ML20128F492

First Set of QA Interrogatories & Request to Produce.Related Correspondence

ML20128F492
Person / Time
Site:	Braidwood
Issue date:	07/02/1985
From:	Guild R GUILD, R., ROREM, B.
To:	COMMONWEALTH EDISON CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20128F497	List: ML20128F492 ML20128F499 ML20128F505 ML20128F509
References
CON-#385-674 OL, NUDOCS 8507080259
Download: ML20128F492 (24)

Text

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RELATED CORRESPONDEM E

7/2/85 Deus hc u

UNITED STATES OF AMERICA E JR. -5 A10 :54 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD [0CkifhG BRANCH hfl[f In the Matter of: )

COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50 4560'

('Braidwood Nuclear Power ) 50 457N-Station, Units 1 and 2) )

ROREM, ET AL., QUALITY ASSURANCE INTERROGATORIES AND REQUESTS TO PRODUCE, FIRST SET Pursuant to 10 CFR Sections 2 720(h)(2)(ii), 2.7 40 b , 2.741 and 2.744, Bridget Little Rorem, et al., ("Intervenors") hereby serve their Quality Assurance Interrogatories and Requests to Produce, First Set, upon the Applicant and the NRC Staff. These interrogatories involve Intervenors' amended quality assurance contention admitted June 21, 1985.

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Each interrogatory should be answered fully in writing, under oath or affirmation, and include all pertinent information known to the NRC Staff and the Applicant, including their officers, directors, employees, agents, advisors or counsel. Each request to produce applies to pertinent documents which are in the l possession, custody or control of the NRC Staff and the Appli-cant, including their officers, directors, employees, agents, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceding each answer or response. Also, please identify the person providing each answer or response.

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These interrogatories and requests shall be continuing in nature. Thus, whenever information is obtained which renders any previous response incorrect or indicates that a response was incorrect when made, a supplement should be made to the previous response to the appropriate interrogatory or request to produce.

Supplements should be made to the responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. Intervenors are particularly interested in the names and areas of expertise of witnesses, if any. Such identification of witnesses is neces-sary if Intervenors are to be afforded adequate time to depose them.

The term " documents" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained. Intervenors request that at a date or dates to be agreed upon, the NRC Staff and the Applicant make available for inspection and copying, all documents subject to the requests set forth below.

l REQUESTS TO PRODUCE Pursuant to 10 CFR Sections 2 741 and 2 744, Intervenors request that the NRC Staff and Applicant make available for inspection and copying at a time and location to be designated, but as soon as possible, any and all documents, of whatsoever description, identified in the responses to the interrogatories below, including but not limited to:

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(1) any written record of any oral communication between or among Applicant, the NRC Staff, either of their contractors, advisors, consultants, agents, attorneys and/or any other persons, including but not limited to l the NRC Staff, Applicant, Intervenors, and their advisors, consultants, agents, attorneys and/or any other persona; and (2) any documents, correspondence, letter, memorandum, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but i

not limited to workpapers, prior drafts, and notes of meetings.

If NRC Staff and/or Applicant maintain that any documents should not be made available for inspection, they should specify the documents and explain why such are not being made available.

This request extends to any such document, described above, in the possession of Applicant, NRC Staff and their advisors, consultants, agents or attorneys.

l INTERROGATORIES Pursuant to 10 CFR Sections 2.740b, 2.720(h)(2)(ii), Inter-venors requests NRC Staff and Applicant, by and through their attorneys, to answer separately and fully in writing under oath or affirmation, by persons having knowledge of the information requested, the following interrogatories:

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. s A. General Interrogatories The following interrogatories apply severally to each part of the quality assurance contention admitted as issues in controversy in this proceeding.

1. Please state the full name, address, occupation and employer of each person answering the interrogatories or assist-ing in the preparation of such answers, and designate the inter-rogatory or the part thereof he or she answered.

2. Please identify each and every person whom you are considering to call as a witness at the hearing in this matter on this contention, and with respect to each such person, please:

a. State the substance of the facts and opinions to which the witness is expected to testify;

b. Give a summary of the grounds for each opinion; and

c. Describe the witness' educational and professional background.

3 Is your claim or defense on the contention based on one or more calculations? If so:

a. Describe each calculation and identify any documents setting forth such calculation.

b. Who performed each calculation?

c. When was each calculation performed?

d. Describe each parameter used in such calculation and each value assigned to the parameter, and describe the source of your data.

e. What are the results of each calculation?

