ML20134C706

Supplemental Response to Intervenor First Set of Interrogatories & Requests to Produce Re QA Program

ML20134C706
Person / Time
Site:	Braidwood
Issue date:	08/08/1985
From:	Chan E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	CASSEL, D.W.
Shared Package
ML20134C669	List: ML20134C666 ML20134C706
References
NUDOCS 8508160405
Download: ML20134C706 (31)

Text

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August 8,'1985 l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DggcED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 Au"o 16 A10 54 In the Matter of )

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COMMONWEALTH EDISON COMPANY Docket Nos.50-457 50D56I3lcf '

(Braidwood Nuclear Power Station, UnitsIand2)

NRC STAFF SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS TO PRODUCE RESPONSES TO GENERAL INTERROGATORIES INTERROGATORY 1 Please state the full name, address, occupation and employer of each person answering the interrogatories or assisting in the preparation of such answers, and designate the interrogatory or the part thereof he or she answered.

ANSWER This answer supplements ou'r response filed July 31, 1985.

The following individuals participated in the preparation of the supplemental answers to the interrogatories. Those individuals who l

either prepared the answer or made major contributions to specific interrogatories are further identified.

W. S. Little General Interrogatory 1 and 2 I Director, Braidwood Project Specific Interrogatories 1-4, U.S. NRC Region III 40, 54 and 55 799 Roosevelt Rd.

Glen Ellyn, IL 60137 R. A. Fortuna Specific Interrogatory 55 Deputy Director, Office of Investigations U.S. NRC Washington, DC 20555 8508160405 PDR e5000s ADOCK 05000456 O PDR. .

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9 INTERROGATORY 2' l

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 sumary of the grounds for each opinion; and

c. Describe the witness' educational and professional background.

r ANSWER i

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a. and b. The following inspectors may testify concerning their inspection findings which' resulted in the violations listed in the QA contention. The basis for their testimony will be their knowledge and their documented findings in NRC inspection reports.

L. G. McGregor R. D. Schulz R. N. Gardner J. W. Muffett

C. C. Williams W. J. Key The above inspectors may also testify concerning the significance of their inspection findings and violations. Mr. Keppler and Mr. Little may testify as to the significance of the findings and violations from the Region III managen,ent perspective. Messrs. Jacobs; J Muffett and Williams may testify as to the engineering and Code significance of the violations in the areas of welding, mechanical, and electrical, respectively.

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,- v Mr. Little may testify as to the Region _ III management oversight of 7

the admitted corrective action programs (CAPS). Mr. Muffett may testify as to the adequacy of the admitted CAPS: Materials Traceability Verification, Corroded Piping and 82-05. He may be supported by additional witnesses with engineering and code expertise as necessary.

John G. Spraul may testify as to the Staff's review of the submitted QA program. The professional qualifications of all of the potential witnesses are set forth in their attached resumes.

3. Responses to Specific Interrogatories ,

INTERP0GATORY I Do you agree that th9 Braidwced 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?

ANSWER The Staff understands the term "Braidwood Quality Assurance Program" to mean the documented written policies, procedures or instructions thrcugh which the Applicant takes planned and systematic actions necessary to provide adequate confidence that the safety-related functions of a structure, system, or component will perform satisfactorily in service.

Fursuant to this understanding of the interrogatory, the Staff's answer is yes, unless a duly authorized exemption is requested and granted.

INTERROGATORY 2 If the answer to No. I 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.

4-ANSWER N.A. See 1.

INTERROGATORY 3 Does the Braidwood Quality Assurance Program comply with each of the criteria of Appendix B to 10 CFR Part 50?

ANSWER Yes.

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INTERROGATORY 4 What are the bases for your responses to Nos.1-3? 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.

ANSWER Preliminary Safety Analysis Report, Final Safety Analysis Report; and numerous Region III inspection reports starting in 1974. See also answer to Interrogatory 12. '

INTERROGATORY 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 NRC ever identified failure by Commonwealth Edison to apply such lessons learned? If so, describe such identification. Please identify any documents which reflect these answers.

ANSWER The Staff objected to the first two questions of this interrogatory.

With regard to the third question the Staff has not identified any failure by Applicant to apply the lessons learned at LaSalle in the area of HVAC installation.

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5- l INTERR0GATORY 5'4 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, specifications or procedures? If so, please describe in detail the circumstances of each such complaint, including the name and address of all person involved, the resolution and any corrective or remedial action taken. Identify any documents which reflect this answer.

ANSWER See the answer to No. 55.

INTERROGATORY-55  :

Please describe in detail any and all complaints by Comstock Quality Control inspectors or other QA personnel, including but not limited to those matters referred to in NRC Inspection Report.84-34/84-32, page 4.

