ML20211M862
| ML20211M862 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/08/1986 |
| From: | Gad R, Tyler T ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#486-1893 OL, NUDOCS 8612180067 | |
| Download: ML20211M862 (40) | |
Text
c.
j!) H Filed: DIcambar 8, 1986.
- ELA1ED COnfttstenagggg DCLKETED UNITED STATES OF AMERICA U5NHr NUCLEAR REGULATORY COMMISSION ,
before the ATOMIC SAFETY AND LICENSING BOARD [0C E' bi Vk N edANL"
)
In the Matter of )
) Docket Nos. 50-4 4 5 -Od-TEXAS UTILITIES ELECTRIC ) 50-446 64-COMPANY et al. )
) (Application for an (Comanche Peak Steam Electric ) Operating License)
Station, Units 1 and 2) )
)
APPLICANTS' ANSWERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (Set No. 8)
Pursuant to 10 C.F.R. sec. 2.740 ff., the Applicants hereby submit their responses to CASE's "CPRT Discovery -
Set No. 8," served by ordinary mail on September 18, 1986.
Instructions The Applicants have ignored the instructions contained in the paragraphs labelled "A" through "F," inclusive, as contained in the document entitled "CPRT Discovery a
Instructions" under the heading " Instructions" (pages 7-10), insofar as the same are contrary to the Rules of Practice.
Desian By agreement of the parties, and with the concurrence of the Board, matters regarding the adequacy of design b503
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-aspects of the CPRT Program Plan have been excluded from the matters in respect of which the Board authorized discovery on August 18 and 19, 1986. Consequently, the Applicants have limited their answers to these interrogatories to matters other than the design adequacy aspects of the CPRT Program Plan.
Interrocatories Interroaatory No. 1:
Was the problem with the Unit 1 heating, ventilating and air conditioning cable tray supports identified under the CPRT program (Transcript, p.5)?
- a. If yes, identify the (portion) of the CPRT in which the problem was discovered, the procedures under which it was discovered, and the circumstances surrounding the decision to issue a 50.55 (e) report.
- b. To what extent, if any, will the HVAC problem be evaluated by the CPRT program for root cause or generic implications and/or considered in the collective evaluations, c.
Is the " sampling program" referred to by Mr.
Counsil on page 7 or the Transcript a CPRT program? If not, what sampling program is he referring to?
- d. Who is Mr. Counsil referring to in his statement "we physically reinspected 60 packages ourselves."
(Tr.Ln.16-17)
- e. Who and what is Mr. Counsil referring to in his statement on Line 20-21, that "we believe at this point the balance of the program on Unit 2 is satisfactory in their proceedings.
. Obiection:
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' l The Applicants object to this interrogatory on the ground that, insofar as this interrogatory relates to actions being taken under or in respect of the Design Adequacy Program, it is, for the reasons set forth above under " Design," beyond the scope of the matters in respect of which discovery was authorized by the Board on August 18 and 19, 1986. The Applicants further object to this interrogatory on the ground that, insofar as it does relate to the CPRT Program, it seeks information developed during the implementation of the Program, and is thus beyond the scope of the matters for which this discovery was authorized by the Board on August 18 and 19, 1986. The Applicants further object to this interrogatory on the ground that, insofar as it relates to CPSES Project activities, the information called for is not relevant to the adequacy of the CPRT Program Plan, and is thus beyond the scope of the matters for which this discovery was authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, it was discovered at approximately the same time both by the CPRT Action Plan VII.c reinspections and the CPSES Project. With respect to the former, the Action Plan VII.c reinspection of this
population of supports revealed deviations between the as-designed supports and the as-built supports. With respect to the latter, the Project was receiving as-built drawings a from Bahnson, the prime contractor for HVAC. A cross-check of those supports against the stress analysis for seismicity on the HVAC system showed some discrepancies between the stress packages and the as-built drawings.
Investigations of the discrepancies ensued.
