ML20213F415
| ML20213F415 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1986 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#486-1468 OL, NUDOCS 8611140195 | |
| Download: ML20213F415 (33) | |
Text
_
gpL rineo: november 198s.
RELATED CC/RESPON02%
UNITED STATES OF AMERICA gotgETED 4
UstlPC NUCLEAR REGULATORY COMMISSION before the .g g 12 R2:28 ATOMIC SAFETY AND LICENSING BOARD CFFC , -!
00CBl: .o
)
In the Matter of )
) Docket Nos. 50-445 TEXAS UTILITIES ELECTRIC ) 50-446 COMPANY et al. )
) (Application for an (Comanche Peak Steam Electric ) Operating License)
Station, Units I and 2) )
__________________________________)
APPLICANTS' ANSWERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (Set No. 6)
Pursuant to 10 C.F.R. sec. 2.740 ff., the Applicants hereby submit their responses to CASE's "CPRT Discovery -
6," served by ordinary mail on September 16, 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.
Design By agreement of the parties, and with the concurrence of the Board, matters regarding the adequacy of design l
l aspects of the CPRT Program Plan have been excluded from I
8611140195 861107 PDR ADOCK 05000445 i G PDR I
DS03
4 s
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.
Interrogatories Interrogatory No. 1:
Identify all mechanisms used to ensure that appropriate personnel within various organizations receive information.
- a. For each mechanism provide the exact title of the mechanism, the form number if appropriate, and/or any other descriptive reference that will enable CASE to understand how information is transmitted from one organization to another (Rev. 3, Appendix F. p. 3).
- b. For each mechanism identify the custodian of the documents.
I c. For each mechanism identify the procedure or
! procedures used to implement the form.
Answer:
The following procedure manuals contain the l
l implementing procedures for the CPRT program (with respect l
l to areas other than design). Descriptions of the i
mechanisms used to ensure that appropriate personnel within various organizations receive information are contained within these program procedures. These descriptions I
include the exact title of the mechanism, the form number l
l r
I L
l
_ _ _ , - _ _,._m___ ,, y - _ , _ _ - , _ .__ __.,--_-_m_,,..m-_ _
,r_-.__-. . -mw ,,,_. .m...
. is if appropriate, details of how the mechanism is used to transmit information from one organization to another, and the custodian of the documents.
Policies and Guidelines (PAGs); QA/QC Review Team Comanche Peak Project Procedures (CPPs).
Please see also DAP-2 (referring to Civil / Structural ISAPa). DAP-15 (referring to Civil / Structural ISAPs), DAP-24 (referring to Civil / Structural ISAPs).
- a. See response above,
- b. See response above.
- c. See response above.
Interrogatory No. 2:
Identify all forms or types of " input data" that are or would be reviewed and commented on by the individual organizations.
Answer CPRT Program Plan, Appendix F, at 7-25 identifies the types of input data that are or would be reviewed and commented on by the individual organizations.
Interrogatory No. 3:
Identify all organization that perform the " review and comment" function.
Answer:
CPRT Program Plan, Appendix F, at 7-25 identifies the organizations that perform the " review and comment" function.
, Interrogatory No. 4:
Identify all organizations that review the comment and/or " resolve any conflict prior to completing" their investigation of subject issue.
Answer:
All organizations identified in Appendix;F which forward " input data" for review and comment will, as stated in the CPRT Program Plan, " consider the comments and resolve any conflict prior to completing their investigation of subject issue."
Interrogatoiy No. 5:
Identify and explain all methods by which a receiving organization can respond to the input from forwarding organizntions.
Answer:
CPRT Program plan, Appendix P,,at 3 requires that a written response be provided when " Action" is specified, and that a written response may be required when " Review and Comment" is specified.
The procedures discussed in response to Interrogatory No. 1, supra, provide further specifics with regard to type of documentation (i.e. memorandum, form, etc).
