ML20137U190

Second Response to Intervenor Second Set of Interrogatories. Related Correspondence

ML20137U190
Person / Time
Site:	Braidwood
Issue date:	12/02/1985
From:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	ROREM, B.
Shared Package
ML20137U173	List: ML20137U166 ML20137U190
References
OL, NUDOCS 8512090226
Download: ML20137U190 (24)

Text

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(q.ATED CORRESPONDENCE UNITED. STATES OF AMERICA hS$[i[c -

NUCLEAR REGULATORY COP 911SSION BEFORE THE ATOMTC SAFETY AND LICENSING BOARD 85 DEC -6 Pl2 :27 In the Matter of ) CNOkhshd'y

) 3 RANCH COMMONWEALTH EDISON COMPANY Docket Nos. 50-456 50-457

-(Braidwood Station, Units I and 2)

NRC STAFF SECOND RESPONSE TO INTERVEN0R'S SECOND SET OF INTERROGATORIES SPECIFIC INTERROGATORY

1. For each sub Control (QC)part, or item,

Inspector of the contention Harassment (including Contention), the Quality please describe in detail any actions, programs or factor upon which you rely to show that the matter asserted in the contention does not evidence a sig-nificant breakdown in quality assurance or a failure of safety-related parts, components, or systems to meet applicable regulatory requirements or to be capable of performing their intended function in service. Please identify any documents which reflect this answer.

ANSWER:

The vast trajority of the items comprising Intervenor's Amended Quality Assurance Contention are taken directly from the Notices of Violation issued in connection with the Region III inspection reports. The Appli-cant's response to each of the Notices of Violation describes the actions taken to correct the problem and to preclude its recurrence. The Appli-cant has also submitted 10 C.F.R. 5 50.55(e) reports concerning several of the items-described in the Notices of Violation which further describe corrective actions being taken by the Applicant.

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j In addition to its regular inspection program, the Staff is monitoring extapsively Applicant's adherence to the comitments made in its responses to the Notices of Violation and in its 10 C.F.R. 5 50.55(e) reports. The Staff will rely on its routine inspection program plus its inspections of the Applicant's corrective actions in determining whether there is rea-sonable assurance that no pervasive breakdown in the Applicant's QA/QC program has occurred, and that all safety related parts, components, and systems meet regulatory requirements and will perform their intended function in service.

Subpart IF - This contention is based upon a statement on Page A-4, Appendix A, Executive Summary of the NRC CAT Reports No. 50-456/84-44; No. 50-457/84-40 (IR 84-44/40). Since the concern was not identified in the Overall Conclusions of Appendix A or in the Potential Enforcement Actions of Appendix B of the same report, the Applicant was not required to respond to this concern. Although there is no specific regulatory requirement for trending programs, it is a commonly accepted method used to assist in the identification of trends that might result in significant problems. In order to determine whether the concerns identified by the CAT team are identified are indicative of a significant breakdown in quality assurance, the Staff will rely upon inspections perfonned during the past several years. These inspections did not uncover any significant deficiency which could be attributed to the concerns identified in the CAT report. In addition, the Staff is currently evaluating the contractor trending programs.

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, Subpart 2C - This part of the contention deals with allegations from .

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-- - -- severalindividuals~concerningpossibleharassmentandintimUationof L. K. Comstock (LKC) electrical QC inspectors. See August 8, 1985 Re-sponse to Interrogatory 55 for a summary of each of these allegations.

The Staff will rely on its investigations of these allegations to resolve the matters raised in subpart 2c. The actions taken by the Staff to date are summarized below:

Allegation RIII-84-A-0119: As stated in the Staff response to Inter-rogatory 55, this allegation was closed in Insaection Report No.

50-456/84-34; 50-457/84-32. The alleger was furnished with a copy of this report on January 21, 1985. The alleger did not then and has not since indicated any dissatisfaction with the Staff's resolu-tion of his complaint. On September II, 1985, Region III received certain information from the U. S. Department of Labor relating to certain statements purportedly made by the alleger which, in the Staff's view, warranted a reopening of this allegation. On September 13, 1985, the Staff requested additional infonnation from the alleger. As of this writing, however, the alleger has not responded to that request.

