ML20137C273
| ML20137C273 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/20/1985 |
| From: | Styles L COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | Guild R GUILD, R. |
| Shared Package | |
| ML20137C278 | List: |
| References | |
| CON-#485-297 OL, NUDOCS 8511260475 | |
| Download: ML20137C273 (2) | |
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ISHAM, LINCOLN & BEALE COUNSELORS AT t.AW 1920 CONNECTICUT Avf NUE.N W
- SUITE 840 .
WASHINGTON. D C. 20036 '
E OWARD S. ISHAM. It?21902 202 833 9730 CH8CAGO OFFICE ROBERT T LINCOLN 1872 1809 e THRE E FIRST NATIONAL PLAZA-WILUAM G. 8EAL(, tagg gg2J CHtCA U t)
November 20, 1985 3 TEux 242 8 Larv ,
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Robert Guild, Esquire BPI 109 North Dearborn Street Suite 1304 Chicago, Illinois 60602 Re: In the Matter of: Commonwealth Edison Company (Braidwood Station, Units 1 and 2) Docket Nos. 50-456 and 50-457 OL
Dear Mr. Guild:
On August 12, 1985, Commonwealth Edison Company
(" Applicant") filed its Fourth Partial Response to Intervenors Rorem, et al. ("Intervenors") First Set of Quality Assurance Interrogatories and Requests to Produce, on August 13, 1985, Applicant filed its Fifth Partial Response and on August 28, 1985, Applicant filed its Sixth Partial Response. Applicant's
. Sixth Partial Response provided responses to Specific Interrogatories 58 and 59, which posed specific questions with respect to the 68 ueparate items of Intervenors' QA Contention. Enclosed barewith are the affidavits of Messrs.
Seltmann, DeWald, Preaton, Shamblin, Quaka' and Fitzpatrick supporting certain of the responses provided in Applicant's Fourth, Fifth and Sixth Partial Responses. Certain of the responses have been revised or corrected as noted on the face of each affidavit.
The affidavit of Mr. Seltmann supports the response to Interrogatory 61 as corrected, provided in Applicant's Fifth Partial Response and the second, third, fourth and seventh paragraphs of the response to Interrogatories 58 and-59 which corresponds to contention Item 6.B.5 as corrected. ,
The remainder of the response to Interrogatories 58 and 59, i Contention Item 6.B.5 is supported by the affidavit of Mr.
Ifof fer -previously provided to you by letter. dated October 8, 1985.
The affidavit of Mr. DeWald supports the ,
supplemental response to Specific Interrogatory 13 as corrected, the portion of the responses to Interrogatories 14 and 16 that deal with L.K. Comstock Company as corrected, the 8511260475 85 $56 PDR ADOCK O PDR Q
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-D' ' Robert Guild,-Esq. ,
p i N o'v e m b e r 2 0 ~, 1985-Page 2 second, third, fourth and fifth paragraphs of the response to Interrogatory 15 as corrected, the information contained in Attachment.2 of the response to Interrogatory 19, all but the first and last paragraphs of the response to Interrogatory 21 and the fourth, fifth and sixth paragraphs of the response to Interrogatory 53. These responses were provided in Applicant's Fourth and Fifth Partial Responses.
'The affidavit of Mr. Preston supports the last paragraph of the response to Interrogatory 21 and the second paragraph of the response to Interrogatory 53. The affidavit of Mr. Shamblin supports the third paragraph of the response to Interrogatory 53. The affidavit of Mr. Quaka supports the second paragraph of the response to Interrogatory 15 as corrected. Attachment 1 of the response to Interrogatory 19 is supported by the affidavit of Mr. Fitzpatrick.
Although the affidavits themselves set out, where applicable, the. corrections made in each of the responses, revised versions of the responses which incorporate the corrections noted have also been provided for your convenience.
Very truly yours, dac.
Lisa C. Styles ns One of the Attorneys for Commonwealth Edison Company LCS:kls Enclosures cc: Service List
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SPECIFIC INTERROCATORY 13 Please describe in detail the selection, training, testing and evaluation program for Quality Assurance personnel and Quality Control '
Inspectors for Edison and for each contractor responsible for any safety-related construction at Braidwood from the connancement of construction until the present.
