ML20214R484

From kanterella
Jump to navigation Jump to search
Discovery Request for Names of Participants in Review & Analysis of Comanche Peak Response Team.Related Correspondence
ML20214R484
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 09/22/1986
From: Garde B
Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Shared Package
ML20214R018 List:
References
OL, NUDOCS 8609290188
Download: ML20214R484 (20)
v • d • e


Text

.. _ _ . ._ . _ _ __

e a ud gnawm', p v c 00CKETED USHRC BEFORE THE .. -

UNITED STAT 8S '26 SP 25 P2 :38 NUCLEAR R8GULATORY COMMISSION 8etore the Atomic Sarety and Licensing ~ Board In tne Matter of )

)

TEAAS OTILITIdS GENERATING COMPANY, ) Okt. Nos. 50-445-OL et al.

) 50-446-OL

)

(Comanche Peak Steam Electric )

Station, units 1 ano 2) )

CPRT DISCOVERY - STAFF 1.

Ioentity the names or all inoividuals who participated in the review and analysis or the Comanche Peak Response Team, as celineatec ceiow:

a. CPRT Review u D. CPRT Review I

, c. CPRT Revision 2

c. CPRT Bevision 3 e.

Answers to tne Staff's questions, August 9, 1985, and Septemoer 40, 19o5,

2. Icentity eaca announced or ur.iar.ounceo inspection, audit, investigation, review, or other ectiJir tnat evaluated the CPRT program plan or its implementation. (II the activity is reported in an inspection report, identity tne inspection report and tue page numoers or that inspection report pertaining to CPRT activities.)

8609290188 860922  !

PDR G

ADOCK05000g5

~= _ _ _ _ - - - - _ _ _ _ _ _ . - - - . - .

s 1

a. For eacn activity ioentified in response to the question aDove, provice tne names of all tne NRC start or consultant personnel wno performea the inspection, auait, or review process, and tnelt expertise, status, and location.
o. For each activity loen titied aoove that is not written up in an inspection report, provide the exact dates, location, and participants in the activity, and what the purpose of the activity was.

J. Icentity each unsatisf actory "open"" item, notice of deviation, or notice of violation tnat the Statf nas issued as a result or inspection activities at tne Comanche Peak site that tne Starr Delieves relatea directly or indirectly to tne CPRT activities, or tne findings or tne TxT.

4. Identity and explain in precise aetail the process oy wnica tne Comanene Peak Response Team program plan has been and is now being overviewea oy NRC personnel.

3 Provice in precise cetail tne time being spent by each inalvidual (Staf f or consultant) for the purposes of CPRT Inspection, auait, ana review process by month since October 1964.

Example:

Oct. d4 Nov. d4 ----------

Aug. d6 Tom Westerman J nrs 100 nrs 90 hrs i O. Provide in precise detail, 'to the extent known to the '

NRC, tne percentage ot CPRT work tha t has had 100% NRC oversignt. -

)

i

7. Iaentity and provice all tne documents, including memos, drarts, notes of meetings, memos to tne file, and any otner cocuments, that were preparea during the review of the CPRT ano detail comments, opinions, questions, or information on tne acequacy or tne CPRT program plan to resolve NRC concerns.
d. Identify all tne inspectors and consultants currently assignea to tue Comanene Peas project, whetner Region IV site inspectors, Region IV support starf, neaaquarters personnel, or consultants. For eacn indivloual describe nis/her Comanche Peak responsioilities.
9. Icentity and produce all cratts or all tne inspection reports listea in response to guestion 2.
10. Iaentity and produce all cratts of SSER f13 ano all memos or otner documents reflecting the views of any Staf f person wno reviewed tnese dratts.
11. Icentity and prcouce all inspectors' notes, logs, or summaries of meetings Detween tne TUGCo of ficials and any NRC otticials, including tne E00 ana nis staft, on eacn of tne tollowing areas:
a. tne management capaoliity or Lou Fikar, Antonio Vega, Ron Tolson, James R. Wells, Jonn S treeter, C. T. Brandt, Ivan vogelsang, Billy Clements, Robert Selvers, uwiynt Wooayara, Ted 811x t, Goraon Puroy, J. T. Mer r t t t, J. D. Turner;
o. tne proposeo or tinal results of inspections of tne CPRT implementation; I

l

l

c. Tne acequacy or tne CPRT Plan, including any revisions or proposed revisions.
14. For eacn or tne issues or comments celow, provice the name or tne person (s) whose personal knowleoge forms tne oasis for tne statement or conclusion.
a. "Tne statt finds tnat the classification process ... is a logical process that should De suitaole for satisf actory implementation by the CPRT and for independent inspection by the NRC s taf f." (SSER #13, p. 1-o.)

