ML20137V145

From kanterella
Jump to navigation Jump to search
Objections & Third Partial Response to Intervenor Rorem 860124 Third Set of QA Interrogatories & Requests to Produce.W/Certificate of Svc.Related Correspondence
ML20137V145
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/13/1986
From:
COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:
ROREM, B.
References
CON-#186-100 OL, NUDOCS 8602190443
Download: ML20137V145 (19)
v • d • e


Text

' 4*

)$b

' t UNITED STATES 080ANER1b.k

" ggy,P0f NUCLEAR REGULATORY COMMISSION 00f.XETED USNHC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

COMMONWEALTH EDISON COMPANY ) Docket Nos.

) 50-45(0kiil.<.im 50-457c t BRoy (Braidwood Station Units 1 and 2 )

APPLICANT'S OBJECTIONS AND THIRD PARTIAL RESPONSE TO INTERVENORS' THIRD SET OF QA INTERROCATORIES AND REQUESTS TO PRODUCE On January 24, 1986, Intervonors filed their Third Set of Quality Assurance Interrogatories and Requests to Produce.

Applicant filed its First Partial Response on February 7, 1986 and its Second Partial Response on February 11, 1986. This submission is Applicant's Third Partial Response.

Applicant's Third Partial Response consists of Applicant's response and objections to Specific Interrogatory 10. For each document referenced or incorporated into Applicant's response a Bates number has been provided if that document was already made available. Additional documents and their respective numbers will be provided by February 24, 198(. ,

Documents for which Applicant is~ asserting a privilege will not be provided, and an index of privileged documents will indicate whether the attorney client ("AC") or attorney work product ("WP")

privilege is being asserted.

8602190443 PDR ADOCK h56 PDR Q

0736H

\x

') yn , )/

> \

i

e

. SPECIFIC INTERROCATORY 10

10. Please identify and describe in detail any and all studies, inquiries, reviews or evaluations of the effectiveness of, results and conclusions of the Braidwood Construction Assessment Program (BCAP); the " top twenty" corrective action programs at Braidwood identified in the April 8, 1985, correspondence from David H. Smith to James C. Keppler; and the " Ongoing Corrective Action Program" identified in Appendix B to the BCAP June 1984 program description transmitted by James J. O'Connor to James G.

Keppler by letter of June 22, 1984. As to each please detail the purpose and objectives, organization, methodology, procedures, staffing, implementation, results and conclusions of each. Please identify any documents which reflect these answers.

OBJECTION Applicant objects to and declines to answer this interrogatory to the extent that it requests identification and description of any studies, inquiries, reviews or evaluations protected by the work product privilege. Applicant moves concurrently herewith for entry of a protective order pursuant to 10 C.F.R. 2.740(c)(1985).

This privileged information is not discoverable. 10 C.F.R. 2.740(b)(1)(1985). Work product information concerning an expert which has been retained in anticipation of litigation but is not expected to testify, cannot be discoverable unless a showing is made of exceptional circumstances under which it is impracticable for the party seeking discovery to obtain facts or opinions on the same subject by other means. Kerr-McGee Chemical Corp. (West Chicago Rare Earths Facility), LBP-85-38, 22 N.R.C. 604, 616-17; cf. Fed. R.

Civ. P. 26(b)(4)(B). No attempt to make such a showing has been undertaken with respect to this interrogatory. Moreover, such a showing is unlikely. All materlat' facts relevant to the Amended QA Contention have been or are being produced. Under NRC practice, Isham, Lincoln & Beale must disclose any newly-discovered material 0723H/ February 11, 1986

+ ,,

SPECIFIC INTERROGATORY 10 l'

facts found by experts providing consulting services in anticipation of litigation, even if otherwise privileged. Therefore, protection of the work product pelvilege in this case is not contravened by any

" exceptional circumstances."

0723H/ February 11, 1986

1 l

SPECIFIC INTERR0CATORY 10 l

10. Please identify and describe in detail any and all studies, inquiries, reviews or evaluations of the ef fectiveness of, results and conclusions of 'the  !

