ML20134P846

Status Rept Re Applicant 850729,30,0805,09,12,13 & 27 Responses & Objections to Intervenors 850702 QA Interrogatories & Requests to Produce.Related Correspondence

ML20134P846
Person / Time
Site:	Braidwood
Issue date:	09/03/1985
From:	Mark Miller ISHAM, LINCOLN & BEALE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20134P834	List: ML20134P831 ML20134P846
References
OL, NUDOCS 8509090068
Download: ML20134P846 (5)

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. Scptember 3, 1985 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

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

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Nuclear Power )

Station, Units 1 and 2) )

STATUS REPORT REGARDING APPLICANT'S RESPONSES AND OBJECTIONS TO INTERVENOR'S QUALITY ASSURANCE INTERROGATORIES AND REOUESTS TO PRODUCE The undersigned, counsel for Commonwealth Edison Co. (" Applicant" or " CECO") , and Intervenors Rorem et al

("Inte rvenors " ) submit the following status report regarding responses and objections to Intervenors' first set of l Quality Assurance Interrogatories and Requests to Produce.

Intervenors interrogatories were served on July 2, j 1985 and comprised 62 interrogatories, some with multiple subparts and one, Interrogatory 58, which required detailed 1 .

i information regarding 68 separate subsections of Interve,nors' Amended Quality Assurance contention. Documents reflecting each answer were also required to be produced. Applicant i filed its objections to certain of the interrogatories on July 29. Thereafter, Applicant filed partial answers to the interrogatories on July 30, August 5, August 9, August 12, ss August 13 and August 27. All but one of the interroga.ories to which no objection was filed by Applicant has now been NoR Q

M E S E s6 PDR 9

answered and that answer will be filed by September 6.

Counsel for all parties met in Chicago on f

i August 14 to discuss Applicant and Staff objections.to ,

Intervenors interrogatories, conferred on the telephone and in person thereafter on several occasions (the most ,

recent being August 29) and have reached an agreement as follows:

, I. Applicant objection '

A. Applicant will answer Interrogatory 10 by ,

I providing 10 CFR 50.55 (e) (iii) reports

initiated at other CECO facilities which predate such reports at Braidwood on N

l similar issues. Applicant will also

, provide a list of all 50.55 (e) reports

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initiated at all CECO sites.

i B. Applicant will answer interrogatories 1

13-16 by providing site procedures for Phillips Getschow, Pullman and PTL com-parable to those previously supplied for Comstock.

C. Applicant will answer Interrogatory 19 by providing rosters of QC and QA personnel i

employed by Phillips Getschow, Pullman,

i Newberg'and PTL (providing business addresses 4

and telephone numbers for current employees.  !

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d and last known home addresses and

' telephone numbers for ex-employees) and the reasons.for termination of r those indivi4uals comparable to the data' supplied for 'omstock. C

, ,D. Applicant will answer. Interrogatories 20 and 22 by providing complaints or sug-gestions submitted by site employees to the Quality First Program, Phillips Getschow,

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Pullman and ,Newberg regarding matters described in the Amended. Quality Assurance Contention.

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r Applicant 6nd' int'ervenors will discuss appropriate confidentiality protection for J names of interviewees contained in the Quality Firyt' files. ,

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E. Applicant will answer Inte rogatories 32-34 as limited to i'tems identified in NRC Inspection Report No. 83-09.

F. Applicant will' answer: Interrogatories 36 and 37 by providing documents and procedures which desc' ribe the identified programs at CECO's LaSalle and Byrcn s,tations.

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.G. Applicant will answer Intgrrogatory 40.

, H. Applicant will answer Interrogatory 61 by providing a narrative answer describing CECO's ,

quality assurance organization and providing v'

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organization charts for the quality control and quality assurance organizations of Phillips Getschow, Pullman and Newberg.

I. Applicant will make its best effort to answer the above interrogatories by September 6.

J. Despite its written objections, Applicant has answered Interrogatories 18, 25, 29, 30, 38, 39, 41, 42, 58, 59, 60 and 62 without regard to the objections.

K. Intervenors agree that the scope of Inter-rogatories 53 and 54 is limited to Comstock and that CECO has provided answers with respect to that contractor.

L. Applicant continues to object to Inter-rogatories 1-9, 17, 27, 50, 52 and 57.

Applicant has agreed to consider a more limited interrogatory relating to these portions of Interrogatory 51 to which it objected.

M. Applicant has provided Intervenor with a further description of its document indexing system and has agreed to consider providing further access to the document indexing system, Supplemental document l

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• indices will identif'y documents for which 4

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a claim of privilege is asserted.

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P Dated: September 3, 1985 g k I i ,

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~One o'f the Attorneys for One of the Attorneys for i Intervenors, Rorem et al.

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-Applicant, Commonwealth Edison Company f

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