ML20137V003

Response to Intervenor Rorem 860131 Request for Production of Documents.W/Certificate of Svc.Related Correspondence

ML20137V003
Person / Time
Site:	Braidwood
Issue date:	02/13/1986
From:	Kezelis E COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	ROREM, B.
References
CON-#186-101 OL, NUDOCS 8602190398
Download: ML20137V003 (5)

Text

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                                      $LIAIED CORRESPONDENC(February 13, 1986 t

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LMETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter Of: )

                                                )

COMMONWEALTH EDISON COMPANY C

)

                                                )    Docket Nos. 50-456CL-{gQ,fgj'}                    '
,'          (Braidwood Station, Units 1         )                 50-457 BRANCH I             and 2)                             )

RESPONSE OF APPLICANT COMMONWEALTH EDISON 3 COMPANY TO INTERVENORS' JANUARY 31, 1986 REQUEST FOR PRODUCTION OF DOCUMENTS In accordance with the provisions of 10 CFR S2.741(d), applicant Commonwealth Edison Company (" Applicant") by its undersigned counsel, hereby responds to Intervenors'

Request for Production of Documents to Applicant Commonwealth Edison Company, dated January 31, 1986.~*/

Request No. 1. Any and all weld inspection reports or documents reflecting the performance by ' former QC Inspector I. DeWald of more than 1,000

,                         welds during one day or on a single inspection document,. including but not limited to DeWald records included in drawing number 1-3061 as described by Inspector Dan Holley in his depo-sition testimony as January 28, 1986.
            */     Applicant notes that Intervenors' request for pro-                                   ,

duction of documents inappropriately referred to 10 CFR S2.744. That section governs production of NRC records and documents, and thus, is not applicable to discovery which Intervenors seek from Applicant. It is assumed that Intervenors intended their January 31, 1986 request for production of documents to be_ governed by the provisions of 10 CFR S2.741.

4 I 8602190398 860213 PDR ADOCK 05000456 .! g PDR bO

e Response No. l(a). Applicant has not completed its review of documents to determine whether any weld inspection reports or documents exist which may reflect the alleged performance by former QC Inspector I. DeWald of more than 1,000 welds during one day or on a single inspection document. In the event that any such documents are located, they will be made available for inspection and copying at a mutually agreeable time and place. (b) Documents reflecting Mr. DeWald's 1981 inspections which correlate to drawing number 1-3061 were produced on February 7, 1986. (D1 00011977-98) Request No. 2. Any and all documents or records compiled or maintained by fcrmer QC Supervisor R.M. Sakalak reflecting adverse, derogatory or other information regarding Comstock QC inspectors - the so-called " Pearl Harbor file" as described by QC Inspector Larry Phillips in his deposition testimony on January 29, 1986. (sic) Response No. 2. Applicant is not in the pos-session, custody, or control of any so-called " Pearl Harbor file" allegedly compiled or maintained by former QC Super-visor R.M. Saklak as described by QC Inspector Larry Phillips in his deposition testimony on January 29, 1986. Dated: February 13, 1986 Submitted by, Michael I. Miller Elena Z. Kezelis O. 7 # . ISHAM, LINCOLF & BEALE /dw / . f_( / [h Three First National Plaza One'of the Atybrnpysjfor Suite 5200 Applicant commonwpaIth Edison Chicago, Illinois 60602 Company (312) 558-7500

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7 @TED CORRESPORW j UNITED STATES OF AMERICA l

• NUCLEAR REGULATORY COMMISSION 00CMETED USNHC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 16 RB 18 40:29 In the Matter Of: )

                                                                                                                                         )                      0FFICE Or h, ~. -

COMMONWEALTH EDISON COMPANY ) 00CMETit:3 /. .u4,:U. BRANN

                                                                                                                                         ) Docket Nos. 50-456 i                               (Braidwood Station, Units 1                                                                               )              50-457 and 2)                                                                                                   )                                                       j l

l CERTIFICATE OF SERVICE I, Elena 3. Kezelis, one of~the attorneys for l I Commonwealth Edison Company, certify that copies of the Response of Applicant Commonwealth Edison Company To Inter-l Venors' January 31, 1986 Request For Production Of Documents I. have been served in the above-captioned matter on those persons listed in the attached Service List by-United States mail, postage prepaid, except as is otherwise noted on the Service List, this 13th day of February, 1986. 4eb[ Elena Zrf Ke aegis b ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 j (312) 558-7500 l E DATED: February 13, 1986 l l l

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8 e o . larbert Grossmn, "sq. atomic Safety and Licensina 'opeal Panel 01 airman United Ctates Nuclear Pegulatory Administrative Law Judge Ccm.tissica Atomic Safety and Licensing Board M shington, DC 20555 United States Nuclear Peculato q Cannission mshington, DC 20555 Dr. Richard P. Cole Mr. William L. Clenents Administrative Law Judge Chief, Docketing and Services Atanic Safety and Licensing Board United States Nuclear Regulatory United States Nuclear Reculatory Ccemission Ccmnission Office of the Secretary mshington, DC 20555 m shington, DC 20555 Dr. A. Dixon Callihan Ms. Bridget Little Forem Administrative Law Judge 117 North Linden Street 102 Oak Iane P.O. Box 208 Oak Ridge, TN 37830 Essex, IL 60935 Stuart Treby, Esq.

• Robert Guild
• Elaine I. Chan, Esq. Douglass W. Cassel, Jr.

Office of the Executive Ingal Director Tinothy W. Wright, III United States Nuclear Regulatory BPI Ccanission 109 tbrth Dearborn Street Mshington, DC 20555 Suite 1300 Oticago, IL 60602 l Atanic Safety and Licensing Board Panel Charles Jones, Director l United States Nuclear Pogulatory Illinois Dnergency Services and l Ccunission Disaster Agency M shington, DC 20555 110 East. Adams Springfield, IL 62705 l l

• By Personal Delivery

[

e I~' William Little, Director Braidwood Project'

          . Region III l

United States Nuclear Regulatory

    .         Ca mission 799 Roosevelt Road

! Glen Ellyn, Illinois 60137 Janice A.sStevens United States Nuclear Regulatory Otznission l- 7920 Norfolk Avenue" l Phillips Building Bethesda, MD 20014 M R ADDRESSEE OILY l George L. Edgar, Esq.

'1hcnas A. Schmutz, Esq.

Newman & Holtzinger, P.C. t 1615 L Street, N.W. Suite 1000 Washington, D.C. 20036 I

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