Include names and addresses, current job title and status for all persons involved, the investigation and resolution of these complaints and any i

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

ANSWER ,

This answer only pertains to the admitted contention: alleged intimidation of L. K. Comstock QC inspectors. The staff is aware of the following complaints which have been brought to its attention:

1. Allegation 84-A-0119 John D. Seeders, Former Level II QC Inspector 115 West High Morris, IL 60450 This allegation is summarized and the results of the staff's conclusions described in the following Paragraph 2.b from Inspection Report 50-456/84-34; 50-457/84-32.

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"(Closed) Allegation (RIII-III84-A-0019). On August 17, 1984, the alleger, an employee of the L. K. Comstock quality control department, stated that he was intimi-dated and harassed by L. K. Comstock quality control supervisory personnel. On September 21, 1984, the 3 inspector met with the alleger and four other quality control inspectors. The five individuals did not provide any specific examples or records substantiating intimida-tion or harassment. During the course of the interview, it was revealed that the main issue is a morale problem which appears to be related to monetary matters and subjective opinions of poor management. The inspector met with Comonwealth Edison Project management and Construction Superintendent to discuss the issue of intimidation and harassment. Subsequently, Comonwealth Edison management met with the L. K. Comstock Site Quality Control management to ensure that all parties understood that any form of intimidation or harassment would not be tolerated by Comonwealth Edison or the NRC.

This allegation is considered closed."

2. Allegation RII-I-84-0123 Worley O. Puckett, Fonner Level III QC Inspector 3672 Spring Grove Road Bethel, Ohio 45106 Mr. Puckett alleged deficient Comstock welding activities and employment discrimination resulting in his being discharged by L. K.

Comstock. The DOL Wage and Hour Division Area Director concluded in a letter dated November 6,1984, that Mr. Puckett was a protected employee engaging in protected activity and that he was discrimi-nated against within the meaning of Section 210 of the Energy Reorganization Act of 1974. L. K. Comstock appealed the Area Director's decision. A Department of Labor (DOL) hearing concerning the employment discrimination charge comenced on. December 12, 1984.

The hearing was dismissed on January 11, 1985, after L. K. Comstock and Mr. Puckett entered into a settlement agreement. The Staff's 1

s inspection' into the deficient welding activities is in progress and will be documented in future inspection reports.

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3. Allegation RIII-85-05 An anonymous L. K. Comstock employee alleged deficiencies in the L. K. Comstock Rework Program and harassnent in the assignment of his work-hours. The Staff's inspection into this matter is in progress and will be documented in a future inspection report.

4. Allecation RIII-85-0062 ,

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An anonymous person alleged that L. K. Comstock supervisors and lead inspectors were not qualified.

The Staff's inspection into this matter is in progress and will be [

documented in a future inspection report.

5. Allegation RIII-85-0068 This allegation file relates to allegations received from three L. K. Comstock Level II QC inspectors, one of whom is anonymous and two whose names are confidential. The allegations were: inspector motivation and ability affected by pressure to perform large quanti-ties of work; NRC spread too thin; electrical inspector told not to inspect outside of his inspection area; (e.g. base metal reduction) and L. K. Comstock inspectors were qualified too quickly.

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The Staff inspection into these allegations is in progress and will be documented in a future inspection report.

6. Allegation RIII-85-A-0072 This allegation file relates to allegations received from twenty-four L. K. Comstock inspectors whose names and addresses were given to Mr. Cassel, Counsel for BPI, by the NRC Senior Resident Inspector Mr. McGregor, on July 24, 1985.

4 The allegations are summarized as follows: L. K. Comstock was more concerned with the quantity, rather than the quality of inspections;

unqualified supervisors; intimidation of QC inspectors by a QC supervisor; inspector closed out 93 hanger inspections in one day; closecut of NCRs without field inspections; ineffectiveness of the Comonwealth Edison Quality First Program; employment discrimina-tion; insufficient Comstock inspection staff; and, hangers were not built according to drawings. These allegations were immediately turned over to Comonwealth Edison to investigate and initiate any appropriate action. As a result a QC supervisor accused of intimi-dation was removed from his job, CECO management met with LKC management and with the Ll(C inspectors to emphasize quality and the methods available to inspectors to bring their quality concerns and complaints of intimidation and harassment to the attention of the proper persons.

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-9 The NRC inspection into the allegations and CECO's investigation and actions is in progress and will be reported in a future inspection report.

7. In addition to the above, the NRC Office of Investigations, has two open cases related to the subject matter of this interrogatory. The Comission has a special policy for disclosure of infomation when j OI investigations are conducted in areas with potential relevance to a pending adjudication. See 49 Fed. Reg. 36,032(1984)..

Respectfully submitted, n

Elaine I. Chan Counsel for NRC Staff Dated at Bethesda, Maryland this 8th day of August,1985 r

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[ cLtN ELLYN. BLLINO15 60137 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

C0!7.0NWEALTH EDIS0N COMPANY Docket Nos. 50-456 50-457 Braidwood Nuclear Power Station, 1 Units 1 and 2 )

AFFIDAVIT OF JAMES G. KEPPLER

a I, Jam s G. Keppler, being first duly sworn do depose and state

1. I am employed as the Regional Administrator, U.S. Nuclear Regulatory Conrission, Region III, 799 Roosevelt Road, Glen Ellyn, IL 60137.