SUPPLEMENTAL Rg3 POW 3s As fully explained in Applicant's objections which were filed on
. July 30, 1985 Applicant has objected to the broad scope of this interrogatory. Applicant provided copies cf the training programs for Comstock weld inspectors and Newberg QC inspectors at Braidwood in its First Partial Response to Rorea's Yiest Set of Quality Assurance Interrogatories and Requests to Produce dated July 30,, 1985, as revisad August 1, 1985. This response provides inforination concerning the selection, training, testing, and evaluation programs for Comstock QA and QC personnel. ,
(1) The selection, training, testing, and evaluation of Comstock QA personnel is based on the requirements set forth in ANSI Standards M45.2.12 (1977) and N45.2.23 (1978), and the following requirements.
Selection is based on the position which is to be filled, as indicated in Procedure 4.1.2, " Position Delineation," paragraphs 3.21 through 3.23 (pages 00000933-0941), and Procedure 4.14.3, " Qualification, certification and Training of Auditors," Section 3.2, subparagraph 3.2.2 (pages 00000983-0991). The latter subperagraph states in part, i
" Personnel selected for Quality Assurance Audit assignments shall have experience / training commensurats with the scope and complexity of the activities to be audited and *.cho are independent of any direct responsibility for performance of the activities which they audit.
0072H/ August 8, 1985
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$3 Consideration sh'ould be given to'special abilities, specialized training, other pertinent experience, personal characteristics and education."
Training.for audit personnel is specified in Procedure 4.14.3,
" Qualification, Certification and Training of Auditors," Section 3.2, subparagraphs 3.2.3 through 3.2.6, and Section 3.4, subparagraph 3.4.3 through 3.4.'47 The aforementioned sections and subparagraphs apply to both Auditors and Lead Auditors.
The qualifications for Lead Auditors and Auditors are set out in the following Procedures: Procedure 4.14.3, Section 3.4, subparagraph 3.4.5,
'and Procedure 4.14.1, " Internal Audit Irogram," Section 3.5, subparagraph 3.5.1_ (pages 00000971-0982) . Evaluation of an Auditor / Lead Auditor to maintain certification is stated in Procedure 4.14.3, Section 3.2, subparagraph 3.2.8 (with respect to Auditors) and in Prceedure 4.14.3, Section 3.4, subparagraphs 3.4.7 through 3.4.7.3 (with respect to Lead
-Auditors).
(2). The selection, training, testing and evaluation of Comstock QC Inspectors is based on the requirements set forth in applicable portions of ANSI N.45.2.6, Commonwealth Edison Braidwood Nuclear Station Project Procedure PM-12, and the NRC's Regulatory Guide 1.58, Rev.-1, which are.
incorporated in Comstock Procedure 4.1.3, " Qualification, Classification
.and: Training of QC Personnel" (pages 00000942-0970). Selection of QC Inspectors is based-on education, experience and physical characteristics. The minimum education and experience requirements for certification of Level I,.II, and III Inspectors without exception are set forth in Procedure 4.1.3, Section 3.1, subparagraphs 3.1.1 through
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3.1.1.3. As indicated in Section I, subsection A of Project Procedure PM-12, the NRC has accepted an exception taken by Commonwealth Edison to the NRC's position in Regulatory Guide 1.58, Rev.-1, that candidates should be high school graduates or have earned the GED equivalent of a high school diploma. Therefore, the Braidwood procedures allow for the qualification and certification of personnel who do not have a high school diploma or GED equivalent.
The technical experience requirements for Level I, II, and III Inspectors are defined in Procedure 4.1.3, Section 3.1, subparagraphs 3.1.2 through 3.1.2.3. Suitability for specific job assignments is then defined in Section 3.2, subparagraphs 3.2.4 through 3.2.4.2.3.1.
Candidates are to be physically capable of performing their assigned tasks. Characteristics that are considered include near-distance acuity and color vision. See Procedure 4.1.3, Section 3.1, subparagraph 3.1.3.
Training of QC Inspectors is described in Procedure 4.1.3. Section 3.3, subparagraphs 3.3.2 through 3.3.2.4, indicate that the candidates will be indoctrinated to the applicable sections of the Comstock Quality Assurance Manual in order to obtain familiarity with all applicable procedures and a general working knowledge of installation and inspection procedures. Additional indoctrination is given pertaining to QA requirements, codes, standards, scope of work, and specifications. Upon
-completion of the general indoctrination, all candidates are given a written closed book test. Each candidate must achieve a passing grade of 80% or better.
