTHLY ACTIVITY REPORTS 7.019 CORRECTIVE ACTION REPORT 7.020 BROCKMAVEN NATIONAL LAB REPORT ON PROTECTIVE C0ATINGS 7,021 SOUTHERN ENGINEERING REPORTS-FOR TEX-LA AND BRAZOS 7.072 COPY OF 1978 MAC REPORT ON QA
.7.023 WESTINGHOUSE PMG AUDIT (10-81) 7.024 EMERSON CONSULTANTS FINAL REPORT OF 4/79 6 80 SAMFLING STUDIES 7.025 CYGNA IAP REPORT 7.026 SIT REPORT 7.027 SALP REPORTS 7.028' TRT REPORTS 7.029 NRC TREND ANALYSES 7.030 ASME SURVEY DOCUMENTATION 7.031 CAT REPORT 7.032- EG&G REPORT 7.033 DUKE POWER REVIEW OF TUGC0 NUCLEAR ENGINEERING l 7.034 EBASCO ANALYSIS OF QA RECORDS MANAGEMENT SYSTEMS 7.035 1985 INPO CONSTRUCTION PROJECT EVALUATION I
7.036- NATIONAL BOARD OF BOILER AND PRESSURE VESSEL INSPECTORS AUDITS 7.037 HARTFORD STEAM SOILER INSPECTION AND INSURANCE COMPANY i AUDITS j 7.038 REQUEST FOR INFORMATION/ CLARIFICATION 1 7.039 CORRECTIVE ACTION REQUEST
y :Pdgo_No. 2 08/14/87 DOCUMENTS WHICH MAY CONTAIN CRITICISMS l
~OF THE UNIT 1 QA/QC PROGRAM 7.040 SURVEILLANCE REPORTS / DALLAS & SITE 7.041 EXIT INTERVIEWS I 7.041 , AUDITS BY MAJOR ENGINEERING ORGANIZATIONS, AND SITE
, CONTRACTORS AND SUBCONTRACTORS 7.043' SIS REPORTS SY HARTFORD !
7.044 SIGNIFICANT DEFICIENCY ANALYSIS REPORTS 7.045 SAFETEAM REPORTS .l 7.046' QA INVESTIGATIONS (QAI'S)
.7,047 NOT LINE INVESTIGATIONS (
7.048 SECURITY INVESTIGATIONS I 7~.049 PIPE SUPPORT. ENGINEERING REPORT (BY EDS) 7.050 DEFICIENCY REVIEW REPORT t 7.051 SN'S 7.052 CREW' AUDIT RZPORTS 7.053 MAC REPORTS OF BROWN $ ROOT 7.054 REPORT ON STONE & WEBSTER REPORT ENGINEERING CORPORATION'S' )
EVALUATION AND RESOLUTION.OF GENERIC TECHNICAL ISSUES l (CPSES) 7.055 T-SHIRT REPORT 7.056 OFFICE OF INVESTIGATION REPORTS 7.057 DALLAS CAR'S 7.058 OPERATIONS QA MONTHLY STATUS REPORTS 7.059 FINAL REPORT - DAMAGE STUDY REVIEW (EBASCO) 7.060 REVIEW.OF SUB COMPARTMENT PRESSURE / TEMPERATURE ANALYSIS (EBASCO) 7.061 UPS AREA AIR CONDITIONING SYSTEM - DAMAGE STUDY FIRE HAZARDS (EBASCO) 7.062 ENFORCEMENT ACTIONS 7.063 SAFETY EVALUATION OF CPSES UNITS 1 & 2 U.S. AEC, 09/03/74 7',064 NRC ADVISORY COMMITTEE ON REACTOR SAFEGUARDS TO NRC CHAIRMAN PALLADINO
SUBJECT:
REPORT.ON CPSES UNITS 1 & 2 1 7.065 REPORT.BY DRESSEL BURNHAM LAMBERT INC. RI: A COMPARISON OF NUCLEAR POWER PLANT PROJECTS USING NRC SALP REPORTS 7.066 NRC'S CASELOAD FORECAST TEAM STUDY OF CPSES )
7.067 DESIGN REVIEW AND QUALITY REVALIDATION REPORT BY TDI DIESEL GENERATOR OWNERS GF.OUP 7.068 TUGCO QA MANAGEMENT REVIEW BOARD REPORTS (1979 SURVEYS) u 7.069 STONE & WEBSTER POSITION PAPER ON VISUAL INSPECTION OF
SUPPORT WELDS 7.070 THERMOIAG FI2LD VERIFICATION WALKDOWN 7.071 PLANT SURVEILLANCE REPORTS 7.072 EBASCO HVAC ASSESSMENT 7.073 NRC AUDITS OF VENDORS 7.074 G&H'NY QUARTERLY QA TREND ANALYSIS 7.075 10CFR PART 21 REPORTS 7.076 VENDOR SURVEILLANCE REPORTS 7.077 EVALUATION OF DAMAGE STUDY PROGRAM FOR CPSES-FIRE PROTECTION DESIGN, JET IMPINGEMENT ANALYSIS / PROTECTION DESIGN, CLASS 5 PIPE 7,078 LARGE BORE FIELD WALKDOWN REPORT
( :. . . ..
Pago No. 3 0$/14/87.
N I")CUMENTS'WHICH MAY CONTAIN CRITICISMS
, OF THE UNIT _1 QA/QC PROGRAM' l-
.7.079 CPPP-5 SMALL BORE WALKDOWN REPORT 7.080 PIPING.AND SUPPORT SYSTEM ENGINEERING WALKDOWN FINAL'REPOR?
- 7.081- PRE-INPO EVALUATIONS L .7.082 SITE-QA ACTIVITY SUNKARY 7.083 WEEKLY ACTIVITY REPORT 7,084 . EXECUTIVE SUMMARIES BY LARRY,PLATT FOR DCC
'7.085 TNE-INTERNAL' SURVEILIANCES FOR ADHERANCE TO PROCEDURES 7.086 UNIT 1 & 2 LESSONS LEARNED
.7.087 FIELD JOB CRDER LOG- . 1 7.088 EVALUATION 0F IE BULLETINS, CIRCULARS, NOTICES APPLICABLE TO CPSES 7.089- EXPEDITING TRIP, REPORTS 7.090 WESTINGHOUSE _0WNERS GROUP REPORT -
7.091 ASSESSMENT OF THE PRODUCTIVITY OF THE CABLE TRAY HANGER DESIGN VERIFICATION PROGRAM AT CPSES UNIT 2 7.092 CTM PROGRAM PRODUCTIVITY ANALYSIS - DUKE POWER 7.092 PNG EXPEDITING, PURCHASING & SUBCONTRACTS WEEKLY STATUS REPORT 7.093 EDS REPORT ON OPERATIONS QUALITY ASSURANCE PLAN 7.094 HUMAN FACTORS ENGINEERING EVALUATION OF CPSES U1 STEAM ELECTRIC CONTROL ROOM 7.095 HUMAN FACTORS ENGINEERING PRELIMINARY ASSESSMENT OF CP UNIT
- 1. CONTROL ROOM 7'.096 SCHEDULE ALERT REPORTS 7.097 OPERATING EXPERIENCE REPORT 7.098 I&E INFORMATION NOTICES
.7,099 IEE CIRCULARS 7.100 GENERIC LETTER AND RESPONSES
'7.102 INDEPENDENT SAFETY ENGINEERING GROUP FORMAL REPORTS 7.103- IE BULLETINS'AND' RESPONSES
.7.104 INFO SIGNIFICANT OP. EXP. RPTS.