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f. Explain in detail how each calculation provides a basis for your claim or defense.

4. Is your claim or defense on the contention based upon conversations, consultations, correspondence or any other type of communications with one or more individuals? If so:

a. Identify by name and address each such individual.

b. State the educational and professional background of each individual, including occupation and institutional affiliations.

c. Describe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.

d. Describe the information received from such individuals and explain how it provides a basis for the issue.

e. Identify each letter, memorandum, tape, note or other record related to each conversation, consultation, correspondence, or other communication with such individual.

'B. Specific Interrogatories

1. Do you agree that the Braidwood Quality Assurance (QA) Program must comply with each of the criteria of Appendix B to 10 CFR Part 50 in order to establish Applicant's entitlement to the licenses sought in this proceeding?

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2. If the answer to No. 1 is negative, please describe in detail the respects in which such compliance is not required and explain fully the factual and legal basis for your position.

3 Does the Braidwood Quality Assurance Program comply with each of the criteria of Appendix B to 10 CFR Part 507

4. What are the bases for your responses to Nos. 1-37 Please identify all documents, physical evidence, testimony or oral statements by any person and legal authority on which you rely in support of your position.

5. Does workmanship in the actual design, fabrication, construction and testing of safety-related structures, systems and components meet or exceed all applicable standards?

6. Please identify all sources of standards (e.g., FSAR, ASME Code) applicable to the actual design, fabrication, construction and testing of safety-related structures, systems, and components.

7. If the answer to No. 5 is negative, please describe in detail the respects in which such workmanship does not meet or exceed all applicable standards or is indeterminate, and explain fully the factual and legal basis for your answer.

8. What are the bases for your responses to Nos. 5-77 Please identify all documents, physical evidence, testimony, or oral stctements by any person and legal authority on which you rely in support of your position.

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9. Please identify each deficiency in design and construc-tion as defined in 10 CFR Section 50.55(e) and for each indicate:

the classification of its significance (i.e., classified under which subsections, 50.55(e)(1)(1-iv); the 10 CFR Part 50 Appendix A, General Design Criteria, to which each relates and the respects in which it reflects noncompliance; the report number, and date, if any; the names, titles, addresses, and telephone numbers of each person responsible for the deficiency, its discovery, its reporting, and its corrective action; a detailed description of the deficiency and its safety implications; a detailed descrip-tion of its corrective action.

10. For each activity under license by NRC conducted by Commonwealth Edison, its contractors and subcontractors involving any nuclear facility or operation, including but not limited to Braidwood, please identify each deficiency, as defined in 10 CFR Section 50.55(e), which represents a significant breakdown in any portion of the Braidwood Quality Assurance Program conducted in accordancis with the requirements of Appendix B to 10 CFR Part 50; identify the Appendix B criteria to which it relates; describe in detail the respects in which the deficiency reflects a noncom-pliance with the requirements of Appendix B criteria; the 10 CFR Part 50 Appendix A, General Design Criteria, to which each relates, if any, and the respects in which it reflects noncom-pliance; the report number and date, if any; the names, titles, addresses and telephone numbers of each person responsible for the deficiency, its discovery, its reporting, and its corrective 7

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I action; a detailed description of the deficiency and its safety implications; and a detailed description of. Its corrective action.

11. Please identify all audits conducted pursuant to 10 CFR Part 50 Appendix B Criterion XVIII or otherwise, including but not limited to the 1980 audit of Phillips-Getschow referred to in the June 29, 1984 letter from George Marcus of Commonwealth Edison to Mari Kaye Roth of Peterson & Co., and any audits by or

, under guidance of the Institute for Nuclear Power Operation

(INPO). For each reported observation, discrepancy, deficiency J or weakness, indicate

the nature of the deficiency; the Appen-dix B criteria, if any, to which it relates and the respects in l which noncompliance is reflected; the date and other identifying

) information of the audit documentation; the names, titles, addresses and telephone numbers of each person responsible for the deficiency, the performance of the audit, the management review of the results and its corrective action; a detailed description of the deficiency and its safety implications; a j detailed description of its corrective action.

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12. Describe in detail each review of the Braidwood Quality Assurance Program by the NRC Staff. For each, please indicate

! the deficiencies found, the adjustments, modifications and i

improvements resulting or otherwise made; the Commonwealth Edison i

position and responses; the names, titles, addresses and tele-phone numbers of each person involved and a description of the

involvement of each.

