ML20215E902

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Response to & Motion Re Applicant 800728 Answers to Case First Set of Interrogatories & Requests for Clarification. Urges Applicant to Answer All Interrogatory Questions. W/Certificate of Svc
ML20215E902
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/04/1980
From: Ellis J
Citizens Association for Sound Energy
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20214X072 List:
References
NUDOCS 8610160018
Download: ML20215E902 (18)
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3EFORE IE ATOMIC EA7 TTY AND LIuz.asiru, BOARD In the Matter of { {." : -:E' D AFFLICATION OF TEl%AS UTILITIES { DocketNos.*iO-W5' ~ ~ GENERATIE CQeANY, ET AL. FOR AN I and,lLOJM6 OPERATIN", LICENSE FM CCHANCIE [ PEAK STEAM ELECTRIC STATION I ~ C- -7 ),g,Js/7,21 oNIIs#1AnD#2(CPSES) ~ '. _ I N Sy 5k ~ CASF'S RESPONSE TO AND MOTION REUARDING keg Eve )j h/ K Z APPLICANTS' ANSWERS TO CASE'S FIRST SET OF INIERROGATORIES AND REQussis FOR CIARIFICATION CASE (Citizens Asseciation for Sound Energy), In'tervenor herein, hereby sub=its its re'spense to " Applicants' Answers to CASE's First Set of Interrosa-tories and Requests for Clarification" dated July 28, 1980 and received by CASE ,..g. p - - August 1,1980. In their July 28 response, Applicants made quite a big point of assuring - that they " vill pursue a prcupt and fair resolution of alb. issues properly raised... during the discovery phase of the proceeding, Applicants vill respond fully and expeditiously to all discovery rehests which seek information rele. vant to the issues being considered." - -CASE does not vish at this time to nahe a major issue of this point, since in this particular single instance there was no great incor:venience or detriment to CASE. However, only because the Applicants made such a =ajor peint of this in their filing, we feel ca::;elled to point out that 10 CFR 2."T!4b(b), pursuant 8610160018 860922~ PDft ADCCK 05000445 A PDR .e* <,_,.,..~-,,,~._n,-+,,

-,.w '.' " ~ ~* a k II) towhichApplicantsrespondedtoCASE's7/7/8 0 interrogatories, states: "The party upon whom the interrogatori the ansvers and objections upon all parties were served shall serve as the presiding officer may allow."after service of th days shorter or longer period 1 Since there is no indication that the Board h this t5me, CASE assumes that Applicants sh as authorized an extension. of 4 .than7/28/80,aweeklate. ould have responded by.7/21/80 rather As we have stated, CASE does not wish to b l b the peint at this time. e a or We vould, however, hope that Applicants and th would be eg. tally lenient in their objections e Board i respcod somewhat untimely in the future. should CASE find it necessary to CASE has h S.)3, M rated its desire to pursue a prompt and fa g dissues properly raised by filing this response 7 d resciution_of., days after receipt) of Applicants' requests fo ng (3 r clarification. With regard to Applicants' objections and requests for clarification: Rusation 3: ~ Supply copies of each and every Field Request f Action (FREA)Icg. er Engineering Applicants have requested clarification and st t d ae that they do. net maintain any records described as " Field Request for Engineering A ti t c on log." What we l Gra referrin6 to (by whatever name it =sy b in the field to the Engineering section to t ke called) are reque 1 I a e sem*e specific action, =ake scue chnnge, or requesting clarification or that Engin eering make some judgement. .c 2-e r -,,we-%-.

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c .~. ~~~.:_, m ~. ~ --= = _e -m n-n:.uw -w w -=n .n. n -.~.,u.e.. n.,, a t A.. Please advise the ;;cper nane for such requests. We are not requesting copies ,of each and every request at this time, but rather copies of each and every log of such requests., Question 5: Supply copies of each and every Concrete Pour log. A plicants have requested clarification and stated that they dcf not maintain P ~ any records described as;" Concrete Pour,. log." Whenever a ednerete pour'is made,-- there is a requirement.that sone record of it be kept, such as a concrete pour- - - - ~ card (or whatever it may be called). Please advise the proper name for such concrete pour records. We are not requesting copies 'of each and every concrete .peur card (or 'vhatever it may be called) at this time, but rather copies of each g nd every log of such concrete pour records. ~ Question 9: How many audits have been performed by insurers (industrial.. risk, builder's risk, etc.) on verk done at Ccmanche Peak? Question 10: How many outside or sub-contractor evaluations, studies or audits have been conducted (by sub-contractors or agents of sub-contractors or by consulting firms or others, etc.)? Applicants have objected to these two questions "as being overly broad and - requesting information not relevant to the matters at issue.in Contention 5. - l Further, to respond to such vague interrogatories would cause undue burden and czpense in researching voluminous materials." Applicants then re guested that "CASI specify the tcpics of the evaluations, studies' or audits with which CASE is concerned, the relationship of such studies, evaluations or audits to Con-7.tention 5 and, with respect to Interrogatory 10, the sub-contractors or consulting 40 O

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.2. 2-. s ...) firms on which Applicants might have perferned the audits, evaluations or studies which CASE seeks." As stated in cur,7/7/80 filing, "Each Interrogatory has been identified as to which specific ac.cepted Contention it pertains to." 3y listing these- .tvo guestions under Contention f5, CASE clearly indicated that we' vere concerned ' ~ vith these two questions. insofar as th,ey apply to Contention Eh. 'If no such evaluations, studies or audits have been performed which might bear'-on this contention, Applicants have only to say so. Applicants' ~ statement that respond-ing "would cause undue burden and expense in researeliing velu=inous materials" would appear to indicate that Applicants are in violation 'of 10 CFR Part 50, APPendi:t.3, XVII, Quality Assurance Re' cords, and IVIII, Audits, which. state M in part: r-- l " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the fallowing: Operating logs and the results of reviews, inspections, tests, audits, monitor' ng of work performance, and materials analyses. The records shall i also include closely-related data such as qu'lifications of personnel, a procedures, and equipment. Inspection.and test records shall, as a mini-mum, identify the inspector or data recorder, the type of observation,, the, results, the acceptability, and the action taken in connection with any defi,ciencies noted. Records shall be idantifiitble a:fe rt trievable. Consistent vith applicable regulatery requirements, the apnlicant shall establish requirements concerning recora retention, such as duration. locatien, and assigned responsibility." (Enphases added.) [ "A comprehensive syste:n cf plar.ned and pe-iciic audits shd1 be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectivensss of the progra=... Audit results shall be documented and reviewed by manage =ent havirg responsibility in the tres audited. Follovup action, including reaudit of deficient areas, shall be taken where indicated." (Emphasis added.) .k. e--- v ---,--._---,-vv.- -vm... ..--.,,,.v w y,-_._ ,. - _ - - _ _ _ - - - - -.,,.,.--. -,,__- wf.,--.

j .. m.2._-._. m. a .~........... m m.. _. i i (% The topics of the evaluations, studies er audits with which CASE is con-f cerned are any and all of the= vhich might have a bearing on Contention f5 We do not know which specific audits may have been perfomed or the names of the sub-contractors or. consulting fins which might have performed such audits, evaluations or studies...However,10 CFR 2.Th0(b)(1) allows partie.s.to. request. _. information asito whether or not such audits exist and what they.arec.' _ m: " Parties-may obtain. discovery regarding any matter, not privileged, which is relevant to the subject matter involved in th'e proceeding, whether it relates f,o the claim or defense of the W seeking discovery or to the < laim or defense of any other party, including the existence, description, nature, custody, condition, and location of any' books,. documents, or other tangible things and the identify and location ~ of persons having knowledge of any disecverable matter." Further,10 CFR 2 7h0(b)(1) states regarding objections: Q M4 "It is not ground for objection that the information sought vill-be in-admissible at the hearing if the information sought appears reasonably calculated to lead to the discovery of admissible evidence." l CASE is aware of one specific such instance of evaluations, studies or audits. Eartford Steam Boiler Inspection and Insurance Co. of Hartford, Conn. apparently was hired to make sure that safeh.y-related pipe systenis at C==~ ke Peak are installed in ecupliance with code standards of the American Society. of Mechanical Engineers. We know about this instance because of an article in the DALTAS TIMES EERALD about three. inspectors quitting Eartford after ecun - plaining repeatedly about lax quality control procedures; this led to an RRC Itsp tf en aM Enforcement (I&I) Report (see I&I Report 80-02, KRC cover letter 5-V % au g m. _,m--.- .--,,--.,.,-.--.---_..,---,.-.-m, ,m+--, ,--.e-ce,------..,, .---e---r-,w

.._ y..-._, n- ~- -n-raw'* " * * ' '** ~ i of March 20,1980). We assume that Hartford made some kind of evaluation, , study, or audit regarding the work at Cemanche Peak, and this is one example .of the sort of infomation we are seeking. ~ Another specific e--nie is referenced in !&E Report 80-01, 2/14/80' ' IUtc '*-~ Cover Letter of February 15,1980: ~ "Throughout the last neveral months of 1979, the RRI (Resident Reactor Inspector) noted that the construction laber force was removing 'honeyecub' on the exterior face of the vs11 areas around and above the reactor area sometimes referred to as the core valls. Such 'hoceycombing' removal is not unusual in concrete work provided that it is neither very large nor very deep into the structure. "o'n December 13, 1980 (7), the licensee notified the RRI that further rem 5 val of the 'honeyecemb' was being suspended pending an in-depth investi- .gation and engineering, review since the area and depth appeared be exceed-ing expected levels...The licensee further indicated that he was $1=aatng ~ on utilizing the services of a consultant,.Meunow and Associates, to at-tempt, by microseismic means, to obtain information on the total extent of the problem...the microseismic (sonic) invest'igative technigae is uniqua to the consultant, Mr. Heunow, who developed it and is the only.1snown person able to interpret the oscillegraphic data,obtained." CASE assumes that this consultant made seme kind of evaluation, study, or audit regarding the work at Comanche Peak, and this is another example of the . sort of information ve are seeking. . Clearly these examples are relevant to Contention 5 and are therefore subject to discovery, as are any other such evaluaticas, studies cir audits vnich r_sy pertain to Contention 5. Applicants should be aware of which specific ovaluations, studies or audits have been done which may pertain to Contention 5, ~ + 9 ~. .s

+ and they should have such infomation in identifiable and retrievable fom, as required by Appendix 3 of 10 CFR Part So. CASE therefore requests the Applicant to supply _the information requested in these two Questions, along vith the corresp-Mnf information in Questions 11(a,b,e and d).. Question 12: Do 3rown 8s Root, Texas Utilities or any of its subsidia" ries _.or ~ ~ ccampanies, or any of the other owners of CPSES have a public rela-tions department for the Cemanche Peak plant (or if not specifi-cally for the Ccananche Pe* k plant, which provide infomation re- - a garding the plant)7 Question 13: If the answer to item 12 is yes, ite=ize the specific _cv4es which have such departments and state the extent of and the type of infomation supplied by each. (For example, is there a specific public relations department for CPSE5? Does a particular cc:npany provide infomation as a part of its over-all public relations .., department's work? Do the com;ianies, or a specific ccanpany, pre-IQ ._ pare special public relations, r.aterials specifically for the CPSES7 D If so, what* type of information?). ._ Applicants ob.jected_to these two questions as " seeking information which is irrelevant to any matter at issue in Contention 5" and therefore "beyond the secpe of pemissible discovery..." Then they turn right around and answer the two questions "in the interest cf reaching an expeditious conclusion to discovery." ' CASE submits that these questions g indeed relevant to Contention 5, for the following reasons. CASE has consistently maintained that there are a vide variety of problems associated with the quality assnrance/ quality control (RA/4::) at the Cccacche Peak plant and that there are many aspects to such W.,le=s. .~ - v i I ,,..m -_.._.,_.m., .____,,__,,_,,..,,.y. _,_..________.,,_y

~,......,.m.m. u.... :.e._. m.i... .. u r. ,n. w ,6...; w. y 4,,... &.,.+:::. x g,r.<>vs..i -i_6i.3!& iX ~ t j l .,8 Scme of these problems have been pointed out i (ItsE) Reports;forexampli: n HRC Inspection and Enforcement Frcut I&E Report 79-15, 6/21/79, NRC Cover letter identified during this investigation" (concer i"Even ~ requirements were Comanche Peak employes) "we did find that th n ng allegations by a former '~ true. We slao noted during this iurestigation thate allegations were essen ^' to alleged problemwith site management andexis s y conancted relative of construction. you made in January 1978 have strengthened the j Peak, we cannot ignore the fact that we are co ti changes._- program at Cccanche 1 tions concerning construction practices. n nuing to receive allega-tions, some of which have been substantiatedTaken individually these allega-significant adverse impact on the conformance of yo, do not appear ments. appears 'to be a morale problem which is eviden c vely, there arid may be attributable, in part, to communication problveral of igp worker * =+1. g ssion." --n ema between the The QA/QC problems have not al.), been worked out sinc e 1979, however, as evidenced by the following examples: Frcar I&E Report 80-03,2/7/80 Notice of Violatio qeduresforCablePulling,and3/20/80repcet Failure to Yellow Pro-n: 1980: , NRC Cover Ietter of March 20, electrical crew foreman or a site Quality Control I~' e o looste the, informed by. the electrician that all of the feramen v or only to be with their general fereman in another area of the b ildiere in a meeting Quality Control people had not yet been around even though th u ng and that the. been working for about one hour at the time of th e shift bad e observation." And further frca ItE Report 80 03, regarding Open I f and 50.hh6/79-26, Failure to Follow Procedures

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s ng Safety Related reviewed and revised to assure consistency with ures vould be N and lifting j, 1 -.. - -.. ~ _ _ _.... _ _,. _ _ _.,..__. -. _ _ _ _ _.... _ _ _ _ _ _ _ _ _ _. _ _. _ _ _ _. _.. _. _ _, _.. _

~~ _.m_._.- _....m,,,, C requirements. The procedures, as revised, appear to provide even less control than the original procedures in that all decisions relative to how to rig and lift, except those defined as ' critical' and apply to only a few major ccuponents, are le2 to the discretion of an engineer. No mechanism _is apparent,to t2ie RRI as to how the engineer is called in to examine any ,given situation nor is there any procedural assurance that a given manu ~ may 'be pertinent."facturer's. instructions will be reviewed for such special requ ~ Fran_,I&E Report 80-08,, %/16/80, ERC Cover Lettei of April 18,,1980, Notice of Violation: Failure to Follow F,rocedures for Reporting and Repair of Damaged Electrical Cable: "The Resident Reactor Inspector (RRI) learned of a Safety Train i-co= trol cable that had been damaged during pulling of the cable through the buried conduit system frem the pri=ary power plant build 1=g to the Service Water Intake 3uilding. The cable was pulled back on or about March 28, 1980, and it was verified by the RRI that the A=7 had been sustained, the Jacket was penetrated, and the repair was made with standard vinyl elitetrical. tape rather than Okonite No. 35 and not in the method e - (,'. required by Okonite_Draving No. D-5715 The original damage and initial . repair vere not reported via a Field Deficiency Report. "This is an infraction." "There was no clear evidence that the three separate type tests of cables, as required by paragraph 2 5.k.3 of N383, had been acccuplished nor was there evidence in the report that individual conductor tests had been performed as required by paragraph 2 5.6. The report did contain an attachment indicating that such testa had been performed and were successful." " Based on the RRI's knowledge...it is very doubtful that the function-ability of the cable would have even been impaired and, therefore, the cut jacket has no direct inpact on safety.. The imelications of the incident do, hovever, have a potential impact on safety in that it is indicative of a breakdown in the Construction Quality Assurance Prorram as evidenced by the fact that an electrician foreman took it upon himself to deteraire the need for the type of repair that was to be made to a damaged cable rather than reporting the matter through proper channels and allowing engineeric6 to make the decision." (Emphasisadded.) CASI has, in its previcus filings, indicated its concern about possible similarities regarding QA/QC between the Cocanche Peak plant and the South 9 O L_%--

E_ w.. .~:=_. _ - - 8 I N i ...) Texas Nuclear Project (STNP), since Brown & Root is building both plants. One of the items which especially concerned the NRC in its investigation report of STNP was,a brochure by Brown & Root regarding the quality assurance program. In the show cause ordar (as, to why STNP should not be shut down in 90' days until - " quality control problems were corrected), the NRC stated: ~ _ "The South Texas Project,QA management does not fully recognize the. requirement for QA/QC organizational freedcm. This is evidenced by 1 ._.a January k,1980. lecture by the B&R Project QA manager to the B&R site QA/QC and ccustruction and engineering supervisory personnel. This lecture which has not yet been revised repeatedly!izing project cost and main overe=phasized the 3&R QA/QC organization's responsibilities for minin ing the construction schedule. In addition, th's lecture stressed the fact that a B&R QC inspector's decisions are subject to question, challenge and ____ supervisory review and reversal...The licensee shall cause the Brown and e Root, Incorporated brochure titled, 'Implemtetation of the Brown and Boot ' $*$ Quality Assurance Program at the South Texas Project Jobsite,' which was videly distributed to site personnel and the subject of seminars on January h,1980, rescinded and the associated video tape to be destroyed or revised. Purther, the licensee shall cause the republication of a new QA Program brochure which has been approved by the licensee which reflects the funda-mental philosophies of 10 CFR Part 50, Appendix 3, and conduct new seminars vith Construction and QC personnel on the time'a antal philosophies and standards 1 of the licensee's QA Program with emphasis on the roles played by the re'spective personne1'and the underlying purpose of the Program." Because the B&R QA/QC brochure presents such fundamental, vital questions about the construction practices of Brown & Root, with implications not only, for the QA/QC program at !?%1P but at Ccmanche Peak as well, we are attaching a copy as Exhibit A hereto. (The brochure has been rearranged to conserve space, but the verding is reproduced exactly frcm the NRC investigation report.) At this point, the reader may well be asking what all of this has to do e dPs A d m m =..' r% ~ ~M*- O w - - &.A-uD.et_ i__ m .g.,_ n - ~ - u%. ---m j

e. m,., _.,_.. .m...., ..y. y. m.,, m... ..s .m r 4 s D vith CASE Interrogatory Questions 12 and 13 CASE believes that the I&Z reports have touched on only a part of the QA/qC probh.em but have not arrived at the root cause 'of the QA/QC problems at Cmam he Peak. CASE believes that the , QA/QC problems are not confined to personnel directly involved with the QA/QC program, but rather_that such problems pemeate the entire organizaf.ional ~' structure and that this in itself may be at the root of many QA/QC problems Quality assurance and/or quality control has many facets; it is as such an- ' attitude on the parts of.all employees as it is anything else. -It,-.is. imperative " that the general work force, including Texas Utilities supervisors and Icanagers, exercise conscientious dil'igent effort and objectivity at all times. The press releases and public relations materials of the Texas Utilities ecm;panies and %m V,3rown & Root are indicative of the nature of this conscientiousness, diligence ~ 1 and' objectivity.. All Cemanche Peak employees derive infor=ation'ftcza such pubMe relations materials as well as the general public. CASE vants to =ake sure that such materials do not represent misinfo=ation which in turn could have an i= pact on the attitudes of anyone involved with the Comanche Peak plant, l taes.tse if workers read in the newspaper or other public relations materials that things art all just fine and dandy at Comanche Peak, they might tend to dischant some of the things which e.re told to them e,n the job by conscientious QA/QC personnel as being harrassment rather than a sincere effort on the part of such QA/QC personnel to perfo= their duties consistent with @/QC objectives. 3. f. 11 'O I g m..

= .--w ' s It is incu= bent upon the NRC, in order to fulf*11 its mandate to protect the public health and safety, to go beyond merely identifying 'QA/QC problems and make every efferito determine the reasons for such problems.., CASE believes that at least part of the reasons may be the impact on C==n-h.Paalt's employees. of public ' relations efforts of t,,he Applicants and Brown as Root.. ;We t,herefore:,- - - urge thait 'the Board allow CASE to pursue this line of interrogatories.. ~ WHEREFORE, PRFTM CONSIDERED, CASE urges that the Applicant ansver-all of CASE's Interrogatory Questions and moves that, if necessary, the 3eard compel the Applicant to do so. Respectfully submitted, GmA /h _c_ s.) Juanita Ellis, President SE (Citizens, Association for Sound Energy) Ik26 S. Polk Dallas, Texas 75224 21h/9k6-9hh6 s/h/so I . U _.y . _., -,, _ -. ~, _.., _. _ _ _ -,

..,.._,.s,.m UNITED STA1ES OF AMERICA I i ~ NUCLEAR REGULATORY COMMISSION _BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I l APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR AN 1 and 50-446 OPERATING LICENSE FOR COMANCHE I PEAK STEAM ELECTRIC STATION 1 UNITS #1 AND 72 (CPSES) I CERTIFICATE OF SERVICE I hereby certify that copies of CASE'S Marwu TO AND M02 TON RLlGARDING APPLICANT 5? ANSWERS TO CASE'S -FIRST.3ET OF INTERROGATORIES AND REQUESTS FOR CIARIFIC in the above-captioned proceeding; haye been served on the following by deposit in the United States mail', first class, this hth day of August,1980: 4 Elizabeth S. Bowe'rs, Esq., Chairman David J..Preister, Esq. Atomic Safety and Licensing Board Assistant Attorney General U. S. Nuclear Rgulatory Commission Environmental Protection Division Washington, D. C. 20555 P. O. Box -12548, Capitol Station Austin, Texas 78711 - ~ Dr. Forrest J. Remick, Member .,'3 Atomic Safety and Licensing Board Mr. Richard Fouke ~

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- ~01/ 305 E:- Hamilton Avenue 1668-B Carter Drive ~; State' College, PA 16801 ' Arlington, TX 76010 Dr. Richard Cole, Member Atomic Safety and Licensing Board Atomic Safety and Licensing Board 1 Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commissio-Washington, D. C. 20555 Washington, D. C. 20555 Nicholas S. Reynolds, Esq. Atomic Safety and Licensing - Debevois e- &- Eiberman Appeal Panel 1200 - 17th St., N. W. U. S. Nuclear Regulatcry Commissi.o: Washington, D. C. 20036 Washington, D.'C. 20555 Marjorie Rothschild Docketing and Service section Counsel.for NRC Staff' Office of the Secretary U. S.' Ndelear Regulatory Commission U. S. Nuclear Regulatory Commissio Washington, D. C. 20555 Washington, D. C. 20555 l Mr. Geoffrey M. Gay Arch C. McColl, III, Esq. West Texas Legal Services 701 Cec:merce Street, Suite 302 100 Main Street (Lawyers Bldg.) Dallas, Texas 75202 l Fort Worth, TX 76102 . Jeffery L. Eart, Esq. I LC21 Preseett Avenue .wM hA 1 d V allas, Texas ' 75219 p.) vuanaca n s, Presiaenc D CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY) e ---w.--, -w .,.,y-m, ---,-.--.---.---.,-y,--,-.- -,wi---,-------+v----,o- --,--v w-,,,- - - - -i-s-.-.-,- - - - - - =

[__. ~ " - - - 5 Implemsntation vf the - - - Exmrr-A.. Brown & tRoot i i 'a n '~ ' "~' = "* ~5 'a ~a *a "~'= Quality Assurance Program and pentect general managers at South Tezu Pro. m at the lect. m -serv of this pi.ni a of imperi.nce to stown a nm. ms re, paramour South Texas Proy.eet Jobsite for saTety is the responsibihty of every Stown & pensibium j 3ROWN & ROOT CONSTRUCTION AND Rooi e,n,io.ee. sach of. ho a, ale to, lay on me team, and H ta QA/QC SEMINAR the fuH cwdinauen of enort of mnone on e team, working toge h to STP JOilSITE accomplish the objective of a safe nuclear power plaat. JANUARY 4.1988 L INTRODUCTION D. ROLE OF QAARC The Seeth Tesas Prefect Quality Assurance New let us azamine specificaHy the role of the QA/ ~ - program, to be fully effective. must be - > accepted and fully implemented by each 7,_ QC erganisattaa la regard,to safety. It is' the ' en this Project. responsibility of QA/QC te verify that this protect is constructed la compHanse with the applicable ' The purpees of this rnesting la to reiterate Brown design desumemas, This is as imperiaat i and & Root Management policy regarding the respen-specific rate la assuring nuefaar safety, but QA/QC albultles and duties of Brown & Root Construcilen does not carry the sole and total responsibnity for and QA/QC personnella implementing this QA safety. Safety is a responsibnity shared with Con-i program. struction and Enginessing. It is Conerrection's responsibility to build the plant in accordance unth N Project QA Manager will describe in detail th* applicable design documents. Engineering also rois QA/QC personnel play es this Project, tae r shares la the respoasibility for safety in that the duties and responsibiltiles, and standards of per* design must seassfy all of the appHcaW federal formance and conduct espected by Brown & Root and laduswy codes and standards, ~ Management. l It le also The Pro}ect Construction Manager wlH describe the responsibinty of the QA/QC (7 how /* 1.a;oa personnel support the Quality ergeassation to ensure that this wortl6 cat 6en is car. g 3,, 9,,,, gg y ';' Assurance progress and what standards of perfor. , 3, g, -l sa M M m plass hee ewa re , mance and, conduct are espected from Construe. sibinty la proper perspective with the concurrent e tien personstal. ,,,,,,,ibility of the engtmeers and construction e forces. QA/QC Inne construction and engineering starts with plans. specificassoas and other doen. ments specifying requiressents and procedural est & General Masaver methods. In verifying the acceptabiUty of the erec. Viss Pr SeithTm Prh tion and fabricazion it is espected and required thet we follow the design documents, specifica-tions and prams strictly as wettten by the IL THE RO!.E OF QC PERSO,NNE!. AT SOUTH engineers. i TEXAS PROJE.CT i N QA/QC ornamintion whne carrying out their A. l INTRODUCTION required furictsen la a timely and cost effeettwe manner shar** ***ther Br**n & R**' 1 O O t- ~ i e- -re- ^ ---.m ~e-~wo--- --,n---e--,,--------e--w--,-n o-

