ML20133D756
| ML20133D756 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/02/1985 |
| From: | Mark Miller COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Rorem B ROREM, B. |
| References | |
| CON-#385-111 OL, NUDOCS 8508070444 | |
| Download: ML20133D756 (10) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI.ON BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456 W 00 g{C s
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50-457ol (Braidwood Nuclear Power
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Station, Units 1 and 2)
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'85 AUG -6 A10 :40 APPLICANT COMMONWEALTH EDISON COMPANY'S
%f,JC >F5jC?jg' gg 5 FIRST SET OF QUALITY ASSURANCE INTERROGATORIES BRANCH AND REQUESTS TO PRODUCE DOCUMENTS DIRECTED TO INTERVENORS BRIDGET LITTLE ROREM, ET AL.
Pursuant to 10 CFR Sections 2.740b and 2.741, Commonwealth Edison Company
(" Applicant") hereby serves its Quality Assurance Interrogatories and Requests to Produce, First Set, upon Intervenors, Bridget Little Rorem, et al. ("Intervenors")
REQUESTS TO PRODUCE Pursuant to 10 CFR Sections 2.741 and 2.744, Applicant requests that the Intervenors make available for inspe.ction and copying at a time and location to be designated, all t.ocuments identified in the responses to the interrogatories below.
I INTERROGATORIES Definitions l
l A.
You or your - means Intervenors, their agents, i
l employees and attorneys, including all employees of BPI, Stanley Campbell and Diane Chavez.
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B.
Documents.
As used in these interrogatories, the term *dccument" includes, without limiting the generality of its meaning, all originals or copies where originals are unavailable and non-identical copies (whether different from originals by reason of notations made on such copies or otherwise) of all written, recorded or graphic matter, how-ever produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting, or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, reports, summaries and results of investigations and tests, reviews, contracts, agreements, construction progress reports, job site inspection reports, progress photographs, working papers, statistical records, ledgers, books of account, vouchers, bank checks, bank statements, invoices, receipts, computer data, stenographers' notebooks, manuals, directives, bulletins, desk calendars, appointment books, diaries, maps, logs, or written or re-corded communications of any kind whatsoever.
C.
Identify or identification.
For an individual, the words " identify" or " identification" mean name, address, employer and telephone number.
For a document, the words
" identify" or " identification" mean the date of the document, addressor, addressee, corporate or other affiliation (e.g.
Nuclear Regulatory Commission) of the addressor and addressee and a brief summary of the subject matter of the document.
D.
Contention.
The word " contention" means the quality assurance contention admitted into controvt.?sy by the Atomic Safety and Licensing Board in its June 21, 1985 order and as supplemented by its oral ruling at the prehearing conference on ?nly 23, 1985 regarding the executed Joint Stipulation of Quality Control (QC) Inspector Harassment Contention.
E.
Refer or relate.
The words " refer or relate" mean any factual, legal, technical or ' logical connection between two or more facts.
Instructions A.
Each interrogatory should be answered fully in writing, under oath or affirmation, and include all per-tinent information known to the Intervenors, including their officers, directors, employees, agents, consultants, advisors or counsel.
Each request to produce applies to pertinent documents which are in the possession, custody or control of the Intervenors, including their officers directors, employees, agents, consultants, advisors or counsel.
In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceding each answer or response.
B.
These interrogatories and requests shall be continuing in nature.
Thus, whenever information is obtained which renders any previous response incorrect or indicates y
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that a response was incorrect when made, a supplement should be made to the previous response to the appropriate inter-rogatory or request to produce.
C.
Whenever an interrogatory requests the identi-fication of documents, Intervenors may, in lieu of answering the interrogatory, provide copies of the documents.
In such instances, the documents should be clearly marked to indicate the interrogatory to which they are responsive.
Whenever an interrogatory requests information D.
regarding each subpart of the contention, the answer should respond separately for each separate paragraph of the conten-tion denominated by an arabic number, a capital letter, an
. asterisk or two dashes.
E.
If any of the information responsive to an interrogatory or document responsive to the request for docu-ments is deemed to be privileged, the answer shall so state.
In the case of an answer to an interrogatory, the subject matter of the communication, its date, the participants in the communication, their employer and job title and the basis on which the privilege is asserted shall be specified.
In the case of a document otherwise responsive to a document request, the document shall be described by its date, addressor, addressee, persons to whom copies of the document were distributed, subject matter, the employer and job titles of all such persons and the basis on which the privilege is asserted shall be specified.
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-S-Interrogatories 1.
Describe every oral communication which you have had which refers or relates to each subpart of the con-tention by:
a.
date; b.
whether the communication was on the telephone or in person; c.
the subject matter of the communicatie-and d.
identify all persons participating therein.
You may exclude all such communications in which counsel for Staff and/or Applicant participated.
2.