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13 Please describe in detail the selection, training, testing and evaluation program for Quality Assurance personnel and Quality Control Inspectors for Edison and for each contractor responsible for any safety-related construction at Braidwood from l the commencement of construction until the present.

14. Please describe the job qualifications required of persons who are responsible for training, testing, certifying and supervising Quality Control Inspectors.

15. Does Commonweath Edison and its contractors have a pro-l gram which insures the integrity of the testing and qualification for Quality Control Inspector certification? if so, please describe in detail the program or programs, all variations and changes in the program since construction began, and describe in detail and identify any deficiencies found in such testing and

qualification.

16. What prior nuclear experience is required of persons responsible for supervising Quality Control Inspectors for (a)

Edison, and (b) for each contractor at Braidwood?

17. Please describe in detail the circumstances and procedures, if any, under which Quality Control inspection l

l criteria may be waived.

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18. With respect to each NRC Staff inspection report l

regarding quality assurance at Braidwood, please identify, and make available for inspection and copying, all correspondence by 9

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and between the NRC Staff and Commonwealth Edison or its contrac-tors regarding such inspection and any corrective action.

19. Please provide the names, titles, addresses, telephone numbers and date of employment for all persons who have been employed in or responsible for the Quality Assurance and Quality Control Programs of Edison and of each contractor, including but not limited to all quality control inspectors and supervisors.

For each such person no longer employed in Quality Assurance /

Quality Control, indicate the reason for termination. For each such person involuntarily terminated, describe in detail the circumstances of termination.

20. Please identify in detail all documents, including correspondence, reports, minutes of meetings or notes of oral conversations, reflecting disagreements, disputes or differences of opinion between Quality Control Inspectors and their super-visors or Commonwealth Edison or its contractors' management.

Include the subject, date, names of persons involved and resolu-tion for each instance so reflected.

21. Does Commonwealth Edison or its contractors have policies or programs to encourage complaints or suggestions by workers regarding substandard workmanship, quality assurance deficiencies, deficiencies in plant design and construction, and harassment and intimidation? If so, please describe in detail.

22. Please identify any complaints or suggestions by workers known to Commonwealth Edison or its contractors regarding 10 o

substandard workmanship, quality assurance deficiencies, deficiencies in plant d'esign and construction, pressure to per-form or approve faulty workmanship, or harassment and intimida-tion. Include the date, name, title, address and telephone number of the source, subject and resolution or other action ,

taken for each.

23 What are the bases for your responses to Nos.13-227 Please identify all documents, physical evidence, testimony, or oral statements by any person and legal authority on which you rely in support of your position.

24. (a) Describe in detail any and all reviews of contrac-tor performance conducted by or for Commonwealth Edison in response to the NRC findings reflected in the February 2, 1983 Notice of Violation and Proposed Imposition of Civil Penalties, EA 82-136, the $100,000 civil penalty. Please identify any and all docu-ments which reflect the results of such reviews, including any nonconformances found and any corrective action taken.

(b) Were these reviews adequate? If so, please set forth any and all facts which demonstrate the adequacy of such reviews. If not, please explain and set forth any and all facts which support such explanation.

25. Subsequent to these NRC findings, did Pullman institute a stop work order involving HVAC work? If so, please describe in detail and explain why this problem occurred. Describe in detail any corrective action taken. Please identify any documents which reflect these answers.

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26. Subsequent to these NRC findings, was a 50.55(e) report made regarding verification of correct piping components for both large and small bore pipe? If so, please describe in detail the circumstances and explain why this problem occurred and correc-tive action taken. Please identify any documents which reflect these answers.

27. Subsequent to these NRC findings, was a supplemental 50.55(e) report made regarding piping components for specification break items? If so, please describe in detail the circumstances and explain why this problem occurred and what corrective action was taken. Please identify any documents which reflect these answers.

28. Subsequent to these NRC findings, did Phillips-Getschow management suspend the engineering department support selection program for process and instrument piping and instrument tubing?

If so, please describe in detail the circumstances and explain why this problem occurred and all corrective action taken.

Please identify any documents which reflect these answers.

29. Subsequent to these NRC findings, did Pullman fail to institute corrective action to establish compliance with AWS D1.1 inspection requirements? If so, please describe in detail the circumstances and explain why this problem occurred and correc-tive action taken. Please identify any documents which reflect these answers.