- a. Action Plan VII.c. The decision to issue a report under 10 CFR sec. 50.55(e) is not a CPRT responsibility. That decision was made and the report filed by the Applicants as the holders of the Construction Permit.
- b. Please see Program Plan, Appendix E. Since the deviations were deviations, at a minimum they will be data for the collective evaluation process. Should the deviations be classified as deficiencies cnr an adverse trend, then a root cause and generic implications assessment will be made.
- c. No. The sample inspections were undertaken by CPSES Project; the nature of the sample program is described in the transcript.
- d. CPSES Project QA/QC.
i
- e. The "We" is Mr. Counsil. The " balance of the
-4 -
s.
program" is the remaining stress reconciliation effort for Unit 2 HVAC supports.
Interrocatorv No. 2:
Are the EBASCO Quality Control teams referred to on Tr. page 9 CPRT inspection teams governed by the CPRT program, or CPSES project personnel under the supervision of TUGCO QA management (Tr. pp. 8-10)? -
- a. If the answer to the above question is that the EBASCO effort is being done under the CPRT, identify the procedures used for training each of the teams, the procedures the inspectors were trained to, and which EBASCO personnel (including consultants and job shoppers) are involved who worked at the Comanche Peak site at any time prior to May 1985.
Obiection:
The Applicants object to this interrogatory on the ground that, insofar as this interrogatory has any relationship to the CPRT, it relates to activities being conducted under the Design Adequacy Program and is, for the reasons set forth above under " Design," beyond the scope of the matters in respect of which discovery was authorized by the Beard on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, we do not see a reference to "EBASCO Quality Control teams" in the cited pages. The inspection to the computer aided designed (CAD'd) as-built drawings is being done by TUGCO QA/QC personnel.
l
4 Interrocatorv No. 3:
Identify all documents used by and prepared during the
" experienced engineers walkdown" that was conducted in November 1985.
- a. Identify all persons who participated in the walkdown (p. 11).
- b. To whom is Mr. Klause referring on Tr. p. 11, line 12-14, when he stated that "we are reviewing those observations to determine what action is required by the project and TUGCo?
- c. Was the " engineers walkdown" conducted under the CPRT program?
- d. If not, will the findings of the walkdown be considered by the CPRT in any way?
- e. If the findings of the walkdown are considered by the CPRT, identify in what phase and under what procedures the findings will be considered.
Obiection:
The Applicants object to this interrogatory on the ground that, insofar as this interrogatory has any relationship to the CPRT, it relates to activities being conducted under the Design Adequacy Program and is, for the reasons set forth above under " Design," beyond the scope of the matters in respect of which discovery was authorized by the Board on August 18 and 19, 1986. The Applicants further object on the ground that, insofar as this I
interrogatory relates to CPRT, it calls for information obtained or in the process of being obtained during the i
- implementation of the CPRT Program, and is thus beyond the i
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scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the documents referred to will be contained in the Working File for DSAP IX at such time as that Action Plan is completed,
- a. The personnel were Stone & Webster personnel.
b.- Stone & Webster.
- c. Yes, as set forth in DSAP IX. The "walkdown" is a part of the piping and pipe support corrective action program being performed for the Project by SWEC, and subject to CPRT overview.
- d. See above.
- e. See above.
Interrocatorv No. 4:
Identify all instances where procedures were required to be modified to give the engineers more specific instructions in the reanalysis effort (Tr. p. 11, Ln 15-19).
Obiection:
The Applicants object to this interrogatory on the ground that, insofar as this interrogatory has any relationship to the CPRT, it relates to activities being conducted under the Design Adequacy Program and is, for the
s.
reasons set forth above under " Design," beyond the scope of the matters in respect of which discovery was authorized by the Board on August 18 and 19, 1986. The Applicants further object on the ground that, insofar as this interrogatory relates to CPRT, it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the procedures referred to are the "CPPP" procedures of which copies have already been provided to CASE.
Interrocatorv No. 5:
Explain, in precise details, what the " major generic technical issues tentatively resolved" are (Tr. p. 12, Ln 6-10). Define the steps that must be completed and the criteria and/or procedures used for " tentatively resolved" issues to become finally resolved.