7.105 MAINTENANCE ACCESSIBILITY REPORT IDENTIFICATION OF PLAN DESIGN PROBLEMS' 7.106 CONSTRUCTION DEFECT REPORTS 7.107 QUALITY SURVEILLANCE REPORTS (QSR'S) 7.108 SELECTED QUALITY INTEROFFICE MEMOS 7.109' DEFICIENCY REPORTS (DR'S) LOG 7.110 _ CORRECTIVE ACTION REQUESTS (CAR'S) LOG 7.111 INPO EVALUATION REPORTS 7.112 REVIEW OF CPSES CONFIGURATION MANAGEMENT PROGRAM BY ROY
> WIGHT-ADVANCED SCIENCE AND TECHNOLOGY ASSOC., INC.
7.113 NWT, INC. REVIEW OF TUGCO CHEMISTRY PROGRAM 7.114 VENDOR EQUIPMENT QUALIFICATION REPORT 7.115 EP DRILL AND EXERCISE REPORTS RADIO AND_ TELECOMMUNICATIONS 7.116 EP INDEPENDENT REVIEW REPORT 7.117 INPO SIGNIFICANT EVENT REPORTS 7.118- UNIT 1 SMALL BORE PIPING AND PIPE SUPPORT GENERIC ISSUES j REPORT l 7.119 UNIT 1 LARGE BORE PIPING AND FINAL REPORT !
'7.120 BNL REVIEW OF TUGCO CPSES UPPER LATERAL RESTRAINT BEAM -
STEAN GENERATOR 4 w______-____-____- i
. P;g3'No. 4~
08/14/67' DOCUMENTS WHICH MAY CONTAIN CRITICISMS
. Or THE UNIT 1 QA/QC PROGRAM 7.121 G&H CONTAINMENT MAT REPORT 7.122 LAW ENGINEERING TESTING COMPANY - CONTAINMENT #1 BASE MAT INVESTIGATION 7.123 BOSTON-BERGEN METAL PRODUCTS REPORT-REWORK OF THE POLAR CRANE BRACKETS 7.124 MR. J BECK'S REPORT TO THE ORC CONCERNING THE CPSES MANAGEMENT MEETING OF SEPTEMBER 13 AND 14 7.125 JOINT UTILITIES MANAGEMENT AUDITS (JUMA) 7.126 EDS REPORT "STARTUP PROGRAM EVALUATION" 7.127 EDS REPORT " REORGANIZATION OF QA/ PROCEDURAL COVERAGE" 7.128 QA OVERVIEW COMMITTEE MEETING REPORTS 7.129 DIAGNOSTIC OF ENGINEERING AND CONSTRUCTION ORGANIZATION 11/19/79 BY MAC 7.130 ASLB TRANSCRIPTS 7.131 PUBLIC MEETING TRANSCRIPTS 7.132 INTERVENOR CORRESPONDENCE 7.133 NRC CORRESPONDENCE .
7.134 RATE HEARING TRANSCRIPTS AND RELATED DOCUMENTATION 7.135 DOCS CONTAINED IN CPRT CENTRAL FILE (INCL. RESULTS RPTS, CQT RPTS, COLLECTIVE EVALUATION AND COLLECTIVE SIGNIFICANCE NOT YET ISSUED) 7.136 PROJECT STATUS REPORTS (NOT YET ISSUED) 7.137 LOBBT,N REPORT " EVALUATION OF THE ORGANIZATION & PLANN!NG FOR STARTUP AND OPERATION OF CPSES" 7.138 REVIEW OF TUGCO CORPORATE NUCLEAR ORGANIZATION (OPNS) 7.139 STOP WORK NOTICES 7.140 REPORTS AS DESCRIBED ON APPLICANTS' PROGRESS REPORTS 7.141 OPERATIONS QUALITY ASSURANCE ANNUAL REPORTS 4
l l t
I
\
L L__________
? ATTACHMENT B Pm h. i 00/11/47
. '"riEi !;st IE li!MS !.iSi (TEN ITEM M li 'i'r! 17 NtlMBER biSCRIFil04 !WIR liEM 445/7302 NO PR'JCIDURE E!!STS FOR I:tPLEMENTING CRITERIA V 0F 445/73 02 VIOLATIC!:
446/7302 10CFR50 APP.B 446/13 02 445/7302 N0 PROCEClfRE FOR IMPLEM!NT[NU DOCU?.!HT Ct;NTR01, 445/73 02 VIOLAiiCN 5 446/7302 446/73 02 445/7302 NO PROCEDURE FOR [MPLEl!ENi[!!G CONTR11, i.F PVRCHASED 445/73 02 il0LAi[0!!
446/7302 MATERIA!., EQUIPMENT AND SERVICES 446/73 02 I
445/7302 FE0CUREMENT PROCEDURE DOES 'l0T ADDRESS THE 445/ibb! Vlut,All0N 446/7302 CUIDELINES IN DETERMINtHG file ADEQUACY OF THE 446/73 02
, FROVISIONS OF ANSI N45.2 445/7302 QUALITY SURVEllt,ANrE MEETINGS NOT liEl.D AS REQUIRED 445/i3 02 VIOLATIuN 446/1302 BY FSAR AND QA PLAN H6/7bO!
445/7302 THE 1,[ CENSING AND REC 0R0 1ETENT!0N FR0Ct00RES O!!Li 445!i3 02 7ttLMl0N
, 446/7302 PARTIAll,i IMPLEMENTED 146/73 02 445/7302 THE DCC AND QA DEVIATION A0MlH!STRAi!dW AND H5/7bO2 VI0l. AT[UN 446/7302 IWiERFACS CON 7ROL FRar!DURF.! tin! [M;riv!';TED 446s7bO!