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30. Did Phillips-Getschow ever fall to implement effective corrective action to verify past installations of large bore piping components? If so, please describe in detail the j circumstances and explain why this problem occurred and further corrective action taken. Please identify any documents which reflect these answers.

31. Subsequent to NRC identification of the need for l Phillips-Getschow to involve Quality Control in heat number l

l traceability and sample inspections, were problems identified i

l i requiring items of large and small bore pipe to be removed? Were l

problems identified with inaccessible pipe? Were problems identified with lack of documentation identifying components

! Installed? If so, please describe in detail the circumstances l

l and explain why this problem occurred and all corrective action l taken. Please identify any documents which reflect these answers.

32. Has Sargent and Lundy ever approved deficient contractor programs at Draidwood? If so, please describe in detail each instance and any and all corrective action taken with l respect to such instance. Identify any and all corrective action taken with respect to such instance. Identify any and all docu-ments which reflect such instances and such corrective action.

Haa the NRC ever identified such instances? If so, please descrioe in detail and identify any documents which reflect such instances and any corrective action taken.

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33 Has Commonwealth Edison management ever approved deficient contractor programs at Braidwood? If so, please 1

describe in detail each instance and any and all corrective action taken with respect to such instance. Identify any and all documents which reflect such instances and such corrective action. Has the NRC ever identified such instances? If so, please describe in detail and identify any documents which I

reflect such instances and any corrective action taken.

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34. Has Commonwealth Edison Quality Assurance ever approved deficient contractor programs at Braidwood? If so, please describe in detail each instance and any and all corrective i action taken with respect to such instance. Identify any and all documents which reflect such instances and such corrective I action., Has the NRC ever identified such instances? If so, please describe in detail and identify any documents which reflect such instances and all corrective action taken.

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35. Has Commonwealth Edison Quality Assurance ever failed to identify deficient contractor programs at Braidwood where such programs have been subject to Commonwealth Edison Quality Assurance auditing? If so, please describe each instance in 1

j detail and any and all corrective action taken with respect to  !

I j such instance. Identify any and all documents which reflect such I

i instances and such corrective action. Has the NRC ever identi-i fled such instances? If so, please describe in detail and iden-tify any documents which reflect such instances and any correc-l tive action taken.

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36. Please describe in detail any programs at Commonwealth 4

Edison's LaSalle and Byron nuclear plants which provide for the l

field verification of correct piping components installed. Has

! such a program been required at Braidwood? If so, please 1

i describe in detail and identify any documents which reflect such a program. If not, please explain why not. Has the NRC ever

identified a failure to require such a program at Braidwood? If 4

so, please describe in detail such identification and any

! response and any corrective action by Commonwealth Edison and 1

identify any documents which reflect such identification, response and corrective actions.

37. Please describe in detail any programs at Braidwood and i Commonwealth Edison's LaSalle nuclear plant for the re-route of small bore piping, including particularly any material [

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differences between the programs now or in the past. Has the NRC 4

i j ever identified any deficiencies in such a program at Braidwood?  ;

j If so, please describe in detail such identification and any i response and corrective action. Please identify any documents reflecting auch programs, deficiencies, responses, and corrective i actions. r i

38. Please describe in detail any problems identified by i

j Phillips-Getschow with field re-routed pipe, small bore heat l

[ number traceability and lack of Quality Control or ANI review of ,

1 j field addition or deletion of pipe bends or welds in or about

! April, 1983 What corrective actions, if any, were taken? Were i

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]. these adequate? Please describe in detail and identify any i

Has the NRC ever j documents which reflect such description.

I j identified such problems or inadequacies? Please explain and i

identify any documents which reflect such identification and your i.

j response and corrective action, if any. i 39 What traveler package control system for identifying l welding procedures and material consumed for HVAC components has i

been implemented at Braidwood? Is such a system an industry-wide

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standard practice? Has the NRC ever identified any deficiencies l

t in the Braidwood HVAC program with regard to such a system? If j so, please describe in detail. Please identify any documents j i

l which reflect such a system, such deficiencies and any response l or corrective action.

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40. In what manner, if any, did Commonwealth Edison apply  ;

lessons learned with regard to HVAC installation from its LaSalle nuclear plant to Braidwood? Please describe in detail. Has the  :

1 NRC ever identified failure by Commonwealth Edison to apply such

i' lessons learned? If so, describe such identification. Please identify any documents which reflect these answers.

