ML20211M903
| ML20211M903 | |
| 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-#486-1894 OL, NUDOCS 8612180076 | |
| Download: ML20211M903 (42) | |
Text
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j %Tto cong Filcds Deccab0r 8, 1986.
k CCLKETEP US!mt UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '86 DEC 16 P4 :04 before the ATOMIC SAFETY AND LICENSING BOARD $hL In the Matter of )
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) Docket Nos. 50-445 ~dL TEXAS UTILITIES ELECTRIC )
COMPANY et al. 50-446- 4 6
)
(Comanche Peak Steam Electric
) (Application for an
) Operating License)
Station, Units 1 and 2) ) -
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APPLICANTS' ANSWERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (Set No. 9)
Pursuant to 10 C.F.R. sec. 2.740 ft., the Applicants hereby submit their responses to CASE's "CPRT Discovery -
Set No. 9,"
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 Instructions" under the heading " Instructions" (pages 7-10),
insofar as the same are contrary to the Rules of Practice. '
Desion By agreement of the parties, and with the concurrence of the Board, matters regarding the adequacy of design hDR DO G h $63
t o
k 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:
Describe in precise detail the circumstances under which the Senior Review Team (SRT) directed that "a written description of quality assurance measures controlling CPRT
- third-party activities be developed" (Appendix G, p. 1).
Include in your answer the following:
- a. Identify the individuals from the SRT who gave the direction to establish the identified quality assurance measures,
- b. Identify all the documents that provide the direction.
- c. Identify the time and date that these directions were given.
Answer:
During public meetings held on June 13 and 14, 1985, the !!RC Staf f expressed a need for clarification of the quality assurance measures to be applied to the CPRT program. To provide a sharper focus on the quality of the CPRT activities, the SRT decided to develop an umbrella QA effort for all CPRT activities that do not fall under the
o TUGCO QA/QC program.
- a. The decision was made by the SRT, acting collectively and collegially.
- b. Program Plan, Appendix G; "CPSES Comanche Peak Response Team Policy on Quality Assurance" (TXX-4538 dated 8/16/85) ; TXX-4720 dated 2/28/86 which describes the role of the OQT; " Overview Quality Team Program for CPRT Activities" (TXX-4931 dated 7/23/86).
- c. The " direction" to develop the program was given at various times between June 14, 1985, and the =>
publication of Appendix G. Please see, in particular, the minutes of the SRT meeting of 6/21/85 and 7/12/85.
Interrocatorv No. 2:
Describe in precise detail how it was decided which criteria and principles from 10 CFR Part 50, Appendix B, were relevant to the CPRT effort.
Answer:
The SRT compared the criteria and principlas referred to in the question to the CPRT Program Plan and made a decision as to which ones were applicable and which were not. The judgment was made by the SRT, acting collectively and collegia 11y.
Interrocatory No. 3:
Describe in precise detail how the CPRT quality assurance program described in Appendix G of Revision 3 meets the goals of the program as described in the 3-
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statement made by W. G. Council in his Aug. 16, 1985, letter to Vincent Noonan, in which he states (p. 3):
It is our view that these steps and the OQT, taken together with the carefully structured third party nature of the CPRT program plan itself, provide a vigorous and open process which meet the requirements of 10 CFR 50, Appendix B, and essentially guarantees its integrity and that of the final product and conclusions.
Include in your answer a description, in precise detail, of what Mr. Counsil believed would be added to the CPRT generally and/or Appendix G in particular that would provide a basis for this statement and that has not been added to the CPRT generally and/or Appendix G in particular.
Answer: %.
As to how the the CPRT quality assurance measures meet the applicable criteria of 10 CFR Part 50, Appendix B:
please see SSER 13 at 4-2 through 4-7, and Program Plan, Appendix G Attachment 1.
As to what Mr. Counsil believed would be added that has not been: nothing.
Interrocatory No. 4:
Describe in precise detail what Mr. Counsil meant in his August 16, 1985, letter to Mr. Noonan when he stated that the CPRT effort will " meet the requirements of 10 CFR 50, Appendix B." For instance, was this intended to indicate that the requirements of the program, if met, would provide compliance with all the detailed criteria of 10 CFR 50, Appendix B?
Answer:
The " meaning" of the quoted statement is identical to the meaning of Program Plan, Appendix G, namely that the
O 4
substance of those Appendix B criteria that are logically applicable will be satisfied (1.g., that by their terms apply to activities of the sort that CPRT is performing).
