ML20052B794

Request for Complete Answers to Citizens Assoc for Sound Energy Listed 820405 Ninth Set of Interrogatories

ML20052B794
Person / Time
Site:	Comanche Peak
Issue date:	04/26/1982
From:	Citizens Association for Sound Energy
To:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20052B791	List: ML20052B790 ML20052B794
References
NUDOCS 8205030578
Download: ML20052B794 (3)

Text

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q t-REQUEST FOR COMPLETE ANSWERS TO CASE'S 4/5/82 NINTH SET OF INTERR0GATORIES T0.-

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APPLICANTS ~AND REQUESTS TO PRODUCE: }j . .

Question 41. CASE questions 38, 39, and 40 prefaced Question 41: -d

^ 3,21 "38. How wem audits of design and construction scheduled at the time of -2 the Lobbin Report? . , V3 "39. How wem audits of design and construction planned at the time of the wMn Lobbin Report? , ' ' 'g y

"40. Have you completed your review of your current practices identified '-+ t in 38 and 397 ( /@l'

,.-y "41. What changes, if any resulted from this review?"

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Answer: "Both of the procedures identified in the responses to Interrogatories Hj 38 and 39 have been mvised." Your answers to 38 and 39 only refer to. ,ji sections of the Corporate Quality Procedures / Instructions Manual. This 1..

does not answer CASE's specific question as to what specific changes "4 resulted from this mview.

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Question 7.c. " Identify audits in which 'TUGC0 QA has in fact made deteminations of generic effect as a result of audit findings.' (Lobbin Report, 3'.g Applicants' Response, page 15)" :3l

' .'i Answer: "As stated in the Lobbin Report (p.15), detemination of generic effect  :

is made on every audit as a result of audit findings. Specifically, an -}

auditor, upon finding a deficiency, must determine, by further review and Q investigation, whether the deficiency is an isolated incident or whether 3 there are additional instances of the same type of problem. In addition, m the auditor determines whether the problem is the result of a program or j procedure deficiency, inadequate training, or attitude. Although there A; is no requirement to, and the applicant does not record this logic sequence, *:

this evaluation is in fact performed on every audit performed by the Applicant."

While the preceding is very informative as to how the process works, it

/4 ;ti does not answer CASE's specific question. We want to know which particular -l -

audits TUGC0 QA has detemined to have findings which indicate generic effect. [p]

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'M Ouestion 77. CASE Question 77 was prefaced by Question 76: , $  :

"76. With reference to 75, was the detemination made that the generic .

effect applied to past activities?" ec Answer: "Yes." @

. rek "77. With refemnce to 76, if the . answer is yes, what remedial measures M were taken to assess and correct the effects? Answer for each audit." ,@@

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Question 77 (continued):

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Answe r: " Tov *er with the audit reports, all corrective and preventive action J!

responses, if required, have been made available to CASE for inspection y and copying with each audit report produced."

-Q This answer is completely meaningless to us, since Applicants have not '.3 answemd our previous question. We have been supplied with many audit "

reports in answer to our requests to produce, and we have no way of know- - 4, j ing which specific reports Applicants are referring to, i; i Question 99: "Has there ever been a trending program for nonconfonnance reports i

• at CPSES?" a' Answe r: "Them are pmgrams in place at Comanche Peak which require that non-con- .

i fonnances be reviewed in an effort to preclude repetition of conditions  : j adverse to quali ty." 9 Does this mean "yes"?

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i Ques tion 100: "If the answer to 99 is yes, who conducted the program?" '..

Answer: "Both Brown & Root and TUGC0 quality assurance organizations implement 9

a program as described in the response to Interrogatory 99."

This answer is meaningless to us, since we don't know what Applicants' d answer to Ques tion 99 means. Please answer this question at the same '

time you answer Question 99. .

91 Question 154. "With reference to 152 (mgarding reporting of items listed as -

d being possibly mportable on the NCR Logs), who makes the deter-mination as to whether or not each ' item was actually reported."

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• a Answer: ik "This responsibility, is defined in site quality pmcedure CP-QP-16.1 (TUGC0 ' Quality Procedures Manual') and procedure CQP-CS-6 (Corporate Quality Procedures / Instructions Manual), which have been made available ]Q

he to CASE.for inspection and copying." p a e This answer is not responsive to our question, which asks who makes

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the determination, not the title or responsibility of such person. We want the name of the person who makes such detennination, (Further, as Applicants are well aware, we have always given Appli-j;y j cants a signed certification of each document we have viewed and had the 9,

opportunity to copy. Applicants should also be aware, from reviewing the list of i the docunents we have copies of, that we do not have a copy.of CP-QP-16.1.) . ,A

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p Question 157. "With refemnce to 156 (regarding the determination to void an item .

on the NCR log), who makes such determination? 7) i I

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Question 157 (continued): s

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. Answer: "See response to Interrogatory 156." M Answer to 156: " Procedure' CP-QP-16.0, Paragraph 3.1.5.1 (TUGC0 ' Quality d Procedures Manual') and procedure CP-QAP-16.1, Paragraph 3.2.1.3 (Corporate Quality Procedures / Instructions Manual) h define the processes of voiding NCR's. These procedures have been made available to CASE for inspection and copying."

Questions 156 and 157 wem not the same. Question 156 asked for an explana-tion of the criteria used in determining whether or not to void an item.

Question 157 asked who makes such determination? As with Question 154, we d

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want the name of the person who makes such detemination. j (See also coments under Question 154 regarding the procedums CASE

~ a does and does not have. We do not have copies of CP-QP-16.0 or CP-QAP- .

16.1. It appears we will have to obtain copies of the entim manuals j in order to get answers to our interrogatories.)

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