Obiection:
The Applicants object to this interrogatory on the ground that, insofar as this interrogatory has any relationship to the CPRT, it relates to activities being conducted under the Design Adequacy Program and is, for the reasons set forth above under " Design," beyond the scope of l
the matters in respect of which discovery was authorized by the Board on August 18 and 19, 1986. The Applicants further object on the ground that, insofar as this interrogatory relates to CPRT, it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, please see the " Generic Technical Issues Report" dated 6/27/86, of which a copy has already been provided to CASE. Also see Applicants' 9/5/86 Response to CASE's Interrogatories of 7/29/86.
Interrocatory No. 6:
Identify the person or persons who were included in the process of determining that it was necessary to replace Monty Wise in order to get a " completely fresh look" at the testing area, as described on page 12.
Answer:
I The determination was made by the SRT, acting collegially and collectively.
Interrocatory No. 7:
Explain in precise terms what Mr. Beck meant by his statement on page 12, in 3-8 that:
l "As that particular discipline was explored over the
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past year, SRT determined that we simply did not have
, a strong enough Third-Party flavor. The cleanest way to do that was to have a new set of eyes and a new .
mind to evaluate all the areas associated with testing,..."
Include in your explanation why a stronger " Third-Party flavor" was needed and in what way the existing system did not meet this need.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the quoted language does not employ any terms with specialized meanings, apart from
" third-party," as to which see our response to Interrogatory No. 2 of CASE's CPRT Discovery - Set No. 2.
At the time that Action Plans were reviewed in connection with the publication of Rev. 3 of the Program Plan, a judgment was made that, both historically and because of the nature of testing, much of the investigations and analysis work that had been accomplished to date had depended heavily on input from CPSES Project personnel. (An exception was Action Plan III.d.) In order to insure that CPRT conclusions, and the data on which they were based, could be defended by CPRT, the SRT determined that a " fresh look" should be taken at what had been accomplished to date and that, wherever appropriate, additional work should be done by CPRT to insure
" ownership." This judgment had nothing to do with Mr.
Wise. However, because Mr. Wise had been the Review Team Leader for Testing since the publication of Rev. 1 of the Program Plan, the SRT felt that he was possibly less able to take a " fresh look" than someone else might be.
Interrocatory No. 8:
Describe, in precise detail, the changes made to the Safety Significance Evaluation group around the time period of the Feb. 6, 1986, meeting.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
l Without waiving the foregoing objection, but rather expressly relying upon the same, the change referred to was the addition of a senior-level manager in the safety significance evaluation area. It had become clear to the i
0 SRT, strictly from a managerial standpoint, that additional and~ higher level attention was required for the management of the SSEG function.
Interrocatory No. 9:
Explain the reason that it was necessary to add a senior level manager to the SSEG group.
Resconse:
The Applicants incorporate their response to the foregoing interrogatory.
Interrocatory No. 10:
What comments did Mr. Hansel receive from NRC staff (either TRT or Region) about the effectiveness and adequacy of the SSEG effort?
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, Mr. Hansel recalls no such comments from NRC Staff on "the effectiveness and adequacy of the SSEG effort".
Interrocatory No. 11:
Identify all conversations between NRC staff members and Mr. Hansel, Mr. Beck, Mr. Counsil, or any other management personnel in which the SSEG was discussed.
- a. -For each conversation identified above identify the date, place, participants,
- b. For each conversation identified above identify all documents prepared during or after the meeting reflecting the comments of the NRC regarding the SSEG.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, none.
Interrocatorv No. 12:
Identify and produce the " log" referenced on page 15 for logging the changes to the ISAPs.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
1 Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the document in question is contained in the CPRT Central File, which has previously been made available for inspection by CASE.
Interroaatory No. 13:
Describe the criteria used by Mr. Terry Tyler to determine whether a change to an ISAP is minor or substantive, and identify all procedures or written documents that describe or govern this determination.