Interroaatory No. 5:
Describe in precise detail what is meant by the statement in the summary at page 3 of Appendix G that
" performance to the requirements of the Quality Assurance Program will ensure high quality standards in accordance with the SRTs and TUGCO management's expectations and commitments to quality."
For instance, was this intended to indicate that the requirements of the program, if met would provide compliance with all the detailed criteria of 10CFR 50, Appendix B?
Answer:
The quoted statements were not made using any specially defined terms. Please see our response to the prior interrogatory.
Interrocatory No. 6:
Identify all TRT ISAPs that were ongoing as of July 23, 1986 in the Civil, Structural, Mechanical, Electrical, Testing, and Miscellaneous groups.
Answer:
Assuming that " ongoing" means that any activity was then in process, all of them except: VII.a.9, III.a.5 (not yet commenced) and II.b, I.a.3, I.a.4, I.a.5, I.b.3, III.d, VII.a.4, VII.b.2 (completed).
Interrocatory No. 7:
I On the ISAPs identified above, provide the completion
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.date of the; actual do:ument review or inspection process.
Explanation: When did the gathering of raw data stop and'the preparation of the Results Reports begin?
Answer:
II b: 6/07/85 I.a.3: +4/22/86 I.a.4:! 7/22/86 I.a.5: 6/03/86
'I.b.3: 3/06/86 III.d: 8/28/86 VII. .ji : 3/06/86 VII.b.2: 3/11/86 Interrocatory No. 8:
L Explain in precise detail the following statement from the July 23, 1986, letter from Counsil to Noonan:
lThese as well as other CPRT audit activities are designed to be in-process activities; therefore, unless specific audit findings indicate a need to audit completed TRT ISAP activities, audits will not be conducted of the implementation of a TRT ISAP after its Results Report has been submitted to the SRT for review and approved.
Answer:
Given that the language employed in the letter was not employed with any specialized meaning, we are uncertain as to what " explanation" is requested. "These" refers to the expansion of the TERA and ERC audits described just previously in the same paragraph. The extent to which o
i those audits of TRT-responsive activities revealed findings that may have implications on theretofore completed Action Plan Results Reports was to determine whether any completed Action' Plan would be reopened. To date, nothing has been found that would warrant reopening.
Interroaatory No. 9:
Identify all the " measures previously instituted by the SRT" referred to in the last sentence on page 1 of the July 23, 1986 letter.
, Answer:
The quoted language was not used with any specialized m.
terms. Therefore, in the absence of some more focussed a question, we do not understand what further explanation is requested. Please note that the quotation has been truncated; in the original it reads: " measures previously instituted by the SRT which are described in Accendix G of the CPRT Procram Plan . . . .
The measures referred to are, as set forth in the letter, described in Program Plan, Appendix G, Attachment 1.
Interrocatorv ?!o. 10:
What was the basis of the SRTs determination that the f."CPRT program principles, implementation requirements, and policies and guidelines, in conjunction with the detailed
- guidance provided in each TRT ISAP are sufficient to ensure l the quality performance of TRT ISAP activities and I
results?" ,
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In providing the answer, identify all documents or oral advice (from whom) upon which the SRT relied.
Answer:
The determination was made by the SRT, collectively and collegially, based on the experience of its members and the opinions expressed to them by the RTLs.
Interroaatory No. 11:
Explain in precise detail what quality assurance measures were in place for each of the completed ISAPs not covered by Appendix G and identify what documents existed that described those measures and/or were used to govern or carry out those measures, including procedures and training manuals. %
Answer:
Please see section III, p. 6 of the Program Plan and Program Plan, Appendix G, Attachment 1.
Interrocatory No. 11:
For each ISAP identified above, explain the basis upon which the CPRT intends to rely to establish the quality of the work performed.
Obiection:
The Applicants object to this interrogatory, which calls for the disclosure of trial strasegy and not for information relevant to the adequacy of the CPRT Program Plan to meet its goals, the subject 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, please see Attachment 1 of CPRT Program Plan, Appendix G.
Interroaatorv No. 13:
Provide the basis for the decision made by the SRT that additional quality measures "would be appropriate to ensure the quality" of the QOC program.
Identify all documents, memoranda, or any meetings at which this issue and decision were discussed.
Answer:
SRT believed that, given the magnitude of the undertaking, the number of people involved in its implementation and the fact that the bulk of this program involves hardware re-inspections, the addition of these measures would enhance the effectiveness of the process.