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41. Has the NRC ever found that quality assurance deficiencies at Braidwood have resulted in construction of  ;

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indeterminate quality in any aren(s), but particularly including I

piping, electrical or HVAC7 If so, please describe in detail the l

circumstances and explain why these problems occurred and what

! corrective action has been taken. Set forth any facts which j demonstrate that such corrective action has been effective.

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Please identify any documents which reflect these answers.

42. Has Commonwealth Edison ever identified incorrect or indeterminate piping items installed at Braidwood? If so, was  ;

such identification through a sample inspection? Is it true that i

the Braidwood program did not require independent verification of all piping components installed? Was there ever a potential for inadequate quality of installed piping which could result in failures during plant operations? If so as to any of these questions, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any docu-ments which reflect these answers.

L 43 Has the NRC ever found that the accuracy of as-built (fleid re-routed) piping drawings is unknown due to lack of quality control verification? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which i

demonstrate that such corrective action has been effective.

Please identify any documents which reflect these answers.

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44. Has the NRC ever observed that design acceptability of field re-routed pipe cannot be determined? If so, please describe in detail the circumstances and explain why these prob-lems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such correctivo action has '

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been effective. Please identify any documents which reflect l these answers.

45 Has the NRC ever found that due to a lack of random measurements during piping receipt inspections there exists a potential for minimum wall violations which could result in ,

piping failures during plant operation? If so, please describe in detail the circumstances and explain why these problems i i

1 occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been  :

effective. Please identify any documents which reflect these l answers.  ;

46. Has the NRC ever found that incorrect hanger calcula-  :

t tions at Braidwood result in pipe support capability which is l l

indeterminate? If so, please describe the circumstances in [

detail and explain why these problems occurred and what correc-i tive action has been taken. Set forth any facts which demon- I strate that such corrective action has been effective. Please l identify any documents which reflect these answers. l

47. Has the NRC ever found that in the area of HVAC the  !

lack of specific weld procedures to be used by craft has allowed craft to select the procedure and technique to be used, resulting in HVAC welding activities of Indeterminato quality? If so, ,

please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set  :

forth any facts which demonstrate that such corrective action has  !

been effective. Please identify any documents which reflect i

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l these answers.

48. Has the NRC ever found that a lack of Quality Control inspections required by AWS D1.1 prior to and during HVAC welding operations has resulted in HVAC structural welding of indeter-minate quality? If so, please describe the circumstances in detail and explain why these problems occurred and what correc-tive action has been taken. Set forth any facts which demon-strate that such corrective action has been effective. Please identify any documents which reflect these answers.

49 Has the NRC ever found a lack of required comprehensive audits by the Braidwood electrical contractor, Comstock, the piping contractor, Phillips-Getschow, and/or the HVAC contractor, Pullman? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Picace identify any docu-monts which reflect these answers.

50. In a February 1, 1984 Chicago Tribuno article, NRC Region III Administrator James G. Keppler anid, in part, with regard to Commonwealth Edison and Druidwood: "One has to question whether the workload has become unmanageable for the staff they have, and I've raised that for management to connider. But I ,

hnvc to be conocened that they are spread thin at tne top ...."

Did Mr. Keppler or the NRC raise thin matter with Commonwealth Edison? Or did Edison otherwine identify such deficionalen? If 19

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so, please describe in detail the circumstances, Commonwealth Edison's response and any corrective action taken and the  :

L results. Please identify any documents which reflect the answers to these questions, i

51. In Inspection Report 83-09, at page 4, the NRC observed that Commonwealth Edison and the NRC Region III Staff discussed during enforcement conferences or otherwise, " CECO Personnel and organizational changes to strengthen the construction project l management team and to increase the emphasis on quality assurance." Please describe in detail any such changes made at that time or since. Identify specifically the names, job titles and duties, qualifications, and objective performance evaluations for all persons involved in such " personnel and organizational changes," including those both before and af ter such changes were made. Please identify any documents which reflect these answers.

52. Have any quality assurance weaknesses or deficiencies -

at Braidwood been caused by management action or inaction? If so, please describe in detail. Have any adverse personnel actions (for example, termination, demotion, transfer or suspen-sion) been taken by Commonwealth Edison and/or its contractors against any person (s) because of QA deficiencies or weaknesses?