Interrogatorv No. 6:
According to the " Detailed Descriptions" section of Appendix F, the SRT receives " evaluations of findings discovered during the implementation of the Action Plan for safety significance, root cause and generic implications."
In regard to the evaluations described above, are these evaluations the actual inspection checklists and/or other I
l i
raw data or are the evaluations some other review of the inspection checklists (i.e., results reports)?
Answer:
It could be either, or both. (Please note that we are unable to determine precisely what is intended to be denoted by the phrase "other raw data," and we have therefore ignored that phrase in responding to this interrogatory.) In all cases, the SRT looks at data presented in Results Reports. In some cases, SRT receives verbal briefings on Action Plan status and findings, the extent to which is documented in SRT meeting minutes. The extent to which " raw data" i s reviewed is a discretionary matter with SRT members individually and as a whole.
Interrogatory No. 7:
' Identify all documents on which the adequacy of corrective action, as determined by the RTL, is documented or recorded or preserved in any way (p. 4).
i Answer:
Procedure CpP-021, Revision 1, entitled CPSES Pro.iect Corrective Action, describes the documents used by the Quality of Construction and QA/QC Review Team to record or preserve adegaacy of corrective action.
In addition, CPRT Program Plan, Appendix H, et 2, l
states that the results of the determination will be l
summarized in the Action Plan Results Reports. For corrective actions completed after issuance of the Results i
l '
I l
--.,-s-, ,c,y, -----m,--- ------,-+-,---w---, --- ~ , - - - - - - --------,--i--v
Report, a supplement to the Results Report will be issued.
Interrogatory No. R:
Identify all documents with which the RTL makes periodic reports (p. 4)
Answer These reports are usually made during meetings of the SRT. No particular forms have been prescribed by the SRT.
InterrogatSty No. 9:
Identify all documents used to record any instances when a PTL does not agree with the CPSES Project in an area of corrective actions in accordance with Appendix H.
Answer:
CPRT Project Procedure CPP-021 Revision 1, entitled CPSES P ro.i e c t Corrective Action describes the process used to resolve instances where the QA/QC RTL does not agree with the CPSES Project in an area of corrective action.
This procedure identifies applicable documents used to recora the process in the quality of construction area.
The extent to which RTLs will document the results of their confirmatory overview of corrective actions is defined in Program Plan, Appendix H. This will either be a part of the Action Plan Resulte Report or a supplement thereto.
Interrocatory No. 10.
At which point in the execution of the CPRT program is it considered complete for the purposes of the SRT advising Executive Vice P r e.. i d e n t (p. 4)?
Answer.
. -.= - - .-. . . - -
Upon publication of the collective evaluation and collective significance reports. See Program Plan at G.
Interrogatory No. 11:
Identify the person (s) who are responsible for making the decision that an " item" (as the term is used on page 4) may be the need for specific corrective action or the incorporation of " lessons learned" into existing work practices.
Answer:
The RTL for each Action Plan is responsible for the accomplishment of all of the tasks required to be performed l under that Action Plan. The RTL has the authority to delegate the performance of tasks at his discretion, but i remains responsible for the performance thereof. The identiiy 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 canpleted.
T u t e r ro ga t o.ry No. 12:
Describe in precise detail the meetings at which the SRT would make decisions to formally transmit information I to TUGC0 Vice President of Operations.
! Answer:
We do not understand what information is requested by a question in terar of " describe in detail . . . meetings
[that have not yet occurred]" and we are therefore unable to answer this interrogatory. Such SRT decisions could
e -
occur during meetings of SRT to approve results reports or collective evaluations or during SRT meetings where the RTL has requested an opporutnity to present recomemendations to the SRT in advance of the presentation of the results report or collective evaluation for SRT approval. In such events, these discussions are noted in the SRT meeting minutes.
Interrogatory No. 13:
Identify the person (s) who would be the " responsible individual," as described on page 4, who would or could receive information from the Chairman of the SRT. [ Provide several specific examples in which this process has Leen used.]
