ML20079F598
| ML20079F598 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/03/1982 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20079F587 | List: |
| References | |
| NUDOCS 8206080102 | |
| Download: ML20079F598 (13) | |
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
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CITIZENS ASSOCIATION FOR SOUND ENERGY (CASE)
APPEAL FROM LICENSING BOARD SCHEDULING DECISION I. Introduction This proceeding is currently scheduled for hearings on June 7,1982. The subject of this hearing will be Contention 5, which states:
"The Applicants' failure to adhere to the quality assurance / quality control provisions required by the contruction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construc-tion practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness. testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft
' labor qualifications and working conditions (as they may affect QA/QC, and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility. As a result, the Commission cannot make the findings required by 10 CFR 50.57(a) necessary for issuance of an operating license for Comanche Peak."
In a ruling on 10/31/81, the Licensing Board construed Contention 5 to cover the 5
Inspection and Enforcement Reports identified by ACORN, previously an intervenor in this proceeding, in its Offer of Proof of August 29, 1980. These I&E Reports dealt with:
QA Program - Lack of Compliance QA Program - Surveillance QA/QC Procedural Deficiencies Method of Identification and Control of Nonconformance Subcontractor's Failure to Report Items of Noncompliance Storage of Electrical Components Failure to Follow Pipe Fabrication Procedures Potential Construction Deficiency Regarding Possible Damage to Unit 1 Pressurizer Failure to Follow Equipment Maintenance Instructions.
Despite repeated requests from intervenor CASE, the Atomic Safety and Licensing Board has failed to provide adequate time for CASE to be prepared to go to hearing on this contention.
In summary, the grounds on which CASE has requested but been denied adequate relief are:
- 1. Obsta'cles to CASE's pursuit of discovery on Contention 5;
- 2. The elimination of other intervenors; 8206080102 820603 DR ADOCK 05000
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- 3. An unduly burdensome scheduling of prehearing deadlines; and
- 4. Repeated surprise " discoveries" by Applicants and the NRC Staff regarding
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documents in their possession.
The overall CASE grievance is that the Atomic Safety and Licensing Board's commitment to completing hearings on Contention 5 has produced a situation wherein CASE has been effectively : denied the rights it received when granted intervenor status. To require CASE to go forward on Contention 5 on June 7 will prevent CASE from being adequately prepared on this most important issue.
II. Jurisdiction CASE recognizes the obstacle to consideration of this appeal found in 10 C.F.R.
Section 2.730(f). This appeal is a request for discretionary interlocutory review via directed certification.10 C.F.R. Sections 2.718(i) and 2.785(b)(1); See Houston Lighting and Power Co. (South Texas Project, Units 1 and 2), ALAB-637, 13NRC367,369(1981).
Since this appeal is in the nature of a requdst for interlocutory review, such an appeal would normally be considered only on exceptional and important issues.
Pennsylvania Power and Light Co. and Allegheny Electric Cooperative, Inc. (Susquehanna Station, Units 1 and 2), ALAB-613,12 NRC 317, 321 (1980)
Among the recognized grounds for such an appedl is that "'a licensing board's actions either (a) threatens the party adversely affected with immediate and serious irr-garable harm which could not be remedied by a later appeal, or (b) affects the basic structure of the proceeding in a pervasive or unusual manner.'" Houston Lighting and Power Co. et al., supra, quoting Public Service Electric and Gas Co. (Salem Station, Unit 1), ALAB-588, 11 NRC 533,uS36 (1980).
An appeal board review will take place when a licensing board " abused its discretion by setting a hearing schedule that deprives a party of its right to procedural due process." Houston Lighting and Power Co. et al., supra, i370-371 quoting Public Service Co. of Indiana, Inc. (Marble Hill Station, Units 1 and 2), -
ALAB-459, 7 NRC 179,188 (1979).
Similar to a previously reviewed decision, this appeal presents a case where Applicants and Staff have abused the discovery process to prevent effective parti-cipation by an intervenor. See Susquehanna, supra p. 2. While not alleging deliberate Board misconduct, as alleged in Susquehanna, CASE does contend the Licensing Board has shown an intractable determination to hold hearings on Contention 5 beginning on June 7, a detennination which, however unwittingly, serves the ends of the Applicants 'and NRC Staff in obstructing the intervenor.
CASE contends the issue presented by this appeal raises fundamental questions cf due process and fairness in NRC proceedings. As such this appeal falls within the recognized area where discretionary interlocutory review is granted.
