ML20129F764
| ML20129F764 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/12/1985 |
| From: | Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Rorem B ROREM, B. |
| References | |
| CON-#385-822 OL, NUDOCS 8507170452 | |
| Download: ML20129F764 (15) | |
Text
~*
y CORRf SPONDENGE
! CouETED July 12,1985sMc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *85 JUL 16 P3:22 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD crFICEGrSEcauA n 00CAETmG h SERviCl' BRANCH In the Matter of COMMONWEALTH EDIS0N COMPANY ) Docket Nos. 50-456
) 50-457 g (Braidwood Nuclear Power Station, )
Units 1 and 2) )
NRC STAFF INTERR0GATORIES TO INTERVEN0R BRIDGET LITTLE R0 REM, ET AL. CONCERNING ITS QUALITY ASSURANCE CONTENTION In accordance with 10 C.F.R. Sections 2.740, 2.740b and 2.741, the NPC Staff hereby serves Bridget Little Rorem, et al. (Rorem, et al.),
as an intervenor in the above-captioned proceeding, with the following interrogatories and request for production of documents. These inter-rogatories and document requests relate to Rorem et al.'s amended conten-tion, as admitted in the Licensing Board's Memorandum and Order (Admitting Rorem, et al. Amended Quality Assurance Contention) dated June 21, 1985.
Each interrogatory shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information available to Rorem, et al., its members or counsel, based upon the personal knowledge of the person answering. Answers to these interrogatories are required to be served upon all parties to the proceeding within 14 days after service of the interrogatories. By each request for production of documents, the NRC Staff seeks to inspect and copy documents which are in the possession, custody or control of Rorem, et al., its members or counsel.
8507170452 850712 gDR ADOCM 05000456 PDR
_2 For purposes of responding to these interrogatories: (1) the word
" document (s)" means all writings and records of every type in the posses-sion, control or custody of Intervenor Bridget Little Rorem, et al. or any individual acting on its behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recording and all other writings or recordings of any kind; " document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of Intervenor or any individual acting on its behalf if they have ownership, possession or custody of the document or copy thereof, or have the right to secure the docurrent or copy thereof, from any person or public or private entity having physical possession thereof; (2) the word
" Applicant" means Commonwealth Edison Company, its contractors and subcon-tractors, vendors, architect-engineer, consultants, agents and employees; (3) give the name, address, occupation and employer of the person or persons (a) answering each interrogatory, or (b) who have served, presently serve, or it is anticipated will serve as consultants or advisors to Rorem, et al. on the subject matter of the interrogatory; (4) identify each person whom you expect to call as a witness to testify at the hearing as to the issue addressed in the pertinent interrogatory. As to each such person, please state (a) the subject matter of his or her testimony and (b) the substance of the testimony and (c) the witness' professional
'or other qualifications to testify on the subject matter on which witness expects to testify; (5) is the answer based on conversations, consulta-tions, correspondence or any other type of communications with one or
more individuals? If so, (a) identify each such individual by name and address, (b) state the ed cational and professional background of each individual, (c) describe the information received from such individual and its relation to your direct answer (d) identify each writing or record related to each conversation, consultation, correspondence or other communication with such individual.
In addition, Rorem, et al. is requested, pursuant to 10 C.F.R. 5 2.740(e), to supplement its responses as necessary with respect to the identity of each person to be called as an expert witness at the hearing in this proceeding, the subject matter on which he or she is expected to testify, and the substance of such testimony. Similarly, Rorem, et al.
is requested to amend its responses if Rorem, et al. subsequently learns that any response made to the interrogatories herein was incorrect when made, or that the response though correct when made is no longer correct.
l
- 1. INTERROGATORY Interrogatory 1 Are there instances other than those cited in subparts A.-F. of paragraph I which support your allegation that Applicant's QA program violates Criterion I of 10 C.F.R Part 50, Appendix B by failing to ,
oversee the performance of their site contractors? l Interrogatory 2 -
If the answer to Interrogatory 1 above is yes:
- a. Describe each such instance in detail, including the time period during which it occurred.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 3 Are you aware of corrective actions which have been taken to remedy the situation set forth in paragraph 1.