445/7302 QUAL,iTY SNVFILI.ANCF ctMITTEE ilAS *:oi RiVIEsili 415iibe! m LAftoN 445/7302 QAreC FROGRAMS AS REQUIREll 446/7bO2 445/1302 AUTHORIT1 DUTIES NOT DEFINED [H QA f!.AN 445/7be! VI01.ATION 446/1302 446/13 02 445/7302 00Cl:MENTAT[0N FERTAINING TO IMFLEMNTATION OF H! sib 62 'l!0LAi!0N 446/7302 PROCEDURES NOT AVAILABLE FOR !.!VEIW 446/ibO2 445/7302 QA PLAN DOES NOT C0".Fli WllH ANel ':45.2.11 H'u ;3 -v: 'liotA T(0H 446/1302 146/13 02 445/1302 FR0rEbuRES LARK!NC I?l LEinita M51al n iRot, !!!,7392 ':leLA i!0':
446/1302 RESFutfSIB!LITIES 146,13 1,2 445/1302 QUALITY RELATED INSikuril.jistpar.it-ri in.E 1:Sti3 a: 'iol.All0N 446/7302 !NAli,UAiE OR WIRE Nui Phi! Iib H6,7' 42 445/7302 CONTROL l.io 00!!DITIC!!$ t/>i Al0RES$ED 19 WA FLAN 45 /i' 02 710'.ATI0H 446/7302 s4(/;3 02
t Pate No.; 2
, 04/11/8T .
vinFs '.F.C !! ITFM3 Lisi ITLM
- 11!.9 NUMBER iiiAIPilet v.*IR .:t M
- .: MitR t , F.5 t'
445/1301 446/f301' QA PLAN 00E$ NOT 'ADDkESS CilANGE3 [N FRorURRENT 445si3 d! viv:.AilCN i
00CliMENTS 446113 0; 445/7302 446/7301 NO PROCEDURB E!!STS FOR CON 1R0L of REf0Rb8 445ti3 WHlrH C- IlULAT!UN HAVE NOT BEIN MICR0 FILMED 446/13 02 445/1301 446/7301- INADEQUATE PROCEDURE ADDEESS!!iG QllALIT7 AUDIT 445/f34i 3 7[0LAften 06/73 01 445/1302 PROCEDURE IN ORAFT STAGE OHLi 446/1301' 445/13-01 VIOLATION
~
446/13 02 445/1301 FRcCEDURES !! AVE NO APPROVAL, $10!'AiURE 446/7301 445/73 92 'it0LATIC!1 4461i3 01 445/1301 446/1301- ALL AFFROVED PROCEDURES '4ERE NOT 445/13 l>[SIRl!UTED V: 'livlA t[0N FOR USE
': . 446/13-01 44511100 (SIGNIFICANT FINDING) glr PROCEDURES L0 NOT CONTAth '
446/7402 445/74 02 QiHER
- REQUIREMENTS OF ANSI iTANDARDS
, 446/74-02 445/7402 H6/1402 (SIGNIFICANT FINDING) TH8 41H POLICI AS 445/74 STATED 01 iHuiHEs THEIR 0A MANUAL DOES NOT COMMIT %S 10 R!.4UIRE!!Eei$
46/14 01 IN AEC GU[0LlNE$
H5/1402 46/1402 (SIGX(FICANf FINDING) GlH QA fcLtrY AS DEFINED H5/it 02 IN uiHER THilR QA MANUAL (S NOT CLEARLY DEFlyti!V!
H6/74 01 445/7403 H6/7403 (SIGNIFICANTFINDING)BARFR0CEDUEEdNOTFULLY 445i14 03 OTHER IMPl.ENENTED 446/14 D3 l'
H5/7403 46/7403 (SIGNIFICANT FINDINGl Fins 4Ar00 ibC~ AM445/M-J3 EEQUlk!SviWER M03E SPECIFIC DETAILS W INT!EFACINd t 4!6!71-0
'EESPONSIBILli!!S 445/H03
($1CHIFICANT FINDING) ti$it sA PLAs EE,iliEEi 446/1403 it!.14 93 o!FER EIPANDING TO INCLUDE SURVEILLANCE Acil'!!if 446I740F 01 DAM H5/7403 446/7403 (51CNIFICANI F1NDING) 4A FF.N EAM Ri d[RFi Hiii4 ADDlittNA(
3 yill!E
[NFO RECARDING INTERFACING E!iP.
4H114 02 445/7403 446/1403 (SIGNIFICANT Fil:blNC) Fei '/ Ti/i:'it Y N CilN1 tif,it..! tiHER 0F AUDliS' DifrREFANT IN 8DFEAL AJl-usJ133
. - _ _ . - - . _ _ - _ _ - _ - _ - _ . - - _ _ - - . - - _ k
7 Page ca. 3 09/11/87 TSES ::EC !! ITEMS 1,lii ITEM ITEM GC 1R THE OF NUMBER DESCRIFi!0!! Ol1!R 1 EM 445/7403 ($1CNIFillANI FINlilN1) INSUFFIrl!Ni '!I:'HD. of FM. 149i1 3 Otii!!
446/7403 QA/QC PROCEDURES TO FACILITATS QA FROMAM 445i14 03 445/7505 (CIFICIENCY) (ICAVATIO!! FRurElmRE Soi DE'i!L;FID lli i5 t c5 :iRER
, 446/7505 FRIOR TO C0!L"ENCEMENT OF *n0RF. 146,75 95 l
l 445/7506 (INFRACTIONS UNAUTHORIZED [N3FECilHli BE!!N !45,73-05 oth!R l 446/7506 PERFORMED 446/15 06 f;
445/1506 (INFRACTION) (NSPECTORS ARE NOT INDEFEN11ENT 0F UNDUE 445/75 06 91HER 446/7506 (NFLUENCE & RESFONSIBillilES FOR SrHE0l'LES l COSTS 446;15 06 445/1506 (INFRACTIONS INSPFCTION PROCEDURE Nui AVAILABLE FOR 445i15 06 OTHER 446/7506 REVElW (CP-QCP-14) 446/75 06 445/1508 GROUNDWATER hiillDRAWAL RATE 115/75 03 'i[0L Ai10N 446/1508 , 446/15 05 445/7510 (INFRACTIUNI !. ACE OF A0HERENCE TO Pgrt0URE 415fi5 10 oiHE!