Allegation R-III-84-0123: Ro change from response to Interrogatory 55.

Allegation RIII-85-05: This allegation was partially closed in In- ,

spection Report No. 50-456/83044; 50-457/85043. Interviews with QC

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.. inspectors did not reveal. any instances of harassment or intimida- ,

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,, i s' ,g AllegationRIII-85-0067{ Thksallegationwasomittedinadvertently

, . c-from the Staff's response to Interrogatory 55. This allegation was s s, raised by an LKC QC. inspector and has three parts: (1) QC inspector reprimanded for alleged failure to meet production quotas; (2) QC inspectors improperly trained in conduit specifications; and

,y (3) L.K. Comstock's double flare bevel groove weld procedure was used by welders before it had been properly qualified.

As discussed in Inspection Report 50-456/85021; 50-457/85022, re-gional inspectors could not: substantiate parts (1) or (2) of this allegation. Part (3) of the allegation involving welding will be addressed in a future inspection report.

. Allegation RIII-85-A-0068: This allegation was closed by Region III inspectors in Inspection Report No. 50-456/85021; 50-457/85022. No instance of harassment and intimidation resulLing in procedural violations or the acceptance by LKC inspectors of discrepant work was identified.

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Allegation RIII-85-A-0072: This allegation, which consists of 17 .

parts or concerns, was closed in Inspection Report 50-456/85021; i

50-457/85022. The report substantiated the claim that one L.K. I Comstock supervisor had engaged in intimidating conduct. This su-pervisor was terminated by L.K. Comstock as a result of an investi-gation conducted by the Applicant after the allegers came to the NRC._ The staff's investigation did not reveal any instances in which the QC inspectors did not perform their inspections properly as a result of the alleged harassment and intimidation.

Subpart 3A - Sec NRC Staff First Response to Intervenor's Second Set of Interrogatories, Specific Interrogatory 1, response to subpart IB for the requested information.

Subpart _38 This part of the contention concerns a violation identified in NRC Inspection Report No. 50-456/85015; No. 50-457/85016. The violation (Region III Tracking Items No. 50-456/85015-01; No. 457/85016-01) was identified by Region III Inspector R. Schulz. The Applicant's response to this violation is documented in CECO's letter to NRC dated June 21, 1985 from D. L. Farrar to J. G. Keppler. The violation involved uncontrolled cutting of holes in webs of safety-related beams. The Staff will rely on its inspections of the corrective actions consnitted to by the Applicant in the above referenced e

response. Region III Inspectors R. Schulz and J. Muffett are conducting ,

the inspections to resolve this issue.

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6-3 Subpart 3C - This subpart concerns a violation identified in NRC o '

, Inspection Report No. 50-456/85006; No. 50-457/85007. This violation (RegionIIITrackingItemsNo. 50-456/85-06-02;No.50-457/85-06-02) was identified by Region III Inspector R. Gardner. The Applicant's respanse to this violation is documented in CECO's letter dated May 6, 1985 from D. L. Farrar to J. G. Keppler. In its response the Appli-cant disagreed that this is a valid violation of regulatory requirements.

Applicant agreed, however, to take action to strengthen its program.

The Staff is satisfied with the Applicant's action to strengthen their program. This will be confirmed in a future inspection report.

Subpart 4A - This subpart is derive.1 from 3 violation consisting of three examples or parts identified in NRC Inspection Report No. 50-456/84-07; No. 50-457/84-07. The item at issue was identified by NRC Inspector W. Kropp who is also responsible for its review and closure. The Appli-cant's response to this violation is documented in CECO's letter to the NRC dated August 20, 1984 from D. L. Farrar to J. G. Keppler.