Interroaatory No. 14:
To what extent, if any, did the SRT review the NRC inspection record of the ERC program at the Braidwood facility?
If the NRC inspection record was considered, identify the person or persons who performed the review and identify all documents that were reviewed.
Answer:
None.
Interroaatory No. 15:
Identify the status of all QOC activities at the time the SRT required the QOC Review Team to implement a quality assurance program for its activities (p. 3).
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4 Answer:
Presuming this question to refer to Action Plan VII.c, the action plan was in the formulation and approval stage.
No hardware inspections had been performed. It should be noted that ERC has had a quality assurance program in place respecting the CPRT activities performed by ERC since November 21, 1984 (prior to the approval and publication of any Action Plan in which ERC was performing activities).
Interroaatory No. 16:
Identify the process by which the Senior Review Team m, will review all audits and corrective actions taken in response to audits. Include in the response to this question the identification of all procedures used to accomplish the review (p. 3).
Answer:
The SRT has delegated to OQT the responsiblity for reviewing all audits of CPRT activities and corrective actions taken in response to those audits. The OQT reports the results of those reviews to the SRI at exit interviews and in OQT Periodic Progress and Status Reports. There are no written procedures used that describe this SRT review process.
Interrocatory No. 17:
Explain the basis of the statement that "CPRT activities associated with implementing these ISAPs were performed by a small number of persons in accordance with the principles of the CPRT Program Plan" (p. 4). Include in your answer how the CPRT has any assurance that the work
was performed in accordance with the plan since there was no QA program for the plan.
Answer:
The quoted statement employs ordinary English, with no terms carrying specialized definitions. Accordingly, we do not understand what further explanation is requested. SRT was and is familiar with the numbers (and the identities) of the individuals performing the Action Plans.
Verification has been accomplished by means of the activities described in Program Plan, Appendix G, Attachments 1 and 4. We wish to note that, in responding to the foregoing question, we have not been asked to signify our agreement or disagreement with the assertion "there was no QA program for the plan" and our response, therefore, should not be misunderstood as signifying either.
Interroaatory No. 18:
Identify each of the consultations between the SRT and the various Review Team Leaders for the TRT ISAPs that led to the determination the " additional implementing procedures, providing details or management controls beyond that existing in the ISAPs and CPRT Program documents, were not required" (p. 4).
Answer:
To the extent that the quoted language refers to formal, organized meetings and presentations, please see the minutes of the SRT contained in the CPRT Central Files, which have previously been made available for inspection by CASE. To the extent that the question could be construed to include all contact and communication between RTLs, ICs, and the members of the SRT, such contacts and communications are a daily event and no such catalog could be provided.
Interroaatory No. 19:
Identify the basis of the RTL's decisions to issue or not to issue supplemental instructions for each TRT ISAP.
The answer should be from each individual RTL and should state that documents he or she reviewed or discussions he or she had to reach that determination. ==
Answer:
With respect to QOC and QA/QC Review Team: the efforts of this team have always been under the controls discussed in the ERC Management Program Plan and the procedures referenced therein, and for that reason no supplemental instructions were deemed necessary.
With respect to the Testing Action Plans: The RTL and ICs were thoroughly familiar with all issues and the requirements of the Program Plan, and therefore no supplemental instructions were deemed necessary.
With respect the Electrical Review Team: The RTL determined that the CPRT Program Plan was sufficient.
Where quality instructions were needed for re-inspections or documentation reviews, these were approved by the i
Electrical Review Team Leader. For these reasons, no supplemental instructions were deemed necessary.
With respect to the Civil / Structural and Mechanical Action Plans: The RTL originally felt that the CPRT Program Plan and ISAPs provided all the necessary guidance to implement the civil / structural / mechanical ISAPs.
However, in mid-1985 the RTL felt that in order to ensure uniformity of these ISAP reviews that certain civil /
structural / mechanical procedures were necessary. This was necessary because of the various persons involved in m.
reviewing a varity of documents associated with these ISAPs. Later, DAP procedures were issued, some of which supplemented the civil / structural / mechanical procedures previously issued.
The SRT was aware of the foregoing determinations at the time they were made and concurred therein.
Interrocatory NO. 20:
For each TRT ISAP identify how the quality assurance criteria requirements of 10 CFR 50, Appendix B, are dealt with.
For example:
ISAP I.A.4 Acolicable/NA Incorporated Criterion I NA Independence not required because the program of
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record.
Criterion II Criterion III Criterion IV Criterion V Criterion VI Applicable Checklist and procedures, Sect. 4.2.0.
