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Category:DISCOVERY REPORTS
MONTHYEARML20236X3141987-12-0404 December 1987 Supplementation of Discovery Responses.* ML20214R4841986-09-22022 September 1986 Discovery Request for Names of Participants in Review & Analysis of Comanche Peak Response Team.Related Correspondence ML20214R4651986-09-22022 September 1986 Discovery Request for Answers to Interrogatories Re Comanche Peak Response Team.Related Correspondence ML20214P6941986-09-18018 September 1986 Discovery Rept 8 Re Transcripts of 851003 & 860206 Meetings. Related Correspondence ML20214P7011986-09-18018 September 1986 Discovery Rept 9,App G,Requesting Description of Circumstances Under Which Senior Review Team Directed That Written Description of QA Measures Controlling third-party Activities Be Developed.Related Correspondence ML20214P7101986-09-18018 September 1986 Discovery Rept 10 Requesting Agreement/Disagreement on Listed Statements.Related Correspondence ML20214P7281986-09-18018 September 1986 Discovery Rept 11 Requesting Response to Listed Questions on Encl Nonconformance Repts.Draft Subpoenas for Depositions Also Encl.Related Correspondence ML20214Q2851986-09-18018 September 1986 Discovery Rept 12 Requesting Sampling of Applicants Comanche Peak Review Team Plan.Certificate of Svc Encl. Related Correspondence ML20206S5681986-09-16016 September 1986 Discovery Rept 5 Re Rev 2 to App E,Concerning 860723 Questions at Comanche Peak Response Team Public Meeting. Certificate of Svc Encl.Related Correspondence ML20214R8081986-09-16016 September 1986 Discovery Instructions Re Applicant Answers to Comanche Peak Response Team Discovery Repts 1 & 2.Related Correspondence ML20214R8301986-09-16016 September 1986 Discovery Rept 1 Requesting Definitions for Each Separate Meaning or Interpretation Used in Comanche Peak Response Team Program Plan.Related Correspondence ML20214R8531986-09-16016 September 1986 Discovery Rept 2 Requesting Answers to Listed Questions for Each Listed Individual Re Involvement W/Comanche Peak Response Team from Sept 1984 to Present.Certificate of Svc Encl.Related Correspondence ML20206S5621986-09-16016 September 1986 Discovery Rept 4 Re App B,Requesting Responses to Listed Questions Concerning Comanche Peak Response Team Insp of Qa/Qc Program.Related Correspondence ML20206S2631986-09-15015 September 1986 Response Team Discovery 3 Rept Re Program Principles & Objectives.Certificate of Svc Encl.Related Correspondence ML20198A0931986-05-15015 May 1986 Intervenors M Gregory & Case Proposed Discovery Plan,In Response to ASLB 860502 Order Admitting Intervenors as Parties.Related Correspondence ML20010H2091981-09-22022 September 1981 Rept of Applicants & Citizens Association for Sound Energy 810909 Meeting Re Discovery Status.Agreement Reached for Applicants to Supply Intervenors W/New Info & Documents. Certificate of Svc Encl ML19347D6031981-03-18018 March 1981 Supplemental Status Rept of Mar 1981.Settlement Completed W/Central & Southwest Corp & Subsidiaries.Reserves Position That No Administrative or Judicial Proceeding Will Prejudice Brownsville Rights in Future.W/Certificate of Svc ML19323H9081980-05-22022 May 1980 Discovery Rept for Apr 1980.Attended Continuation of Nc Lerner Deposition.Responded to Houston Lighting & Power First Set of Interrogatories.Joined Parties' Motion for 30- Day Extension.Certificate of Svc Encl ML19324A0461980-05-19019 May 1980 Discovery Rept for Apr 1980.Participated in Gtc Taylor Deposition.Responded to Houston Lighting & Power Motion to Compel Production of Documents.Undertook Settlement Discussions & Trial Preparation.Certificate of Svc Encl ML19323G8981980-05-15015 May 1980 Discovery Rept for Apr 1980.Participated in Nc Learner & G Taylor Depositions.Reveived NRC Updated Response to Houston Lighting & Power Second Set