The first part of this violation (Region III Tracking Items No.456/84-07-02(a);No.457/84-07-02(a))wasclosedinInspectionRe-port No. 50-456/84-42; No. 50-457/84-38. This inspection verified the Applicant's corrective actions described in their response referenced above. The inconsistencies upon which this violation was based is not indicative of a significant br.eakdown in Applicant's quality assurance program.

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Thesecondpartofthisviolation(RegionIIITrackingItems .

No.456/84-07-026;No.457/84-07-026) was closed in Inspection Report No. 50-456/85-32; No. 50-457/85-31, as was the third part (Region III Tracking Items No. 456/84-07-02c;No.457/84-07-02c). The concerns upon which these two parts of the violation were based are not indicative of a significant breakdown in quality assurance.

Subpart 48 - This part of the contention also is derived from Inspection Report 84-07. The Applicant's response is also referenced under subpart 4A. This problem (Region III Tracking Items No. 456/84-07-04; No.457/84-07-04) was identified by and will be resolved by NRC Inspector W. Kropp.

'Subpart 5A - This part of the contention is derived from a statement made on Page A-3 of the CAT Inspection Report (No. 50-45684-44;No.50-457/84-40).

The CAT Team did not regard this problem significant enough to highlight it under those items requiring additional management attention in the Overall Conclusion, (Appendix A), or to include it under the Potential Enforcement Findings, (Appendix B). Therefore, Applicant was not required to respond to this concern. Apparently, the CAT Team considerM Appli-cant's connitment to modify S&L Braidwood Field Instruction (BRFI) 4 adequate to resolve this problem. (See Page VII-12 of the CAT report Details). Region III will confirm that this field instruction was-modified. The Staff does not believe that this one instance identified' by CAT evidences a significant breakdown in quality assurance.

Subpart 5B - This subpart is.a derived from NRC Inspection Report 85-15. .,

This violation (Region III Tracking Items No. 456/85015-07; No.457/85016-06) was identified and will be closed by NRC Inspector W. Kropp. The Applicant's corrective actions are described on Page 16 of Inspection Report 85-15.

Subpart SC. - This part of the contention concerns a violation identified in Inspection Report No. 50-456/84-43; 50-457/84-39. The Applicant's response to the violation, including corrective action, is documented in Ceco's letter to the NRC dated April 15, 1985 from D. L.

Farrar Director of Nuclear Licensing, to J. G. Keppler, Regional Administrator. Inspector Moffett identified this violation and is also responsible for its resolution and closure. The NRC inspections of the corrective actions have been completed, and an inspection report will be issued soon.

Subpart 6B - This subpart relates to Violation 2.a. through 2.e.

identified in NRC Inspection Report 83-09. The Applicant's responses describing their corrective actions are documented in the Staff's interrogatory response relatina to subpart IB.

Violation 2.a. was assigned Region III Tracking Items No. 456/83-09-02(A);

No. 457/83-09-02(A) and was identified by R. Schulz who also has the responsibility for review and closeout. Inspection of this item is in progress. A followup inspection is documented in Inspection Report .

No. 50-456/85032; No. 50-457/85031.

Violation 2.b. was assigned Region III Tracking Items No. 456/83-09-02(B);

No.457/83-09-02(B). NRC Inspector J. Muffett will be responsible for review and closure of this item. This violation involved the failure to make piping wall thickness measurements during receipt inspection. A supplemental response to this violation was submitted by the Applicant's letter dated September 25, 1985 from L. O. DelGeorge to J. G. Keppler.

This letter also references the 30 day and supplemental reports submitted on this subject as 10 C.F.R. 6 50.55(e) No. 84-10. All of these documents describe corrective actions that the Staff will inspect to resolve this-issue.

Violation 2.c. was assigned Region III Tracking Items No. 456/83-09-02(C);

No.457/83-09-02(C). R. Schulz identified this violation and is respon-sible for review and closure. .

Violation 2.d. was assigned Region III Tracking Items No. 456/83-09-02(D);

No.457/83-09-02(D). R. Schulz identified this violation and documented his review and closure of the item in Inspection Reports No. 50-456/85032; No. 50-457/85031. The Staff's inspection of this item did not produce any evidence which would suggest that a significant breakdown in quality assurance had occurred.