2. I have provided the answer to Interrogatory 50. That answer.is true and correct to the best of my knowledge, information and belief.

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%%&nL (James G. Keppler Swore to and subscr;lbed before me this ,3 / dayof.Ou s ,_ 1985 V i hj7auub dasi Notary Public My Commission Expires r2 /fl.

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

COMM01, WEALTH EDISON COMPANY Docket No. 50-456 50-457 (Braidwood Nuclear Power Station 1 Units 1 and 2 )

AFFIDAVIT OF JOHN M. JACOBSON I, John M. Jacobson, being first duly sworn do depose and state:

1. I am employed as a Metallurgist, in the Materials and Processes Section, Engineering Branch, Division of Reattor Safety, Region III, U.S. Nuclear Regulatory Commission, 799 Roosevelt Road, Glen Ellyn, IL., 60137.

2. I have provided the answers to Interrogatories 25, 29, 33, 34, 35, 39, 47 and 48. These answers are true and correct to the

, best of my knowledge, information and belief.

LOls n>}(Jacobson Sworn to and subscrib before me \

this 4/ day of 6 1985

!  % oa s25t Notary 4 ublic 4

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NUCLEAR REGULATORY COMMISSI0';

"BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Ir the Matter of )

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00:*F.C:rn'EALTH EDISON COMPANY ) Docket No. 50-456

) 50-457 (Braidwooc huclear Power Statior, )

Units 1 and 2 )

AFFIDAVIT OF RONALD N. GARDNER I, Ronald N. Gardner, being first duly sworn do depose and state:

1. I ar employed as a Project Inspector, in Projects Branch 2, Division of Reactor Projects, U.S. Nuclear Regulatory Comission, Region III, 799 Roosevelt Road, Glen Ellyn, IL., 60137. . .

2. I have provided part of the answer to Interrogatory 24. That answer is true and correct to the best of my knowledge, information and belief.

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Ronald h. Gardner Sworn te and subscrib%before me this 8/ day of W'<-.f. 1985 4'

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of COR40NWEALTH EDIS0N COMPANY Docket No. 50-456 50-457 (BraidwoodNuclearPowerStation Units 1 and 2 AFFIDAVIT OF WILLIAM S. LITTLE I, William S. Little, being first duly sworn do depose and state:

1. I am employed as the Director, Braidwood Project, in the Division of Reactor Projects, U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, IL., 60137.

2. I have provided the answers to General Interogatories 1, 3 and 4 and Specific Interrogatories 5, 6, 7, 8, 15, 18, 23 and 60. Those answers are true and correct to the best of my knowledge, information and belief.

I M William 5. Little Sworn to and subscribe H efore me this .,.!// day of Vah 1985

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Notary Fublic My Comission Expires J/8d' 4

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i l h0 CLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i r

! In the Matter of C0WGNWEALTH EDISON COMPANY Docket No. 50-456 50-457  !

(Braidwood Nt. clear Power Station i Units 1 and 2 l l

AFFIDAVIT OF PAUL R. PELKE I, Paul R. Pclke, being first duly sworn do depose and state:

1. I am employed as a Project Inspector, in Projects Branch 3, in the Division of Reactor Projects, U.S. Nuclear Regulatory Comission, Region III, 799 Roosevelt Road, Glen Ellyn, IL.,  ;

60137  ;

2. I have provided the answers to Interrogatories 12, 21, and 51.

These answers are true and correct to the best of my knowledge,  ;

information and belief, i 0 h' Paul R. Pelke Sworn to and subscriked before me  !

this .5/ 0 ty of' _1,_/u _ 1985 lA4de '

Notary Public My Comission Expires .4 4'.

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY C0m!SSION l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l i

In the Matter of COMMONWEALTH EDISON COMPANY Docket Nos. 50-456 50-457 (BraidwoodNuclearPowerStation, Units 1 and 2)

AFFIDAv!T OF JOHN G. SPRAUL l

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I, Jchn G. Spraul, being first duly sworn do depose and state:

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1. I am employed as a Quality Assurance Engineer, in the Quality Assurance Branch, Division of Quality Assurance, Vendor, and t Technical Training Center Programs, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555.

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2. I have provided the answer to Interrogatory 12. That answer is true and correct to the best of my knowledge, information and belief.