III. Discussion A. The History of Contention 5 Contention 5 is in fact a combination of various contentions. See Memorandum and Order (Rulings on Consolidation of Parties, Appointments of Lead Party-Intervenors, Miscellaneous Motions and Other Matters) (December 31, 1930). The contention itself is very comprehensive, including the history of non-compliance by the Applicants with 10 C.F.R. Part 50, Appendix B and the history of construction failures at the nuclear plant.
Discovery on this contention by CASE has been difficult and often CASE has turned to the Licensing Board for relief of these difficulties. See e.g. " CASE's Motion for Extension of Time for Discovery on Contention 5" (March 1,1982);
" CASE's Motion for Reconsideration of Extension of Time for Discovery on Contention 5" (March 22, 1982); and " CASE's Motion for Additional Time for Discovery on Contention 5" ( April 20,1982). For motetthan~: half the time since this contention was accepted, CASE was not allowed to do any independent discovery on the contention. See Memorandum and Order... (December 31,1980), supra and Order Subsequent to Prehearing Conference of December 1,1981 (December 18,1981) (restoring CASE I
to ind: pendent status on Contention 5).
For the Appeal Board to gain some sense of the obstacles faced by CASE in its efforts to conduct discovery, CASE refers the Appeal Board to th 6/5/81 Pre-Hearing Confemnce Agenda from Beard re:
conference 7/8/81 and 7/9/81.
6/26/81 CASE received telegram from new Board Chainnan cancelling conference 6/29/81 CASE received Applicants' 6/24/81 Motion to Cancel Prehearing (contains list of outstanding motions to be ruled on by the Board) 7/16/81 CASE received 7/13/81 NRC Staff's motion to modify its March 4 motion to compel against CASE
,1981 7/25/81 CASE received 7/22/81 Board Order re:
longer party to this proceeding) motion tt. clarify contention 3 andC stating: "This pmceeding is already suffering from a flood of motions, answers, objections to interrogatories and the like which constitute an imposition upon the Bodrd. The subject of excessive and unneces filings with the Board and proposed remedies therefore will be discusse in another Order to be released shortly."
(It should be noted that at this time the Board had not ru dating back to 3/81; has the Board ruled in a timely fashion, there woul not have been so many mctions pending.)
7/28/81 A.M. (filed before going to work that morning) - CASE filed th 1.
March 4,1981 Motion to Compel Against CASECASE's Ans 2.
Motion for Board Clarification of Wording on Contention 5 3.
CASE's Motion for Reconsideration R' larding Prehearing Conference (t Board had rules on Applicants' 6/24 Conference before CASE had even been aware of Applicants' M f
7/28/81 P.M. (in the afternoon mail) - CASE received:
1.
7/23/81 Board Order Scheduling evidentiary hearings beginning 12/2/81 on NEPA and other selected issues 2.
Discovery Directives Applicable to all parties 7/23/81 Boar 3.
Dismissal and designating CFUR as the lead party o 8/3/81 - CASE received 7/29/81 Board Order granting NRC Staff's 7/13/81 M Staff's motion before receipt or consideration of CASE to Staff's motion) 8/4/81 - CASE received 8/3/81 Board Order striking CASE's 3 pleadings o 8/10/81 - CASE filed two pleadings:
1.
CASE's Withdrawal from Contention 23 2.
Request for Clarification Regarding 10 CFR 2.730(c) (asking whether or not answers to motions will be allowed in the future pursuant to 10 CFR 2.730(c) and 2.710.
,4,
8/24/81 - CASE received 8/20/81 Board Order denying CASE's 8/10/81 Request for Clarification Regarding 10 CFR 2.730(c)
CASE makes no claim to expertise. Represented by a lay person, CASE has proceeded as best it could based on learning even the basic rules from scratch.
The'Comnission is aware of and recognized the difficulties faced by a volunteer intervenor. See Susquehanna, supra p. 2, at 336.
Much of the discovery time wP.ich would have been.available to CASE on Contention 5 was taken up with odler contentions the Board insisted on pursuing unnecessarily, for example, CASE's contention 25'on financial qualifications. On 10/19/81, CASE filed a joint motion with the Applicants to defer consideration of Contention 25 at the December 2, 1981 hearings due to the proposed rulemaking of the Commission. The Board went forward with the hearing. On 11/18/81, CASE answered the NRC Staff Motion for Summary Disposition on Contention 25. This entire period, including the time devoted in the hearings on December 2 to Contention 25 was wasted.