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QuhHty Asst.txance Program and perses paeres maaseci se Seeth Tesee pee. 3esi. m eserv.s a.e pies, is of,e,eme,ses at the

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South Texas Proj.ect Jobsite Im selevy se the raseneshmar of every seows & Reei e,nwe,ee. rnh a. has e,sie u,ie, ee p,e BROWN de R007 CCMSTRUCTION ANO lease. end it tekee ne fuH semelemanen oldiert of -/ CAA3C SEMINAR euervene en one two. wwkleg tege w r, to eseempneh one e6Jwwwe of a esfe amanut me.er STP JOESITE P3" 1. JANUARY 4.1980 L INTRODUCTION D. Ref.I 0F QAARC The Seeth Tenee Preises Quelley Aseerenee preyrem, se be f=Dy effeeuve. muss be _- f _ Newlet me seenhas ; _ "; the esie of the QA/ asespeed and folly Isapnemenaed by eneh employee _ QC ery==a==h la regend.ie miemp. It se the so see Prerest. respometheisy of QA/QC to serify thes this poiset le emmeWomed la ammellemme wetAn the appusekte ne pwomes w ese mesome se se seessmee ase=a ",. dessee" ' a This le es inoponent med & Rees F. _1 peney vesseems the reopen. spemans eene le esmeems seminer esfesp. bee QA/QC estaatues and desses of Benue & Rees Cemenesseen dess een essey she seis and seena respeesshaney ser , med QA/QC paneesel in -' - -'. shoe QA miemp. Selevyle a e Fa-==r. ehesed with Cee. preerna. eenense and =7 _ __ k is e--- f. he'Preess QA Mene ewen deseme ne dessa theapphenble deseen desessenes. "T.. eles ressemeamuy se hand the pies is essardenes wie e 'eie QA/QC pensese,l play a mes Pre 6mes esF. ebenes to e -- ser essa, se mes me danese and tospeessbilsuse, and egnederde of par dese s must emeesfy e5 et the oppmeable federal s rer. nee med emed. es,wiany a,o-o & Rea ,,g ledener codes a.e4 easedesde. ' Menesesases. n le le else the -, ". of the QA/QC %y Ces M wege win demerine '9**88**'** '* *"*"'e them thee wortfacasema as ear. g g, g,g,, reed set to a unsely east eHeestwo seemmer. la ne Asenresee program med what standarde of perfer. ,leipereses thes seek of as plass hee owe teopaa. menes and sendest are espeeted from Conserne. esblusy to proper ww me W emenrems U****'*****3* reopenilhanty of es sagtesere ud mine fasene. QA/QC Inse somewuenaa and engemeerias eterte wetit pleen, speefficassene and other deens. JJt. Geene meste vpsedlynes reemareeneese med precedural Vlee Pr esdent & Cemeent Menever meesde.l mesfytag me wepsettDey of on was. Seura Tenee Proieet * - use and labnamson la le upsened and Ngeirod - th 4 we fellow the doeste ' 6 speestles. these and preeminese seressay as wetessa by taae rL.THE ROLE OF QC PERSONMt1. AT SOUTM emessous. ?.C; " TEXAS PROJECT The Q'A/QC orgenteden imhne geseyens east Este ~ ~ A A. INTRODUCTION regelred 8=== as a temeny sed esas effeeveue ' enemmer eheres eseeker Seewe & Rees tones In the poet peer dase se evenes Hhe Thsee MGe resoneeststley of seengageeng the preteet ~ me le end. pueste entenues wee lesseed en the aslevy eastedete wethan she protoveed rose escassinee. ftme , ~ esseein of emeleet power paeans, and une effeseswe. of esempiesses as ef ones lessmervenes se ene sweees aus ei the Quehey Assumees progreene omdar and to the potate.Mewever. Qisehey as the eso een. wMeh Owy en built and operased. This eenentes sideressen ser Caes,meuse se wess se se quQC, hee sessed nearmeesd prammere med tensione assong Tliise the elitammes yeal el the Brewe & Rest seeen eu neveh.ed perum, she Nualeer Regoletary Cam. 18 e male pieme, esamenseed en sabedule et the neweeg pose;bie emes. ' meessee. Se ML&P and Brown & Rees. Thereisee. "***""*I****'Id****"*'"*** becesse evident thea we re-enemise med restese the E. NEC135 TTY pOR ATTITUDE OF RESPECT purpose med the leastles of the Qeelity AND CDCPERAT!QM ^""'****4**U 'I '""*" * *d P wer,rses the trsmework of the Brown & Rees tease, !! the Brewe & Rose seem to g,,, m,, g,,,g,to emessed la seesung ,g ,,, g 1. REGL*.ATORY FRAM51870Rht Farse. les es beteAy toweew the tele of the Noelear necessary thee se etsmeophere of mensel reopes

    • d ~

Requiesery C-- - _ he United Suseo Cee. -- ~ ~ be meassessed at e5 Umse at press serosen as e Aieses Emerve Ast eheeged une elee mene est QW men W lespostlene M se ene M done mes progeen weeufme. Cosam.usen with one rupeseawney to esense me tw la means une ^ 1 en puesee win malesy asenderes ehrasen the pro,

=== be waning to eese el liesseses roepoesstee putte selfisy essa. eeneet esiteneeman whomene famed. pen.ee se pian med seassrest aweiser pose piante - % lesettoteotyeat F 2 mustseem and te.ee i sonreie ame plasse when semplewd. ""F QA/QC "i'**** *I t's *** *'**** e'"os Thee the ?vRC to repose 8hne for toe 6eetag. a* inspeesus med apprewteg en arpeats of the desige, nest he QA./QC panesmal en est the Seal werd eessarvetsee end operesies of the plants. Th6s en ee oceepubHity w oneesepeshtuvy of ear g6ne liam er stressessenes. segetasery pseer is esereised threegh the li:sesteg c elseetly upon the unlury earnpesy 4 as

1. comet, hus the liesseee 6e directly responsible is stor NRC for nucleet seicy. The licensu can be timed ee tes.ee e Esente because of fellere to com.

g rny eith segeleierr standeres or to preenstly reeert '.D.,to the NRC seyenes that eevid or m.ths poesie6y

  • d 'M "*" *d U " **Nd U "W #

g e,,,,,,,, be espotle et mehlag the eluneese deeJeana en ewey eseeste of w ~ m.1 tothefasesume of SROWN & ROOT *3 TOTAL. RESPONStFJTY ow QuQC orgonneessee se s;ess: ment the m. bent I ?l.e f.ewatee hee elated 4 stemiendees stelleense nadines el the pleet.18 as the respeessulevy of l sagineettag to &epeettlee esperenree freen spie ' " ^.......

. - L.; > i.QQ l.6,Le,&Q.... v.%_ g . Q.s. gg.w . ~.,,,... q 3sa.p.9 w sp. 3.3:,g p .gma -* ~~ ' esehensees se hown and 33 apply a breeder degree i "W*esee da'** **meaase

    • 8

8 se' he ol d.seressen in ep,ree.as. u uusemanerv. a uneral rewereed se eendommense. !: se imeersmas to reanes dewbuen whosh no witano Gee taient of h plane i thes own the engemeer's d6epostuen le embrees to end speeffisetsene. But even they are vesertened is e and eneroval by the owner and the Neelear. their caerecee..and they are est partesned to Regw!asery Casamesseea's design reweew prier se approve devieuens !! they seald possibly lawelve a .saw.ng the ownee se opersung lissaee for this departure trem the latent el the design eng6nes. '[ ) The design engineer smay. of eeures. Interpret. plamb startfy. er caenge the design demenense to perma ,s f C. INDEPENDENCE OF QA/QC the sesentence of the work as u.has been pe. a fermed. If you resume that you ase poet of a large N C A/QC ergeatsessee. ahhough a fell fledged sn en, with a wry les,anent but netted esses of memeer el the Seewn & Rest Protest Management sothersey and reopensatsilty.and mas no one is the Teessi. enjoys a unaeus,orgensaattomal essess la flaat werd. la should be seeier to essept the less that Cemetrueuem has er r6ths to guessaan QA/QC thes as snee eepens dirsep, to the sep - eleasedene. and. shot a queetten er seen a rowersalle manageant of Brown & Aset Power Desteaan, Thee independemos le preceded to casare that undes met mesesearily disereditleg er tsadersnaatag presserve enames be appaned is eases semesmearen. eeshortsp. ing work to be esempied. These ese seen higher seehweses la es swee's ergenseessoa sad the $beeld these artes e ease le wheek the maae le se NaC to reselee goesumes of eash easteme enese ag sortees then le ladsennes lasempeumes er had feath annest be men essuy W The N er bed ledgemens er esa seassadoreennelas se the part of year teamediese esperweser inte restewed ergensenstem ohne ladopendees muss resegnes' the masser and allowed aanearemsen to preena mas hephe oesherutas de esist who how want euer year rejecuum yes teave the deer is pereee the naponsibeasy for destge.,senswweues and salesp. messer further email yee are saueDed that aampe. ~ tems senhartsy weshie Erewe & Rees as the highest loseL 18 - - hee agesewed emesse, esmeidered M. Q A4C DECISIONS CAN RE CHALLINGID es saaner and fasad it este. And furdie. If yee essu feel yes are r6ght. you hate a desy to report the We a5 hees pride in ear eart and it is se la)ery to em w h h R@w h ear ande whom ear were la essousaed er ettaessed. ~ All Brown & Rees team mesebus must reases thes they are not the flaal word and that theer does. K. QUALITIES AEQlAAID OF QAADC e6eas are oueiess to shallenge and that it le PERSONNEL appreertate for h6gher suchenty te make destaiene A,,,,,,,g,,,,,,,,,,,, 3ob in Q A/QC pse. veholding er tersrung their work.Too ellee pseele g feel that a cha!!ames of their deessies le se ebene. , gg ,g, an anemet to dienredit these.as anesept se endw. ,,,,,,,,,,,,73,,L,g,,,,,,,,,,,,,,,,,g,,,,,,,,, meme meer authertry. 6e,aa enempt to eewer se ,,4 sheedy and onesseranb.e warh. Perkm m ,,,,,,,,,,,,,,,,,,,,4,,,,g,,g,,,,,,,,,,g,,, 4H3tude temshe fresa the lack of understnading d 4 es essapsbees weth essa resquaressee el the resp =dedes ashers share is the dessga and sea-ammeeressen work parierse We home a highay Nt88em el 8 emelear Power M. ,gggg,g,,,,,,, ggfgg, _, _L,,4,gg,g,,, he=e desmenessaed year emalltienesest en these fC,, " "'d* " " "' " T L INTERNAL. STRUCTURE OF QA4C.

  • "er*ed are sense ombysenese and passare iden.

Q.c sens Tjne Pro 6eet QA/QC le smede up el a 'esember of "' UF "*" rpeenelleed groups and fumetsene. Each QC lespee. ter has a clearby delleed tree sad aespe of serh. g, g,gegriep. Howeesy send Cander and he has the reseensibinsy to laspect the werb am ble jar edlestem to seeste that it le performed Titeme ese se elemnly selated t$ney sesy be e aseerdlag to plane and spee6fiendene. The inspes* treated as one. Otonesely we amenes have ter has the resposaiblufy and abeelste aushersey to pegehuley in Mme asesreses of saleep and prevent Une work fresa preseeding estil One werb is Duelley emisse the QC Inspesa6ees and au satislamory. This le a peuit whsch must be eser* QA/QC perseemel are werewerony and stead etth a high sense of respoestbility.18 le a reNable to a desese that looptree 6esap6ete power and anthertty which is met abesluse er flank seeManes and allees no euepirion. Any bet whosh may be subject to shauenge end pre 6ow doubt la thee asas weenid roguera rep &eee= by othere vessed wtth even greater authority and seest el seek person. . respeaalblitep. la is newer easy to aseept a reversal of one's desimies. but it should help tf we rustaa S. Seppert of Neelene Power unas a reversal el seek a destesen may not mesa. and probably does mes nieen, that the desseen wee QA/QC,- ' have gross ressen. oveng er that it wee an abuse of asshorley se reises esbEhey for essesspinehang the perpenas of 4 to "enge eff" work e hich a highet eedierley later essernesang a pale emelaar pleas as approves. la may not be isnmed etely apparent se menemmen east and es sahadene. you why eveh a newsreel of one destenen eens met amena thes one sessenen wee weene, het let's S. Leyeley se Bewee & Rees eensname thes end I memb yee well underused shot what I am anytad le entryck Yee haue e mpeselbility to powe empieyer se e past of the teewe & Rees J. SUCCESSIVE LEVELS OF DECISIONS TO 8e*88 Mosenalbee for buildlag thes pieno APPROVE DEVIATIONg As e member of pine team you are espected to pull for Jhe team and that la is eerrut that the CC Inspector is not enewed to maae au of the nam. imel. ding the e esercise diacreuee is waiving dowtattene free rtrerttee crews. That means you must street and hieral comphance with plane end hews nopect der your tease. and rutiae stetitleetheas and he muse relues to " sign.eff= that an abeelusely sale plans le stie prsen. any week wh6th does not eseleen anacuy to the ery objecuve el the eestre orga==== draweegt. epecificauens and/or preceduras. These not just QA/N*. *here le ne room here are h.gher authersuae within the QA/QC and for a QA/QC men who laske confidence \\ lagtseering ergestaatione who ase allowed in the esenegesment er la has feDow ) bemasee diserettene and greater oatherity to worke,, the g,,,,3, g e t n,Th.,e ,j appreme work met withan entut and/or useret eneep* es ne seeme fee a mee weio messid esak to l' ease w*th See dreweegs er words of the reassines. emberten er herie has essapesy when he Q but wh6th are wtthis the real latent el lano Gew&d laseead help hie ensungssy % lee Jeb doenge eagmeer. It is suureay proper for thee regent. - + .-,---___.,__..-_e_ .,.,--,_____,v.

l 4. Osweties so Saty 5.

  • We aC. tods,6deelly. have a reopenesbussy l

3 QNCC pareenael mes he M = is the NRC. If anyone feels tha8 ime e e,,iem h.s fassed in its peranaemet ebem. ~. une usal salesy sad eenlicy ttwo af salevy. he has a duty to report has fonetten they are hered ta perforse and ,,,,,,, g, gne gag. after first besag eere they meet es unwitting to bosome e pasw that respeasible Brown & Reet efiscals se unaccessable practsess just is ease, ,,,,,,,og g, age.nen. theer Joe. The lassester who weeld sharge that veelassess had seeerred la the past Th6s is a semples subkat which moearse matere and thes he partiespaied sad ladled in }edgessent and underssanding. Withis the QNQC esport them beenene he "eas mahang ergantant6en yes.haos the especsey elseek ondere. poed freeney."la contempuble,and has se tanding. If yee have any seesuena. take these se plass as Broen & Reet. year superv6eer indhr6deally and he well emplare these in depth. If you sta8 beve geessione er een* I 1. Team Spires seres. I won be en eine ogweral days a week and j senseseas as "Open Deer Peiney" to dessene any QA/QC perseeael are espected to app,eeek theer werb wom *a seem opere6 miser saastere see pen. Yee am aos here se esem and pamaatt / weenesere, het to meets eeher team men. bars se perform sheer werb eswesels. Yes Profess QA Messeer we empened is sheek and meme has mestehas are enested and eerremed as the tsf. CONSTRUCTION SUPPORT POR STP QA peeper time kime men, serveeue* PROcaA38 beesmes too eastly. Yes are speeed.m de e diffleets and osmounes unplemanas The Preises QA Manager has spoken to yes thee Joe w6th ines and dyl--=r Se helpded missessa shoes she desses and responsabillem of I and go me seers mue w help spedias and, QMQC as STF. I esophaease the ressensibiliums el simpilly earressews - Casserensen se baudaag a sale "a* poser pleas. We are that part of the team theryod with 6. Reeposeeneesee to Autheetty eresasa of the engemeer's doesyn. Each employee has a base and respeessee. Mew de we go abeat his effort and ressado esos nees se the d.reetseas el eae's emperweser effesowe? Nesober one. =e have se plea ser work se an essessial part of the daeapinae la asah a smaamer thee we een besid ow pasas one necessary se mobe say ergeniastnea op'r* ties as near as possan8e se the plans and speeifisse sie effeettwesy. le Q N Q C werb unas uses. We been se hane magteserlag opprowel ler means ressoassveness se seshassal as weA esy destastees.There has been la the past h6siery as the adm6asserative desistene of year el this protest sorse differesses el opseAes b-sswee superiore. Your superviser la 'the proper the ~

en fermemen and the QC 4pectors asuieresy to evaluee, year Seesstems and sesy what eensuoused a dowtessen from the draw.

se roles them where reestred. tage and spam. The Process QA Manager has penseed eos mes the QC laspumer has many llendeed .Q } $UMMARY AND CONCLUSION lemmede when en seampremmen le roseired, when-QCasp e,.as.foreemen does em agros w6th she meopmareenen .e psi .sy chemid enR ie mser Whas rwe been selksag shaus le el e8eal temportamee se an of us here today to each es se lameedes4ly. ,, gi,,,,,, g,,. to the organtastion esas which we resseseek w een _.,, gg, 9 gg,,, toisemas eerbel'or phyeleal hernessneses of QC sempest. Brown & Rest and to the patine and een eeustry. lt is importent that we all understand ear laspemere by _.. emp&oyese and seek proper fusstaen la helpeng to.seles ear'Neassa a den med be greemde for teresassion. energy problem. la enese es =45 he usere esse effortlee to ser* sees es deviaalen than ena la esveral layers el la ar.nuv. i. m emphuiu uwwarand i=pr-

== pe==. , men,ge,,,en,,o,e isee ed .e, rem.m. we ased ei en u s.m. sm.e = 6eep.= pr* een er a desessen that emeld add addluomal ones and delays. 1. CA/QC la het one eleness la ea'asrtag that the faciusy we are levolved la beild. These is enh4Wied on this protest at th. ...n ,, g,,y,,,,,,,,g,,,,,,, g,,,,,4,, g g,,,, g tag will be seie when is, is flatshed and y ,,g,g _ - _..- sen we saa hese use placed la opersuma.... ; -.. sesse seaan operts threaghnes the reaha. We are 2. QA/QC le but one saember of she Breme, i. ; a program to fanssnernes all senseres. & Aest team -i-"-- ' to beeld unie uma seresnes esth the seemersemente and ahrenes of assiner power plaat seek member hostat the QC laepessure. l ^. has.here el the: tout reepeaseb434sy for the esse sad umely sempletten of a laeGasy g mey to mes gespassed less any pruden.tue beind eiheest w6D be sale se operesa. qu lesy predeems taman inopues tense to essere we 3. As Brewe & Ame(employs $spero en this hees -haa"-d a emaney predes. neelear project operate w6them as organisattesal streetere where super. Censuression '. - ^ ea ens preken eessga. . ors he,e y,mier rmpensiosusy sad sees and espperie ear QA/QC Deparunes m an eetherity than these whom they soeur* vise. Tae emperwesers have the respea. laseptal part of the total protest orgwataation. C:ven my chetes I would preter to he=e Quahey sibille. se review teshatsal dactsaens and Centrol ea say protest that I am asaecteemd with la modify or reverse there where aeeded, and the lesers. to enforts descipilae. lacledlag the deey to reprimand er discharge these who are met 3 ,3g ggg,,,,3,,,,gth thee stasement. t have en performeng se accordamse with the asub" "Open Deer Petwy* end wtII be ovelleben se die. i behed syssesa. evts your problems with yes at any Ussee that yes f ~ ' } 4. Wtthse u.e QUQC orgeaisstlen we ham saanes pet a sasialectory resposes freen yee o .Y-e special ressensibilary for essering saas esperdeer. 1 the slaat is constreened 6e accorsance I with the design. The alueese respea. sabehty for the safety of the plass resas -.. weth the Power D6viseen Managemeet. Project Cemetrussies Managet a 1 i .u.... l i i E=.mam.* --,-,w, ,,-,---,r-.--,,...e-.._-----,..

w j - m ~ ..s Oremerely a reisettea of eenaarweisen work by e ghgg,ggggg* QC laspector should be lemmediasely assepeed sad

  • I""d3*"I'* I" ***** *"

la come!.seen.I want to say we esAH have a beg }eb *"'****d'""*'**"*3d'"*"*"**'******* eased of we in covapleting the Semah Taas Pro 6ees. "b' Complete seepersseen from all sentribeling '"'***"*d'd****" reeps se ruwwed end imanmedesien and heressa shmid k emeed by peeps nienei of the menee mene from any evarier will met se talerseed. We

    • 'A*'"'"

\\, l w43 he ta'ing a number el steps le the future le m followup and esemphastaa the Stews & Root g,3 pegt,, dedseateen is esalssy that yew heard today. I home e'ery toalle8*se se our Asown & Rees team. la sur Babe & Rest le dedleased is foraleheng heen I eality.re!!aeie plaats and serwwee. All wert shall aes!!EV to resagalas the leapenames el enth eso. 4 arteenstag geoup el peop6e and la sur e64348W. uerh* cempey with applieeble eesign doevenessassen and lap together. to bin 3d a sale aussent power pleas el goed esasarvettom preessees. press '- ---- to Brown & Rest and to ser To esmolemens this pelsey the tenewing presedwe Caesi. Neussen Liebens & Power. I appreenase has been edensed. Te.be fully effsetswe. this yous anenties and unam4yee Ier ammans. pnsgram must be underessed. assepeed mad fully M -- ' by eesh e'smaleyes. Theeedese, all superwieers in the Emesmeerine. Co eussisee, and JA8"" QA/QC ergeassen shan esePeiese w emesse viei President & General Manager ,,,,g,,,,, i Sese Tamas Pe_eleet 4.2 Procedere Denne . 2 N dtNeeneseelepimase esesshaammier r "4*8'"""*" h

  • BRO w M & RO 07.INC.

and e QC lassemer enmees be speedily eeeenaud besween these et the woredag level the desselen of SOUTM TEXAS PROJECT the QC lassener shan proveel seWees to the f*Ilewing preesdures 1. If the Cemeensettaa 'spervleer wishes e IU

  • dI review he shell contact his owe disses REVISION O espervener wM shad le ture sentact has cometerpon superstaat la the QA/QC organdaattoa. The deelstee' el wh6ek lasersestasien is correas =43 he made by the QC seper,6 ear la consehauan eeth PROCEDURE FOR Rt.5CLVING D the Comesterssoa senereteery personnel.

SETWEEN The QC supereiser well utsines whosever wa asederaa's k decome esensaasy CONSTRUCTION AN_O QAAQC PERSONNEL se asemiesneet his owe hassetedge to smah. O al gag.this deelsson. h*y# v D Janeaev T.1988 The QC W*e m and es ' jeestflestaea wIII be hw en the appropriate report. and the QC '--y== wel be furnished s espy theteel. Other i.veised parase win be #m e ap, u j._ "*~' i 1% 2. If thsee le. etall disagreesnent. the J.R. GEURTs DATE differenees wel be referred leanedlessly STP PROJECT CENERAL MANAGER se the h6ghest level el5 town & Rest QA/ QC _ _ - "_t then present at the sees la re ww sad final doutosee end dese. 1.0 PtJRPO SE messed ee proseded abase. The'persone ed thee precedere la to state Brews & The docteeee of the QC laspector ehen be semiolled Rees policy regardlag one implementestee of the wuh by the Ceaetnsessen ergeaiendee um6gne that Seeth Temas Protes QA progreme. and se defles Wee le changed through the Ieregolas pro = the method for ruelvene disposes between stowe ,,g,,,, & Rest Ceaserwettes and QA/QC pereenmel. Differenees el epiasse between Stowe & Rees 3.0 SCOM Cemeeruelless sad 3rown & Rees QA/QC periemasi

    • 'e*h****3 Pr***d"'es teenstemenee see se be._.