Criterion VII Criterion VIII Criterion IX Criterion X Criterion XI Criterion XII Criterion XIII Criterion XIV Criterion XV Criterion XVI *w Criterion XVII Criterion XVIII Answer:
Please see Program Plan, Appendix G, at 4-5 and SSER 13 at 4-2 through 4-7.
Interrocatory No. 21:
Explain in precise detail the basis for excluding each of the following Appendix B criteria from the CPRT:
Criterion III -Design Control Critorion IV -Procurement Document Control i
Criterion VII -Control of Purchased Materials, Equipment and Services Criterion VIII -Identification and Control of Materials, Parts, and Components Criterion IX -Control of Special Process Criterion XI -Test Control l
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Criterion XII -Control of Measuring and Test Equipment Criterion XIII -Handling, Storage, and Shipping Criterion XIV -Inspection, Test, and Operating Status Answer:
We do not agree with the assertion contained in this question. Nonetheless, the following information is supplied:
With the possible exception of Criteria XI, CPRT is not performing any of the activities referred to in the 10 CFR, Part 50, Appendix B criteria that are not applicable **
l to it. Testing is performed for CPRT by outside organizations employing their own, TUGCo-approved QA/QC programs or by CPRT in accordance with the approved ISAP where the testing is required.
Please see SSER 13 at 4-2:
" Conversely, the staff has determined that the CPRT OQT j program should not address the following criteria:
L
" Criterion 8, Identification and control of material, parts and components
" Criterion 9, Control of Special Processes
" Criterion 11, Test Control
" Criterion 13, Handling, storage and shipping
" Criterion 14, Inspection, test, and operating status "These criteria are not applicable to the CPRT program
o since these provisions of 10 CFR 50, Appendix B, apply to activities which the CPRT is not responsible for and/or does not intend to perform."
Interrocatorv No. 22:
Identify any other measures not described in Appendix G upon which the Applicants rely to demonstrate that there is assurance of the quality of TRT ISAP activities.
Obiection:
The Applicants object to this interrogatory, which calls for the disclosure of trial strategy and not for information relevant to the adequacy of the CPRT Program %.
Plan to meet its goals, the subject for which this discovery was authorized by the Board on August 18 and 19, 1986.
Interrocatorv No. 23:
Identify and produce all audits and/or inspections conducted into the CPRT program plan or any of its elements since October 1984. This includes but is not limited to TUGCO audits, INPO audits, audits by the NRC inspectors, MAC, Brown & Root, Stone & Webster, Combustion Engineering, EBASCO, TERA.
Obiection:
l The Applicants object to this request, which on its face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside the scope of the I
discovery authorized by the Board on August 18 and 19, l
l
O 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, all such documents will be contained in the Working Files associated with particular Action Plans or in the CPRT Central Files at such time as the program (or particular Action Plans) have been
. completed.
Interrocatorv No. 24:
In regard to the Overview Quality Team (OQT), identify =>
the criteria upon which the SRT will conclude that "the level CPRT activities no longer justifies the need for the "OQT" (p. 2 of the OQT program, Rev. 2, July 23, 1986).
Answer:
The criteria are stated in the quoted language.
Interrocatory No. 25:
Identify the criteria by which the OQT will evaluate the implementation of the CPRT QA program " relative to achievement" of the objectives listed on page 2 of the OQT.
Answer:
We do not understand tne question. If it means
" criteria," the criteria are stated in the quoted material.
If the question meant "means," the means are set forth on pages 3-6 of the OQT Program (7/23/86). The acceptability of items is determined by comparing the items reviewed to applicable CPRT Program requirements (including 1
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implementing documents) using the judgment of the experienced OQT members.
Interrocatory No. 26:
Identify the "other measures"-- and identify all documents that describe these measures and/or are used in implementing these measures, including procedures and training manuals--that assure the quality of the following activities:
- a. SRT activities;
- b. Technical Review of Results Reports;
- c. Assessment of the CPRT Program Adequacy.
Answer: =>
These activities are either performed and reviewed by SRT itself, or by persons retained by SRT to advise it and functioning under its direct supervision. There are no written procedures.
Interrocatory No. 27:
Identify and explain the basis on which the OQT will I
make the determination as to whether personnel "are l
adequately qualified and trained to perform their assigned tasks" (p. 3).
Answer:
Please see OQT Program at 3, Section 3.1.
