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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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dEFOMS Trit. 00CMETED UNITED STATES NUCL8AR R8GULATORY COMMISSION Before tne Atomic Safety and Licensing-Board
. . '86 SEP 18 All:25 0FFICE OF !! D.Lin '
In tne Matter of ) 00CKETIN'i A sir en.!.
BP:J m
)
TEXAS UTILITIES GENERATING COMPANY, ) Dkt. Nos. 50-445-OL et al. ) 50-446-OL
) {
(Comanche Feak Steam Electric )
Station, Units 1 ano 2) ;
CPRT DIECOVERY - 4 APPENDIX d
- 1. 8xplain, in precise detail, how the completion of tne first and second component of the CPRT (described in Appendix B, summarized in the last two paragraphs of 99 2) will fully.
resolve and/or fully cound the safety-significant implications of deficiencies in the CPSES construction VA/QC program?
- 2. Appendix e (page 31 states tnat the self-initiatea component of the CPRT will permit the CPRT to make a firm statement about the "... acequacy of tne VA/vC program employed during its construction". Explain, in precise detail, witn reference to the elements of the program plan, what ISAPs/0 SAPS explore tne f ailures of the QA/gC program to meet original commitments witnout regard to tne adequacy of tne resultant hardware. (Throughout these discovery requests, the railure of QA/uC to meet an original commitment, sucr. as failing to report an unsat conuition, it it is not aeemed a oeficiency or a 4
~
8609220266 860916 PDR G ADDCK 05000445 PDR
, discrepancy by the CPRT, will oe referred to here as a " boo-boo."
- 3. Appendix B provides for the DAP to report " areas of concern" involving design control processes required by 10 C.F.R.
50, Appendix 8, Criterion III to the QA/QC Review Team Leader for evaAuation. In regards to this element of the program:
- a. Identify all procedures or documents which are used in the identification of the area of Concerns.
- b. Explain, in precise detail, the term
" areas of concern" as used on page 3 of Appendix 8, including but not: limited to how design observation becomes an area of concern, wno is responsible for making the decision whether a boo-boo is an area of concern, and what source documents are reviewed to determine if a boo-boo is an area of Concern.
- c. Ioentify all forms or procedures used to provide the concern to the QA/QC RTL for evaluatioa.
- d. Identity, by name and form number, the procedures used to perform the evaulation rererreo to on page 3.
- e. Ioentify the person or persons responsible for conducting the assessment of the concerns.
- f. Ioentity the procedures used to perform the assessment and if required, the analysis
_3 described on page 3, para. 4.
- 4. Provide tne matrix referreo to on pg. 4, para. 7.
- 5. Explain, in precise terms, how a concern is determined to be " valid" in order to be tracked on the matrix.
- 6. Identify the person or persons from the QA/QC review team assigneo to oevelop the matrix.
- 7. Explain, in precise detail, the circumstances under which external source issues would not be adequately addressed oy existing ISAP's such that revisions ot ISAPs or new ISAPs would be necessary. (Page 4)
- d. Explain in precise oetail now a review and verification of an already implemented TUGCo Corrective Action program would be used to provide additional data to the collective evaluation process.
- a. Identity each TUGCo. program wnich falls into the description provide in response to question 6.
- b. For each pro 3 ram identified provice the following information:
- 1. When tne program was instituted.
- 2. If concluded, when the program was concluded.
- 3. What was the original impetus or !
the program.
- 4. Name the organization and the principal individuals responsisble
- 4. Provide the matrix referred to on pg. 4, para. 7.
- 5. Explain, in precise terms, how a concern is aetermined to oe " valid" in order to be tracked on the matrix.
- 6. Identity the person or persons f rom the QA/QC review team assi*gned to develop the matrix.
- 7. Explain, in precise detail, the circumstances under which external source issues would not be adequately addressed by existing ISAP's sucn tnat revisions of ISAPs or new ISAPs would be necessary. (Page 4)
- d. 8xplain in precise detail how a review and verification of an already implemented TOGCo Corrective Action program woulo De used to provide auditional data to the collective evaluation process.
- a. Identify each TUGCo. program whicn falls into the description provide in response to question 8.
- o. For eacn program identified provide the following information:
- 1. Wnen the program was instituted.
- 2. If concluded, when the program was concluded.