If so, please identify the circumstances and persons involved, including names and addresses, and identify any documents reflecting such instances and their resolution.

53. What policies or programs are in place at Draidwood to assure compliance with the provisions of 10 CFR 50 7 prohibitions 20 .

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I against discrimination? Please describe in detail and identify and documents which reflect this answer.

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l 54. Have any complaints been made by any present or former Braidwood employee of harassment, intimidation, retaliation or other discrimination by Commonwealth Edison or any contractor because of the expression of safety or quality concerns or the performance of duty in assuring compliance with applicable codes, 1 specifications or procedures? If so, please describe in detail i

the circumstances of each such complaint, including the name and  !

t address of all persons involved, the resolution and any correc-i l tive or remedial action taken. Identify any documents which i reflect this answer.

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i 55. Please describe in detail any and all complaints by l t i i Comstock Quality Control inspectors or other QA personnel,  ;

including but not limited to those matters referred to in NRC

r l Inspection Report 84-34/84-32, page 4. Include names and 1 addresses, current job title and status for all persons involved, the investigation and resolution of these complaints and any

, disciplinary or corrective action taken. Please identify any documents reflecting these answers.

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56. What involvement, if any, has senior Commonwealth  !

Edison management had in organizing and implementing the quality j assurance program at Braidwood? Please describe in detail any l auch involvement including specific names, dates, circumstances i and actions taken. Identify any documents reflecting this annwer.

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l 57. In what respects are NRC requirements understood to be i .

, either minimum or maximum requirements with regard to the design  !

i i and construction of Braidwood? Please explain in detail and ,

I identify any documents which reflect this answer.

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58. For each quality assurance violation or unresolved or open item referred to by Intervonors in their amended quality assurance contention (served upon all parties May 24, 1985), j j please describe in detail the circumstances involved, including l I \

the name and address of each person involved, the manner in which l 1

such deficiency was identified, the manner in which the deficiency was investigated and evaluated for significance, root i cause and generic implications, the manner in which the ,

deficiency was remedied and corrected, including any corrective l

l action taken with rogard to the existence of other related deficiencies. Set forth any facts upon which you rely to show that the deficiency and its root cause have been effectively l corrected. Please identify any documents which reflect these

, answers. i l

i 59. With respect to the deficiencies referred to in  !

) Interrogatory 58 above, identify in detail all documentation and

, hardwsre changes or re-work undertaken in the course of remedini i

or corrective actions including numbers of items changed or  ;

3 reworked. Please identify any documents reflecting these i i answers. i l l

! 60. Has any member of the NRC Staff ever expressed any I

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dispute, disagreement, or dissenting views or submitted an [

l " inspector or inspection evaluation report" (see, Warnick f ,

l deposition, Tr. 204) with respect to any quality assurance l

! t deficiency or finding about Braidwood? If so, please identify I l '

l the circumstances and persons involved, including names and addresses, and identify any documents reflecting such instances i

l and their resolution.

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l 61. Describe in detail the organization established to  !

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I execute the quality assurance program at Braidwood, including any I

( material changes made in such organization from the inception of l )

construction until the present. Please identify the numbers of ,

i persons performing each QA function for Commonwealth Edison and i each contractor over the life of the project. For each person, include a description of the duties assigned, the pay grade and benefits for each position as compared to non-QA positions, the p opportunities for advancement both within and without the QA l l

program for QA personnel, the length in months of the person's (

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l prior nuclear QA or QC experience, and comparative data on the l I l relative turnover rate for QA personnel as compared to non-QA personnel. Explain in detail the pay scale for Edison Braidwood QA personnel, including all QA managers, and all other pay scales i within the Company. Please identify any documents which reflect l these answers. i

62. For all intra-Company transfers into or out of Edison l l

QA at Braidwood, please identify, as applicable, the previous department, position and pay of the employee immediately prior to t

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i his or her transfer to Braidwood QA; his or her position, pay and length of tenure in Braidwood QA; and the department, position and pay of the employee immediately following transfer out of Braidwood QA.

July 2, 1985 By:

klLu Robert Guild One of the Attorneys for Intervenor Rorem el aJ1,.

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Dougissa W. Cassel, Jr.

Robert Guild Timothy W. Wright, III 109 North Dearborn i Suite 1300 1 Chiongo, 1111noin 60602 (312) 641-5570 l 24 i

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