Objection:
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 f
expressly relying upon the same, insofar as the reference to page 4 implies a reference to Iteu II.A.3., the Vice-President, Operations is Mr. Austin B. Scott, and TUGCO Assistant Project General Manager - Unit 2 was Mr. John T.
Merritt and now is Mr. Donald E. Reynerson.
_ . _ - - . _ , -__ _ - - _ _ . _ _ _ _ _ _ _ . , _ _ . . _ _ _ - - . _ _ _ . . _ _ _ , _ _ _ _ . _ . - . _ . _ ~
Interrogatory No. 14:
Does the Chairman of the SRT retain a file of all TUGC0 " internal memos" he generated as a result of CPRT activitiet (i.e., the need far corrective action or the incorporation of " lessons learned" (p. 4)? If so, produce the file for inspection and copying.
Objection:
Insofar as this " interrogatory" calls for the production of in process materials the Applicants object to it on the grounds that it is attempted discovery with regard to CPRT Program Plan implementation, as opposed to plan . adequacy, and is therefore beyond the scope of the discovery authorized by the Board on August 18 and 19, l
1986, and that requests for the production of uncompleted, in process materials being prepared in anticipated of the precentation of expert evidence is not proper.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the Chairman of the SRT does not maintain a file of TUGC0 internal memoranda generated as a result of CPRT activities. Any such memoranda that reflect the decisione of the sRT are retained in the CPRT working file for the associated Action Plan or Collective Evaluation or in the CPRT Central File if the decision is not directly epplicable te a particular Action Plan or Collective Evaluation.
1 l
4 Interrogatory No. 15:
Describe in precise detail how the CPSES project completed work that is affected by the memo described in Question 14 i. incorporated into the CPRT evaluations.
Example: The CPRT identifies a problem with Type A widget installation during a random sample inspection. The CPRT informs the SRT, and the SRT Chairman informs the Project Superintendent, who in turn discovers that the Type A widget problem occurs in one out of ten widgets.
Ob.i ec t i o n :
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, Program Plan, Appendices E and H provide details on the circumstances which require corrective actions to be concurred in by the third-party.
As stated in Appendix H, for these circumstances the corrective actions must satisfy the RTL and the SRT.
Interrogatory No. 16:
Identify the person (s) who make the decision on which issues arising from SAFETEAM "could potentially impact accomplishment of the CPRT Program Plan" (p. 5).
Answer:
The CPRT Program Director is the person responsible to
decide which issues arising from SAFETEAM are relevant to CPRT. This is contained in PAG-09, Revision 0, entitled
. CPRT Policy on the Review of Ongoing CPSES Licensing and Safeteam Activities for Potential Impact on CPRT Third-Part y.
Interrogatory No. 17:
Identify the criteria used by the individuals identified in response to Question 16 to make the decision on which issues could "potentially impact accomplishment of the CPRT Program Plan" (p. 5).
Answer:
The SRT has prescribed no closed set of criteria, since so doing would rob the Program Director of the ability to deal with situations that might not have been anticipated in the formulation of such criteria. The criteria that the Program Director would employ include (but are not limited to): whether the item in question contains data that would appear to be useful to an RTL in making a decision or judgment with which he is charged, or whether the item describes an issue that, in the absence of
! additional consideration by the CPRT, would interfere with 4
attainment of the CPRT Program goals. Please see PAG-09 at 2: "The CPRT Program Director will review these documents every two weeks to identify those that are directly relevant to the issues within the CPRT scope of review.
(This is a subjective review, and when in doubt as to 1
i
relevancy of document to CPRT activities, the CPRT Program Director will classify the activity as relevant.) If a 1
document is relevant, the CPRT Program Director will so indicate on the document and will designate the affected i
RTL(s)."
Interrogatory No. 18:
Identify the person (s) responsible for transmitting
)
the issues arising from the SAFETEAM to the SRT Chairman (p. 5).