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~ John G. Spraul l

Sworn to and subscribed before me thisr # M day of / 1985 f  ;^ %

Notary Public

! My Comission Expires _7///P6 l t t l

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3 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of WMONWEALTH EDISON COMPANY Docket No. 50-456 50-457 (Braidwood Nuclear Power Station )

Units 1 and 2 )  :

AFFIDAVIT OF JAMES W. MUFFETT I, James W. Muffett, being first duly sworn do depose and state:

1. I an employed as a Reactor Inspector, in the Materials and Processes Section, Engineering Branch, Division of Reactor Safety Region III, U.S. Nuclear Regulatory Commission, 799 Rcosevelt Road, Glen Ellyn, IL., 60137.

2. I have provided the answers to Interrogatories 24, 26, 27, 28, 31, 32, 36, 37, 38, 41, 42, 43, 44, 45, 46 and 49. These answers are _ true and correct to the best of my knowledge, information and belief, wC b-James W. Muffett W L

! Sworn to' and subscribed before me this ./ day of/i , _/ 1985 I

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Notary Public' w e. n... . . . . ..

My Commission Expires "

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EEEQBE_INE_61gd1G_SGEEIY_6UQ_LIGEUSIUQ_EQ66Q In the Matter of )

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COMMONWEALTH EDISON COMPANY ) Docket No. 50-456

) 50-457 (Braidwood Nuclear Power Station )

l Units 1 and 2 )

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GEEIDBY1I_0E_LEQUBSD_02_dCOBE008 I, Leonard G. McGregor. being first duly sworn do depose and state:

1. I a n. employed as the Senior Resident Inspector, Operations, U.S. Nuclear Regulatory Commission, Resident Inspectors Office, RP #1. Box 79, Bracevi l l e. IL. 60407.

2. I h+se provided pert of the answer to Interrogatory 24. That ar.2-er is true and correct to the best of my kno6. ledge, inforn.ation and belief.

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Leonard G. McGrego Sworn to and subscribed before me thio __/ d _ day of . _ _ 1985 r tary Public MY CX)MMIS$10N DMRES My Ccmmi ssi on Expi r es ___9qip!ER_1jdte!_______

UNITED STATES OF AMERICA 3

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r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DEEQBE_IBE_GIDMIC_EGEEIX_GUD_LIGEUSIUG_E98BD In the Matter of )

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COMMONWEALTH EDISON COMPANY ) Docket No. 50-456

) 50-457 (Braidwood Nuclear Power Station )

Units 1 and 2 )

1 6EEID8Y11_DE_E9EESI_Dz_SCOULI I, Robert D. Schul , being first duly sworn do depose and state

1. I am employed as the Senior Resident Inspector, Construction, U.S. Nuclear Regulatory Commission, Resident Inspectors Office.

RR #1, Box.79, Braceville. IL. 60407.

2. I have provided parts of the answers to Interrogatories 32 through 35, 07 through 39, and 41 through 45. Those answers are true and correct to the best of my knowledge, information and belief.

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Sworn to and subscrib d before me this __y g _ day of _ _

1985 h .H\1 Notary Public MyCommissionExpires__[.Q[_ $________

UNITED STATES OF AMERICA 1

o UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of COPHONWEALTH EDISON COMPANY Docket Nos. 50-456 50-457 (Braidwood Nuclear Power Station, Units 1 and 2) i AFFIDAVIT OF R0GER A. FORTUNA I

I, Roger A. Fortuna, being first duly sworn do depose .and state:

1. I am employed as the Deputy Director, Office of Investiga-tions, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555,

2. I have provided part of the answer to Interrogatory 55. That

, answer is true and correct to the best of my knowledge, information and belief. ,

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Subscribed ja d sworn to before me this ftA day of /2v;wT,1985

/ 'Sfb' f. ( u Notary Public My cosafssion expires: 4 3 /

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LEONARD G. MCGREGOR Organization: Nuclear Regulatory Commission, Region Ill litle: Senior Resident Inspector - Braidwood Station Gr:de. GG-14 Birth Date: August 26, 1935 Ecucation: South Dakota State College Civil Engineering, 1954 Experience:

1982 to Present Senior Resident inspector (Operations) - Braidwood, IL - Plans, supervises, and conducts inspections at the Braiowood site, to ascertain licensee compliance, public health and safety. Represents the NRC to the licensee, state and local officials, and the news media (NRC).

1982 to 1982 Actina Section Chief, Reactor Projects Section 28 -

Respcnsible for coordinating and controlling inspection activities related to construction and operation of assigned nuclear power plants (NRC).

1980 to 1981 Project Inspector - Inspected reactors in operation and coordinated inspection program at assigned sites (NRC).

1978 to 1980 Reactor Inspector,- Reactor Operations and huclear Support Branch - Inspect reactors in operation, test, and startup (NRC).

1976 to 197E Lead Mechanical Startup Enoineer - Startup and preoperational testing of Salem Unit 2. Supervised 14 startup engineers.

1976 to 1976 Director of Transportation - Responsible for operation, budget, scheduling, training and safety. Supervisory responsibility for 42 people (U.S. Navy).