Answer:
Please see CPRT " Policies and Guidelines" PAG-01.
Interrocatory No. 14:
Identify the person or persons who are responsible for the. determination of whether an ISAP change is substantive or minor, and identify all procedures or written documents that describe or govern this determination.
Answer:
The RTL. Please see PAG-01.
Interrocatory No. 15:
Explain, in precise detail, the revision added to ISAP VII.A.2 for reviewing the technical adequacy of NCR dispositions (Tr. p. 23).
- a. Identify the procedures developed to implement the revision.
i b. Identify and explain the basis for the revision of the ISAP.
Answer:
j The revision "added" is in writing and speaks for
I itself. It is not understood what further explanation is requested.
- a. The procedures developed during the implementation of Action Plan VII.a.2 will be contained in the Working File for the Action Plan and made available for inspection at such time as that Action Plan is completed.
- b. A judgment was made by the RTL, with which SRT concurred, that completeness required a review of the technical adequacy of the disposition of NCRs (in addition to the review of the adequacy of the procedural program for the initiation and processing of NCRs already contained within the scope of the Action Plan).
Interrocatorv No. 16:
Identify the internal concerns referred to by Mr. Beck on Tr. p. 28.
- a. For each concern identified above provide the details of how the concern was brought to the attention of Mr. Beck, and what specific portions of the CPRT program were involved.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
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Without waiving the foregoing objection, but rather expressly relying upon the same, the concerns are identified in the. transcript referred to. Please see also the minutes of the SRT meeting of 1/8/86 and 1/9/86 and "SRT Sub-committee Report on Quality of CPRT Hardware Inspections," both of which are contained in the CPRT Central Files, which have previously been made available for inspection by CASE.
Interrocatory No. 17:
Produce all documents developed during the course of the investigation and/or audit of the QOC program, including but not limited to all notes of interviews of any persons interviewed and all analysis of those interviews and any other information gleaned during the investigation or audit. (This answer should include all information, in precise detail, developed or discovered during the investigation or audit about the quality instructions, including listing the procedure and the revision number or the procedure.)
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery i
authorized by the Board on August 18 and 19, 1986.
I Answer:
Without waiving the foregoing objection, but rather l
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( ._ . _ _ _
expressly relying upon the same, all such documents are contained in the CPRT Central Files, which have previously been made available for inspection by CASE, or will be contained in the Working File for Action Plan VII.c and made available for inspection at such time as that Action Plan has been completed.
Interrocatory No. 18:
Identify the individuals who participated in the retraining or " hand-in-hand exercise walkdown of QI's" referred to on Tr. pg. 29.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, all such documents and i
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information is or will be contained in the CPRT Central Files, which have previously been made available for inspection by CASE, or will be contained in the Working File for Action Plan VII.c and made available for inspection at such time as that Action Plan has been completed.
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Interroaatorv No. 19:
Explain in detail what is meant by the phrase
" accuracy and completeness" as used on p.30, Lines 12-15.
Answer:
The terms were employed in that passage with their ordinary English meaning. It is not understood what further explanation is requested.
Interroaatorv No. 20:
In reference to the stop work order, identify which ISAPs or portions of ISAP work was actually stopped, when work was actually stopped, and when it began for each ISAP.
- a. Produce the stop work order instructions or other documents directing personnel at all levels to stop work.
- b. Produce the documents directing personnel at all levels to restart work.
- c. Produce all documents in which the decisions to stop and/or restart work were discussed and/or made.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same: Action Plan VII.c; January
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t
8, 1986; January 24, 1986.
a.-c. Please see the minutes of the meetings of the SRT for 1/8/86 and 1/9/86, and the 2/6/86 NRC CPRT status meeting transcript at 30 lines 19 and 20 which are contained in the CPRT Central Files.
Interrocatorv No. 21:
Identify all cases in which "backfit" of the implemented CPRT work would be required as referenced by Mr. Tyler on Tr. p. 31, Line 7.