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at Training of Level I and II Inspectors is defined in Section 3.3.3 l l
The candidate must at a minimum and subparagraphs 3.3.3.1 thru 3.3.3.3.
be administered the following training in each area of potential certification: -
- 1. A one-hour formal lecture;
- 2. An eight-hour lecture / demonstration;
- 3. Forty hours of "on the job" training to learn inspection techniques, documentation practices, and proper data taking, and to achieve a 100% proper accept /
reject skill.
At the completion of the OJT Training, a written evaluation of the trainee's ability to perform inspection activities is done.
Testing of candidates for certification is described in Section 3.5, subparagraphs 3.5.1 thru 3.5.1.4.1. Upon successfully satisfying the training requirements, each candidate / trainee is given a written forty-question closed book test from a test bank which consists of a minimum of eighty questions. An 80% passing score is required. In addition, a practical examination is also administered in which known rejectable and acceptable items are included. The trainee must obtain a 100% passing grade for the accept / reject criteria of the practical exam.
Should a candidate fail any test described in Procedure 4.1.3, the Level
- III examiner will evaluate the test and determine the extent of additional training required. If a candidate fails the second test, any additional testing will be evaluated in accordance with Section 3.2, subparagraph 3.2.1.2, which requires an exception letter to be written by the Comstock Site Quality Control Manager and concurred in by Commonwealth Edison PCD and QA.
0072H/ August 8, 1985
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j Performance Evaluation of Quality Control Inspectors is defined in Section 3.7. Quality Control personnel must be evaluated annually or at any other time as may be required in the specific discipline in which the
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inspector is certified. Quality Control Inspection personnel not performing inspection and test functions within a specific discipline during the one year period are retested in accordance with Section 3.5.
Yearly.ev'aluations are documented on the original certification form.
These evaluations signify that the inspector has performed inspection and test functions of specific disciplines. Recertification of Quality Control Inspectors is conducted for each area certified, during a period not to $xceed three (3) years, by administering a new General Inspection Proficiency Test per the requirements of Section.3.5.1.1.
This response describes the current program. Copies of revisions which have been made to Procedure 4.1.3 have been provided (page s' 00000001-0344). Copies of revisions to Procedure 4.1.2, 4.14.1, and 4.14.3 will be made available for inspection at a later date. ,
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l SPPCIFIC INTERROCATORY 14 l
, Please describe the job qualifications required of persons who are )
responsible for training, testing, certifying and supervising Quality l control Inspectors.
RESPONSg .
App 1 Leant has objected to this interrogatory to the extent that it seeks information for entities other than Comstock and Newberg.
(1) Comstock: The job qualifications required of those who are responsible for training, testing, certifying and supervising QC Inspectors are described below.
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The Quality Control Manager is to be qualified to a Level III capability in accordance with Procedure 4.1.2, " Position Delineation,"
Section 3.25 (pages 00000933-0941), and as defined in Comstock Procedure 4.1.3, " Qualification, Classification and Training of QC Personnel,"
Section 3.1, subparagraphs 3.1.1.3. Items A, B, C, D or g (pages 00000942-0970).
The Assistant Quality Control Manager is to be qualified to a Level III capability in accordance with Procedure 4.1.2, " Position Delineation," Section 3.26 and Procedure 4.1.3, " Qualification, Classification and Training of QC Personnel," Section 3.1, subparagraph 3.1.1.3 Items A, B, C, D or E.
The Quality Control Training coordinator must meet the qualification-requirements of a Level II Inspector. In addition, this individual is to
- h. Ave previous experience and training enabling him or her to administer and coordinate the training program.
0073H/ August 8, 1985
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As General Quality Control Supervisor must be trained and knowledgeable in the area of responsibility and have the necessary background experience'to meet the Level II capability requirements of ANSI N45.2.6 and Procedure 4.1.3, " Qualification, Classification and Training of QC Personnel," Section 3.1, subparagraph 3.1.1.2.
Quality Control Supervisor of Inspectors must meet the qualification requirements of a Level II capability as prescribed in Procedure 4.1.3,
" Qualification, Classification and Training of QC Personnel," Section 3.1, subparagraph 3.1.1.2. The qualification requirement is defined in Procedure 4.1.2, " Position Delineation," Section 3.29, subparagraph A.