446/7510 REQUIREMENTS CONCRET3 IRAhSli Mll 446/75 10 445/7510 (lNFRACiluNi LACK OF ADIIEREN:E Tu lhuC!!:URE tt5s75-lu uisER 446/i510 REQUIREMENTS-CONCRETE FLACEMENT 446/15 10 445/7501 l,ACK OF QC PROCEDURES C0STAll: MENT l.l!:ER 145,16-)I 'il0LAilL N 446/7601 446/16 01 445/7601 DESICN CHANGE CONTE 01,-PROCEDi.RAL 0!FiCl!NCY 44!ii!-01 VIOLAllCN 446/7601 416/76-01 445/7601 LACK 0F QC SURVEILLANCE FRecli;t:kE.;Mna.i 4:5/15 Fi '!i0LAtl0N 446/1501 146/76 01 445/7601 LACK Of PROCEDiiEES ME,iL01 liul,ATION 446/7601 444/16 01 445/7601 .!!AMINAil0N AND REPAIR FEW i>i:4L .iflC '!:Fl 145/?6-01 i!0l.Afl0N 446/1601 446/16 01 445/76M iELDING OF iAFETT RELAi!D cmot:E!: i M5,*S 07 i!ulAil9N 446/1607 146t16 07 445/7608 DOCUMENT CONTE 0L 14 /16 08 11 CLARION 446/7608 U6/75 04
~
Page No 4 08/II/8i IFHis !:RC lt ITIM! Llii ITEM ITEM 9RC IR DE sf WUMBER DRfCRIPiteN NUMBER liEM 445/7608 TUSI 4A 00CUMENTAi!0N OF SURVEILLANCE uf ACTIVITIES 445/76 o8 WIOLATION 446/1608 446/76 08 445/7701 (INFRACTION) PROCEDURAL, 445/77 02 OTHER 4(6/1702 [NFRACTION CERTIFICATION / DOCUMENTATION !F (NSFEC10RS 446/77 02 445/770: (INFRACT!0ll) FROCEDURAL INFRACTIutl SU! CONTRACTORS 445/77-02 otHER 446/7101 FAILURE TO REPORT ITEM 0F NONCOMPl. LANCE 446/17 02 445/1710 FAILURE TO PR0 VIDE WPS At l/)CATlull VRERE WELDING IS 145/i7 10 VIOLATION 446/7710 PERFORMED (CVCS)AUI.BLOG. 446/17-10 445/7110 FAILURE 70 REMOVE WELD SURFACE PRIOR 10 ilHAL 445/11 10 VIOLATION 446/7110 ACCEPTANCE (CREM.1 VOL. CONTROL SYSTEM) 446/77 10 445/1805 FAILURS TO FALLOV PIFE FABRICAtluN ?ROCEDURES 445/73-05 VIOLAf!0N 446/7805 446/78'05 445/7A08 ~
DEFICIEN Y - FAllURE TO MA[NTAlH FLOW IN LOWER SQUAV 445/iA-08 il0LATION 446/7808 CREER 446/18 08 445/7811 FAILURE TO FOLLOW FIFl?ii, [1SIALLAlloH PR!;CFHJRFS 445s;8 It /[0LAi!0N 446/181) (46/7R 11 1
445/1812 FAILURE TO FULLuW vel.lilNC FROP!i?tif.!S (2 EACHI 145/74-12 VivLAil0N H6/1811 FAILURE TO CONTROL & TAG NONCONFORHl!N 116:!$ ( E\ CHI 446/18.IZ 445/1813 FAILURE TO FOLLOV CONCEETE TE$illM FRufEDURES 445/78 13 VIOLATION 446/1813 '
446ii8 13 445/1816. FAILURE TO PROMPit,Y REFORT A SIGN!IICANT LEFICIEN U ;15/18-16 V10LA T'.ON 446/7816 446/18 16 445/1818 FAILURE 10 FOLLOW /El.0lliG PR' cSK:Ri! 848.i?R li il0LAiluN 446/1918 It5lill M 445/1904 FAILUBE TO FULLOW AFFRV.iD FE':C!'.'VhE inR MAINIDASCE 4tSii3 04 7lvlAi[0N 446/1904 0F EQUIPMENT [N STORACE 446/il H 445/1906 FAILURE TO FOLLOV QC th!FECiloN I' v: RID!ihEs 14*o79 05 it':LAi[0N 446/*906 44slii 06
)
( 445/7306 INONCOMPLIANCEI REYlEV of iLAS5 IE R? M is (15t?? 06 UTHER 446/1906 446/79 06 L________
. . i l ....'. PHe No. 5
'H/II/81 cFS!$ ::RC IE !IE!!$ Lisi n j
, ! TEM . (TE:t W ;R iiFi ei NUM8ER DiSCRIPild 'ACER U!r .;
445/7911 FAILURE 10 !MPLEH!NT iWS 4A FROCEAM F0R CIVIL 415/79 !! Vl0LATl0W ;
446/1911 CONSTRUCTION 446/i9 11 1 445/7918 FAlt,URE TO CONTRUL SC INSFECT[uN STAMP 145/19 18 VIOLATI0ll
-(46/7918 (46/79 18 445/7918 FA!!,URE i0 TEAtH A!;D 1:!!'0CTRINATE 40 PER."0NNEL 445r19-12 VIOLATION 446/7918 446/19 .
445/1918 RECORD OF INSPECT [0N 445/i9 14 VIULAll0N 446/7318 446ii9 18 445/1918 INSIALLAt[0N OF ELECTRICAL ':0FFCNE:if 3 445/19 l! 1(0LAi10N 446/1918 H6/19-1B 445/1919 NONCONFORMANCE REPORT CORIEci!VE Aci10!! 445/19-19 'll0LAT10N 446/7919 446/19 19 445/1925 (INFRACfl0N)FAILURETOTOLLOWNONC0kF0EMANCE 445/1!-25 OfflER 446/1914 PROCEDUE!$ FOR ELECTRICAL CABLE 446179 14 445/7917- FAILURE to REVISE CBSOLEiB QA FRoCED"RES 415/79 27 VIOLATION 446/1916. .
446/19 26 445/7917 FAILURS 10 FOLL1s FROCED' IRE Fo!! H0ISTIN'I SAFEff 415/79 27 710LAflCN 446/1916 RELATED COMP 0HEWii 446/19 15 l 445/1928 FAtt,URE to PROVID8 AFFROPRIATE INsiEUCTIONS tor H5/1) 13 VIOLATION 446/7911 INSTALLAi!0N OF El,ECikiCAl, fANil 446/19 27 445/f931 FAILURE.10 TOLLOW vel.0!NG FRXEDURIS 145/19 31 7101,A *10N H6/1919 06/19-19 445/#001 FAILUBE to P20VIDI [N$iRUCil0N AND FK0CEDURES H5/A0 ci Vl0LAi!0N 446/8001 APPR0FRIATE TO CIRCUMSTANCE 146/40 01 445/8003 FAILURE TO F01, LOW FROCEDURES F01 CARLE FULLING 14il49 03 VIOLATION 446/8003 06/40 03 445/8008 F AILL'RE TO F01,1,01 PR9CEiiURFS F"C. k"Itiill;U AND 4tf,iA9 U: i!0LAil0N 446/8008 E! PAIR OF THAGED ELECTRirAL CA%E 416eA9 04 445/80c8 Fall,t'RE To itEMRT A $lt;:![!!:'.P i * ';,iRNU.3 ;;g,c,.n4 y[gLAi[0g 446/8008 91FICLEhtY ng;o.g
__ _ - _ _ _ - _ _ - _. i
4 Pste No; '$
08/11/81i 4: ?f!ES (RC !!. lie 55 LIST:
+
'i liEM liEM -tlRC IR mi (F -
NUMBER- DESrRifTl0li LNUMBlit l', EM '
445/8009z .GROU!!0 VATER VITHDRAWAL RATES 445,40 'j3 /!0lJT10N 446/8009 ,-
446/80 Ps 1
-445/8011- FAILURE TO FOLLuW PIPlHC l!!$iALLATI0ll TECEDURES 445/80 11 VloLAtlull 446/8011 446/80-11 445/8013 FAILURE TO FOLLOV vel, DING FROCEDilkEs. 145/U i3 VIOLATION 446/8013 446/40 13 44!/8013 FAILURE TO FOLLOW ELECTRICAL INSPECTION PROCEDURE 445/60 13 VIOLATION 446/8013 446/10 13 J445/8015 FAILURE 10 F01, LOW CUNifRUCil0H PPMID'JRE HEQUIRED Bf 445e80 i5' 710LAi!cN 446/8015' ORAVING 146/80 15 445/80li FAltDRE TO FOLLOV ORAVlWG FOR iELD PREP DETAILS 111/8011 710LATicN
-446/8011 446/80-17
. s.