- a. For each case in which backfit was anticipated if Rev. 3 was approved as written, identify the ISAP, the objective, and/or the specific portion of the CPRT which was anticipated to require backfit as of February 6, 1986.
- b. Explain, in precise details, Mr. Tyler's statement that the backfit would be "mainly in the area of how you categorize findings that come out of the program..."
- c. Explain, in precise detail, Mr. Tyler's statement that the backfit will impact "how you go through and do evaluation for root cause generic implications..."
- d. Explain, in precise detail, how the backfit would affect the method for overview of corrective actions by the CPRT.
- e. Describe in detail the actual implementation of these backfits and identify all documents directing the backfit, all documents reflecting the changes caused by the backfit, including procedures and training manuals, and all documents reflecting the changes in implementation of the CPRT as a result of the backfit.
Obiection:
The Applicants object to this interrogatory on the
ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and'19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the cases are described in the transcript portions referred to, as is a description of what is meant by the term "backfit." The changes in question all referred to utilization of the classification procedures contained in Program Plan, Appendix E, and the corrective action procedures contained in Program Plan, Appendix H.
Interrocatory No. 22:
Explain why "the additional steps to the Action Plan" referred to by Mr. Tyler don't impact the status of the CPRT.
Answer:
The question has truncated what was said. What was said was that these additional steps " don't impact the status as wg gave 11 12 vou today." Tr. 31 (emphasis used to indicate material elided by the interrogatory). The reason for this is furnished in the next sentence of the same transcript: "We took that into account in the status as we gave it to you today." Id.
v \
e Interroaatorv No. 23: ,
-For each situation identified in response to question 21 above identify whether Revision 3, if approved as written in February 1986 would requira expansion of work already finished'or doing the CPRT, or any part of it, over again. '
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Obiection:
The Applicants object to this interrogatory, on the ground that what might have been required of a resu ts >
report under a prior revision of the Program Plan is ;not \ >
relevant to the adequacy of the current revision, and this interrogatory is therefore beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without daiving the foregoing, objection, but rather expressly relying upon the same, al? results reports ~
published to date have been published subsequent 'to' the s publication of Rev. 3 and therefore subject to its \
requirements. Whether any additional work would have been required had (i) the results reports been pubiished earlier and (ii) had Rev. 3 been published earlier is, therefore, a speculation.
The difference in Action Plan tasks can be obtained by comparing the Action Plans as published under ~
Rev. 2 of the Program Plan with the Action Plans as published under Rev. 3 of the Program Plan plus Appendices N
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,E a,dd H of Rev. 3 of the Program Plan. All steps' required
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unde {Rev. 3 of the Program Plan, including appendices,
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were,-in fact taker prior to the publication of all Results V
Reports. El'4ase see our response to Interrogatory No. 3 of
) ,\
CAS "CPRT Discovery - Set No. 3."
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(' y , E 's' Interrocatory No. 24:
\
'J ' . lI f' ,'on pg. den 32,.line ify and produce the audit described by Mr. Hansel 10-11.
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Obiection: r I
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- The Appl.tcants object to this interrogatory on the
,k _ ground that it calln for information obtained or in the t ,
s CY proc'iri of being'obtained during the implementation of the a
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CfRT Prcgram, and is thus beyond the scope of the discovery p
., authorized by the Board on August 18 and 19, 1986.
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! I' A' Without waiving the foregoing objection, but rather T'
expressly relying upon the same, the document is entitled
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" Audit ERC 96-01". It will be contained in the CPRT Working File .' associated with the Quality of Construction r
Program;and will be available for CASE's inspection at such 8
.. time as that Program is complete.
l vInterrocatorv No. 25:
s Identifyiand produce the " proposed Action Plan" that i '
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Mr. Hansel referred to on Tr. p. 32, line 12-13.
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The Applicants object to this interrogatory on the ground that it calls for information.obtained or in the processofbekngobtainedduringthe-implementationofthe
- 1 CPRT Program, and is thus beyond the scope of the discovery aut orized by the Board on August 18 and 19, 1986.