The esepe oppslee se me remeteone of elHerenes. mesaved prompety and is a bussaseensam manner. et op. aeon en eenha.seJ er presedewel reewaremense h 18eemelvoelemenor h W s that menet be rese#wed by the Cemetrueues and any Steve & Reet esoployee of esy othe Brewe & CA/CC paraennel direaty laeolved. Reet eneployee wt!! not be islerated. As elfended employee theeld brtog such eenduce w the anon. 3.4 DISTR!gUTTON stes el his own Isassediate supereteer. AH sassJs ~ - esseplaista shah be reviewed Ismenedamsely by lies I 01str6tuuen shad Lactede: Brewet & Rest Preiset. Menegermeist for proper acues which may include terminaden of empley. 1. Preius General M6aater

3..

Engtaeartag Protest Manager stent of the effendlag empisyee. This la e sermal i 3. Constrwesen Protus Manager fvacusa of the "Qpesi Deer Poucy" which auews 4. Protus Centrols Manager any employee to bring eay job related prehieves se 5. Pmteet Masertal Mansgw die aneaties of his eusseessve superweeers and s., 0* E"8 OA M * **'" mausnately to assapany effleure withous fear el ntanaissa er huh s Ciner n, we shan be diseneu.ed, se.

d. en seure esmpiece essapuemee wtah thee 4

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. _ _ = t...._.. 1,- 3 ~. a .= x S.pt-r 8, 1,..0 r :....i, ; > n pag,J f:W & 2 I. UNITED STATES OF AMERICA g /[rt NUCLEAR SLSCUIMORY COMMISSION : FF ,I BEFORE THE ATOMIC SAFETY AND LTCENST G RCARD i .I i J In the Matter of J 0 1 ~ t TEXAS UTILITIES CENERATING ) Docket !;on:.

5. - 4 4 ',

COMPANY, et al. ) f.0-446 y (Co anche Peak Stearn Electrie ) ( Appli ca t ion it,r Station, Units 1 anc' 2) ) Op.ratino Licence) P

]

APPLICANTS' RESPONSE TO CASE'S ? REQUESTS FOR PRODUCTION OF DOCUMENTS l AS CLARTFIED BY CASE n l (3 Pursuant to 10 C.F.R 52.741(d), Texas Utilitics Generating Company, ej al., (' Applicants") here1',y submi t l : ' l Applicants' Response to " CASE's First Set of Interroga-li l tories to Applicant," dated July 7, 1980,'with respect te 1, those requests to produce-as to which App 2icants souaht i i; clarification in their ' Answers to CASE's Interrogatories " .j da.ted July 28, 1980. CASE clarified those requests in it.r. I 3 l " Response to and Motion Regarding Applicants' Answer:,," dated August 4, 1980. The procedures for inspection an1 copying of the documents requested by CASE are set.forth in " Applicants' Response to CASE's Requents for Prnduction l of Documents," dated August 11, 1980 and are set forth h again below. ? ? ~ ,d ^ , J L,, J.L m ge s - o luy ' u /, /

~.~~~ " "- wm' nmmw +- dy:h.:.q - ? 'h T.. i ~ . g. Applicantm' Responses To Roquests To Produce f -; w M.. I Bach request to produce l's identified by ites number, jj g, corresponding to the numbers in " CASE's First Set'of [' .1, Interrogatories to Applicants," dated July 7, 1990. Contention 5 Question: 3. Supply copies of each and every Field Request for Engineering Action (FREA) log. Supply copies of 'each 'and every concrete Pour log. 5. 9. How many audits have been performed by insurers (industrial risk, builder's risk, etc.) on work done 5 at the Comancho Peak plant? - l.y'

10. How many outside or sub-contractor evaluarlons, studies.

or audits have been conducted (by sub-cont: actors or agents of sub-contractors or by consulting firms er l others, etc.) ?

11. Regarding items 8 through 10, provide the iollowing informations (d)

Where is the audit, evaluation, or study kept so that we can review it? (Regarding Items 9 and 101 Answer: Applicants will produce for' inspection and copying the documents within the scope of the above requesta for e production of documents, as clarified by CAsz, according 9 ,_t.. J;. % $.. l. ] k l

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'i 1. The documents identified above will be provided V? l for inspection at the Texas Utilities Generating Company' of fices,18th Floor, 2001 Bryan Tower, Dallas, Texas, during normal business' hours (8 a.m. - 5 p.m., Monday - Friday);. ~ 2. CASE should schedule inspection of. documents by notifying Homer C. Schmidt, at ( 21~4 ) 653-4782, who will arrange for doc w nts to be inspected. 3. CASE should 6ot remove any documents from the dp room provided for such inspection. CASE should l identify those documents it wishes to be copied j and Applicants will make and supply copies at d CASE's expense and at a rate of 15 cents per pae13. y sdhmitted, ,p - Raspec u 3 )' { Wicho: Is M. Reynold's. ' 9: 1' q ,) l William A. Morin i 1 Debevoise I, Liberman h 1200 Seventeenth Street, N.W. i Suite 700 l Washington, D.C. 20036 ] (202) 857-8817 Counsel for Applicants September 8, 1980 \\ y ~ + . 1; 3 l H 2 l '- 4 \\ ? [ ? '). [ j-l I I t (, h;

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--y; t g .x UNITED STATES OF ANIRICA. M NUCLEAR REGULATORT CC3OLISSICN

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U j BEFORE THE ATCMIC SAFETT AND LICENSING 90ARD E.1 O;, 5 4-l \\

..- l In the Matter of P

TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 a j COMPANY, g d. ) 50-446 i ) I

  • (Comanche Peak Steam Electric

) (Application for l Station, Units 1 and 2) ) operating License) y ? 11 p .CERTIFICAT:: CF SERVICE = ..j I hereby certify that copies of the foregoing g

  • Applicants' Response to CASE's Requests for Production of Documents as Clarified by CASE *, in the above captioned matter 2

f were served upon the following persons by deposit in the . i United States mail, first class postage prepaid thia 4th day 1 of September, 1980: '.2: f':; m'i I Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, Atasic Safety and Licensing Appeal Panel i Licensing Board U.S. Nuclear Regulatory 1 1001 Connecticut Avenue, N.W. Comunission j Washington, D.C. 20024 Washington, D.C. 20555 e l Dr. Forrest J. Semick, Member Marjorie Ulman Rothschild, Esq. j Atomic safety and Licensing office of the Executive i Board U.S. Nuclear Regulatory Legal Director ] 305 E. Hamilton Avenue ~ State College, Pennsylvania 16801 Coassission .[ Washington, D.C. 20555 j Dr. Richard Cole, Member d Atestic S4fety and Licensing David J.-Preister, Esq. b Soard Assistant Attorney General ( U.S. Nuclear Regulatory Environmental Protectica 'Coeusission Division l Washington, D.C. 20555 P.O. Box 12548 i capitol scation Chairman, Atenio safat and Austin, Texas-78711 I40ensing Board Pane %../, 9 U.S. Nuclear Regulatory Mr. Richard L. Fouke Pf,%F.{ [E Coensission CFUR Washington, D.C. 20555 1668B Carter Drive ,,.., i. ft - 6-Arlington, Texas 76010 4 r [, t.f [ ~ j .i 3 L

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s M ) $) ' i [ q Arch C. McCo'll, III, Esq. Mr. Geoffrey M. Gay 3 701 Commerce Street West Texar. Legal Services Suite 302 10.0 Main Street (Lawyers B1dg.) Dallan, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq. Mr. Chase R6 Stephens 4021 Prescott Avenue Docketing &.Servico Branch i Dallas, Texas 75219 U.S. Nuclear Regulatory i commission I Mrs. Juanita Ellis Washington,.D.C. 20555 President, CASE ); 1426 South Polk Street + Dallas, Texas 75224 I 3 l 3. l ? William A. Horin ,e i ./ ~ j cc: Homer C. Schmidt i Spencer C. Relyea, Esq. ( i .ll 3 1 4 ,i l 1 1 'i a s. l 4 l : l : { l i.

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.4.e. e e seepe ,p.;..; sees eews +sse+= e.neet as iG .g,, s =y 3 , y eesse e see ese eeee December. 22., 1980 l brMny' h Mrs. fuanita Ellis ^ [ g President, CASE g 1426 South Polk Street t Dallas, Texas 75224 4 \\ D

Subject:

Supplementation of Applicants' Reepense [ to CASE's Request for Production 2 Dear Mrt..E111s t D 3 This is to notify you that Applicants hereby supplement .. ~ j their response to CASE's first set of interrogatortes and 1,Y.%) y' requests to produce. As a result of Applicants' continued ' t:. a, search-for documents within the scope of your discovery 'g requests, Applicants have identified the document 11st ed below as coming within the scope of Item 10 of your July.7 1980 y [ interroge. tories and requests to produce, as clarified on August .7 4, 1980. Applicants submitted snelt response to Item 10 on I. september 8, 1980. t Accordingly, the following document has been placed in j; the Dallas of fices of Texas Utilities Generating coepsny for l ^ your inspection and copying ce the terms set forth in Appla-h cants' September 8, 1980 response. d 3 " Final Report on Concrete Evaluation in Dome Roof g Section of Comanche Peak Unit 1, Glen Rose, Texas," p Muenow and Associates. t j Since ) 4 i I Reynolds j Nicho a Counsel Jgr Applicants i r NSR:11 l cc: Atomic Safety ard Licensing Board Marjorie Ulman Rothschild, Esq. ,1 i 3 a '1 r

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  • DEBEvoISE & LIBERMAN
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isoo sevewtesava steert. m.w. g c/ -.. to. s. veum .e mens an ee March 5, 1982 N Rdis /d ITsk Mrs. Juanita Ellis fp President, CASE, /)),*g used / F 8#"" ""ffs'4 1426 South Polk Street Dallas, Texas 75224 - Subjects Texas Utilities Generating Company ~ (Comanche Peak Steam Electric Station,

Units 1 and 2), Docket Nos. 50-445 and 50-446:

Supplementation of Response to CASE Discovery I

Dear Mrs. Ellis:

This is to notify you that Applicants hereby supplement their response to CASE's fi.rst set of inter'rogatories and requests to produce. As a result of Applicants' continued search for documents within the scope of your discovery requests, k?) Applicants have identified the document listed below as ~-4ag Q'7 - within the scope of Item 10 of your July 7, 1980 interrogatories and requests to produce, as clarified on August-4, 1980. :Appli-cants submitted their response to Item 10 on Sept' ember 8,.1980 and supplemented the response by letter dated December 22, 1980. In the interest'of expediting discovery on contention 5 in accordance with the Board's. directive, the following'docu-ment has been placed in the Dallas offices of Texas Utilities Generating Company for your inspection and copying: " Review of the Quality Assurance Program for the Design and Construction of the Comanche Peak Steam Electric Station." Prepared by F.B. Idbbia. (February 4, 1982) f SincerfI i l Nichola Reynolds Counse{fogApplicants NSR/pv y l cc: Service list. . M.., l l l t t I /-

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DEBEVOISE & LIBERMAN / .- m.m..-as.. - i =.aia.m... c.. m e enoe...... April 19, 1982 p ^ g,JidaY Mrs. Juanita Eb.lis ~ g,pr e e. President, CASE [t:Cond _/f 1426 South Polk-Dallas, Texas 75224 __S_ubj : Texas Utilities Generating Co., g al. (Comanche ~ Peak Steam Electric Station, Units 1 and 2), Docket Nos. 50-445 and 50-446; Supplementation of Response to CASE Discoverv

Dear Mrs. Ellis:

This is to s tify you that Applicants hereby supplement.

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their responses to CASE's first set of interrogatories and .: W ' ( requests to produce. As a result of Applicants' continued search for documents within the scope of your discovery requests, Applicants have discovered and identified the i , document listed below as coming within the scope of Item 10 of your July 7,1980 interrogatories and requests to produce, as clarified on August 4, 1980. Accordingly, Applicants have placed the following document in the Dallas offices of Texas Utilities Generating Company for your. inspection and copying: i " Report of Independent Review and Analysis of QA Records Management Systems for Texas Utilities Services, Inc.," prepared by Ebasco Services Incorporated (June 16i 1981). Sizicag 1 Nichola S. Reynolds Counsei fo Applicants h cc: Service List ..j l [ NSR:vms i s g

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May 29,1985 y .1 Peter B. Bloch, Chairman Administrative Judge !l Atomic Ss.fety and Licen. ting Board U.S. Nuclear Regulatory Commission ^-- Washington, D.C. 20555 Dr. Walter H. Jordan Administrative Judge 881 W. Outer Drive q Oak Ridge, Tennessee 37830 '*} O.-?!) Dr. Kenneth A. McCollom -0 $' O

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Administrative Judge Dean, Division of Engineering, .i Architecture and Technology M Oklahoma State University Stillwater, Oklahoma 74078 t Re: In the Matter of Texas Utilities Electric Company, et al 'j.. (Comanche Peak Steam Electric Station, Units I and 2) .e Docket Nos. 50-445 1 and 50-446 1 '.'j Supplementation of Applicants' Response to CASE's Request for Production 1 1~]

Dear Administrative Judges:

This is to notify you and all parties to the above dockets that Applicants have 1 Identified a document which we believe to be within the scope of item 10 of ,-j CASE's Interrogatories and Requests to Produce dated July 7,1980, as clarified on August 4,1980. 1980 and supplemented their response by letters dated DecemberApplic 22,1980, March 5,1982, and April 19, 1982. The document, a copy of which is enclosed with this (MAC) following a management review and audit of the qu s ) V of the Comanche Peak Project. 1 li EXHIBIT 4

, Administrative Judges, ' 'c May 29,1985 Page Two 'l. \\ .y Recently, in gathering data for a prudence audit being performed for TUEC, a search was made by TUGCO personnel of Inactive and closed corporate files located in TUCCO's Dallas office. In the course of such search, the enclosed report was found. A memorandum dated July 11, 1971, which details TUGCO resolutions to the findings and recommendations made by MAC,is also enclosed. d d. TUCCO management is evaluating the failure to produce this document at an f, earlier time and will advise the Board and parties of the results of ttils, evaluation 2 in the near future. - Respectfully subImitted Robert A. Wooldridge / Counsel for Applicants' =- -RAW /klw 1- - Enclosures cc: Service List ) . "5: .,- g l - s' e T a D l l I l 'T I) i .i ,d 7 7, a' -- 1 I _ 10 '~

h e' ~ AD*t eam 4-85-008 WOROHAx. Foocyraz. SAMPEI.S & WOOPR.tDGz ,w. as,,* F ev..sw.s...D 3..a... ",.... .....=.6. DA2.LAs. TrJus 75901 s.t.a....... .. s..........,...... ...'../.'!'t/*:. ,.a.....,,,.>,....... ,,,........u 7,..g,...;. s oog3 u...,......... us s .... ~..... T.'/;f":./* "**,"..... '85.AN 13.Pl2:06 June 12,1985 ........s.. crra a= fw.:. . 6 s ..u... 00CxETmG & s pfi - BRANCM Peter B. Bloch, Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. 3ordan Administrative Judge 881 W. Outer Drive Oak Ridge, Tennessee 37830 i ,-g f. a Dr. Kenneth A. McColloin W Administrative Judge Dean, Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74078 Re: In the Matter of Texas Utilities Electric Company, et al, (Comanche Peak Steam Electric Station, Units I and 2) Docket Nos. 30-445-1 and 50-446-1

Dear Administrative Judges:

Further to my letter of May 29, 1985, in which we forwarded the report by Management Analysis Company (May 1978) regarding the quality assurance pro-gram of the Comanche Peak project, this will provide the Board with the results of Applicants' evaluation of the failure to produce the report at an earlier time. As we indicated in our May 29th letter, the report was found in the course of a search of inactive and closed corporate files in connection with a pending prudence audit being performed for TUEC. When the report was found, it was reviewed in the context of discovery requests in this proceeding in order to determine whether~ lt was subject to discovery. We determined that the report was subject to discovery and current TUGCO management concurred in that view. c;c,h -1rymem 3*w Ao ex o 3 e gxgx,17 3 --...,...-,~.---,n., ,--,,-_.-,-------,--,,,,.----,.-,,--,-,-,.--.-,,,,-.--.c. .,L

n ,,-w-,mm wg x.3a; - i 4 Administrative Judges . June 12,1985 ~ ' Page Two At the direction of Mr. Spence, TUGCO President, I interviewed a number of company employees in order to determine why the report was not produced in 1980 in response to CASE's first discovery request. Those interviews indicated that the TUSI officer then responsible for licensing, Mr. F1kar, made the decision in 1980 that the report was proprietary and should not be produced. Mr. Fikar stated that it was his view that the report was prepared solely for a few members of company management and was confidential. Mr. Fikar further stated that he thus believed that his decision not to produce the report was justified. No advice of ' ounsel was c obtained at the time regarding the discoverability of the report. The interviews also Indicated that a TUGCO officer, Mr. Clements, was aware of the report in 1980, even though he had not read the report. Mr. Clements assumed responsibility for.QA/QC shortly after Mr. Fikar made the decision that the report should not be produced, was aware of the decision not to produce the report, but did not revisit that decision. The interviews further revealed that Mr. Chapman and Mr. Toison were aware of the MAC report and were of the view that the report was within the scope of the discovery request but their views either were not known to, or were not shared by, Mr. Fikar. Applicants believe that Mr. Fikar's decision was clearly an error in judgment 60 and Mr. Fikar now recognizes the, error. Applicants believe also that Mr. ~,. Clements should have requested that the decision by Mr. Fikar be reconsidered. None of these individuals is presently involved in Applicants' nuclear organi-zation. Mr. Fikar has announced his retirement from 'the company. As of July 1, 1985, he will no longer be a part of TUGCO management. Mr. Clements has been reassigned to a position with a non-nuclear operating division of TUEC effective June 11,1985. As the Board is aware, Mr. Chapman was reassigned out of the nuclear organization several months ago, and Mr. Tolson left the company several months ago. At Mr. Spence's direction, Applicants are taking steps to assure that no other such documents exist and to assure that a similar situation does not recur. While we believe that all other documents that are within the scope of discovery have been produced, we are again thoroughly reviewing company files and all discovery requests to assure that no others exist. We also w111 reiterate Applicants' obligations in this regard to those who have responsibility to provide information to the NRC and to the parties. Respecifi21y submitted, ./, .s-Robert A. Wooldridge i Counsel for Applicants ,9 RAW /k1w J cc: Service List t l

.vw>..n ~. _.< n:s wmvw=m :mMlg???Mt.dWWMMil&4%'MMNOW'W' ~ 4-85-008 (JNITED STATES OF AMERICA '~ NUCLEAR REGULATORY COMMISSION . . ' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i _, In the Matter of Docket Nos. 50-445 TEXAS UTILITIES ELECTRIC 50-4 M COMPANY, ET AL. 50-445-2 50-4M-2 (Comanche Peak Steam Electric Station, Units 1 and 2) ' 's l' . APPLICANT 3' RESPONSES TO CASE'S INTERROGATORIES ~ RE: 'THE MAC REPORT AND ISSUES RATUO BY THE MAC REPORT Pursuant to 10 C.F.R. Sections 2.740b and 2.,741, Applicants hereby provide ~ their responses to CASE's Interrogatories in connection with the MAC Report and issues Raised by the MAC Report dated June 24, 1985. Applicants' responses are governed by the Memorandum and Order entitled " Memorandum (Motions Relating to the MAC Report)" dated July 22,1985. ~ , f,, ,g - % ia' On page 2 of Applicants' 5/29/85. cover Icec, It is stated that7,.n..% 1. ~ Report was discovered "In gathering data for a prudence iaudi).. '...:/,' tv J.%. performed for TUEC," and other relevant details are given. l Provide the following regarding such prudence audit: (a) ^What company / companies or organization (s) is/are performing the pru-dence audit? Answer: Cresap, McCormick & Paget. \\ l (b) Provide the name (and company / organization and title) of each Indl. l vidual who is performing such prudence audit for the company /organi-l zation in (a) prect. ding. Answer: There are a number.of Individuals working for Cresap, McCormick & Paget on the audit. A list of these Individuals is at ached. (c) What organt:stions affiliated with Applicants (TUSI, Brown & Root, Ebasco, PSE, etc.) are involved with such prudence audit, and what is the extent of their involvement? _ Answer: The ' audit is being performed solely for Texas Utilities V Electric Company., Other firms have personnel who have been n>h,m

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l' EXHIBIT 6. e ~ yuw y * /

. wu :. m mm - m~.r vm w ~-wmw WY:c./Mi: J W:s==W W + O. Interviewed and/or have responded to questions posed by Cresap, McCormick & Paget, but - only Texas Utilities Company sub-l i sidiaries are being audited by the Cresap firm. (d) Provide the name (and organization and title) of each Individual with each of the organizations in (c) preceding who is primarily or actively involved with such prudence audit. Answert Applicants object to this Interrogatory and also to Inter-rogatories 1.(f),1.(m), and 1.(s) for the reason that each of said Interrogatories Inquires in detail as.to matters which have ab-solutely nothing to do with the MAC report, are wholly outside the scope of these licensing jon.edings and such Inquiries con-stitute a fishing expedition for matarla! related only to CASE's participation in Applicants' rate cases before the Texas Public Utility Commission. Same is, therefore, not a legitimate purpose for discovery pursuant to 10 C.F.R., Section 2.740b. In this s,.i.ection, Applicants would refer the Board and the Intervenor to answers to Interrogatories 1.(e) and 1.(k) below for an ex-planation of the purpose of such prudence audit. Such audit has no bearing upon the discovery of the MAC Report. The Report was found by Applicant, and not by the auditing firm. The only reason the prudence audit was even mentioned was to explain why Applicant happened to be inspecting files. To permit, therefore, the Intervenor to engage in discovery on such wholly unrelated matter contrary to the purpose and intent of this Commission's rules and to the prejudice of Applicants and other parties who may be involved in rate cases before the Texas Public Utility i Commission is wholly unjustified and unnecessary and should not be permitted by this Board. (e) What is the purpose of such prudence audit?- Answer: The purpose of the audit is to provide an independent third-party evaluation of the economic effect of management decisions on the total cost of the Comanche Peak project. (f) Who (name, organization, title) determined the purpose and scope of such audit? If such Individual (s) consulted with others, provide the name, organizatien, and title of each such person.- Include in your answer a brief discussion of how it was decided that such an audit was to be performed, the scope of such audit, what role each Individual played in making such decisions, etc. (i.e., how the whole process evolved). Answert See objection contained in answer to Interrogatory 1.(d) above. (k) For what purpose (s) will the prudence audit be used by Applicants? Answert it may form a part of TUEC's testimony in any rate case to consider the rate-making treatment of Comanche Peak as above described. (m) Which other audits, reports, analyses, etc., were reviewed or will be reviewed by prudence auditors in connection with the prudence audit? 4 8,

jp.6?RnWWUW-MiWM?N%-W5WMW&##tM:&2MWiWi'@RMW!OW'S 4*. Answer: See objection contained in answer to Inteirogatory 1.(d) above. / (s) Provide copies of all documents (in the broad sense of the word, as defined on page 2, item 3, of this pleading) regarding your answer to items (a) through (r) preceding. Include copies of au drafts of the prudence audit, as wen as the ' final prudence audit itself. Answer: See objection contained in answer to interrogatory 1.(d) above. 2. (a) Specifically who (name, organization within TUGCO, title) made the " search... of inactive and closed corporate flies located in TUGCO's Dallas office"? Whose (specifically, both now and at any time pre-vlously) office was the report in? Answer Mr.. Andrew 5. Jones, senior auditor employed by Texas Utilities Services Inc. The report presently is in the possession of counsel for the Company, Mr. Robert A. Wooldridge. At the time it was found, it was located in a storage box in the TUGCO corporate offices on the 31st floor of Skyway Tower. It tem-pararily was being stored in the office of Mr. Homer Schmidt, but was not actively maintained by Mr. Schmidt. (b) Specifically who (name, organization / company, title, duties and re-3 n; sponsiblHties) first identified the MAC Report as being a document ~ which Applicants should have provided in response to CASE's 1980 discovery requests? Answer Mr. Robert A. Wooldridge, an. attorney representing the Applicant. l (c) Provide a summary of exactly when, how and by whom the M' C Report A was found and the process by which the determination was made that i Applicants should have provided it in response to CASE's 1980 discovery requests. Include specific details as to exactly when each action or event occurred, who (name, title, organization at the time, current title and organization) was involved, etc. (The type of Iriformation we want includes something like: Auditor (name) with (name) company asked to see all management audits which had been performed regarding Comanche Peak. brought the auditor a stack of files for review. Secretary ((name) Auditor name) indicated that he/she wanted a copy of the MAC Report and/or that he/she (Name) planned to consider and include it in, the prudence audit. TUCCO (title), and (names) were present at the time Auditor (name),gave such Indication. (Name), TUGCO (title) realized that the MAC Report should have been provided to CASE on discovery in 1980, and informed (name, title, organization), who informed (name of l attorney, law firm) on (date). .3 Answer: The MAC Report was located by Mr. Andrew S. Jones in late i.;;/ April,1985, while he was surveying the contents of the inactive and closed corporate files stored in Mr. Schmidt's office. He was i.