of Interrogatories.Inspected NRC Documents Designated by Expert Witness ML19323G7221980-05-15015 May 1980 Discovery Rept for Apr 1980.Util Counsel Participated in Depositions of Nc Lerner & G Taylor,Expert Economic Witnesses for NRC & Dot,Respectively ML19323F6071980-05-0101 May 1980 Correction to Apr 1980 Discovery Rept by Public Utils Board of City of Brownsville,Tx.Failure to Depose J Bruggeman Was Due to Counsel Independent Decision to Attend ASLB 800307 Hearing.Certificate of Svc Encl ML19323B7101980-04-30030 April 1980 Discovery Rept by Public Util Board of City of Brownsville, Tx for Apr 1980.Deposed JW Wilson.Participated in G Stagg Deposition.Responded to Houston Lighting & Power Motion to Compel Production of Documents.Certificate of Svc Encl ML19316A8921980-04-21021 April 1980 Discovery Rept for Mar 1980.Participated in D Springs & Gtc Taylor Depositions.Updated Response to Tx Utils Generating Co First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl ML19323H5871980-04-16016 April 1980 Discovery Rept for Mar 1980.No Discovery Requests Initiated or Received.Certificate of Svc & Change of Address Notice Encl ML19323C7911980-04-16016 April 1980 Discovery Rept for Mar 1980.Deposed a Smith,Jw Atkins,Gw Stagg & G Knowles.Participated in J Wenders,Ja Bruggeman & D Springs Depositions.Responded to Houston Lighting & Power Motion Re Expert Testimony of C Stover.W/Certificate of Svc ML19316B0351980-04-15015 April 1980 Discovery Rept for Mar 1980.Participated in J Wenders,A Wood & J Bondurant Depositions.Filed Response to DOJ & NRC Joint Motion for Mod of ASLB Order Re Settlement Discussions. Received Documents from Tx Utils.W/Certificate of Svc ML19310A0141980-04-14014 April 1980 Discovery Rept for Mar 1980.Participated in Bruggeman, Wenders,Wilson & Wood Depositions.Filed Supplementary Answers to Central Power & Light First & Third Sets & NRC Initial & Third Interrogatories.W/Certificate of Svc ML19309E3361980-04-0808 April 1980 Discovery Rept for Mar 1980.Deposed Ja Bruggeman,Jt Wenders, Aj Wood & DA Springs.Moved to Compel NRC Deposition of Nd Lerner.Responded to DOJ Motion to Compel Supplemental Answers to First Interrogatories.W/Certificate of Svc ML19309C9581980-03-19019 March 1980 Discovery Rept for Jan-Feb 1980.Participated in M Ozymy Deposition.No Discovery Requests Initiated.Certificate of Svc Encl ML19309C1571980-03-17017 March 1980 Discovery Rept for Feb 1980.Participated in Ammons,Beams, Borchelt,Campbell,& Yarbrough Depositions.Inspected DOJ Documents.Received & Opposed Central & Southwest Motion for Addl Time to Reply to Interrogatories.W/Certificate of Svc ML19309C2621980-03-14014 March 1980 Discovery Rept for Feb 1980.Deposed J Wilson,Gc Campbell & V Robertson Et Al.Attended DOJ & NRC Depositions.Served 800201 First Set of Interrogatories to Nrc.Received Addl Responses to Interrogatories.Certificate of Svc Encl ML19305C8471980-03-0707 March 1980 Discovery Rept for Jan & Feb,1980,City of Austin Has Neither Initialed Nor Received Any Discovery Requests ML19309C9721980-03-0606 March 1980 Discovery Rept by Public Utils Board of City of Brownsville, Tx,For Feb 1980.Deposed M Borchelt of Central Power & Light. Participated in R Edelstein Deposition.Received Documents from Central & South West Corp.Certificate of Svc Encl ML19309C7341980-03-0505 March 1980 Discovery Rept for Feb 1980.Deposed W Taylor,M Hebb,De Simmons & El Watson.Participated in Depositions Noticed by TX-LA Electric Cooperative & City of Brownsville,Tx.Reviewed Diamond Shamrock Documents.Filed Application for Subpoenas ML19309C9211980-03-0505 March 1980 Discovery Rept for Feb 1980.Participated in a Gerber,M Hebb, E Simmons,V Robertson & Gw Beams Depositions.Attended J Turk, & s Phillips Depositions.Filed Motion for Addl Time to Respond to Tx Utils Interrogatories.W/Certificate of Svc