Braidwood Construction Assessment Program (BCAP);  !

the " top twenty" corrective action programs at Braidwood identified in the April 8, 1985, ,

correspondence from David H. Smith to James C.  !

Keppler; and the " Ongoing Corrective Action Program" i identified in Appendix B to the BCAP June 1984 program description transmitted by James J. O'Connor to James C. Keppler by letter of June 22, 1984. As to each please detail the purpose and objectives, organization, methodology, procedures, staf fing, implementation, results a'dn conclusions of'each.

Please identify any documents which reflect these answers.

RESPONSE

Applicant has interpreted this interrogatory as requesting information on' overviews of the ef fectiveness, results and conclusions  ;

of the corrective action programs described in response to Specific Interrogatory 7 of Intervenors' Second-Set of QA Interroga' tories.

t To the extent that Appiteant has objected to this Specific Interrogatory, Applicant has not responded.

The NRC has reviewed corrective action programs identified by this Interrogatory. Some NRC reviews are identified 'in the response t

to Specific Interrogatory 7 (Second Set). Intervenors have received l

all NRC inspection reports and should be able to identify any reviews not referenced in the response and update to Interrogatory 7.

The NRC reports reflect or will reflect results, conclusions, purpose, f

methodology and implementation of the NRC's reviews.

l f

I i

O Reviews of BCAP BCAP Quality Assurance and the Independent Expert Overview Group (IEOG) conducted overviews of BCAP. The purpose and objectives, organization, methodology, procedures, staffing and implementation of BCAP Quality Assurance and the Independent Expert Overview Group are described in the BCAP Report (E0000731-E0000824) .

The BCAP Report summarizes the findings of the Quality Assurance Overview of BCAP in Appendix C. All BCAP QA records, including the Final Overview Report for BCAP QA (QC 71.5), have been made available for parties' review at the Braidwood site. The Final BCAP QA Overview Report is also available for inspection and copying as B0016297-370.

The IEOG issued its final report in December 1985 (E0005797-5839).

This report states the conclusions and results of the IEOG and des-l cribes the IEOG's staffing and methodology. All documents reficcting l the IE0G's work which were in official BCAP (11cs, BCAP QA files, or informal BCAP working files have been made available for parties' review at the location where they are stored. In addition, certain of these documents have been made available at the offices of Isham, Lincoln &

Beale by agreement between Intervenors' and Applicant's counsel.

At the request of Mr. John llansel of Evaluation Research Corpor-l ation, the General Office Quality Assurance Department conducted an evaluation of the RSCAP element of the Braidwood BCAP Program on September 10-14, 1984 and October 15-18, 1984. The report for this evaluation describes the purpose, methodology, and conclusions of the General Office Quality Assurance Review. This document has been made available for inspection and copying as B0016205-238. General l

Of fice QA audit 20-85-A (B006029-6046) examined the Construction Sample Reinspection (CSR) portion of the BCAP Program to verify compliance to applicable procedures. A detailed description of the audit results is presented in the audit report under the paragraph titled "BCAP CSR Progress". (More information concerning General Office Audits is provided in the section of this response titled "Other Corrective Action Programs").

Review of Other Corrective Action Programs The Special Project Group of Commonwealth Edison's Site Quality  ;

Assurance has conducted audits or surveillances of all the corrective action programs identified by this interrogatory except for BCAP. The introduction to the Response to Specific Interrogatory 4 (Second Partial Response to Second Set of QA Interrogatories)-and the Introduction to the Response to Specific Interrogatories 58 and 59 (Sixth Partial Response of First Set of QA Interrogatories) describes the purpose and function of the Special Projects Group. The fanctional organization of this Group is depicted on the attached organization chart (Attachment 1). The surveillances and audits conducted by this Group are identified on the attached Quality Assurance Reference List by the Corrective Action Program to which they relate (Attachment 2). These documents describe the results and conclusions for each surveillance or audit. In general, QA monitoring found that the audited activities were performed in an acceptable manner.