D. Tne starf has aetermined tnat its original concerns aDout "tne CPRT's ability to adequately identify items that were not in compliance witn licensing commitments" nas been resolved satisfactorily (p. 1-o).

j c. Tne statt has tound that tne process tor resolving cisputes Detween the CPxT and tne CPSES project is acceptaole (p.

1-9).

a. "Tne statt nas determined that TdEC's metnod for implementing corrective action and tne CPRT's commitment to incependently concur ano overview Key aspects of that corrective action are acceptable" (p. 1-9).
e. Tne starf nas found that tne CPRT's description or metnoas for accumenting tne results of tneir ef forts "will provice ror an organized approach to cocument results that will ensure tnat an auaitaole and complete record is estao11shed of the CPRT tincings as well as tnelr tinal resolution concerning the m. " (P. 1-1J.)

__ _ _ _ ~ _ _ . , _ _ . _ _ _ . _ _ - __ _ . - - - __

j ~5-

r. The staff found the docusaentation or the population to be compatioie witn tne CPRT plan descrioed in VII.c. and found tne oevelopment or tne inspection enecKlists ano the documentation associated with tnis process to oe consistent for all populations.

9 Tne staff found tnat tne documentation for tne checklist aevelopment was adequate to ensure that tne process could be audited in the future.

n. The statt found tne self-initiated program acceptable as an important contrioutor for evaluation of tne adequacy of construction at CPSES.
1. Tne statt considers tne overall sampling process presenteo in Appenaix 0 "to oe effective" (p. 2-10).

"The starf nas determined tnat tne CPRT Program Plan J.

presents an acceptacle approach for accomplisning the objectives or tne tnree components of the CPRT Program" (p. 2-10).

K. Tne start concluaes "tnat tne construction adequacy i

program provides an acceptaole process for resolving all current and any future external source issues."

1.

Tne start concluaes tnat the selt-initiatec construction I acequacy program "provia tesj important eviaence concerning tne q uali ty or construction" (p. 2-10).

m. "Tne start finds acceptaole tne metnocology of the
sampling process employed oy tne CPRT to address some ESis and to pertorm its seir-initiateo evaJuation (p. 2-11).
n. "Tne start rinds tne CPaT organization acceptaoie" under i

e

10 CFR 30 Appenoix B oasea on the CPRT organizational chart and responsibilities (p. 4-2).

o.

Tne statt tinos that the CPRT meets the 10 CFR 30 Appenaix d requirements of a gA program requirement (p. 4-4).

p. "Tne statf tinos tnat the CPRT design controls are acceptacle" unoer 10 CFR 50 Appendix 8 cased on the measures cescrioea in tne CPRT (p. 4-4).

9 "Tne statt tinds that tne CPRT procurement document controls are acceptable" pursuant to 10 CFR 50 Appendix 8 (p. 4-4).

c. The statt finos that the CPRT use of instructions, proceaures, and drawings is acceptacle" according to 10 CPR S0 i App. d standards (p. 4-4).

l s. "Tne staft finds tnat the CPRT program for document control is acceptabic" according to 10 CPR 50 App. 8 (p. 4-5).

, t.

"Tne staft finds that the CPRT program for the control of purchased services is acceptacle" according to the requirements of 10 CFR 30 App. 8.

u. The statt tinas that tne CPRT program for tne control of tne CPRT inspections is acceptaole pursuant to 10 CFR SU App. 8.
v. Tne start finos tnat the CPRT program tor control of measuring and testing equipment is acceptable pursuant to 10 CFR 30 Ape. B criteria.
w. Tne statt finas that the CPRT program for control of nonconformances is acceptacle pursuant to 10 CFR 30 App. d.

x.