ML19305C8131980-03-0404 March 1980 Discovery Rept for Feb 1980.Southwest Tx Electrical Cooperative,Inc & Medina Electric Cooperative,Inc Neither Initiated Nor Received Any Discovery Requests.Certificate of Svc Encl ML19294B0631980-02-15015 February 1980 Discovery Rept for Jan 1980.Participated in Autry,Beard, Borchelt,Castillion,Chalker,Corder,Farrington & Harrison Depositions.Received Central & Southwest Corp Second Request for Production of Documents.Certificate of Svc Encl ML19296D1351980-02-0808 February 1980 Discovery Rept for Jan 1980.Deposed TR Locke,O Castillon,R Corder & R Farrington.Participated in J Milford,S Phelps,P Hayers & H Marsh Depositions.Responded to Houston Lighting & Power 800103 Request for Conference Call ML19294A9261980-02-0505 February 1980 Discovery Status Rept for Jan,1980 Submitted on Behalf of Central & Southwest Corp.Attys Inspected Addl Documents Re Tx Utils Generating Co Response to 790822 Request for Documents.Certificate of Svc Encl ML19296C1961980-02-0404 February 1980 Discovery Rept by Public Utils Board of City of Brownsville, Tx,For Jan 1980.Participated in Central Power & Light Depositions.Produced Addl Documents to Houston Lighting & Power.Certificate of Svc Encl ML19260D6901980-01-23023 January 1980 Discovery Rept by TX-LA Electric Cooperative,Inc for Dec 1979.Participated in Gambrell,Howard,Hughes,Campbell,Skelton & Spense Depositions.No Discovery Requests Initiated ML19257C7061980-01-18018 January 1980 Discovery Rept by Public Utils Board of City of Brownsville, Tx for Dec 1979.Inspected West Tx Utils & PSC of Ok Documents.Took Notice of Deposition of D Chalker of Central Power & Light.Certificate of Svc Encl ML19262C0911980-01-15015 January 1980 Discovery Rept for Dec 1979.Participated in Austin,Berman Brittain & Campbell Et Al Depositions.Opposed W/O Success Discovery Extension Requested by Doj.Responded to Central Power & Light Third Interrogatories.Certificate of Svc Encl ML19257C0771980-01-0909 January 1980 Discovery Rept for Dec 1979.Participated in Central & South West Co,Houston Lighting & Power Co & Tx Utils Generating Co Depositions.Filed Applications for Subpoenas Duces Tecum. Certificate of Svc Encl ML19257C1491980-01-0808 January 1980 Discovery Rept for Dec 1979.Utils Did Not Initiate or Receive Any Discovery Requests.Certificate of Svc Encl ML19257C1451980-01-0808 January 1980 Discovery Rept for Dec 1979.Intervenor City of Austin Neither Initiated Nor Received Discovery Requests. Certificate of Svc Encl ML19211C4481979-12-14014 December 1979 Discovery Rept for Nov 1979.Participated in Bowers,Hartley, Woerner,Taylor,Phippips,Bradley,Marquardt,Robertson,Holt, Fikar & Butts Depositions.Filed Jul 1979 Written Testimony Before Sec ML19257A7501979-12-13013 December 1979 Discovery Rept for Nov 1979.Participated in Bowers,Gambrell, Robertson,Butts & Phillips Depositions.Did Not Initiate Any Discovery Requests.Certificate of Svc Encl ML19290C1141979-12-13013 December 1979 Discovery Rept for Nov 1979.Participated in Bowers,Gambrell, Robertson,Butts & Phillips Depositions.Did Not Initiate Any Discovery Requests.Certificate of Svc Encl 1987-12-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
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t Lh1LO CONItEE 00CHETED edFOds THg USNRC UNITdD STATdd NUCLEAa RnUULATORY COMMISSION 1
SD)22 f! 5 8 decore the Atomic Safety and Licensing soard UFK: "a ~,_ '
000.- . ,, ,
In tne Matter or )
)
TEXAS UTILITIES GdNdRATING COMPANY, ) Dx t. Nos. 30-445-OL et al. ) 50-446-OL
)
(Comanene Peak Steam diectric )
Station, Units 1 ano 2) J CPRT DISCOVdRY - 9 Appendix G
- 1. Descrioe in precise detail the circumstances unoer wnica tne Senior aeview Team tsxT) directed tnat "a written oescription or quality assurance measures controlling CPRT tnird-party activities ce oevelopeo" (Appendix 6, p. 1).