445/io 14 YhlAi!CK 445/8018 FAILURE TO RDURT A $1Gl!!!!CANI C0!iiist!CileN 446/8018 DEFICl!NCT i46180 .
445/8013 FAILLRE T0 FOI-LOV FROUDURE !N MAgl!!G FULL 44!/8 M 3 VblAt:0N l 488/8013 FENETRAT10iVELOS 445,80 4 3 445/8101 FAILURE TO FOLLOV PROCEDURIS FOR PIPl!!G l!!5TALLATION 445/8 01 7tCLAi10N 446/8101 446/81 11 445/8115 FAILURE TO FOL, LOW QA FRUCEDUEES F0F. IE! (HSPECTICM 445/81 15 7IutaTit'N 446/8115 0F C0ATING (MISCELLANE003 STEEL. CABLE TRAf5 S';PPORT 446t8t 15 ORPIPESUPPORIS) 445/8103 PROCUREMENT CONTROLS' 11ba2-)3 VliLAfle!!
446/8103 446/st-03 445/8111-V 01 FAILURE i0 Fl:eFERLi !!her1RitiAi! N TEA!N iiiS0!n!L 445,41-11 /!0LAil0N PERFORMING ACT!VlilES AFFEtilNG ',UAlltf (16181 11 4
445/8111 FAILURE 10 PERF0EM INSP!Cil0!:S OF !!!!!AL' .Ail 0N 145/81 11 VIOLAi!0N 446/8111 AC!!Vli!ES RELATED TO UNIT I C0!!!Al!!!!!Ni P0 LAB CRA!iR 445/81 11 445/8115 CIRTIFICAfl0N OF !!!SfiCi9RS 445t 5145 VI')LAi!0N 446/8113 415/8: 13 1
l
l, Fay h. T
_04/11/81 H!! W lE iiiMi i,bi (fin
. ITEM NUMBER
!.EC it IVF2 0F DE!CRIHluN W!!ER
- EM 445/8215 44(/!!!3. AUDIT 5 of NFS IN00S13tE$ A!!D Cell 145/82 23 VlulAi!0N 446382 13 445/8225 446/8213 CERilFICATIONOFlx!FECT0as 445/82 25 7l0LAfl0'N 446/82 l3 445fE!25 CDITS 446/8213 145/82 25 'll0LA T10N 446/s2 13 445/8230 V 01 t;
FAILURE 10 FOLLOW FROJEDURFS 445/82 30 VIOLATION
' 445/8303 V 01 FA! LURE 10 (HPLIMNT A GA FROGRAM 0F FLOO0 TITE POLE ASSf'S FOR INSTALLAT!0N 445/83 03 VIOLAtl0N 446/13 01 445/8307 446/8304 FAILUSE 70 FOLLOV PROCEDURES 445/8347 V!0lAf*0N 485/83 04 445/8308 V 01 fA!!,VRE TO REVIIV CHANCES TO AffR0VED is0CE0MES 445/ir3 08 VicLAtlow 445/8318 V 01 46/8312 V-01 L Act 0F PRcCEDUP.S. !!lSTRUCil0Ns t 445t Dec'S ick u li Vl0LArioy INSTALLATION 0F NAJOR liEMS 4Hi43 12 44!!8kl8 V 02 Fall,URE le FX9Vll'R O!WAi! MAlW1BAhrB 446/8312 V 02 : MAT'l i EGUlP (N 05/000R AREAS fli/il H 19t A il di 446/a3 12 44!/8*,18 V-03 446/8312 V 03 FAILURE TO REMOVE 0?iOLU3 DIAVihGi 415/U li H.i M VoRE AREAS il0LAtl0W 446/43 12 H5/8318 Vr04 1 446/8312-V04 Tall,URE TO FROVIDE A0!QUATE CMIROL LF VE1ill.AT10N i SYSTEM FABRICATION 445en 18 Vicuil0N 44/83 12 445/8323 V 01 HARDWARE filHS DEVIATS FMi H510 (YUMt.Nii 145,D 23 110LAINN 445/8323 V 02 (NAbiOUATE IN$iAl,LAfl0V f R00E00?.ES iSEl5!!!C $WAi i STRUT l 445/R'-23 V!qlAt[(N 445/8340 V 01 FAILURE Id DLL04 FR0cl00EES
- 145 M 40 'llouttes 445/8408-V 01 i CAPS 0x "sli i tutAR rRA'E stAri',' i ::..:ste. t 415,ila! CoLailati C0KHECil0!!S Eir!E0 0! sic!: REQUIREMihtS tHlH 04
Li' j ,. ' Pate.No. -8 j 08/11/17 1 gy criij wkc IE ITEMS LIS-
]
'ITEN li:.X HEC [R IYPE i)F NUMBER 9ESChiFi!a9 $0Mi9. 1:IM
- . :::::::::::::::::::::::::::::::::::::::::::::::::::: ::::::::: :::::n:::
" 445184 U8 VluLATION 445/8408 V 02 FAILURETOPERFORM(NSFECTIONOJFACTIVliESRELATE01 10 Unit 1 MAIN COOLANT SYSTEM CROSS 0VER LEG 446/8 W 4' RiSTRAllitS 4(3/8416 V 01 FACLURE TO PROPERLY INSPECT CABLE TRAY NAEERS- 445/84-16 VIOLAtlull 445/8416 V 02 FAILUS8, TO PR0 VIDE LONTRULLED ISSUANCS OF QESICH 445/8 h l6 VIOLATION DOCUMEdtS AND CHANGES 1
4!5/8418 V 01 FAILURE 70 FOLLOW PROCEDURES 445/84-18 Vl0LAT10N f
(
445/84l8 V 01 FAILUi(E TO PE0 VIDE ADEQUATE TESi' PREREWJ[$1 Tis 445/84 16 V10LAtl0N !