"Tne statt finds tnat the CPRT controls for corrective action are acceptable" pursuant to 10 CFR 50 App. 8.

y. "Tne statt tinds that the CPRT controis for gA records are acceptable" pursuant to 10 CFR DU App. 8.
z. "The s tatt rinds tnat tne CPMT controls for audits of QOC and DAP are acceptacle" pursuant to 10 CFR 50 App. B.

aa. Tne statt conclusion tnat tne CPRT QA program meets the appropriate provisions or 10 CFR SO Appendix 8, except for auditing ot tne TRT ISAP program.

1J. Precisely identity all information the Staft now possesses tnat is inconsistent with any information or assumptions useo oy the Statt in reacning any of the conclusions identitleo in Question 12.

14. Icentity any Staf f employee or consultant with personal Knowledge ot facts relevant to any of the conclusions icentitled in question 12 tnat aid not and/or aoes not agree with the I

conclusion. With respect to each point or disagreement, -identity tne person (s), tne tacts they rely upon for tneir position, and Enelt view of tne proper conclusion tnat should be or should have Deen made.

15. For eacn of tne issues or comments identified in guestion 12, provice the factual oasis on which tne Statt re11ed ano relles for tne conclusion.
10. For eacn or tne issues or coanments Delow, provide tne name or the person (s) wnose personal Knowleoge forms tne oasis ror the statement or conclusion:

)

l l

1

-d-

a. "Tne statt considers loss of margin to be important and considers it a matter tnat must be aadressed curing tne safety-slynificant evaluations." (SS8R #13, p. 1-6. )

D. "Tne statt nas examined tne CPRT's description of its intendea metnods ror determining root causes and finds that the CPRT's description lacks sutticient cetail to permit an indepenaent evaluation or the metnodology." (P. 1- 7. )

c. "Tne staf f has examinea tne CPRT's description of its intended metnods tor determining generic implications and finds tnat tne CPRT's description lacks specificity to permit an indepenaent evaluation or tne methodology" (p. 1-d),
d. Tne CPRT process for stratitication of a population into a newly aerinea stratum is to be evaluated turtner in incividual renuits repor ts (p. z-7).
e. If factors arfecting initial homogeneous populations are found curing sampling, tne original population should oe

" restructured to account for the newly identitied factors artecting tne attriou te " (p. 2-10),

t.

Tne matrix descrioea in Section 2.1 should oe supplementea to correlate attrioutes inspectea to tne associated naraware populations (p. 2-10) 9 Tne start round tnat tne TRT ISAP program lacks tne aetailed auait approacn normally tound in wA programs,

h. Tne start found it unacceptacle to have Criteria 12 omittea from tne CPRT wA program.

l l

l 1

1

-9_

1/. For each of the issues or comments identified in Question 10, provice the tactual basis upon which the Staff relied and relies for the conclusion.

18.

For each of the tollowing wA/wC issues trom SS8R fil, Appendix P, identity that element of the CPRT program plan tnat tne Start celleves is responsive to the concern.

Category I - Specific Allegations Document Control Ag-J (SS8R 11, p. d)

AQ-4 (SSER 11, p. 5)

Aw-5 (SS8R 11, p. 6)

Au-9, Aw-17, 19, 42, 58, 104, 107 (p. 6)

Au-10, Aw-37, Aw-d9, Ag-60, Au-71 (p. 6)

Ag-19 (p. 6)

Aw-JJ (p. o)

Aw-49, 74, 12d (p. of Au-72, 103 (p. b)

Au-91 (p. b)

Au-102 (p. 6)

Aw-luS (p. 7)

Aw-110 (p. 7)

Au-117 (p. 7)

Aw-144 (p. 7)

AwO-34, 30, 62 (p. 7)

AQO-Jb (p. 7), all allegations AgO-138 (p. 7)

Revlon IV Report, 50-445/d4-16 (p. 7)

Training AQ-23 (SSER-11, p. d)

Aw-100 (p. of Aw-2o (p. d)

Aw-7J (p. u)

Av0-33 (p. d)

Aw0-22 (p. e)

AwO-J2 (p. d)

Aud-10 (p. 8) j i

AwC-9 (p. 9) '

AM-4Ja (p. 9)

