ML20213F485
| ML20213F485 | |
| 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-#486-1465 OL, NUDOCS 8611140229 | |
| Download: ML20213F485 (64) | |
Text
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Filed: NoveDber 7 1986.
1965 UNITED STATES OF AMERICA REULTED CCagESYONDYOb NUCLEAR REGULATORY COMMISSION DOLMETED Uf>?iRC before the ATOMIC SAFETY AND LICENSING BOARD 86 E 12 Pi2:21 CFr 0%
)
In the Matter of
)
a
)
Docket Nos. 50-445-d' TEXAS UTILITIES ELECTRIC
)
50-446-ek 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. 3)
Pursuant to 10 C.F.R.
sec. 2.740 ff, the Applicants hereby submit their responses to CASE's "CPRT Discovery -
3," 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" (pages 7-10), insofar as the same are l
l contrary to the Rules of Practice.
l Design l
By agreement of the parties, and with the concurrence of the Board, matters regarding the adequacy of design aspects of the CPRT Program Plan have been excluded from the matters in respect of which the Board authorized 8611140229 861107 l
l PDR ADOCK 05000445 G
PDR t)S 03
a 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 by name, title, and organization the individuals who participated in the decision to develop the Comanche Peak Response Team (CPRT).
(Revision 3, Pg.
1-of the section on Program Principles and Objectives).
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 expressly relying upon the same, the Comanche Peak Response Team was established by Mr. Spence on September 22, 1984.
(See " Meeting Minutes - Senior Review Team Meeting on 9/22/84.
Please see also Mr. Spence's Memorandum of 9/24/84 on this subject.
Both of these documents are contained in the CPRT Central File, which has previously been made available for inspection by CASE.)
Mr. Spence is s
I O
the President of Texas Utilities Generating Company.
Interrogatory No. 2:
Identify all meetings, between July 1, 1984 and October, 1984 at which the response to the September 18, 1984 letter from the Technical Review Team (TRT) was discussed.
(pg. 1)
(a)
For each meeting identified list all participants, whether or not they are employees of other owners, TUEC, Brown & Root, other site contractors, subcontractors or consultants.
(b)
For each meeting identified produce all documents, (see instructions) in the possession of any of the participants.
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 expressly relying upon the same, to the extent that the I
referenced subject was discussed at meetings of the SRT, the minutes of those meetings have previously been made available for inspection and copying by CASE.
j Interrogatory No. 3:
Produce all drafts of Rev. O of the program plan.
Objection:
' l i
r-i o
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, we are not aware of the existence of any drafts of Revision 0 other than the final approved document, which is contained in the CPRT Central Files and which has already been made available for inspection by CASE.
[ Susan Palmer to double check corporate files in Dallas and interview Fikar, George, Clements, Beck, Merritt, Vogelsang, Hooten, McBay, Moehlman, Camp, etc. to see if they have drafts of Rev. O of the Program Plan.)
Interrogatory No. 4:
Describe in detail the process (each step in the l
development, research, writing, editing and finalizing) l used to develop the CPRT program approach (objectives, scope, breath, methodology, details, etc.) taken in Rev.
O.
l 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 l (
r on August 18 and 19, 1986.
Interrogatory No. 5:
Was any consideration given to the appropriateness of using then current site QA/QC personnel (e.g.,
Tony Vega, Ron Tolson) in the CPRT development process or the CPRT Plan itself?
(a)
If yes, what consideration was given and by whom.
(b)
If no, why not?
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.
Interrogatory No. 6:
The CPRT, Rev.
3, states that TUEC has made a number of changes to the CPRT Program as a result of three listed factors.
For each factor answer the following questions:
(a)
" Additional Meetings" - Identify all meetings with the NRC, CASE, Cygna and allegers which provided any impetus for change in the CPRT.
(b)
For each meeting identify the time, place, participants, and topics discussed.
(c)
For each meeting provide all documents in the possession of any of the attendees (or their representatives or colleagues) who l
participated in the meeting at the request of TUEC, other owners, Brown & Root, or any of the contractors, subcontractors or consultants.
(d)
" Additional NRC Requests For Information" -
identify all requests for information received from the NRC which provided any impetus for changing the CPRT.
r (e)
For each " request for information" identify in what way it influenced a change to the original CPRT.
(f)
Identify each change which was generated by additional request for information from the NRC.
(g)
In regards to TUEC's determination that the CPRT should engaged in a self-initiated evaluation completely explain the full basis of that determination.
(h)
Identify all meetings at which the self-initiated evaluation was discussed.
(i)
For each meeting identified list all the participants in each meeting, and identify each participant's title and organization.
(j)
For each meeting identified produce the documents used at that meeting or generated in preparation for, at or as a result of the meeting which are in the possession of any of the participants, or in the possession of TUEC, the other owners any of their contractors, subcontractors or consultants.
Objection:
The Applicants object to this interrogatory, on the ground that the requested information is not relevant to I
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:
l l
Without waiving the foregoing objection, but rather expressly relying upon the same, the following information is supplied:
l l
The Nuclear Regulatory Commission (NRC) established a Technical Review Team (TRT) to review certain aspects of !
r the Comanche Peak Steam Electric Station (CPSES).
The purpose of the TRT was to evaluate certain technical issues and allegations of improper construction practices at CPSES.
In July 1984, the TRT began onsite activities as part of its review plan, using a team divided into five groups:
electrical / instrumentation, civil / mechanical, QA/QC, coatings, and testing program.
On September 18, 1984, a public meeting was held in the NRC's offices in Bethesda, Maryland, at which the NRC management and the TRT presented Texas Utilities Electric Company (TUEC) with a request for additional information.
This request was based on the results of the TRT efforts to date in the electrical / instrumentation, civil, and testing program areas.
The TRT stated that they required additional information in order to make a determination of the safety significance of certain concerns.
The TRT request for information was documented in an j
attachment to an NRC letter dated September 18, 1984.
The request was divided into three primary areas and several sub-areas, each representing a subject of concern to the TRT.
TUEC founded the Comanche Peak Response Team (CPRT) and developed a program plan and individual action plans for each of the issues identified in the September 18, 1
l l !
l l
l
r 1984 letter.
The program plan and the Issue-Specific Action Plan (ISAPs) were submitted to the NRC by letter dated October 8, 1984.
Subsequently, public meetings were held at the NRC's Bethesda, Maryland, offices on October 19 and 23 at which TUEC made verbal presentations of the program plan and the action plans, obtained verbal NRC comments and provided clarifications by answering questions.
On November 29, 1984, the NRC-TRT sent a letter to TUEC containing potential open issues and requesting additional information for the resolution of allegations and concerns related to mechanical, piping, and miscellaneous topics.
The CPRT developed ISAPs to fully investigate and resolve these concerns.
The NRC's letter to TUEC also contained the status of the evaluation of coatings allegations.
On January 8, 1985, the NRC issued a letter to TUEC informing it of the TRT's findings in-the construction QA/QC area.
In the letter NRC requested a program and schedule for completing a detailed and thorough assessment of the QA issues contained therein.
The CPRT developed ISAPs to fully investigate and resolve these concerns.
In mid-January 1985, the NRC issued Supplement to the Safety Evaluation Report (SSER)-7 on e
electrical / instrumentation and testing findings.
CPRT revised action plans as necessary to reflect additional insights presented in the SSER.
