ML20092P252

Second Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20092P252
Person / Time
Site:	Byron
Issue date:	06/28/1984
From:	Cassel D BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES
To:	COMMONWEALTH EDISON CO.
Shared Package
ML20092P250	List: ML20092P249 ML20092P252
References
NUDOCS 8407060103
Download: ML20092P252 (5)

Text

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s UNITED STATES OF AMERICA r NUCLEAR REGULATORY COMMISSION. egQt

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B_EFORE THE ATOMIC SAFETY AND LICENSING BOARD

'84 J1 -5 P1 :54 In the Matter of:

COMMONWEALTH EDISON COMPANY ) hla. ~NiZ.i;.u..

) Docket Nos. 44544 (Byron Nuclear Station, ) 50-455 Units 1 and 2) )

INTERVENORS' SECOND REQUEST TO EDISON FOR PRODUCTION OF DOCUMENTS s

As used herein, the term " document" means all writings and recordings of any kind, including but not limited to notes, l memoranda, summarios, drafts and computer stored and/or generated data in the possession, custody or control of Edison or its contractors. The term "mootings" includes telphone conversa-tions. The term " contractor" includes all contractors at Byron including the architect-engineers and the independent testing laboratories. The term " consultant" includes any expert or person '

l with expertise consulted by Edison and/or its contractors in connection with the Byron plant.

l Please produce the following documents:

1. All welding proceduro specifications, used by the Hunter Corporation, Hatfield Electric Corporation, and Pittsburgh Testing Laboratories, either to install or inspect hardware at the Byron Nuclear Station. This request includes welding specifi-cations created by Sargent & Lundy, Commonwealth Edison, any contractors to Commonwealth Edison, and their consultants.

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2. All names, line-by-line program listings, test run documentations, and program use manuals for SEISHANG, PIPSYS, and other "in-house" computer programs employed by Sargent &

Lundy in its desi;n of the Byron Nucicar Station, and utilized by Sargent & Lundy, the Nucicar Regulatory Commission, and inspectors for Commonwealth Edison, the Hunter Corporation, Hatfield Electric Corporation, and Pittsburgh Testing Laboratories, during the reinspection program conducted in response to the 82-05-19 noncompliance.

3. All ..a-an of connercial, time-share computer programs employed by Sargent & Lundy in its design of the Byron Nuclear Satation, and utilized by Sargent & Lundy, the Nuclear Regulatory Commission, and inspectocs for Commonwealth Edison, the Hunter Corporation, Hatfield Electric Corporation, and

, Pittsburgh Testing Laboratorica, during the reinspection program conducted in response to the 82-05-19 noncompliance.

4. All " pro-format," or standardized forms, used in l connection with the computer programs and manuals referred to in Document Requesta 2 and 3, above.

5. Any design tables and enginocring procedures, developed by Sargent & Lundy, the llunter Corporation, Hatfield Electric Corporation, Pittsburgh Testind Laboratorica, Common-wealth Edison, or consultants to any or the above firms, for l

construction of the Byron Nuclear Station and/or used to review results from the ruinspection program at this facility. This request includes, but in not limitud to, a design table identi-find in Sargent & Lundy Wold Surveys for Byron and 1. aidwood as

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" Technical Training Design Packar,o DV-89: Design Table for Varying Widths of Auxiliary Stcol" (Bates Stamp No. S0005034),

6. Any design guides or other references employed to assist Sergent & Lundy, the Nucicar Regulatory Commission, Commonwealth Edison, the llunter Corporation, Hatfield Electric Corporation, and Pittsburgh Testing Laboratories, in their evaluation of mathematical calculations concerning the inspection l and reinspection programs contlucted at the Byron Nuclear Station, i

j DATED: June 28, 1984 D

mb M CUf55 W. CASSEL \

l One of the Attorneys for )Intervenors on issues and matters pertaining to quality assurance l

l Douglass W. Cassel 109 North Dearborn Suite 1300 Chicago IL 60602 (312) 641-5570 l

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WIMrc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ""'"i U;,gg", kl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -

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In the Matter of )

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COMMONWEALTil EDISON COMPANY ) Docket No. 50-454

) '50-45Si'cc'

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(Byron Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copios of "INTERVENOR'S SECOND REQUEST TO EDISON FOR PRODUCTION OF DOCUMENTS" in the abovo-onptioned proceeding have boon served on the following by deposit in the U.S. Mail, first class. or as indiented by an astorisk, by Federal Express, this 2nd day of July, 1984, or as indicated by two nsterisks, by hand-delivery on June 28, 1984 elvan W. Smith, Chairman # Stephen Lowls Administrative Judge Offico ,f Executivo Legal Atomic Sarcty and L1 conning Director Board U.S. Nucionr Reguintory U.S. Nucionr Regulatory Comminston Commission Washington, D.C. 20555 Washington, D.C. 20555 Offico of the Socrotary of

1. Dr. A. Dixon Cn11than thn Comminston Administrativo Judge Attn Docketing & Servico Union Carbido Corporation Section P.O. Box Y U.S. Nucicar Regulatory Oak Ridge, Tennessee 37830 Comminnion Washington, D.C. 20555

1. Dr. Richard r'. Colo Administrativo Judge Alnn S. Rosenthal, Chairman Atomic Safety and Licensing Administrative Judge Board Atomic Saroty and Licenalng Doned U.S. Nucionr Reguintory U.S. Nucionr Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

1. 1. Michnol I. Millor, Esq. Iloward A. Wilbur Isham Lincoln & Donio \dministrntivo Judge Throo First Nationni Pinza Atomic Snfoty & Liaonning Donrd Chiongo, IL 60603 U.S. Nucionr Regulatory Commission Washington, D.C. 20555

Dr. Reginald L. Gotchy Joseph Gallo Administrative Judge ISHAM, LINCOLN & BEALE Atomic Safety & Licensing Board 1120 Connecticut Avenue N.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 General Counsel Region III Office of Inspection and Enforcement 799 Roosevelt Road Glen Ellyn, IL 60137 DATED: June 15, 1984 Joshua Levin Law Clerk to Jane M. Whicher Subscribed and Sworn to before me this 2nd day of July, 1984.

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