- 3. What was the original impetus of the program.
. 4. Name tne organization and the principal individuals responsisole '
tor conducting the program.
- 9. List all the procedures used in developing and/or implementing the CPRT activities described in Appendix 8.
- 10. Identify all evaluations which will be conducted by another Review Team instead of the Safety Significance dvaluation group.
- 11. Identify the form or procedure used by the safety-significant evaluation group to identify design-related deviations in oraer to turn them over to the Design Adequacy Review Team.
- 12. Explain in precise detail the actual methodology by which the CPRT will determine,
- a. the root cause of any safety-significant deficiences,
- o. the generic implications of the root cause in order to determine if other areas of hardware might contain safety-significant deficiencies attributable to the same root cause, and .
- c. how it will be determined if additional hardware evaluations would be required to establish root cause or to bound the root cause or determine generic implications.
- 13. 8xplain how the SIE will "save timd* in the resolution of areas which the category I ISAPs indicated had generic implicatior.s as a result of the root cause determination.
i
- 14. Explain how the SIB resolves tne concerns that mi9nt exist about the QA/vC program breakdown which results from evidence of inadequate qualifications of QC inspectors in the 1
.. past.
- 13. explain how the SIE resolves concerns that might exist aoout the QA/QC programs implementation over the history of tne project as a result or potential occurrence of harassment, intimidation, or pressure of gC inspectors.
lo. To tne extent that the presentation or Mr. Hansel and others at the Octooer 2 or 3, 1985 puolic meeting, does not
- adequately aescrioe or explain or differs from now the installed safety-related hardware was categorized into populations, and then into homogenous work activities, provide a correct explanation.
- 17. Iaentity each population into which safety-related haraware was/is categorized (App. B, pg.d-9).-
lo. Identify the person or persons wnose " experience" was relied upon to categorize each of the populations identified aoove. (App. B, pg.8-9).
- 19. Identify for eacn population the " reasonably homogenous work activities" identified. (App. B, 99 8-9).
- 20. Describe, in detail, the process used to determine-whica " quality characteristic" tor eacn HWA to use.
- 21. Iaentify each quality characteristic for each HWA which will be verifiea, and which characteristics will be veritied oy sampling methods and wnich characteristics will be verifiea of actual inspection or the installed work (99 8, et seq.).
- 22. Identity, ror each attribute of each dwA, which
. attributes will be reinspected and which attributes will oe reviewea tot samples of the hardware. (pg.9)
- 23. Explain the process in detail, including identifying the procedures used to accomplish the tasks described in the above questions.
- 24. Identify (by name, job title, entity employed by, supervisor) the person or persons responsible for selection of the samples described on page 9, paragraph 2 of Appendix 8.
Include in your response the person or persons (identified by name, job title, entity employed by, supervisor) responsible for selecting the subset of the population defined as "having greater importance to satety."
- 25. Identify the procedures or instructions used by the individuals identiried in response to the previous question to accomplish the sample selection process.
- 26. Idenfity all sources of input to the collective evaluation of CPRT findings, observations, and conclusions that relate to the adequacy of the CPSSS construction QA/QC program.
- 27. Ioentify all sources of input to the collective evaluation of CPRT findings, observations and conclusions that relate to the quality of the installed hardware at CPSES.
- 28. Identify (by name, job title, entity employed by, i supervisor) the person or persons who are responsible for preparing each of the collective evaluation reports identified above.
- 29. Describe in detail the process oy wnich the two collective evaluations will be merged to torm tne summary report 1
O O
-g-on tne QOC.
30.
Identity (by name, job title, entity employed by, supervisor) tne person or persons responsiole to preparing tne VOC Summary Report.
31.
Explain now the SIE resolves concerns that might exist about the VA/QC program's implementation over the history of tne project as a result or the potential f ailure of management to possess or exhibit the proper character or competence to properly implement the VA/QC program.
- 32. Produce for inspection and copying all documents identified in the answers to these interrogatories and relied upon or examined in the course of answering these interrogatories.
Respectfully submitted, Billie P. Garde pf 'T' Trial Lawyers for Public Justice ,.
2000 P Street, Nd washington, D.C. !
20036 !
(202) 463-8600 Counsel for CASE Dated: September 16, 1986 l
l 1
,