ML20079J357

Answers to NRC Second Set of Interrogatories Re Contention 1A.Certificate of Svc Encl.Related Correspondence

ML20079J357
Person / Time
Site:	Byron
Issue date:	12/22/1982
From:	Morrison P LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8212280188
Download: ML20079J357 (5)

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_ UNITED STATES OF AMERICA 12/22/82 s NUCLEAR REGULATORY COMMISSION agg'ran en, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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. LEAGUE ANSWERS TO NRC STAFF SECOND' SET OF INTERROGATORIES RE CONTENTION lA Intervenor Rockford League of Women Voters hereby answers the NRC Staff Shcond Set of Interrogatories with respect to contention

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Interrogatory 1A-1: Identify and list all the specific QA/QC deficiencies at Byron upon which Contention lA is based and identify the Inspection Reports, if any, that note such specific QA/QC de ficiencies .

Answer to Interrogatory-1A-1: The League relies on all QA/QC deficiencies noted in the following documents , all of which have previously been served on the NRC staff and on all parties:

(1) DAARE/ SAFE's Motion to Reconsider Summary Disposition With Respect to Quality Assurance and Quality Control, dated September 23, 1982, and supporting exhibits; (2) Petition of DAARE/ SAFE For Waiver of or Exception to n

y Financial Qualifications Regulations, dated July 30, 1982, exhibits Q through W; (3) All QA/QC deficiencies noted in the League's prior interrogatory answers, l

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o The League's new counsel will promptly review additional QA/QC documents obtained from the League's former counsel, and the League will thereafter supplement this answer as soon as possibic.

Interrogatory 1A-2: State in detail the basis for the assumption that deficiencies identified at plants other than Byron are relevant to the operational safety of the Byron plant.

7 Answer to Interrogatory 1A-2: Deficiencies identified at plants other than Byron are relevant, not by way of " assumption" as the interrogatory incorrectly suggests, but as a matter of law and fact. Such deficiencies are relevant in at least the following i ways:

(1) Deficiencies at other Edison plants are attributable in part to the same applicant, with the same management, whose policies and program and budgetary priorities with respect to QA/QC at any other plant are relevant to showing their QA/QC policies and priorities at Byron.

(2) Deficiencies at other Edison plants reflect deficiencies in Edison's company-wide QA/QC program, which affect Byron as well.

(3) Deficiencies at other Edison plants, to the extent attributable to deficiencies in Edison's employment and training of QA/QC personnel, are likely to arise and to have arisen for the r,ame reasons at Byron.

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I Deficiencies at other Edison plants, to the extent attrib utable to Edison's excessive reliance on contractors ' QA/QC representations, and indeed Edison's discouraging contractorn from

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k adequate QA/QC efforts and knowingly acquiescing in QA/QC short-comings, are likely to arise and to have arison for the same reasons at Byron.

(5)[ Deficiencies at other plants , to the extent attributable to the same contractors or subcontractors as are (or have been) engaged at Byron, are relevant to the QA/QC programs of thesec contractors at Byron.

(6)) Defic encies at other plants , to the extent attributable

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to a pattern of oversight or other omission or inadequacy by NRC Region III personnel, are likely to be subject to the same pattern at Byron.

(7) , Pa'tterns; of QA/QC deficiencies is at a number of other 1 .

plants may also ' bear on the. significance and likelihood of recurrence'of similir_QA/QC problems at Byron.

(8)- QA/QC problems at oth'er plants of similar design are helpful in identifying QA/QC problem areas at Byron, and the results of these problems at other plants bear on the safety significance of QA/QC problems at Byron.

(9) Additional relevancies may arise with respect to particular QA/QC deficiencies at particular plants.

. Rockford League of Women Voters i December 22, 1982

, W OM'Ufon Pat Morrison e President

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1 WEjg.E0 CERTIFICATE OF SERVICE

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'82 DEC 27 P4:28 I hereby certify 'that I have served copies _of Leagtye . Answers acnturiisije,vis to NRC Staff Second Set of Interrogatories Re Conisiiliton 1A on each of the persons listed on the attached Service List by n

) causing them to be deposited in the United States mail, first class postage prepaid, this 22nd day.of December, 1982.

Douglass W. Cassel, Jr.

Jane M. Whicher December 22, ,1982 _

eM b DougiassW.Cassel, Attorneys for Rockford League of Women Voters on issues and matters relating to quality assurance / quality control

'I Douglass W. Cassel, Jr.

Jane M. Whicher 109 North Dearborn Suite 1300 Chicago, IL 60602 (312) 641-5570

...t SERVICE LIST Ivan W. Smith,' Chairman Steven C. Goldberg, Esq.

Administrative Judge Office of the General Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington , D.C. 20555 Dr. A. Dixon Callahan Office of the Secretary of Administrative Judge the Commission Union Carbide Corporation ATTN: Docketing & Service P.O. Box Y- Section ,

Oak Ridge, Tennessee 38730 U.S. Nuclear Regulatory 1 Commission Washington, D.C. 20555 Dr. Richard F. Cole Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Ccmmission Washington, D.C. 20555 Alan P. Bielawski, Esq. Joseph Gallo, Esql Isham Lincoln & Beale Isham Lincoln & Beale LE<Dee First National Plaza 1120 Connecticut Avenue, N.W.

-51st Flcer Room 325 Chicago, IL 60603 Washington, D.C. 20036 Ms. Betty Johnson 1907 Stratford Lane Ro ck fo rd, IL 61107 n

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