445/84!1V01 PROCEDURE VIOLATION .iOP 501A 445/84 11 VIO!,ATION l 1
L 445/8411-V01 STARTUP TEST PROCEDURE 'll0LAtl0N 445/14 2'l ' VIOLATION 445/84-22 VIO!,Af10!! I
,, . 445/84tt V 01 FAILURE TO MAINTAIN FCSITlil FRES$URE ^N i1ECT -
- ~
. PENETRAflod$ 446/84-91
. 445/8421 V 01 FAILURI to N',4[FY WEC AS RirJlEED BY 100Fv50.!!(el
, 445/st 22 V101,Att0K )
(14/84401 I f
, .445/8432 V-03 FALLURE TO CatAlW WORE AUiHORIIAt[0ll TO BREAli 6?ALS 145/84-12 VIOLAtl0N l U6/84-07 l i
l 445/8f!2 V 05 FA(LURE TO DOCUMENT THE A$ 30!LT CONFICURAll0li 145/A4-12 VIOLAt!0M i 446/!4-07 )
445/8426 V 01 FAILURE to FROVIDE QC INiFECTItN CRIT!RIA 445/84 16 VIOLAi!0W H5/84:5 V 01 FAILURE to PROPERLY INSPECT 44!/84 ti VIOLAi!ON :
443/84!1 V OL FAILURE to FOLLOV PE0CEDUEE MIN. 4200 lNTEEFA$3 445I84 23 710LATION t!MP. 446/84 10 445/8431 V 45 FAILED TO MAEE CHANCES 10 !!,5 M1 ! AV 83!t44 31 Vl0LAil0W STAe105, REV. 1 1
445/8431 V-07 iMLUKE tu FOLLijd >Euri!,'UsE.4 4:5, d i- i t ilistAlli)N i
)
(45/8431 V 08 FAILtu to FEwi!,E nFacAi! !:MiviFi 145tA4 31 '!!99 t l0N l
)
., v 1 t
'* 'Pn e No,- 9'
- 08/11/87
' IIEll ITEM hRC IR TiPE 9F NUMBER DESCRIPil0N
, NUMBER IIEM s
- ::::.:::::::::::::::::::::::::::::::::::::::::::::::: :t::::::: :::::::::t 4
445/8431 V- H FAILURE TO PROVIDE ADEQUATE FROCEDUllES 145/84 31 v10LAtt0N 44518430 V 01 FAILURE TO ESTABLISH QA FROCEDURES I') R!il'LAEi,Y H5/A( 12 VIOLAi!0N i
j 446/8411-V01 REVIEV STATUS AND ADEQUACY OF C01;STRUCT10N 4A 416/84 11 1 PROGRAM j
i H5/8H2 V 03 FAttURETOPROP)iRLIPpHORFRODUCSEVIDiNCEOF U H5/84 31 VIOLAttcN i 446/8411 V 03 PLANNING FOR A COMPREHENSIVE AUDIT PROGRAM TO VERIFT H6/8 bit -
c COMP!, LANCE WITH QA PROGRAM
'~
\
445/8431-%05 FAILURE TO PRDPERLY CERTIFY A VEND 0R CuMFLIANCE H5/84 32 Vl01,Atl0N l 446/8411 V-05' INSPECTOR-446/84 11
{
H5/8434 V 01 FAILURE OF INSPECTION (0 (DENTIFf N0b CONFORMANCES 445/84-14 VlutAil0N 446/H 13
- 1
, , 445/8434V0$ Fall,URE TO NOTIFT NRC AS REQUIRED of 10CiR50.15(41 445184-34 'll0LAtivu
' . . . . .- H6t.H.[3 445/3440 V 01- FAILURE 10 FOLLOV PROCEDURAL REQUIREMEWIS FOR 445/84 40 Vl0LATI;H j ASSIGNING A UNIQUR IDEHiltliR 10 A IN F750.!5 4 1 Hit 44i5' ITSN H5/8HS V 02 IA! LURE TO PROVIDI ADEQt' ATE PROCEDU'ES AFFR0PRI Ai! 445/34 6 '/10LAi!0N TO CIRCUMSTANCES 445/8515 11 01
[DEFICIENCil FAILURE TO COMPLY WITH 10C?iS0.7th)(3) . H5/i5 15 ottiEl 446/8511 H 01 446/85 12 445/8502-V05 iAILURE TO FOLI,03 PE5 SCRIBED FE6CEXRE SU.cP 517-45 145tA5 0 Vict.ATION 00 AUI SYST I 445/8506 V 03 Fall,l'RE TO FROVICE AN Al,iWAI! FEeCEnk! 1AINildACE l4!I!5 06 VIOLATION DIV.ifROCE0llRECilAhClil 445/A507 V-01 FAILURE 10 PRu! PLY C0P.REcf A'i !!!!:flilit FE08Lih - 445i35 07 VIOLAi!0N M6/8505V-01 iT! DELTA POTENTI Al, iRANSFuRME!! 'FRIMAkt l'!sCt!.1ECT 446t!5 05 CLIPS) 445/850? t et Fall,URE to FULL 9V Nil.uit . - at ;F CAI AERAil.is 4ts;AS 67 71: LAi!0l; 446/9505 V 04 iCAl,E HOT DOCUMECID ON A ibR tCI5!Ni F T.!) 4 H .15 45
_ - _ - _ _ _ - - _ - _ _ _ _ _ _ _ _ _ - - _ _ - _ _ -___ = -.
,j '
' P'He No. 10 q
- 01/11/87 l rP!Ei NRC IE liEMS i, lit y
[7EM ITEK ' NRI !R TYPE OF I NUMBER DESCRIlflyN Wl:MBER iiEM j
- = :::::::::::::::::::::::::::::::::::::::::::::::::::: ::::::::: ::::::::::
y 445/8507-V 03 QC RECEIVING lil8PECT!0N ACCEPTED 445/85 07 VIOLATION OUT 0F SPECIFICATION SAFifi REl.ATID EQUlFMENT '446/85 05 g- 445/8507 V 04 CONCRETI TRUCE MillHG Bl,A0E INSPECTION PROCEDURE- 445/85 07 VIOLAil0N 446/8505 V 02 VI0l,ATION(CCP-10) 446/85 0(
445/8507 V-01 FAILURE T0 F01, LOW PROCEljusE C9MMERCIAL GROUT USED 445/i! 07 Vlut,Afl0N l IN 1, LEU OF. CLASS "E' CONCRETE 446/85-08 f 445/8511 V OL Fail,URE TO REPORT NONCONFORMING CONDITIONS (Fall,URE 445/85-11 V!cLATION TOISSUE.NCE) 446/85-06 q
-. 445/8513-V 01 (NOV) PROCEDURE V101,ATIUNS INCOMPl,ETE AND MISSiliG 445/85 13 il0LAfl0N l
.CONDUlf LDENTIFICAtl0N - Ql-QP-il.3 8, 446/85 09 QI-QP il.2 13.T
,- , 1 445/8514 V-03 AS BUILT ORAWINGS REVl!ED WitHOUT UPS REVIEV 445/85-l4 Vl0LAil0N 446/85-11 445/8514 V 01 NZO CHEM REr0RDS 445/8! 14- VIOLATION ,
446/45 1l !
445/!514 V 01 Fall,USE to IMPLEMENT FRucDi.'EES F0P. D""'UNE!il 031R01, 145/:5 14 VIOLATION ;
446/8511 V 03 AND INVENIORY I4E/d5 ll 445/8514 V-04 Fall,URE 10 C9MPl,I WITH Ql 'd-ll.* ",5 4l5185 14 V101,Atl0N l 486/85 11 ,
- l 445/8515 11-01 (DEFICIENCilDATA010h0TCONTAINTAG 445/85-15 OillEE !
446/8511ii-01 446,8! 12 l l
445/8515 H 03 [DEFICIENCil ISC MA' LAG!i IAlLED !0 E!LIEVE SHIFT 8ti/85 15 OTHER (46/8512 H 03 SUPV (4EsiS l!
