ML20206S568

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

ML20206S568
Person / Time
Site:	Comanche Peak
Issue date:	09/16/1986
From:	Garde B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Shared Package
ML20206S559	List: ML20206S556 ML20206S562 ML20206S568
References
OL, NUDOCS 8609220270
Download: ML20206S568 (10)

Text

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,MAAIED GUMMtDFUNUCNW 9

BEFORE THE 00CKETED UNITED STATES USNRC NUCL8AR REGULATORY COMMISSION 8efore the Atomic Safety and Licensing Bo 0FFICE Or 3!C 1TARY In the Matter of ) C0CKE. TING ^ Y MLE

) ERM!H TEXAS UTILITIES GEN 8 RATING COMPANY, ) Dkt. Nos. 50-445-OL et al. ) 50-446-OL

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

CPRT DISCOVERY - 5 Tnese questions are based on the July 23, 1986 Revision 2 to Appendix E of the CPRT, and on information presented by members of the CPRT at the public meetings on the CPRT between the staff and the Applicant.

1. Identify by name, position and employer the person or persons for each ISAP or DSAP who is responsible for determining whether an " unsatisfactory ites" noted on a CPRT checklist is a deviation, discrepancy, or deficiency. Indicate what, if any, connection this person has to the Applicants such as employee, consultant, employee of consultant, contractor, etc. (include any former connection to Comanche Peak) and describe the control which Applicants have over this person.

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2. Iaentify the procedure or procedures used to classify or l determine whether or not an " unsatisfactory item" noted on a CPRT inspection checklist is a deviation, discrepancy, or deficiency.

3. Does the safety-significance evaluation group (SSEG) review all of the completed checklists f rom all ISAPs and DSAPs l

to identify unsatisfactory items for evaluation? I l

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a. If the answer to the above question is yes, explain in precise detail, what the process is by which the review is accomplished.

b. If the answer to the above question is no, explain in precise detail, the process by which the SSEG receives any inputs from the CPRT programs.

5. Explain the process in precise detail, using examples from released results reports where helpful, how discrepancies are " classified into categories of real tive significance."

a. Identify all categories used for classification.

b. Identity the types of bases used to establish the classification, and identify on what forms the bases will be documented.

6. Explain, in precise detail, what a discrepancy is. (Use examples from completed checklists available to CASE or other checklists attached to your answer.)

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7. To what extent, if any, do the inspection checklists

! record differences between the as-built as installed hardware and i

information recorded on the the original inspection checklists.

Example: The CPRT identifies an unsatisfactory item for attribute A.

, Attribute X was also an attribute on the original quality control inspection report, i'

where it is marked " sat". On what form or in

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what place does the CPRT identify the failure of the original QA/QC inspection to identify the unsatisfactory item.

8. Identify the person, persons, or groups who are responsible for the classification of design discrepancies as observations, deviations, or deficiencies discussed in Appendix E, on page 1.

9. For each design review or inspection describe which documents of the original package are included in the review process.

10. For each design review of inspection identify each attribute for which the original inspection reports are includea in the inspection process.

11. Explain, in precise detail, what an " identified error" is as it is used on page 1 of Appendix E.

12. Describe in detail the process which is used to decide what is a safety-related structure, system, or component that I

could have an adverse impact on the adequacy of the desiclide.

13. Explain in precise detail, the process by which an identified design discrepancy "is determined" to not constitute a design deviation and therefore becomes a design observation.

14. Explain, in precise detail, what is a " verified failure to meet a design commitment or specification." Include in the definition which of the original commitments and specifications are included and which are excluded.

15. explain in precise detail, the process by which an

l identified design discrepancy is determined to be a " verified failure to meet a design commitment or specification."

16. Identify the person or persons (see instructions) who l

make the determination on whether a set of related design discrepancies constitute an adverse trend.

17. Identify all person or persons (see instructions) who are responsible for classifying construction discrepancies as deviations or deficiencies.

18. Explain in precise detail (see instructions) the process through which an unsatisfactory item on a checklist becomes a discrepancy or deficiency.

19. In regards to the classifications made of boo-boos (see CPRT Discovery - 4, Q. 2) in the construction adequacy program, what definition is used to describe a f ailure of the original inspection to identify the boo-boo?

20. Identify the person or persons (see instructions) who make the determination that a set of related construction deviations constitutes an adverse trend.

21. Describe or identify the CPRT program element that identifies failures of the original QA/QC inspection process to identify a condition which was unsatisfactory at the time of the original inspection.

22. To what extent does the QA/QC program adequacy intend to draw conclusions or make statements about the implementation in compliance with 10 CFR Part 40, Appendix B, of the original QA/QC program?

23. explain in precise detail, using examples if helpful,

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what is or woulo be a " verified f ailure" of the QA/QC program to meet a regulatory requirement.

24. Identify the CPRT procedures or checklist used to determine what is a " verified failure of the QA/wC program."

25. Describe in precise aetail the process by which a verified failure of the QA/QC program becomes a QA/QC program deficiency.

26. Explain in precise detail (see instructions) what would be a " substantive revision of the program" as used on page 4 of Appendix E in evaluating the inadequacy of a QA/QC program element.

27. Explain in precise detail (see instructions) what the term extensive evaluation" means as used on page 4 of Appendix E.