Awd-4, Ave-o, AQE-12 (p. 9)

Au-132 (p. 9)

AE-15 (p. 9)

Construction ana Testing Au-4 (SSER 11, p. 9)

AgC-lb (p. 9)

AC-24 (p. 10)

AC-20 (p 10)

AC-12, AC-37 (p. 10)

AP-4 (p. 10)

Aw-33 (p. 10)

AC-J9 (p. 10)

Civ11 and Structural Cat. o, Sec. e(4) (SSER-11, p. 11)

Cat. O, Sec. e(5) (p. 11)

Cat. 6, Sec. e(o) (p. 11) i Cat. 6, Sec. e(7) (p. 11)

AC-13 (p. 11)

AC-15 (p. 11)

AQ-30 (p. 11)

Aw-50 (p. 12)

Region IV IR d4-16, 3A.4 (p. 12)

AT-1 (P. 12)

AW-bd (p. 12)

Agw-6 (p. 1J)

Aww-29,.dJ (p. 13)

AgB-2a (p. 1J)

AP-b (p. 13)

AP-7 (p. 14)

AW-ds (p. 13)

AW-46 (p. 13)

AwS-12 (p. 13)

AQ-138 (p. 14), all allegations Aw-34 (p. 14)

NonConformances and Corrective Action AP-10 (SSod 11, p. 13)

Region IV IR de-lo (p 15)

AQO-7 (p. 13), all allegations Aa-52 (p. 15)

AQP-1 (p. 15)

AM-230 (p. 15 AM-12 (p. Ib)

Ad-3 (p. 13)

Aww-7J (p. 10)

Ad-0, AW-50, AW-5d (p. 16)

AgW-4 (p. 10)

AP-11 (p. 16)

AuW-74 (p. 16)

SRT-o (p. lo)

Aw-Jd, AgW-z4 (p. 16)

l age-Jb (p. 16)

Ag-3e (p. 16)

AP-15, 16, 17 (p. 17) gC Inspection AE-13, lu, 22 (SS8R 11, p. 17)

Region IV IR 84-10 (p. 17)

AC-19 (p. 17)

AC-35 (p. 17)

AC-52 (p. 17)

AC-32 (p. 17)

AC-10 (p. 18)

AQC-1 (p. 18)

AwC-2(2) (p. 18)

AwC-2(4) (p. id)

AgC-3 (p. id) j AgC-7 (p. lu) 1 AQC-40 (p. 18)

AgC-51 (p. 19)

AwC-6 (p. 19)

AwC -11 (p. 19)

AwC-40 (p. 19)

AwC-43 (p. 19)

AM-15 (p. 19)

AM-21 (p. 19)

AwO-50, 52 (p. 19)

Awo-20 (p. 20)

AQO-20 (p. 20) ,

AQO-37 (p. 20) i AQO-7u (p. 20)

AQW-77 (p. 20)

An-10 (p. 20)

AM-11, AW-40, 42, AQW-80, dl, 82 (p. 20) s AgW-17 (p. 20) i Agd-3, AB-12 (p. 20)

AP-13 (p. 20)

AwW-78 (p. 20)

AW-49, 51, 35 (p. 20)

Aw-43, 31 (p. 20)

Au-d2 (p. 20)

Aw-69 (p. 2u)

Au-30 (p. 20)

Region IV IR 84-26 (p. 20)

Ag-55, 76 (p. 20)

Aw-114 (p. 22)

Aucits and Reporting Region IV IR 84-32 (SSER 11, p. 22)

Ag-11J (p. 22)

Aw-126 (p. 22)

Aw-1J2 (p. 22) i

Aw-1JJ (p. 22)

AgP-23 (p. 22)

Inaaequate Proceaures AC-31 (SSER-11, p. 23)

Au-121 (p. 23)

AQw-26 (p. 23)

Awo-13 (p. 23)

Aw-34 (p. 2J) awO-43 (p. 23)

AgO-10 (p. 23)

Ago-45 (p. 23)

Awo-10 (p. 23)

AQ-135 (p. 23)

AW-J4 (p. 2J)

Ago-o2 (p. 23)

Region IV IR d4-26 (p. 25)

SRT-4, SRT-S (p. 25J Aww-78 (p. 23)

SRT-9 (p. 23)

Category II wA/QC Conclusions Based on TRT Work and Generic Implications for tne Historical VA/uC Program at CPS 8S 4.2 Document Control (SSER 11, p. 27)

Finaing: Tne TRT tound a nistory of recurring accument '

control ceticiencies prior to July 1964 tnat raise concerns aoout certain aspects of tne quality of construction.