On January 17, 1985, a public meeting was held in the NRC's offices in Bethesda, Maryland, at which NRC management discussed the contents of the January 8 letter with TUEC and the CPRT.
On February 7, 1985, representatives of CASE, TUEC, and the CPRT met with the NRC Contention V Panel in Arlington, Texas.
The CPRT presented the scope and findings in the implementation of the electrical, testing, civil / structural, QA/QC and mechanical action plans to date.
At this meeting Mr.
Spence, President of TUGCO, announced to the NRC that the CPRT would be investigating design adequacy as a part of its charter.
Also, at the I
same meeting, CASE had a dialogue with the Contention V Panel on many of the CPRT issues.
i In mid-February 1985, NRC issued SSER-8 dealing with i
civil, structural, and miscellaneous areas.
CPRT revised l
action plans as necessary to reflect additional insights l
l presented in the SSER.
On February 26 and 27, 1985, the CPRT met the NRC-TRT at Comanche Peak to discuss TRT concerns in the piping and pipe support area and to discuss conceptual CPRT activities t 1
O in this area.
On February 28, 1985, the CPRT met with the NRC-TRT at Comanche Peak to describe the electrical Issue-Specific Action Plans and implementation results to date.
On March 5, 1985, the CPRT met with the NRC-TRT at Comanche Peak to discuss the approach to be taken to resolve the QA/QC issues raised in the January 8,
- 1985, letter.
On the morning of March 6, 1985, the CPRT met with the NRC-TRT at Comanche Peak to describe the testing ISAPs and implementation results to date.
On the afternoon of March 6, 1985, the CPRT met with the NRC-TRT at Comanche Peak to describe the civil / structural ISAPs and implementation results to date.
On March 7, 1985, the CPRT net with the NRC-TRT at Comanche Peak to describe the mechanical ISAPs and implementation results to date.
l On March 14, 1985, the CPRT met with Cygna in San Francisco to understand the full extent and breadth of their concerns which have arisen from their conduct of the CPSES Independent Assessment Program.
l l
In mid-March 1985, NRC issued SSER-9 declassifying protective coatings at CPSES.
Based on the findings of this SSER the CPRT eliminated the RTL position for l
e protective coatings.
On March 23, 1985, the CPRT met with CASE, in particular Messrs. Walsh and Doyle, to hear first hand their concerns in the pipe and pipe support area.
In late-April 1985, the NRC issued SSER-10 dealing with mechanical and piping issues.
CPRT revised action plans as necessary to reflect additional insights presented in the SSER.
On April 23, 1985, TUGC0 submitted a draft revision of the CPRT Program Plan and final revision of the electrical, civil, structural, testing, and miscellaneous action plans to the NRC for review.
In late May 1985, the NRC issued SSER-ll on QA/QC issues.
CPRT revised action plans as appropriate to reflect insights provided in the SSER.
On June 13 and 14, 1985 TUGC0 met with NRC in a public meeting in Arlington, Texas, to discuss CPRT activities in the design adequacy and quality of construction and QA/QC program adequacy areas.
In early July, 1985, TUGC0 submitted revision 2 of the
{
CPRT Program Plan and associated ISAPs and DSAPs related to Design Adequacy, Quality of Construction and QA/QC Adequacy and Testing Adequacy Programs to NRC.
On August 9, 1985, NRC transmitted their NRC Staff e
Evaluation of the CPRT Program PJan - Programmatic Comments to TUEC.
On September 17, 1985, TUGC0 met with NRC in a public meeting in Bethesda, Maryland to discuss visual inspection of welds through paint.
On September 30, 1985, NRC transmitted NRC Staff Evaluation of the CPRT Program Plan - Detailed Comments to TUEC.
On October 10 and 11, 1985, TUGC0 set with NRC in a public meeting in Granbury, Texas to discuss the basis for establishing homogeneous hardware populations in the Quality of Construction and QA/QC Adequacy Program and the Stone and Webster pipe and pipe support reanalysis program.
On November 5 and 6, 1985, TUGC0 met with NRC in a public meeting in Granbury, Texas to status CPRT l
implementation and discuss the results of recent NRC audits of the CPRT Program.
On November 22, 1985, TUGC0 submitted responses to l
NRC's comments on the CPRT Program.
l On December 2, 1985 the NRC stated that they had no objection to the proposed use of CPP-022, Rev. O
" Supplementary Evaluation of Visual Welding Inspection Techniques" submitted by TUGC0 letter dated October 3, 1985.
l l
1 l
e o
On December 18 and 19, 1985, representatives of TUGC0 met with the NRC in a public meeting in Arlington, Texas to discuss the cable tray as-built program and status of CPRT program plan activities.
On January 21, 1986, the NRC transmitted the results of its inspection of the Comanche Peak Design Adequacy Program Scope Validation Process and Review Checklist Development (Inspection Report 85-17/14).
On January 31, 1986, TUGCO submitted Revision 1 of Appendix D, "CPRT Sampling Approach, Applications, and Guidelines" to the NRC.
On February 6, 1986, representatives of TUGC0 met with the NRC in Arlington, Texas to discuss the hearing and licensing issues relating to Comanche Peak.
On February 7, 1986, TUGCO submitted Appendix E, "CPRT l
Procedure for the Resolution of Discrepancies Identified by l
the CPRT" to the NRC.
l On February 13, 1986, the NRC conducted an audit of the cable tray design verification program at EBASCO's New York office.
l On February 28, 1986, TUGCO submitted the Testing ISAPs (except ISAP III.a.}) and separately submitted a l
description of the CPRT Overview Quality Team (OQT) to the l
NRC and the ASLB.
l
! l l
l t
n On March 14, 1986, TUGCO submitted the Train C Conduit
- Two inch and Under, Criteria Document and Appendices to the NRC.
This document was prepared for TUGC0 by 1MPELL, GIBBS & HILL and EBASCO.
On March 14, 1986, TUGCO submitted the EBASCO responses to NRC questions and document requests discussed at the February 13, 1986, audit of EBASCO.
On March 18, 1986, representatives of TUGC0 met with the NRC in Bethesda, Maryland, to discuss statistical matters discussed by the ASLB in its 11/11/85 Memorandum (Statistical Inferences from CPRT Sampling).
On April 4, 1986, TUGC0 submitted five SRT approved Results Reports (I.a.4, I.b.3, II.b, III.d, VII.b.2) to the NRC and ASLB and also made available for inspection the backup for these Results Reports.
On April 22, 1986, a prehearing conference before the ASLB was held in Dallas to discuss status of CPRT and l
l schedule for hearings.
Representatives of CASE, NRC, and l
TUGC0 participated.
On April 28, 1986, the TRO ite transmitted a request for additional information on the five Results Reports l
issued on April 4,
- 1986, (I.a.4, I.b.3, II.b, III.d, VII.b.2).
TUGC0 submitted its response to this request on May 2, 1986. l l
l l
{
I
On May 9, 1986, the NRC Staff transmitted a request for CPRT Checklists.
TUGC0 submitted its response to this request on June 9, 1986, and submitted the checklists on July 11, 1986, with periodic updates to follow.
On May 13, 1986, TUGC0 submitted to the NRC and ASLB revisions of ISAP III.a.1, VII.a.9 and VII.b.l.
On May 15, 1986, the NBC Staff transmitted a request for additional information regarding ISAP VII.b.2, Valve Disassembly.
TUGC0 responded to this request on May 23, 1986.