Interrogatory 4 If the answer to Interrogatory 3 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 1. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 3.
Interrogatory 5 Explain the meaning of the term " widespread deficiencies" as used in pdragraph 1 on page 19.
Interrogatory 6 Are the instances described in subparts A.-C. of paragraph 3 the sole instances upon which you rely as your basis for the contention that Applicant's QA program is not adequately documented by written policies, procedures and instructions and does not effectively control activities affecting quality?
Interrogatory 7 If the answer to Interrogatory 6 above is no:
- a. Describe in detail each additional instance on which you rely as a basis for paragraph 3.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 8 Are you aware of corrective actions which Applicant has taken to correct the deficiencies cited in paragraph 3.
Interrogatory 9 If the answer to Interrogatory 8 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 3. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 8.
Interrogatory 10 Are the instances cited in subparts A. and B. of paragraph 4 the only instances which form the basis for the contention that training and indoctrination of those performing activities affecting quality was inadequate?
Interrogatory 11 If the answer to Interrogatory 10 above is no:
- a. Describe in detail the other instances upon which you rely as the basis for this contention, including the date of their occurrence.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 12 Are you aware of corrective actions which Applicant has taken to remedy the situations in subparts A. and B. of paragraph 4 Interrogatory 13 If the answer to Interrogatory 12 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 4. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 12.
Interrogatory 14 Are the instances alleged in subparts A.-C. of paragraph 5 of your contention concerning quality assurance the only instances upon which you rely as the basis for your contention that there is inadequate program to assure that applicable reoulatory requirements and design basis are
correctly translated into specifications, drawings, procedures, and instructions?
Interrogatory 15 If your answer to Interrogatory 14 above is no:
- a. Describe in detail all other instances upon which you rely as the basis for subparagraph 5 of your contention.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 16 Are you aware of any corrective actions being taken by Applicant to correct the situations described in subparts A.-C. of paragraph 5 of your contention?,
Interrogatory 17 If the answer to Interrogatory 16 above is yes:
- a. Describe what you understand to be the corrective actions being taken by Applicant.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 5. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interroga-tories 15 and I6.
Interrogatory 18 Are the instances specified in subparts A.-I. of paragraph 6 of your quality assurance contention the only instances on which you rely as the basis for your contention that there is inadequate prescription of activi-ties affecting quality by documented procedures, instructions and drawings?.
Interrogatory 19 If the answer to Interrogatory 18 above is no:
- a. Describe in detail the other instances upon which you rely as the basis for paragraph 6 of your contention.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a sumary of their contents.
1 Interrogatory 20 Is the instance set forth in subpart A. of paragraph 7 of you conten-tion the sole instance of inadequate document control which provides the basis for your contention that Applicant has failed to establish a program of adequate document control?
Interrogatory 21 If the answer to Interrogatory 20 above is no:
- a. Describe in detail the other instances you allege form the basis of paragraph 7 of your contention, including the date of occurrence of each instance,
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a surrmary of their contents.
Interrogatory 22 Are you aware of any corrective actions taken by Applicant to provide adequate document control?
Interrogatory 23 If the answer to Interrogatory 22 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 7. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 22.
Interrogatory 24 Are the instances specified in subparts A.-F. of paragraph 8 of your contention the sole basis for your contention that Applicant's program for material and parts control is inadequate?
Interrogatory 25 If the answer to Interrogatory 24 above is no:
- a. Describe each instance in detail, including the time period during which it occurred.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 26 Are you aware of any corrective actions which have been taken by Applicant to improve materials and parts control at the Braidwood site?
Interrogatory 27 If the answer to Interrogatory 26 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 8. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 26.
Interrogatory 28 Are the instances set forth in subparts A.-E. of paragraph 9 of your contention the sole basis for your contention that Applicant's program does not provide adequate control of special process and adequate ensurance that these special processes are accomplished in accordance with applicable codes and standards?