4 Answer:
As contained in PAG-09 (See Response to Interrogatory 16), issues determined to be relevant to CPRT are transmitted by the CPRT Program Director to the appropriate 4
RTL(s) by memorandum with a copy to the SRT.
Int errogat ory No. 19:
Describe in precise detail what role, if any, the SAFETEAM has in deciding which issues arising from the SAFETEAM could potentially impact accomplishment of the CPRT Program Plan (p. 5).
i Answer:
Nonc.
Interrogatory No. 20:
Explain in precise detail, using examples, what type of SAFETEAM issue could potentially impact the I accomplishment of the CPRT Program Plan (p. 5).
i
, Answer:
1 Please see our response to Interrogatory No. 17, I supra.
l
Interrogatorv No. 21:
Identify all the reports from the CYGNA Independent j Assessment Program that were assigned to Review Team
~
Leaders for review (p. 5).
Ob.ie c t i o n :
Insofar as this interrogatory calls for the identification of actions taken during implementation of the Program Plan, the Applicants object to it on the ground i
that it 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 CPRT Program Plan provides for review of all reports from the CYGNA Independent Assessment Program by the Quality of Construction and QA/QC and Design Adequacy Program Review Team Leaders.
Interrogatories Nos. 22-26:
1 l Describe in precise detail what items or criterin the Review Team Leaders were looking for during their review of the CYGNA IAP reports for issues to be included in Action Plans.
Identify the actual Review Team Leaders or their designees who performed the review to identify issues to be included in the Action Plan.
Describe in precise detail the process by which the SRT will review the RTL's list of identified issues to make their decision regarding proper coverage in approved Action Plans.
4 i
i l
What criteria was used by the SRT to determine whether proper coverage for that issue was provided by the Action Plan?
What input, if any, was solicited from CYGNA to determine whether a particular action plan was adequate to resolve the CYGNA issue?
Objection:
By agreement of the parties, the design aspects of the i
CPRT Program have been excluded from the matters as to which the Board authorized this discovery on August 18 and 19, 198G. Therefore, the Applicants object to these 1 interrogatories.
Interrogatory No. 27:
Identify all persons who have been or are retained as
" experts" within a particular technical discipline, by aren of expertise (p. 5).
- a. For each person listed under a technical discipline, provide a copy of the person's resume.
- b. For each person listed under the specific l technical discipline, describe the basis of the decision to retain that person.
- c. For each person listed under the specific technical discipline, identify what involvement he/she had in the development of the ISAPs/DSAPs for each revision.
- d. For each person listed, identify what involvement he/she had in the review of the results reports.
Objection:
1 The Applicants object to this interrogatory on the ground that the information called for, namely the identification of specific persons performing tasks
. . - . , _ _ - ., . . _ . _ __ _ ,_- _ .,.-._.. _ _ _ -_ ~ . . . _ _ _ . ,--_. - _ . _ , _ . _ . _ _ . _ _ .
described in the Program Plan, is not relevant to the issue of the adequacy of the Program Plan and is therefore beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986. The Applicants further object to this interrogatory on the ground that it pertains to experts retained in anticipation of litigation who have not been designated to testify, and therefore is improper. See Fed. R. Civ. P. 26(b)(4); Commonwealth Edison Co. (Braidwood Station, Units I and 2), LBP-86-7, 23 NRC 177 (1986); Kerr-McGee chemical Corp. (West Chicago Rare Earths Facility),
LBP-85-38, 22 NRC 604 (1985); Carolina Power & Light Co.
(Shenron Harris Nuclear Power Plant, Units 1 and 2), LBP-83-27A, 17 NRC 971 (1983); Public Service Company of New
. Hampshire (Seabrook Station, Units 1 and 2), LBP-83-17, 17 NRC 490 (1983).
+
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, a partial list of the
" Advisers to the CPRT" (to which the reference in Appendix F at 5 is made) are enumerated in Program Plan at 23.