Ansver:
Without waiving the foregoing objection, but rather
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expressly relying upon the same, the " proposed Action Plan" referred to corrective actions to be taken to resolve t
" Audit ERC-86-01 ". It will be contained in the'CPRT s ,
Working File associated with the Quality of Construction
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Program and will be available for CASE's inspection;at such
, time as that Program is cor.plete.
Interroaatorv No. 26: ,s Identify all documents prepared in the review of the safety significant evaluation described by Mr. Hansel on Tr. p. 32.
Obiection:
The Applicants object-to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather t
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P .
t expressly relying upon the same, the documents will be contained in the Working File for Action Plan VII.c and available for CASE's inspection at such time as the Results Report for that Action Plan has been approved and published by the SRT.
Interrocatory No. 27:
Identify the person or persons who participated in the review of the quality instructions.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986. The Applicants further object on the ground that the identity of individuals performing tasks under the CPRT Program Plan is irrelevant to the adequacy of the Program Plan and this interrogatory is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without. waiving the foregoing objection, but rather l expressly relying upon the same, the identity of the persons who reviewed and approved the QIs appear on the signature page of each QI; the QIs have already been l
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provided to CASE.
Interroaatorv No. 28:
Identify the procedures and describe in precise detail the process used to do the review of the instructions.
Answer:
Please see CPP-001.
Interroaatory No. 29:
Identify the nine inspectors conducting the "over inspections" referred to on Tr. pg. 33, line 21-24.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the
- CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986. The Applicants further object on the ground that the identity of individuals performing tasks under the CPRT Program Plan is irrelevant to the adequacy of the Program Plan and this interrogatory is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather I
expressly relying upon the same, the identity of those inspectors will be contained in the Working File for Action Plan VII.c, which will be available for CASE's inspection
(
at such time as the Results Report for that Action Plan has been approved and published by the SRT.
Interroaatory No. 30:
Identify the CPRT procedure or procedures used by the inspectors to do the over inspections.
Answer:
Please see ERC-QA-28.
1 Interrocatorv No. 31:
Identify which ISAPs or portions of ISAP/DSAPs or the self-initiated inspection is covered by over inspections.
Answer:
Action Plans VII.c and VII.b.3.
Interroaatorv No. 32:
Identify all documents created by the overinspectors (or anyone else in the process) which was used to " evaluate each inspector" (pg. 34, line 2-3).
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond th*. scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
1 Without waiving the foregoing objection, but rather l expressly relying upon the same, the documents in question will be contained in the CPRT Working File for Action Plans I
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VII.b.3 and VII.c, which will be available for inspection by CASE at such time as the Result Report for each Action Plan has been approved and published by the SRT.
Interrogatorv No. 33:
Identify all documents created by the over inspection (or any other process) which was used to give " good insight as to the accuracy of inspections" (p. 34).
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
4 Without waiving the foregoing objection, but rather expressly relying upon the same, the documents in question will be contained in the CPRT Working File for Action Plans VII.b.3 and VII.c, which will be available for inspection by CASE at such time as the Result Report for each Action Plan has been approved and published by the SRT.
Interrocatorv No. 34:
Identify the supervisor to the over inspectors l referred to on page 34, line 17-19.
Obiection:
The Applicants object to this interrogatory on the i
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ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986. The Applicants further object on the ground that the identity of individuals performing tasks under the CPRT Program Plan is irrelevant to the adequacy of the Program Plan and this interrogatory is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the information requested will be cortained in the CPP.T Working File for Action Plans VII.b.3 and VII.c, which will be available for inspection by CASE at such time as the Result Report for each Action Plan his been approved and published by the SRT.
Interroaatory No. 35:
Identify the 66 inspections which were referred to by Mr. ifansel as complete on page 34, line 19-22.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for infornation obtained or in the process of beir.g obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the information requested will be contained in the CPRT Working File for Action Plans VII.b.3 and VII.c, which will be available for inspection by CASE at such time as the Result Report for each Action Plan has been approved and published by the SRT.