Another example is Contention 24 on cost benefit analysis. On 10/17/81, CASE filed its motion regarding Contention 24 asking that the Board defer consideration of this contention until such time as the final rule was promulgated or until it was apparent that the rulemaking would not be completed in a timely fashion. See
" CASE's Motion Regarding Contention 24" (October 17,1981).
Finally, there was Contention 22 on emergency planning. CASE repeatedly urged the Board to defer consideration of this contention because there was no plan.
j It was not until CASE filed a motion containing an affidavit from the State of Texas saying in effect that there was no emergency plan to litigate about did the Board finally decide not to hear the issue.See CASE's motion 10/16/81 B. The Elimination of Other Intervenors When this proceeding began there were three intervenors, twenty five contentions, and three Board questions. See Order Subsequent to the Prehearing Conference of April 30,1980 (June 16,1980). Hearings have been held on only one contention (financial qualifications). Now there is one intervenor, two contentions, and _
three Board questions. To a great extent, the other intervenors were driven out of this proceeding by the same obstructionist tactics in discovery that CASE has
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repeatedly complained of. See Affidavit of J. Marshall Gilmore attached hereto as Exhibit 1. When the other intervernors left, their contentions left with them.
The high attrition rate (66% for intervenors and 92% for conter.tions) has left CASE with the entire burden of providing an adverse case to Applicants and placed a higher burden on Contention 5 to be the source of such an adverse case.
C. Burdensomescheduling of Prehearing Deadlines In June 1981, Marshall Miller became the new chairman of the Licensing Board.
At that tine, there were numerous pending motions which the Board had not resolved.
See supra p. 4, 7/25/81 entry.
Chairman Miller set to work clearing the decks.See supra p. 4, 6/26/81, 7/25/81; 7/28/81; 8/3/81; 8/4/81; and 8/24/81. Chairman Miller clearly expressed his desire and intention to go forward in an expeditious manner under his firm control. Memorandum and Order (July 23,1981).
CASE's complaint is that the Board's nonentum under Chairman Miller carried it beyond the reasonable demands of timeliness and into violation of CASE's rights as an intervenor.
CASE is sympathetic to the perceived NRC need to proceed in an orderly and timely manner so operation of plants is not delayed. Statement of Policy on Conduct of Licensing Proceedings, CLI-81-8,13 NRC 452, 458 (1982). At the sane time, the Commission is committed to hearings that are " fair, and produce a record which leads to a high quality decision that adequately protects the public health and safety and environment." Icl. at 452. Of course, in any conflict between a plant being turned on and a fair hearing, the fair hearing comnitment would take precedence. To do otherwise not would ste only violate the due process of litigants but also give a strong indication of prejudgment harmful to the credibility of the Commission's licensing process.
In this instance, the plant in question is not scheduled for fuel loading -
until mid-1983, according to information the utility supplied to the 4/13/82 Caseload Forecast Panel meeting. A hearing on Contention 5 in August 1982 instead of June 1982 would not adversely affect the operating date, assuming a license is granted, but would provide a significant improvement in CASE's chance to produce a record leading to a high quality decision.
After a series of motions and rulings, the Board ended up exteking discovery requests on Contention 5 until May 7, filing of motions for sumary disposition until May 10, and responses' to sumary disposition motions until May 31 in a confereoce call on April' 22. At the same time, the Board held on to the June 7 date for the hearing on Contention 5.
CASE requested and received over 20,000 pages of material in discovery from Applicants over the period from April 22 until the close of discovery on May 7, except that we did not receive our last documents until May 21. Actually, CASE has not received all the documents requested, but CASE has not had time to file a motion to compel in order to get the remaining documents because the response toothe motion for sumary disposition and this motion took precedence.
After CASE was restored to independent status on Contention 5, CASE was told by Applicants that the permissible way to examine documents was for CASE to specify documents Applicants should copy and bring to :their Dallas offices for CASE review. CASE took a very limited approach to requests for review, asking only for documents which it had enough information about to know it probably wanted.
When discrepancies between typed and hand written documents as well as evidence of white out on certain copies appeared, CASE requested discovery at the site on original documents. The Applicants refused. CASE filed a motion with the Board requesting such discovery and the Board granted the motion. CASE's Answers to Applicants' Motion for Protective Order and CASE's Motion to Compel Discovery
( April 5,1982).