Violation 2.e. was assigned Region III tracking Items No. 456/83-09-02(E);

No.457/83-09-02(E). R. Schulz identified this violation and P. Pelke reviewed and closed out this item in Inspection Report No. 50-456/85051; No. 50-457/85049. The Staff's inspections of this item do not indicate

a significant breakdcwn in Applicant's quality assurance program has .

occurred.-

Subpart 6C - This subpart concerns a violation noted in Inspection Report No. 50-546/85-07; No. 50-457/85-07. The Applicant's corrective-action is documented in its response dated May 3, 1985 from D. L. Farrar to J. G. Keppler. The violation (Region III Tracking Items No. 456/85-08; -No. 457/85-07-08) was identified by R. Schulz who also is respon-sible for review and closeout. A followup inspection was documented in Inspection Report No. 50-456/85032; No. 50-457/85031 (IR 85-32/31).

Inspection of this concern is in progress.

Subpart 6D - This subpart is a violation identified in the NRC inspection report referenced under subpart 6C above. The Applicant's response is also referenced above. In addition the Applicant documented a supple-mental response in the CECO letter dated September 9,1985 from A. D. Miosi, Nuclear Licensing Administrator to J. G. Keppler, Regional Administrator. R. Schulz ider.tified this problem and is responsible for.

review and closeout. It is assigned Region III tracking Items No. 456/85-007-02; No. 457/85-007-02.

Subpart 6E - This subpart concerns a violation noted in Inspection Report No. 50-546/84-31; No. 50-547/84-29. The Applicant's corrective action is documented in its. letter to NRC dated December 21, 1984 from D. L. Farrar to J. G. Kepoler. This item (Region III tracking Item No. 457/84-29-02) .

was reviewed and closed by NpC Inspector R. Schulz in Inspection Report

No. 50-456/85007; No. 50-457/85007. This violation did not evidence a .

significant breakdown in quality assurance.

Subpart 6F - This subpart concerns a violation noted in NRC Inspection Report No. 50-456/84-21; No. 50-457/84-20. The Applicant's corrective action is documented in its letter to the NRC dated January 31, 1985 from D. L. Farrar to J. G. Keppler. This violation (Region III Tracking Items No.456/84-21-03;No.457/84-20-03) was identified by NRC Inspector R. Schulz. Inspector Schulz reviewed the corrective actions and closed this issue in Inspection Report No. 50-456/85-07; No. 50-457/85-07. This violation did not evidence a significant breakdown in quality assurance.

Subpart 6G - This subpart is a violation identified in Inspection Report No. 50-456/84-17; No. 50-457/84-17 (IR 84-17). The Applicant's correc-tive action is documented by Ceco's letter dated November 28, 1984 from D. L. Farrar to J. G. Keppler. . Inspector R. Schulz identified this item (Region III Tracking Items No. 456/84-17-01;'No.457/84-17-01) and closed it in Inspection Report No. 50-456/84-42;_No. 50-457/84-38. The effect that chemical cleaning of the corroded-pipe had on the pipe wall thick-ness is being addressed by the corrective actions documented in the Ap-plicant's 10 C.F.R. 9 50.55(e) Report No. 84-10 submitted to the NRC on July 20, 1984.

- Interim reports on the above 9 50.55(e) report were submitted to the NRC on September 18, 1984; November 2, 1984; December 12, 1984; February 27, .

1985; and May'2, 1985. The final report is being prepared by the J

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Applicant. Inspector J. Muffett is responsible for review and closeout --

of this report.

Subpart 6H .This subpart is a violation identified in Inspection Report No. 50-456/84-09; No. 50-457/84-09 (IR 84-09). The Applicant's corrective action is described in Ceco's letter from D.'L. Farrar to l J.. G. Keppler dated July 31, 1984; October. 22, 1984; November 7, 1984; i

and February 13, 1985. This item (Region III Tracking Items No.'456/8'4-09-01;No.457/84-09-01) was identified by R. Schulz and review and followup responsibility has been assigned to J. Muffett.