445/8515 H 04 10EFICIENCil Gl,EN USK !!.'I 140',7til; lN iSiLTERING 445/25 15 OINEit -
446/8511 11 04 RiCOMMEND. 446,!!-12
, 445/8516 V 08 (NADEQUATE ANAi,YSIS AND PEteEDURE IN FCA 13343 (45/U 16 Vlut,ATION t16 45-13 4 0/8516 V-13 FAILURE TO [0ENilFi (;!!DEEil~.5 WFI.h 445/65 16 'i10LATIOS
- t 6,!5 13 F
s.
,e
- Pye No. 11 08/11/87 GS!6 Wid! It liEMS LIST
(' li1M NUMBER liEM DESCRIPil0H HRC 1R
' LUMB ER
'VPE OF liFM
- = :::::::::::::::::::::::::::::::::::::::::::::::::::: ::::::::: ::::::::::
H5/8516 V-14 NODESIGNCilANCiDOCUMENTSAPPROVINGMtulMUMBOLT 445/d5-16 VIOLATION SPACING VI0l,ATION 06/85 13
- CONDUli 51CESSIVEl,Y 1,0NG H5/851 A Vl0i,Ai!0N H5/8518 V-01 46/85 15 445/8518 V-03 INSPECTORS NOT PROP!RLY CERTIFIED 445/85-18 v10LAil0N 446/8515 V 02 446i45 !5 445/8518 V li CABLETRAYSNOTPROPERLI(,ABil,ED H5iB5 18 VIO!,AT LW
,4 ,
H6/i! 15 445/8518 V 15 DESIGN CHANCE PROCEDURES 00 kOT FOLLOV 10 CFB, 445/85 18 V10lAil0N APPEN0!! 8. CRITEgl0N 3 446/i5 15 445/8601 V-l! FAILURE TO IMPLEMENT PROCEDURES FL't HANDLlllG NON 445/8601 VI']LAtlCW I
- CONFORMING MATERIAL,S PARIS, uk CUM M ENis H6/8601 V 03 H6/86 01
,. 445/h601 V H FAILURE TO PERFORM OR IMPLEMENT FREECRIBED FlELD 445/i6 Cl V10LATIO4 l H6/8601 V 04 TEST OF CABI,E Reil, 446/86 01 445/8603 V-02 Fall,URE TO TREND 445/36-03 110LAi10N I M6/d6 02 i
. 445/8603 V 04 DESIGN CHANGE AhD NCR DISCREPANCY 445/86 03 VICLATION i 446/86 02 445/8604-V 02 QUEST 10NS PERTAINING TO INCINEERING ADEQUACY 445/R6 04 VI0l,ATION H l/8603 V 02 PENCILI,ID IN OW DRAWINGS DISTRBUISD TO DCC IEE (EPA) US/8bO3 445/8604 V 03 BRC PROCEDUR! 123 1286 FOR FIELD REVORK FAILURE TO HS/86 04 V10LAi[0N' )
, 446/8603 V 03 IDENTIFY EPA'S AS NONCONFORMING AND IMPLEMENT 446/86-03 CORRECTIVE ACTION H5/8604 V 04 EQU!PMENT WUAl,lFICAil0H Ali!QUACY REcokb HR FlfLf) H5:46 04 il0LAil0N 06/8603 V 04 REVORE OF CARLE SPLlCES ARE Wot GENERATED H6/36 03 H5/8604 V 0Y RBCEIVING INSPECTION, Fall,URE 10 COMPli VITH H5/M-H Vl'.CA tl01 H.6/8603 V-07 PROCEDURE CP-QAP-7.2, R.3 IEPA'S RECEIVING 446/66 0; INSPECi10N) 4 05/3604 V 08 iALLURE OF RECIEPT INSPECTION 10 !!91t!Fi IHE H5N6 04 HOLAtl0N 446/8603.V 08 NONCONFORMING CONDITIONS VITH REff E':T i0 REQU! RED 145/ abo 3
!TACCERlWG OF CABLE SP',,lrE3
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',~*l 1 Page.No. ' 12 .
08/11/87
.; CFSES NRC !! IfiMS LIST' ITEN ITEM- NRC IR TYPE SF NUMBER DESCRIPTION' NUMBER ' ITEM 445/8&04V-ll ACCEPTANCE ST QC 0F ( W ALLED CONFIGURATIONS, 445/66-04 Vl01,AT10N -l
, CONTRARfTOORAVINGS(CABI,ESUPPORTASSEMBLIES) 446/86-03.
(45/8604-V 13 Fall,URE TO PERFCRM REQUIRED SF(1,100 UPERATIONS, 445/66 04 ' 'l!0LAtl0N EPA'S TO JUNCTION B01 446/86 03 445/8604 V 15 Fall,URE TO ACCOMPLISN l'NSTAl,LAil0N IN ACCORDANCE 445/86 04 ll0LAT!1W . ;
V!TliPRESCRIBElfINSTRUCTIONS(IE14 SUPPORTS) 446/86-03 445/8607 V !! TEMPORARf MODIFICAfl0N TAOS NOT USED IN ACCORDANCE 445/86 07 v10LAtl0N
'VITil CP !AP-13 445/86 05
, 445/8607 V-01 DESIGN CALCULAll0NS BT TNE AS PROV10E0 WERE 445/86 07 VIOLATION
- UNAPPROVE0 AND INCOMPLETE 446/8605 445/8607-V04 DEstCH CHANGRS VERE NOT SUEMlTTED TO THE 445/86 07 Vi4LAil0N ORGANIZATION THAT PERFORME0 TIIE ORlCINAl, DESIGN FOR 446/86-05
- 7. REVIEW AND APFROVAL ..
445/8607 V-10 TERMINAL, BLOCKS IN PANEL, cpl ECF IRdl NOT 145186 07 Vl9LATICW
'i IllENTIFIED 446/6645 445/8607-V22 DESIGN DRAllNCS NOT APPROPRIATELY REVl VED FOR 445/86 07 Vl0LAT10N ,
ACCURACT 446/46 05 44f/8607-V24 CORRECTIVE ACTION REFORT CLCSED FRIOR TO COMPI,ET!0N 445/86 07 V10LAtl0N I 0F CORRECTIVE ACTION 446/86 0$
445/8608 V 01 FAILURE TO FULL,Y AUDIT Tile BiR aim!/'JA FROGRAM 445/96 08 VIOLATION 146/8606 V 01 446i86-06 445/8608V01 INADIQUATE DOCUMENTS lt! IUDIT rip 9Ei! 115/86-08 V10LAi[0h 446/8606 V 02 CP 18,CP ll,CP 24 CP 27 446/86 06 445f8608Vh3 INADEQl' ATE DOCUMENTATION IN AUDli ?!fuRIS rP-18 TEU 445/86-44 Viol.ATION 446/8606 V 03 CP 31 146,46 06 (45/8608 V 08 AUDIT DEFICIENCY No.10F icGC0 AUD*T TCP 51 WA5 415/86 08 Vl0LAi[0N
.446/1606 V-10 (MR1PiR!,Y CluSED 901- 116/86 06 445/8614 V 'jl Tall,URE T4 (DENTIFi, 7AG. hsu 2;AIE i h! M T tl5/li l4 Vl01,iTICN XCNCONF0kM!NG li!HS 446/56 11 l
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08/11/87 CF!!$ M 18.liEM List 1
ITEN 115!! 9C lR TYPE OF NUMdER 11ESCRIPi!0!! tW.lER li!!!