,... n _ -.a v -. ,c,?e- . wn ~ _ w a > w y. = w = w w m = m w w ' m' * *~ m ' " " ' l looking for information relevant to the prudenc odit. Mr. Jones .I mentioned the MAC Report to Mr. Robert Spangler and Mr. Dave Chapman during a discussion of Q.A. Issues related to the .v ' prudence audit. Mr. Chapman iniormed Mr. Jones that there-tofore the document had been kept confidential and that Mr. Jones should review the report with TUGCO management before making it available to the Cresap firm. Mr. Jones then delivered the report to Mr. Tom Rose. Mr. Homer Schmidt,.Mr. Rose's supervisor, reviewed the document and suggested that the matter should be reviewed by Mr. Wooldridge to determine whether the report should be made'available to the auditors. On or about May 10, 1983, the audit report was delivered to Mr. Wooldridge, who reviewed the same shortly thereafter. Mr. Wooldridge then dhw the matter with Mr. Chapman and reviewed the prior discovery requests of CASE in the ASLB proceedings to determine whether the MAC report was within the scope of those requests. (d) Provide the exact extent of knowledge (attended initial Interview regarding MAC Report, attended pre-audit meeting, attended post-audit meeting, received copy of report, knew about report, participated in Internal management discussions regarding report, was aware report should have been provided to CASE on discovery, was interviewed by Mr. Wooldridge "In order to determine why the report was not produced in 1980 in response to CASE's first discovery request," etc.) of each of the individuals listed below. (If the extent of his/her knowledge changed, give specific details .. c.., as to.how, why, in what way, and at what time such change occurred.) .y D. N. Chapman R. G. Tolson R. V. Fleck

3. V. Hawkins
3. B. George
3. T. Merrit(t)

E. G. Gibson B. 3. Murray

3. 3. Moorhead B. C. Scott j
3. P. Clarke R. Mann H. O. Kirkland U. D. Douglas D. C. Frankum i

P. Poscolo L.Hucock i A. boren A. Vega C. Beggs R. Gary (Fikar) ! Fiker l P. Brittain I ~ Michael Spence i John Marsha!! 4 ' f z

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Susan Spencer Homer Schmidt Thomas Brandt Gordon Purdy John Beck Other Brown & Root personnel (list each) Anyone with the minor owners of Comanche Peak or their agents, consultants, etc. (list each) Any of Applicants' new (since January 1984) consultants, em-ployees, or agents (Est each Individual, his/her title and organi-zation) Answer: The following persons (upon information presently available to Applicants from interviews) had no knowledge of the MAC audit, the report, or discovery relating to the report, until the time mentioned in paragraph 2(c) above, i.e., May or June,1985: Michael Spence, John Beck, Homer Schmidt, Tom Brandt, Gordon Purdy, the minority owners, and Applicants' new consultants, em-j playees, agents. Regarding the extent of knowledge of others mentioned in Inter-rogatory 2(d), see the answer to paragraph 2(e) below and the affidavits attached. ...,4 4 .~ (e) For each of the Individuals in (d) above who had any knowledge of the MAC Report, provide the following information: I (1) Specifically when did he/she first find out about the MAC Report? If the extent of his/her knowledge changed, specifically when did each such change occur? o (2) How did he/she first find out about the MAC Report? l (3) Title and organization at time he/she first found out about the MAC Report; title and organization as of December 31, 1984; title and organization at present; date of each change in title } and/or organization between December 31,1984 and the present. l (4) If no longer employed by 'Appilcants or theli agents, provice ' his/her last known home and business addresses and tele' phone i numbers. (5) Provide a sworn affidavit by each Individual that the statements in your answer are true and correct. (6) Make each Individual listed in (d) above or your answer to (d) above available for CASE to take his/her deposition. Answer: See the affidavits attached to this response. O Applicants were unable to locate 3. 3. Moorhead (believed to be in Saudi Arabla), R. V. Fleck (believed to have last been employed by Florida Power & !.lght), and R. Mann (left CPSES in July of 1978).. ,,s.m m v.uvez.wrg,m. m.w m:,,.%.m y.cy m..,g,,,p;.g. .,., g..,.,,,y...,,,,;. g., p., a,., -f Applicants were unable to obtain a statement Sr affidavit from the following Individual: H. O. Kirkland. 's w 2 .) Affidavits are expected to be received froni 3. P. Clarke, Peter Foscolo, and Lee E. Hancock but were not available for filing on this date. This answer will be supplemented when the affidavits are received. Regarding paragraph 2(eX6), A formal request, if necessary, pplicants will consider a reasonable and in accordance with the Com-misalon's Rules of Practice, as to specific tions. Applicants expressly reserve the right to file ob and motions in response tw e. (f) (1) When the MAC Report was first received by Applicants in 1978, what distribution was mad, of it; who recolved copies of It? Answert Same was received by Applicants on or about the 24th day of May,1978. Copies were made available to Messrs. Brittain, F1kar, Gary, and those individuals who have stated they also received a copy of same In thu affidavits attached. Appucants are not aware of any others receiving a copy. (f) (2) Were copies of the Report distributed to others at a later time? If so, give specific and complete detaHs as to who, when, etc. Answer: Not to Appilcants' knowledge. (f) (3) What happened to each copy of the report in your answers to (1)- arid (2) above? Did the Individual still have a copy at the time the report was rediscovered during the prudence audit? Did anyone (Mr. Flkar, for instance) confiscate the other copies of the Report? If so, provide specific and complete details as to who, when, etc. Answer: The report which was located by Mr. Jones had originally been the file of Mr. Brittain, who was then the President of TUGCO. Such copy was still in the TUGCO files at the time it was found. Mr. Fikar also had a copy of the report in his office. Both Mr. Gary and Mr. Chapman had copies initially, in 1978, but they did not retain them. See the affidavits attached. No copies of the report were " confiscated" by Mr. Flkar. (f) (4) Did anyone (Mr. Flkar, for Instance) order the other individuals who were aware of, or had copies of, the Report not to supply them to CASE on discover the Report's existence? y or not to advise Applicants' counsel of If so, provide specific and complete details as to who, when, etc. 1 Was there any discussions between or amon and/or any others listed in (d) or your answer to (d) g Mr. Fikar i preceding as j to whether or not the Report should be supplied to CASE on i discovery? If so, provide specific and complete details as to who, j when, the result of such discussions, etc. ) Ansv/e, r, Not to Applicants' knowledge, although Mr. Fikar, we be-fieve, made the decision that the MAC report was proprietary and t-

gg n.wmwwm mm.~emxMir~n%~MH'*WG&iWP*%M** MOW 9 should not be disclosed Ir response to CASE's discovery request in ~ this proceeding. Such decision was made known to Mr. John Marshall and possibly to others. See affidavits attached. (f) (5) To whom specifically (name, organization, title, responsibilities) was Mr. Wooldridge referring when he stated that "TUGCO management is evaluating the failure to produce this document at an earller time..."? Answer At the request of Mr. M. D. Spence, Mr. Wooldridge s continued to have discussions with the various personnelinvolved. (f) (6) To whom speelfically (name, organization, title, respzisibilities) was Mr. Wooldridge referring when he stated "We determined that the report was subject to discovery"? To whom specifically (name, organization, title, respon-sibilities) was Mr. Wooldridge referring when he stated " current TUGCO, management concurred in that view"? Answer: With the assistance and advice of Mr. Wooldridge, Mr. - Spence determined that the report should be produced. Other members of the current Texas Utilities management that con-curred in that view were Messrs. Perry G. Brittain, William Counsil, and John Beck. (f) (7) Specifically who (name, organization, title, reeper Ibilities) did Mr. Wooldridge Interview "At the direction of Mr. Spence... to (no) determine why the report was not produced in 1980..."? l.. Answers Mr. Spence did not direct Mr.' Wooldridge as to who he should interview. Mr. Wooldridge has interviewed, In alphabetical order, the following Individuals, relating to the MAC report: ('( l Debra Anderson, Texas Utilities Generating Company 3ohn Beck, Texas Utilities Generating Company Tom Brandt, Ebasco Services Perry Q. Brittain, Chairman of the Board and Chief Executive, Texas Utilities Company ) Dave Chapman, Texas Utilities Fuel Company B. R. Clements, Vice President, Texas (Jtilities Generating Company L. F. Fikar, Executive Vice President, Te*xas Utilities Generating Company R. 3. Gary, Executive Vice President, Texas Utilities Generating i,y. Company D Joe B. George, Texas Utilities Generating Company i ( I . _ _ _ _.,.... _. _... _. _ _ ~, _ _ _ -.

s m w.,m e,., news.-~ wave.c.w: v mm,rr m. . e m..z.....,;...... e..;.c m, w :-i. Andy Jones, Texas Ut111tles Generating Company i John Marshall, Texas Utilities Generating Company .m John Merritt, Texas Utultles Generating Company S. Susan Spencer Palmer, Texas Ut111tles Generating Company Nicholas 5. Reynolds, attorney for Applicants Tom Rose, Texas Ut111tles Generating Company Homer C. Schmidt, Texas Utilities Generating Company Robert Spangler, Texas Utluties Generating Company Michael D. Spence, President, Texas Utultles Generating Company Ron Toison,1114 Briarbrook, DeSoto, Texas. 75115 Antonio Vega, Dallas Power at 1.lght Company (f) (8) Specifically who (name, organization, title, responsibilities) were the "few members of company management" whom Mr. Flkar believed the report was solely prepared for? Answer: Messrs. Brittain, Fikar, and Gary. (f) (9) Applicants' 6/12/85 letter stated: "Mr. Fikar further stated that s he thus believed that his decialan not to produce the report was justified. No advice of counsel was obtained at the time

a regarding the discoverability of the report."

When did Mr. Fikar seek advice of counsel? Provide details of how, when, by whom (name, organization, title, responsibilities), under what circumstances, App!! cants' counsel first became aware of the Report. Who specifically of Applicants' counsel was first informed of the Report? Answer: To Applicants' knowledge, Mr. Fikar had not sought advice of counsel regarding this report at any time prior to the time Mr. Wooldridge first Interviewed him regarding same in mid-May, 1985. Regarding the inquiry concerning when Applicants' counsel first became aware of the report, see answer to 2.(c) above. Mr. Wooldridge was not aware of the report until on or after May 10, 1985. Mr. Reynolds was not aware of the report until Mr. Wooldel'dge advised him of same. (f) (10) App!! cants' 6/12/35 letter states that the Interviews indicated or revealed that Messrs. Fikar, Clements, Chapman, and Tolson were aware of the report, and provides some detall about the extent of such awareness. Did Messrs. Flkar, Clements, Chapman and vide the information about his own awarenes,s, or/or Tolson pro-was the infor-mation obtained through interviews with other Individuals? .t.

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1 -~ ~ O. Answer Mr. Wooldridge interviewed Messrs. Chapman, and Tolson. The statements attribu. Fikar, Clements, ted to them were provided by those Individuals. (f) (11) Provide a comparison of the time frame when the MAC Report was rediscovered during the prudence audit to the time when recent changes were made in management (specifically, but not limited to, Messrs. Fikar, Clements, Tolson, Vega, Chapman, Purdy). Did any of the changes in management occur as a result of the rediscovery of the MAC Report? 4 . Were any of the changes in management made in ble or in part as a disciplinary measure? Were any of the Individuals whose positions were changed or who were involved in rec'ent management changes offered the option of resigning, retiring, being reassigned to other duties, j and/or having disciplinary action taken? Provide specific and complete details, regarding each Indl-vidual. Answer: The MAC report was found subsequent to the changes in management which have involved Messrs. Tolson, Vega, and Chapman, and subsequent to the time of Mr. Fikar's reassignment . (@$, Fikar's retirement, Mr. Clements' reassignment, and Mr. Purdy's to non-nuclear activities. The report was discovered prior to Mr. M 1~t to resign from Brown & Root. Mr. Purdy's decision was not related to the MAC report. Mr. 1 Fikar made the decision to request early retirement following a l cor.versation among he and Messrs. Spence and Wooldridge, which conversation involved the dLv=1~i of the circumstances sur-rounding the disclosure of the MAC report. Mr. Clements' i reassignment, in part, related to his failure to insist upon a reconsideration of Mr. Fikar's decision to not disclose the report. Regarding the " offering of options" to these Individuals, no such options were dLeM (I) (12) Were all " inactive and closed corporate files" reviewed in con-nection with the prudence audit? 4 ) If so, what else was found which may be discoverable? If not, provide them or access to them for inspection and copying. (f) (13) Do similar active er inactive / closed corperate files exist at TUSI, TUEC, TU, DP&L, TP&L, TESCO, minor owners of Comanche i Peak, and/or TUGCO's offices (either in Dallas, other offices, or at the plantsite)? v 9

+ i t A, If so, answer all applicable questions herein regarding those flies. .s If your answer is that you don't know, provide them or ~ access to them for inspection and copying. Answer to 2.(fX12) and 2.(fX13): In the Board's Memorandum and Order (Motions Relating to the MAC Report) dated July 22, 1985, these interrogatories are stricken to the extent that they are "not iW.elve to outstanding discovery requests." All of the closed flies which were in Mr. Schmidt's office were reviewed and will be reviewed again as part of the Plan for Inspection of Flies, attached. Appilcants are not t aware of any documents, other than the MAC report, whether In those files or elsewhere, which would be responsive to outstanding discovery requests that have not previously been produced. 3. (a) Applicants' 6/12/85 letter stated: "... Applicants are taking steps to assure that no other such documents exist and to assure that a similar j situation does not recur." Specificall by whom (name,y what steps are being taken in this regard, and title, organization) are they being taken? Answer Mr. John Beck, as the TUGCO officer responsible for i hcensing, has inittsted a program of review of documents. A description of such program entitled Plan for Inspection of Flies is 1.'? attached. Mg* gJ (b) Ap!! cants' 6/12/85 letter stated: "We also will. reiterate Appilcants' oblifrations in this regard to those who have sw.eibility to provide inic:/mation to the NRC and to the parties." (1) Who specifically will reiterate Applicants' obligations in this regard? (2) Who specifically (name, title, organization). currently has l " responsibility to provide 'Information to the NRC and to the parties"? (3) Who specifically (name, title, organization) in the past had "resprs.51b111ty to provide information to the NRC and to the arties"7 Specify the time frames during which each such adividual had such responsibility. (4) What is.the current criteria for determining whether or not l documents would be provided to CASE on discovery? I l (5) What were the former criteria for determining whether or not documents will be provided to CASE on discovery? i (6) What is the current criteria for determining whether or not the NRC. (both the Staff and the !.! censing Board) will be advised of the existence of, or provided copies of, documents? 3 1 l. O

We r,wt un sswu 'e:-M.d'*1n WWWr"Wi4MU?W6E IID5@NEDWUI O ~ (7) What were the former criteria for determinin NRC (both the Staff and the Licensing Board)g wihether or not the would be advised of the existence of, or provided copies of, documents? (8) Specifically who (name, title, organization, duties) decided upon such criteria (both past and present)? (9) How do management reviews and/or audits, QA reviews and/or audits, etc., which are performed by consultants (as opposed to being part of Applicants' formalized internal and/or vendor auditing system) fit into A assurance / quality control? pplicants' overall system of quality Include in your answer (but do not limit your answer to) the following: Q) How and where are reports / audits such as this flied and kept? (Answer for both past,and preseht practices / procedures.) (11) By whom (name, title, organization) are such. reports / audits kept? (Answer for both past and present.) (111) What is the system of filing and distributin / audits? (Answer for both past and present.) g such reports Qv) Provide a copy of the distribution list (all past and present lists) for such reports / audits. F m-(v) How are the findings and concerns of such reports / audits h,N. trended? (Answer for both past and present.) v (vi) Provide copies of all such trending summaries /re-ports / analyses, etc. 1 ) (vil) Is/was there a listing (computerized or otherwise) of all such reports / audits? If so, provide a copy of all such listings. If not, by what means are such reports / audits tracked or kept up with? What assurance is there that there are not l other such reports / audits which should have been, but have not been, supplied on discovery to CASE 7 (vill) Were, or are, such procedures / practices /criterla pro-ceduralized? f = If so, provide copies of all such procedures (past and present). If not, what assurance is there that such procedures were or will be followed consistently? Answert in its Order of July 22, 1985, described above, the Board struck Interrogatory 3 (b). However, Applicants were directed to ,r.. state in appropriate evidentiary form precisel V, will take to " reiterate Applicants' obilgations." y the actions they i g )

2 2.m mn -ment ~swww aWW T': I &&'P * ' ' ' W" ***M* *'##' ' g I 1 Mr. Spence has requested that Mr. Wooldridge dev'e[op a program ~- to make sure that those who are responsible for collecting and ) responding to discovery requests are aware of the Applicants' obligations relating to such discovery. Mr. Wooldridge, or Mr. Reynolds, or one of the members or associates of their firms, will be responsible for assuring that those persons resp.er.sible for collecting or gathering data or information are aware of the NRC Rules of Practice and NRC decisions relating to dec.sw y re-quests and know that any request for information not objected to and upon which an objection has not been sustained is to be provided in accordance with each specific document rme These persons will be lastructed that to resolve any possible doubt about discovery, any question regarding the discoverability of any document which might be considered to be proprietary or con-fidential is to be brought to the attention of Applicants' counsel for review. 4. (a) Whose handwritten notes are shown in the margins of the MAC Report? Answer: Mr. P. G. Brittain's. (b) When were such notes made? Answer: The notes were made shortly after receipt of the audit report in 1978. (c) The handwritten notes on CASE's copy of the MAC Report were not-clear, and in some Instances were run so that part of the notes.were off. '. (- i the page. i Provide good, clear copies of all pages with handwritten notes. Answer See attached for another copy of the report. i 6. Provide any and all documents (in the broad sense of the word, as defined on page 2, item 3, of this pleading) relating to all of your answers to questions 1 i through 5 preceding. i t Answer: See objection as to documents requested under Question 1. Such other documents are available for review in the offices of Mr. Robert A. Wooldridge, 2001 Bryan Tower, Suite 2500, Dallas, Texas 75201. R% dully submitted, Nicholas S. Reynolds William A. Horin BISHOP, LIBERMAN, COOK, l PURCELL & REYNOLDS 1200 Seventeenth Street, N.W. Suite 700 Washington, D.C. 20036 (202) 857-9800 3 l w) 5 i 4

a.,yc ~ c= u -.e.- -.. aec - .n c.y v. t ngens..wm.av.w.gsgr.ve;+n. ygfj$GMr=iyfgh WJL 2 O, Thomas G. Dignan, 3r. R. K. Gad, III ROPES & GRAY 225 Franklin Street Boston, Massachusetts 02110 (617) 423-6100 Robert A. Wooldridge WORSHAM, FORSYTHE, SAMPELS & WOOLDRIDGE~ 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 (214) 748-9565 s -~ - By xl Robert A. Wooldridge Counsel for Applicants m, 9 9 9 e eE e G e a'*O 8 e _ _ _ _ _ _ _ _ _ _ _ ___ c

e t i a. r AFFIDAVIT N , j ./ THE STATE OF TEXAS COUNTY OF DALLAS Before me, the undersigned authority, a Notary Public in and for, Dallas ~ County, Texas, on this day personally appeared ROBERT A. WOOLDRIDGE, who, after being by me first duly sworn, upon his oath stated that he is attorney for Applicants, is authorized to reply to CASE's Interrogatories Re: The MAC Report and Issues Raised. by the M'AC Report on behalf of'the Applicant, and further-stated that, to the extent the responses to these Interrogatories refer to state. ments made by others, he has relled upon such statements and the Affidavits attached to these answers, and that he has no reason to belleve that any of the statements are untrue and that insofar as the answers to Interrogatories refer to actions'taken by him personally, said answers are true and correct. f$h. n / A ~ ROBERT A. WOOLDRIDGE hl SUBSCRIBED AND SWORN TO before me by the said ROBERT A. WOOLDRIDGE on this, the MTM day of August,1985. V EM Ndtary Dubile in and for Dallas County, Texas My Commission Expires: rH-9A d 14. ,_______.L__ _... - _ _ -.. _ - - _. - _ _ _ ~.. -., _ _ - _, ...,_..,_-.--__m_e.

= UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t i n. l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-445-1 So 995 1 TEXAS UTILITIES ELECTRIC 30-445. COMPANY, ET AL. So ttL2 (Comanche Peak Steam Electric (Application for Station, Units 1 and 2) Operating Licenses) ?- CERTIFICATE OF SERVICE I hereby certify that copies of "Appilcants' Responses to CASE's Inter-rogatories Re: The Mac Report and Issues Raised by the MAC Report"in the above captioned matter were served upon the following persons by express mall (*) or by hand delivery (**) or by Federal Express (***) on the 12th day of August,1985. Mr. Peter B. Bloch, Esq., Chairman *** Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 D Dr. Kenneth A. McCollom*** , Administrative Judge Dean, Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74078 Ellysheth B. Johnson *** Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Wr.!ter H. Jordaa+'+ Administrative Judge 881 W. Outer Drive Oak Ridge, Tennessee' 37830 Mrs. Juanita Ellis* President, CASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks, Esq.**+ Assistant Attorney General i V Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 t- .- }.- --.-----

t Nicholas S. Reynolds, Esq." William A. Horin, Esq. Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W. ." N Suite 700 ' -). Washington, D.C. 20036 Mr. Michael D. Spence, President ++ Texas Utilities' Generating Company Skyway Tower 400 North Olive Street,'L.B. 81 ~ nm it... Texas 75201' Mr. Thomas G. Dignan, 3r." Mr. R. K. Gad, III ~- Ropes & Gray - ~ 225 Franklin Street Boston, Massachusetts 02110 -~.. Robert D. Martin ++ Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin+++ 3022 Porter Street, N.W., #304 Washington, D.C. 20008 f.. (hg g gg### 55;,,. Atomic Safety and Licensing Board Panel 'V M U.S. Nuclear Regulatery Commission Washington, D.C. 20555 Mr. William L. Clements+++ Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stuart A. Treby, Esq.* -Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman

  • Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commissiqn Washington, D.C. 20535 Ms. Ellen Ginsberg, Esq.++*

U.S. Nuclear Regulatory Commission 4350 East / West Highway,4th Floor Bethesda, Maryland 20814 Geary S. Mizuno, Esq.~ Office of Executive Legal Director J l U.S. Nuclear Re Maryla.d Natic.:gulatory Commission ! Bank Bldg., Room 10105 7~ 5 Oli Geern oven Road Bethead, Ma.yiand 2h14 .2

.~ Herbert Grossman, Alternate Chairman" ~ Administrative Judge Atomic Safety and 1.lcensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20535 Billie Pirnet Gardem Citizens Clinic Director Government Accountability Project 1901 Que Street, N.W. Washington, D.C. 20009 Anthony Roisman, Esq.* Executive Director Trial Lam ers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D.C. 20036 ~~ Joseph Gallo, Esq.= Isham, Lincoln & Beale 1120 Connecticut Ave., N.W. Suite 840 Washington, D.C. 20036 .O, ) / 9% ~ Robert A. Wooldridge p I si e O O e 3 a.,. ,_.,..,,,.__w.n.. ._,,,n_.

,f ~ CRESAP, MCColEECK AND PAGI"2 ,s ~ ~ Staff Involved In ..) Retrospective Audit Of CPSES Name Title Jeff Schmidt Vice President Bruce Pittanger Vice President Ian.Wass Vice President Garry Dietz_. Managing Cbnsultant - - 2 Ned Sickle _ Managing Consultant Greg Presely ' Managing Consultant Jim Sullivan Cbnsultant Steve Brauer Consultant Bob Cornick censultant '? Marshali David c:msultant John Dolan Qansultant Joel Elliott Qansultant Tem Fleming Consultant Andy Patterson Consultant Clay Press Consultant Bart Rocca Cbnsultant Bob Shields Cbnsultant . Tem Jackson Consultant G I I .s 4 .--9 .,m,--p,-y, -wr%.,m,. .,-m_ .,,-mm.gm--,,.e--e ew-

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t E AFFIDAVIT OF 3OHN W. BECK THE STATE OF TEXAS COUNTY OF DALLAS BEFORE 'ME, the undersigned authority, a' Notary Public in and for Dallas County, Texas, on this day personally appeared 3OHN W. BECK, who by me being - duly sworn upon his oath deposes and says: My name is John W. Beck. I am Vice President of Texas Utilities Generating Company, 2700 Skyway Tower, 400 N. Olive Street, Dallas, Texas 75201. I began my employment with TUCCO In the spring of 1984. Until contacted by Mr. Wooldridge on or about the 21st day of May,1985, ! D had no knowledge that Management Analysis Company ("MAC") had conducted a management review or audit of Comanche Peak Quality Assurance Program. I was not aware that MAC had written a report to TUGCO management until that time. W u.L L JOMNW. BECK SUBSCRIBED AND SWORN To before me by.the said 3OHN W. BECK on this, the day of .1985. / U Notary Public in and for Dallas County, Texas My Commission Expires: %cabA /> /Hf. e t ^A^E ^ gg6 2M Tg _ -.,-rapya'.