Subpart 61 - This subpart is a violation identified in IR 84-09 by R. Schulz. The Applicant's responses are referenced under subpart 6H.

Mr..Schulz reviewed and closed this item (Region III Tracking Items No. 456/84009-05; No. 457/84009-05) in Inspection Report No. 457/85-16. .

The event did not evidence a significant breakdown in quality assurance.

Subpart 7A - This subpart is a violation identified in IR 83-09 by R. Schulz._--This issue (Region III Tracking Items No. 456/83-09-01; No. 457/83-09-01) is part of the small bore piping issues addressed in the Applicant's responses referenced under Subpart IB of the Staff's First Response to Intervenors Second Set of Interrogatories. Inspector

.J. Muffett is assigned review and closeout responsibilities for this item.

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Subpart 88 - This subpart is a. violation identified in IR 84-44/40. This item (Region III Tracking Items No. 456/84-44-03;No.457/84-44-03)was identified by CAT and became a violation in the Notice of Violation (NOV) documented in NRC's letter dated April 11, 1985 to Ceco from C. E. Norelius to Cordell Reed. The Applicant's corrective action is documented in its letter to NRC dated May 16, 1985 from D. L. Farrar to J. G. Keppler. Inspector R. Mendez is responsible for the review and closure of this item.

Subpart 8C - This is a violation identified in IR 84-44-40. This item (Region III Tracking Items No. 456/84-44-04;No.457/84-40-04) was iden-tified by CAT and became a violation in the NOV referenced under Subpart 88. The Applicant's corrective action is referenced under Subpart 88. Inspector W. Kropp is assigned to review and followup this item. A followup inspection is documented in IR 85-32-31.

Subpart 8D, 8E, 8F - This is a violation consisting of three examples identified in Inspection Reports No. 50-456/85-08; No. 50-457/85-08. The Applicant's corrective action is documented in CECO's letter to NRC dated May 15, 1985 from D. L. Farrar to J. G. Keppler. Inspector D. Williams identified and is responsible for review and closure of this item (Region III Tracking Items No. 456/85-08, 10a, -10b and -10c).

Inspection of these items is in progress.

Subpart 9A - This subpart is a violation with two examples identified in Inspection Report No. 50-456/S4-21; No. 50-4576/84-20 (IR 84-21/21).

The Applicant's corrective action is documented in Ceco's letter to the NRC dated January 31, 1985 from D. L. Farrar to J. G. Keppler.

These items (Region III Tracking Items No. 456/E4-21-01; No. 457/84-20-01; No.456/84-21-02;No.457/84-20-02) have been assigned to NRC Inspector J. Jacobson for review and closure. Item No. 456/84-21-01; No. 457/84-20-01 was closed out in Inspection Report No. 50-456/85040; No. 50-457/85039. This item did not evidence a significant breakdown in quality assurance. The second item is not ready for closure.

Subpart 9B - This subpart is a violation identified in IR 84-21/20 The Applicant's corrective action is documented under Subpart 9A. Inspector J._Muffett has been assigned responsibility for review and closure of this item (Region III Tracking Items Nu. 456/84-21-08;No.457/84-20-08).

Subpart 9C.- This subpart is a violation identified in Inspection Report No. 50-456/84-13; No. 50-457/84-13 by R. Schulz. The Applicant's correc-tive action is described in CECO's letter to NRC dated September 21-1984 from D. L. Farrar to J. G. Keppler. Inspector K. Ward reviewed and closed out this violation in Inspection Report No. 50-456/85-05; No. 50-457/85-05. This violation did not evidence a significant break-down in quality assurance and did not result in deficient welds.

Subpart 9D - This subpart is a violation consisting of two examples iden-tified in IR 84-17. The corrective action is documented in IR 84-17 and no response was required. Inspector K. Ward closed these items in Inspection Report No. 50-456/84-40; No. 50-457/84-37 (Region III

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tracking Items No. 456/84-17-06; No. 457/84-17-06; No. 456/84-17-08; '

No.457/84-17-08). These violations did not evidence a significant breakdown in cuality assurance, or in a component being incapable of performing its intended purpose.