On June 5, 1986, representatives of.TUGC0 met with the NRC at Comanche Peak to discuss SSER No.
8.
On June 5, 1986, TUGC0 submitted the response of the CPRT to the Board's 14 questions and responses to CASE's document requests and interrogatories regarding Results report I.a.4.
On June 6, 1986, TUGC0 submitted Results Reports I.a.3 and VII.a.4 and Appendix E, Revision 2 of the CPRT Program l
l Plan to the NRC and ASLB.
l On June 9, 1986, the NRC Staff transmitted a request
(
that an audit program be established and implemented by the
{
i SRT for the TRT ISAP program.
TUGC0 submitted a response
{
l to this request on July 23, 1986, describing the actions L
taken by the SRT and OQT.
l l
l l
l !
t i
i
On June 9, 1986, the NRC Staff issued Supplement No.
13 to the Comanche Peak, Unit Nos. 1 and 2 Safety Evaluation Report (NUREG-0707) (SSER-13).
On June 13, 1986, the NRC Staff transmitted a request for additional information related to ISAP I.a.4.
TUGCO submitted a response to this request on July 23, 1986, discussing additional sampling undertaken on ISAP I.a.4 and out-of-scope observations.
On June 19, 1986, the NRC Staff transmitted a request for additional information related to the revisions made to Appendix E of the CPRT Program Plan, Rev.
2.
TUGC0 submitted a response to this request on July 23, 1986, and submitted a revision bar annotated copy of Appendix E, Rev.
2 to the NRC Staff.
On July 9, 1986, TUGCO submitted the Report on Stone &
Webster Engineering Corporations's Evaluation and desolution of Generic Technical Issues to the NRC Staff.
On July 15, 1986, the NRC Staff transmitted a request for additional information regarding ISAP VII.b.2 " Valve Disassembly".
TUGCO submitted a response to this request on July 25, 1986, discussing the status of documentation of certain valve bonnets.
On July 28, 1986, TUGC0 submitted copies of the updated procedures for implementing the SWEC proposed methods for _
assuring resolution of external source issues which relate to pipe stress analysis and pipe support design.
On July 30, 1986, the Applicants submitted to the ASLB their first Progress Report and Annotated Bibliography in accordance with the Board Order of June 6, 1986.
On July 31, 1986, the NRC transmitted their comments on ISAP's submitted on May 13, 1986 (III.a.1, VII.a.9, VII.b.1).
On August 11, 1986, TUGCO submitted ISAP III.a.S "Preoperational Test Review and Approval of Results" to the NRC.
This ISAP was generated to address ASLB concerns as described in Board Memorandum dated December 21, 1984.
On August 11, 1986, TUGCO submitted SRT approved Results Reports I.a.4, I.a.5, and VII.a.S to the NRC and ASLB and on August 14, 1986, made available for inspection the backup files for these Results Reports.
On August 14, 1986, TUGC0 submitted the CPRT response to the Board's 14 questions regarding Results Reports I.a.3, III.d, VII.a.4, VII.b.2 to the Board.
On August 18 and 19, 1986, a pre-hearing conference before the ASLB was held in Dallas, Texas to discuss scheduling of the case and outstanding discovery disputes.
Representatives of TUGCO, NRC and CASE participated.
On August 19, 1986, TUGC0 submitted the SRT approved.
Results Report III.a.4, Traceability of Test Equipment, to the NRC and ASLB.
On August 21, 1986, the backup files for these Results Reports were made available for inspection.
On August 21, 1986, representatives of TUGCO met with the NRC in a public meeting in Arlington, Texas to discuss CPRT progress.
On August 28, 1986, representatives of TUGCO met with the NRC in Bethesda, Md. to discuss Comanche Peak FSAR Updates for Stone & Webster Piping Requalification Program.
On September 9, 1986, the NRC transmitted to TUGCO the results and conclusions of its inspection of the DAP, implementation of DSAP X, Mechanical Systems and Components (Inspection Report 86-18/85).
On September 12, 1986, TUGCO submitted the SRT approved Results Report I.d.3, Craft Personnel Training, to the NRC and ASLB.
The backup files for this results report were made available for inspection on September 16, 1986.
On September 17, 1986, TUGCO submitted the documents for " Evaluation and Resolution of Generic Technical Issues for Cable Tray Hangers" prepared by EBASCO and IMPELL for l
l TUGCO.
On September 19, 1986, TUGCO submitted copies of Stone
& Webster's Comanche Peak Project Procedures to NRC.
On September 26, 1986, TUGCO submitted its answers to t -
l t
CASE's first two sets of interrogatories and requests for document production on the adequacy of the CPRT Program (CPRT-1 and CPRT-2).
On September 26, 1986, TUGC0 submitted SRT approved Results Report I.d.2, Guidelines for Administration of QC Inspector Test to the NRC and ASLB.
On September 30, 1986, Applicants submitted their second Progress Report and Annotated Bibliography in accordance with the 6/6/86 Board Order.
On September 30, 1986, TUGC0 submitted the CPRT response to the Board's 14 questions regarding Results Reports I.a.5, and I.b.3 to the Board.
With respect to the decision to include the self-initiated evaluations within the CPRT scope (sub-part (g) of the question), that decision was made by Mr. Spence, at l
l the suggestion of SRT.
I l
With respect to sub part (c), meetings have either l
been in the form of public meetings, which were l
transcribed, or audits, which are documented in NRC l
l correspondence.
Copies of transcripts of meetings are contained in the CPRT Central Files, which have previously been made available to CASE for inspection and copying.
NRC correspondence is sent the Service List, which includes CASE.
With respect to sub parts (h), (i) and (j), meetings of the SRT at which the referenced subject were discussed are contained in the CPRT Central Files, which have already been made available for inspection by CASE.
To the extent that written records may exist of communications between RTLs and NRC Staff personnel in respect of specific Action Plans, such records will be contained in the Working Files for such Action Plans and will be available for inspection and copying by CASE at such time as the Results Reports for such Action Plans have been approved and published by the SRT.
Interrogatory No. 7:
The CPRT states that the scope of the charter was expanded to " include quality of construction and construction QA/QC issues" raised by additional sources.
For each source listed identify the issues for review which I
were included beyond the original scope of the CPRT from the sources listed below:
(Revision 3, pg. 1)
(a)
NRC ASLB OL proceeding (which portion of which order):
(b)
NRC Staff SSER's (which one and which portions):
(c)
NRC CAT inspection (which one and which portions):
(d)
NRC SIT inspection (which one and which portions)
(e)
NRC Region IV Inspection Reports (which one end which portions):
(f)
Cygna Independent Assessment Program (which findings or communications):
(g)
For each of the issues identified in a-f characterize the issue as either a " quality of l
construction concern" or a " construction QA/QC l
[ l l
l l
concern."
Objection:
The Applicants object to this interrogatory.
As set forth in the program plan, development of a comprehensive list of issues raised by the External Sources is one of the CPRT Program Plan outputs.
As a consequence, this interrogatory calls for information regarding the implementation of the Program Plan and is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Further, the Applicants object to this interrogatory on the ground that it calls for information related to CPRT efforts that are still in process and not yet completed or published.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, one of the outputs of the completed CPRT program is expected to be a list of all external source issues addressed, the source of the issue and where it has been addressed.
Please also see
" Applicants' Response to Board Memorandum of 8/8/86 l
(Assistance to the Board)" filed 10/6/86.