Incluae in your answer the followings
- a. Ioentity the individuals f rom the SRT who gave the airection to estaolian the identified quality assurance measures.
- o. Ioentity all tne documents that provide the direction.
- c. Loentity tne time and cate that tnese directions were 91ven.
- 4. Descrion in precise cetail now it was cecided which criteria ano principles trom 10 CPR Part 30, Appendix B, were relevant to tne CPRT ettort.
8609240029 860918 DR ADOCK 050004 5
-2_
1 3.
Describe in precise detail how the CPRT quality assurance program aescrio~ ed in Appendix G of Revision 3 meets the goals of the program as aescribed in the statement made by W. G.
Counsil in niw Aug. 10, 19o3, letter to Vincent Noonan, in which ne states (p. J):
it is our view that these steps ano the Oyt, taxen together with the carefully structured taira party nature or the CPRT program plan itself, provide a vigorous and open process which meet the requirements of 10 CFR 60, Appenaix 8, ano essentially guarantees its integrity ano tnat or the final product and Conclusions.
Incluoe in your answer a description, in precise detail, or what Mr. Counsil cellevea woula De acced to tne CPRT generally ana/or appena1x u in particular enat woula provide a basis for this statement ana that has not been added to the CPRT generally ana/or Appenaix G in particular.
4.
Describe in precise detail what Mr. Counsil meant in his August 16, 1965, letter to Mr. Noonan when he stated that the CPRT efrort will " meet the requirements or 10 CFR 50, Appendix 8." For instance, was this intenced to indicate that the requirements or the program, if met, would provice compliance with all the aetailed criteria or 10 CPR Part 60, Appendix at 3.
Describe in precise aetail what is meant by the statement in tne summary at page J of Appendix G tnat "perrormance to tne re3uirements or the wu ality Assurance Program will ensure high quality stanaaras in accordance with the SRTs ana 'rucco management's expectations ano coannitments to quality."
l a
N
For instance, was tnis intenaea to indicate tnat the requirements or tne program, it met, woulo proviue compliance with all tne deca 11eu criteria or lu CFR Parr 30, Appena1x et o.
Identity all TRT ISAPs tnat were ongoing as or July 43, 1900 in tne civil, Structural, Mecnanical, Electrical, Testing, and silscellaneous groups.
l.
Or tne ISAes icentitieo aoove, provice tne completion aate ot tne actual document review or inspection process.
Explandtlon:
wnen aio the 9atnering of raw cata stop ano tne preparation or tne Resultu Report begint
- o. Expidin in precise cetdil tne rollowing statement f rom tne July 23, Ivoo, letter trom Counsil to Noonan:
Tnese as well as otner CPRT audit activities are aesigned to De in process activities; tnererore, unless speciric audit findings indicate a neea to audit completed TRT ISAP activities, audits will not ce conducted of tne implementation ot a TRT ISAP arter its Results Report nas Deen suomitted to tne SRT ror review ano approvea.
- v. laentary all tne " measures previously instituted of the dRT" reterreo to in tne last sentence on page 1 of tne July 4J, 1300 letter.
Au.
wnat was tne casts or tne SdT's cetermination tnat tne "CPRT program principles, implementation requirements, ana po11cles anc guiuelines, in conjunction witn tne aetailed guidance proV10ed in eacn TMT 18AP are sutricient to ensure tne qu ali ty eerrormance ot Thf ISAP activities and results"t i
_4_
in proviainy the answer, ioentify all documents or oral aovice trrom whom) upon which the SRT relieo.
- 11. Explain in precise detail what quality assurance measures were in place for each of the completeo ISAPs not covereo of Appenoix b and identify what documents existed that descrioed those measures and/or were used to govern or carry out tnose measures, including procedures and training manuais.