Conclusion:

"The TRT gA/yC group concludes that ... the implications of past inadequacies on construction and inspection have potential generic significance wnich has not yet oeen fully analyzea Dy TUSC. "

1 4.3 Training and wualifications (SSER 11, p. 28)

Fincing: The TRT founa a pattern or inadequacies with the training, certirication, and qualification program at CPSES which the TRT tracea Dack to TUSC's and B&R's " minimal requirement" training, certitication, ano qualification program; tne lack ot or tailure to follow procedures and gulaelines; ano a lack or programmatic controls to assure tnat the program acnteved and maintainea requirements as set tortn by 10 CFR Part du, Appendix 8.

1

Conclusion:

"Tne TRT VA/vC group concludes tnat aericiencies in procedural requirements and guidelines in TUsC's training, certicication, and qualification programs nave potential qua11tf significance. Further evaluation by i

TudC is required in order to aetermine tne impact ot tne

cericiencies on tne safety of the project." (p. 29)

4.4 Construction and Testing Finding: Tne TRT round recurring const.ruction craft practices that were ceticient and indicated a lack or proper rirst-level supervision.

Conclusion:

Certain listed practices were either a primary or contriouting factor ana had a plant-wide impact (p. 31).

4.3 Contormances and Corrective Actions Finalng: Tne TRT wA/wC group identitled deticiencies in the implementation of tne NCR system, tne disposition of the NCRs, generic deticiencies in the corrective action system, ano inaaequacy or contusion ot the multiple systems for reporting nonconforming conditions.

Conclusions:

The QA/wC group found aeficiencies in NCR 1mplementation; and in some cases NCR corrective action was unsatisfactory. "Tne wa/wC group found 86R and TUGCo's corrective action systems poorly stricturea, inettective, ano poorly applied."

4.0 gC Inspection Findiny: Tne TRT wA/vC team founa many items of yC inspection tnot were conslaereo to be aericient.

Conclusion:

Tne wA/QC group considers tne site VC inspection program to De less than tully ef tective in monitoring, cetecting, and reporting deficiencies that have or could nave a significant satety impact on the plant (p.

31).

4.7 Audits and Reporting Finding: Region IV found tnat TUEC's audit procedures aia not comply with NRC requirements, and tnat the program was not implementea in accordance witn procedures.

Conclusion:

Tne TRT concludes that the WA audit anc reporting program nas naa and continues to exhioit ceticiencies. These include recurring dericiencies, inaaequate staffiny, tallure by management to review wA program ror ettectiveness, procedural and implementing inadequacies, questionaDie quaAltications and capabilities, etc. (p. JJ-34).

4.0 Inadequate Procecures I j

l Finding and

Conclusion:

The TRT round tnat procedures in some areas aid not comply with 10 CPR 50 Appendix B 1

1 1

i

t Criterion V requirements, as aescribed in SSER 11, at p-J4.

19 c'or eacn staf t inspection conductea since Octooer 1904, identity all items / issues or components / processes found of Staff inspectors tnat were not done accoruing to tne original site requirements. (Tnis answer is limited to tnose inspection result tinalngs tnat were maae by the Start inspector but were not issuea in tinal inspection reports. Tne answer should include all tindings oy resident, TRT, or Region IV inspectors or otner NRC Stati personnel or consultants.)

40. 8xplain in precise detail what is meant by the phrase:

tne program plan "w111 provice important evidence wnen implementea"t (SS8Rv13, p. 2.)

21. Icentify eacn or the inalviduals wno made up tne multi-aisciplinary team that conductea tne review ot tne CPRT's process ror its self-initiated program, as cescribed in 32.4.2, on p.

4.0.