The Quality Control Supervisor of Document Control is.a Level II capability individual with the background and experience required under Procedure 4.1.3, " Qualification, Classification and Training of QC
' Personnel," Section 3.1, subparagraph 3.1.1.2. This individual is trained and tested as defined in Procedure 4.1.2 " Position Delineation,"
Section 3.29, Subpara, graph B.
(2) Newberg:
TheQualityAssuranceManagerisresponsi6keforthetraining, testing, certifying and general supervising cf Quality Control Inspectort for G.K. Newberg. .Further supervisionfdf Newberg inspectors is provided
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by the Quality Control Supervisor. ,rNo specific job qualifications are
( required of either the Manager /of Supervisor. Level I and Level II inspectors are supervised dire /ctly by Level III personnel. The job qualifications required fg[ Level III personnel, including any requirements related prior nuclear experience, are set forth in the Quality Control Pr edure, Section 37, Revision 7 provided in response to Specific Interr atory 13, (pages 00000117-0113).
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4 SPECIFIC INTERROGATORY 15
- 15. Does Commonwealth Edison and its contractors have a program which insures the integrity of the testing and qualification for Quality Control Inspector certification? If so, please describe in detail the program or programs, all variations and changes in the program since construction began, and describe in detail and identify any deficiencies found in such testing and qualification.
RESPONSE
Applicant has objected to this interrogatory to the extent that it is not limited to the integrity of the testing and qualification of Comstock QC Inspectors.
The Manager of the Quality Control Program for Comstock is authorized to maintain the integrity of testing and qualification of inspection personnel. See QA/QC Manual Section 1.0.0 (pages 00000932).
The Quality Control Manager's responsibility in this area is further defined and detailed in Procedure 4.1.2, Subparagraph 3.25 (pages 00000933-0941).
The programmatic requirements for testing and qualification of Comstock QC personnel can be found in Procedure 4.1.3, " Qualification, Classification and Training of QC personnel" (pages 00000942-0970). This procedure _has been revised and approved for use several times since the initial approval date of July, 1979. The successive revisions to the
-procedure have been provided as part of Applicant's First Partial Response (pages 00000001-0344). The variations and changes to the Comstock procedure include addition of forms, clarifications and addition of detail, deletion of one area of certification as not required and addition of one area of certification to coincide with scope of work, addition of blanks to record dates for testing, certification, and expiration, and QC Manager signoff for individual areas of
r-o certification. In addition, the procedure was revised to incorporate enhancements to the Braidwood inspector certification program as directed by Commonwealth Edison. These included specifying minimum time frames for all training; establishment of test question banks; utilization of unique examinations; specifying separate indoctrination, general and practical examinations; ar.d weekly submittal of personnel certification status.
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The administration of the training program rests with the QC Manager. In order to compensate for the increased volume of activity in the testing and qualification aces resulting from the expansion of the QC work force, Comstock, in conjunction with Commonwealth Edison, established the position of-Quality control Training Coordinator in June of 1984. The Quality Control Training Coordinator is responsible for implementing the training program. See Procedure 4.1.3, subparagraph 3.27. In July of 1985, the training program was further enhanced by adding a supervisory level person to overview the inspector testing and qualification program.
The current program is defined by a procedure which conforms to the Commonwealth Edison project requirements for the qualification / certification of contractor personnel performing inspection l
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services at the Braidwood Station. The procedure includes the following provisions: 1. Verification of previous employment and education credited toward certification; 2. Formal indoctrination to the l applicable sections of the Comstock Quality Assurance Manual, codes, standards, specifications and scope work. This concludes with the satisfactory completion of an indoctrination examination with questions I
0075H/ August 8, 1985
selected from a test question bank; 3. Assigned read / study to an approved list; 4. Formal lecture for each area of certification;
- 5. Lecture demonstration and question / answer session for each area of certification; 6. Inspector on-the-job training and demonstrated capability'for-each area of certification; 7. General closed book
~ written examination with questions selected from a test question bank for each area =of certification; 8. Practical examination, using checklist (s) and inspection tools, on-all major types of different items to be inspected and, where practical, the use of hardware specimens with and without known defects; 9. Safeguarding the test question banks by the QC Manager; 10. Proper documentation and certification package record retention. Examinations are monitored by the Training Coordinator or one of the Level II inspectors working in the Training Department. The Training Coordinator grades them and_the QC Manager or another Level III inspector-reviews them. Completed tests and certification packages are maintained in the vault, to which access is controlled. Unsuccessful candidates receive additional training and may not take the test again until at least two days have passed.