- 12. For each ISAP identified above, explain the basis upon wnica tne CPRT intenas to rely to estaoiish the quality of the worn performeo.
1J. Provice tne casis ror tne oecision made by the SRT that aooitional quality measures "would oe appropriate to ensure the quality" or tne WOC program.
Ioentity all documents, memoranda, or any meetings at which this issue and decision were discusse6..
- 14. To wnat extent, it any, did the SRT review the NRC inspection record of the exC program at the Braidwood facility?
It tue NRC inspection record was considereo, identiff the person or persons wno performed the review and ioentify air documents tnat were revieweo.
- 13. Iuentary tne status or all w0C activities at the time tne Sat required the QOC Review Team to implement a quality assurance program ror its activities (p. 3).
A
lo. loentity the process of wnich the Senior Review Team will review all audits ano corrective actions ,taken in response to aucith. Incluue in the response to this question the iuentitication or all proceoures used to accomplish tne review 19 Jf.
it. Explain tne oasis or the statement that "CPRT activities associateo witn implementing these idAPs were perrormeo of a smaiA numoer of persons in accordance with the principles ot the CPhT Program Plan" (p. 4). Include in your answer now tne CPkt nas any assurance that the work was pectormed in accoraance with tne plan since there was no QA program tor the plan.
10.
loentity each or the consultations oetween the 3df and tne various Review Team Leaders for the TRT ISAPs that led to the aetermination that "auoltional implementing procedures, providing aetails or management controls beyond that existing in the ISAPs anu CPRr Pro w ram uocuments, were not requireo" (p. 4).
13 loentity the oasis or tne RfL's decisions to issue or not to issue supplemental instructions for each tat ISAP. The answer snoulo De trom eacn indivioual RTL and should state what oocuments ne or sne reviewed or discussions he or sne had to reacn tnat determination.
40 For eacn ruf 1 SAP ioentarf now the quality assurance critetta requirements ot 10 CPR 50, Appendix d, are coalt with.
For example I
-g-For example:
ISAP I.A.4.
Applicaole/NA Incorporateo Criterion i Na Incepenaence not required because not the program of record.
Criterion 11 Criterion III Criterion IV
" y V1 Applicaole Checklist ana procedures,
" Sect. 4.2.0.
VII .
VIII IA A
x1 All x111 Alv AV AVI Avil AV111
- 21. ' Explain in precise aetail the basis for excluding eaca of the following Appendix B criteria from the CPRT:
Criterion III - Design Control Criterion IV - Procurement Document Control Criterion VII - Control of Purchased Materials, Squipment and Services Criterion VIII - Ioentification and Control of Materials, Parts, and Components Criterion IA - Control or Special Process Criterion A1 - Test Control Criterion All - Control of Measuring and Test Equipmentt Criterion A111 - Hanoling, Storage, and Shipping Criterion A1V - Inspectin, Test, and Operating Status 1
22 Ioentity any other measures not aescrioed in Appendix G upon wnicn tne Applicants rely to uemonstrate that there is assurance of tne quality or TRT IsaP activities.
23.
Iaentity and proauce all audits and/or inspections conoucted into tne CPRT program plan or any of its elements since Octooer 1964. Tnis incluaes out is not limited to TOGCo audits, INPO audits, audits by the NRC inspectors, MAC, Brown & Root, Stone = Weoster, Comoustion Engineering, E8ASCO, TERA.
44.
In rewaro to tne Overview guality_ Team (OyT), identify tne criteria upon whicn tne SRT will conclude that "the level of CPRT activities no longer justities the need for the OQT" (p. 2 or tne OwT program, Rev. 2, July 2J, 19o6).
es. Luentity tne criteria oy which the OQT will evaluate tne implementation or the CPRT WA program " relative to 1
acnlevement" or tne oojectives listea on page 2, of the OyT.
- 26. I Identity the "other measures" -- and identify all ,
oocuments that descrioe these measures and/or are used in :
I implementing these measures, including procedures ano training manuals -- tnat assure the quality or the following activities:
- a. SRT activities;
- o. Tecnnical Review of Results Reports;
- c. Assessment ot tne CPRT Program Auequacy.
i 2 /. Iaentity ano explain the oasis on which the OUT will mane tne determination as to wnether personnel "are acequately .
qua11tica ano traineo to pertorm tneir assignea tasks" (p. J).