Interrocatory No. 29:
Identify and explain the basis on which the OQT will make the determination as to whether personnel "can perform I their assigned tasks objectively and without influence from l prior organizational affiliations" (p. 3).
l Answer:
l l
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Please see OQT Program at 3, Section 3.1.
Interrocatory No. 29:
Explain in precise detail the following about the OQT's Procedure Review, Section 3.2 of the OQT (p. 4).:
- a. How are the procedures to be reviewed by the OQT selected?
- b. Identify the criteria upon which the OQT makes its determination on whether the procedure, if properly implemented, "will achieve the objectives of the QA program?"
- c. Is the QA program referred to in this section the CPRT QA program as described in Appendix G, or the site QA program?
N
- d. Explain in precise detail how the OQT processes, comments on, or questions the procedural implementation, e.g., on what form are comments or questions recorded?
Answer:
- a. On the basis of a judgment by OQT as to which procedures are most important.
- b. The determination is based on a comparison of the procedure to any applicabile CPRT Program requirements.
i
- c. The former.
- d. There are no forms on which OQT comments or questions regarding procedural implementation are recorded.
Such OQT comments or questions are discussed with responsible CPRT Review Team personnel to achieve resolution and are referred to the SRT when such resolution l
cannot be achieved. This resolution process is delineated
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in Section 3.7 of the OQT Program. Pending resolution, the matters are carried as OQT Open Items and may also be addressed in summary form in the OQT Periodic Progress and Status Reports.
Interrocatorv No. 30:
In regard to Section 3.3, " Audit Plans and Record Review," identify the written form or procedure upon which the OQT will log any desired additions or changes with the DAP and QOC (p. 4).
Answer:
The OQT Program does not require the logging of such me.
desired changes and there are, therefore, no procedures or forms. Any desired changes are handled in the manner described in the response to Interrogatory No. 29(d),
suora.
Inte'erocatory Noo 31:
Identify the written forms or procedures upon which any areas of disagreement will be referred to the SRT for resolution (p. 4).
Answer:
There are no written forms or procedures used to refer areas of disagreement to the SRT for resolution. The process of problem resolution, including those related to audits, is accomplished in the manner described in the response to Interrogatory No. 29(d), suora.
Interrocatory No. 32:
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Identify the criteria the OQT will use to determine if selected audit plans are " adequate" in regard to audit frequency, timeliness, and thoroughness (p. 4).
Answer:
l The adequacy of selected audit plans and the overall plans and schedules for audits are assessed with regard to timeliness and thoroughness by considering applicable CPRT Program requirements (including implementing documents) and past audit results, using the judgment of the experienced OQT mt cers.
Interrocatory No. 33: >>
Identify the process which records and evaluates the OQT's concerns in the event that the records review referred to in Section 3.3 generates a question from the OQT with respect to whether or not audit er.ectives were achieved. (p. 4).
Answer:
Any concerns regarding the achievement of audit objectives are discussed with the responsible CPRT Program personnel and are recorded in the OQT Periodic Progress and Status Reports.
Interrocatory No. 34:
Explain in precise detail the reason that the OQT's additional auditors or inspectors " work under the direction of the DAP and QOC program audit team leaders," instead of under the OQT (p. 4).
Answer:
The DAP and QOC program contractors are responsible l
for conducting the audit programs; the OQT is responsible ;
for overviewing these audits. In accordance with section l 3.4 of the OQT Program, it is not the duty of the OQT to perform audits directly. Additional qualified auditors and inspectors are assigned as deemed necessary by the OQT to assist in the audits and to address specific areas of interest to the OQT. These additional auditors and inspectors work under the direction of the DAP and QOC Program audit team leaders to avoid detracting from the authority and responsibility of the audit team leaders. %-
The OQT assures it is cognizant of the findings of the additional auditors and inspectors by overviewing the audits in which they participate, by discussing their roles and evaluations during the course of the audits, and by reviewing the resultant audit reports.
Interrogatory No. 35:
Identify those audits conducted by the QA organization of the DAP and QOC program review teams which the OQT members will participate in as observers (p. 4). How is this selection made and what criteria are used to make it?
Answer:
The audits conducted by the QA organization of the DAP and QOC programs in which OQT members participate as observers are identified in the OQT schedule in each OQT Periodic Progress and Status Report beginning with Report l
No. 2 (11/1/85). The selection of the audits for OQT participation as observers is based on considerations of the results of past audits and previous OQT audits observed, and activity and location to be audited. There are no other criteria for this selection.
Interrocatorv No. 36:
Identify those overview inspection activities for which the OQT will perform direct observations (p. 5).
