ML20052B220
| ML20052B220 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/28/1982 |
| From: | Horin W DEBEVOISE & LIBERMAN |
| To: | Ellis J Citizens Association for Sound Energy |
| References | |
| NUDOCS 8204300181 | |
| Download: ML20052B220 (4) | |
Text
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LAW O F FIC E S O F DEB EVOIS E & O BERMAN 12 00 S EVENTE ENTN STREET,N.W.
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April 28, 1982 s
Mrs. Juanita Ellis Y
D Presi dent, CASE G
N 1426 South Polk Street Dallas, Texas 75224 g
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R OO I982b &
Subj:
Texas Utilities Generating Co;,
a et al.,
(Comanche Peak Steam 9
sonIky 3 mc Electric Station, Units 1 and 2)
Docket Nos. 50-445 and 50-446; t
Clarification of P.csponses to g
'g CASE's Ninth Set of-_ Interrogatories
Dear Mrs. Ellis:
This is to confirm the results of Applicants' telephone 3
conversation with CASE on April'27, 1982, concerning CAS2's requests for,further ihformation with respect to seven inter-rogatories posed in CASE's Ninth Set of Interrogatories to Applicants.
Specifically, by letter dated April 26, 7.982, CASE sought clarification of Applicants' answers to Interroga-tories 41, 75, 77, 99, 100, 154 and 157.
Set forth below is the information which we discussed.
As you indicated in our conversation, this additional information satisfies the requests made in your April 26 letter.
Interrogatory 41 As Applicants stated in our telephone conversation, the revised procedures supplied in response Lo' Item 42 of CASE's Ninth Set indicate on their face what revisions were made.
Each procedure includes vertical revision " bars" next to the text which has been amended.
However, to assist CASE in understanding the revisions, Applicants noted that the pro-cedure referenced in Interrogatory 39>vas revised with only minor administrative changes and the procedure referenced in Interrogatory 38 was revised by addition of the following paragraph:
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),r Mrs. Juanita Ell'is President, CASE April 28, 1982 Page two On a yearly basis the coordinator Vendor Evaluations / Audits will prepare an audit
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plan identifying all areas and elements which should be audited.
Input from key l
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project personnel will be solicited.
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This audit plan is to 1x3 developed.with-
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out considering available resources and shall be broken up into quarterly schedules.
From this plan a monthly schedule will be generated.
Changes to site procedures will be reviewed on an ongoing basis and utilized as input into this audit schedule.
The schedule will also reflect priority based on signifi-cance of activities.
Audits may be added or postponed on current site activities.
Interrogatories 75 and 77 As Applicants stated in our telephone. conversation, the question of whether a particular audit finding has a generic effect is examined ~in every audit.
If there is such an effect, it is discussed in the audit report, the audit response or the evaluation of the audit response.
All audits, audit responses and evaluations thereof referenced in Interrogatory 75 have been provided to CASE for inspection and copying.
Applicants have not, however, compiled a list or otherwise separately identified the audits where such effects were found.
Accordingly, to provide a listing of those audits would require a review of each audit,. audit response and evaluation.
Thus, the information is not available without performing substantial research.
In view of these facts, you indicated that no additional information need be provided in response to Interrogatories 75 and 77.
Interrogatory 99 and 100 As Applicants stated, the answer to Interrogatory 99 should be "Yes."
The additional information in our original response is for CASE's benefit.
Also, this clarification negates the need for additional informatien in the' response to Interrogatory 100.
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Mrs. Juanita Ellis President, CASE April 28, 1982 Page three 1
l Interrogatory 154 As Applicants stated in our telephone conversation, the procedures referenced in Applicants' response to this Interrogatory identify, by title, the person who has this responsibility.
As we indicated in our telephone conversation, the individual who presently holds that position is David N.
Chapman.
Interrogatory 157 As with Interrogatory 154, the procedures referenced in Applicants' oricinal response to this Interrogatory identify, by title or description, the persons who may exercise this authority. */
As we agreed in our telephone conversation, the names oY those individuals are provided below.
Procedure CP-QP-16.0, Paragraph 3.1.5.1 of the TUGCO
" Quality Procedures Manual", states that the QC Supervisor or his designec may void NCR's.
The persons who currently fill QC Supervisor positions are, as follows:
/
Bob C.
Scott - QA/QC Supervisor - General Tom B,randt - QA/QC Supervisor - Mechanical / Civil There are no specific individuals who serve as a " designee" of these persons.
Procedure CP-QAP-16.1, Paragraph 3.2.1.3 of the Brown &
Root "ASME QA Procedures Manual", states that the QC Super-intendent/ Lead, Quality Engineers or positions above those can void NCR's.
Listed below are the persons who currently fill those positions:
- /
As was noted in our telephone conversation, the procedure
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CP-QAP-16.1, referenced in the responce to Interrogatory 156, should be identified as being from the Brown & P.oot "ASME QA Procedures Manual," which has been made available to CASE.
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o Mrs. Juanita Ellis President, CASE April 28, 1982 Page four Doug Sanders John Morton Ron Washington Jim Ragan Ron Meissner Prem Lahoti Don Lattimore Gordon Purdy J.P.
Patton Danny Leigh Greg Bennetzen Bethel Lloyd Donnie Doyle Pat Ashcraft Billy Snellgrove Virginia Wasinger Richard Ice Richard Wheeler George Willis Sincerely, i
(U b.
William A. Horin Counsel for Applicants f
Overnight delivery cc:
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