ML20114B659

Confirms That Documents Responding to Intervenor Third Set of Interrogatories & 850104 Request for Production of Documents Located in Same Room w/840214 & 1228 Responses & Util Objections.Svc List Encl.Related Correspondence

ML20114B659
Person / Time
Site:	Hope Creek
Issue date:	01/23/1985
From:	Fryling R Public Service Enterprise Group
To:	Thurber J NEW JERSEY, STATE OF
References
CON-#185-275 OL, NUDOCS 8501290403
Download: ML20114B659 (15)

Text

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• . RELATED CORRESPONGENC2

PSEGE9 6.' AILING ADDRESS / P O Box 570. Negrry, f;J 07101 83 Park P6za. No., ark, NJ 07101/ 201430 64r5 Richard Fryling, Jr. Assziate General S %utor T5E ..-

V :28 January 23,1985 John P. Thurber, Esq.

Assistant Deputy Public Advocate State of New 3ersey Department of the Public Advocate Division of the Public Interest Advocacy CN 850 Trenton, New Jersey 08625 Re: In the Matter of Public Service Electric and Gas Co., et al.

(Hope Creek Generating Station)

Docket No. 50-354-OL

Dear Mr. Thurber:

In order to avoid any further misunderstandings concerning availabilit of documents, this will confirm that the documents in response to Interv Set of Interrogatories and Request for Production of Documents to Applic dated January 4,1985, served by deposit in the United StatesSet) mail, are av review in the same room as the documents provided on February 14,198 and December 28,1984 (Second Set). As in the past, please advise as to when you desire to schedule your attendance in order that proper accommodation made.

In response to the Board's order overruling our objections h to the t set,I am enclosing for service upon you those respons we objected.

a available as indicated above.

Very tr yours r, .

Richard Frylin , 3 RF:mbb CC Service List 8501290403 850123 PDR ADOCK 05000354 PDR g \

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3rd NJ PUBLIC ADVOCATE INTERROGATORY Page 12 Question 6 Identify all documents in your possession relating to allegations or reports of records falsification by Authorized Nuclear Inspectors (ANIS).

The following documents were identified as relating to a report of falsification of an Authorized Nuclear Inspector's (A.N.I.)

initials.

a) Office Memorandum, dated 6/29/82, reply dated 7/2/82, from E. Eirikis, A.N.I. of Hartford Steam Boiler to A. J. Bryan, Project Construction Quality Control Engineer.

b) Entry in the bound diary maintained by the A.N.I. Entry dated 6/29/82.

c) NRC Inspection Report No. 50-354/84-10.

3rd NJ PUBLIC ADVOCATE INTERROGATORY Page 12, Question 7 Identify all steps taken by PSE&G or Bochtel in response to the allegation of records falsification by a soils testing technician employed by GEO Construction Testing, Inc. as referred to in your response to Interrogatory 12(f).

RESPONSE

The following documents were identified as relating to an allegation of records falsification by a soils testing technician employed by GEO Construction Testing Inc.:

a) GEO Construction Testing Inc. letter to Bechtel CLB-204, dated October 10, 1984. Subject is " Technician Termination and Quality Evaluation."

b) Bechtei letter to GEO Construction Testing Inc., BLC-311, dated October 15, 1984. Subject is " Technician Rehire."

c) GEO Construction Testing Inc. letter to Bechtel CLB-205, dated October 18, 1984. Subject is " Technician Testing Deviation."

3rd NJ PUBLIC ADVOCATE INTERROGATORY Page 15, Question 19 Identify and describe each " recurring deficienc(y)" identified by the formal trend analysis program established to monitor the construction of Hope Creek, as referred to in your response to Interrogatory III.24. For each such recurring deficiency so identified, identify and describe all corrective action initiated as a result.

Attached is a QA Trend Summary indicating the identified trend number (column 1), description of the potential trend (column 2),

whether the potential trend was an actual trend (column 3) and the action taken by referencing the pertinent documentation (column 4). The referenced documentation is attached when a trend was identified.

s 3rd NJ PUBLIC ADVOCATE INTERROGATORY Page 15, Question 20 Identify and describe each recurring problem identified by the Nonconformance Report trend analysis program performed by Bechtel Quality Assurance Engineers assigned to the Hope Creek jobsite, as referred to in your response to Interrogatory III.24.

For each such recurring problem identify and describe all corrective action initiated as a result.

This question was responded to within the response to question 19.

There'is no differentation. Any recurring deficiency is evaluated and if a trend is determined to exist, thoroughly investigated.

Question 19 respense explains this process.

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3rd NJ PUBLIC ADVOCATE INTERROGATORY Page 15, Question 21 List t nd identify each " trend" identified as a result of all inves,igations of " potential trends" identified from the periodic reviews of the " trend analysis log" of all validated NCRs, as referred to in your response to Interrogatory III.24.

For each such trend, identify by date and describe all requests for corrective action issued as a result.

See response to Question 19. Columns 2 and 3 of the QA Trend Summary identify each trend and column 4 of the QA Trend Summary identifies the applicable documents describing the corrective action taken.

THIRD SET OF INTERROGATORIES MANAGEMENT COMPETENCE INTERROGATORIES A

SECTION III, ITEM 49 DESCRIPTION: H List and describe all " recurring failures or problems" identified as a result of the "[t] rend analysis of periodic preventative maintenance, corrective maintenance and surveillance testing activities" referred to in your response to interrogatory III,

29. For each such failure or problem so identified, list and describe all corrective action taken as a result.

RESPONSE

See response to Interrogatory III.38.