Answer:
OQT directly observes selected overview inspections in N
progress during scheduled OQT meetings. Those overview inspections observed are selected based on overview inspections underway and past performance, using the judgment of the experienced OQT members.
Interrocatories Nos. 37 & 38:
Identify the written forms or documents on which the OQT will record its observations from reviewing the activities described in Section 3.5 and 3.6 of the OQT.
Identify all written forms or documents upon which the OQT will identify any problems or issues it believes need resolution.
Answer:
The documents are the OQT Periodic Progress and Status Reports. There are no forms.
Interrocatory No. 39:
Identify the criteria the OQT will use to determine if the work products of QA activities are conducted in accordance with applicable industry standards and practices. (p. 5).
Answer:
The knowledge and experience of the OQT members is utilized to judge conformance of the QA activities to applicable industry standards and practices.
Interrocatorv No. 40:
Identify and provide all OQT open items tracking sheets discussed in 3.11 that have been completed to date (p. 6).
Answer:
4 OQT open item tracking sheets are included with each OQT Periodic Progress and Status Report beginning with Report No. 7 (5/16/86).
Interrogatorv No. 41:
Identify and provide all periodic progress and status reports of the OQT effort (p. 6).
Answer: ,
OQT Periedic Progress and Status Reports are contained i in the CPRT Central Files which have previously been made I
available to CASE for inspection and copying.
Interrogatory No. 42:
Identify the individual (s) who are assigned to the positions listed on Figure 2.1 QA/QC Review Team Organization.
Obiection:
j The Applicants object to this request, which on its
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face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside 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 Program Plan, Appendix B, Attachment 5, except that Mr. E. Brabazon is the Engineering Deputy Program Manager. =>
Interroaatorv No. 43:
In regard to Figure 3.4 of the CPRT QA/QC Review Team Quality Assurance Matrix, identify each 10 CFR Part 50, Appendix B, criterion that is not deemed applicable to the QA/QC Review Team Activities and explain the basis for its exclusion.
Answer:
Please see our response to Interrogatory No. 21, suora.
The criteria not applicable are all the ones not listed on Figure 3.4.
Interrogatory No. 44:
On page 26 of the MP plan, Rev. 4, under the Procurement Document Control, Section 4.0, it states that
"[c]ertain procurements for services were accomplished prior to the establishment of this MP Plan." For each of these procurements, identify it and provide the documents reviewed and the criteria by which ERC determined that there was proper inclusion of quality assurance requirements.
Obiection:
The Applicants object to this request, which on its face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without vaiving the foregoing objection, but rather expressly relying upon the same, ERC conducted audits of g, each of its sub-contractors to review their QA programs and associated records. These audits were restricted to cover only those requirements that were applicable to the services to be provided to ERC in support of the CPRT Program, i.e., QA Program, Document Control, Quality Assurance Records, and Personnel Certification. Details of the audits, criteria and audit results are included in Working Files maintained by the QOC RTL.
Intarrocatory No. 45:
Explain in precise detail what is meant by the term "non-conforming hardware and documentation" as used in the MP Plan on page 33.
Answer:
The term is identical to " deviation" as defined in Program Plan, Appendix E, as applicable to the referenced
program. See CPP-010.
Interroaatory No. 46:
Identify what part of the CPRT reinspection of hardware and documentation is not done by the QA/QC Review Team according to the MP Plan.
Answer:
Where the reinspections are performed by a sub-contractor, in each case as identified in the Action Plan.
Please see also Program Plan at 12.
Interrocatorv No. 47:
Explain in precise detail how a non-conforming %>
condition is identified.
Answer:
Assuming that the question addresses the Quality of Construction program, by inspection of the hardware or document in question and comparison of what is observed to
, the applicable accept / reject criterion.
Interrocatory No. 48:
The MP Program states that the DRs "are used only for QA/QC Review Team Evaluation purposes." Identify all persons who perform the evaluations of the DRs.
Answer:
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 contained in the Results Report or in the Working File for that Action Plan once it has been completed.
Interroaatory No. 49:
Identify all the procedures used to do the evaluations of the DRs.
Answer:
CPP-010, -011 and -016.
4 Interrocatory No. 50:
Explain in precise detail what tracking or trending of the deficiency reports are done.
Answer:
The terminology " deficiency report" is not familiar.
Assuming that the intention of the questioner was to refer to " deviation reports," all valid deviations are trended as a part of and to the extent set forth in the adverse tr7nd process. See Program Plan, Appendix E, and CPP-011.