_g_
zo. Iaentity ano explain tne casts on wnich the OyT, will make tne aetermination as to whether personnel "can perform their aSalynea tasks oojectivelf ana Witnodt incluence from prior organizational artiliations" (p. a ).
49.
Explain in precise detail tne rollowing about the OyT's Procecure Review, Section J.4 of tne OQT (p. 4):
- a. How are tne procedures to ue reviewed by the OQT selectedt
- o. Icentity tne criteria upon which tne owT makes its aetermination on whetner the proceaure, if properly implementea, "w111 acnieve tne oojectives ot tne QA program."
- c. Is tne wA program reterreo to in tais section the CPRT wA program as aescrioea in Appendix G, or the site wA program?
- a. Explain in precise detail now tne OQT processes, comments on, or questions the procedural implementation, e.g., on what torm are comments or questions recordea?
JU. in re9 ara to Section J.J, "Auait Plans and Record Review," identify tne written torm or procedure upon wnich the Uwt will 109 any aesireo additions or changes with the OAP and w0C 19 4 ).
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Icentify tne written torms or proceuures upon which any areas ot disagreement will oe reterreo to tne SRT tor resolution
\p. 4),
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_9 J2. Iaentity tne criteria the OQT will use to determine if selected audit plans are "aaequate" in regard to audit frequency, timeliness, ano thorougnness (p. 4).
JJ. Icentity the process which records and evaluates the OwT's concerns in tne event that the records review reterred to in Section J.3 generates a question f rom the OyT with respect to wnetner or not aucit oojectives were achievec (p. 4).
J4. Explain in precise detail the reason that tne OQT's acoltional aualtors or inspectors " work under the direction of -
the DAP and yOC program aucit team leaders," instead of under the OwT ty. 4).
J 3. Icentity tnose aucits conoucted by the QA organization ot tne DAP ana WOC program review teams wnich tne Ogf members will participate in as observers (p. 4). How is this selection maae and what criteria are used to make it?
J o. Icentify those overview inspection activities for which the OwT will pertorm direct observations (p. S).
J 7. Identity tne written forms or documents on which the Out will recora its observations from reviewing the activities aescrioco in Section J.d ana 3.0 of the OwT.
Jo. Identify all written forms or cocuments upon whicn the OwT will loentity any prooleins or issues it oelieves need e .
resolution.
- 49. Identity tne criteria the OQT will use to determine if the work prooucts or QA activities are conducted in accordance witn applicaoie industry standards ano practices (p. 5).
- 40. Identity ano provide all OQT open items tracking sheets oiscusseo in 23.11 tnat have oeen completed to date (p. 6).
- 41. laentify and provide all periodic progress and status repor ts of the OwT ef rort (p. o).
- 42. Identity the individual (s) who are assignea to the positions listed on Figure 4.1 uA/QC Review Team Organization.
- 43. In regara to Figure J.4 or the CPRT wA/yC Review Team guality Assurance Matrix, identity each lu CFR Part 50, Appendix d, criterion that is not aeemed applicable to the QA/QC Review Team Activities ano explain the oasis for its exclusion.
- 44. On page 26 of the MP plan, Rev. 4, under the Procurement Document Control, Section 4.0, it states that "iciertain procurements for services were accomplished prior to tne establisnment or this MP Plan." For each or these p rocu r e sken ts, identity it and provide the documents reviewed and tne criteria oy which ERC determinea that there was proper l Inclusion of quality assurance requirements.
i 43 i
Explain in precise detail what is meant oy the term
( "non-contorming haroware and accumentation" as usea in the MP Plan on page JJ.
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40 Icentity wnat part ot the CPRT reinspection of hardware ano cocumentation is not done of the wA/yC Review Team according to tne MP Plan.
- 47. Explain in precise detail now a non-conforming condition is luentified.
4o. Tne MP Program states tthat the DRs "are used only tor WA/wC Review Team dvaluation purposes." Identify all persons who perrorm tne evaluations ot the DRs.
49 loentify all tne procedures useo to ao the evaluations or tne uns.
a u. Explain in precise detail wnat tracking or trending of tne dericiency reports are cone.