22. laentity the cate, place, and participants of each onsite aucit, examination or nomogeneous populations, and relatea ,

work activities, ana/or inspections or reviews that formed tne casts of tne statt's comments and conclusions on tne evaluation ot tne selt-initiateo construction program (p. 4.01.

43. Explain in precise detail the casts of tne statt conclusion that tne process is surficient to provice important eviaence aoou t tne quality of tne insta11ea naraware ( p. 2- 7 ) .

l l

l

24. Explain what is meant by tne staf f statement that the process "is suf ficient to provide important evidence about the quality of tne installed naraware, irrespective or human and aaministrative f ac tors." (P. 2-7.)
25. Explain in precise detail what is meant by the statement tnat: "The staf t will consiaer acceptacle a process to estaolish new nomogeneous strata wnich follow the same ground rules as those used for establisning the original population" (p.

2-7).

26. Explain in precise aetail wnat is meant Dy the term

" population restratification" as used on p. 2-7 of SSER #13.

27. Explain in precise detail wnat is meant by the acceptance of the self-initiateo program as "an important contrioutor for evaluation or the adequacy of construction at CPSES" (p. 2-7).

2o. Icentity and explain in precise detail what additional "information the start needs about tne integration of these three components (of tne program planj in oraer to develop a perspective aoout tne comprenensiveness of tne scope to permit an assessment of tne extrapolation to all haroware at CPSES, Dased on tne rindings anc resolutions related to the items inspected" tp. 2-1U).

29. Wnat is the basis of the staf f's determination that the CPRT wA Program should adoress each of the 10 CFR SO Appendix B

T criteria below:

a. Criterion 1, Organization
o. Criterion 2, wA Program
c. Criterion 3, Design Control
d. Criterion 4, Procurement, Document Control
e. Criterion 5, Instructions, Procedures and Drawings
f. Criterion 6, Document Control 9 Criterion 7, Control or Purchased Material, Equipment, anc Services (as Claritied)
h. Criterion 10, Inspection
1. Criterion 12, Control of Measuring and Test Equipment J. Criterion 15, Nonconforming Materials K. Criterion 16, Corrective Action
1. Criterion 17, QA Records
m. Criterion Id, Audits Jo. Explain in precise detail what the Staff meant by the terminology used tnat tne CPRT wA program "snould address" tne aoove listed criteria. If it does address, identify precisely what portion or the program does adoress and explain the basis for the conclusion. It it does not aadress, explain what the start intends to do about that.
31. Bxplain tne basis for the Statf's exclusion of the tollowing lu CPR 30 Appendix 8 criteria f rom tnose tne CPRT QA prograin "snoula aaaress":
a. Criterion o, Identification and Control of Material, l Parts, and Components {

\

l i

I D. Criterion 9, Control of Special Processes

c. Criterion 11, Test Control
c. Criterion 1J, dandling, Storage and Shipping
e. Criterion 14, Inspection, Test, and Operating Status
42. As to eacn of tne following concerns or questions raised by tne statt in tne August 9, 1985, and September 30, 1965, stati evaluations of tne CPRT, provide the following information:
a. Identify the person (s) who reviewed tne Applicants' response to tne question or upon whose knowledge the review was casea.
o. State definitively whether the answer proviced by tne Applicants was found to be satistactory, responsive, or otherwise acceptaole. *
c. It tne answer was not responsive or satisfactory, iaentity and explain how the NRC Staf f is going to or has resolved its original concern.

August 9 t 1985, Letter Concern 3.1.A. Design Review Breadtn, Mechanical, Electrical, and Instrumentation Systems (p. 5 of Aug. 9, 19o5, NRC letter; p. 4-10 of Section A of Applicants' Nov.

22, 1965, letter)

Concern J.1.d. Design Review Breadth, Civil / Structural (p. 6-7 of Aug. 9, 1963, letter; P.11-14 or Section A of Nov. 22, 1965, letter)

Concern 3.e Destyn Organization Interfaces (p. 8 ot 8/9/05 letter; p. 17-z2 or Sec. A or 11/22/d5 letter)

Concern J.J External Source issues (p. 9 of d/9/05 letter; p.

zJ-Ju ot Sec. A of 11/22/d5 letter)

i Concern 3.5 vA/wC Issues (p. 10-11 or o/9/dd letter, p. 32-35 of Sec. A or 11/22/d5 letter)

Concern 3.7 Acceptance Criteria (p. 13 of d/9/03 letter; p.