Deficiencies are tracked for oversight of corrective action, as set forth in Program Plan, Appendix H.
Interrocatory No. 51:
Is each nonconforming condition, whether or not it is l
determined to be a deviation, documented on a deviation I
report? On any report? If so, which one or ones?
Answer:
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Assuming the reference is to the Quality of Construction activities, we do not understand what is intended by the definition " nonconforming condition, . . .
" See Program Plan, Appendix not . . . a deviation . . . .
E. We therefore cannot answer this portion of the question.
All deviations are recorded on a deviation report.
CPP-010.
Interrocatorv No. 52:
Explain in precise detail the process by which =>
deficiencies " undergo an evaluation to verify validity."
Include in your answer an identification of all the procedures used for verifying the validity.
Answer:
We are unaware of where in the Program Plan or the Management Plan the quoted language is employed in connection with deficiencies.
If the intended reference was to deviations, please see CPP-010.
Interroaatory No. 53:
Explain in precise detail what is the disposition of the deviations that are deemed invalid according to the criteria explained in response to question 52.
Answer: 4 The determination of invalidity is noted on the deviation report. Please see CPP-010.
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Interrocatory No. 54:
Explain in precise detail, including identifying, the process that has been established to ensure that rework or repair is not done until after the safety significance evaluations is completed.
Answer:
ERC tagged the equipment at the time of the inspection. The Project was/is' required to verify that the safety significance reviews are completed prior to any rework of the affected item.
Interrocatory No. 55:
N Identify the criteria used by the SSEG to determine if a deviation, if uncorrected, would result in the loss of capability "to perform its intended safety function" (MP, p.34).
Answer:
Please see Program Plan, Appendix E, at 2 & n.; CPP-016.
Interrocatory No. 56:
Identify, by example if necessary or helpful, in what cases the QA/QC Review Team Leader "may designate other Review Teams responsible for conducting evaluations for safety significance in lieu of the SSEG" (MP, p.34).
Answer:
No complete list of the possible situations can be provided. The purpose of the language referred to was to anticipate the possibility that, in the performance of other Action Plans, another Review Team Leader might be
already fully familiar with a given subject matter and hence able to perform the safety significance evaluation with greater expedition and consistency.
Interrocatorv No. 57:
Have any cases arisen to date in which other RTLs conducted the sa'fety significant evaluation instead of the SSEG? If so, specify.
Obiection:
The Applicants object to this request, which on its face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan. >>
The request is, therefore, outside 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, no.
Interrogatory No. 58:
Describe in precise detail the requirements and procedures for conducting root cause and generic implication analyses of safety significant deficiencies, i Answer:
Please see the answer to Interrogatory No. 12 of CPRT Discovery - Set 4.
Interrocatorv No. 59:
Describe in precise detail the requirements and s
procedures for the review and evaluation of deficiency reports "for the purpose of identifying adverse trends" (MP Plan, p. 34).
Answer:
The terminology " deficiency report" is not familiar.
Assuming that the intention of the questioner was to refer to " deviation reports," all valid deviations are trended as a part of and to the extent set forth in the adverse trend process. See Program Plan, Appendix E; CPP-011; PAG-04.
Interrocatory No. 60:
Describe and explain in precise detail the difference **
between a " problem," a " deviation," and a " deficiency,"
relating to TUGCO's QA Program, as discussed on p.35 of the MP Plan.
Answer:
" Deviation" and " deficiency" mean the same thing in the MP as they do in the Program Plan. " Problem" means an observation that, if valid, is a deviation (prior to the time that it has been reviewed for validity).
Interrocatory No. 61:
Describe and explain in precise detail the difference between a " problem," a " deviation," and a " deficiency,"
relating to the Comanche Peak Station hardware.
Answer:
Please see our response to the foregoing interrogatory.
Interrocatory No. 62:
Explain in precise detail the circumstances under which problems, deviations, or deficiencies would not be identified or processed on a deficiency report (DR), but would appear either in a Results Report or in a collective evaluation report (p. 35). Treat each separately.
Answer:
Assuming the intended reference to be to Action Plan VII.c, none.
Interrocatory No. 63:
Describe and explain in precise detail the process by which recommendations for corrective action are provided to TUGCo.
Answer: "w Please see Program Plan, Appendix H. On occasion, SRT has requested RTLs to communicate corrective action recommendations to CPSES prior to formal SRT approval.