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t n (45/8614 V 03 Ql-QP'S FOR CA8LE TRAI AND CASL6 TEAT (ESTALLAi!0N 44s/86 14 VIOLATION 446/8611 V 10 INSPECTION 3 00 NOT A0 CRESS !!f PROCESS CONTROLS F0E- 446/86-11 THE DRIf,Ll%G OF N0LES IN CA86 .RAIS TO ACCOMODATB .- ,
it RAPS J 445/8615 4 06 LAC 1'0F UNIT 1 PFG PROCE!'JPTS TO CCNTROI, DESfCN 445/86 15 VIOLAi!0N D')CUMENTS.lS$UE0F0kEITy.NDEDr!RIODS 446/86 10 en 445/861'S-VOf LACE OF PROC 200BE TO C0XTR0! FAB SXOP ITEM 445/86 15 VIOLATION 446/8612-V07 TRACHABILITT. 446/86-11 e
445/8615 4 01 LACE-0F PROCEDURAL INSTRUCTION RELATIVE TO VRITTEN 445/86-15 V10LAil0N ]
446/8611 4 -08 . REQUEST TO FAB SHOP 446/86-12 ]
H5!86204 03a - FAILURE TO INCLUDB WORE PROCEDURE REFEkENCE, REV. H5/R640 YI01.tT10H l 46/86174-Oh ' LEVEL,0F. DRAWING, SPEC. OR FROCEDURE ON TRAVEL.ERS 446/86 445/8610 V 03b T'RAVELERS FOR WORR ON NSSS SQVIPHENT DID HOT INCLUDE H5/26 10 Vl0LATION Y. -
446/8611-V03b THE SICHATURE OF WESTINGHOUSE 446/86 17
....s 445/86204 04a MISSING OR INA0KQUATE 20RR OPERAilMIS ON TRAVE l,iR3 445/26 10 VIOLAI!0N 446/86174 04a FOR SAFitt !!!JECTION SYSTEM ACCUMULATOR TAXlS 44,6ti6 11 445/86104-04b MISSING OR INA0EQUAi! 'iORR OPERAila!S ON TRAVELiES 145/86 10 VloLAi!0E H6/iitf 4 04b FOR INSTALLING CLASS lE SVliCHES 446/86 17 445/86:0 V 05a TRAVELER REVISED AFTER APPROVAL Asb NO REVIStuN 445tH 10 i10LAi10k 446/86174 05a. NUMBERS OR O!SCRIPTION OF CHANGES 446/86 l1 i 445/8622 4 01 SAFEff VAlit DISCS 00 907 HAVE FE0PER CEkiS. 1 445/36 12 Vl0LAi!0N I
446/8620 4 03 SillPPING/ RICE!PT INSPECTIONS NOT PERFORMED 446/!6 10 445/8612 V 04 !MPROPER hYOR0 00CUME!!TAiluN UN (IT GRihWEL VALVE 445/86 11 V10LAfl0N BON!!Et3 H6t86 10 445/8612 4 16 PIP! IMPROPERLY STOR!D OUIS10E 'iAREHuuSE C I!i 445/86 F Vl0LAll0!!
H6/86204 07 V10Lat!0W 0F MCP 10 ti6i46 10 1
445/8626 7 02 C ARLE FULLING RUPES !!MAINING IN Ml'Ulf AND CAlil.E li$tdC 16 VNLAtl0N
- EnY 146/P6 12 445/862544tl ESL 'dil. DER PEEFORMA!P,5 00AI.lFICCION F.EGRDS 14'< / H 46 V10LAi!UN H6/8612 V 05 446/46 11
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' hge No.' 14 '. .
s: 0 88/!!/8? .
T,o a.o ,
CPSCS H C !! (TIMS 1,IST-
'*J 0- -
ITEN : ITEM
. NUM8tk .
NE:: It ti!! 0F L'UCR!Pilui! ?.UMht ;IEM.
445/8631 V el -0!!P0St0N OF NCR M U 10llt3, LALK UF tcA ISSUANCE 445i46 31 'iiutAt!ON l AND LACE OF Rt ilLM TO StiFPORT EVALUA110N 446/16 15 445'/8602 V 01 SiCURITYISSUE 445186 01 VIOLATICH
' 445/8601-V-01
).
SECURITY ISSUE 445/86 01 V[CLAf[0N 445/8707-V 01- FAltURE TO N0ilIY NEC PER PR0tlS!0NC 0F 10CfR50,55e 4 d/87-07 VtutAt!0N 446/8106 V 01-
- 446/87 06' 445/8707-V-02 NCR PROGRAM & PROCIDUR!S (AA0f90 ATE T0 ff?tEMENT 445/87 07 Vl0LAtt0N c -j
.CRlTERICW IV 0F APP, S. 10CF150 445/87 06 6
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CEgfI7ICATE OF SERVICQ
'07 nilliam S. Eggeling, hereby certiff that on August NG 3; lkf !O2 I,
?'
j
. 1987, I made service of " Applicants' Responses to Consolidated i 4 ! . j Interveners' (6/19/87) Interrogatories and Request for Documents" t I
by mailing copies thereof, postage prepaid, to:
Peter Bi Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Lic6nsing c/o U.S4 Nuclear Regulatory Board Commission <
U.S. Nuclear Regulatory P. O. Box 38 Glen Rose, Texas 76043 j Commisnicn Washington, D.C. 20555 ]
Dr. Walter H. Jordan Ms. Billie Pirner Garde i Administrative Judge GAP-Midwest Office !
881 W. Outer Drive 104 E. Wisconsin Ave. -B !
Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 Chairman Chairman l Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel i U.S. Nuclear Regulatory U.S. Nuclear Regulatory l' Commission Commission washington, D.C. 20555 Washington, D.C. 20555 ,
1 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire j Assistant Attorney General Atomic Safety and Licensing /
Environmental Protection Division Board Panel P. O. Box 12548' U.S. Nuclear Regulatory capitol Station Commission .
Austin, Texas 78711 Washington, D.C. 20555 l l
p.g. - -
o u ..
hf ]
Yl; pV, Anthony:Roisman, Esquire. Mr. Lanny A. Sinkin Suite 600 Christic Institute j 1401 New York Avenue, N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002-Dr. Kenneth A..McCollom Mr. Robert D. Martin !
Administrative Judge, Regional Administrator 1107' West Knapp Region IV
- Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 1 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esquire ,
Administrative Judge Office of the Executive l Oak Ridge National Laboratory Legal Director 1 P. O. Box X, Building 3500 U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission i Washington, D.C. 20555 Nancy H. Williams 2121 N. California Blvd.
Guite'390 Walnut Creek, CA 94596 William S. Egge @ g f-
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