Commonwealth Edison General Office Quality Aasurance has also audited some of these Corrective Action Programa. These corporate audits have been performed at Braidwood on a four to six month cycle since the early stages of the project. The audits are performed under the direction of the Director of quality Assurance for Engineering and Construction. The Audit Team Leader and auditors are selected from members of the Quality Assurance Department who do not work at the Braidwood Site. These audits examined the activities of the site contractors and the site CECO Departments. The scope of these audits 8enerally covers a broad range of site activities with emphasis on key work activities or concerns as deemed appropriate for the time period during which the audit is to be performed.

Two corporate audits were performed of the Braidwood Site Correc-tive Action Program activities. The Audits #20-85-A and d20-85-D vere performed during the weeks of March 4, 1985 and May 13, 1985, respec-tively. A detailed discussion of the purpose, scope, references, staffing, results and assessment are included in each of the audit reports. General office audits are identified on the Quality Assurance Reference List (Attachment 2).

In addition, each of the contractors involved in these programs has a Quality Assurance Program which conducts audits of that Contractor's activities. Phillips, Cetschow Internal Audit 84-BR16 (K0036803-36806) reviewed MTV packages to verify compliance to the requirements of Procedure QCP-B31 " Material Traceability Verification Program." Com-stock Corporate Special Audit CQA-85-133 (00012075-178) reviewed the implementation of the following Corrective Action Programa s Electrical Conductor Extension Butt Splicos. LKC Document Review, and QCIRP.

These audit reports include the purpose, scope, references, staffing, results and conclusions of these reviews. In addition, site contractors perform regularly scheduled surveillances and audits of their procedures.

While these reviews are not overviews, the audited procedures include i

I  :

l

procedures which govern work performed for Corrective Action Programs.

Audits and surveillances of this type have or will be made available for inspection and copying as part of the document production responding to Specific Interrogatory 7 of Rorem's Second Set of QA Interrogatories and Requests to Produce and its update. These documents will be listed on the index for appropriate Corrective Action Programs.

BCAP looked at some of these corrective action programs in its Review of Significant Corrective Action Programs (RSCAP). RSCAP reviewed KTV, NSSS Components Support Verification Duct Fittings (as part of HVAC Retrofit Program review), LKC Document Review, Reinspection of Safety Related Equipment, Quality Control Inspector Reinspection Program (QCIRP), Quality Control Structural Steel Review (QCSSR), Safety Related Pipe Supports, and Instrument Retrofit Verification (IRV). In addition, although not an overview, the Construction Sample Reinspection (CSR) portion of BCAP inspected population items which overlapped partially with populations inspected as part of the following Corrective Action Programs: HTV, CEA Inspeutions. HVAC Installation Tolerances.

NSSS Component Support Verification, NSSS Support and NSSS Support Steel, Structural Steel Installation Traveler (SSIT). Newberg Welding Program, HVAC Housing and Air Risers, HVAC Duct Fittings, LKC Document Review, Reinspection of Safety Related Mechanical Equipment, QCSSR, and Safety Related Pipe Supports. The purpose and objectives, organization, methodology, procedures, staf fing, implementation, results, and con-clusions of BCAP are detailed in the " Report on the Braidwood Construction Assessment Program (BCAP)" dated November 1985. The report summarizes the results of the CSR and RSCAP programs. All documents which reflect these findings have been made available for parties inspection and 5-

copying. The RSCAP conclusions are discussed in more detail in the RSCAP Evaluation of Results (QG 69.50.2)(B0016239-296).

The National Board of Boiler and Pressure Vessel Inspectors (NBBPPVI) conducted an independent audit of the Braidwood Station at the request of Commonwealth Edison Company to address specific NRC i

concerns about ASME work at the Braidwood Site. Appendix A of the Report on Material Traceability Verification Program is NBBPVI's

" Supplementary Report on F0nf Program." This appendix describes the purpose, methodology, results and conclusions of the NBBPPVI audit '

with respect to MTV. A ccpy of the MTV Report has already been provided to Intervenors. Additional detail concerning the staffing, organization, scope and results of the NBBPVI review can be found in the NBBPVI's first interim report (L0000877-883) dated April 1, 1985 and second interim report (A0013536-13544) dated May 17, 1985.