In February, 1984, Commonwealth Edison Site Quality Assurance instituted a 100% review of all contractor quality control inspector certifications to ensure acceptability prior to the inspector performing actual. inspections in the field (page B0002322). This review remains in effect. Additionally, audits performed by Comstock and Commonwealth Edison provide an independent verification that the procedure is being implemented in accordance with the approved procedure. Those audits that have identified deficiencies are among those that have been submitted in response to Specific Interrogatory 11 (pages B0000000-0659).
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. fg NRC violation 84-07-02, Contention 4A, relates to the certification of Comstock inspectors. The NCRs identifying any deficiencies will be identified and made-available for inspection at a later date.
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SPECIFIC INTERROGATORY 16 What prior nuclear experience is required of persons responsible for supervising Quality Control Inspectors for~(a) Edison, and (b) for each contractor at Braidwood?
RESPONSE
Applicant has objected to this interrogatory to the extent that it seeks information for entities other than Comstock and Newberg.
'( 1) Comstock's Quality Control Supervisors must comply with Procedures 4.1.2 and 4.1.3 (pages 00000933-0941 and 00000942-0970). As delineated in Procedure 4.1.2, the Quality Control Supervisor of Inspectors "shall be trained and knowledgeable in the assigned areas of responsibility and will obtain certification to Level II capability in those areas." For the Quality Control Supervisor to obtain certification to Level II capability, he or she must meet the requirements of Procedure 4.1.3 for that level of certification as indicated in Section 3.0, subsection 3.1, Paragraphs 3.1.1.2 and 3.1.2.2. The requirements of Procedure 4.1.3 are in accordance with Commonwealth Edison Procedure PM-12 (pages A0013767-13780), American National Standards Institute N45.2.6, and Regulatory Guide 1.58.
(2) With respect to G.K. Newb g, the answer to this interrogatory is contained in the Response to pecific Interrogatory 14.
SPECIFIC INTERROGATORY 61 Describe in detail the organization established to execute the quality assurance program at Braidwood, including any material changes made in such organization from the inception of construction until the present. Please identify the numbers of persons performing each QA function for Commonwealth Edison and each contractor over the life of the project.
RESPONSE
Applicant has objected to the scope of Specific Interrogatory 61 and its response is limited accordingly.
The Comstock Quality Assurance Department is responsible for monitoring and maintaining the Quality Program onsite through the utilization and evaluation of audits, surveillances, trend analyses and procedure origination / revision, which assures compliance to contract specifications and regulatory codes. Prior to 1982, there was not a Comstock Site quality assurance organization. The Quality Assurance function was performed by the Comstock corporate office. In 1982, an on-site quality assurance organization was, formed. It initially was comprised of one Quality Assurance Engineer with support from Comstock's corporate quality assurance organization. There are currently six individuals assigned to this department. Attached are various organizational charts depicting the structure of the Quality Assurance organization from February of 1979 when L.K. Comstock commenced construction at Braidwood, to the current status of today. To comply with a Commonwealth Edison request, Comstock has provided a Licensing Coordinator who presently is the Site Quality Assurance Manager. This individual is responsible for the licensing requirements as related to LKC.
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- f-1 The-Quality Control Department is responsible for inspections within the-Comstock scope of work. Initially, there was only one Comstock-QC inspector assigned to Braidwood. There are now over 100. The number of inspectors for each inspection area and the organization charts for the Quality Control Department are found at pages 00001066-1094.
y CONTENTION ITEM 6.B.5
- 6. Contrary to criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Cossnonwealth Edison Company has failed to ensure that activities affecting
. quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
B. A special NRC QA inspection reported May 7, 1984 that:
- Contrary to L. K. Comstock Quality Assurance Manual, drawings located in site document Station Number 5 were voided in that they were up to four revisions old and were
- neither returned to document control as voided drawings nor marked as being voided drawings for_information only.
(Inspection Report 83-09, Exhibit 5.).