'Subpart 9E - This subpart is a violation identified in Inspection Report No. 50-456/84-08; No. 50-4576/84-08. The Applicant's corrective action is documented in CECO's letter to the NRC dated June 21, 1984 from D. L. Farrar to J. G. Keppler. Inspector K. Ward reviewed and closed this violation in Inspection Report No. 50-456/85-05; No. 50-457/85-05.

The Staff's inspection did not reveal evidence of a significant breakdown in quality assurance. The lack of a specific requirement documenting weld fit-up verification did not appear to have resulted in unacceptable welds.

Subpart 108 - The subpart is an unresolved item (Region III tracking Items No. 456/83-09-04(a);No.457/83-09-04(A)andNo.456/83-09-04(B);

No.457/83-09-04(8)) identified in IR 83-09. This part of the contention consists mainly of ' quotations from the NRC letter transmitting IR 83-09 to the Applicant. All of the related documentation is referenced in the re-sponse to Specific' Interrogatory 1, Subpart IB, NRC Staff First Response

to Intervenor's Second Set of Interrogatories. This unresolved item was 4

identified by.NRC Inspector R. Schulz. NRC Inspector J. Muffett is responsible for review and closure. To resolve this issue the Applicant committed to carry out the Paterial Traceability Verification Program ,

(MTVP). The final report of the MTVP has been 1: sued and was transmitted l

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to the . Staff by letter dated November 20, 1985 from L. O. DelGeorge to J. G. Keppler. Staff followup inspection of the MTVP are documented in Inspection Reports No. 50-456/85-09; No. 50-457/84-09: No. 50-456/84-21; No. 50-457/84-20: No. 50-456/84-31; No. 50-457/84-29: No. 50-456/84-34; No. 50-457/84-32: No. 50-456/84-42; No. 50-457/84-38: No. 50-456/85007; No. 50-457/85007: No. 50-456/8515; No. 50-457/85016: No. 50-456/85043; No. 50-457/85042. The Staff's inspections to date have not revealed any design or safety significant deficiencies occurring as a result of the concerns identified in IR 83-09. The final Staff review is in progress and an inspection report will be issued.

Subparts 10C, 10D, and 10E - This contention is a violation conr.isting of three parts identified in the CAT (IR 84-44). The Applicant's corrective action is documented in the letter referenced in subpart 8B.

Subpart IOC (Region III Tracking Items No. 456/84-44-05; No. 457/84-40-05) has been assigned to Inspector P. Kaufman for review and closure.

Subpart 10D (Region III Tracking Items No. 456/84-44-06;No.457/84-40-06) is the same as Subpart 10. See the NRC Staff First Response to Inter-venor's Second Set of Interrogatories for the response to subpart 10.

Siopart 10E (Region III Tracking Items No. 456/84-4407;~~No. 457/84-40-07) has been assigned to P. Kaufman for review and closeout.

Subpart 10F - This subpart is a violation identified in IR 85-15/16. .

The Applicant's corrective action is documented in the June 21, 1985 ,

letter referenced under subpart 38. Inspector W. Kropp closed this

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item (Region III Tracking Item No. 456/85018-18) in Inspection Report No. 85-32/31. This violation appeared to be an isolated incident which did not evidence a significant breakdown in quality assurance.

Subpart 118 - This contention is a violation identified in inspection Report No. 50-456/84-39; No. 50-457/84-36. Inspector P. Pelke identi-fied this item (Region III Tracking Item No. 457/84-36-01) and is respon-sible for its review'and closure. The Applicant was not required to respond to the violation as the. inspector was satisfied with the correc-tive action taken prior to the completion of the inspection. Additional followup by the Staff in this area will be conducted when NRC Bulletin 82-04 is closed for Braidwood Unit 2.