i I I

ATTACHMENT 1 (Interrogatory 10)

SPECIAL PROJECTS & ACTIVITIES ,

S. C. (Steve) Hunsader QA Supervisor I I MECHANICAL STRUCTURAL / EQUIPMENT Mat rial Traceability Verification Mechanical Equipment Backfit ASMK Nameplate Pullman Rework:

ASME Section II Program Duct Fitting Verification N-5 Review Missing Weld I.D. - HVAC Welds Linear Indications - Duct / Stiffener Welds System Coi'rol Hexcell In:trument Retrofit Block Wall Column Backfit C:rroded Pipe QCSSR Mandrell Extrustion CEA Backfit SSIT Doc. Review CKNA Welding CKNA On-Coing Midway Kres-Duguid Flange Bolt-Up Program Equipment Internal Cleanliness ASME Material Procurer.ent (DRSS) Hanger Reinspection CB&I Rework Equipment Preventative Maintenace Recycle Hold-Up Tanks FCCo KRR Requests Field Erected Tank Repair Bio-Shield Repair NSSS Support Steel Structural Surveillances NISCo On-Coing Mechanical Surveillances est ffing included eight QA Engineers and two PTL Inspectors 1 \

i l

0120H \

O ATTACHMENT 2 (Interrogatory 10)

QUALITY ASSURANCE REFERENCE f.TST Corroded Ploe

1. Ceco QA survelliance 4507 Rev. 1 (LOOO1070-1075)
2. Ceco QA Surveillance 4968 (B0014756-14758)
3. Ceco QA Audit 20-85-521 (B0014829-14838)
4. Ceco GO Audit 20-85-A (50006029-6046)

.M

1. Ceco QA survelliance 3809 (B0016092-16095)
2. Ceco QA Surveillance 4181 (B0016097-16098a)
3. Ceco QA surveillance 4250 (B0016099-16105) 4 Ceco QA Surveillance 4458 (L000400-402)
5. Ceco QA Audit 20-84-592 (B0007591-7600)
6. Ceco QA Audit 20-85-446 (B0016055-16068)
7. Ceco QA t.udit 20-85-547 (B0008089-8095)
8. Ceco QA Audit 20-85-516 (80015484-15498)
9. CECO QA Audit 20-85-533 (B0002311-2321)

ASME Natorial Procurement

1. Ceco QA Surveillance 4699 (50014804-14807)
2. Ceco QA Surveillance 4874 (B0014797-14798)
3. Ceco QA surveillance 5069 (B0016174-16177)
4. Ceco QA Audit 20-85-553 (B0014808-14815)
5. CICo QA Audit 20-85-523 (B0014816-14824)

Nameplate Documentation Retrieval Pronram (NDRP)

1. Ceco QA Surveillance 4476 Rev.1 (80014825-14828)
2. Ceco QA Audit 20-85-521 (B0014829-14838)

CEA Inspections

1. Ceco QA surveillance 4566 (80016131-16132)
2. Ceco QA surveillance 4670 (B0016152-16153)

CEA's in Repaired Areas

1. Ceco QA Surveillance 4773 (B0014862-14869) ,
2. Ceco QA surveillance 4715 (80014905) 1
3. Ceco Go Audit 20-85-D (B0006797-6810) 0724H/ February 13, 1986

CEA's Finished Slabs

1. Ceco QA Surveillance 4607 (80014908)
2. CRCo QA Surveillance 4728 (B0014906-14907)
3. CECO GO Audit 20-85-D (B0006797-6810)

Welded & Bolted Connections - Block Wall Columns

1. Ceco QA Surveillance 4351 (B0016106-16107)
2. Ceco QA Surveillance 4389 (B0014917-14919)
3. Ceco QA Surveillance 4431 (B0014920-14921) 4 Ceco QA Surveillance 4550 (B0014915-14916)
5. Ceco QA Surveillance 4882 (B0014913-14914)
6. Ceco QA Surveillance 4397 ( )

HVAC Installation Tolerances

1. Ceco QA Audit 20-85-520 (80008053-8064)

NSSS Component Support Verification (NSSS Supports and NSSS Support Steel)