On Aoril 22, CASE began site discovery. The ability to request large numbers of documents for review which could be t;rought immediately changed the nature of
CASE's discovery. Examining far more documents than CASE intended to under the old Dallas-only system, CASE found far more material relevant to Contention 5. More than 30,000 pages of discovery are now in CASE's possession, most received within the last 30 days.
To analyze, understand, organizfe, and prepare these complex documents for presen-tation at the hearing is a mamoth task impossible to accomplish in the short time remaining.
On top of this load, the Chaiman, apparently using his discretion under 10 C.F.R. 2.711, changed the time for filing motions for sumary disposition set out in 10 C.F.R. 2.749(a). Under 2.749(a) motions for sumary disposition on Contention 5 would have been due April 23, 1982 and an answer due by May 13. Under the Board schedule, such mot. >ns were due May 10 with answers due May 31. CASE did receive an extension until June 2 to file the answers.
The Applicants therefore had more than the usual amount of time to file their sumiary disposition motion. CASE's time to respond was taken from the period immediately preceding the hearing date.
On May 11,1982, the Applicants filed a motion for sumary disposition to which CASE hau -o respond by June 2.
The Applicants' motion was 300 pages long.
With the organization of its case already an impossible task, the additional burden of responding to the motion for sumary disposition surpassed CASE's ability still further.
On May 21, CASE filed " CASE's Motion for Rescheduling Hearing on Contention 5."
This motion called the Board's attention to the matters set forth in this motion and requested the hearing on Contention 5 be rescheduled for August 9,1982.
On May 25, the Board denied this motion in a telegram which termed CASE's Motion " repetitious" and " dilatory". See telegram May 25, 1982.
CASE did answer the Applicants'sumary disposition motion with a response totalling mom than 800 pages. The composition and production of this response took a night and day effort for the entire twenty-two days given CASE by the
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Licensing Board.
In the course of preparing its response, CASE discovered two major deficiencies in the plant which CASE believes the NRC knew nothing about until CASE released its information.
(See Exhibit 2.)
The burdens placed on CASE by the scheduling of the hearing on Contention 5 are so great as to constitute a clear violation of CASE's right to due process of law.
Furthermore, CASE is the only intervenor left.
It will be up to CASE to carry the complete burden to argue failures on the part of the Applicants.
If CASE is inadequately prepared, the Licensing Board will have before it an incomplete record on this most important issue.
Whether the Board will preside over a true adversary proceeding or only over a hollow exercise depends on CASE's having the time necessary to respond to the Applicants' case and to present a substantive case of its own.
Finally, there simply is no need. for this rush. A hearing in August is not materially different to anyone but CASE unless the additional time is al.so beneficial to the Staff and Aoplicants.
IV. Conclusion For the above and foregoing reasons, CASE appeals to the Atomic Safety and Licensing Appeal Board in this proceeding to grant CASE the following relief:
(1) Three more weeks of discovery to permit follow-up questions on the last-minute answers received from the Applicants and NRC Staff, and (2) Five additional weeks to prepare for the hearing on Contention 5.
Based on the circunstances set out above, CASE considers this request for eight additional weeks to be reasonable and necessary. _ _ _ - _ _ _ _ _ _ _
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Respectfully submitted.
(bh
/J4rs.) Juanita Ellis, President VCASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 O
e CASE EXHIBIT 1 DEFORE ME, the undersigned authority, on this day appeared J. MARSHALL GILMORE, who after bein6 duly sworn and on oath deposes and says:
"My name is J. MARSRALL GILMORE and I am coordinator for CITIZENS FOR FAIR UTILITY REGULATION,
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"CFUR", and make this sffidavit on behalf of CFUR and from personal knowledge.
CFUR voluntarily withdrew from the licensing hearing, Docket Nos: 50-445 and 50-446, as an active intervenor party because of lack of financial resources.
CFUR throughout the early stages of the legal process attempted to utilize the civil discovery procedures available to it but found s,.
that due to the non-responsive attitude and tactics of both the NUCLEAR REGULATORY COMMISSION STAFF and the applicant, that those discovery procedures were inadequate to prove CFUR's case.
Consequently CFUR found it would be necessary to employ its own experts to recreate evidence supporting its case that should hav'e been available to it from the records, witnesses
.and other discoverable materials of the. Applicant.
Funds were not forthcoming for this expense and therefore CFUR was forced to withdraw any meaningful participation and leave its case unlitigated."