Interrocatorv No. 36:
Identify all documents which were created in the review of the 66 inspections referred to on page 34, line 19-20.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the documents in question will be contained in the CPRT Working File for Action Plans l VII.b.3 and VII.c, which will be available for inspection by CASE at such time as the Result Report for each Action Plan has been approved and published by the SRT.
Interrocatorv No. 37:
What is meant by the phrase " adequacy of the construction" as used on p. 64, ln 12-20 (Transcript, October 3, 1985, meeting)? Explain in precise detail, including identifying what is considered " adequate," and who makes that determination.
Answer:
Please see our response to Interrogatory No. 1 of CASE's "CPRT Discovery - Set No. 1."
The RTL for each Action Plan is responsible for the accomplishment of all of the tasks required to be performed under that Action Plan. The RTL has the authority to delegate the performance of tasks at his discretion, but remains responsible for the performance thereof. The identity of the specific individual (s) involved in the performance of each Action Plan will be revealed by the Results Report or in the Working File for that Action Plan once it has been completed. The overall collective significance evaluation will be performed by the SRT.
Interrocatory No. 38:
What is meant by the phrase " adequacy of the QA/QC program?" Explain in precise detail, including identifying j what is considered " adequate and who makes that determination.
Answer:
Please see our response to Interrogatory No. 1 of CASE's "CPRT Discovery - Set No. 1."
o The RTL for each Action Plan is responsible for the accomplishment of all of the tasks required to be performed under that Action Plan. The RTL has the authority to delegate the performance of tasks at his discretion, but remains responsible for the performance thereof. The identity of the specific individual (s) involved in the performance of each Action Plan will be revealed by the Results Report or in the Working File for that Action Plan once it has been completed. The overall collective significance evaluation will be performed by the SRT.
Interroaatory No. 39:
Identify all documents developed in or for the work described on Tr. p. 66, in 24, to p. 68, in 20. This list should include out not be limited to:
- a. the list of questions or checkpoints used to determine 4);
if an activity was " reasonably homogenous" (in 1-Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the documents in question
will be contained in the Working File for Action Plan VII.c, which will be available for inspection by CASE at such time as the Result Report for that Action Plan has been approved and published by the SRT.
Interrocatory No. 40:
Explain in precise detail what was meant by the statement on p. 67, ln 18-20, that "we didn't want to fluster [ sic] into the same population the work done by two groups or two companies, or two different inspection groups."
Answer:
What was meant was that " work done by two groups" and
" work done by . . . two different inspection groups" are boundaries of homogeneity employed for HWA determination.
Interrocatorv No. 41:
Identify all documents developed in or for the second phase of the analyses described on pp. 68-69.
obiection:
C The Applicants object to this interrogatory on the ground that it calls for information obtained or in the I
process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
l Without waiving the foregoing objection, but rather expressly relying upon the same, the documents in question 1
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will be contained in the Working File for Action Plan VII.c, which will be available for inspection by CASE at such time as the Result Report for that Action Plan has been approved and published by the SRT.
Interrocatorv No. 42:
On page 72, Mr. Hansel identified an "early verification" process in lines 4-8, which apparently provided the information to permit the grouping of different attributes. In regard to this early verification process, answer the following questions:
- a. Identify the date or dates, or time period, that the early verification process covered.
- b. Identify all the persons who participated in the early verification process by name, position, and employer.
- c. Identify the procedures and/or criteria by which the early verification process was conducted.
- d. Identify all project individuals (i.e., TUEC, B&R, Gibbs & Hill, etc.) who participated in the early verification process.
- e. Identify in precise detail what was being verified or reviewed.
f.
Provide the contract (s) that commissioned the work described above.
- g. Identify the documents that are the result of the early verification process and their location.
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information obtained or in the process of being obtained during the implementation of the CPRT Program, and is thus beyond the scope of tha discovery authorized by the Board on August 18 and 19, 1986.