Interrogatory 29 If the answer to Interrogatory 28 above is no:
- a. Describe in detail each other instance of inadequate control or oversight of special processes which forms the basis for your contention in paragraph 9.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 30 Are you aware of any corrective actions taken by Applicant to improve control of special processes and to ensure compliance with applicable codes and standards?
Interrogatory 31 If the answer to Interrogatory 30 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 9. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 30.
Interrogatory 32 Are the instances set forth in subparts A.-F. of paragraph 10 of your contention the sole basis for your contention that Applicant's inspection program is inadequate?
Interrogatory 33 If your answer to Interrogatory 32 above is no:
- a. Describe in detail each other instance of an inadequate inspection on which you rely for your contention.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 34 Are you aware of any corrective actions proposed by Applicant to improve its inspection program?
Interrogatory 35 If the answer to Interrooatory 34 above is yes:
- a. Describe such corrective actions with particularity,
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 10. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 34.
Interrogatory 36 Are the instances set forth in subparts A.-D. of paragraph 11 of your contention the sole basis for your contention that the Applicant's program for the maintenance of records is inadequate?
Interrogatory 37 If your answer to Interrogatory 36 above is no:
- a. Describe in detail the other instances of inadequate maintenance of records which form the basis for paragraph 11 of your contention.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 38 Are you aware of any corrective actions taken by Applicant to improve the maintenance of QA records?
Interrogatory 39 If the answer to Interrogatory 38 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 11. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 38.
Interrogatory 40 Are the instances set forth in subparts A.-J. of paragraph 12 of your contention the sole basis for your contention that Applicant has provided an inadequate program for the identification and correction of conditions adverse to quality.
Interrogatory 41 If the answer to Interrogatory 40 above is yes:
- a. Describe in detail such other instances the date of occurrence of each such instance.
- b. Identify all documents which relate to such instances by title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents.
Interrogatory 42 Are you aware of any corrective actions which have been taken by Applicant to improve the identification and correction of conditions adverse to quality?
}
i Interrcgatory 43 If the_ answer to Interrogatory 42 above is yes:
- a. Describe such corrective actions with particularity, i
i b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 12. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 42.
Interrogatory 44 i .
Are there any instances other than those set forth in subparts A.
and B. of paragraph 13 of your contention which form the basis of your
(
contention that maintenance of sufficient records concerning activities 4 affecting quality is inadequate?
Interrogatory 45 If the answer to Interrogatory 44 above is yes:
4 a. Describe in detail each such instance and the date of occurrence of each incident.
- b. Identify all documents which relate to such instances by 4 title, author, if any, date of issuance and, if other_than NRC documents, provide a summary of their contents.
Interrogatory 46 Are you aware of any corrective actions taken by Applicant to
- improve the maintenance of records relating to activities affecting quality? ,
f Interrogatory 47 l If the answer to Interrogatory 46 above is yes:
t, -
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 13. State with particularity your basis for your position.
I c. Identify all documents relied upon in answering 4 Interrogatory 46.
f
. _ _ _ - _ _ , _ _ _ _ - _ . _ .__ _ _ _ . _ . . _ _ _ _ ~ .- - - _ _ . . . _
L 12 -
Interrogatory 48 Are the instances set forth in subparts A. and B. of paragraph 14 the sole basis of your contention that Applicant fai7dd to institute a systematic program of audits of quality related activities?
Interrogatory 49 _
If your answer to Interrogatory 48 above is yes:
- a. Please describe in detail each instar.ce,
- b. Identify all documents which relate to such instances by-title, author, if any, date of issuance and, if other than NRC documents, provide a summary of their contents. ..
Interrogatory 50 Are you aware of any corrective ections taken by Applicant to improve;its program of audits of quality related activities?,
Interrofatory51 If the answer to Interrogatory 50 above is yes:
- a. Describe such corrective actions with particularity.
- b. State your position as to whether such corrective actions would or would not be adequate to remedy the situation described in paragraph 14. State with particularity your basis for your position.