In general, the advisers were not involved in the formulation of the Program Plan or the Action Plans.
l However, where an advisor was used in such a capacity, it was subject to the review and approval of the RTL and
- - - - - - - ~ _ - - - - - , - , -w,- r,.,,,----.v w -- , + v<vm -- - ~ - - - - -w,-- ~m-- - - e--- - - ~ - - ---~~~
ultimately the approval of the SRT. Where an adviser participates in the formulation or implementation of an Action Plan, that fact will be noted in the Action Plan or in the Results Report for the Action Plan or in the Working File for the Action Plan.
Interrogatory No. 28:
For the QA/QC-RTL to the DAP-RTL Interaction responsibilities, which are shown on an interface matrix on pages 8 et seq. of the CPRT, Revision 3, explain in precise detail the actual procedures used to implement the commitment to a certain activity.
Answer:
The below listed procedures provide precise detail on the processes used to control interaction responsibilities:
PAG-08, Revision 0, entitled Policy on CPRT Interfnces for Design and Construction Discrepancies Identified by the ISAP RTIS DAP-2, Revision 4, entitled Documentation and Tracking of Issues and Discrepancies.
DAP-12, Revision 2, entitled DaP Interfaces and Communications.
DAP-10, Revision 3, entitled Processing and Review of Information Between the Quality of Construction. QA/QC l'rogram and the Design Adequacy Program CPP-018, Revision 1, entitled QA/QC Interface with the Design Adenuncy Program Interrogatories Nos. 29-31:
I P
For each item on the matrix, identify the key person or persons who perform the activities which are marked by an "x".
For the "QA/QC-RTL to other RTL" (Section 2 of Detailed Descriptions, p. 10), provide the names of all of the individuals who perform the tasks described in 2, subsections a-f, on page 10.
Explain in precise detail who will be assisted by whom in preparation of the Quality Instructions for use by inspectors (p. 10, Item 2, a).
Objection:
The Applicants object to this interrogatory on the ground that the information called for, namely the identification of specific persons performing tasks described in the Program Plan, is not relevant to the issue of the adequncy of the Program Plan and is therefore beyond the scope of the discovery euthorized by the Board on August 18 and 19, 1986.
4 Answer:
4 Without waiving the foregoing objection, but rather l 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 l
performance thereof. The identity of the specific individual (s) involved in the performance of each Action l
i 4
- , - - - - - - ,en-, ~-,+--r-we.ae-,,- ,----,,e,---,,.i - ---.-,--r
,v-w-w- - - ,---.e -,--- --.--m-en--- en,,--en,-4-- ------4 .
Plan will be contained in the Results Report or in the Working File for that Action Plan once it has been completed.
Interrogatory No. 32:
Identify and describe what type of reports of [or?]
inspection activities are conducted by the QA/QC RTL in support of the ISAPs (p. 10, Section 2, b).
Answer:
Please note that the language contained at the cited location is " reports of inspection activities."
The QA/QC Review Team Inspection Group may be utilized by other Review Team Leaders te conduct inspections for certain Actior. Plans. In such cases, the QA/QC Reviw Team will prepare a Quality Instruction in accordance with CPP-001. The Quality Instruction will be reviewed and approved i
- by the RTL for the Action Plan in question. The results of the inspection will then be submitted to the appropriate RTL.
CPRT Program Plan, Appendix F. Page 10 Item 2.b.
states "Frovides reports of inspection activities conducted J
in support of ISAPs". The QA/QC RTL does not " conduct" reports of inspection activities as misstated in the Interrogatory. The output of individual inspections (i.e.
inspection reports, checklists.) will be provided to other RTLs if applicable to their scope of responsibility. Each i
u I
l Quality Instruction defines the output documents. The reports of inspection activities conducted in support of ISAPs will be contained in the Working File associated with the Action Plan.