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r-l PUBLIC ADVOCATE THIRD SET OF INTERROGATORIES III MANAGEMENT COMPETENCE

50. List and describe all the "(i)ndustry operating experience" that has been evaluated and found to be potentially applicable to Hope Creek, as referred to in your response to Interrogatory 111.29. State '.10w each is or will be applicable to Hope Creek.

RESPONSE

See Evaluation Completion Report being provided with response to Request for Production of Documents.

THIRD SET OF INTERROGATORIES MANAGEMENT COMPETENCE SECTION III, ITEM 59 l

59. Identify and describe all alleged problems identified by site personnel under the " Safe Team program" referred to in your response to Interrogatory 111.40.

RESPONSE

See documents provided with response to Request for Production of

. Documents.

III. MANAGEMENT COMPETENCE: INTERROGATORIES

67. Identify each instance in which PSE&G has requested an extension of time from the NRC within which to complete its obligations under the May 6, 1983 NRC Confirmatory Order. For each such instance, identify (a) the date of the request; (b) the obligation involved; (c) the rea.5on for the request; (d) the NRC's response; and (e) all documents related to this request and the NRC's response.

RESPONSE

By letter dated November 14, 1983, PSE&G requested that the May 6, 1983 Confirmatory Order for Salem Generating Station Units 1 and 2 be amended by incorporating a revised schedule for completion of Corrective Action Program Item C.8.a.4 (Managed Maintenance Program). This Item, originally scheduled f or January 198 4 completion, was found to be unachievable in light of the magnitude of effort required to fully research every safety-related component and the attention to detail required to ensure accuracy in the' development process.

A staged completion schedule was proposed whereby PSE&G would incorporate certain critical safety-related systems and components into a Managed Maintenance Program by February 28, 1984, and complete the development of the Managed Maintenance Program for all safety-related systems and components by June 30, 1984.

By a Mocification of Order dated January 31, 1984, the Nuclear Regulatory Commission granted the requested extension of the completion date for Item C.8.a.4 of the .

3 PSE&G Corrective Action Program.

Documents related to the request and NRC Response are as follows:

November 14, 1983, PSE&G request for amended schedule for completion of Corrective Action Program Item C.8.a.4.

January 31, 1984, Varga to Uderitz letter of transmittal for Modification of Order Dated May 6, 1983.

January 31, 1984, Modification of Order Dated May 6, 1983.

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. . l SECTION III. MANAGEMENT COMPETENCEs INTERROGATORIES INTERROG?- ?ORY #68: State the total number of person / days you have estimated were required to complete all Action Plan Items in 1 the PSE&G Plan for the Improvement of Nuclear Department '

Operations. List the percentage of this total that was scheduled to to applied and the percentage of this total that was actually applied by (a) June 30, 1983; (b) December 31, 1983; (c) June 30, 1984; and (d) December 31, 1984.

RESPONSE: Manday information for the PSE&G Plan for the Inprovenent of Nuclear Department Operations is provided in the following Documents:

PSE&G Action Plan Monthly Status Reports (previously provided in response to the December 14, 19R4 Interrogatory III.17.)

PSE&G Action Plan Manhour graph. (Attached) s 1

SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES Page 2 - #68 6

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SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATURY 969: Identify all changes in expected completion dates for all Action Plan Items. For each, identify (a) the date of the change; (b) the reason for the change; and (c) all documents related to this change.

RESPONSE: Changes in expected completion dates for all Action Plan items are identified in the following docunents:

Action Plan Sponsor's Weekly Status Report (PSE&G Action Plan - General Infornation)

Manhour and Schedule Sunnary (PSE&G Action Plan - General Infornation)

PSE&G Action Plan Weekly Reports PSE&G Action Plan Status - Fonthly Reports All of these documents were previously provided in response to the Decencer 14, 1984 Fequest For Documents IV.S.

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e SECTION III. MANAGEMENT COMPETENCE: INTERROGATORIES INTERROGATORY 470: Identify by name and job title all persons assigned to comple :e tasks included in any Action Plan item. Por each such person, also identify all non-Action Plan responsibilities assigned to that person.

RESPONSE: All persons assigned to complete tasks included in any Action Plan item were previously identified in response to the December 14, 1984 Interrogatory III.16, PSE&G Action Plan Task Forces.

All non-Action Plan responsibilities assigned to each person are identified in the Hope Creek FS AR , Chapter 13, which has been previously provided.

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e SERVICE LIST 1

Marshall E. Miller, Esq. Atomic Safety and 1 Chairman Licensing Appeal Panel i Atomic Safety and U.S. Nuclear Regulatory  ;

Licensing Board Panel Commission U.S. Nuclear Regulatory Washington, DC 20555 I Commission l Washington, DC 20555 Dr. Peter A. Morris Atomic Safety and Atomic Safety and Licensing Board Panel Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Dr. David R. Schink Docketing and Service Section Atomic Safety and Office of the Secretary Licensing Board U. S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Lee Scott Dewey, Esq Richard E. Shapiro, Esq.

Office of the Executive Susan C. Remis, Esq.

Legal Director State of New Jersey U.S. Nuclear Regulatory Department of the Commission Public Advocate Washington, DC 20555 CN 850 Hughes Justice Complex Trenton, NJ 08625 Carol Delaney, Esq. Mark J. Wetterhahn, Esq Deputy Attorney General Conner and Wetterhahn Department of Justice 1747 Pennsylvania Ave., N.W.

State Office Building Washington, DC 20006

-8th Floor 820 N. French Street

. Wilmington, DE 19810 t , . . . - - . . - . -