1972 to 1976 Nuclear Power Plant Shift Supervisor /NPP Maintenance Supervisor /NPP Operation Supervisor Directed the operations for all maintenance shops and deck crew on a floating nuclear power plant, Supervised reactor refueling team and plant operations. Certified as a Shift Supervisor (U.S. Army).

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ROBERT 0. SCHULZ Organization; U.S. Nuclear Regulatory Commission. Region III

Title:

Reactor Inspector C adt. GG-14 Birth Date: June 9, 1946 Education: B.S., Northern Illinois University, 1970 Completed BWR Technology Courses and lwo-Week PWR Tecnnology Course, Chattanooga, TN Experience.

1984 tc Senior Resident Inspector (Construction) - Braidwood Present Site. P.lans, supervises and conducts inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media. (NRC) '

1983 to Reactor Inspector - Inspects reactors under construction 1984 and in operation._ (NRC) 1982 to 1963 Senior Resident Inspector - Nine Mile Point Plant, Region I, Construction Site. Plans, supervises and conducts inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media.

(NRC) ,

- 1981 to Resident Inspect r - Nine Mile Point Plant, Region 1,

. 1987 Construction Site. Performed 2513 and 2514 inspection programs at the Nine Mile Point Plant. (NRC) 1980 to Reactor Inspector - Inspected reactors under construction 1981 and in operation in Region III. (NRC) 1975 to 0. A. Engineer - Morrison Construction and Engineering, 1980 LaSalle Station, Braidwood lownship, IL. Mechanical Contractor.

1973 to Senior Buyer - Sundstrand Nuclear, Belvidere, IL.

1975 Purchased material for the fast Flux lest Facility located in Hanford, Washington.

1971 to Quality control Inst,ector - Morrison Construction and 1972 Inginevring, Zion Station, Zion, IL, Mechanical Contracter.

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RONALD N. GAP.0NER ORGAN 12AT10h: U.S. huclear Reculatory Comission. Region !!!

l TITLE: Project inspector, Division of Reactor Projects GRADF: CS-14 BIRTH DATE: June 19. 1945 I l EDUCATION: 196F - 1970, Thomas Nelson Comunity College  !

1970 - 1977, Vircinia Polytechnic Institute. B.S.

in Electrical ingineerino 1975, Department of the Navy, Ship Superintendent School (Nuclear)

EXPERIENCE:

July 1, 1985 to Project inspector - NRC - Maintaining status of operational Present anc regulatory performance of operating reactors.

Aucust 1984 te Project Manacer - NRC - Manages and coordinates '

July 1. 19Ri inspections / investigations of BCAP activities to assure l that the program is being conducted in accordance with ,

regulatory reautrements and licensee commitments.

October 1987 te Project Manager - NRC - Coordinate licensing activities and August 1984 'p_erform inspetti,nns on reactors under construction (Dffice of Special Cases).

October 1980 to Electrical Inspector - NRC - Perfom electrical inspections October 190l, on reactors under construction.

1977 to 196C tiectrical Incineer - Daniel Construction Company - i Responsible for systems completion and cable teminations  ;

on nuclear plants under construction. ,

1975 to 1977 riectrical Engineer Norfolk Naval Shipyard - Responsible  !

To~r timely overnaul of Nuclear Submarines, t 1972 to 1975 Electrical Test Encineer - Newport hows Shipyard - '

Responsible for testing of electrical systems on Nuclear Surf ace Ships, i

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. 1971 - 1975 Reactor Test and Startup and Operations Inspector -

Project inspectur at Browns Terr 7ToFthree years and Brunswick for six months. Assisted in inspections at

'other sites. (AEC. Region II) 1968 - 1971 Licensing Suaervisor - Managed B&W licensing activities forlrystal River, Davis-Besse, Three Mile Island and _

Bellefonte plants. Supervised three-four licensing  :

l en0i neers. (B&W) .

1966 - 1968 Syperv_isor, Emergency Core Cooline Test Section -

DeveToped and man ged research anc development programs in support of emergency core cooling systems for comercial nuclear power plants. Supervised four engineers.

(PhillipsPetroleumCompany) l 1965 - 1966 Supervisor. Heat Transfer Hydraulics and Radiography i

Section - Engineering support of test reactor operations I in areas of fuel inspection and testing; hydraulic l

facility, operation; safety analysis, preoperation, startup and surveillance testing; core thermal-hydraulics; and nuclear engineering. Provided radiography. service for NRTS.

graphers Supervised and NOT technicians. six-eight eng(ineers and six radio-PhillipsPetroleum) 1959 - 1965 Plant Engineering - Performod various engineering f" unctions in support of test reactor operation. ,

(Phillips Petrolcum Corupany) 1956 - 1959 Proicct Engineering - Project enginecring for liquid metal cifoiid" and fueled experiments in test reactors. (Phillips PetroleumCompany,)

1955 - 1956 in the area of Research heat transfer Engineering andief rigeration - Development systems. testing (Trane Corrpany) 1953 - 1955 F110t Plant Engineer - Organic chemical process development. (TerIriesee Corporation) l l

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• 3 JAMES K. MUFFETT Organization: Regior 171 71 tic: kcacter Inspector (Mechanical)

Crade

CS-14 Birth 14te : January 5, 1930 l Educa tior.: L. S. Phyr. ice., Purdue University 197 l MS Mechanicc: Engineerint l

University of.ldaho 197E l

l Ferie r rr.r ien: Preferrional T.ngineer. 733fecis. Indiant. Minnesets l

l L7pertenect ,

l 19r.; - 1rtiset }.c.arter insporter - Responribit fct insp9etior of reactor uncr constructae:. and it epicratier..