1 l
Interrogatory No. 8:
l For each source listed in 7(a-f) identify the issues for review which were included beyond the original scope of the CPRT.
1 l 1
Response
The Applicants incorporate their response to the foregoing interrogatory, which this one appears to duplicate.
Interrogatory No. 9:
The CPRT states that "the charter was expanded to include a mandate of assuring TUEC management of the safety of the plant regardless of the extent to which issues might have been raised by external sources."
(a)
In regards to that statement describe what individuals or group in "TUEC Management" must have the assurance of the plant's safety.
(b)
For each person identified in response to question (a) include that individual's own description of what is considered proof that the plant is safe.
(c)
For each person identified in response to (a) above identify any meetings or presentations in which the CPRT program plan was explained to them or any way in which the individual had input into the CPRT program plan.
Objection:
The CPRT Program Plan calls for the development of information, which the Applicants may in the future offer into evidence in this proceeding, for the purpose of establishing the requisite reasonable assurance regarding the CPSES facility.
Any additional function to be l
l accomplished by the same program is not relevant to these l
[
proceedings, and any additional function is not relevant to the adequacy of the Program Plan to establish that l
l reasonable assurance.
The Applicants therefore object to i !
l l
t
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 Applicants offer the following information:
(a)
Michael D.
Spence, President, William G.
Counsil, Executive Vice President - Nuclear, and John W.
j Beck, Vice President.
(b)
Insofar as it concerns matters possibly relevant to Contention 5: completion of the CPRT Program and completion of all corrective actions derived therefrom that are needed for operation.
(c)
Each of the identified individuals has attended i
numerous meetings at which the CPRT Program Plan, or j
aspects thereof, have been or may have been discussed.
No records exist that would permit an exhaustive catalog of such meetings.
l Interrogatory No.
10:
Identify all CPSES project personnel involved in the CPRT, by category of work responsibility, and when that responsibility started, ended, and or was changed, removed or replaced: l r
-, ~ -
-,--,--.,,,n,
- - - - - - - - -,...,. _,,.,. - -. - - - -, - - -.. ~, - -, _,,
Example:
Reason Person CPRT From To for Responsibility Change Ron Tolson Paint Coatings 10/8/84 - 3/3/85 resigned RTL This question includes site QC Inspectors and QA personnel.
Ob.i e c t i o n :
To the extent that this interrogatory calls for information about the identity of persons who have in the past, are presently or may in the future be engaged in providing support to the CPRT, such information will be contained in the Working Files for each Action Plan, but, except for those Action Plans for which Results Reports have been published, is presently in process.
In addition, the information called for has no relevance to the adequacy of the CPRT Program Plan, as written, to accomplish such of its objectives as might be relevant to these proceedings.
The Applicants therefore object to this interrogatory, on the ground that the requested information is not I
relevant to the adequacy of the CPRT Program Plan, and t
therefore is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
24 -
o Without waiving the foregoing objection, but rather expressly relying upon the same, information regarding principal personnel involved in the CPRT from time to time is contained in prior and current revisions of the Program Plan, and its constituent parts, all of which are contained in the CPRT Central Files that have previously been made available for inspection by CASE.
Interrogatory No. 11:
Identify the reason or reasons which the CPRT program changed from "a project effort" to a "primarily third party effort."
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 l
l expressly relying upon the same, the referenced change was i
effected in order to render moot certain comments expressed by the NRC Staff at a meeting held in Bethesda on October I
i 19 and 23, 1984.
See Program Plan, Attachment 1.
The subject was also discussed at the meetings of the SRT on November 2, 1984, and November 9, 1984, the minutes of _. _ _
which have already been made available for inspection by CASE.
Interrogatory No. 12:
Identify when the CPRT program changed from "a project effort" to a "primarily third party effort."
(a)
Identify what work was completed or partially completed when the CPRT was primarily a CPSES project.
(b)
For work partially completed identify the percentage completed.
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 l
expressly relying upon the same, the date of this change cannot be pinpointed.
However, the SRT approved the
(
l replacement of last of the non-third-party RTLs by a third-party RTL on 11/9/84.
All ISAPs prepared and work i
performed prior to that time were reviewed by the third-party RTL and any actions in the ISAP or work done prior to the RTL review that did not meet the new RTL's satisfaction was either rewritten (Action Plans) and approved by the SRT j i l
l l
. - = -.
~
=
or the work was re performed to the RTL's satisfaction.
Little, if any, of the work called for by the Action Plans had been completed by that time.
Interrogatory No.
13:
For all the work done while the CPRT was a " project effort" identify to what extent any third party overview was done of the original work Example:
The majority of the I.a.4.
inspection work was done on December 29, through January 3, 1984 [ sic) while the CPRT electrical work was under the direction and supervision of project personnel.
To what extent was any CPRT work conducted under the direction and supervision of project personnel reviewed or will it be reviewed by third party experts?
Explain in detail what constitutes a third party expert in your answer and the process of the review.
Answer:
Prescinding from the erroneous premise on which this question is founded, all work done by non-third-party personnel which supports any conclusion of CPRT is reviewed and verified by the RTL, who is responsible for all conclusions.
The precise manner and means by which such review and verification may be accomplished will vary from Action Plan to Action Plan, and is (or will be upon I
completion of specific Action Plans) obtainable by review of the Results Report or the Working File for such plans.
l For the definition of " third-party," please see our l
response to Interrogatory No. 2 of CASE CPRT Discovery -
l Set No.
1.
i
! l
~
Interrogatory No.
14:
Identify at what point and in what manner the CPRT will advise TUEC management to whether or not there is
" reasonable assurance that CPSES has been designed, constructed, and tested such that it is capable of being operated without undue risks to the Public"?
(Pg. 2)
Objection:
The CPRT Program Plan calls for the development of information, which the Applicants may in the future offer into evidence in this proceeding, for the purpose of establishing the requisite reasonable assurance of the CPSES facility.
Any additional function to be accomplished by the same program is not relevant to these proceedings, and any additional function is not relevant to the adequacy 1
of the Program Plan to establish that reasonable assurance.
The Applicants therefore 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 l
on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, by publication of the output documents called for by the CPRT Program Plan, at such time as they have been cowpleted and approved by the SRT.
See Program Plan at 17 (section VI).
Interrogatory No.
15:
Identify which TUEC management officials will receive the CPRT evaluation and from whom, or in what form the report will be received.
Objection:
The Applicants incorporate their objection to Interrogatory No.
9, supra.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, Mr. Counsil; by transmittal of the documents referred to in the response to the prior interrogatory from the SRT.
Interrogatory No. 16:
Explain, by example and definition, when or under what circumstances it would not be possible to " investigate and determine" the root cause of found safety-significant deficiencies.
Objection:
The Applicants object to this interrogatory to the extent that it calls for the disclosure of information that the CPRT is presently in the process of formulating, on the ground that discovery regarding the in process formulation of opinions by expert is not proper discovery.
Answer:
Without waiving the foregoing objection, but rather i
expressly relying upon the same, the SRT had, when the Program Plan was published, no particular scenario in mind.
Investigation will always be possible.
The Program Plan recognizes, however, that a determination of root cause may not be possible in all cases.
Interrogatory No.
17:
To what extent is it an objective of the CPRT to resolve failures to adhere to project QA/QC commitments or procedures?
What process will be used to accomplish this purpose.