- c. Identify all documents relied upon in answering Interrogatory 50. ,
II. REQUEST FOR PRODUCTION OF DOCUMENTS The NRC Staff requests that P.orem, ella ., pursuant to 10 C.F.R. 5 2.741, provide copies of, or make available for Staff inspection and copying,anydocumentsdesignatedbyRorem,etal.knresponsetothe above interrogatories. -
t
~ Respectfully submitted, Janice E. Moore
. b f DM Counsel for NRC Staff Dated at Bethesda, Maryland this 12th day of July, 1985 ;
1 l
l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS!0N ,
i BEFORE THE ATOMIC SAFETY AND LICENSING BOAPD In the Matter of )
COMMONWEALTH EDISON COMPANY Docket Nos. 50-456
) 50-457 (Braidwood Nuclear Power Station, )
Units 1 and 2) )
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter. In accordance with 10 C.F.R. 9 2.713(b) the following information is provided:
Name -
Janice E. Moore Address -
U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington, DC 20555 Telephone Number -
Area Code (301) 492-7313 Admission - Court of Appeals for the District of Columbia; United States District Court for the District of Columbia Name of Party -
NRC Staff U.S. Nuclear Regulatory Commission Washingtcn, DC 20555 dDbk OSL_-
Janice E. Moore d
Counsel for NRC Staff
! Dated at Bethesda, Maryland this 12th day of July, 1985
D0tGTED usMC UNITED STATES OF AMERICA '65 JJL 16 P3:22 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LQC[T G SER 1 BRANCH In the Matter of COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Nuclear Power Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INTERROGATORIES TO INTERVENOR BRIDGET LITTLE ROREM, ET AL. CONCERNING ITS QUALITY ASSURANCE CONTENTION" and " NOTICE OF APPEARANCE" for Janice E. Moore in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by (*) through deposit in the Nuclear Regulatory Commission's internal mail system, or (**) by overnight or express mail delivery this 12th day of July, 1985:
Lawrence Brenner, Esq., Chairman
- Comonwealth Edison Company Administrative Judge ATTN: Cordell Reed Atomic Safety and Licensing Board Assistant Vice President U.S. Nuclear Regulatory Comission P.O. Box 767 Washington, DC 20555 Chicago, IL 60690 Dr. A. Dixon Callihan Thomas J. Gordon, Esq.
Administrative Judge Waller, Evans & Gordon l 102 Oak Lane 2503 S. Neil Oak Ridge, TN 37830 Champaign, IL 61820 Dr. Richard F. Cole Region III Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board Office of Inspection & Enforcement U.S. Nuclear Regulatory Comission 799 Roosevelt Road Washington, DC 20555 Glen Ellyn, IL 60137 Rebecca J. Lauer, Esq. Joseph Gallo, Eso.
Isham, Lincoln & Beale Isham, Lincoln & Beale Three First National Plaza Suite 840 Suite 5200 1120 Connecticut Avenue, N.W.
Chicago, IL 60602 Washington, DC 20036
-, Ms. Bridget Little Rorem C. Allen Bock, Esq.
117 North Linden Street P.O. Box 342 Essex, IL 60935 Urbana, Il 61801 Douglass W. Cassel, Jr., Esq. Atomic Safety and Licensing Board Timothy Wright, Esq. Panel
- 109 North Dearborn Street U.S. Nuclear Regulatory Commission Suite 1300 Washington, DC 20555 Chicago, IL 60602 Atomic Safety and Licensing Appeal Erie Jones, Director Board Panel
- Illinois Dnergency Services U.S. Nuclear Regulatory Commission and Disaster Agency Washington, DC 20555 110 East Adams
-Springfield, IL 62705 Docketing and Service Section*
Office of the Secretary Lorraine Creek U.S. Nuclear Regulatory Commission Route 1, Box 182 Washington, DC 20555 1Manteno, IL 60950 Robert Guild, Esq.**
c/o Cassel 3242 N. Racine
, Chicago, IL 60657
[MQ Janice E. Moore If MD s Counsel for NRC Staff 6