Answer Without waiving the foregoing objection, but rather expressly relying upon the same, the information and documents in question will be contained in the Working File for Action Plan VII.c, which will be available for inspection by CASE at such time as the Result Report for that Action Plan has been approved and published by the SRT. The questioner should understand that the "early verification" referred to had to do with one particular question raised by the Staff regarding homogeneity of cable termination populations. See II. 71-72.
Interroaatory No. 43:
In reference to the discussion in the Oct. 3 transcript regarding the establishment of the Homogenous Work Attributes (HWAs), provide all preliminary assumptions used in developing HWAs and all bases you have for accepting these assumptions.
Example 1: There is an assumption that if the electrical craft are trained for the most complex activities they "should be able to" handle lesser activities (see p. 79, 80).
Example 2: There is an issumption that the TUGCO turnover and checkout procedure was very effective (p.
104).
Answer:
Please see CPP-005.
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'4 Interroaatorv No. 44:
Provide the criteria used to decide whether there is sufficient commonality to determine that conclusions can be drawn from a single strata sample for:
- a. processes
- b. people
- c. procedures
- d. specifications Answer:
Please see CPP-005.
Interrocatorv No. 45:
Explain in precise detail the basis for selection of the homogenous work activity and how it was accomplished (Tr. pp. 79-87, 106-109, 114-120).
Example: On p. 84 of the transcript, lines 21-24, Mr.
Hansel states that "[W]e have looked at this sufficiently to answer in our minds that the work processes are the same; no need to go back through all the other common attributes and commonality procedures and specs." Explain what the actual basis of determining the HWA was for each HWA in the electrical area, as well as for each other specific HWA.
Answer:
Please see CPP-005.
Interrocatory No. 46:
Considering the explanation of the basis for each HWA provided in response to Question 45, identify how the homogeneity was based on the people who did the work, not the attributes or procedures for each HWA.
Answer:
Since the question appears to assume that one cannot a
have multiple bases for homogeneity, or that such_ bases are mutually exclusive, we'do not understand what is requested.
For the basis for each HWA, please see CPP-005.
Interrocatorv No. 47:
Produce for inspection and copying all documents identified in the answers to these questions and all documents relied upon or examined in the preparation of the answers to these questions.
Answer:
. Applicants will produce for inspection and copying, at the offices of. Texas Utilities Generating Company, 400 North Olive Street, Dallas, Texas, at a time to be mutually agreed upon by counsel or other representatives of the parties, any document referred to herein without objection specifically identified by CASE of which it has not already had an opportunity to inspect, and they will produce the
'CPRT Working Files in the manner and at the time set forth in the Applicants' answers to CASE's 8/27/85 interrogatories.
Motion for Protective Order To the extent required by the Rules of Practice, the Applicants move for a protective order on the objections interposed in the foregoing responses.
SIGNATURES I, Terry G. Tyler, being first duly sworn, do depose and say that I am the Program Director of the Comanche Peak Response Team ("CPRT") (see " Comanche Peak Response Team Program Plan," 6/28/85), that I am familiar with the information contained in the CPRT files and available to CPRT third-party personnel, 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 or the CPRT (third-party personnel) but not within my personal knowledge, as to which I, based on such information, believe them to be true.
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t 4w e Terry [/Tyleg/ i Sworn 5
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to beforg p pe g s day of f.01- _er, 1986:
A.,, Q 44,,ty_s Wotary Pdblic drara on ree s My commission, expires: 444 4 cu ts; t4s f As to Objections:
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'% z W Thomas G. Dignan, Jr.
R. K. Gad III William S._Eggeling Kathryn S. Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 l
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!"iNRC CERTIFICATE OF SERVICE I, Kathryn A. Selleck, oneoftheattornhfb0$rlkhEkh@licants herein, hereby certify that on December 8, ISS6,il made service of 00CKEi thsl , ; c,gy~
the within " Applicants' Answers to CASE CPRT Prodfah Plan Interrogatories (Set No. 8)" by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory 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 Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 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 Stuart A. Treby, 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
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'Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing
. Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street-2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 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, Esq.
Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director-P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesdt, Maryland 20814 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111
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'Kathryn A. Selleck