Answer:
The CPRT will investigate QA/QC failures in the following circumstances: in connection with the programmatic issue-specific Action Plans; as necessary to investigate root cause of found deficiencies; as necessary to investigate root cause of adverse trends of deviations; and as necessary to complete the QA/QC Collective Evaluation.
The " process" involved in the issue-specific Action Plans is defined in those Plans.
With respect to root cause assessments, see Program Plan at 7& n.
and " Guide on Root Cause and Generic Implication" (CPRT Policy and Guidelines PAG-04); CPP-Oll.
Interrogatory No.
18:
Through what process will the discovery of a root cause assist the CPRT identifying potential generic implications.
Answer:
As is described in the Program Plan, the root cause determined by assessment of a found deficiency is treated
' 1 m__-
.-n vv-.--
as potentially having been the cause of similar, replicate failures elsewhere in the facility (to the extent that the root cause had application elsewhere).
Hence, the
" process" of " identifying" potential generic implications, given the identification of a root cause, is entirely analytic.
Interrogatory No. 19:
i In any investigation into the probable cause of a deficiency, how will the possible " contributing causes" be recorded or preserved?
(page 2, footnote).
Answer:
Any " contributing causes" identified by the CPRT will be discussed in the Results Report and documented in the Working File for specific Action Plans.
Interrogatory No. 20:
i The first paragraph on page 3 describes a complementary process of program expansion.
Identify where in the CPRT the implementation details of the process are explained, or explain how the process works. (Page 3)
Answer:
As is described in the Program Plan, "[t]he investigation and determination where possible of root cause and evaluation for generic implications may lead to I
additional areas of the construction, design or testing processes requiring evaluation, and the evaluation of found safety-significant deficiencies or adverse trends of non-safety-significant deviations or design observations may
. l-3
__._r________
lead to the establishment of additional root causes and potential generic implications.
Similarly, the evaluation of specific deficiencies may lead to the expansion of programmatic issues; and the evaluation of programmatic root causes may lead to the expansion of the review of specific hardware, design or testing activities."
See Program Plan, Appendix B, Attachments 2, 4.
Please see also PAG-04; CPP-011.
i Interrogatory No. 21:
Since the expansion provisions were added after the initial program plan (Revision 0) explain how the work already done was covered by the process described above.
Answer:
The premise of this question is not correct, and therefore it cannot be answered as framed.
Generally, since the Program Plan is not a static document, it is the responsibility of the Review Team Leader to assure himself that all work performed under an Action Plan is consistent with the latest version of the Program Plan (and the Action Plan) in effect at the time a Results Report is submitted to the SRT for approval.
In fact, no Results Reports were published prior to the publication of Rev. 3 of the Program Plan, and all conform to that Revision.
Interrogatory No. 22:
I -.
e Identify what External Source Issues were recognized as having potential generic implications?
(Page 3)
Answer:
The interrogatory has lifted the referenced material out of context and, in the process, has assumed a connotation not intended.
The statement in question, which appears at Program Plan at 3, was intended to articulate the proposition that, given what generic implications might be hypothesized, were some of the TRT issues to be confirmed, the resulting investigations for root cause and generic implications bounding that would otherwise be required would take the CPRT into areas that, if aggregated, could extend nearly as far as the scope of the self-initiated actions.
By undertaking the self-initiated actions directly, CPRT was able to capture whatever effort might be required to pursue found deficiencies while at the same time achieving certain economies of anticipation as well as enhancing the scope of the ultimate statements CPRT would be able to make.
All External Source Issues are recognized as potentially having generic implications if determined to be both valid and safety significant.
Interrogatory No. 23:
For each of the issues identified in response to question 22 describe the process through which that decision was made, this includes but is not limited to the
, i 1
_ - _ ~.
e following:
(a)
Identify all persons or the person responsible for identifying each of the external source issues with
" potential generic implications."
(b)
Identify all discussions or meetings, at which the topic of the potential generic implications were discussed, who they were between, when they occurred, and the individuals present.
(c)
Produce all documents developed for or at the discussions identified in response to Item 23(b) above.
Answer:
No answer required.
Interrogatory No. 24:
The SIE does not include in its objective the need for supporting bases for conclusive statements about adequacy of the QA/QC program or its implementation.
Why is this left out of the SIE?
Answer:
The goal of the self-initiated aspects of the CPRT Program is to afford confidence regarding the present state of the as-designed, as-constructed facility.
The QA/QC program is but one of the many components of the process by which that facility was created; the process also includes i
l the construction capabilities of the craft, the instructions and training given to the craft, the testing program, overview inspections by such organizations as the ANI, as-built engineering walkdowns, and other things.
It is, however, the product of the entire process that is !
+
relevant for purposes of the providing the reasonable assurance requisite to the Operating I.icense proceeding.
Once assurance of the present state of the facility has been established, it is functionally irrelevant (i.e.,
incapable of further affecting that determination) precisely which portian of the process was responsible for the non-existence of deviations (i.e.,
causes the facility to be designed and constructed properly or caught instances where it was not).
Consequently, while the CPRT Program ;s indeed concerned about the non-function of QA/QC wherever found deficiencies exist -- as a means of determining the extent to which one found deficiency may indicate the existence of I
others -- the concern of the self-initiated program with QA/QC is as a means of achieving the stated goal (and not as an end in its own right).
As stated in the Program 4
Plan, output will include statements about the adequacy of both design and construction QA to the extent indicated by the implementation of the Program.
The Program's goal, however, neither includes nor requires an assessment of the implementation of the historical QA/QC program beyond the function described above.
Accordingly, if and to the extent that the premise of the question is correct, which from its phraseology we i
?..-
cannot tell, this explains why.
Interrogatory No. 25:
Identify the person or persons within the CPRT who
" recognized" the need for additional investigative efforts to support conclusive statements regarding the CPSES quality of construction and design.
(Page 3)
Answer:
The recognition referred to was achieved by consensus of the SRT.
(We wish to point out that the question has taken the statement of the Program Plan somewhat out of context, and in the process transmuted the statement made therein into some sort of interim finding about the quality of the facility.
The statement made in the Program Plan was that, as a result of pursuing the root cause and potential generic implications of the issues raised by others, studies reaching into many of the same areas as is done in the self-initiated assessment might be required, and that proceeding directly to the global effort described in this section of the Program Plan, in addition to permitting conclusions to be drawn that were not dependent upon the scope of externally-raised issues, also permitted issues and potential issues to be enveloped more expediently and i
in a more organized fashion than might otherwise be the case.)
Interrogatory No. 26: l
s Identify the basis of the SRT determination that "the testing area did not require a self-initiated effort."
(Page 3)
(a)
Identify the person or persons on the SRT who reached the decision not to include testing in the SIE.
(b)
Identify all documents (see instructions) which were generated in the decision-making process regarding leaving the testing area out of the SIE.
Answer:
At the time of the publication of Revision 3 to the Program Plan, the SRT considered whether, in order to achieve global scope in the testing area similar to that achieved in the design and construction areas, a self-initiated program was required in order to extend the breadth of the investigation beyond that required in order to respond to the External Source issues.
The SRT concluded that no such expansion was required because the i
i investigations undertaken in the testing Action Plans responsive to External Source issues essentially covered all of the aspects of that program that might be the subject of a self-initiated investigation.
The judgment in question was reached by the SRT acting collectively and collegially.
No specific documents have been identified that were generated as a result of the decision-making process other than the Program Plan.