~ Interrogatory No. 33:
Describe in precise detail the process by which the QA/QC RTL reviews the ISAP Results Reports for QA/QC implications or generic implications on hardware of programmatic issues (p. 10).
Answer:
Please see CPP-014.
Interrogatory No. 34:
How is it determined whether other RTLs need assistance in conducting the root cause and generic implications analysis (p. 10).
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 responsibic 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. Any need for assistance will be determined on a case-by-case basis by the RTL (with possible comments from the SRT) considering the specific l
evidence developed or the potential causes and implications identified in a root cause or generic implications analysis.
Interrogatory No. 35:
Describe in precise detail what is meant by the activity described in items 2(e) on page 10 of Appendix F as cocrdinating with other RTLs as required to determine safety significance of construction related deviations identified during investigations or inspections.
Answer:
Each RTL has the prerogative to utilize the services of the Quality of Construction group responsible for safety significance evaluation in support of ISAP VII.e. Each RTL will request this support formally, and these evaluations will be transmitted to the RTL for his evaluation and retention, a Upon determination of need by an RTL, they will request input from the QA/QC RTL to assist in their safety signi ficance evaluations.
Interrogatory No. 36:
Explain in precise detail what are the activities _that would be performed for someone to coordinate the ISAP results reports information during collective evaluations (p. 10, Section 2 ( f)) .
, Answer:
Please see CPP-014.
i Interrocatory No. 37:
. Explain in precise detail what it means when there is i
f I
l i
I i
. , _ . . - . . . _ _ _ ..,. ,,_..____,,_m._ . , , . , _ , _ _ , _ . , _ . _ . . _ - _ _ _ _ _ _ _ . , _ . _ _ _ , _ _ , . _ . . _ _ _ . _ , _ . - _ _ _ . , _ _ . _ _ _ _
an "x" in the " Action by Project" block of the matrix on page 10.
i j Answer:
The term " Action" is described in CPRT Program Plan, Appendix F, page 3. " Action by Project" means that CPRT expects action by CPSES Project personnel.
Interrogatory No. 38:
Explain in precise detail what it means when there is an "x" in the " Info" block of the matrix on page 10.
Answer-The term " Info" is described in the CPRT Program Plan, Appendix F, page 2, in the paragraph entitled Information.
The "x" means that the organization with the "x" will receive the item for " Info."
Interrogatories Nos. 39 & 40:
Identify the management person (s) of the Project who i are responsible for each of the items in the matrix on page i 10.
i
- a. Document and information requests
- b. Support services requests
- c. Identified deviat ions and deficiencies (prepare NCR and review for 50.55(e) reportability).
{ d. Corrective actions Identify all persons of the project who participate in or implement the project's actions for each of the following items on the matrix on page 10.
. a. Document and information requests I
- b. Support services requests
- c. Identified deviations and deficiencies (prepare NCR and review for 50.55(e) reportability).
T
- d. Corrective actions Objection:
The Applicants object to these interrogatories on the ground that the information called for, namely the
- identification of specific persons performing tasks described in the Program Plan, is not relevant to the issue of the adequacy of the Program Plan and is therefore beyond the scope of the discovery authorized by the Board on August 18 und 19, 1986.
a Interrocatory No. 41:
l Identify and define all types of information developed through the action of the discipline review teams referred to on page 17 of Appendix F. Provide specific examples.
, Answer:
The types of information referred to on page 17, as categorized in the matrix on page 17, are as follows:
Action Plans - Those Action Plans found in Appendix C of the Program Plan.
Items Identified...in SSER - This category consists of external source issues which a Review Team Leader wants to call to the particular attention of the QOC Review Team, to assure that all external source issues are being covered by the appropriate Review Team.
\
I l
_._ _ _ __ __ . _ . __ _ _ - . . - . _ . . .. . _ m.
Findings... - This category includes items discovered i
by a discipline Review Team which in the opinion of that Review Team pertains to QA/QC matters or specific items directly found to be discrepant by the discipline Review Team.