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J./ ARSHALL GILMORE
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SUBSCRIBED AND SWORN to before me on this_
f day of f/Lp dwn J1b,Sw
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1 FRONT PAGE DALLAS MORNING NEWS Thursday, June 3,1982 i
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Coman. c._. h.._e..._P_ _..eak fault c_i..ted _. i,'
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? Utility'failbd ioieport reactor crack in 1977 %
i By Bill Lodge NRC's possession show the crack is tion and depth of the crack men- '
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,only 1% inches deep and is located tioned in the records are mistakes
- staff wruer of na News
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SN982,7$e Da!!as Morping N' ws.,
in the upper-level radiation shield-in the owners' paper work.
c i.r' ing for the reactor.
Officials in the Texas Utilities i There is a crack in the concrete. A Experts say the size and location system have informed Citizens As-i work around the first nuclear reac-of the crack r.nd the way it was re-sociation for Sound Energy, inter-'.,.
. tor installed at the Comanche Peak paired will determine whether it is venors in the. licensing hearings.,
' power plant, according to records a safety hazard. A split of the base that they never reported to the U.S.
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. filed for the federallicensing hear-mat-the foundation on which the Nuclear Regulatory Commission : P j ings for the plant.
nuclear reactor sits - could be the discovery in 1977 of the base 1 One set of records from Texas dangerous, particularly if water mat crack. The Texas Utilities sys..j Utilities - which, through its sub. seeps in to corrode structural rein-tem includes Dallas Power & Light t sidiaries, owns 88 percent of Co-forcir.g steel, the NRC says, but a Co., Texas Power & Light Co. and d'
'{ manche Peak-indicates the crack shallow crack in the shielding Texas Electric Service Co.
- I is through the entire Afoot thick. Fould be of little consequence.
CASE, a frequent critic of the.I ness of the ba* mat holding the re- ! The NRC spokesman said that Texas Utilities groupJ obtained ;;.
actor. But officials of the U.S. Nu-they also have records showing a records on the quality of construe-. f.
clear Regulatory Commission said crack through the 7 foot thick base tion work at Comanche Peak in :4 ility company records in the met but that they believe the loca-See N PLANT on Page 6A.
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pf 6 A mrpalinoleraissisauf ' T'tursday, June 3,1982 f
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(J.' lyreparanon for feamt licensing hear-on t's cepth and locaMon otthe crack k
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were mistaken.
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tags schedaled, ta etsume Monday in That report guersted an angry re-t Fort Worth.T:,e licenoug process for
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sponse from Dahas based CASE, whose lhe plant which Texas Utilitsee hopes
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representat'ves said they w:lt ask led-30 templete try the sad of 1985, began $
- f' eral officials to determine the size and last December.
locction of creets possibly affecting Comanche Peak 14 under construc-s
. host naar Clen Rome. in Somervell '
- the safety of the reactor.
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y,, Canty lst,ont to allee southwest of.
CASE *pkaswortan Juanite' E!!k '.. !
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.g'OfficialsVthe Texas Utilities sys-
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said rties of the U1 Atomic 5atcy and e ae Icasieg Bwrd req.ure !? ant owners
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,ttegJtefused.to' answer.gaestions from fM7g to proMde CUE v4th couplete isJor-r1h4 Da:tas'Wonug Mrs abouithir mation ti a11 C42 questicna ccacert. -
l crack, conten.tlog that pubite discus -
r g the grafty of cor.struction tt Co-a merd.e Peas.
on of the taatter cowlf )sopardian 3,h.M"*J2 s
i Mrs. Elis said CASE had secuested h' their efforts to obtain an operat ng D.-
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q]* g j' all information on the repor*ed crack.
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The.otticials did issue'a*writtent, in the base met before the (L11ag dead.
lF"I,Q.kitbe con!nsion, repeating %at tg
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- N line of the 11ceng.ng board May 7, and -
,atement, tut.tbe satement'added
. had Psen proyued the report noting a s
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' 7. foot 4eep crack in the base mat. If the Pasin the bene n.at.i i
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- 1. ; "Two sertP.at shrin. age' cracks in'"
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. hformation provided toCEEist ccr-I tae Unit I cor.tainment base mat werel 3.)..
st'or incom]ilete, the onners,may
' have "withbald informatfen frcs as as -
. i$enttfted by construction quality <ond' y ttol personnel during a routine inspec,
D aneerw r,*1*rn Eh saldr****"" '
n" said the statement, lasned May;
~1 cannot ima jne tisem (Trams Ut:1-it w
j."Due to the location sad engineeru itieO puttirg in.em og that tnis is a 7-Pg *Pptication of this structure, the foot verticJ cracs withat6t first chect-cracks do not cr.ustitute a s_afetyprob*-- 'w"ra.-&sras found in M.e.Co" 8 She band.he odginal concrete pour -
n 4 thetan.sase,impm ingitsd th*Mrs.LaisVA.