2o. Explain in precise aetail (see instructions) what a

" set of related QA/QC deviations" is as used on page 5 of Appendix E.

29. Identify the person or persons (see instructions) who make the determination when a set of related QA/QC deviations is determined to constitute an adverse trend that is programmatic in nature.

30. Explain in precise detail (see instructions) how the CPRT program determines if a trend "is likely to have resultea in the occurrence of an undetected deficiency in the affected area, population or stratum."

31. Explain in precise detail (see instructions) what an

" unclassified trend" is as used on page $ of Appendix E.

32. Identify all procedures, or checklists, used to conduct the evaluations for adverse trends as discussed on page 5 of Appendix E.

33. Describe in precise detail, (see instructions) the process by which an identified trend will be evaluated. (pgs.5-7)

34. Explain in precise detail (see instructions) the factors considered when deciding whether it is more practical or expeditious to not perform a safety-significance evaluation.

(Id.)

35. Identify the procedures or source documents on which

" unclassified deviations" would be found. (Id.)

36. Describe, or identify, the process by which unclassified deviations or trends will be traced for purposes of root cause and generic implications.

37. Identify or explain the criteria for identifying "special cases" in which it would be appropriate to take or do actions beyond those listed in the program plan.

36. Identify the person or persons who decide whether or when it would be appropriate to'take or do actions beyond those listed in the program plan.

39. Describe in precise detail (see instructions) how the CPRT insures that "all deviations" are transmitted to the CPSES project for evaluation and disposition.

40. Describe in precise detail (see instructions) the process by which the CPRT determines that appropriate corrective action has been defined for the non-conformance associated with the deviation.

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41. Describe in precise detail (see instructions) the process by which the CPRT determines that appropriate corrective action has been accomplished for the non-conformance associated with the deviation.

42. Describe in precise detail, (see instructions) how it is determined what is the "affected area, population or stratum" of the generic implications of the deficiency.

43. Describe in precise detail, (see instructions) how the CPRT will determine whether appropriate corrective action has been accomplished for- the non-conformance associated with each deficiency.

44. Describe in precise detail (see instructions) how a trend which is not classified as an " adverse trend" is dealt with under the CFRT.

46. Identify how the results of adverse trends will be documented and reported.

47. Produce for inspection and copying all documents identified in the answers to these interrogatories and all I

documents examined and/or relied upon in providing answers to i these interrogatories.

Respectfully submitted, h L/

BILLIE P. GARDE Trial Lawyers for Public Justice 2000 P Street, NW, #611 Washington, D.C. 20036 (202) 463-8600 Counsel for CASE Dated: September 16, 1986

,ct.t A tt U G u n n G N N U M UNITED STATES OF AM8RICA 00CMETED NUCLEAR R8GOLATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gg gp gg In the Matter or ) 0FFICE OF SE at.),ay

) 00CHETING & SERVICT' TEXAS UTILITIES G8N8 RATING ) BRANCH CUMPANY, et al. ) Docxet Nos. 50-445-OL

) and 50-446-OL (Comancne Peak Steam Electric )

Station, Units 1 ano 2) )

CERTIFICATE OF SERVICE By my signature Delow, I hereby certify that true and correct copies of CASS's CPRT DISCOVERY - 4, CPRT DISCOVERY - 5, and NOTICE OF APPEARANCE OF uILLIE FIRNER GARDs have been sent to tne persons listed oelow this 16th day of Septemoer 1986 by:

Express mail where indicatea by *; dand-delivery where indicated of **; ana First Class Mail unless otherwise indicated.

Aaministrative Juoge Peter 8. Bloch U.S. Nuclear Regulatory Commission

. wasnington, D.C. 20356 Dr. Kennetn A. McCollom 1107 West Knapp Stillwater, Oklahoma 740/5 Dr. Walter H. Joraan 861 W. Outer Drive Oax Ria9e, Tennessee J7o30 Elizabetn d. Johnson oak Rioge National Laboratory P.O. dox X, Building 3500 Oak R1 age, TN 37030

. 811en Ginsoerg, 8sq.

O'S. Nuclear Regulatory Commission

. washington, D.C. 20555 Rooert A. Wooloriage, Esquire Worsham, Forsythe, Sampels s wooloriage ,

2001 aryan Tower, Suite J200 uallas, Texas 75201 Nicholas Reynolos, Esquire aisnop, Lioerman, Coon, Purcell = xeynolos 1200 17 th Gtreet, N.w.

washington, D.C. 20036 Geary S. Hizuno, Esquire Office or Sxecutive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20553 Docketing & Service Section

, Orrice of the Secretary U.S. Nuclear Regulatory Commission wasnington, D.C. 20s55 Renea Hicks, dsguire Assistant Attorney General Environmental Protection Division Supreme Court duilding Austin, Texas 7o711 Mrs. Juanita Ellis Presioent, CASE 142o S. Polk callas, Texas 75224 Mr. W.G. Counsil Executive Vice President Texas Utilities Generating Co.

4 Skyway Tower, 25th Floor 400 N. Olive Street Dallas, Texas 75201 Mr. Roy P. Lessy, Jr.

, Morgan, Lewis & Bockius -

1000 n Street, N.W.

wasnington, D.C. 20036

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.Mr..Tnomas G. Dignan, Jr. I Ropes & Gray 22S Franklin Street  :

Boston, Massachusetts 0211u )

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