191 . - ; 9 t '; Enginerrint M.Innyty - Kanated t < chanical design and ar.s)ysit r,roup witt staf: ef 20 (hulech).

196( 19t; Product Lugineer - kesponsibic for development of edvancet

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Tesigr rieIbidt. (Internations) harvoster) 1971 - 196( Scrict Enrincer - Responsible for development and appit u.-

tact of advaneid, design methods. (Cuncius Engine Lt.., Inc.)

1975 197f adcr - Leader of piping analysir group whici.

l Croug pct,ormeLe,d,pipint senlysis f or LOFT reactor at2dehr l hationti Latineeritt I.ab. (EC & C Idaho) l

! 197;

• 1C7! itrese Analvet - Performed piping stress analysis, support sesign and f1c3d interface duties at variout nuclear power stations. (Sargent & Lundy) l  !

s CORDELL C k'1LLI AMS Orgar.17.a t ioni: hegior. III Titic- Chief Plant Systeine Section c sic: G5-15 Eirth bate- 11/26/39 i

l T.ducaticc: Cumilative 2 years i.o11can; University of Texas,

! kantin. 'lexm>

l Cor.tra Costa Collegt. Contra Costa. California (1:y. inv e r ing'-

Expericm.t:

l'6*. - Iret.er.; Ch i e.1. _ l I s nt Fyt t en Sect son - Engineerity Lnspectson L a os.cl. ~ Supervises enginet:ing support 11 spet.tcri, with

v>tien>1b112t v tur progree Anspections , invektigations.

Au;. inceirats to detern ant. for f at.111 tier undet Cor:-

A*.rc r.s t er and f,per n a cens , if wanagement's nperatannt une s er. .truct ten are at.t.o'eplished it. manni.r te protect 1.t:.111. and safety of tht publac. haconmend action to cuts si licensee t:a acharv+ cont);.ince with requirements.

(%C)

F/t; - 2/M Acy nt Cr.icj . EnMy, prig ini. rect toi. b anch - Manages, a brancl. consist ant of f our sect aunt having a staff of approxan.st ely'3L, prof essionals klth djverse engineering t>&cip r ounds . Th. . ranch is responsible for routine and

e s.ct s ve ins pe r,t i nnt of fer.!)f ties under constructior.,

rint tnt, preopernt innat tent inA and during operation.

Manarc> tht rerional prograrr f or evolustier. of oatters regardant.16pecialfred engineering skills.

19t1 Cniel, P1, ant 6,ysteeg Scetton l l'a79 196f Chis f. Frejcett. Sce t t et. Nt.. 2 - koactor Cons t ructiot, asic !.ntaneetant Support 1:anel.. hupervists project in peners vath responsibility for pror.rar innpections.

Anves.t agst ions., and inquiries tn determir.t. for faci)*

islet under construction if management ated conntruction, i are ar.comnlinhrd in a manner to protect health and 6af et) l cf the public. hecommend actiuti to cause # licensee to '

schsevt compliance sitt. requisee.ents. (hTC) 1975 - 1976 k.,g, actor Invriector Engiti+ering and Proje ct inspector l hvactor (,onstruct act. and Engineerint, Eupnt.rt branet.

l annocott nurlear poker pl&nts under constructint. and oper ot,lont (Anaservaco inspct.tson). (NNC/AIC) 1

______.__-_-__-_-_____--__-__-___--__--______._-_-_-_-_-__-___-_____-_-_-__-_-________--_____-__-___._-__-__._----__D

l t.'lI.I.I A': .1. K13 Orpntaattor. hegiosi !!!

T3tle. hva'. tor *nent.ctor Gradt: 05-14 t

l Firth D6tt: Ot'/27/24 1.d n attor.* Migh Scliool Graduatt:. tuo years entlege tredits l..s per t vor.r :

1

! !* * *. F i v > v t.t f.t.a c t e ? 1:4 1.tv e,t er . Try in et r itin P r og r eep ,,},r,,,g,11Q,4, Mate r sin 6 i,re.r.r.st.y,,.Nect 10t. - Inneryt cr inspection.

inaspect ice: of modisasetsons. and repairs of, operating

,  ::wele ci* co w n ? ricastvat. Innpnetion of nuc)*ar power ,

ld 0 fit f. Under uUlittrMtto!.. f MC) ,.