1. Ceco QA surveillance 5142 ( )
2. Ceco QA Surveillance 5149 (B0016191-16192)
3. Ceco QA surveillance 5248 (B0016193-16195)
4. Ceco QA Surveillance 4419 (B0016110-16124)
5. Ceco QA Surveillance 4650 (B0016136-16151)
6. Ceco QA Surveillance 4768 (B0014944-14945)
7. Ceco QA Surveillance 4830 (B0016158)
8. Ceco QA Surveillance 4885 (B0016159-16163)
9. Ceco QA Surveillance 5096 (B0016178-16180)
10. Ceco QA Surveillance 5097 (B0016181-16183)
11. Ceco QA Surveillance 5115 (B0016069-16071)
12. Ceco QA Surveillance 5368 (B0016196-16198)
13. Ceco QA surveillance 5388 (80016199-16200)
14. Ceco QA Surveillance 5389 (B0016201-16204)
15. Ceco QA Audit 20-85-510 (B0014970-14980)
16. Ceco QA Audit 20-85-530 (B0014959-14969)
17. Ceco QA Audit 20-85-551 (B0014946-14952)
18. Ceco QA Audit 20-85-523 (B0014416-14824)
19. Ceco QA Audit 20-85-557 (B0015823-15832)
20. Ceco QA Audit 20-85-550 (B0016043-16054)

Southwest Feb. Radioarashs

1. Ceco QA Surveillance 4750 (B0015009)

EIL Radioaraphic Density l

1. Ceco QA surveillance 4749 (B0016154-16157)
2. Ceco GO Audit 20-85-D (B0006797-6810) 0724H/ February 13, 1986 l

a Electrical Conductor Extension Butt solicos

1. CBCo QA Surveillance 4586 (B0016133-16135)
2. Ceco QA Surveillance 4708 (B0015043-15044)
3. Ceco QA Surveillance 4845 ( )

4.

Ceco QA Audit 20-85-503 (B0016034-16042)

5. CECO QA Audit 20-85-557 (B0015823-32)
6. CECO GO Audit 20-85-D (B0006797-6810)

Structural Steel Installation Travellers (ssIT)

1. Ceco QA Surveillance 3659.(80016078-16091)
2. Ceco QA audit 20-85-539 (B0006827-6851)
3. Ceco QA Audit 20-85-564 (B0016028-16033)
4. Ceco GO Audit 20-85-D (B0006797-6810)

Newbert Welding Program

1. Ceco QA Surveillance 4804 (B0008078-8085)
2. CECO QA Surveillance 3866 (B0015122-15138)
3. Ceco GO Audit 20-85-D (B0006797-6810)

HVAC Housing & Air Risers

1. Ceco QA Audit 20-85-520 (B0008053-8064)
2. Ceco Go Audit 20-85-D (B0006797-6810)

HVAC Duct Fittinas

1. CICo QA Surveillance 4652 (50015145-15152)
2. Ceco QA Audit 20-85-520 (B0008053-8064) t,KC Document Review
1. Ceco QA surveillance 4688 (B0015153-15167)
2. Ceco QA surveillance 4410 (B0016108-16108a)
3. Ceco QA Surveillance 4735 Rev. 1 (B0006984-7006)
4. Ceco QA Audit 20-85-522 (B0006957-6968)
  • I system control - Control Board Welding
1. Ceco QA Surveillance 4479 (50016129-16130a)
2. Ceco QA surveillance 5266 (B0014765-14767) l 0724H/ February 13, 1986

4 Reinspection of Safety Related Mechanical Equipment

1. Ceco QA Surveillance 4671 (B0015219-15221) l
2. Ceco QA Surveillance 4717 (B0015213-15214) '
3. Ceco QA Surveillance 4958 (B0016166-16167)
4. Ceco QA Surveillance 5196 (B0015215-15218)
5. Ceco QA Surveillance 4988 (B0008049)
6. Ceco QA Audit 20-85-505 (B0015229-15246)
7. Ceco QA Audit 20-85-546 (K0036206-36208)

