ML20133H613

Second Partial Response to Rorem First Set of QA Interrogatories & Requests to Produce Addressing Interrogatory 11.Affidavit of Sc Hansader & Certificate of Svc Encl.Related Correspondence

ML20133H613
Person / Time
Site:	Braidwood
Issue date:	08/05/1985
From:	Gallo J COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	ROREM, B.
References
CON-#385-144 OL, NUDOCS 8508090420
Download: ML20133H613 (11)

Text

hk August 5, 1985 g IED UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION USNRC

• • - BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 AUG -8 M2:18 l

In the Matter of: ) gg;g y 3tcag,,,.

COMMONWEALTH EDISON COMPANY ) 00ChETmG & SERVla

) Docket Nos. 50-456cL BRANCH (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )

APPLICANT'S SECOND PARTIAL RESPONSE TO ROREM'S FIRST SET OF QUALITY ASSURANCE INTERROGATORIES AND REQUESTS TO PRODUCE On July 2, 1985,.Intervenors Rorem, et al.

("Intervenors"), filed their First Set of Quality Assurance

Interrogatories and Requests to Produce. On July 30, 1985, Commonwealth Edison Company (" Applicant") filed objections to certain of those discovery requests and its first partial response to.Intervenors' discovery requests. In its cover letter accompanying its first partial response, Applicant noted that although documents responsive to specific Interrogatory No. 11 were being provided, the actual response to-specific Interroga, tory No. 11 would be provided at a later date. This submission, which is Applicant's second partial response to Intervenors' discovery requests, provides the response to' specific Interrogatory No. 11. Investigation continues for. responses to all of the requests to which Applicant has not objected.

Each-document identified in Applicant's response or incorporated by reference into Applicant's response has been 5000 56 PDR DSoS

identified with a number. In addition, Applicant has provided indices for these documents organized by interrogatory number, which identify for each numbered document the date, author, recipient, and type of document. The indices will be updated with each partial response submitted by Applicant.

Documents which are incorporated by reference to answer interrogatories are being provided to all parties.

Documents which are simply identified in answers to interrogatories, but not incorporated by reference, are available for inspection and copying. Documents for which Applicant is asserting privilege have not been provided, and an indication can be found on the indices as to whether the attorney client ("AC") or attorney work product ("WP")

privilege is being asserted.

With regard to requests for addresses and telephone numbers of individuals employed by Commonwealth Edison or its contractors, onsite personnel can be located by contacting Braidwood Nuclear Power Station, Braceville, Illinois 60407 (phone 815-458-2801). Other Commonwealth Edison personnel can be located by contacting 72 W. Adams St., P.O. Box 767, Chicago, Illinois 60690 (phone 312-294-4321). Applicant is making a further review of individuals identified in response to specific interrogatories and will supplement its answers to the extent that such individuals now have other addresses or telephone numbers.

f Specific Interrogatory 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 the guidance of the Institute for Nuclear Power Operation (INPO). For each repcrted observation, discrepancy, deficiency or weakness, indicate:

the nature of the deficiency; the Appendix B criteria, if any, to which it relates and the respects in 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 detailed description of its corrective action.

Response

Subject to Applicant's partial objection to this_

interrogatory, " audits conducted pursuant to 10 C.F.R. Part 50, Appendix B, Criterion XVIII or otherwise" have been compiled. These audit reports are identified and stamped as pages B0000000 through B0000659; 10000000 through I0000095; I0000180 through I0000576; and M0000282 through M0000373.

In general, two categories of audit reports have been provided. The first category includes those audit reports encompassed by Subparts 12A., 12H., 14A., 14B.2, 14B.3, and 14B.4 of the Amended QA Contention and any related audit reports and surveillances that were conducted as follow-up activities. The second category encompasses those reports of audits of corrective actions taken by Commonwealth Edison Company with respect to specific deficiencies identified in the Amended QA Contention and the reports of any ensuing follow-up surveillances. This latter category includes audit reports encompassed by Subparts 3A.4e, 4A.,

6B.5, 14B,2 and 14B.3 of the Amended QA Contention. The documents provided contain information on the corrective actions-for findings and observations made in the audit reports.

Specific Interrogatory No. 11 sets forth a series of questions that seek information that is embodied in the documents provided. No attempt has been made to extract that information for inclusion in this response because it can be readily gleaned from the audit reports and other documentation. A review is continuing to determine if any additional documents falling within the purview of Interrogatory 11 exists. Any such information, if found, will be provided in a supplemental response on a prompt basis.

Although the entire audit report has been provided in each instance, in some cases specific pages or parts of the audit report provide the response to specific Interrogatory No. 11.. The following table provides this information.

Page Audit Page References Contention Begins On Within Audit Referred to B0000000 Through B0000006 12H B0000007 B0000009-10, 12A, 14A B0000014-15, B0000017-19, B0000023-32 i

i B0000033 B0000034-40, 12A, 14A B0000042-44 B0000045 -Through B0000052 12A, 14A B0000053 B0000055, 14B.4 B0000057, B0000062-63, B0000090-93 B0000100 B0000102, 14B.4

. B0000104, B0000139 B0000142-143, 14B.4 B0000148-169 B0000175 B0000177-178, 3A.4e, B0000182-186, 14B.4 B0000191, B0000196-199, B0000203-204, B0000223-225 B0000226 Through B0000232 -'14B.4 B0000233 B0000234, 14B.4 B0000239, B0000251-252 B0000253 B0000255-256, 14B.4 B0000259, B0000267, B0000269

'B0000290 B0000292-293, 14B.4 ,

B0000295-297, B0000304, B0000307-310, B0000311-313, B0000317-320 B0000328 'B0000337, 4A B0000361-369 JB0000386 B0000388-389, 6B.5 B0000404-415 B0000423 B0000424-425, 14B.2 i- 'B0000431-432, .