39-41 or Sec. 11/22/o5 letter)

Concern J.0 Sampling Criteria (p. 1J-14 of d/9/03 letter; p.

42-42 or Sec. A or 11/22/o3 letter)

Concern J.9 Corrective Actions (p. 14 or 8/9/d5 letter; p. 43-40 or Sec. A or 11/22/d5 letter)

Concern J.10 CPRT/SRT Management ceam (p. 14 of d/9/85 letter;

p. 47 of 11/22/od letter)

Septemoer 30, 1965, Letter item 2 Corrective action (p. 3-4 or 9/30/85 letter; p. 3-5 or Sec. 8 of 11/22/05 response)

Item J Auait of training programs (p. 3-5 of 9/J0/85 letter; p. o, Sec. 8, 11/22/d5 letter)

Item 4 dxtrapolation of results (p. 3-3 of 9/30/85 letter; p. o-7, Sec. 8, 11/22/d5 letter)

Item 5 Lessons Learned (Unit 21 (p. 3-6 of 9/30/85 letter; p. 7-6, Sec. 8, 11/22/d5 response)

Item o evaluation ot safety-significance (p. 3-6 of 9/JO/63 letter; p. 8, Sec. 8, 11/22/05 response)

Item 7 aoot cause and generic implications (p. 3-6 ot 9/Ju/ds letter; p. 6, Sec. 8, 11/22/83 response)

Item o sampling Techniques (p. 3-6 of 9/30/85 letter; p.

9, Sec. u, 11/22/do response)

Section 3.J nomogeneous work activities (p. 3-14 of 9/30/85 Item i letter; p. 2d-29, Sec. 8, 11/22/d5 response)

Item 2 nomogeneous popula tions (p. 3-15 of 9/30/85 letter; p. 26-29, Sec. 8, 11/22/65 response)

Item 3 CAS8's critique re: welding construction (p. 3-15, lo, 9/30/dd letter; p. 30, 11/22/d5 response)

Item 4 Listing or inaccessible naroware (p. 3-16, 9/JU/d5 letter; p. JU, 11/22/d3 response)

ISAP VII.a.3 Management Assessment (p. 3-40, 9/30/dS; p. 82-83, 11/22/d5)

f ISAP VII.a.o Bxit Interviews (p. 3-47, 9/30/85; p. 84-86, 11/22/03)

ISAP VII.c. Construction reinspection / documentation review plan (p. 3-55, 9/a0/85; p. 101-106, 11/22/85)

Section J.5 CPRT sampling approach, application and guidelines (Appendix D) (concerns 1-6, p. 3-82-83, 9/J0/d5;

p. 171-176, 11/22/d5)

Section 3.6 Procedure for the classitication, evaluation, and ,

tracking or specitic design or construction discrepancies identified by the CPRT (p. 3-84, 9/30/d5; p. 171, 11/22/d5)

Section 3.7 CPRT interfaces (Appendix fl (p. 3-dS, 9/J0/85; p.

176-idu, 11/22/dS)

JJ. Tne NRC also required TudC to investigate the role of tne principal contractor personnel (Brown & Root and Bbasco) in regara to WA/yC concerns (SSSR 11, P-30). Iaentity that portion of tne CPRT tnat the NRC believes accomplianes that task.

34. Tne NRC asked that TOEC also consicer the prudence of continuing to rely on contractor management personnel involved in ongoing work and recovery efforts snen tney are the same people airectly responsiole for tne proolems identified herein (SSSR 11, P-36). Icentify that portion of the CPRT that the NRC Delieves accomplishes tnat task.

J5. Proauce ror inspection and copying all documents icentifiec in the answers to tnese questions and all documents examinea and/or relied upon in preporing the answers to tnese  !

l

f 1 questions.

Respectfully submitted, BILLIE P. GA10)E Trial Lawyers for Public Justice 3424 North Marcos Lane Appleton, WI S4911 (414) 730-8534 Counsel for CASE Dated: Septemoer 22, 1966 i

Retrieved from "https://kanterella.com/w/index.php?title=ML20214R484&oldid=3242924"