Quality control Inspector Reinspection Proaram (OCIEP)

1. CECO QA Surveillance 4730 (B0015285-15306)
2. Ceco QA Surveillance 4902 (B0015267-15284)
3. Ceco QA Surveillance 5046 (B0015247-15266)
4. Ceco QA Surveillance 5056 (B0015229-15246)
5. Ceco QA Audit 20-85-515 (B0015312-15323)
6. Ceco QA Audit 20-85-507 (B0015353-15360)

Quality control Structural Steel Review (OCSSR)

1. CECO QA Surveillance 2931 (B0016072)
2. Ceco QA surveillance 3041 (B0001673)
3. Ceco QA Surveillance 3080 ( )
4. Ceco QA Surveillance 3134 (B0016075)
5. Ceco QA surveillance 3242 (B9916076)
6. Ceco QA Surveillance 3553 (B0016077) 7.- Ceco QA Surveillance 3976 (B0016096)
8. Ceco QA Audit 20-85-501 (B0015328-15334)

Safety-Related Ploe Supports

1. Ceco QA Surveillance 4472 Rev. 1 (B0016125-16128)
2. Ceco QA Surveillance 4667 (B0015350-15352)

(B0015368-15370)

3. Ceco QA surveillance 4997 (B0016170-16173)
4. Ceco QA surveillance 5289 (B0015392-15453)
5. Ceco QA surveillance 5181 (B0015324-15327)
6. Ceco QA surveillance 4891 (B0016164-16165)
7. Ceco QA surveillance 4992 (B0016168-16169)

Instnament Retrofit Verification (IEV)

1. Ceco QA Surveillance 4568 Rev. 2 (K0020921-20930)
2. Ceco QA Surveillance 4740 (B0015454-15455)
3. Ceco QA surveillance 5373 (B0015388-15391)
4. Ceco QA Surveillance 5062 (B0015499-15504)
5. Ceco QA Surveillance 4074 (L0001087-1128)
6. Ceco QA Audit 20-84-592 (50007591-7600) ,
7. Ceco QA Audit 20-85-516 (B0015484-15498) i
8. CMCo QA Audit 20-05-545 (B0015461-15467) 0724H/ February 13, 1986 l

i o

gggESPONDENCE i

=

UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION g

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

)

ColGIONWEAL'JH EDISON COMPANY ) Docket Nos. S g, ; y,

) 5- BRANCH (Braidwood Station Units 1 and 2 )

AFFIDAVIT OF ROBERT L. BYERS I, Robert L. Byers, being first duly sworn, depose and state as follows:

1. I an employed by Conunonwealth Edison Company as Assistant Superintendent for Unit 2 Construction, Project Construction Department at Braidwood Station.
2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
3. I have participated in the preparation of the response to Specific Interrogatory Number 10 filed by Intervenors Rorem el_ . a1_.

in their Third set of Quality Assurance Interrogatories and Request to Produce. In particular, I have responsibility for the portion of the response which concerns reviews by and of the RSCAP element of the BCAP Program.

4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 10 identified above is true and correct.

Further affiant sayeth not.

. . 1- -

Robert L. Byers(/

Subscel to and Sworn before me this day of February 1986 hLuAQ.M 9

b 0

My Commission expires on

/0/*/69 0738H/4

EUAiED CORHf.SPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00t.8ETED USHRC In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 86 FEB 18 A10:26

) 50-457 (Braidwood Station Units 1 and 2 ) Ff i**;'~

0 BRANCH AFFIDAVIT OF STEVEN C. HUNSADER I Steven C. Hunsadse, being first duly sworn, depose and state as follows:

1. I am employed by comonwealth Edison Company as Quality Assurance Supervisor at Braidwood Station.
2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
3. I have participated in the preparation of the response to Specific Interrogatory Number 10 filed by Intervenors Rorem et. al.

in their Third set of Quality Assurance Interrogatories and Request to Produce. In particular, I have responsibility for the portion of the response to Specific Interrogatory 10 which concerns overviews by Edison's General Office QA Department and the Special Projects Section of the Site QA Department as well as attachments 1 and 2 to the response.