Identify the documents in your possession prior to the admission of the contention which refer or relate to each subpart of the contention and identify each person supplying you with each such document.
3.
Identify each individual and organization with " quality assurance expertise" whom you have consulted concerning Braidwood and identify each document which refers or relates to such consultation.
4.
Define the word " breakdown" as it is used in the contention.
5.
For each subpart of the contention describe the corrective action which has been or is being implemented to correct the deficiency described therein.
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6.
For each corrective action identified in answer to interrogatory 5, state whether you believe the corrective action has been or will be, if implemented in accordance with its description, effective in rectifying the specified quality assurance deficiency.
If your answer is negative, describe fully the particulars in which the corrective action is asserted to be ineffective, the basis for each such assertion and identify all documents which refer or relate to your answer.
7.
State whether you will contend at the hearing that the specific factual occurrences set forth in the con-tention exhibit an asserted pattern of quality assurance deficiencies on any common basis other than the specified criterion of 10 CFR Part 50, App. B set forth in the contention.
If so, describe each such common basis for an asserted pattern of quality assurance deficiencies and identify any documents which refer or relate to such common basis.
8.
Define the words harassment, intimidation, retaliation and discrimination as used in the Joint Stipulation on Quality Control ("QC") Inspector Harassment Contention
(" Joint Stipulation").
9.
Describe each instance of (A) harassment and (B) intimidation either (1) carried out or (2) participated in by Irv DeWald, Larry Seese, Bob Seltman and R. M. Sakalac and for each such instance:
ej.
a.
identify the QC inspector or other Comstock employee allegedly harassed or intimidated; b.
identify the Comstock supervisor involved; c.
describe the quality or safety concern expressed by the QC inspector or other Comstock employee; d.
state whether the quality or safety concern was resolved and if so, describe its resolution; e.
state the date of each such instance; and f.
identify documents which refer or relate to each such instance.
10.
Describe each effect of Mr. Sakalac's alleged harassment which remains uncorrected, identify each person on whom each such effect has operated and identify all documents which refer or relate to each effect.
11.
Identify each of the "more than 25" Comstock QC inspectors referred to at page 5 of the Joint Stipulaticn dated July 12, 1985.
12.
Identify each and every person who you intend to call as a witness at the hearing in this matter on the
- contention, and with respect to each such person:
a.
Describe the witness' education and e
professional background.
i b.
State the substance of the facts and opinions to which the witness is expected to testify; c.
Give a summary of the grounds for each opinion; and d.
Identify all documents which form the basis for each opinion.
13.
State the full name, address, occupation and employer of each person answering the interrogatories or assisting in the preparation ei such answers, and designate
'the interrogatory or the part thereof he or she answered.
Ohe of the Attorneys for Commonwealth Edison Company August 2, 1985 Isham, Lincoln & Beale 3 First National Plaza 52nd floor Chicago, Illinois 60602 (312) 558-7500
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'85 AUG -6 A10 :40 r y :-(
c ec CERTIFICATE OF SERVICE i,3: s._ l : ~,m I, Michael I. Miller, do hereby certify that a copy of the foregoing APPLICANT COMMONWEALTH EDISON COMPANY'S FIRST SET OF QUALITY ASSURANCE INTERROGATORIES AND REQUESTS TO PRODUCE DOCUMENTS DIRECTED TO INTERVENORS BRIDGET LITTLE ROREM, ET AL. was served on all persons in the attached service list by deposit in the United States mail, first class (or by expedited means, as shown) this day of August, 1985.
Michael I. Miller i
l SERVICE LIST Lawrence Brenner, Esq.
Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary 1
United States Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 C. Allen Bock, Esq.
P.O. Box 342 CDr. Richard F. Cole Urbana, IL 61801 Administrative Law Judge Atomic Safety and Licensing Board Ms. Bridget Little Rorem United States Nuclear Regulatory 117 North Linden Street Commission P.O. Box 208 Washington, DC 20555 Essex, IL 60935 o Dr. A. Dixon Callihan
- Robert Guild Administrative Law Judge Douglass W. Cassel, Jr.
102 Oak Lane Timothy W. Wright, III Oak Ridge, TN 37830 BPI 109 North Dearborn Street Suite 1300 Stuart Treby, Esq.
Chicago, IL 60602 Elaine I. Chan, Esq.
Office of the Executive Legal
. Director Ms. Lorraine Creek United States Nuclear Regulatory Route 1 Commission Box 182 Washington, DC 20555 Manteno, IL 60950 Atomic Safety and Licensing Charles Jones, Director Board Panel Illinois Emergency Services United States Nuclear Regulatory and Disaster Agency Commission 110 East Adams Washington, DC 20555 Springfield, IL 62705 Atomic Safety and Licensing Appeal Board Panel United States Nuclear Regulatory Commission Washington, DC 20555
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