B0000438-440 y

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B0000448 B0000449, 14B.3 B0000452-454 B0000458 B0000460, 14B.3 B0000472-473, B0000475-477 B0000484 Through B0000494, 12A, 14A B0000498-500, B0000503-504, B0000505-537 B0000552 Through B0000597 12A, 14A B0000598 B0000599, 12A, 14A B0000601-603, B0000612-614, B0000616-639, B0000644-650 10000000 I0000001-03, 12A, 14A I0000009-11, I0000015-38, I0000043-45 I0000048 10000057-58, 12A, 14A I0000062, I0000072-73, I0000083, I0000093-94 10000181 10000185-186, 12A, 14A 10000192-193, I0000210-211 I0000214 I0000216-225, 12A, 14A, I0000295-378, 14B.2 I0000381, I0000398-400, I0000479-483 M0000282 Through M0000298 14B.3 M0000299 Through M0000316 14B.3 M0000317 M0000325-326, 14B.3 M0000330-334, M0000337-339, M0000349-355

n-M0000356 M0000358, 14B.3 M0000361-366 Respectfully submitted b1 Jdp6ph Gdillo rN One of the Attorneys for COMMONWEALTH EDISON COMPANY Isham, Lincoln & Beale 1120 Connecticut Ave., N.W.

Suite 840 Washington, D.C. 20036 (202) 833-9730 u

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.. i August 5, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

COMMONWEALTM EDISON COMPANY )

) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )

AFFIDAVIT IN RESPONSE TO ROREM, ET AL.,

OUALITY ASSURANCE INTERROGATORIES 11 I, Steven C. Hunsader, being first duly sworn, hereby depose and say as followa.

1. I am employed by Commonwealth Edison Company (" Edison") in its Braidwood Projects Site Quality Assurance organization. My job title is Quality Assurance Supervisor. As a result of my experience in this position and others in the Quality Assurance organization, I have knowledge of the Edison quality assurance documentation system and of the filing and retrieval system for Quality Assurance documents both for Edison and for its contractors at Braidwood.

1

2. I have either conducted or reviewed the search of records which was conducted in response to specific Interrogatory No. 11. To the best

.of my ability to determine, the search has been thorough and complete. To the extent specific Interrogatory No. 11 is not objected to, the answer to specific Interrogatory No.11 is true and complete to the best of my knowledge and belief. To the extent the request for production of documents is not objected to, the documents provided or made available are a complete and accurate response to the best of my knowledge.

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3. The foregoing representations are made on the basis of my personal knowledge.

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Steven C. Hunsader SUBSCRIBED AND SWORN to before me this 2 M day of c

August, 1985 I IM6 k.Illll?:W Notary'Public j My Commission expires /d / 3o /f5 i

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August 5, 1985 WTEDCORRM UNITED S'ATES T OF AMERICA 00LKETED NUCLEAR REGULATORY COMMISSIONUSNRC BEFORE THE ATOMIC SAFETY AND LICENSING vs ava BOARR,19 u ru.

In the Matter of ) GFFILE u; ;t a. if,

) 00CnLTING & SERn!

COMMONWEALTH EDISON COMPANY ) Doc $b@>hos. 50-4 5 60L-

) 50-457 (Braidwood Nuclear Power Station )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of COMMONWEALTH EDISON COMPANY'S Second Partial Response to Rorem's First Set of Quality Assurance Interrogatories and Requests to Produce were served on the persons listed below by deposit in the United States mail, first-class postage prepaid, unless otherwise indicated, this 5th day of August, 1985.

1 Lawrence Brenner, Esq. Chairman C. Allen Bock, Esq.

Administrative Law Judge P.O. Box 342 Atomic Safety and Licensing Board Urbana, IL 61801 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and ,

Administrative Law Judge Licensing Board Panel 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 Callihan Atomic Safety and Administrative Law Judge Licensing Appeal Board 102 Oak Lane Panel Oak Ridge, TN 37830 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Bridget Little Rorem 117 North Linden Street P.O. Box 208 Essex, IL. 60935

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Myron Karman, Esquire Mr. William L. Clements Elaine I. Chan, Esquire Chief, Docketing and Services l Office of General Counsel U.S. Nuclear Regulatory j U.S. Nuclear Regulatory Commission ]

Commission Office of the Secretary I Washington, D.C. 20555 Washington, D.C. 20555

• Robert Guild, Esquire Douglass W. Cassel, Jr., Esquire Ms. Lorraine Creek Timothy W. Wright, III, Esquire Route 1 BPI Box 182 109 North

Dearborn Street Manteno,

Illinois 60950 Suite 1300 Chicago, Illinois 60602 Charles Jones, Director Illinois Emergency Services and Disaster Agency 110 East Adams Springfield, IL 62705

• Federal Express Service deposit on August 5, 1985 for delivery on August 6, 1985.

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,%e of the Attorneys for COMMONWEALTH EDISON COMPANY

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