4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 10 identified above is true and correct.

Further affiant sayeth not.

(  !" -

Steven C. Hunsader Subscrib to and Sworn before me this day f February 1986 e

My Comission expires on

/ 0/WF/ l l

0738H/2 l

I

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

)

COMMONWEALTH EDISON COMPANY ) Docket Mos. 50-456

) 50-457 {Ff 0 ( S .'l'J BRANOi (Braidwood Station Units 1 and 2 )

AFFIDAVIT OF CEORCE M. ORLOV I, George M. Orlov, being first duly sworn, depose and state as follows:

1. I am a consultant to commonwealth Edison company as Staff Assistant to the Project Manager at Braidwood Station.
2. My business address is Braidwood Nuclear Power Station, Braceville. Illinois 60407.
3. I have participated in the preparation of the response to Specific Interrogatory Number 10 flied by Intervonors Rorem et. al.

In their Third Set of Quality Assurance Interrogatories and Request to Produce. In particular, I have responsibility for the portion of the response to Specific Interrogatory 10 which concerns overviews of BCAP by the Independent Expert Overview Group and the scope of the CSR element of BCAP.

4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 10 identified above is true and correct.

Further affiant sayeth not.

Chivu W. 0 4 CeVege'M. Orlov Subscrib to and Sworn before me this day f February 1986

~

Ab - e f O' My Commission expires on 10/xW9 0738H/3

s IED CORREWONCLNN UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION COLKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 (FFitt e . < . .

) 50-457 u0CK ET A s af > c.I.

(Braidwood Station Units 1 and 2 )

CERTIFICATE OF SERVICE I, Gary A. Kruse, one of the attorneys for Conunonwealth Edison Company, certify that the following persons have been served in the above entitled matter with copies of Applicant's Third Partial Response to Intervonors' Third Set of Interrogatories and Request to Produce by deposit in the U.S. Mall on February 13, 1986 unless otherwise indicated.

SERVICE LIST Herbert Crossman, Esq. Mr. William L. Clements Chairman Chief Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Comunission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Washington, DC 20555 Dr. Richard F. Cole Ms. Bridget Little Rorem Administrative Law Judge 117 North Linden Street Atomic Safety and Licensing P.O. Box 208 Board Essex, Il 60935 United States Nuclear Regulatory Washington, DC 20555 Dr. A. Dixon Callihan Charles Jones, Director Administrative Law Judge Illinois Emergency Services 102 Oak Lane and Disaster Agency Oak Ridge, TN 37830 110 East Adams Springfield, Il 62705 0737H

, Stuart Treby, Esq. William Little, Director Elaine I. Chan, Esq. Braidwood Project Office of the Executive Legal Region III Director United States Nuclear Regulatory United States Nuclear Regulatory Commission Commission 199 Roosevelt Road Washington, DC 20555 Clen Ellyn, Il 60137 Atomic Safety and Licensing Janice A. Stevens Board Panel (For Addressee only)

United States Nuclear Regulatory United States Nuclear Regulatory Commission 7920 Norfolk Avenue Washington, DC 20555 Phillips Building Bethesda, MD 20014 Atomic Safety and Licensing George L. Edgar Esq.

Appeal Board Panel Thomas A. Schmuts, Esq.

United States Nuclear Regulatory Newman & Holtzinger, P.C.

Commission 1615 "L" Street, N.W.

Washington, DC 20555 Suite 1000 Washington, DC 20036

/

  • Robert Guild Douglass W. Cassel, Jr. .-'

Timothy W. Wright, III ~ '

BPI 109 North Dearborn Street Suite 1300 Chicago, Il 60602

  • Nessenger delivery on February 13, 1986.

d

) i buse ' */

Alld Garf A.

an '

Isham, Lincoln & Beale Three First National Plaza suite $200 Chicago, Illinois 60602 (312)558-7500 Dated: February 13, 1986 l

l l

l 0737H

,

Retrieved from "https://kanterella.com/w/index.php?title=ML20137V145&oldid=2828818"