~......- O. AFFIDAVIT OF t, ~ ~ ..T CHARLES BIGGS M. THE STATE OF TEXAS COUNTY OF DALLAS BEFORE ME, t(e undersigned authority, a Notary Public in and for Dallas County, Texas, on this day personally appeared CHARLES BIGGS, who by me being - duly sworn upon his oath deposes and says My name is Charles Biggs. I am presently employed by Texas Utilities Generating Company and reside at 2309 Regal Road, Plano, Texa.s 75075. I do not recall having been Interviewed by Management Analysis Company ("MAC") in connection with any work they were doing at Comanche Peak in 1978. I may. have.but do not; think I was so Interviewed. I was transferred to Basic Resources Inc. In June,1979, and was not aware that MAC had issued a report.' I ~ 2- } l did not receive a copy of the report, have not read same, and have no knowledge of I any report in c.weiection with any request for discovery by Intervenors in the Comanche Peak IIcensing proceedings. I first found out about the MAC report with the recent publicity e=~ h ed t -.with the filing of the report with the Licensing Board. I am currently an Administrative Assistant at Texas Utilities Generating Company. I held this same position when I learned of the MAC report as well as on December 31,1984. f / ^ ' *p.~ _ 2 CHARLES BIGGS t..' / SUBSCRIBED AND SWORN TO befo me by the said CHARLES BIGGS on 0% . this, the 4-day of C ^ .1985. l ( b g

i 9 9. J. t ,~ Notary Pubuc in and for Dadas County, Texas My Commission Expires: %bda th RW. 7 e 0 0 0 0 e W G e e 8 e G I: p.- 9 9 9 e e 9 9 9 p' .Ds f O t ,,e w. e-w,--- w , = ~ ~ ' " ' ' ' ' ' " ' ' ' - " ' ' ' ' ' ' ~ ~ ' "

2 --- - i I t i AFFIDAVIT OF ' [lT ..} A.H.BOREN THE STATE OF TEXAS 8 COUNTY OF DALLAS BEFORE ME, the undersigned authority, a Notary Public in and for Dallas County, Texas, on this day personally appeared A. H. BOREN, who by me being duly sworn upon his oath deposes and says: My name is A. H. Beren. I am presently employed 'by Texas Utilities ~ Generating Company at Dallas, Texas. My residence address is 319 Harrington Drive, Duncanville, Texas 75116,. In 1978, I was Supervisor of the D=f t==-Vendor Compliance Group for TUGCO. ~ I do not recall having been Interviewed by Management Analysis Company ("MAC") C In connection with a review being performed by them of the Quality Assurance Program at Comanche Peak but I may have been. I do not recall when I first learned that MAC had Issued a report. It may have come to me from a newspaper article. I do not recall ever having received or read a ' copy of the report. I was Maintenance Services,QA Manager for 11gnite and ~ gas power plants for TUGCO on December 31,1984 and currently hold this same -position with TUGCO. While I was aware of requests for records having been made by the Intervenor in the Comanche Peak licensing proceedings, I was not Involved in the requests for information or the search for documents, was not aware of the existence of the MAC report in 1980, and did not participate in any discussions regarding whether the MAC report should be produced in response to the CASE discovery requests. .) h/d n-A n soggy ? - - - - - - ' - ' ~ ~ ~ ~ ~ ~

. q n ~ a w:=.a x*=u " a _. . w w.,.-- .s, SUBSCRIBED AND SWORN To before me by the said A. H: BOREN on this, the day of hCHWA ,1985. v ? Notary PuDlic in and for DaHas County, Texas My Ccmmission Expires: W Ib.19W. O e 9 0 e e e O se e = , ~, ..h e --e c. ,wn - + -, - - -

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AFFIDAVIT OF - ' ~ ~ ,e C. THOMAS BRANDT - 3 ~ ...):; THE STATE O M COUNTY OF BEFORE ME, the undersigned authority, a Notary Public in and for - M#I

County, M

, on this day personally appeared C. ~ THOMAS BRANDT, who by me being duly sworn upon his cath deposes and says: My name'is C. Thomas Brandt. I am employed by Ebasco Services, Inc. at the Comenche Peak Steam Electzic Station site near Glen Rese. Texas I came to won O the Comanche Peak site on September 10,1980. I first learned that Management Analysis Company ("MAC") had performed a review of the Quality Assurance Program for TUGCO at Comanche Peak and had written a report thereon sometime in the last week of May,1985. Prior to that time I had no knowledge of or participation in any MAC review or audit of the Quality Assurance Program at Comanche Peak and did not participate in any discussions regarding whether the MAC report should or l' shonid not have been produced in response to anypcov ry reque / C.TMiAS BRANDV SUBSCRIBED AND SWORN TO before me by the said C. THOMAS BRANDT on this, the /M d day of b/ .1985 AJ Notary Puilic in and for We#/ County, Texas My Commission 3xpires: ..si J0/jf//G ,., v p vr y s. -

c AFFIDAVIT OF t n PERRY G. BRu i AIN THE STATE OF. TEXAS COUNTY.OF DALLAS BEFORE ME, the undersigned authority, a Notary Public.In and for Dallas County, Texas, on this day personally appeared PERRY G. BRITTAIN, who by me being duly sworn upon his oath deposes and says: My name Is Perry G. Brittain. I am presently the Chairman and Chief Executive Officer of Texas Utilities Company at 2001 Bryan, Dallas, Texas 75201. I reside at 6806 Hyde Park Drive, Dallas, Texas 75231. My telephone number is ' 214/653-4623. In 1978, I was the President of Texas Utilities Generating Company and also held positions with Texas Utilities Company and other subsidiaries of Texas Utilities Company. On December 31, 1984, I was Chairman and Chief Executive officer of Texas Utilities Company and was also the Chairman and Chief I Executive Officer of several +MT-Ies of Texas Utilities Company but was not at that time an efficer of Texas Utilities Generating Company. In 1978, I authorized a study to be conducted by Management Analysis Company ("MAC"). I attended meetings with one or more representatives of MAC, both before and after they performed their review. In addition, Imet with R. J. Gary and L. F. FIkar after MAC performed its review to discuss with them the recommendations and findings made by MAC. I asked MAC to do an organizational review. I did not consider this to be an audit in the usual sense of that werd. I simply wented to obtain an outside perspective on the TUGCO management organization for the Comanche Peak l Steam Electric Station Project. It was never Intended that we would rely upon MAC's review to meet any NRC regulatory, requiremenp. I received a copy of the ~ -, -., m t~ n 'O3f 01J f'f %

report prepared by MAC as a result of their review and I die==d this report with .e s representatives of MAC and with Messrs. Gary and Fikar. After we reviewed the recommendations contained in the report, I had my copy of the report placed In the ines maintained by the President of TUGCO where, I assume, it remained untu sometime in late April or early May,1985 when it was found by personnel who were - searching for Information for a prudence audit being performed for Texas Utuities Electric Company. ~ ~~ ~ I believe that it was generally understood by both R.1 Gary and L. F. FIkar that the werk b<aing performed by MAC was solely for our use and benefit, to 1 enable the senior manage [nent of TUGCO to properly perform its managerial responsibility. The results of the MAC review were thus not publicized and it is my ~ understanding that the MAC report did not receive wide distribution among TUGCO employees at the site. I h_ ave not been an active pareI@=M In the gathering of data or Information 1 .c. In response to requesta for Information made by the Intervenor or others In tne, Comanche Peak Heensing proceedings. In 1980, I was not aware that CASE, the Intervenor in the proceedings, had requested Information from TUGCO as to evaluations, studies, and audits which had been conducted at Comanche Peak. I did not become aware of this request for Information until Mr. Wooldridge contacted i 1 me in late May,1985, to dia-this matter with me. Prior to that time, I had not participated in any di==lans with anyone regarding whether the report prepared by MAC should or should not be prd ced In response to any request for ~ Information in the IIcensing proceedings. g ^ PERRY jTa. BRITTAhN i l

=. 8 SUBSCiUBED AND SWORN TO before me by the said PERRi G. BRITTAIN on this, the 7th day of August 1985. -!? b 'f h w s ]x,) NvW Publicin and for Danaf County, Texas My Commission Expip May 9. 1989 e S e-e J ..sc? O e 85 e 9 m='.s 6 i ~,.

4.. --u._. e ..,g e --..1..._. ..-c 3 s. AFFIDAVIT OF N. DAVID N. CHAPMAN -Jl ~ i THE STATE OF TEXAS 's COUNTY OF DALLAS .BEFORE ME, she undersigned authority, a Notary Public In and for Dallas Countyi Texas, on this. day personally appeared DAVID N. CHAPMAN, who by me q being duly sworn upon his oath deposes and says: My name is David N. Cfhapman. I am presently employed by Texas Utilities Fuel Coinpany and office at 2001 Bryan Tower, Dallas, Texas,75201. i I reside at 627 Parkvlew, Richardson, Texas 75080. My office telephone number is 214/653-4642 and my home telephone number Is 214/238-7394. I first became aware of a report pre # by Management Analysis Company. a" _, ~-_" ("MAC") sometime In mid-1978. At that time, I was Manager, Quality Assurance, ~ for Texas Utilities Generating Company. I also had that position In 1980 and on, December 31,1984. On March I' 1985, I transferred from Nuclear QA Manager to Executive Assistant to the VIce President for TUGCO Gas Plant Operations In Dallas. On June 1,1985, I was transferred to Texas Utilities Fuel Company as Executive Assistant to the Executive Vice President. - = - - - ~ ~ ~ ~ ~ ~

  • ~

I M being Interviewed by a representative of MAC In connection with their review of the organization of TUGCO at Comanche Peak In 1978. I do not recall attending any formal meetings with representatives of MAC prior to the review but I did meet with John Jackson sometime prior to the review. I believe that I also attended a meeting with representatives of MAC after this review, but I am not sure of this. I was aware In 1978 that MAC had issued a written report, and D ' < :) I received a copy and read it shortly after it was sent to TUGCO in 1978. While I initially had a copy of the report, I no longer have one, and I do nbt recall what _n aon [ - - - ~ - - - - '-- ~ ' " ' ' ~ ~

p, happened to my copy or whether I even kept my copy after the review of 'he MAC t .- s report was completed. I aided in drafting a response to the recommendations and findings made in the MAC report. That response Is the same as the one bearing the signatures of R. 3. Gary and L. F.. FIkar addressed to P. G. Brittain and attached as a copy to Mr. R. A.Wooldridge's letter to the Licensing Board of May 29,1985. In 1980, I was aware that CASE, the Intervenor In the Comanche Peak 11 .siri proceedings, had requested a. substantial amount of Information from ~ TUGCO in connection with TUGCO's Quauty Assurance Program. I also hecan M'=!N of the MAC report in the context of the diss,vsf requests having taken place with Susan Sprw Palmer and Ron Tolson. k recall @'"Mg this matter with Mr. B. R. Clements, to whom I reported. It Is my recoHecien that Mr. Clements assumed the responsibility for TUGCO' Quality Assurance, as an officer of TUGCO, sometime shortly after CASE's request for Information was received by , g?.':ib ,_ TUGCO. Mr. Clements informed me that the decision had already been made by O.' one or more other rc44 s of TUGCO management that the MAC report was not - subject to the diss,vsf request. It is possible that I also discussed thisl matter ~ with John Marshall butI do not recall the specifics of any such conversation. While I do' not recall any specific conversations with anyone after the discovery and produedan of documents in 1980, It Is possible that the MAC report and its confidentiality was discussed again with B. R. Clements or Ron Tolson or Susan Spro.. Palmer. I do not recall any conversations regarding the dis- . coverabluty of the MIC report with L. F. FIkar, R. 3. Gary, or P. G. Brittain. In late AprH or early May,1985, I had a conversation with Andy Jones who - asked me about the MAC report in contiection with his effort to gather documents for the prudence audit being conducted for Texas Utilities Electric Company. I told him that before the report should be deHvered to the prudence auditor, the matter should be discussed with Mr. Clements. The next information I had concerning the MAC report was in a conversation which I had with Mr R A ~,, -,, -, - ,p., ,,,,,m-. ,,,,,,,,n--,,- ,,-,_,,-_,_,,.,,,w,,._,__,,_

6., Wooldridge, legal counser to the Te:.as Utilities _ Companies, sometime In mid-May, 3, 1985. /~ ' ' $/ MHA 1 1 A AAA M _ " DAVE R.' CHAPMAN ~ ' SUBSCRIBED AND SWORN TO before me by the said DAVID N. CHAPMAN,,~ on this, the 3kk day of b\\AGALST ,1985. ~ NW Public in and for Dallas County, Texas My Commission Expires: 9-\\*69 O e

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AFPIDAVIT OF B. R. CLEMENTS THE STATE OF TEXAS ~ \\ COUNTY OF TARRANT : BEFORE ME, the undersigned authority, a Notary Public in and for Tarrant County, Texas, on this day psw lly appeared B. R. (" 8'MENTS, who by me!being duly sworn upon~his oath deposes and says: ~ My name is. B. R. Clements. I am presently employed by Texas Electric Service. Company as a Vice President. My business address is P. O. Box 970, Fort Worth, Texas. My office number is 817/429-jP589. At the time I first learned of a report having been prepared by Management Analysis Company ("MAC") In w Mon with a review of TUGCO management at the Comanche Peak Steam Electric Station, I was a.VIce President of Texas Utilities Generating Company. I ~ # ~ had the same title on December 31,1984. I transferred to Texas Electric Service .I C6mpany on June 11,1985. I did not participate in the MAC management review at the Comanche Peak plant in 1978. I was not Interviewed by MAC representatives at that time and l attended no pre-or post-audit meetings with representatives of MAC. I never had in my pa-iari a copy of the MAC report untilI received a copy with Mr. R. A. Wooldridge's letter to the I.lcansing Board of May 29, 1985. I had not read all or any p'ortion of the report prior to that time. I did not participate in any management discussiors regarding the MAC report or its findings or recom-mendations at any time in 1978. In 1980, when I assumed the responsibility for the Quality Assurance Program i ) at Comanche Peak,' which I believe was sometime in August of 1980, I became generally aware that CASE, the Intervenor in the Comanche Peak licensing .-,,oan , _.,, -, -, - - -, - ~ ~ ~ ~ - - ~ ~ ' ' ' ' ' ~ ~ ~ ' ' - " ^ ^ ~ ~ ~

O e .s. proceedings, had requested inictmation from TUGCO concerning the Quality s Assurance Program. While I was generally aware of the review performed by MAC in 1978, I did not have and had never seen a copy of the MAC report at that time. I recall that the subject of the possible discoverability of the MAC report was discussed after Ibecame.w.sible for the QA Program. It was my urA. r4 ~ that the decision had already been made by TUGCO management that the MAC report was not within the scope of CASES request for Information. I was notItald who, yh"y, made the decision. I do not recall who told me of this previous-' ~ ~ decision but'believe it was Mr. Dave N. Chapman. 'I recall being told that the reason given for not submitting the MAC report was that it was an Informal review of the Comanche Peak Steam Electric Station Project and was used only as a management tool and therefere was not subject to discovery. Since I was not familiar with the details surrounding the hiring of MAC to perform 'the work in 1978 and did not participate in the MAC review itself and had never read the MAC ~ _.9 -d l report, and since the decision had already been made by an officer or officers senior to me in the TUGCO organization, it did not seem appropriate to me at that time to revisit the mattair with those to whom I M M I had no conversations fI with Messrs. Flkar, Gary, or Brittain s.wr.ing the discoverability of the MAC report in connection with CASES request for Information. v p R.CLEMENTS SUBSCRIEED AND S'FORN To before me by the said B. R. CLEMENTS on this, the STM day of Su.Gws? , 1985. CLu OM Notary INolic in and for Dallas j County, Texas My Cornmission Exp, ires: t. 9-\\.3Cg

.i i ,s, P e., .f AFFIDAVIT OF WILLIAM G. COUNSIL THE STATE OF TEXAS COUNTY OF DALLAS .,, BEFORE ME, the undersigned authority,'a Notary PubIle'In and for-Dallas County, Texas, on this day personally appeared WILLIAM G. COUNSIL, who by me being duly sworn upon his oath deposes and says: My name is William G. Couns11. I am Executive Vice President of Texas Utilities Generating Company, 2500 Skyway Tower, 400 N. Oilve Street, Dallas, Texas 75201. I began my employment with TUGCO effective May 1,1985. Q _ Until contacted by Mr. Wooldridge on or about the 21st day of May,1985, I \\. :. v' had. no knowledge that Management Analysis Company ("MAC") had conducted a management review or audit of Comanche Peak Quality Anurance Program. I was not aware that MAC had written a report to TUGCO management until that time. i ~ k!N&f WILLIAM G. COUNSIL LDSCRIBED AND SWORN To before me by the said WILLIAM G. COUNSIL l on this, the day of ,1985. 1 G.4 o (fotary Puolic in ena for Dallas County, Texas l My Commission Expires: Th eP9 J l / / l I g QCrd> lost I n d r 'V~'f

= - - - - - - - - - - - - s-c.. AFFIDAVIT OF .?) U.D. DOUGLAS THE STATE OF A abama COUNTY OF Monteomerv BEFORE ME, the undersigned authority, a Notary Public In and for MontgomeryCounty, Alabama, on this day personally appeared U. D. DOUGLAS, who by me being duly sworn upon his oath deposes and says: My name is U. D. Douglas. I am presently employed by Blount International, Limited in Montgomery, Alabama. My telephone number Is 205/277-8360. I recall being Interviewed by Management Analysis Company ("MAC") In connection with their management quality assurance review of Comanche Peak In ,.]) 1978. ' At the time of the MAC review In 1973, my position at Comanche Peak was x. Construction Project Manager for Brown de Root. I knew that MAC had Issued a report, received a copy of the report, and read it. I dId not take a copy with me when Ileft the project. I left the Comanche Peak Project in November of 1979. I was not aware that in July,1980, a request for discovery was made by the Intervenor, CASE, of evaluations, studles, or audits that had been conducted at Comanche Peak and I did not participate in any efiv-~l~ts regarding whether or not the MAC report should i be produced in response to CASE's discovery request. U.D.HOUGLAS[ ~ m y,,,. w

e .s, SUBSCRIBED AND SWORN TO before me by the said 17. D. DOUGLAS on this, the day of ba_,f. , 1935. U 4)YL Nota &y Puolic in and for ynnwrw County, Alabama. / / My Commission Expires: Tuli / dl /9fr ~ ~ i s e e e O ee S 9 9 e e O 6 7 4 '*e.

.~. _ - ^ - ~ i s, AFFIDAVIT OF T ~ ~ ~ - LOUIS F. FIKAR THE STATE OF TEXA5 COUNTY OF DALLAS BEFORE ME, the undersigned authority, ~a Notary Public in and for Dallas County, Texas, on this day p sw. ally appeared LOUIS F. FIKAR, who by me being ~ ~ duly sworn upon his oath deposes and says: ~ My name is Louis F. FIkar. I reside in Fort Worth, Tarrant County, Texas. I retired from Texas Utilities _ Generating Company effective July 1,1985. At the time of my retirement, I was Executive Vice President of the C$mpany. I held that position since 1978. In 1978, Management Analysis Company ("MAC") reviewed the Quality 'h '~.sy ,,, Assurance Program and other aspects of the TUGCO organization at the Cotnanche Peak Steam Electric Station. This review was requested by Perry G. Brittain, the then President of TUCCO. I attended both pre-and post-audit meetings with representatives of MAC and was Interviewed by MAC representatives In wisdon i with their review. Sometime in May of 1978, I received a copy of the report prepared by MAC In wi&Gon with their work at Comanche Peak which I thoroughly reviewed at that time. I also recall meeting with Messrs. P. G. Brittain and R. 3. Gary to discuss the recommendations and findings which resulted from the MAC review. I retained a copy of the report In my office and gave my copy to R. A. Wooldridge sometime in late May or early June,1985. In 1980, I was aware that CASE, the Intervenor in the Comanche Peak licensing proceedings, requested Information concerning QA sudits at Comanche Peak. In the process of respcnding to those requests, I recall a question being l e - - " - - - ' - - - - - ' ~ - ~ ~ ' ' ~ '

1 ? Y. l 'si f," raised as to whether or not the discovery applied to the MAC repcrt. It was my opinion that it did not and I so stated. I do not recall any further dir='an or question about this matter at the time, nor do I recall any d'==8ons with any l amr.ey or other Company officer about this matter. I did not believe that the MAC report was subject to CASP.'s dh' i requests because it was not then and, to my Imowledge, never had been a part of the Comanche Peak plant records. It was pdhmed solely for the use of senior TUGCO management for its purpose In assessing the TUGCO program for carrying ~ out its commitments. It was not an audit in the usual sense of that word and l certainly did not constitute the type of an audit that would be useful In' satisfying NRC requirements to audit a quality assurance program..From a corporate standpoint, confidentiality of the results of the review had, to. my Imowledge, been maintained since the. report was delivered in 1973. I recall d_Lv=8m in 197& with P. G. Brittain and IN 1 Gary to the effect that the results of the report should not. be published or made available generally to employees at the Comanche Peak site or elsewhere. The three of us were generally aware of the possibility that the performance of the review might be taken as an Indication that management was critical of the existing TUGCO organization at Comanche Peak. This was not the J... . __J:ase_and distribution was restricted to only those persons who needed to have the report in order for us to properly assess MACS recommendations and findings. In my judgment, I felt the MAC report was a proprietary document made solely for the benefit of the senior management of TUGCO and, therefore, was confidential and not to be a public document. 5* ca the results of the MAC report were m generally favorable to the TUGCO organization and the QA program at Comanche Peak and a number of MACS recommendations had already been or were being implemented, the findings in the MAC report itself had nothing to do with my beilef that the report should not be produced in response to the requests for v information. ) A

...... ~.. _.... i i c, I do not recall any discussions concerning the discoverability of the MAC- ' j) 1 s report again 'until a conversation that I had with R. A. Wooldridge sometime in mid-May,1985. j \\ AM 7 ~ LOUIS F. FIKAR l SUB5CRIBED AND SWORN To before me by the said LOUIS F. FIKAR on i this, the 9TM day of b4. GEST . 1985. t i. M Notary Suolic in anc fo.r Dallas County, Texas My Commission Expires: 9-1-%ct g v. e e 4 e S e S w' e ah a mee m em m e -ww="v^" ' ~ ' ' ' *"