RESPONSE
NRC Quality Assurance Program inspections were performed on 6/20/83
- 6/24/83, 6/27/83 - 7/1/83, 8/1/83 - 8/5/83, 8/9/83, 10/4/83 - 10/7/83, 10/24/83, 1/11/84 - 1/13/84, 1/26/84 and 2/9/84 by T. E. Vandel, R. D.
Schulz, I. T. Yin, D. E. Keating, C. C. Williams and D. R. Hunter. The results of the inspections were recorded in Report Number 50-456/83-09(DE), 50-457/83-09(DE).
The subject report noted that when the NRC reviewed the drawing 4
racks at document station 5, the inspector identified a superseded
! drawing (revision (N) of drawing 1-3515). The current revision of the drawing was (S). This occurrence was contrary to L. K. Comstock Quality Assurance Program manual, Procedure 4.2.1 which requires the return of voided drawings to Document Control within three days. Comstock then performed a complete review of the drawings at document station 5. The review identified additional superseded drawing revisions which were
! removed from the current stick files, i
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a 0149H/ August 27, 1985
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CONTENTION ITEM 6.B.5 In response to the NRC findings, Comstock QC ince:ased the surveillance activity of the Document Control Department. Specifically, the Quality Control Department performed random monthly drawing control surveillances of document stations between July, 1983 and January, 1984 in accordance with Comstock Procedure 4.8.15.
In April of 1984, Comstock completed an internal audit (L.K.
Comstock QA Audit No. I-059-084) of all document stations performing safety-related work. Also, Commonwealth Edison Site Quality Assurance Department completed document audit 20-84-585 in May 1984 which resulted in a 100% review of all drawings controlled by L.K. Comstock. Both audits identified document control problems and resulted in the implementation of a plan to streamline the document control system.
Specifically, the plan a) reduced the number of document stations, b) reduced the number of drawings at each station, c) reduced the number of document master cards, d) eliminated void print files, e) computerized and reduced the number of transmittals, and f) restructured the Document Control Department.
Notwithstanding the fact that cases were discovered in which stick drawings used by crafts did not have the most up to date revision, the inspection process required Quality Control to use the latest revision of a drawing in its inspections irrespective of what was on the stick drawings. Thus QC would identify any hardware not in accordance with the
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CONTENTION ITEM 6.B.5 latest drawing. Commonwealth Edison Audit No. 20-84-585 found that all L.K. Comstock QC drawings sampled were the current revision.
Site QA is monitoring this activity with the results documented in surveillance 4212, 4451 and 4719. These results indicate that L.K.
Comstock drawings are being controlled properly and maintained up to date. Other major contractors' drawing control is subject to CECO surveillances on at least a quarterly frequency. Presently, Comstock is involved in other activities which will provide an additional measure of confidence that the correct revision of drawings has been used. A drawing review program is being formulated to address the NRC concern that revisions prior to April 1984 were not properly controlled. This program may involve a field walk down of current installations and/or a review of Comstock installation and Quality Control documentation with respect to the current field drawings. If the field installations are not installed and inspected to the latest drawing revisions, rework / inspections will be implemented in accordance with current site procedures.
Furthermore, under L.K. Comstock Procedure 4.13.1.1, Comstock is conducting a review of all inspection checklists. This review includes a check of the inspection checklist attribute recording drawing revision to assure that the proper drawing revision was used at the time of inspection. Any discrepancy found will be evaluated as part of the above referenced drawing review program to assure conforming of installed
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i CONTENTION ITEM 6.8.5 hardware to the appropriate design documents. Commonwealth Edison believes that the combination of the above programs will provide c confidence that the as-built configuration of the plant is in accordance with the latest revisions of design drawings.
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0149H/ August 27, 1985
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CONTENTION ITEM 6.B.5 REF53tDICSS
- 1. NRC Inspection Report 456/457/83-09 (pages A0001440-1507).
- 2. L. O. Del George letter to J. G. Keppler, dated 7/6/84
Enclosure:
Response to inspection report numbers 50-456/83-09 and 50-457/83-09 (pages A0001508-1572).
- 3. L. K. Comstock drawing review program, dated 4/25/85 (work instruction 4.2.2-01 is not approved) (pages 00002698-00002722).
- 4. L. K. Comstock Procedure 4.2.2, " Design control," dated 09/18/84 (pages 00002546-2553).
- 5. L. K. Comstock Procedure 4.2.1, " Document Control" (pages 00002535-2545).