Interrocatorv ?To. 64:
Identify the person (s) who make up the Procedures and Project Assurance Group.
Obiection:
The Applicants object to this interrogatory, on the ground that the requested information is not relevant to the adequacy of the CPRT Program Plan, and therefore is 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 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. In particular, the names of individuals are identified on each CPP as the preparer and on each surveillance report as the person who conducted the surveillance. This information will be available in the Working Files maintained by the QOC RTL at such time as the *w QOC has been completed.
Interrocatory No. 65:
Explain in precise detail the process by which the Procedures and Project Assurance Group ensures that identified problems are corrected.
Answer:
Please see MP at 36-39.
Interrocatory No. 66:
Provide each corrective action request written on the Comanche Peak project since ERC began work under these procedures (p. 36).
Obiection:
t The Applicants object to this request, which on its s
face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside the scope of the 1
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discovery authorized by the Board on August 18 and 19, 1986.
ID19rrocatorv No. 67:
Provide each'stop work order written on the' Comanche Peak project since'ERC began work under these procedures (p. 36).
obiection:
The Applicants object to this request, which on its face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside the scope of the m.
discovery authorized by_the Board on August 18 and 19, 1986.
Interrocatory No. 68:
Describe and explain the basis upon which, after a stop work order is in effect, the QA/QC RTL and the Manager of QA would agree that work may be resumed (p. 36).
Answer:
Please see ERC-QA-024.
Interrocatory No. 69:
Identify what records.are kept in the E&ESD files described on p. 37 of the MP Plan.
i Answer:
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Copies of ERC QA audits and audits of sub-contractors.
Interrocatorv No. 70:
l Does the ERC audit program describe on p. 38 of the MP Plan meet the requirements of 10 CFR Part 50, Appendix B?
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- a. If not, explain what portions of the program do not meet criteria requirements and why.
- b. If so, indicate which portion of the ERC program meets which criteria. If the compliance is not self-evident, please explain now the program achieves the claimed compliance.
Answer:
Yes. (a) No answer required. (b) No answer required.
Interrocatory No. 71:
Identify and produce all audits conducted by the ERC Division Manager of Quality Assurance of any of the QA/QC **
Review Team activities as " defined in the CPRT program plan and appendices... and QIs" (p. 38).
Obiection:
The Applicants object to this request, which on its face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Interroaatorv No. 72:
Identify the circumstances under which the Manager of Quality Assurance would conduct or would be required to conduct audits of ERC subcontractors and other third-party inspection agencies utilized by the CPRT Review Teams.
Answer:
ERC conducts audits of its sub-contractors to
determine their ability to comply with the requirements of the CPRT Program, 1 3., to provide qualified and certified inspectors in accordance with ANSI N45.2.6 (1978) and Regulatory Guide 1.58, Rev.1, 1980.
See Program Plan section III.K.
Interrocatory No. 73:
Have any audits been conducted pursuant to the circumstances described in question 72 above? If so, produce the audits.
Obiection:
The Applicants object to this request, which on its face calls for information regarding the implementation of the CPRT Program, not the adequacy of the written Plan.
The request is, therefore, outside 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 response to Interrogatory No. 44, suora.
Interrocatorv No. 74:
Produce for inspection and copying all documents
- identified in the answers to these questions and all l
documents relied upon and/or examined in preparing the answers to these questions.
r Answer:
Applicants will produce for inspection and copying, at l
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 and specifically identified by CASE of which it has not already had an opportunity to inspect.
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. 4
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.
bb' .
n Terry / Tyler //
p Sworn
/ 5.- to befo day egi of - g: r_er,s 1986:
b9 bh trotary "Public,'stne oc Ter* J l
My commission expires: m,t c.u 2s <9 8 5 As to Objections:
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1 Thomas G. Dignan, Jr.
R. K. Gad III /
William S. Eggeling Kathryn S. Selleck Ropes & Gray 1 225 Franklin Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 40 -
0L KE T E r-uvii<c CERTIFICATE OF SERVICE I, Kathryn A. Selleck, one of the attorneys for ke h[p[kckdt@4 herein, hereby certify that on December 8, 1986, I mideEservice i of GOCYi.ium , y pgg' the within " Applicants' Answers to CASE CPRT Program PlaERAM" Interrogatories (Set No. 9)" 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. Folk Street U.S. Nuclear Regulatory Dallas, Texas 75224 l Commission Washington, D.C. 20555 l
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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 Ins'..itute 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 37330 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111 a ' _k? (.,'
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<a'thryn A . Selleck
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