Interrogatory No. 27:
l l
l 1. - -,
i s
~
To what extent is the SIE determining that the investigative efforts of the CPRT program are of sufficient depth and breadth to permit the conclusions for the components of the external source investigations to be extended to:
(a) the balance of the installed hardware at the plant, (b) the adequacy of the QA/AC program as implemented during the construction of the plant.
Answer:
Please see our response to Interrogatory No. 24.
4 Interrogatory No. 28:
i Identify what portions of the plant are considered
" safety-related" in the commitment on page 3.
Answer:
Please see the response to Interrogatory No. 20 of CASE's "CPRT Discovery - Set 1."
Interrogatory No. 29:
Explain, by example and definition, when or under what j
circumstance it would not be possible to " investigate and determine" the root cause of found safety-significant deficiencies or adverse level (sic: trend] of non-safety j
significant deviations or design observations.
(Page 4) l Answer:
i l
Please see our response to Interrogatory No. 1G, which this interrogatory appears to duplicate.
Interrogatory No. 30:
To what extent is accomplishment of these objectives (referred to in the previous question) dependent upon compliance with specific program procedures and commitments as opposed to compliance with the program's general principles.
l l l
Answer:
I If the intended question is, are detailed procedures required in order to assess with accuracy the root cause of a found safety-significant deficiency, the answer is probably in the negative.
Procedures are employed to achieve uniformity when repetitive operations are being i
conducted over time and by different people; they are akin to checklists.
A procedure is helpful to insure that something is done, but it is not always necessary to tell l
l someone how to do it.
In the main, the determination of i
root cause is guided by the knowledge, experience and judgment of the personnel involved in the assessment, and it is doubtful that these qualities can be conferred by procedure or that detailed procedures are particularly I
helpful for what is inherently an analytical task.
If the question is, what " procedures" has the SRT promulgated in this area, please see our response to l
Interrogatory No. 17.
I If the question intended to be something else, we do 1
i not understand what was intended.
J Interrogntory No. 31:
l Have any situations arisen which made it appropriate to revise the conduct of the CPRT as identified on page 4?
j (a)
If the answer to the above question is yes, identify all the situations which have arisen and what
! i i
l l
changes resulted in the CPRT.
(b)
If the answer is yes, identify all documents which describe or explain each situation and/or which were generated or used in making the decision.
Objection:
The Applicants object to this interrogatory, on the ground that the requested information constitutes the results of implementation of the Program and is neither i
relevant to the adequacy of the CPRT Program Plan nor within 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 SRT is presently considering revisions to the Program Plan but has not yet made final decisions.
It is expected that Revision 4 of j
the Program Plan will be approved and published prior to the end of the calendar year.
l Interrogatory No. 32:
Have any situations arisen where it has become appropriate to revise the scope of the CPRT's activities?
(a)
If the answer to the above question is yes, identify all the situations which have arisen and what changes resulted in the CPRT.
r, (b)
If the answer to the above question is yes, identify all documents which describe or explain each of the situations above and/or which were generated or used i
making the decision.
6
Response
The objection and answer to the foregoing interroga-tory, which this one appears to duplicate, are incorporated by reference.
Interrogatory No. 33:
Identify the person or persons who decided to include
" experienced third-party personnel" in the CPRT organization and when the decision was made. (pg. 4).
Answer:
Please see the response to Interrogatory No. 11.
As noted there, the purpose in making these changes was to moot certain comments that had been expressed by the NRC Staff.
The changes were not made on a single day: the first step involved the replacement of CPSES Project personnel with third-party personnel as RTLs and the addition of third-party personnel to the SRT.
The second step involved the withdrawal of non-third-party personnel (other than Mr. Beck) from the SRT.
The changes described resulted from a decision made by Mr. Spence.
Interrogatory No. 34:
For each person identified in response to the preceding question include their explanation of why the CPRT organization was changed to ensure "a fresh and objective" perspective. (pg. 4)
Answer:
Please see the responses to Interrogatories Nos. 11 and 33.
Interrogatory No. 35:
In what cases or types of cases will the CPRT identify possible implications of its findings that should be considered by TUEC for impact on design, construction, testing and maintenance after the unit is in operation?
(pg. 6).
Answer:
Such identification will be made wherever SRT judges it to be appropriate based on the results of implementation of the Program Plan and the findings made.
This question cannot be answered in a vacuum.
Interrogatory No. 36:
Identify the process through which the Quality of Construction Review Team will consider closed External Source issues for information regarding potential root cause and generic implications.
Include in the definition any forms or procedures used to do the review.
Answer:
Please see CPP-014.
Interrogatory No. 37:
Explain, by description and example what the type of information the Quality of Construction Review Team would consider in a closed external source issue as relevant to potential root cause and generic implications.
(pg. 6)
Objection:
Insofar as this interrogatory calls for information regarding the results of implementing the Program Plan to date, 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 s
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 our response to the foregoing interrogatory.
Interrogatory No. 38:
Explain by description and example, what type of information the QA/QC Adequacy Review Team would consider in a closed external source issue as relevant to potential root cause a generic implications.
(pg. 6)
Objection:
Insofar as thic interrogatory calls for information regarding the results of implementing the Program Plan to date, 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, please see our response to Interrogatory No. 36, supra.
Interrogatory No. 39:
Explain, by description and example, what type of _ _. _ _..
information the Design Adequacy Review Team will consider in a closed external source issue report as relevant to potential root cause and generic implications.
(pg. 6)
Objection:
For the reasons set forth above under " Design,", the Applicants object to this interrogatory in its entirety.
Interrogatory No. 40:
For each of the CPRT program principles identified on page 6, and explained on pages 7-13 explain in precise terms, using examples from completed Results reports, how the principle objective is achieved.
Include in the response to each, principle answers to each of the following questions.
If the question is not appropriate explain why it is not.
(a)
Identify what individual or group of the CPRT is responsible for conducting the activity.
Example:
John Doe, CYGNA Quality Engineer, is responsible for the " thorough review" for ISAP.A.7.
(b)
Identify what procedures govern the work done to achieve each principle.
Exam:
CYGNA Records Review Procedure 36.1, " Review of Records for the ISAP X.A.7."
used to accomplish the review.
(c)
Identify the individual and/or organization responsible for the insuring that the implementation of the activity to achieve the program principle was properly implemented.
Example:
Jane Smith, CYGNA QA, or another member of the document review team reviews the X.A.7.
records.
(d)
Identify the procedures used to insure that implementation of the activity to achieve each specific program principle was properly implemented Example:
CYGNA QA procedure 3.42 was used to conduct the quality review of the activity.
Objection:
Insofar as this interrogatory calls for information __.
s regarding the results of implementing the Program Plan to date, 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 requested information, to the extent that it requests information about the plan as opposed to its implementation, is believed to be contained in the Plan and in each of the Action Plans.
Please see also PAG-01 through -12; CPP-001 through -027.
Interrogatory No. 41:
For each member of the CPRT Senior Review Team (SRT) include an explanation of why each " insisted" on the development and inclusion of the principles in the Program Plan.
Answer:
The conclusions referred to, which were reached by the SRT acting collectively and collegially, were based upon the opinion that the principles in question make sense and will contribute to a product that will be recognized by competent individuals in the field as one of high quality and thoroughness.
Interrogatory No. 42:.
The plan commits to a " thorough review of each issue".
Describe the process of review used for items which are not classified as either deficiencies or deviations.