- 31. Is each nonconforming condition, whether or not it is determinea to De a deviation, documented on a deviation report?
On any report / It so, which one or ones?
34 Explain in precise aetail the process by which oeticiencies "uncergo an evaluation to verify validity." Include in your answer an identification of all the procedures used for i veritying tne valiaity.
DJ. Explain in precise aetail wnat is the aisposition or tne oeviations tnat are aeemeo invalla accoraing to tne criteria explainea in response to question 32.
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se. dxplain in precise detail, including identifying, the process that nas been established to ensure that rework or repair is not cone until atter the safety significance evaluations is completed,
- 33. Iaentity tne criteria used by the SSEG to determine if a aeviation, if uncorrected, woula result in the loss of capability "to perrorm its intenaea safety function" (MP, p. , 3 4 ).
So. Identity, by example if necessary or helpful, in what cases tne wA/wC Review Team Leaaer "may designate other Review Teams responsible for conducting evaluations for safety signiricance in lieu of the SSEG" (MP, p. 34).
6 /. dave any cases arisen to cate in which other RTLs conouctea tne safety signiricant evaluation instead of the SSEG?
If so, specify.
so. Descrioe in precise detail the requirements and proceaures for conoucting root cause and generic implication analyses of sarety signiticant ceticiencies.
5v. Descrine in precise cetail the requirements and
{ proceoures tor tne review and evaluotion of deficiency reports j " tor the purpose or iaentitying adverse trends" (MP Plan, p. 34).
00 Describe ano explain in precise detail the difference I
Detween a "proolem," a "ceviation," and a "cericiency," relating l
l to TuuCo's wA Program, as aiscussea on p. JS of the MP Plan.
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- 01. Descrioe ano explain in precise detail the difference between a " problem," a "aeviation," and a " deficiency," relating to cne Comanene Peak Station hardware.
- 62. Explain in precise aetail the circumstances unaer which proolems, aeviations, or deficiencies would not be identified or processed on a deficiency report (DR), but would appear either in a Results Report or in a collective evaluation report (p. 35).
- Treat each separately.
oJ. DescriDe ano explain in precise detail the process by which recommendations for corrective action are provided to TUuCo.
- 64. Identity the person (s) who make up the Procedures and Project Assurance Group.
os. sxplain in precise detail the process by which the Procedures and Project Assurance Group ensures that identified proolems are correctea.
co. Provide each corrective action request written on the Comanche Peak project since ERC began work under these procedures (p. 30).
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o /. Provice eacn stop work order written on the Comanche Peak project since BRC began work under these procedures (p. 36).
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Descrioe ano explain tne basis upon which, after a stop worn oraer is in ef fect, tne QA/wC RTL ano the Manager of QA would agree tnat work may be resumeo (p. Jo),
- 09. Identity waat records are kept in the B&ESO files aescrioea on v. J / of tne MP Plan.
/U. Does tne ERC auait program descrioed on p. 38 of the MP Plan meet the requirements of 10 CPR Part 50, Appendix B?
- a. It not, explain wnat portions of the program ao not meet criteria requirements ana sny.
- o. It so, inaicate which portion of the ERC program meets whicn criteria. It tne compliance is not self-eviaent, please explain now tne program acnieves the claimea compliance.
- 71. Identity ano produce all auaits conducted oy the BRC Division Manager or wuality Assurance of any of the QA/QC Review Team activities as " defined in the CPRT program plan and appenaices ... anc wis" (p. 30).
/2. Iaentity tne circumstances under which the Manager of quality Assurance woulo conduct or would be required to conduct auaits ot BRC suocontractors ano other third-party inspection agencies utilized by tne CPRT Review Teams.
/J. dave any dualts oeen conducted pursuant to tne circumstances cescrioco in question /z aoove? It so, procuce the aualts.
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- 74. Produce for inspection and copying all documents iaentitiea in the answers to these questions and all documents reliea upon and/or examined in preparing the answers to these questions.
Respectfully submitted, y
alLLIE P. GAto)E f /
Trial Lawyers for Public Justice 3424 North Marcos Lane Appleton, WI 54911 (414) 730-8534
, Counsel for CASE Dated: Septemoer 18, 19o6 4
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