I AFFIDAVIT OF 1 DOUG FRANKUM. THE STATE OF TEXA3 COUNTY OF 3* M * *V5W BEFORE ME, the undersigned authority, a Notary Public In and for somem:4 County, Texas, on this day personally appeared DOUG FRANKUM, who by me being duly sworn upon his oath deposes and says: My name is Doug Frankum. I am employed by Brown & Root, Inc..at the Comanche Peak Steam Electric Station site near Glen Rose, Texas. My present position is Senior Project Manager. I held this same position on December 31, ., 4 I was aware generally that Manageinent Analysis Company ("MAC") was on the Comanche Peak site sometime in 1978 doing a review of TUGCO's Quality Assurance Program. I have been at the Comanche Peak site since 1977 and have never seen a copy of the MAC report as of this date. I did not receive a copy of the report nor have I read same. Furthermore, while I had been generally aware' l that the Intervenor, CASE, in the Ilcensing proceeding has requested a lot of i documents, I was not aware of the specific documents they requested, did,not know that they had made a request which would have included a report by MAC, and I did not participate in any discussions regarding whether the MAC report should be ' produced In response to the CASE discovery requests. ho -- w/ DOUG FRANKUM / i 1 ->sj d amm thJ fr-fI? W ~ ' ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ' ' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ' ~~ ~

s SUBSCRIBED AND SWORN To before me by the said DOUG FRANKUM on X, - this, the la 1 day of AvauJr .1985. 'u V!l A.- Mtary PuDli()n and foWLw,w County, Texas My Commission Expires: Mw 19 19 9 9 9 90 e O e O 9 e O 5 9 0 e b. 8 9 O .h g a m

y-I s '., AFFIDAVIT OF R. J. GARY THE STATE OF TEXAS COUNTY OF DALLAS _ BEFORE ME, the undersigned authority and notary pubHc in and for DaHas County, Texas,.oo this day pebnally appeared R. 3. GARY, who by me being duly sworn upon his oath deposes and says: My name is R. 3. Gary. I am presently employed by Texas Utilities Generating Company as Executive Vice President and office in the Skyway Tower, 400 N. Olive Street, Dallas, Texas 75201. I reside at 2706 Ripplewood, Dallas, Texas 7I228. My telephone numbers are 214/979-8858 and 214/327-1184. In 1978 and in 1980, I was Executive Vice President and General 54anager for TUGCO. On C' December 31,1984, I was Executive Vice President of TUGCO. I was aware in 1978 that Management Analysis Company ("MAC") performed a review of the Quality Assurance Program for TUGCO at Comanche Peak Steam Electric Station. I attended both post-and pre-audit meetings with representatives of MAC. I was Interviewed by a MAC representative in connection with their review. I received a copy of the report prepared by MAC in connection with their i management review sometime in May of 1978. I read the report at that time. , With the assistance of Dave Chapman, a response to the recommendations contained in the MAC report was prepared and provided to the then President of TUGCO, P. G. Brittain. I did not retain a copy of the report as it had served its purpose and discarded my copy sometime in 1975, within a couple of months following when it was first received by me. .w %_.) The review performed by MAC in 1978 was done so at the request of Mr. Brittain. it.was not considered an " audit"In the normal sense of that word but was t- ~ o

i rather an organizational review, for the_use pf senior TUGCO management which s ')~ Included Mr. Brittain, Mr. Fikar, and myself. It was never intended that MAC's review would be used us satisfy any QA audit obilgations which might be required by NRC regulations and the report was never intended to become a part of the permanent plant records for Comanche Peak. At the time It was performed, Mr. ~ Brittain, Mr. Fikar, and myself were all concerned about the possibility that the-purpose for. the MAC review might be misintwpsted by plant employees as Indicatirig that senior management was critical of past performance and this was ,not the case and for that reason, neither the findings nor the report were publicized and the information regarding the results of MAC's review was made available only to a very few who needed to have such information in. order to respond to the findings and to implement the recommendations which we concurred with. While I,,was ~ generally aware that CASE, the Intervenor In the Comanche Peak licensing proceedings,.had requested a substantial am.ount of Information from TUGCO in 1980, I did not participate in the gathering of data or Information In response to those requests as that was the responsibility of the licensing group which was not under my direction. I did not have a copy of the MAC report at such tims and I did not participate in any discussions with anyone in 1980, or thereafter, concerning whether or not Information relating to the MAC review should or should not be made available in response to discovery requests. After I responded to Mr. Brittain on the results of our review of MAC's recommendations, In 1978, I recall no further dLessions about the MAC report until I was contacted by Mr. Wooldridge in mid-May of 1985, shortly after a copy of the report was apparently located by those gathering information for the Texas Utilhles Electric Company's prudence audit. A/w R. 3.IARY [ -J

\\ i 0, 1, SUBSCRIBED AND SWORN To before me by~ the said R. 3. GARY on this, ^ the 7th day of August .1985. ---J>. \\ Notary Public in and for Dallas. ~ County, Texas ~ ptmeA saisON, Notary rw-My Commission Expires: k and for Danes co,untyg, - E3Dunmissha *. _ ~ ~ February 17, 1989 ~ - - - ' ' e e O t e .. ?.h; b ,o - c O e e G e 9 O e me e 'N / I. 1 i -n .,,,m

= .. = .= g.. =. = p, AFFIDAVIT OF v..Y - 30E B. GEORGE THE STATE OF TEXAS COUNTY OF' DALLAS BEFORE ME, the undersigned authority, a Notary Public in and for Dallas County, Texas, on this day personally appeared 3OE B. GEORGE, who by me being duly sworn upon his oath @s and says: My name is Joe B. George. I am presently VIce President and Project General Manager of Engineering and Construction of the Comanche Peak Steam Electric Station Project for Texas Utilities Generating Company. My address is P. O< Box 1002, Glen Rose, Texas 76043 and I reside at 129 Comanche Vista, DeCordova Bend Estates, Granbury, Texas 76048. My telephone numbers are \\,.. 817/897-4367 and 8.17/326-4154. I am aware that Management Analysis Company ("MAC") reviewed the Quality Assurance Program of TUGCO at Comanche Peak in 1978. I may have been interviewed by MAC but I do not recall the details of such interview. While It is possible that I did, I do not recall ever receiving a copy of the report or reading same until a copy of the report was sent to the Atomic Safety and Licensing Board by Mr. Wooldridge In late May,1985. It was my impression that the MAC review was for the benefit of the top management of TUGCO and I was not aware of any formal submittil being made or any response being required thereto. I ma'y have attended a pre-audit meeting with representatives of MAC but I do not recall any of the details of such meeting. I do recall attending a meeting to discuss questions . raised by MAC which related to the storing of stainless steel pipe. l Regarding CASE's discovery request in July of 1980, I was generally aware that the Interveno'r had asked for a substantial amount of information. As stated i s u _w .-..-. 7 ~~ ~ ~ '~ ~ ~

o O, previously, I did not recall the existence of any report. I do' bot recall any discussions concerning the study performed by MAC in connection with the response to any discovery requests. 77 8 h /r / pave B. GEOKGE SUBSCRIBED AND SWORN To before me by the said 30E B. GEORGE.on this, the TH day of b O G u.S T 1985. A EW Notary P6 bile in and for Dallas County, Texas My' Commission Expires: i n-\\ -3 8 N@) I s e e e e e e e 4-e - v;j' I s 8 4

i t. ..} AFFIDAVIT OF E. G. GIBSON, 3R. j THE STATE OF TEXAS COUNTY OF DALLAS BEFORE ME, the undersigned authority and notary pubIlc In and for Dallas County, Texas, on this day personally appeared & G. GIBSON, OR., who by me being duly sworn upon his oath deposes and says: My name is E. G. Gibson, Jr. I am presently employed by Impell Pacific as Manager' of Projec:s. My business telephone number is 503/243-5100. I held this same position as of December 31,1984. I currently live at 349 Mt. Washington, Clayton, California 94517. g,E,. 2:. I recall.being Interviewed by a representative of Management Analysis ~ ' Company ("MAC") In' 1978 regarding some: work that MAC was performing at Comanche Peak. The y lasted about twenty or thirty minutes. I am not b aware that MAC issued a report in connection with their review. I did not receive a copy of the report and have not read the report. I did not attend any pre-or post-audit meetings with MAC. I was not aware that In July of 1980, ' CASE requested disswy of evaluations, studies, and audits at Comanche Peak and I did not participate in any d1== tons regarding whether or not any report prepared by MAC should be produced in response to such discovery requests.

a. G. GIBSON, JR.. _6W RA a

lD T l

~~ - SUBSCRIBED.AND SWORN To before me by the said E. G. GIBSON,3R. on this, the [N day of fl.Q , 1935, o ~ j 5 Notary Puolic in and for DaBas County, Texas My Commission Expires: ~ [ M /h,/fPt. a I s g [I. l l c.*> .D ~ l

~ AFFIDAVIT OF

3. V. HAWKINS THE STATE OF COUNTY OF dde$r# -

BEFORE ME, the undersigned authority, a Notary Public in and for ..c 5/M County,1111nols, on this day personally appeared 3. V. HAWKINS, who. by me being duly sworn upon his oath deposes and says: My name is 3.--V. Hawkins. I am presently employed by Power Systems Incorporated and I reside at Route 1, Box 195, Clinton, Illinois 61727. My . telephone number is 217/935-6155. I. worked at the Comanche Peak Steam Electric Station construction site O. . from January of 1975. to October of 1981, as a Gibbs & M111 employee and was - ~{.'s Gibbs & Hills' site QA Sepervisor. I recall that Management. Analysis Company ("MAC") reviewed the TUGCO Quality Assurance Program at Comanche Peak in 1978. I recall having an interview with MAC representatives. I was aware that MAC had issued a report and received a copy at that time. I do not recall what happened to the copy I read. 'I was not aware that in July of 1980, CASE, the Intervenor in the Comanche ~ l - -PeaY licensing proceeding, had made a request for discovery of evaluations, studies, and audits that had been conducted at Comanche Peak. No one, to my recollection, inquired of me concerning this matter. I do not recall anyone asking me either directly or Indirectly any questions cencerning the MAC report as it ~ l related to any discovery requests in the licensing proceedings. I was not generally involved in those types of decisions and I did not participate in any discussions regarding wh.ethec the MAC report should be produced. I do not recall attending any pre-or postgudit meetings with MAC representatives.-

="- - " " ~ " " Amt a. J. V. HAWKINS SUBSCRIBED AND SWORN To before me by the said J. V. HAWKINS on this, 1 -hm11db .1985. Y day of ~~~ ~ ~ ~ ~ the + VAs4 M O - ~ _ - - Notary Public in and for 4 >zehW County, Illinois My Commission Expires: qfpy y i // / G, t..,v..t 4 D' l C l O q v ' ! vy i e~vw ---m-- rr ,,,--,,-,---,,-_m,m-e,, ,,m ,,,a _.,-.n -,-,--,_--y ,.g -<e---, - - - -

. - - - - - - ~ - AFFIDAVIT OF ~ I y 3OHN S. MARSHALL THE STATE OF TEXAS COUNTY OF DALLAS BEFORE ME, the undersigned authority, a Notary Pubile In and for Dallar County, Texas, on this day personally appeared 3OHN, S. MARSHALL, who by me being duly sworn upon his oath deposes and says: My name is John S. Marshall. I am Licensing Supervisor for Texas Utilities Generating Company and office In Dallas, Texas in the Skyway Tower offices of TUGCO. I have been Licensing Supervisor since April 1,1980. I first became aware of a report prepared by Management Analysis Company .3.(1 ("MAC") when its existence was brought to my attention In 1980. In July of 1980, .W CASE, the Intervenor in the Comanche Peak IIcensing proceedings, sent TUGCO a request for information. My duties at that time included the collection of information from the various segments of the TUGCO nuclear organfration to be able to respond. to the discovery requests. Sometime after the request for information was received, I recall either Dave Chapman or Susan Spencer Palmer mentioning to me that MAC had done some review work for TUGCO at some ear 11er time and that MAC's report on those. activities should be considered In determining.what documents should be produced In response to the request. I brought this matter to the attention of my management, which at that time would have been either Homer Schmidt or Lou Fikar. I do not recall which of the two I ~ mentioned the matter to Initially Prior to the time we responded to the request for information, I recall that the question of the discoverability of the MAC report .S) was mentioned again by either Dave Chapman or Susan Spencer Palmer. I asked ' Lou F[Fikar, the TUdCO officer who was responsible for the Licensing of eA es.f r-W > 1 o - y w y ve 7vm

ygg y -, - =**- Comanche Peak, about the MAC report and whether it should.be produced in response to C,ASE's request for Information. ' Mr. Fikar told me that the MAC review was not within the seope of CASE's request for information and should not be included in the documents which were to be made available for CASE's review. Since at that time I had not read the report and did not have a copy of it, and was not familiar with the circumstances surrounding the MAC review in 1978 nor .. employed by TUGCO at that time, I had no basis to disagree with Mr. Fikar's opinion about the matter. I do not recall the MAC report, or any question regarding its discoverability, being mentioned again until I discussed this matter with Mr. Wooldridge sometime late in May of 1985. .. ' ' ~ CHN 5. MARSHALL SUBSCRIBED AND SWORN.TO before me by the said JOHN 5. MARSHALL ~ ~ Z on this, the . day of M .198.5. /Jk' Notary Public in and for Dallas County, Texas My Commission Expires Youndo /b;MW 2.g 't. l w 8 ..--,,-,,------..,--,---a,_--.--.,.,,.n.--..,- -,-,n-.--., a --r -,,. - - - ~

t 1 .x AFFIDAVIT OF 3OHN T. MERRITT,3R. THE STATE OF TEXAS COUNTY OF DALLAS i I BEFORE ME, the undersigned authority, a Notary Public In and for Dadas County, Texas, on this day p-411y appeared 3OHN T. MERRITT, 3R., who by ' me being duly sworn upon his oath deposes and says: My name is John T. Merritt, Jr. I am employed by Texas Utilities Generating Company as the Assistant Project General Manager at the Comanche Peak Steam Electric Station, P. O. Box 1002, Glen Rose, Texas 76043. My present business telephone number is 817/897-2722. I was the Assistant Project General Manager

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..e for TUGCO on December 31,1984. In 1980, I was Manager of Engis.; -bg and Construction for Texas Utilities Services Inc. at the Comanche Peak Project site. In 1978, I was aware that Management Analysis Compank ("MAC") reviewed i TUGCO's Quality Assurance Program at Comanche Peak. Although I do not speciffany remember an Interview, I am aware that my name appears In the i report as having been Interviewed and I do not deny that such Interview took place. I was not aware that MAC had Issued a written report to TUCCO management in whrch it' described the results of its review until I first saw the report in late May, 1985. Prior to that time, I never had in my ;-:=:===!on a copy of the repert. I do not recall attending any pre-or post-audit meetings with representatives of MAC in connection with their review. I recall a meeting in 1973 to discuss MAC's recommendations and TUGCO's responses thereto but, again, I was not aware that N e) there was any written report to TUGCO m'anagement. yJ Mm ms** I

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A a o i i r a, Prior to -May 29,1985, I was not aware that CASE, the htervenor in the Comanche Peak licensing proceedings, had in July of 1980 requested information i - from TUGCO as to all " evaluations, studles, or audits" which have been conducted at Comanche Peak. ) ~.- T.unne,i 4, gg.r J I V SUBSCRIBED AND SWORN To before me by the said 3OHN T. MERRITT,- 3R. on this, the kTh day of b4G 42T ,1985. -w, Notary Puouc m anc for DaMas County, Texas My Commission Expires: p$@ R ~\\-QQ 1 4 .a t e e 0 e e 1 - 3., l t L e e

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1 j >8 0, AFFIDAVIT _OF -- - - r, T f -) B. 3. MURRAY THE STATE OF TEXAS COUNTY OF DALLAS BEFORE ME, the undersigned authority, a N4.y PubHc in and for Dallas - County, Texas, on this day. personally appeared B. 3. MURRAY, who by me being duly sworn upon his oath deposes and sayst My name is B. 3. Murray. I currently work In Construction Management Services for oil, gas, and fossil plants for Texas Utilities Generating Company In' Dallab. Texas. I have not beenelnvolved at the Comanche Peak Steam Electric Station since August or September,1984. 'For about three and one-half years prior , c, to leaving Comanche Peak, I was Construction Manager at Comanche Peak and - Ef~

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prior to that was. Manager of Engineering in the area of pipe and electrical supports. I have no recollection of having been Interviewed by Management Analysis Company ("MAC") in 1975 In connection with their management quality assurance review of Comanche Peak. I do not have a copy of the report prepared by MAC In connection with this review and have never had a copy of same nor have I ever read ' the report. While I was generally famillar that in 1980 CASE, the Intervenor in the licensing proceedings, was on the Comanche Peak site reviewing documents, I did not participate in the collection of documents and did not know what was being e requested. I did not participate in any discussions regarding wnether the MAC report should be produced in response to CASE's discovery requests., 4 W.JJRORRAY' n _,m. gaoymr

_ _ -.. ~..._.. .. n o i t . w. SUBSCRIBED AND SWORN TO sefore me by the said B. 3/MURRAY on this, Y ' day of 01LGUh ..Liss. the \\ U ) r } = - - NW Pubuc m and for Dadas ~ '. ~ County, Texas My Commission Expires: ~ [d /S, /WI-g = t ) 9 e ee m a e 0 t I s e 4 I . _ _. _, _,.. _.,,. _,, - _., - -. -.... -, - - - -,...,... ~,, - - -. - _,.., -_,,.,.-_._.,-,.--,_~,,_,,y..,__.,__. v.-.m.,.-

= 8 t s t AFFIDAVIT OF ,i SUSAN SPENCER PALMER ~ THE STATE OF TEXAS COUNTY OF DALLAS BEFORE ME, the undersigned authority, a Notary Public In and for Dabas ' County, Texas, on this day personally appeared SUSAN, SPENCER PALMER, who by me being duly sworn upon her oath rhy=== and says: 1 My name is Susan Spencer Palmer. I am employed by Texas Utilities ' Generating Compahy as a Senior QA Auditor. I office at 400 N. Olive Street, ~ Dallas, Texas 75201 and live C 2955 Tumbleweed Trall, Grapevine, Texas 76051. My office telephone number Is 214/979,-8861 and my home telephone number is Q 817/488-8247. I have been an employee of TUGCO since January of 1979 and was originally hired as an Associate QA Auditor. At the time I first learned about a report having been prepared by Management Analysis Company ("MAC") In connection with a management review of the TUGCO organization at Comanche i Peak Steam Electric Station was in 1979 or 1980. I was a Senior QA Auditor Supervisbr, QA Administration for TUGCO on December 31,1984. Sometime in 1979 or 1980 I became aware that, prior to that time, MAC had ...~. reviewed the TUGCO organization, including the QA organization, at Comanche Peak. I had not seen a copy of the MAC report, and never had a copy in my possession or subject to my control, until I received a copy of Mr. R. A. Wooldridge's letter to the Licensing Board of May 29, 1985. I did not read the report until sometime thereafter. I first became aware of the MAC review through casual conversation with Dave Chapman, and possibly others, in 1979 or 1980. .\\ In .[j 1980 I assisted in gather'Irig Information to respond to the request for information i l l made by CASE, the Intervenor.In the Comanche Peak licensing proceedinEs.At i ~T5

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s e f that time, I recall having heard about the work which had been hormed by MAC and I asked Dave Chapman about the MAC report and whether it was subject to the , g, discovery request. Mr. Chapman told me that a decision had been made and that the report would not be supplied in response to the interroghtcr'y. It is my urA.A that that decision was made by one or more members of TUCCO ~ management but no name or names ~of the person or persons who made the decision was mentioned. I recall that I also mentioned the MAh, report to John Marshall but I do not recall any spelfic response which he made about the matter. Since I was' ~ not even employed by TUGCO when the MAC review was performed and the report ~ was written, was not aware of the circumstances surrounding the d@ian to have. the review performed and had never seen nor read the report, I did not feel that I was in a position to second guess decisions made by my superiors. While I do not recall any specific conversations, It is possible that the matter of the MAC report jg and its diswi in 1980 was also dLv'---d with Ron Tolson or others in the j TUGCO QA organization at the timer. l -$tw $W_'e 5USAN SPFNCER PALMER SUBSCRIBED AND SWORN TO before me by the said SUSAN SPENCER PALMER on this, the day of .1985. _M Notary Pubile in and for Dallas County, Texas SLENDA BENScN. Notary Puade My Commission Expires: to and for carras countyggs, Mg e2nwen y gmig.a % 0 29 .~ 3 e

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AFFIDAVIT OF

s GORDON PURDY i'

THE STATE OF dy45 COUNTY OF Snsonn i n BEFORE ME, the undersigned authority, a Notary Public in and 'for - Moon County, Texas, on this day personally appeared GORDON PURDYrwho a by me being duly sworn upon his oath deposes and says: My name is Gordon Purdy. I am presently employed with Comanche Peak Steam Electric Station near Glen Rose, Texas as a contract employee for Brown & Root. I was In Spain in the U.S. Navt in 1978. I was not employed at the Comanche Peak site In 1980. I have no knowledge of a review performed by _ Management Analysis Company ("MAC") of the Quality Assurance Program at

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,l Comanche Peak in 1978. I was not aware that MAC lasued a report until May, 1985, and had not received a copy of such report prior to that time ' or had I read n same. I did not participate in any dLv='ans regardIng whether the MAC report should be pr%'M in response to the discovery request by the Intervenor, CASE, in j the Comanche Peak 11 censing prMAg. ] I first became aware of the MAC report when it was mentioned in a management meeting conducted by Mr.1 Merritt at the Comanche Peak Steam Electric Station site sometime In May of 1985. At that time, I was Site QA Manager for Brown & Root. This Is the same position I have held since November 4 of 1981. I held this position as of December 31,1984. .J 3a. 2, g ..a GORDON PURDY D pdI I ,g ww7vywf~ s.....-.---. -

i g% i 0 I + t SUBSCRIBED AND SWORN To before me by the said GoltDON PURDY on 2.;;.:.y this, the /N day of hwn ' $ , 1985. ~~ r i lL NI.ry Pungd in and for h/_s County, fans My Comrnission Expires: /ofgr//4 O O 9 G 'i ;/ eo m m* ) ) .v s n )

= -* ~ AFFIDAVIT OF ~ HOMER C. SCHMIDT ..;) THE STATE OF TEXA5 COUNTY OF DALLAS B, EFORE ME, the_ undersigned authorit'y, a Notary Public in and for Dallas - ~ County, Texas, on this day personally appeared HOMER C. SCHMIDT, who by me being duly sworn upon his oath deposes and mys ~ l My.name is Homer C. Schmidt. I am Manager of Nuclear Services for Texas Utilities Generating Company at 400 N. Olive Street, Dallas, Texas 75201. My telephone number is 214/979-8234. On or about May 9,1985, I first became aware that Management Analysis Cornpany.("MAC") had performed a review or audit of the Quality Assurance [@.' + . Program for TUGCO at Comanche Peak Steam Electric Station. Prior to that tinie, I never had in my p-lon a copy of such report and had not read ame. I was not Interviewed by MAC in 1978 and did not attend any pre-or post-audit meetings. The MAC report came to my attention through a review of Quality Assurance documents for the ongoing prudency audit being conducted for Texas Utilities Electric Company. As Manager of Nuclear Services with the responsibility for 11cansing, In 1980, I was generally aware of discovery requests from the Intervenor In the licensing proceedin5s. 'I was also aware that on or about July 7,1980, CASE requested Information from TUGCO as to evaluations, studies, and audits which had been conducted at Comanche Peak. At the time of such discovery requests and at all times up until on or about the 9th day of' May,1985, I was not aware of the existence of the MAC report a.td I have not participated in any discussions nAA Q. ag e. m 7,y r - l l.. - ~ ' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

. ~. - - regarding whether the MAC report should be produced in r'esponse ~to CASE's request for information. My position has been Manager of Nuclear Services. I was employed in such capacity for TUSI1n 1980 and for TUGCO on December 31,1984. In addition, I have read the answers to Question 1, and all subparts thereof, of-CASE's Interrogatories in connection with the MAC report and such answers are true and correct. "~ ~ 36 MOMER C. SCMMIDT SUBSCRIBED AND SWORN To before me by the said HOMER C. SCHMIDT on this, the day of b ,1985. a 4))$. (g NW Pubuc in and for Canas ' ~ ~ County, Texas My Commission Expires: M aua A /3,/9fr. i e a e e M eee O %e,

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\\, 8 AFFIDAVIT OF ) B. C. SCOTT THE STATE OF TEXA5 COUNTY OF DALLAS BEFORE ME, the ' undersigned authority, a Swf Pubile In and for Da$as ~ ~ ~ County, Texas, on this day personally appeared B. C.. SCOTT, who by me being ~ duly sworn upon his oath deposes and says: My name is B. C. Scott. I am presently employed by-Texas Utilities Generating Company in Dallas, Texas. My residence address is M01 Michelle Drive, Arilngton, Texas 76016. In 1978, I was Site QA Manager for Brown de Root and I recall being g;n Interviewed by Management Analysis Company ("MAC") In c.s. cIlon with their O ..y, management audit of Comanche Peak Steam Electric Station. I was aware diat MAC had lasued a report and recall dLv'--8ng the report with P G. Tolson of i TUGCO. I do not recall ever having a copy of the report. I left the Comanche Peak Project in June,1979, and did not return until ) March of 1981. I have not participated in any dLv'== fans regartilng whether the l MAC report should be produced in response to CASE's discovery requests. On December 31,1984, I was Supervisor of Vendor Compliance for TUGCO in NH= ; Texas and currently hold this same position. B. C. SCOTT d l SUBSCRIBED AND SWORN To before me by the said B. C. SCOTT on this, the day of .1985. .i I u 1 s _ yp a & A A / y.*I y v f = . ~. -.... __c...._____.__~_,____._.__.-.___._.._,._.____.___.__.__.,__.___._____.______.-

s l, y a .) .~. Notary Puchc m anc for Dallas ~ . County, Texas My Commission Expires Y&&,djr./%,/ftf 4 O e 9 9 9 0 8 Yk .. s p 5 9 4 e O E 4 t-9 ...v.. ,-._,_..,,_____,___,,__,,_,,_,.___.,_-_.___,,,__,_,__,,..__..__.,,,______.._,,_,y

