ML20214R830

Discovery Rept 1 Requesting Definitions for Each Separate Meaning or Interpretation Used in Comanche Peak Response Team Program Plan.Related Correspondence

ML20214R830
Person / Time
Site:	Comanche Peak
Issue date:	09/16/1986
From:	Garde B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20214R802	List: ML20214R799 ML20214R808 ML20214R830 ML20214R853
References
OL, NUDOCS 8609290291
Download: ML20214R830 (12)

Text

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wwtATt's COMEWOM y,(, 9 f7 UNITED STATES OF AMERICA '[

NUCLEAR REGULATORY COMMISSION  ? SEP 161986P' d]

BEFORE ThE ATOMIC SAFETY L\ ocacTmo r.

AND LICENSING APPEAL BOARD SRic 3 cr $ c" ".22

'N In the Matter of 43 '

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TEXAS OTILITIES GENERATING )

COMPANY, et al.

) Docket Nos. 50-445

) 50-446 O L-(Comanche Peak Steam Electric ).

Station, Units 1 & 2 )

CPRT DISCOVERY - 1 DEFINITIONS Eacn interrogatory below contains a worc or phrase which is used in the CPRT program plan.1 For each of the following questions indentify name, Joo description and employer of each person who nas tne autnority to oecide what each of tnese terms and phrases mean in practice and answer the question in light of the meaning given to the phrase or term in practice.

Where there are different meanings or interpretations given by different persons provide each separate meaning or interpretation.

For each answer provide at least two examples from the actual work of the CPRT with references to documents, procedures, and results reports which illustrates the application of tne definition in practice. If the term or phrase nas a different meaning in different contexts, provide at least one example for each different context of the application of the term or phrase.

1 All subsequent page references are to the Introduction to Revision 3 unless otherwise noted.

hhh ADO K 5 g5 G

, 1. Explain the ditference oetween the phrases " quality

' of construction concerns" and " construction QA/QC concern."

(Pg.1)

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

1 i b. If tne person who answered tnis question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

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2. Explain the term " third-party expert" as used in the CPRT. (Pg.2)

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

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b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the

] person wnose knowledge tne answer was based on.

c. Ioentify the documents by description, date, and location which were used or examined to answer the i question.

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3. Explain the phrase " safety-significant deficiency" in reference to those components or processes which were classitied as " safety-significant" at the time tne work was done

(i.e. f uel-pool liners, paint coatings), (pg.2) i

a. Identify the person or persons who answered this question, include the name, position, or title, and organization,

b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

j 4. Explain wnat is meant wnen the phrase " determine the nature of" is used. (page 2.)

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

b. It the person who answered tnis question did not rely on first-hand, personal knowleoge provide the name, position or title, and organization of the i

person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

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5. Explain the CPRT's definition ot " root cause". (pg. 2)

a. Identify the person or persons who answered ~this question, include the name, position, or title, and organization.

b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the f person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

6. 8xplain the term " adverse trend of non-safety j significant deviations or design observations. " (pg. 2)

a. Iaentify the person or persons who answered this question, include the name, position, or title, and organization.

b. If the person who answered this question did 4

not rely on first-hand, personal knowledge provide j the name, position or title, and organization of the d g person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

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7. Explain, in detail with examples, the process of analyzing the generic implications of each root cause. (pg.2) l l

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a. Identify the person or persons who answered this question, include the name, position, or title, and organization,

b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

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8. Explain the term " single definitive root cause."

(pg.2)

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

9. Explain the difference in the two phrases in questions 5 and 8 supra,

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

b. If the person who answered tnis question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of tne person whose knowledge the answer was based on.

c. Identify the documents oy description, date, and location which were used or examined to answer tne question.

10. Explain the difference between the " root cause" and

" probable cause". (page 2).

a. Identity the person or persons who answered this question, include the name, position, or title, and organization.

b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the i

person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the

~

l question.

i 11. Explain the phrase "(t)o investigate on a proactive basis...". (page 3),

a. Identify the person or persons who answered this l l

question, include the name, position, or title, and '

l organization.