- 6. L. K. Comstock Procedure 4.8.15, " Quality control Inspection of Document Stations" (pages 00002648-2652). , ,
- 7. L.K. Comstock Audit No. I-59-084 dated April 18, 1984 (pages 00002724-00002775).
- 8. Commonwealth Edison QA Audit No. 20-84-585 dated May 18, 1984 (pages C0003357-C0003378).
- 9. Licensing file on Item 83-09-02E, Cont. 6.B.5 (pages A0007314-7345).
l 0149H/ August 27, 1985 I
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CONTFNTION ITEM 6.B.5 NAMES AND ADDRESSES T. E. Vandel NRC Region III R. D. Schulz NRC Region III I. T. Yin NRC Region III D. E. Keating NRC Region III C. C. Williams NRC Region III L. O. DelGeorge Commonwealth Edison Company C. Mennecke Commonwealth Edison Company J. Gieseker Comunonwealth Edison Company D. Hoffer Commonwealth Edison Company I. Dewald L. K. Comstock F. Rolan L. K. Comstock J. Klena L. K. Comstock R. Seltmann L. K. Comstock 0149H/ August 27, 1985
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of: )
COMMONWEALTH EDISON COMPANY )
) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )
AFFIDAVIT OF EUCENE E. FITZPATRICK I, Eugene E. Fitzpatrick, being first duly sworn, hereby depose and state follows:
- 1. I am employed by Conunonwealth Edison Company as Assistant Manager of Quality Assurance at the Braidwood Station.
- 2. My buriness address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of response to Specific Interrogatory No. 19 filed by Intervenors Rorem, et. al. This response was submitted in Applicant's Fifth Partial Response to Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce on August 13, 1985. In particular, I am responsible for compiling the information contained in Attachment 1 of the response to Specific Interrogatory No. 19.
- 4. To the best of my knowledge and belief, the information contained in Attachment 1 of the response to Specific Interrogatory No. 19 of Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce was true and correct at the time it was submitted.
Further affiant sayeth not.
A Eugdne E. Fitzpatl'ick Subscribpdandsworntobeforeme this f*fi day of October, 1985 blib k . h '[ ['l Notary Publ'ic L My Commission expires on N - t 0317H
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of: )
COMMONWEALTH EDISON COMPANY )
) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )
AFFIDAVIT OF RAY PRESTON I, Ray Preston, being first duly sworn, hereby depose and state follows:
- 1. I am employed by Commonwealth Edison Company as Director of Quality First at Braidwood Station.
- 2. My business address is Braidwood Nuclear Power Station, Bracev111e, Illinois 60407,
- 3. I have participated in the preparation of the response to Specific Interrogatories Nos. 53 and 21 filed by Intervenors Rorem, et. al. These responses were submitted in Applicant's Fifth Partial Response to Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce on August 13, 1985. In particular, I have responsibility for the last paragraph of the response to Specific Interrogatory No. 21 and the second paragraph of the response to Specific Interrogatory No. 53.
- 4. To the best of my knowledge and belief, the statements contained in the last paragraph of the response to specific Interrogatory No. 21 and in the second paragraph of the .
response to Specific Interrogatory No. 53 of Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce are true and correct.
Further affiant sayeth not.
Ray [Preston Subscribed and sworn to before me this<?t/ day of October, 1985 l
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F UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of: )
. COMMONWEALTH EDISON COMPANY )
) Docket Nos. #5C-456 (Braidwood Nuclear Power ) #50-457 Station, Units 1 and 2) )
AFFIDAVIT OF DANIEL L. SHAMBLIN I, Daniel L. Shamblin, being first duly sworn, hereby depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as Project Construction Department Superintendent at Braidwood Station.
- 2. My business address is Braidwood Nuclear Power Station, Bracev111e, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory No. 53 filed by Intervenors Rorem, et. al. This response was submitted in Applicant's Fifth Partial Response to Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce on August 13, 1985. In particular, I have responsibility for the third paragraph of the response to Specific Interrogatory No. 53.
- 4. To the best of my knowledge and belief, the third paragraph si the response to Specific Interrogatory No. 53 ot intervenor's First Set of Quality Assurance Interrogatories and Request to Produce is true and correct.
Further affiant sayeth not.
M L Xi Daniel L. Shamblin Subscelbed and sworn before me this //"f / day of October 1985
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