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• ! t g 1 *.,, J t ettt ttfi'.,s, ),t. h tige: + Q';*Bitt a gdit a r.y Anf'.

t .r u .; i l .w e et t.cs.s t ruct arer . n'.*. tvit t u c ! niiclear i .f t r f *. a f. . : t.s.ne; t.onst rut t ici.. fi i c.h .t i Corpor ation)

'. w l **t .,.;'La,td t 1 Cefit t ' ult 101 }hspector_And 1UDgtV)Sn

• an> pectin., tes,titig, and ecceptani.e et equipment manu-st.c?ure:n nr. thi (i.:ted State 6 and Japar. tn be used in ceaa.trut.li.,s of the Calif ornia aqueduct. (Department rf Latt: 1.t >g:te.cr., state of California) a 196* Nende strutt ive Mt in},,Tef.h 14i 9 fc jcig - Assist in f,te rarat ter. cf ND*. rroccai.ren. 'perf ore and evaluate tet.t results fr.r generatthg equipet.nt to be used

• aboard L.). Navy subearisees and nuclear power plants.

O, v 6 t i nt,hout.t Llettrir. Corporation) 1 % e

• l'n ' he ,t r,v i t Chief t!acJtnerY Rep,atraaf Various retinas ator, responsibilitsen an the Enr.ineersng Ltpartment and LM* 1ty /f t urai.ct Divisinr. abestd thiti grid an) ort.

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o JOHN M. JACOBSON Organization

• Region III litle: Reacto' Inspector (Metallurgist)

Graov. GS-14 Birte Date. May 25. 1949 Eoucat t or.+ B.S. Metallurgical Engineering, University of Illinois, 1975 Experience.

1984 - Present kcacto' Inspector, Division of Engineerino - Responsible for routine ano reactive inspections anc investigations of reactor plants unoer construction and operati*ng. (NRC) 195. 196: Senin Consultant Responsible for providing senio' consulting servicet ir the areas of welding meta 11urgy.

materiale , engineet ing, welding progran. ovvelopneent and ticio ope ations (hutech Engineers) 19EC 196: Sentoe welding Engineer - Responsible for welding proce-cure oevelopment, resolution of metallurgical / welding issues for both shop and field fabrication of nuclear containments. Duties included responsibility for the Metallurgical Laboratory and numerous research and development programs. (Graver Energy Systems) 1977 - 1980 Maintenance Staff Engineer - Responsibilities included coordination and development of station weldir.g programs, preparation of maintenance and repair procedures, design of plant modifications and technical direction of large scale maintenance projects. (Commonwealth Edison, Dresden hoclear Power Station) 1o75 - 197/ Quality Assurance Engineer - Responsible for review of contractor's crocedures, caily monitoring of welding and erection activities of the LaSalle County Nuclear Power Statfore, review and acceptance of NDE results and auditing of supplier's facilities, (Commonwealth Edison, LaSalle County Nuclear Power Station) l

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WILLIAM S. LITTLE T C S R B S JJL, &

Organization: U. 5. Nuclear Regulatory Conrnission, Region 111

Title:

Director, Braidwooc Project Grace: GG-15 Birth Date: August 22, 1930 Education: B. S. Chemical Engineering Georgia Institute of Technology, 1953 Professional Memberships: Member of ASME Workirig Group on Duties and Responsibilities (SCIII)

Experience: .

• 04/85 - Present Director, Braidwoed' Project - Manages the' Braidwood l

l inspection prograrri." Supervises three resident '

inspectors and two project inspectors. (NRC, Region III) 11/84 - 04/85 - Chief, Operations Branch - Managed a branch consisting of approximately 30 professionals with diverse engineering backgrounds. The, branch is responsible for reactor operator licensing and for routine and reactive inspections primarily at operating facilities. (NRC,RegionIII) 1982 - 11/84 i Chief, Enuineering Branch 2 - Manages a branch consisting ut three sections havTng a staff of approximately 35 professionals with diverse engineering backgrounds. The branch is responsible for routine and reactive inspections i ,.

at facilities under construction, during prooperational testing and during operation. Manages the regional ,

orogram for evaluation of matters regarding specialized cngineering skills. (NRC,RegionIII) {

i 1980 - 1981 Chief, Reactor Projects Section - Supervised seven resident irispecturs and one pr6 ject inspector responsible for the inspection; program at the Duane Arnold, Marble

-Hi!), Monticello and Prairie Island sites. (NRC, Region 111) 1975 - 1979 Chief, Nuclear Support Section - Supervised seven inspectors and one intern, prbviding specialists in support and the reactor operations inspection program; routinely irispecting,in areas of core physics, core thermal hydraulics, refueling, preoperational and startup testing, training and requalification and containment leak rate tests; and responsible for research reactor inspection progratts. (NRC,RegionIII) 3