Subpart 11C - This contention is a violation identified in Inspection

' Report No.-84-17. The licensee's corrective actions are included in the .

documents referenced under subpart 6G. Theviolation(RegionIIITrack-ing Item No. 456/84-17-02; No. 457/84-27-02) and has been assigned to J. Muffett for review and closeout.

Subpart 11D . This contention -is a violation identified in Inspection Report No. 84-07 by Inspector W. Kropp (Region III Tracking Items No. 456/84-07-05; No. 457/84-07-05). Mr. Kropp is responsible for review and closeout of the Applicant's corrective actions documented in Ceco's 1etter dated August 20, 1984 referenced under subpart 4A. This violation was closed in Inspection Report No. 85-32/31, and did not evidence a l

! significant breakdown in quality. assurance.

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Subpart 128,- This contention is Violation 1.a., 1.b., and 1.c. identi-fied in the_ Inspection Report No. 83-09 Notice of Violation. NRC Inspector R. Schulz identified this violation. The Applicant's corrective actions are in documents referenced in Subpart IB, Specific Interrogatory 1, NRC First Response to Intervenor's Second Set of Interrogatories.

Violation I.a. (Region III Tracking Items No. 456/83-09-07(A);

No. 457/83-09-07(A)) has been assigned to NRC Inspector J. Muffett for review and closeout.

Violation 1.b. (Region III Tracking Items No. 456/83-09-07(B);

No. 457/83-09-07(B)) has been assigned to NRC Inspector J. Jacobson for review and closeout.

Violation 1.c. (Region III Tracking Items No. 456/83-09-07(B); .

No. 457/83-09-07(B)) has been assigned to NRC Inspector J. Jacobson for review and closeout.

Subpart 12C - This subpart is a violation identified in Inspection Report No. 85-15/16 (Region III Tracking Item No. 456/85015-06). The Applicant's corrective action is documented in the June 21, 1985 letter referenced

-under Subpart 38. A followup inspection is documented in Inspection Reporttio. 85-32/31.

Subpart 120 - This subpart is Violation 4.a. and 4.b. identified in the Notice of Violation of Inspection Report No. 84-44. These items

(Region III Tracking Items No. 456/84-44-08; No. 457/84-40-08; and .

No.456/84-44-09;No.457/84-40-09) were identified by CAT and are assigned to NRC Inspector P. Kaufman for review and closeout. The Applicant's corrective action is referenced under subpart 88.

Subpart 12E - This subpart is Violation 2.a. identified in Iaspection Report No. 85-06/07. This violation has been withdrawn. See June 27, 1985 letter from C. E. Norelius to Cordell Reed.

Subpart 12F - This subpart is a violation identified in Inspection Report No. 50-456/85006; No. 50-457/65006. The Applicant's corrective actions are documented in CECO's letter to NRC dated May 6, 1985 from D. L. Farrar to J. G. Keppler, and in NRC's letter to Ceco dated June 27, 1985 from C. E. Norelius to Cordell Reed. NRC Inspector R. Gardner is responsible for review and closecut of this item (Region ,,

III Tracking Items No. 50-456/85006-01(B);No.457/85006-01(B)).

Subpart 12G - This subpart is a violation identified in Inspection Report No. 50-456/84-21; No. 50-451/84-20. The Applicant's corrective action is described in CECO letters to NRC from D. L. Farrar to J. G. Keppler dated January 31, 1985, February 27,1985, April 4,1985, and April 16, 1985. The Staff conducted a followup inspection documented in Inspection Report No. 50-456/85-11; No. 50-457/85-11. NRC Inspector T. Tongue has been assigned responsibility for final review and closeout

+ of this item (Region III Tracking Items No. 456/84-21-07; No.457/84-20-07).

P e-m -- y Subpart 12H - This subpart is .a. violation identified in Inspection Report No. 84-07.(Region III Tracking Items No. 456/84-07-06;No.457/84-07-06).

Mr. Kropp'is_ responsible for review and closeout of the Applicant's corrective action documented in CECO's letter dated AJgust 20, 1984 referenced under subpart 4A.