Answer:
This question does not quite make sense, since an
" issue" is not something thought of as constituting a
" deficiency" or " deviation," and one's ability to explore an issue is not thought of as being dependent upon the presence or absence of that quality.
The issues to which the issue-specific Action Plans are responsive are susceptible of being thoroughly reviewed even if invalid; an invalid issue will reflect no deviations or deficiencies.
If the question refer s to the process by which design or construction failures not constituting " deviations" or
" deficiencies" will be assessed in the self-initiated programs, the response is set forth in Appendix E to the Program Plan.
All failures of construction to conform to design requirements are either deviations or deficiencies, and hence the premise of the question is invalid.
In design, there is a category of discrepancies that do not constitute a failure to meet design commitments; these will receive the treatment set forth in Appendix E.
The SRT believes that this constitutes a thorough review of the matters identified as a result of implementing the self-initiated programs.
Interrogatory No. 43:
How does the CPRT determine if a loss of capability of a system, structure, or component would, as opposed to could result in the inability of the system to performs intended safety function.
(Page 7)
Answer:
"Would" is addressed in the determination of safety-significance of a deviation.
See Program Plan at 7 (section III.B).
"Could" is addressed in the evaluation of adverse trends.
Program Plan, Appendix E at 5 (section B.5).
Interrogatory No. 44:
Identify all documents, working or completed, which were used to classify each system, structure, or component.
Objection:
Insofar as this request calls for in process implementation results, the Applicants object to it on the grounds that it is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986, and on the grounds previously asserted in response to prior requests for in process CPRT discovery.
Answer:
If the request is for the classification of findings, then to the extent that any such classifications have been made in the Action Plans for which Results Reports have been approved and published, all such documents are,
contained in the Working Files for those Action Plans, which have already been produced for inspection by CASE.
If the request is for the classification of items as safety-related or not, please see our response to Interrogatory No. 20 of CASE's CPRT Discovery - Set No.
1.
If and to the extent that any additional items may be investigated, this will be contained in the Results Report or the Working File for particular Action Plans.
Interrogatory No. 45:
To what extent is the " safety-significant" clarification determined by the original classification of the affected system, structure, component.
Example:
Paint coatings / fuel pool liners were classified as safety related at the time of failures to meet commitments but are not classified as safety-related now.
How would similar failures to meet past commitments be classified under the current definition?
Answer:
Please see our response to Interrogatory No. 3 of "CPRT Discovery - Set No.
1," which this question appears to duplicate.
Interrogatory No. 46:
The program plan states that root causes will be investigated and determined where possible.
(pg.
8)
Explain when it would not be possible to complete a root cause determination.
Answer:
Please see our response to Interrogatory No. 16, supra. -
Interrogatory No. 47:
Describe or identify the implementing procedures which will be used to govern the tasks which will " investigate and determine the root causes of identified deficiencies, (Pg. 8)
Answer:
CPRT Policies and Guidelines " Guide on Root Cause and Generic Implications" (PAG-04); CPP-Oll.
Interrogatory No. 48:
To what extent, if any, are root cause determination investigations pursued for failures to meet original commitments where the previous failures to meet a commitment are not now classified as deficiencies.
Answer:
Please see our response to Interrogatory No. 3 of "CPRT Discovery - Set No.
1."
Root cause determinations are performed in the case of deficiencies and adverse trends of deviations or design observations.
See Program Plan, Appendix E.
Interrogatory No. 49:
Identify forms or documents or types of documents on j
which " initial root cause hypotheses" are recorded.
Answer:
I j
If referring to preliminary assessments made prior to l
l the publication of the Action Plan, to the extent made such i
assessments appear in the Action Plan.
If referring to preliminary assessment made during implementation of the Action Plan, no specific form has been prescribed by the - -
SRT for the " recording" of " initial root cause hypotheses."
on whatever form, any such records should be contained in the Working File for the Action Plan in question.
Interrogatory No. 50:
What individual or group of individuals are responsible for making the initial root cause hypotheses on each ISAP?
Answer:
The Review Team Leader is responsible for the accomplishment of all of the tasks contained in an Action Plan.
The Review Team Leader has the discretion to delegate tasks to others but retains the ultimate responsibility for their performance.
Interrogatory No. 51:
To what extent, if any, will root cause determinations be reached for specific deviations which do not become an adverse trend.
Answer:
The answer to this question is contained in Program Plan, Appendix E.
Interrogatory No. 52:
Identify the person or persons responsible for performing each evaluation of potential generic implication as a result of a root cause determination.
Answer:
Please see our response to Interrogatory No. 50, supra.
' l l
l
\\
e Interrogatory No. 53:
Identify the CPRT procedure which are used to perform the evaluation of each potential generic implication.
Answer:
CPRT Policies and Guidelines " Guide on Root Cause and Generic Implications" (PAG-04); CPP-Oll.
Interrogatory No. 54:
To what extent will there by any collective significance evaluation of identified deviations or design observations?
Answer:
As set forth in the Program Plan, the collective evaluation for hardware and the overall collective i
significance evaluation look at the aggregate of CPRT findings, including deviations.
Program Plan at 17.
Interrogatory No. 55:
l Identify the person or persons responsible for performing each collective significance evaluation.
Answer:
With respect to quality of construction and I
construction QA/QC, by the Quality of Construction and Construction QA/QC Review Team Leader, subject to review and approval by the SRT.
The overall collective significance evaluation will be performed by the SRT.
Interrogatory No. 56:
i i
t l l
l l
(
Identify the procedures to be used to perform each evaluation or evaluat ions of collective significance.
Answer:
CPP-014.
There is no formal procedure for the SRT's collective significance evaluation.
Interrogatory No. 57:
Identify in what manner the collective significance evaluation will receive for consideration the " multiple, apparently isolated and relatively minor discrepancies" in order to perform a determination.
Answer:
See our response to the prior interrogatory.
Interrogatory No. 58:
Identify the procedures used to perform and record the collective significance evaluation, and at what stage of the CPRT it will be performed.
Answer:
Please see our response to Interrogatory No. 56, supra.
Collective evaluations are performed following completion of the activities within the scope of the particular collective evaluation in question.
Interrogatory No. 59:
Identify the person or persons (s) responsible for identifying " lessons learned" through the collective significance evaluation.
Answer:
Please see our response to Interrogatory No. 55, supra.. _ _ _ _ _
Interrogatory No. 60:
Identify the procedures or forms upon which the
" lessons learned" from the collective significance evaluation will be recorded.
Answer:
No specific form has been prescribed by the SRT for the " recording" of " lessons learned" from the collective significance evaluation.
On whatever form, any such records should be contained in the Working File for the for the collective significance evaluation.
In addition, the SRT may from time to time communicate information of this type to the utility by memorandum or other form of correspondence, in which case copies of such correspondence will appear in the CPRT Central Files.
Interrogatory No. 61:
Explain, in precise terms, how the collective significance evaluations including the lessons learned, will apply to already completed - as opposed to future -
j activities at CPSES, Units 1 and 2.
i Answer:
The question as drafted appears to be confused.
The collective evaluations are evaluations of the collective i
l l
significance of the aggregate of CPR'r findings with respect l
l to "already completed - as opposed to future - activities at CPSES, Units 1 and 2."
" Lessons learned" are not intended to be of assistance to the utility with respect to completed activities but only to future activities.
l q.
Interrogatory No. 62:
Explain what is meant by the statement " appropriate corrective actions will be defined to resolve all specific and programmatic deviations and deficiencies identified by the CPRT..."