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l D. If the person who answered this question did a

not rely on first-hand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on,

c. Identify the documents oy description, date, and location which were used or examined to answer tne question.

12. Explain the phrase " static document". (page 4)

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

b. If the person who answered this question did not rely on first-hana, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were usea or examined to answer the question.

13. Explain the phrase " preliminary a sses sment" . (pg.7)

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a. Identify the person or persons wno answered this question, include tne name, position, or title, and organization.

b. If tne person who answered this question did not rely on first-nand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

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c. Identify the documents by description, date, and location which were used or examined to answer the question.

14. Explain, in precise terms, what is meant by the commitment that "each issue will be thoroughly evaluated." (99 7) i

a. Identify the person or persons who answered this question, include the name, position, or title, and

organization.

b. If the person who answered this question did not rely on first-hand, personal knowledge provide i

the name, position or title, and organization of the person whose knowledge the answer was based on.

c. Identify the documents by description, date, and location which were used or examined to answer the question.

15. What criteria are used to decide whether an issue has been thoroughly evaluated and which persons apply those criteria.

a. Identify the person or persons who answered this I

j question, include the name, position, or title, and organization.

I o. If the person wno answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the person whose knowledge the answer was based on.

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c. Identify the documents by description, date, and location which were used or examined to answer the question.

16. Explain, in precise terms, what is meant by the descriptive phrase " multiple, apparently isolated and relatively minor discrepancies". (pg.9)

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

b. If tne person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, anc organization of the person whose knowledge the answer was based on.

c. Icentify the documents Oy description, date, and location which were used or examined to answer the question.

17. Explain, in precise terms, the term " population" (Appendix B, pages 7-13).

a. Identify tne person or persons who answered this i

question, include the name, position, or title, and organization.

b. If the person who answered tnis question did 1

not rely on first-hand, personal knowledge provide i the name, position or title, and organization of the person whose knowledge the answer was based on.

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c. Identify the documents by description, date, and location which were used or examined to answer the question.

18. Explain, in precise terma, what is meant by a

" reasonably homogenous work activity. " ( Appendix B, pg.8) .

a. Identify the person or persons who answered this question, include the name, position, or title, and organization.

b. If the person who answered this question did not rely on first-hand, personal knowledge provide tne name, position or title, and organization of the f

person whose knowledge the answer was based on.

c. Identify the documents by description, date, and j location which were used or examined to answer the i

question.

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19. Explain, in precise terms, what is meant by the descriptive phrase " quality characteristic." (Appendix B, pg. 8)

a. Identify the person or persons who answered this

question, include the name, position, or title, and organization,

b. If the person who answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of the I person whose knowledge the answer was based on.

l c. Identify the documents by description, date, and location which were used or examined to answer the question.

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! 20. In reference to the explanation of safety significance as provided on page 2 of Appendix E, identify all systems which have the potential for including safety significant discrepancies. (Appendix E, pg. 2) j a. Identify the person or persons who answered tnis question, include tne name, position, or title, and organization,

b. If the person wno answered this question did not rely on first-hand, personal knowledge provide the name, position or title, and organization of tne person whose knowledge the answer was based on.

c. Identify tne accuments by description, date, and location which were used or examined to answer tne question.

1 21. Explain in precise detail the phraso " programmatic i

j in nature" as used throughout Appendix E.

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a. Identify the person or persons who answered this question, include the name, position, or title, and 7

l organization.

b. If the person who answered this question did not rely on first-nand, personal knowledge provide 4 the name, position or title, and organization of the i

4 person whose knowledge the answer was based on.

c. Identify the documents by description, date, and

! location which were used or examined to answer the l

question.

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22. Produce for copying and inspection all documents examained and/ or relied upon in answering these questions and identity for each document produced to which answer it is related.

Respectfully suomitted,

, ~4 BILLIE P. GARDE <

TRIAL LAWYERS FOR PUBLIC JUSTICE 2000 P Street, N.W.

Suite 611 Washington, D.C. 20036 I

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