Subpart 12I - This subpart is a violation identified in IR 84-08 (Region III Tracking Items No. 50-456/84-08-02;No.50-457/84-08-02).

The Applicant's corrective action is documented in TECo's letters to the NRC from D. L. Farrar to J. G. Keppler dated June 21, 1984; September 12, 1984 and December 13, 1984. PRC Inspector J. Jacobson is responsible for review and closecut of this item.

Subpart 12J - This_subpart is a conterr Ritad by the CAT in the last paragraph, Overall Conclusions, Appendix A, IR 84-44/40. The Applicant was not required to respond to this concern in writing. IR 85-02, Report Details,'Page 7 documents steps taken by the Applicant to resolve this concern (Region III Tracking Items No. 50-456/84-02-03;

.No. 457/84-02-03). This issue is addressed in internal NRC memoranda dated March 1, 1985 and April 12, 1985 from C. - E. Norelius, Director, Division of Reactor Projects to J.- G. Keppler, Regional Administrator which are attached to IR 85-06 and IR 85-18 respectively. NRC Inspector R. Gardner is responsible for review and closeout of this item.

Subpart 138 - This subpart is a violation identified in Inspection Report No. 50-456/84-43; No. 50-457/84-39 (Region III Tracking Items No. 456/

l l

I

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. 84-43-01; No. 457/84-39-01). The Applicant's corrective action is documented in the following Ceco's letters to the NRC:

October 22, 1984 letter from L. O. De1 George to J. G. Keppler December 11, 1984 letter from T. R. Tram to J. G. Keppler April 22 1985 letter from T. R. Tram to J. G. Keppler NRC Inspector J. Muffett reviewed and closed this violation'in IR 85-40/39.

This violation did not evidence a significant breakdown in quality assurance, t

Subpart 14B - This contention is Violation 4.a. through 4.d. in IR 83-09. (Region III Tracking Items No. 456/83-09-08(A),(B),

(C), (D); No. 457/83-09-08(A), (B), (C),-(D)). The Applicant's documents describing their corrective action are referenced in '

subpart IB, Interrogatory 1, NRC Staff First Response to Intervenors

~Second Set of Interrogatories.

Violation 4.a. was identified by NRC Inspector R. Schultz who is also responsible for review and closeout. A followup inspection is documented in IR 85-32/31.

Violation 4.b. was identified by NRC Inspectors T. Vandel and P. Pelke is assigned responsibility for review and closecut. Inspection Report

, No. 50-456/85051; No. 50-457/85049 closed this item. The violation did not evidence a significant breakdown in quality assurance.

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Violation 4.c. was identified.by NRC Inspector'R. Schulz who is also responsible for review and closeout. A followup inspection is documented in IR 85-32/31.

Violation 4.'d. was identified by NRC Inspector I. Yfn and is assigned

'to NRC Inspector J. Muffett-for review and closeout.

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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COMMONWEALTH EDISON 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 Comission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137.

2. I have provided the answers to Specific Interrogatory 1 of the Staff's First Partial Response to Rorem's Second Set of Quality Assurance Interrogatories. These answers are true and correct to the best of my knowledge, information and belief.

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William S. Little/

Sworn topd sub cribed L before me this /6 day of 7(/d&r/a1985 Notary Public My Comission ExpiresJ2!d <Fj e

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00CKETING & SE8V!U NUCLEAR REGULATORY COP 91ISSION , BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -

In the Matter of )

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COMMONWEALTH EDISON COMPANY- ) Docket No. 50-456

) 50-457 (Brci uood Nuclear Power Station )

Unit.s 3 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, Illinois, 60137.

2. I have provided the answers to Specific Interrogatory 1 of the Staff's Second Response to Rorem's Second Set of Quality Assurance Interrogatories. These answers are true and correct to the best of'my knowledge, information and belief.

William 5. Little' Sworn to and subscribed before me this 4 6 day of W m 4 4985 Y0 Not#y Public W MyCommissionExpires-7/4/J%

- . _ .