Answer:
The quoted statement was not used with any terms intended to have special significance.
What is appropriate is determined on a case-by-case basis depending upon the findings made by CPRT; corrective actions may, as appropriate, include the rectification of any non-conforming conditions identified by the CPRT, revisions to procedures so as to prevent recurrence and such re-inspections or re-analyses as may be deemed appropriate to providing reasonable assurance that the detection and l
correction of replicate non-conformities has been l
l accomplished.
In the absence of a more focussed question, I
l it is not understood what further explanation is requested.
Interrogatory No. 63:
Identify the person or persons who will decide what is the duration of each third party overview of corrective actions.
Answer:
l The appropriate RTL, subject to review and approval by the SRT.
Program Plan, Appendix H at 4.
Interrogatory No. 64:
Provide a definition of " third party personnel" as used I
l l 1
I
a on pg. 9 Sec.
h.
Answer:
Third-party personnel is used to signify those individuals who are responsible to, and whose activities are conducted under the direct supervision of, the SRT, an RTL or the delegates of either.
Please see Program Plan at 17.
Interrogatory No. 65:
Identify the person or persons responsible for deciding what provisions of the CPRT program plan are deemed essential to the execution of the work in each group (pg.
9)
Answer:
As is set forth in the sentence from which this question is taken, the appropriate Review Team Leader.
Program Plan at 9.
Interrogatory No. 66:
Identify when it would not be applicable to provide training to action plan or existing QA program procedures.
l Answer:
We do not understand the question.
Please note that training with respect to each Action Plan is a matter to be covered in each Results Report.
See Program Plan at 31, l
i 36.
Interrogatory No. 67:
l l
Explain in precise terms what the phrase "auditable record of the CPRT program" means. i l
f e
s Answer:
Auditable record was used with its ordinary English meaning, and its interpretation by the SRT is reflected in the balance of the section from which this question was drawn, as well as in Program Plan, Appendix G.
Attachment 4; PAG-02; CPP-004; CPP-026.
Interrogatory No. 68:
Identify the person or persons who decide when it is necessary for members of the CPRT to have access to doco-ntation and plant areas. (p. 12)
Answer:
Any CPRT personnel.
Interrogatory No. 69:
Describe in precise terms the mechanism by which the SRT's exercise their " review and approval" over the RTL's in establishing the scope and content of ISAP and DSAPs.
(p. 12) l Answer:
The SRT exercises its prerogatives and discharges its l
obligations either by reviewing proposed action plans, i
l implementation procedures or other program outputs prepared by the appropriate RTL, by considering and disposing of change requests initiated by the appropriate RTL or by drafting and approving the Program Plan or subsidiary documents itself.
Interrogatory No. 70: l t
i
t 9
What is the purpose of the requirement on pg. 12, Item II, that analysis and calculations will be performed either by an organization "not previously responsible" for the technical subject area for the CPSES project or the alternative of the third party overview?
(pg. 12)
Response
The Applicants incorporate their response to Interrogatory No. II, supra.
Interrogatory No. 71:
Identify what process or procedure is undertaken to insure the organization's independence discussed in the previous question.
Answer:
Please see Program Plan at 17 ff (section VII); PAG-01, section 5.4.
Interrogatory No. 72:
Does the CPRT require that individuals working for the independent organizations be different from those who had performed the previous analyses or calculations?
Why or I
why not?
l Answer:
I Please see Program Plan at 17.
The reasons are set forth in our response to Interrogatory No. 11, supra.
Interrogatory No. 73:
Identify the process through which it is determined whether CPSES inspectors were not personally involved with the inspection activities they are working on for the CPRT (P.
12)
Answer:
See Program Plan, section VII; PAG-07; CPP-003. -
r t
Exceptions, if any, are jus t i fi ed in individual Results Reports.
Interrogatory No. 74:
What is the basis used by the RTL and the RTL for the QA/QC Review Team to decide on selection of personnel.
Answer:
Whether they are capable of doing the job for which they are being hired (or considered) and whether they meet the objectivity criteria set forth in the Program Plan.
See Program Plan, section VII; CPP-003.
4 Interrogatory No. 75:
Identify the person or persons who decide whether records reviews and evaluations will be performed either by third party personnel or by CPSES Project personnel (P.
13)
Answer:
The appropriate RTL, subject to review and approval by the SRT.
i Interrogatory No. 76:
Identify the person or persons who decide whether record reviews and evaluations will be performed either by 3rd party personnel or by CPSES Project personnel?
(Pg.
13)
Response
The Applicants incorporate their response to the prior interrogatory, of which this interrogatory appears to be a verbatim copy.
Interrogatory No. 77: K
l o
l i
Describe in detail the differences, if any, between the application and scope of the CPRT to Unit I and Unit 2.
Answer:
Apart from the inherent differences in the stage of completion of the two units, and that which ineluctably flows from that fact, none.
Any specific differences in investigative technique that might be applied to the two units will be described in the specific Results Report or the Working File for particular Action Plans.
Interrogatory No. 78:
Produce for inspection and copying all documents identified in these answers, examined and/or relied upon in providing the answers.
Answer:
It is not believed that any documents of which copies have not already been produced for inspection by CASE are so described (except for CPP-014, which has been modified since last provided to CASE).
Nonetheless, the Applicants l
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 l
counsel or other representatives of the parties, any document referred to herein without objection specifically l
identified by CASE of which it has not already had an l
l l
i
\\
e
(
o 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.
1 d2 i
SIGNATURES I,
Terry G.
Tyler, being first duly sworn, do depose and say thut.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 p' reparation of the forego!ag 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, be.ieve them to be true.
)\\
a
____O___b_-__"__A Terr G.
T r
Sworn to before me this
_f___ day of Saycember, 1986:
JVoyembeL i
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Notary Public
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}
My cciamission expires : _l_Q][h_/_h_h_________
E f
As to Objections:
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_ _ _ _ _ _ _ _.au Thomas G.
Dign Jr.
R.
K.
Gad III William S.
Eggeling Kathryn S.
Selleck Ropes & Gray 225 Frankling Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 1
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eaATED CURRESPONDENCX cxcit:
<BM CERTIFICATE OF SERVICE T6 MJV 12 R2:21 I,
Robert K. Gad III, oneoftheattorneysforth(( Applicants herein, hereby certify that on November [71986, I made service of I
the within " Applicants' Answers to CASE CPRT Program Plan Interrogatories (Set No. 3)" by mailing copies thereof, postage I
prepaid, to:
Peter B.
Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector i
Administrative Judge Comanche Peak S.E.S.
l 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 l
Washington, D.C.
20555 Dr. Walter H.
Jordan Nancy Williams Administrative Judge Cygna Energy Services, Inc.
881 W.
Outer Drive 101 California Street, Suite 1000 Oak Ridge, Tennessee 37830 San Francisco, California 94111 l
l Chairman Chairman l
Atomic Safety and Licensing Atomic Safety and Licensing i
Appeal Panel Board Panel l
U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission l
Commission Washington, D.C.
20555 l
Washington, D.C.
20555
~
Stuart A.
Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE i
I Legal Director 1426 S.
Polk Street U.S.
Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555 l
l l
l
ro 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 Na31onal Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Ms. Billie P.
Garde Midwest Office 3424 N.
Marcos Lane Appleton, Wisconsin 54911 i
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Robert K. C; fcy III 1