4 Request for Inspection - Items for which the QOC l
inspection group provided inspection services for other discipline Review Teams.
Please see PAG-08.
Interrogatory No. 42:
4 Explain in precise detail the methods by which each category of information identified above is "made available
- to the QA/QC group" (p. 17).
i
- Answer
i i
Please see PAG-08.
1, Interrogatory No. 43:
What, from Mr. Hansel's perspective, are all items
- that would be of interest from "a QA/QC viewpoint" (p. 17)?
l j
Ob.lec t i on :
i The Applicants object to this interrogatory on the 4
- 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, 198G.
1 Answer:
r i
i i
i 1
1
- . . - , - - . ,,,y,..-- -. ,.m,.,.,,m, .-7,, - , - , , ,,,,. ~,7, 7 ..m_,,m.,_, ..,_v., , , - - - _
}
Without waiving the foregoing objection, but rather expressly relying upon the same, this question cannot be answered in a vacuum, but rather will depend upon what is found during implementation of the Program Plan. Items of interest are any items which the Quality of Construction and QA/QC HTL deems pertinent to the interpretation of compliance to QA/QC codes and standards which TUGC0 has committed to follow.
Interrogntories Nos. 44 A 45:
Identify and describe the extant process and criteria by which " deficiencies" are determined to be common to more than one discipline (p. 17).
Identify and describe the process by which deficiencies are determined to be of a "QA/QC" nature (p.
17).
Answer:
Please see CPP-14.
Interrogntories Nos. 4G-48:
Identify the person (s) who have the responsibility to combine deficiencies of a QA/QC nature as defined above for further evaluatlon.
For each of the 4 items identified on the matrix on page 17, identify the person (s) responsible for the functions identified by "x" in the columns.
Identify the person (s) responsible for ensuring that the Review Team Leaders are furnished with the information that is committed to be furnished per the matrix to other RTLs (p. 18).
Objection:
The Appliennts 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. 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.
Interrogatories Nos. 49 L 50:
The matrix on page 18 contains the category " Findings identified ns possibly applicable to other responsibility area." Explain and describe in precise detail the criteria and the process by which these findings are identified.
The matrix on page 18 contains the category "Information considered helpful to other RTL." Explain and describe in precise detail the criteria and the process by which this "information" is identified,
- reviewed, analyzed, categorized, should be shared with other RTLS.
Answer:
l :
i
._ . _ _ . . _ _ ~ - _ - _ ~ _ - _ . _ - _ . . . - - - - - . . _ . . .- -- _ . - .
i M
+
Please see PAG-08.
Interrogatory No. 51:
) Explain what is meant by the footnote on page 19 which l
states that Corrective Action is only tracked by the Program Director.
2 Answer:
i
.The footnote means that the only " action" taken by the Program Director is tracking. He is not responsible for
- j. implementing specific actions required by the item.
Interrogatories Nos. 52-56:
i
!' What action is taken by the CPSES project on the
" action plans" (p. 20).
What action, work coordination, data requests, or corrective action is required by the CPSES project in
{ response to the CPRT document information requests (p.
20)?
! What action, work coordination, data requests, or corrective action is required by the CPSES project in response to support services requests (p. 20)?
f j What action, work coordination, data requests, or j
corrective action is required by the CPSES project in l response to identified deviations or deficiencies (p. 20)?
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j
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What action, work coordination, data requests, or corrective action is required by the CPSES project in response to corrective action (p. 20)?
Answer:
r '
i The actions by the CPSES project that CPRT expects to
- be taken are specified in each Action Plan, as well as in j Program Plan Appendices E and H.