9 clpm."
5 The owners would*not discuse w, T RJ.A'c hy.f manche 'Pe card-a detailed record of the pouring
,tpey did not report the crackpt the3J) ant.in 1977(, y, nuclear, pe,wer - fcr the tme omat is ide rIase mat to the NRC whenge crack. + *
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" lost'fromTexasUtra.tes ects.
k asfirstnotedin1977.~. i J 1IYss!'is'arppi.rtni from the top edge d' cs's that p!ans to place seaars en the Aut, she tiid, oner awfds inet-8 '
in a memorandum-dated Janek;t
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. ed.es of the crack - to prevent crato l 977,a qualitycsurance official for tha;; *his thfu." s U
- If etcee 14 trJe mat or the t.hfeld
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,Stown & Root lac. -- reported that on7. feet,5,yfrst said, Texas Uu"res' faind f wall had been cracked to a #pt c3 ' in the com: rete-were not comp i
,gril26,B77,hehad"found'a'verticalyto rehrt the probtfm te.1977 rouM WM9h.
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qrack that extended through the 7. foot-thick mat' naar the""tions. "completelf ' beve been a nastuu of NW reguts-
"You don 1 fool around with a t%-
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inc.Jerack for two years," Mrs, nits denter of its midspan acrosithe
- cavity sal 3.
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jftor the reactorvesseD." f EC ; f.(]ered s atricms pub'am ar.4 teeclot re-Bir*a'1%.tsch c ack is 3
. ! The memorandum also says: "Staceif quire a neport to the ga emment.*cy-thr> ugh either the base mat or shi
. We job specthcations do not.eddrerg fritsait.
v psi would pose aser%us problem.
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- Taa wall prodec " shielding frorn grocks relative to any acceptance crite. Seyfrit also said the NRQ( baia!
- pdlosctivity that is generate r;a, (quality,controll" generated a N
1pemoto fBrown & Root) Construction, recordsray;. lied 1y thee srs..ths the crack tr esa!'Is had es ghe re
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identifying the thation'and stating-Several engineers said a 7. foot crack i
that (qual *7 contal) would not allow,spector could sLstrhe a 1%.inct+ep ' ons
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day more.concretef.acements in thifi crack for see y krt c;ep, Seyfrit said;
( y, es until the desigtgangineerihad7J*Tbb ont structural steel. The mat is de:Igned to
- 7. t ean evaluatha." ^t $ f.hQ;tbat Jf yn are an inspectot'asd youf shlag tiat f can tell yss is, prevent mo Despite the Jana 3,1977, memo and ing an earthquake, expbek,n r,r other ltRCofficials maintain that the crack if fe'ownars' stay 27 written statement?, cra 3
s Texas Utilities ow.is more than 88 I % inches deep andislocated la radia@, Wing and yce 'ack ab.ag the side ofit and you see that the crack goes ath'# g percent of the nucitar tower plant
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jt on shielding located abovt the bow g wayto the botto:t,yven0ghtconclude 'TPht.andTESCOthrough three substdl.rte t
1bre two thirds of the reactor vessel,de7
--*;;@, ' 5 cribed as approximately40 feet hi N C;. that it was a cract that went allthe wsp 3
Other owners include Waco based KarlSeyfrtt,deputyadministrator.st% ally chipped outanyconcrete to exam g San t p,',
j yIa,mid the'affected' structure la"py-(~ thecractreallyis" e NRC regtesel office in Arlinf onJ ine f.tortbar tore what the depth of Power Cooperative of Texas inc* and, sdy a shield wall for the reactor venerb '. Seyfrit as5d the NRC has in its f+/' the Texas Municipal power Agency,'
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And it also provides a support for the,,i session a 1577 acgfmeeting repo's for of Bryan, Denton, which obtair_s electrtelty for the cities ccactor vesselDat is, the reactor w the owneru that shows initial rt ports ville.
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