J JAMES G. KEPPLER . . ...__  :

BIOGRAPHICAL INFORMATION

, _ _ , Mr. James G. Keppler has been Regional Administrator of the Nuclear Regulatory

, . Commission's Region III Office since 1973. (The Nuclear Regulatory Commission

• y was forned in January 1975 to take over the regulatory functions of the former Atomic Energy Commission.) *l l

r The Regional.4ffice .inhnf.l. lyn is .rgsponsible .fo,r..the NRC's .1'nspection '

program and other regulhter ctiviti stat NRCalicensed facilities in eight .

r midwestern states. This en ases $uclear power plants (24 reactors) now in operation 6 power. reactor under Onstruction at five sites,13 research reactors, four fuel facilities and 3,$00 byproduct materials licenses -- '

generally for medical, industrial or bducational applicat1ons..

Mr. Keppler joined the AEC in 1965 as a reactor inspector. Prior to his present post as Regional Administrator, he was Chief of the Reactor Testing and Operations Branch in the AEC Headquarters in Bethesda, Maryland.

He is a 1956 graduate of LeMoyne College in New York State. Mr. Keppler's experience in the nuclear field includes nine years with General Electric Company, first in its aircraft nuclear propulsion department and laterr inasta's reactor atomic power equipnent department.

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t JOHN G'.SPRAUL PROFESSIONAL QUALIFICATI0M5 OUALITY ASSURANCE BRANCH OFFICE OF IN5PECTION AND El.FORCEMENT ,

I am a Quality Assurance Engineer in the Quality Assurance Branch in the Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission. In this position, I am responsible for the review and evaluation of applicants' descrip-tions of quality assurance programs proposed for the design, construction, and l operation of nuclear power plants as assigned to me. l l

I received a Bachelor of Chemical Engineering degree from the Georgia Institute of Technology in 1951. In 1971. I completed the requirements for the Profes-sicnal Designation in Quality Control at the University of California, Los Angeles. My nuclear experience prior to joining the NRC include's 2 years of engineering w' o rk in gaseous diffusion with the Goodyear Atomic Corporation and 12 years'of nuclear fuel and nuclear power plant component design, manu-facture, and testing with the Atomics Internationti Division of Rockwell International. My quality assurance experience prior to joining the NRC includes 2 years as Chief Inspector and 4 years as Director of Quality Assurance at Atomics International, where I was responsible for managing the entire quality assurance program.

I joined the Quality Assurance Branch of the NRC in 1974. Since joining the NRC, I have reviewed the quality assurance program descriptions for design and construction and for operations for numerous nuclear power plants as well as topical reports on quality assurance submitted by utilities, architect-engineers, NSS suppliers, and constructors.

I am a mer.ber of the American Nuclear Society and a senior member of the American Society for Quality Control. In 1972, I was certified as a Quality Engineer by the American Society for Quality Control. This certification has been enewed r

to cover the 1983-1985 time period.

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1 UNITED STATES OF AMERICA EO NUCLEAR REGULATORY COMMISSION DN{C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 AUG 16 A10 :54 In the Matter of )

) 5MtNJ COMMONWEALTH EDIS0N COMPANY ) Docket Nos. 50-456 cmCE 00CKEiggf"gc

) 50-457 (Braidwood Nuclear Power Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF SUPPLEMENTAL RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS TO PRODUCE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, by deposit in the Nuclear Regulatory Commission's internal mail system (*), by hand delivery (**),

and express mail (***) this 8th day of August,1985:

Lawrence Brenner, Esq., Chairman ** Commonwealth Edison Company Administrative Judge ATTN: Cordell Reed Atomic Safety and Licensing Board Assistant Vice President U.S. Nuclear Regulatory Commission P.O. Box 767 Washington, DC 20555 Chicago, IL 60690 Herbert Grossmar., Chairman ** Thomas J. Gordon, Esq.

Administrative Judge Waller, Evans & Gordon Atomic Safety and Licensing Board 2503 S. Neil U.S. Nuclear Regulatory Commission Champaign, IL 61820 Washington, DC 20555 Dr. A. Dixon Callihan*** Region III Administrative Judge U.S. Nuclear Regulatory Comission 102 Oak Lane Office of Inspectfon & Enforcement Oak Ridge, TN 37830 799 Roosevelt Road Glen Ellyn, IL 60137 Dr. Richard F. Cole ** Joseph Gallo, Esq.

Administrative Judge Isham, Lincoln & Beale Atomic Safety and Licensing Board Suite 840 U.S. Nuclear Regulatory Comission 1120 Connecticut Avenue, N.W.

Washington, DC 20555 Washington, DC 20036 Rebecca J. Lauer, Esq.

Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, IL 60602

4 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 Emergency 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 -

Manteno, IL 60950 l

J-o b. b Elaine I. Chan Counsel for NRC Staff I

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