. - - = s AFFIDAVIT OF .) ROBERT SPANGLER l THE STATE OF TEXA5 COUNTY OF DALLAS ) i BEFORE ME, the undersigned authority, a Notary Public in and for Dal5as ~ County, Texas, on this day personally appeared ROBERT SPANGLER, who by me being duly sworn upon his oath, deposes and says: My name Is Robert Spangler. I am presently Supervisor of QA services for _ Texas Utilities Generating Company in Dallas, Texas. I have held that position since May of'1984. Prior to that time, I was a Staff Engineer holding the title of i . Senior Engineer workins In operations support in sc.ectan with the Comanche Peak Steam Electric Station Project. I began that job in June of 1982. From the middle of 1981 until. June of 1982,Iwas employed by 3 dis Controls. Prior to that time, I was employed by'the Nuclear Regulatory Commission, Region IV, and was employed by the NRC in 1978. Sometime after May of 1984, when I was transferred to TUGCO QA In >"==. I became aware that Management Analysis Company ("MAC") had reviewed the-TUGCO QA program at Comanche Peak sometime In the past. I did not have a . copy of the report and first read the report sometime after May 29,1985, when a copy of the report was flied with the Licensing Board. I do not recall from whom I-first heard about the MAC review but it was my general. understanding that it was a cenfidential document and was not a part of the QA records for Comanche Peak. In late April or early May,1985, Andy Jones, who was gathering Information in connecticn with Texas Utilities Electric Company's prudence audit, asked me about the MAC report. I told him that it was my understanding that it was a confidential document and suggested that he talk w!th Dave Chapman' about the inatter. It is 3mg c > rd n l ' - 7. r sf"//

e . 3 0, my understanding that he did so. At that time, I was not aware ' hat there was any t question concerning the previous discoverability of the MAC report in connection with requests for Information in the Licensing Board p'roceedings. h )?T-:kJ = 'ROBERTSPANGLER SUBSCRIBED AND SWORN To before me by the said ROBERT SPANGLER ~= , on this, the day of b . 1985. i u ) Notary Puolic in and for Dadas County, Texas My Commission Expires: hg kA,.lbg l4 tt. I i e 6 6 I e +" l

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=;:.. '3<. AFFIDAVIT OF .,..-.t 1 h _ MICNAEL D. SPENCE ~~ THE STATE OF TEXAS COUNTY OF DALLAS .BEFORE ME, the undersigned authority, a Awf Public In and for Dallas ~ County, Texas, on this day personally appeared MICHAEL D. SPENCE, who by me being duly sworn upon his oath deposes and says: ~ My name is Michael D. Spence. I am President of Texas Utilities Generating Company,3100 Skyway Tower, 400 N. Olive Street, Dallas, Texas 75201. In 1978, I was employed by Texas Power & Light Company. I became Assistant to the President of such Company In June of 1978 and served In that capacity through n May of 1979 when I became a VIce President of Tecas Power & Light Company. 14.9 'V served in such capacity until June 1,1981 when I became the President of Texas ~~ ~ j Ut111tles Generating Company and also served as President of two other sub-1 sidiaries of Texas Utillt es Company and I also was Executive VIce President of Texas Ut!11 ties Company. I was President of Texas Utilities Generating Compan l l ' on December 31,1984. Until contacted by Mr. Wooldridge on or about the 14th day of May,1985 i ' 'had no knowledge that Management Analysis Company ("MAC") had conduc management review or audit of Comanche Peak Quality Assurance Program. I was not aware that MAC had written a report to TUGCO management until that time. .s J O 's e M~>*>-w ' MICHAEL D. SPENCE (/ ^..- ~ g u r qw,, w SUBSCRIBED AND SWORN To before me by the said MICHAEL D. SPENCE l 'pM day of _ %.cuav , 19s5. X ....on.this, the _ _ _.. _,, ~... _ _ _ _ _ _

t O, Q( e ~ Notary RIDuc in and for Dadas County, Texas My. Commission Expires: q -\\-14 = 4 g e s, e e O e k . e e f e D S 4 4 44 ?. 't _/ t. t e e

AFFIDAVIT OF i ), ' .V RONALD G. TOLSON THE STATE OF TEXA5 r COUNTY OF DALLAS .BEFORE ME, the_ undersigned ah-lif, a Notary Public in and for Dallas' l ,. County, Texas, on this day personally appeared RONALD G. TOLSON, who by me - being duly sworn upon his oath de and says: My name Is Ronald G. Tolson. I am employed in private Industry as a ~ consulting engineer. I can be contacted through Robert A. Wooldridge at 214/979- '3014. During the year.1978, I was the site QA supervisor for Texas Utilities y Q.& _, Generating Company.at the Comanche Peak Steam Electric Station construction project. I held this'same job in 1980.' Sometime In March of 1984, I ceased being ~ the QA supervf.sor at Comanche Peak and was at thatl time assisting Joe B. George 3 at the project site. Sometime in November of 1984, i nnoyed to the Dallas office of TUGCO to assist John Marshall on TUGCO licensing matters. Ileft the employ of TUGCO In February of 1985. I recall that In 1978 Management Analysis Company ("MAC") performed a management review of TUGCO at Comanche Pa.ak. I do not recall attending any pre-audit meetings but I was Interviewed by a MAC representative In connection with their review. I do not recall attending any post-audit meetings with a representatives of MAC but I did attend an Internal meeting of TUGCO personnel to discuss the recommendations made by MAC. I recall reading the report in 1978 and I participated in preparing a written response, same being the response signed by R. 3. Gary and L. F. FIkar to p. G. Brittain, a copy of which was attached to Mr. Wooldridge's May 29,198f letter to the I.!cens!ng Beard. a u n+ 'h e a ma i v y u 4.J f evy _ =

l l r' i i O. In 1980, I was generally aware that CASE, the Intervenor in.the 11 censing proceedings, had requested Information from TUGCO: I recall a discussion with Dave Chapman concerning whether the MAC report was to be produced In response to CASE's discovery request. Mr. Chapman told me that TUGCO management had decided that the report was not subject to the disw y request. I do not recall whether he told me who had made such decision however. I do not recall having ~ any conversabans with L. F.'FDcar, R..T. Gary, or B. R. Clements about this ' ' matter and I recall no d1==larm at that time with anyone other than Dave Chapman and possibly Susan Spencer Palmer but it is certainly possible that the matter was dLe'M with o' ther TUGCO personnel. /\\ /$/ RONN,0 G. TOLSON k -j;..,: ) SUBSCRIBED AND 51ORN To before me by the said RONALD C. TOLSON" ~ " - on this, the. N day of, bd'a t.sh ~ . 1945. .) g,/ ((,. LLLv le c. Nowy Publit:in and for Dallas County, Texas My Commission Expires: N .;t. c4 -r 7 4 O 9 O

i i' AFFIDAVIT OF .s ANTONIO VEGA ,/ THE STATE OF TEXA5 COUNTY OF DALLAS.. : BEFORE ME, the. undersigned authority and notary public In and for Dallas County, Texas, on this day personally appeared ANTONIO VEGA, who by me being duly sworn upon his oath deposes and says: My name is Antonio Vega. I am presently employed by Dallas Power & Light '~ Company, a division of Texas Utilities Electric Company. I am Manager of System Prewction and Testing in the Substation and Transmission Department of DP&L. My address is 1506 Commerce ' Street, n="=. Texas 75201 and my telephone number is 214/698-7392. In 1972, I officed In n="-, Texas, working for Texas.. OM m c-Utilities Generating Company as either a Senior QA Engineer or as Supervisor of QA Services. I held this position un1!!! about March 16,1984. when I was transferred (th the Comanche Peak Steam Electric Station site and served the QA Manager. I moved to my present position on March 1,1985. In 1978, I was generally aware that an assessment was being made of the QA organization at Comanche Peak. I do not recall having been Interviewed but I may have been. Likewise, I do not recall attending any pre-or post-eudit meetings. It is possible that I participated in responses to questions w.cordng the review but I recall no specifics. I beIIeve that I saw and read the report prepared by Management Analysis Company ("MAC") in cennection with their management review but I do not belleve that I ever had a copy of it and I do not have one at this time, It may have been that I first read the report in the process of attempting to respond to it in 1978 but I cannot be sure. ~?. I am generally aware that in 1980, CASE, the Intervenor in the Comanche psak 11:ensing proceedings, recuested inform from the Applicant in these y____ ._m - " ~ ~ ~

'gMIngs. I was not Involved in keeping track of what was'being suppIIed in s response to those requests. I was not Involved in any dL*=6ns concerning the MAC report In 1980 or thereafter nor any discussions of whether or not the MAC report should or should not be pr+M In response to the discovery recuests. Following that time I do not recall hearing anything about the MkC report until ' May of 1915 at or about the time Mr. Wooldridge sent a copy to the um Boardo.It was at this time that I first heard of any question wsning the MAC reportin wi.ecdon with CA51L's discovery requ In the h.eing gxsdp i ~ gg ,Io ygcA - j-SUBSCRIBED AND SWORN To before me by the said ANTONIO VEGA on this,tras bT% day of hGu.s t- '. 1915. (p) ~.~ k WW NW1ublic in and for Dallas County, Texas My Commission Expires 9- \\ -N I l t l l l s l %).. ^

._;.--------= . - - -=. _ - ~'~~ i .g ~ ~'N~ ) .. COMANCHE PEAK STEAM ELECTRIC STATION - PLAN FOR INSPECTION OF PILES - PURPOSE To reassure Texas Utilities management, the NRC Staff, and the ASLB that ' documents related to Interrogatories frem CASE have been Identifled and provided. Texas Utilities recognizes that dishj is an extremely important and integral part of any hearing or court proceeding and this review should emphasize this commitment. BA'CKGROUND In May 1985, Texas Utiuties alerted the ASLB and all parties involved in CPSES Licensing Hearings that they had discovered a report that had not previously been provided to the ASLB even though it fell within fe scope of an intervenor discovery request in 1980. Tens Utilities has committed to conduct a thorough review of company flies and discovery requests to assure that no other similar documents exist. 1 METHOD To RESOLVE CONCERNS \\ 16 l { relating to CASE Interrogatories In ASLB hearings be condu w :- l j (if any) Identitled as responsive to CASE 1 parties In the ASLB hearings as soon as poss..i..vgstories will be provided to an ible following disoi. The search and review process will be documented and a brief summary of the results will be prepared following completion of the Ir i-cilon. l SCOPE OF FTT-E REVIEW The review will include project files that could contain documents relating to CASE Interrogatories cer.cor.ing contention 5 (QA/QC), including all Quality Assurance /QuaHty Control fHes (>"=, CPSES), Licensing fHes (DaHas), Retro-spective " prudence" audit flies and any other project files maintained by QA/QC management personnel and executives that had ultimate re.ier lbuity for CPSES. WORK PLAN. The following general work plan describes a two-phase process to conduct and document a thorough search of CPSES related fues in relation to CASE discove requests. This plan should be viewed as a " maximum" effort tofallay concerns about prior ASLS discovery. determined untH Phase I has been completed.The work effort required for Phase H ca .h . -y a e e

.. _ _.. _.. m.m-m.-- PHASEI ~ (' 1) Form " Search Team": Assign a project manager to oversee and manage the conduct of the . review. Assign 3 team members to supervise the file search; each would be assigned p-e'Mc areas: Executive /Cor ... o Project Filer porate Flies (Bryan Tower /5kyway) Dallar(Skyway Tower) o o Project Files-Ste (CPSES). Indoctrinate / educate Search Team on appropelate legal standards ~ governing dh y, Irah44 NRC Rules of Practice and Federal Rules of Civil Wh 2) Review all CASE dism i requests relating, to contention 5 and screen questions (i.e. questions requesting. specific documents, questions requiring information to be developed, etc. will not be considered further), 3) Summarize discovery requests from above, Identifying sperfM-='ly what the Search Team needs to look for. 4) Identify and locate the specific files that are to be examined - this search for -ties wil1 Includes Interviews with appropriate personnel Reviews of historical.and current organization charts P11es identifled by CPSES Roseg-nive Audit Team ~ = Physical search of offices and storage arena (Bryan Tower, Skyway ~ Tower, CPSES). Document the decision-making dw Appropriately tag flies that are reviewed. Li PHASE II 5) Develop ar. detailed work plan with procedures to be used as a guide for the conduct of the actual search of f1Ies. The plan will contain the following: Purpose and basic methodology for search SWMc work steps and schedule A h for o conducting search of a file o gMg " potential" Information for review o processing Information for final review Resource needs. 6) Conduct kick-off meeting (s) as appropriate for personnel involved in the search of files and explain work plan and procedures. 7) Conduct the search of flies , j., b Identify " potential"Information track progress of search closely. e 4

=.=_- s 3)~ " Search Team" core group Gdentifled In 1) reviews aII " pot'ential"Information Qf any) and prepares a package of Information for review by legal counsel and company management. s '1.d 9) Provlde any relevant "new" Information Qf any) to 'all parties In the ASLB p==1p 10). Complete documentation of the search effort and summarize the review Process purpose and methodology p':';+.;, work p an and gdwes which files searched (magnitude, number, etc.) ~. ~ results; SCHEDULE The time to prepare for and conduct the above work plan is roughly estir6ated ait two to three months depending on the number and extent ol files searched. Phase I will require two to three weeks to conduct, at which time a more definite schedule for Phase II can be established. RESOURCE NEEDS Plise Iof the 1.w+MThe following TUEC/TUGCO personnel are possible ca ~ i l o A. Jones - Steer -2 and 3: Lead the effort to review and summarize the applicable CASE discovery requests so they can be used In the search. 3 This would require direct Interface with 7. Marshall, B.14orin, and S. Palmer. Steo 4r Identify and locate specific flies to be searched o Executive / Management F11est D. Flore111 Project Files (Dallas)r T. Smart and F. Biza. Project Files (Site): P. Milam l Determination of resource needs for Phase II should not be made until Pha is complete. . -h -~~-~~w" ' ' ^ ^^ " " ' ' '^' ~~

Q ~ Management Analysis, Company a, 11100 Rossue st san Diego. CA Ss121, 714/452 1391 [.. i May 17,1978 MAC-JPJ-471 Mr. Perry Brittain President Texas Utilities Generating Company -l 2001 Bryan Tower Dallas, TX 75201 ~, i

Dear Mr. Brittain:

Enclosed is the report of the Management Quality Assurance Audit conducted for Texas Utilities Generating Company. The audit disclosed that, in general, the Quality Assurance activities were effective, that there is good team spirit between TUGC0/TUSI personnel and the Architect / Engineer and.the Constructor. The audit resulted in the identif,1 cation of some failures to comply with regulatory requirements, the. Quality Assurance Plan or the PSAR. These deficiencies are identified in an Audit Report as Appendix A. The audit also identified areas of potentially W. improved practica.. These are identified as.0bservations and Racessiendations M and Appendix B to this letter. As you know, MAC participated in an audit of .the Comanche Peak site and significant improvement is noted since that audit. Manag'ement Analysis Company received full cooperation from all personnel con-tacted during the audit TUGCD/TUSI, Brown & Root, and Gibbs & Hill. The general openness of personnel and their frank discussion not only enhanced the conduct of the audit, but exemplifies an attitude conducive to correction of any deficiencies. We appreciate the opportunity to be of service to Texas Utilities Generating Company and Texas Utilities Services, Inc. and hope to do so in the future. If there are any coments or questions regarding this work, please contact Mr. J. M. Norris or me at (714) 452-1391. Sincei@y, f..,. t j John P. Jackson Principal Partner JPJ:bew ~

Enclosures:

Appendix A Appendix B 3.. %27 = ~ -

_ - ~ _ -..,.. ~ l _.s ! i I l (~. -.. 1 APPDDIX A ~ TEXAS UTILITIES GENH ATING COMPANY. l AUDIT REPORT Ie E. I I .sw-T.i@. l f e e f ~ MANAGEMENT ANALYSIS COMPANY i L-

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2 l E APPDIDIX A- . 5 l l B M TING COMPANY, l AUDIT REPORT g h.) [ w .e ia p l t. 0 I f 1,. s,.. 9 ________.L

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Subject:

Audit of Texas Utilities Generating Company, Dallas Offices and Conanche Peak Steam Electric Station Construction Site Q Date of Audit: May 1-12,1978 l Audit Scope: A uanagement audit was conducted of the Quality Assurance Program of Texas Utilities Generating.Cogany during the -l weeks of May 1 and May 8,1978. The purpose of the audit was to determine the adequacy of the Quality Assuranca g Program as related to Nuclear Regulatory Ocamission require-ments and the effectiveness of iglementation to meet program g requirements and authority delegations. Activities were la audited at both the TUGC0 offices in Dallas and at the Comanche Peak construction sita. Activities of the Architect / h Engineer and Constructor were audited only at the construction sna. The scope of the, audit included comnitments made in l the PSAR, the Corporate Quality Assuranca Manual, the Comanch Peak Quality Assurance' Plan, the Project Procedures Manual g and the Brown & Root Quality Assurance Manuals and Procedures related to the Comanche Peak sita. t I b Auditors: Dallas office, May 1-3, 1978 J. P. Jackson, MAC Audit Team Leader J. M. Nor41s MAC Auditor l Comanche Peak Construction Site, May 4 & 5. May 8-12,1978 J. P. Jackson, MAC Audit Team Leader g. J. M. Norris, MAC Auditor J. A. Hendron, MAC Auditor (May 8-12 only) g. Personnel NAME COMPANY TITLE fn"erv D. N. Chapman TUGC0 QA Manager. *-1-2 t R. G. Tolson TUGC0 Mgr Site Surveillance. *-1-2 R. V. Fleck TUGCD/G&H Civ. Inspec. Supv., *-1 l J. V. Hawkins TUGC0/G&H Prod. Assurance'(QA), *-1 3 mm w m.

~. 1 \\ -.i TUGC0 AUDIT REPORT * ..i Personnel NAME COMPA,Ny, TITLE h"terv J. B. George TUSI Proj. General Mgr., *-1-2 8 J. T. Merrit TUSI Resident Manager. *-1 E. G. Gibson TUSI Project Engineer', *-1-2 B. J. Murray TUSI . Engineering Supv., *-1 J. J. Moorhead 6&H Resident Engineer

  • -1-2 B. C. Scott B&R Site QA Manager. *-1

'l J. P. Clarke B&R Site QC Manager. *-1 R. Mann BAR QA, Records Coordinator.

  • g H. C. Kirkland B&R Proj. General Mgr, *-1 U. D. Douglas BAR Project Manager. *-1 D. C. Frankum B&R Asst. Project Mgr., *-1 P. Foscolo B&R Proj. Chief Engineer
  • -1 g

L. Hancock B&R Mat'l Procurement Con-y struction Branch

  • -1 A. Boren -

TUGCD Vendor Compliance.

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~~ A. Vega TUGC0 .QA/' Central Staff Function. *,. ,,3 C. Beggs TUGC0 Systems Compliance

  • -1-2 R. Gary TUGC0 Y.P., Operations. *-1

=m L. Fiker TUSI I V.'P., Design & Procurement. *-i P. Brittain TUGCD/TUSI President,1 g Interview t l 1 Pre-audit meeting 2 Post audit meeting Audit Method: The audit was conducted through a series of interviews with responsible management and supervision and examination of Quality Assuranca manuals, procedures,' records and work operations both at the Dallas headquarters of Texas Utilities Generating Company and Texas Utilities Services, Incorporated and at the Cemanche Peak construction site. Sumary: The audit disclosed that re. cent changes in authority dele- } gations had been generally well accepted and that morale a k m-

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.g 1 TUGC0 AUDIT REPORT ~ J. Sumary (Cont'd'): and team spirit were good. However, the changes had not yet been femalized in revisions to the PSAR and the Comanche Peak Quality Assurance Plan. The audit also h disclosed that,present practices in the control of design changes and of certain nonconformances do not provide the E a='='* ' ' a' '

    • *** "$"*' d = a" r- '"

other instances it was evident that design changes were .E the areas noted herein and below, there was generally good adherence to existing procedures.- ] Findings: 1. The current activities of TUGC0 Quality Assurance per-h ,sonnel are not consistent with the authority delegations to Brown & Root and to Gibbs & Hill as defined in the g PSAR and Comanche Peak Quality Assurance Plan. ~ Similarly, the Quality Assurance, Plan and Procedures are not consistent with current and planned revisions in E authority ilelegation's to the Architect / Engineer and the ~. Constructor, and is not complete in addressing all eighteen criteria of 10CFR50 Appendix 8. The lack of a h well identified plan of reorganization and responsibility causes uncertainty in carrying out some activities. l, There nee' ds to be a plan for revising the Quality Assur-ance Program; such a plan should include the establishment g { of an architecture of procedures to show how other TUSI/ TUGC0 and contractor manuals inter-relate with the Quality i 8 Assurance Manual. The TUGC0 QA Manager should establish a schedule and assign responsibilities for complet' ion of the necassary procedures. The schedule should be supple-mented with a management effort to monitor adherence to the plan and achievement of the schedule. 2. The current site DC DDA system of after the fact coordi- . nation of design changes with the original designer !5- ~ .5 i \\ L. r

...... ~. - ' ^ ' y--..----.. l TUGC0 AUDIT REPORT I i O. M E. \\ H'" Findings: provides a significant risk of design error and does (Cont'd). not meet the requirements of 10CFR50 Appendix B, nor of ANSI N45.2.ll, " Quality Assurance Requirements for the Design of Nuclear Power Plants". 'E ~ A system for expediting and documenting Gibbs & Hill home office approvals should be established using g telephone, telecopier or telex as a means of speeding consuunication. 3. The Comanche Peak Quality Assurance Plan does not provide E for a Quality Assurance review of procurement documents and changes thereto prior to purchase order placement. except for site originated procurements. Such a review h is identified in 10CFR50 Appendix 8. Criterion IV and ~ is a requirement of ANSI N45'.2.13. It should be required on all safety related procurements, w I

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TUGC0 Corporate Quality Assurance Manual, the Comanche E Peak Quality Assurance Plan, Project Procedures and Brown & Root Manuals and Procedures pmvides a complex array of procedures which is difficult to maintain current and consistent. l 5. The current system of providing inspection instructions or checklists to inspectors is too generic, placing an j undue burden on the inspector in attempting to determine applicable drawings and specifications and applicable l revisions thereto. A review of records of concrets pours incidates that configuration reflecting the as-l poured condition is not clearly defined. Applicable DC DDAs are noi: noted in inspection documentation. Configuration needs to be clearly identified to l?v. ; inspectors on a current basis, including all applicable l 1 i y., ens::m _,. _..:: M -- :... ~ - ~ -- - - - - ~ ~

_ _ = - - - -..._: C~ ~ T-' T % t TUGC0 AUDIT REPORT h .M yp g Findings: DC DDAs and completed documentation must reflect the - (Cont'd) status of the applicable changes. h 6. Special processing markings for later in-servica inspections are carelessly applied. The circle and l arrow used for such marking is sometimes incomplete and not recognizable for its intended purpose. In one g instance only a portion of the circle resembling the letter "C" was discernible. Failure to properly 8 mark these locators ncx will cause delay and possible error when in-service inspections are nede in highly irradiated areas. 7. Disposition of nonconforming items does not always h achieve the requisita review by appropriately qualified design personnel. A procedure, limited to defects in g concrete, was recently issued which bypasses the estab- .,{ J}. lished nonconformance control system and, thus, violatas. '- regulatory requirements in this regard. In other instancas, the DC DDA program has been used to bypass E the nonconformance reporting systam. The nonconformanca control system should be the means for maintaining in-spector integrity, identifying problem areas and provide a driving force for their correction. l 8. The records storage facility does not currently have any means of internal fire protection during hours it is unmanned, although it is understood some method is planned. Quality Assurance records, such as personnel qualifications, are not maintained in the Records Center, but are maintained in fireproof file cabinets in a trailer under the cognizance of Brown & Root training coordinator. 9. Approximately twenty-four percent of Central Staff audits have not been conducted as scheduled. Combining Central '. Staff audits, site audits and site surveillance activities l

m L.J. TUGC0 AUDIT REPORT i 8, 3 ~ .- s-e / ~~ g Findings: (Cont'd) by TUGC0 and by Brown & Root into a single, cohesive program would provide improved visibility to the overall 75 d audit and surveillance effort and permit evaluation and ajustment to the audit schedule to attainable and yet effective frequencies. .. a O g. 4 E ll ~ D e e ' ?4 e s e g R' ~ 8 ~ g 0 g... \\ / !8 Eiiiii . =. - = = =

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  • f TEXAS UTILIU ES GENERAU NG COMPANY l

l OBSERVATIONS AND RECOMMENDATIONS 1 I 13 I ~ l I! 1 l' I I. ~ ~ lg(-.; MANAGEMENT ANALYSIS COMPANY ,I

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L _.. l.. ~ u- {. I [ TUGC0 AUDIT OBSERVATIONS AND REC 0fftENDATIONS I. ORGANIZATION ~ A. _ General N TUGC0 Quality Assurance has undergone considerable reorganization in the qbJ past year. The general thrust of this effort has been the assumption of, greater direct involvement in the management and supervision of the' Cemanche Peak. Quality Assurance Program. It is to be noted that! 1mporta shifts in responsf5111ty were being made at the time of MAC's review. 'l As a part of this assessment, MAC evaluated the reactions of key

  • manag supervisors and inspectors to the overall changes that have taken place to date.