4 Interrogatories Nos. 57-59 & 61 & 63-64:
l
}
t t
i
Identify each person within the CPSES project with management responsibility for initiating, directing, deciding, evaluating, responding to, providing, deciding not to provide, or implementing any action in response to each of the following items:
- a. action plans
- b. document information requests
- c. support services requests
- d. identified deviations or deficiencies
- c. corrective action Identify each person within the CPSES project with implementing responsibility for initiating, directing, deciding, evaluating, responding to, providing, deciding not to provide, or implementing any action in response to each of the following items:
Identify the APGM-Unit 1 and APGM-Unit 2.
Identify each individual in the CPSES project who has any responsibility for implementing CPRT program requirements,
- n. Provide the personnel chart or list for the construction group dedicated to CPRT program requirements,
- b. Identify the person (s) from each of the three technical groups who are responsible for interfacind directly with the third party RTL.
- c. Identify each of the person (s) from all contractors who are responsible for performing review, evaluations, and analysis that is overviewed by a third party element.
Identify each CPSES project person (s) assigned to each of the technical groups who perform the review of the CPRT action plans, implementing procedures, and results reports for the purpose of:
- a. providing a historical perspective.
- b. determining corrective action.
- c. determining plan implementation.
Identify each person (s) on the CPSES project who evaluates, reviews, decides whether to take action in light of, or otherwise reacts to the findings of the CPRT inspectors, and describe in detail their duties and the criteria and/or procedures that govern their duties with respect to findings of the CPRT.
Objection:
The Applicants object to these interrogatories on the ground that the information called for, namely the identification of specific persons performing tasks described in the Program Plan, is not relevant to the issue of the adequncy of the Program Plan and in therefore beyond the scope of the discovery authorized by the Board on August 18 nnd 19, 198G.
Interrogatories Nos. 60 & G2:
Identify all of the CPSES project procedures used for coordinating CPRT activities and CPSES project activities.
If there are no procedures, describe the process in precise detail.
Describe in precise detail how the project personnel who are responsible for obtaining the required project information or access to the hardware will do so for each ISAP, DSAP, and QOC action plan.
l Example: In ISAP I.a.4, project QC inspectors Jon j Jones and Bill Smith accompanied the ERC inspectors during l the actual hardware inspection.
i Answer:
The methods for obtaining information or access to 1
l hardware is varied and will be handled on a case-by-case i
j ,
I 1
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i e
basis. Standard project procedures are utilized.
Interrogatory No. CS:
produce for inspection and copying all documents identified in the answers to these questions and all documents examined and/or relied upon in answering these questions.
Answer:
Apart from documents objected to, it is not believed that any documents of which copies have not already been produce for inspection by CASE are so described (except for Cpp-014, which has been modified since last provided to CASE). Nonetheless, the 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 specifica]Iy 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.
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 as familiar with the information contained in the CFRT files and available to e 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.
Terry . Tyl Sworn to before me this
_h__ d a y o f Oc.Leb er , 1986 :
//DJensDGAb
- A - - h*-----
My or:n l expires: __Q @_$_ _ _k__,,______
As to Objections:
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____J_____________ 'r_i_ _ _--+-
Thomas G. Digna , Jr.
R. K. Gad III William S. Eggeling Kathryn S. Selleck Ropes & Gray 225.Frankling Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 l
L I
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EYSW 90@M OX K E ii t t%M CERTIFICATE OF SERVICE '86 tc/12 N .2B GFFL ,!
I, Robert K. Gad III, oneoftheattoneysforthe9i[ffijyats'([' 0 herein, hereby certify that on November 986, I made service of the within " Applicants' Answers to CASE CPRT Program Plan Interrogatories (Set No. 6)" by msiling copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident, Inspector Administrative Judge Comanche Peah 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 Nancy Williams Administrative Judge Cygna Enargy Services, Inc.
881 W. Outer Drive 101 California Street, Suite 1000 '
Oak Ridge, Tennessee 37830 San Francisco, California 94111 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 i 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 Bethesda, Maryland 20814 Ms. Billie P. Garde Midwest Office 3424 N. Marcos Lane Appleton. Wisconsin 54911
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I 1 Robert K. hd III 1
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