It was generally observed that those interviewd thought that with few exceptions the changes were for the better. There appeared to,be a team 3 effort on the part of QA and Construction with excellent TUSI executive -f;~; %nagement and project management support of the QA program. There was no noticeable problem with organizational prejudice brought about by the l organizational intermixing of TUSI, Brown & Root or Gibbs & Hill work forces and supervision. B. Orcanization l During the course of the audit !!AC discussed the value of a revised organizational structure wi.th the TUGC0 Quality Assurance Manager and g the Manager, Site Surveillance. l g It is reconnended that TUGC0 adopt an organizational realignment of i a activ,1 ties. as set forth in Exhibit 1, whereby Quality Engineering and Inspection report to the Site QA Supervisor as two separate sub-organizational entities with responsibilities as defined in Exhibit 1. Such an organization will better supplement the existing Constructicn { organization and will permit better organization for handling day-to-day site prob'lems as well as implementing recen:nendations of this report. (.j This is particularly so in the area of inspection planning. a g;;;; _~ _ __ n.,.

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I TUGC0 OBSERVATIONS & RECOMMENDATIONS

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.) C. Quality Surveillance Comittee All minutes of meetings of the QSC since its inception were reviewed. [ t It is noted that the QSC was established as a mechanism for providing C 3 top TUGC0 management with a periodic update on such matters as " schedules, d l and milestones" or " audits and corrective actions". ya/ 1 <p% It was noted that recent meetings dealt with tracking on the status of / action items as set forth in the Outstanding Surevillance Report Items or the Quality Assurance Items of Concern Report. In such instances it / l appeared the Quality Su veillance Comittee was taking on the role of a task force or problem solving group. The problem that exists if the QSC l assumes such a role is that problems would tend to await the three month meeting cycle before the necessary management attention is effected. 1 ~ = It is recomended that TUGC0 re-evaluate the charter of the QSC and serious I consideration given as to its value to the projec,t recognizing that: [ l All actio'n to resolve problems should be handled on a day-to-day basis 1. through the functioning organization, and l 2. The primary objective of maintaining management awareness of Quality Assurance status might be accomplished more efficiently, effectively and on a more timely basis through a monthly Quality Assurance progress report distributed to the TUGCD/TUSI executives. D. Qualification of Personnel MAC reviewed the qualifications of all TUGCO/TUSI and Gibbs & Hill Quality Assurance personnel and many of the Brown & Root personnel., It was observed that" most of tna TUGCO/TUSI Quality Assurance personnel have y gained their Quality Assurance experience through Comanche Peak activities only. Although the project has provided valuable experience, it is ree-omended that any future assignments in Quality Assurance be filled with quality engineers hired from outside the company with broad nuclear ex- .') perience, preferably in construction. Such experience added to the existing starf will serve TUGCO/TUSI well. in accomplishing the important siEi2

~ -.., _._ : m+e mm '" ' ...~M l ~ TUGC0 CBSERVATIONS & RECOMMENDATIONS j l 'q.,, ~ 1 piping, electrical and startup activities ahead. l MAC had occasion throughout the audit to assess the qualifications and ( ex,erien. of 20-301.,ectors th,oughout the construction site. The. / p. observations are worth mentioning: I The inspectors are generally young and inexperienced with many ha 1. l as little as six months experience fri inspection. h 2. There was an obvious need for more seasoned inspectors to work with F the novice inspectors on a day-to-day basis. 3. Too much responsibility is placed on the inspectors with respect to preparation of inspection planning, resolution of site problems and determination of the design configuration base for performance of inspections. l ... y . s.,;. ~ II. QUALITY ASSURANCE PROGRAM 7 [ The Quality Assurance Program is defined in three baste documents: 6\\ i / The Corporate Quality Assurance Manual / Chapter 17 of the PSAR The Comanche Peak Quality Assurance Plan These documents are not in total agreement with one another. Since there is no other nuclear plant currently planned and since the authority dele. gations identified in the Corporate Manual are not in consonance with practices on Comanche Peak. TUGC0 should consider discontinuance of the Corporate Manual unless there are other projects to which it is to be applied. If a Corporate Manual is required at a later date, a new one could be prepared based on Comanche Peak experience and the requirements of any new projects to which it would be applied. The Comanche Peak Quality Assurance Plan addresses only the following criteria of the eighteen identified in 10CFRSO Appendix B. t- @ -m_. ^

= x -. y = t I TUGC0 OBSERVATIONS & RECOMMENDATIONS Organization Design Control Procurement Administration Inspection --4 Nonconformance Control h Document Control i =co,ds n Audits ~ With the expanded responsibilities of the TUGC0 Quality Assurance Depart-h ment, the plan needs to be expanded to address all eighteen criteria to reflect the creation and functions of the procureme't Department and to g be consistent with the aut{ority delegations and functions still resting with Gibbs & Hill and with ' Brown & Root.

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I Thergends to be a, plan for procedural identification and development g and a schedule and assigned responsibilities for their completion, including - G a complete architecture of Quality Assurance pmcedures, project procedures. 3 ~ and interfacing procedures of the Archits.-t/Engi.neer and Constructor. The y effort should be to minimize the number of procedures required and to eliminate duplicating or ov'erlapping procedures through consolidation of ~ g detail and joint approvals of the' organizations involved. It is recommended that the Quality As.surance Manager use his organization as the driving g' force to achieve required procedural coverage on schedule. It was noted that TUGCO.is planning on obtaining its own Code manual. The stated reason for this was the fear that Brown & Root would not achieve Code acceptance. The auditors feel that the Brown & Root manual would be acceptabls to the Code Surve'y Team and that its weld practices as exempli,- fied in the Wald Shop are very acceptable, The auditors are of the g opinion that obtaining a Code Stamp will be difficult where all the work of implementing the program is performed by others. III. DESIGN CONTROL The present system of expediting field changes by referring design changes to the original design organizatien for approval after the fact does not { .~ m m-s

~ ' - - ~ ~ ~ TUGC0 OBSERVATIONS & RECOMMENDATIONS I c

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meet the intent of 10CFRSO Appendix B nor of ANSI N45.2.11, which require that field changes be subject to design controls commensurate with tho exercised on the original design. TUGC0 audits have already disclosed 6 that the Architect / Engineer has not been reviewing.ffeld origingted changes on a concurrent basis, thus the design engineer's connents may be received after the specific construction work is complete resulting in. possible loss of design integrity. undue pressure on the designer to justify what has been done, loss of designer responsibility or possible extensive repairs. It is recoseended that a system for expediting review and } approval by the original designer be established on all safety related changes using telephone, telecopter or talax as necessary to coordinate g and document change approvals. IV, PROCUREMENT DOCUMENT CONTRCL O Except for site procurements, the Comanche Peak Quality Assurance Plan I does not provide for a review of procurement documerits and their changes prior to, placing a purchase order. This is contrary to requirements of l . 10CFR50 Appendix B, Criterion IV and ANSI N45.2.13, " Quality Assurance Requirements for Control of Procurement.....". There is a review of pro-curement documents by Quality ' Assurance during Design IWview but is was l ascertained that this was a review of the drawings at:dOpecifications and not the purchase order or contract. Procurement document review by Quality Assurance should assure that all necessary requirements for access to the supplier's facilities are provided and that necitssary controls and documentation have been specified and that the appropriata configuration has been defined. The review should I also assure that requirements imposed are appropriate to the procurement and that there are no excessive requirements for quality program develop-ment or for the delivery of unnecessary documentation. Sme of the pro-curement packages reviewed appeared to have both blanket requirements for !f Quality Assurance programs and excessive requirements for documentation. i ! I' N 'I fEli -A ~ ~ "A ~ - - - - - - ~

--- v 2 ': 2. TUGC0 OBSERVATIONS & RECOMMENDATIONS O.. r, _.' .s ,. ) V. INSTRUCfIONS A. Inspection planning The current system of providing inspection instructions or checlilists to the inspectors is too generic in nature. In the case of concreta inspection - I planning the inspector fills out a simple pour card with an attached Concrete Placement Checklist, a Reinforcing Steel Electrical, Mechanical and Embedded Item Placement Checklist and a Stainless Steel Liner checklist, l the combination of which: l 1. Provides no information with rsspect to unique, embedments or penetrations to be 1.ncorporated in the pour. 2. Places an undue burden on the inspector in attempting to determine applicable drawings, specifications, applicable revisions and Q l applicable DC 00A's. Much of this input should be prbvided by 4 clerical support under the direction and subsequent approval of g[:- l a quality engineer. l Inspectors estimated that 45-70% of their time'is spent on docu-mentation rather than physical inspection activity. Well thought i out planning enuld do much to alleviate this situation. l l Traceability It was observed that Comanche Peak has established a program of unnecessary material traceability which, based on one estimate, consumes l at least a three-man level of effort and perhaps as,high as a six man level of effort if one considers all the support functions required to j implement the program. All anchor bolts and B series cadwelds are fully traceable to heat numbers such that through an elaborate and extensive system of mapping all installations, the capability exists of identifying each embedded anchor bolt, B series cadwelds and other standard embeds to its h' eat number. There exists no such NRC or industry requirement for this degree of traceability. It is inter-r l esting to note that rebar does not require traceability on Comanche Peak '} (and shouldn't), MAC knows of no other project that imposes this require- ./ u 1 E

--_w ..;7.- ~ _ _. ~ i TUGC0 OBSERVATIONS & RECOMMENDATIONS [s 7-

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%Q R ment and could not identify a Comanche Peak specification or procedure requiring it. 'Accordingly, it is reconnended that this practice be dropped innediately. Such a move would enhance inspector morale as those, involved are aware that the practice serves no useful purpose. h C. Procedure Simplification ~ Newly established pr' ocedural systems are such that Construction and Quality Assurance issue procedures on similar subject matter jointly, for example, the recently issued procedure on shop traveler's was l jointly prepared by Construction and Quality' Assurance. It is recom-mended that important procedures such as those related to concrete be revised and issued as a single procedure approved by Construction and Quality Assurance. Similarly, those procedurts related to piping and electrical should be revised and jointly issued as a single Comanche Peak procedure. i D. Procedures Independent of Houston .The present system of obtaining-Brown & Root, Houston office approval ? on construction procedures should be modified. Guidelines should be worked out with the Houston office whereby they approve only top level \\ procedures, permitting the site fnll flexibility in revising detailed. site procedures. Perhaps the Brown & Root. Houston office could retain approval authority on those top level documents that establish Brown & l Root policy, control the necessary type of forms, etc. However, g' detailed operating procedures should be changed with site approval only. Perhaps the Houston office would agree to a retroactive review procedure. E. Configuration Control V (< A review of records for completed concrete pours indicates that the configuration reflecting the as-peured condition is not properly defined. It was noted that the inspectors record the particular drawing nunter and revision letter, however, all applicable DC DDAs are not noted anywhere in the inspection supporting documentation. K. [ , _,, _ _ -. - - - ~ - - - - - - - - - ' - ' ~ ' ' ' " ' ' " " ' ' " ' " ' ~ ~ " ' ' '

s 6 y TUGC0 OBSERVATIONS & RECOMMENDATIONS 3 .) E PreolannhngofConstructionWork F. In discussions with construction management personnel it was indicated that a new scheme of construction planning is being developed. This new scheme provides for a detailed mateHal takeoff on all Gibbs & Hill 7.% drawings which provides detailed instructions to the crafts as to the y civil, mechanical and electrical items to be included in each segment ~ of work. This formalized approach of taking material takeoffs in the office and providing this infornation to the field forces on an approved meterial takeoff list will do much to improve the quality of the work. ,'] Since the material takeoff is a formal process accomplished by construction engineers well in advance of the work, it provides a significant measure g of preplanning, including the processing of necessary desmign changes to accomplish the work. Such an effort will do much to minimize field errors with respect to left out embedments or inability to complete work as a. result of design errors. It is reccanended, however that, this effort bed 0 formalized into a Comanche Peak site procedure. ] As such, it will be fi. recognized as part'of the system and will do much to assure that Gibbs & G Hill drawings es - forwarded to the site on a timely basis to accomplish this preplanning effort. l g VI. DOCUMENT CONTROL g[, While there appeared to be some problems with bringing the Automatic - Records Management System on line, the manual system backing.it up l appeared to be functioning satisfactorily. The auditors found no g deficiencies in document control., e VII. CONTROL OF PURCHASED MATERIAL, EOUIPMENT AND SERVICES The Quality Assurance Plan is not up to date in regard to TUGCO's responsibilities for procurement, source evaluation and :ource sur-veillance. TUGC0 has developed a program for rating supplier perfonn-ance and shows evidence of actions when reatings are unsatisfactory. The list of suppliers requiring evaluation and source surveillance is } not kept up to date by the Architect / Engineer. The list in use is over - J g mEE l . ----mn

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,. _ - ~ y..=~- - - ~ -~~ ~ '# m " " 3 '~ " * '- ~.. .I m 'TUGC0 OBSERVATIONS & RECOMMENDATIONS ~~ X L four months old, but is maintzined man'ually by the TUGC0 Supervisor of r Supplier Compiiance.~ There does not appear to be any method of assuring that the l'atest con. figuration is supplied to the personnel performing source inspection h prior to shipment of procured items. The source inspector appears to be at the mercy of the supplier in determining diat, changes have been 'g identified and incorporated. Thus.'it is conceivable that items will be. shipped to the site that do not meet the desired configuration even g though requirements of the purchasing document have t,een met. Such I receipts can cause delays and unwarranted costs in meeting the proper i configuration. E It is recomended that a practice be established of identifying and confirming required configuration prior,to procurement and prior to l shipment.of purchased materials and components. d ~ V VIII. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS No fic ncy n'oted. Material reviewed in the warehouse, in open l storage and in the weld shop appeared to be adequately identified. ~ l, IX. SPECIAL PROCESSES l A. Radiocraphy l Iridium 192 is being used as the radiation source for all radiography h at the site. This isotope has its optimum capability at about 1.5 inch l-thickness of steel and is not recommended by the Code below.75 inches. lq l l g It is pemitted for lesser thicknesses when the use of other radiation sources is not practical and when resolution of the outline and 4T hole size of the penetrameter can be demonstrated. The energy levels of iridium isotopes are higher than optimum for materials.375 inches or thinner, resulting in a flat image and lack of contrast. Because exposure time relates to distance, the isotope is normally placed against the pipe opposite" the film. With a.100 inch source size, this causes blurring kf. of the image. Lack of contrast and a blurred image makes it unlikely v Ig IEEE I

_z - - ~~ ~ I q ~. rTUGC0 OBSERVATIONS & RECOMMENDATIONS ' h ), s a that hairline cracks will be seen and difficult to accurately define large indications. The use of iridium 192 meets the minimum requirements E of the Code, but by not providing optimum identification of observed anomolies it does three undesirable things. First it causes unnecessary removal and mpair of indications that can be seen-but not ' properly hl. identified; secondly, it masks narrow cracks, tight-lack of weld pene-tration and non-fusion which can be detrimental to. service life; thirdly.

  • )l it does not provide an adequate base line for in-service inspections performod after the plant has gone into operation. Failure to have clear identification of the original indications at that point can cause delays, the cost of which greatly exceeds the cost of providing better identifi-
M cation and necessary repair of defects found in the' construction phase.

Recomendation - It is recomended that TUGC0 require x-ray for shop welds. [ and conside'r its use where practical for construction welds. X-ray machines in the range of thirty pounds of weight are available and are H ris a r* ai

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  • e3 size and variable voltage, x-ray can give superior radiography.' The

{F feedback of infomation to welders can improve the guality of welds and l minimize the potential for defects. The ability to discriminate between indications having roundness.or sharpness at the ends can eliminate repair. L The ability to positively identify in the construction phase 'those indi-cations which have a potential for growth and failure can pemit economical repair without radiation hazards that are inherent if found later in the i l l operating phase. ~ !E l B. Weldino 'k No causes for concern and no procedural noncompliances were found in review of the weld shop. There seemed to be a general opinion that l after radiography repairs are being required that are acceptable within the Code. A review of a small quantity of rejected film indicates this g generalization may be valid. It was disclosed during the audit that radiographs may be reviewed by as many as five individuals. Such ex-E cessive review leads to supercritical evaluation of film and to excessive l As'previously stated, better radiography pemits better. 'A repair. I ,y4u m. - e=. N =

3 - _ ~. ..,3 ,,..L n TUGC0 OBSERVATIONS & RECOP9tENDATIONS ~ .*\\ t. identification of conditions acceptabl'e within the Code. Unnecessary repairs increase cost and reduce pipe reliability.- l h Reconnendations - Have radiographs dich have been rejected for defects. reviewed by TUSCO Level III radiographer. If a_ reasonable statistical sample shows that excessive repair of welds has been required, establish the policy that Code acceptable, indications shal,1, remain untouched, but shall be recorded on the reports. j As an economy., consider reducing the mmber of pehens performing sequential review of radiographs. ~ ( NDE Oua11fications g,' The site NDE Level III situation is unclear. Only Level II certification u4 b Brown & Root was available for the NDE Supervisor; however, it is b unterstood that TUGC0 has issued a letter identifying him as Level III. Reconnendation - Clarify the authority and responsibility cf the NDE g supervisor in administering tests and'avaluating.and certifying per-sonnel. This is very important as related to Code work, since the { Level III will be working under the authority of the holder of the Ccde stamp. X. INSPECTION There were no deficiencies noted relative to inspectioni however, it was noted that a large number of inspection personnel are receiving M " their first nuclear construction experience on the Comanche Peak site. As a consequence, it is necessary to improve the ~ quality of inspection plannihg and to increase the leve's of supervision and quality engineering support. Inspection planning should identify the required configuration including applicable DC DDAs, the features to be verified, the inspection Q method and acceptance. criteria in order to minimize possible confusion and error. -l [']

~ - - ~ ~ - ~ ~ ~ \\ .1 L TUGC0OBSERVkTIONS&REbOMMENDATIONS 3

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XI. TEST CONTROL A review was made of the TUGC0 startup administrative procedures, with the following observations. T-1. The procedures appear to be written around the old ' organization; that is. in several instances they refer to the. Brow & Root QA/QC input required in the preparation of "startup work requests". It was noted 'that an unique system is being established to handle 2. nonconformances during the startup phase. ' It i' recommended that - s wherever possible existing schemes utilized in c' onstruction be used during the startup process. This is important since most personnel involved in dispositioning such items as nonconformances and design l changes will be the same persons involved in constiuction. l XII. CONTROL OF MEASURING & TEST EQUIPMENT It was observed that out of 24 instruments sampled which are utilized in l , civil, structural, mechanical and electrical work.approximately 50 l percent had not been withdrawn from the calibration laboratory since its last calibration date. This is particularly significant when it is g [s, recognized that the present system is such that if a calibration date becomes due, the instrument is recalibrated whether or not it has been issued for use. It is recomended that consideration be given to simply ~ changing the calibration date rather than going through a calibration I cycle if the tool has not been used. E It was note.d that many construction tools are calibrated. It is l important to note that calibration of construction tools is not I necessary with respect to 10CFR50 Appendix B. Although calibration 5 "d ="* "*"c '=

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'=a=r**"* " =#"=*r"c*'a" *# '=- '*==' be that frequencies may be relaxed. } XIII. INSPECTION, TEST AND OPERATING STATUS No deficiencies were noted in this area. Material and equipment observed in receiving inspection, in the warehouse and outside storage

-j 9 + =1.. TUGC0 OBSERVATIONS & RECOMMENDATIONS f3-area appeared to be adequately identified. No tests were observed. XIV. HANDLING, STORAGE AND SHIPPING N Exterior storage practices should be reviewed. The' protective coverings d of many items are damaged; some reported on monthly surveillance reports have not been corrected. Large temporary structures, such as those over the emergency. diesel engines, require wind bracing.to prevent further damage.. Because of soil chemistry, rain and himiidity, the current prac-4 tice of allowing large stainless steel piping to remain uncovered should,b. be reviewed. Sensitized stainless is extremely sensitive to chloride, fluoride and sulphide contamination which with water as a couplant can f cause intergranular corrosion and prematu're failure. XV. CONTROL OF NONCONFORMANCES 9 l There appears to be an effort to reduce the nurser of documented non-conformances. y ~ It was noted that DC DDAs were being utilized for-nonconformance reports. Althougn this was observed on a small percentage afaDC DDAs issued during i the month of April, it is recomended that this practice be stopped ih imediately. The TUGC0 system is correctly established whereby non-l confonnances are written after the fact and DC DDAs are reserved for g' design changes before the fact. It is important that this practice be l enforced since DC DDAs prepared after the fact necessitate that workers be directed verbally to violate the drawing since the deviation will be i handled after the fact. with DC DDAs. This is a poor Quality Assurance I - practice ' 0 ~ t Procedure CPQ1-AB, Rev. O, dated 5-5-78 was issued for the purpose of b, prov'iding expedient disposition of concrete discrepancies. The procedure l infers that discrepancies of 72*F versus 70*F or 6.2% air content versus 6.0% maximum is perfectly acceptable when it is signed off by the field l engineer. Such a system shortcuts the established nonconforming material { control system as defined in Brown & Root and TUGC0 procedures and should I" g w= i .% ~='.==: y;~_ ~ -~.. ~.. w ~..

33 ^^ .J-TUGdo OBSERVATIDNS & RECOMMENDATIONS I s', t be discontinued. If tolerances are unrealistic such that the 72*F is acceptable, then the design specification should be changed to so indicate. n = =, It is reconsnanded that good inspection planning be provided inspectors, identifying the characteristics to be inspiected, the method of inspection and acceptance criteria and that inspectors identify nonconformances to such criteria. This will naintain the integrity of, inspectors and provides "l identification of problem areas and provides a means for their correction. g It is reascnable to assum. that on a project as laig'e as Comanche peak there will be several thousand nonconformance reports. The number does y not reflect adversely on the quality of construction, but the failure to 4 identify nonconfomances does reflect adversely on the. integrity of [ inspectors and leaves unknown the quality of the plant. dn c XVI. CORRECTIVE ACTION r 7,, --

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There were no deficiencies noted relative to corrective action on hard'- "U l The Supplier Compliance Supervisor has established a method of ware. h tracking vendor performance and shows positive results from actions taken l to correct supplier quality problems. A review of reports of site sur-g veillance conducted by TUGC0 showed corrective action responses were l being promptly received. A review of reports of surveillanca actions by Brown & Root showed generally adequate response and resolution of corrective action except for a period of four months when surveillance ~ . personnel were assigned to other tasks. 1 In general, corrective action appears to be adequate an~d timely on vendor and site related problems, but some deficiencies, identified in audits of major contractors still persist. Some of the changes in authority dele-jl gation to major contractors appears to be action taken to correct inadequate or untimely respense by those organizations; however, other actions taken, such as handling of field changes and nonconfomances, appear to be those of circumventing the problem rather than correcting it. g s ;;;; 1 ="h*

.,...__.,._..m.mm I m 7 ~. TUGC0 OBSERVATIONS & REC 0f9fENDATIONSi -15 # y.. .. ? XVII. RECORDS l Except for lack of internal fire protection, the quality records area g is considered to be satisfactory. Some Quality Assurance records, such as personnel qualifications, are not stored in the records cantar but are maintained separately by the Brown & Root training coordinator. Them is not currently a catalog or listing of required records although it is being. prepared. A review of a selection of-Quality Assurance records showed the documents in them to have been properly completed ) and in the correct order. 1 Recomendation - The installation of an inert gas fire extinguishing \\ system or the identification of geographically separate duplicata records ~ should be expedited. TUGC0 should review the fire protection capabilities of storage facilities in' the training supervisor's ' railer and consider t a duplicate set of such records to be maintained in the records center. AU'ITS [. XVIII. D bq There are several audit and surveillance programs-1p effect. Audits by the Quality Assurance Department Central Staff are verfomed on site J activities, major contractors and suppliers. Site su veillance actions b are performed under the direction of the TUGC0 QA Site Supervisor. Similar l surveillance activities are carried out under the direction of the orown & Q' Root Site Quality Assurance Manager. While called surveillance act"ons, the survefilance programs are formally planned and scheduled, utiliu {}r' checklists to guide the activity and record results, and issue reports of deficiencies and require correction. Except for formal and documented pre-audit and post-audit meetings, all the elements of'an audit program are in place. It was reported that the reason for calling the activity " surveillance" was to avoid outside auditors finding the program deficient because it did not include the documented pre-and post-audit meetings, I yet the auditors found that such meetings were conducted, but on an h' infomal basis. l {' Recommendation - The auditors consider the present program to be an ls effective tool which could be further improved. TUGC0 should consider II~"% - : - = l?.I... - ~ - - -

i s TUGC0 OBSERVATIONS & RECOMMENDATIONS 16-h ..T ..) g combining the audit and surveillance activities into a single, cohesive effort. Such an integrated effort could cover requirud areas more g efficiently, without duplication and at a frequency that can.be main-tained. Such an audit program should be described in written procedures 'and include a description of both the formal audit and the continuous audit plan (surveillance) and the method of conducting prw-and post-audit meetings should be described to preclude later criticisms by outside ~hl organizations. The resulting audit program should be a superior tool for ~ management assessment of program implementation and effectiveness. k' I E I E i8 g ] l e l 5 i I5 l5 i 5 ~ i 1 S l iC ~ ) i S. liii5ii _____m._

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