ML20138D914

Second Set of QA Interrogatories & Requests to Produce Re 850621 Amended QA Contention.Certificate of Svc Encl.Related Correspondence

ML20138D914
Person / Time
Site:	Braidwood
Issue date:	10/21/1985
From:	Guild R GUILD, R., ROREM, B.
To:	COMMONWEALTH EDISON CO.
References
CON-#485-882 OL, NUDOCS 8510240490
Download: ML20138D914 (12)

Text

{{#Wiki_filter:. c l 9 RELATED CORRESPONDENCS 10/21/85 . UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 97

                                                         ~

Y[o l[h N403 l 4 i BEFORE THE ATOMIC SAFETY AND LICENSINC BOAbT23 g O c: ? % n 5 k Yh.fL 1 YI In the Matter of: ) COMMONWEALTH EDISON COMPANY ) / p#/Il.N-$ s

                                          )  Docket Nos. 50-4 (Braidwood Nuclear Power               )                50-457 Station, Units 1 and 2)                )

ROREM, ET AL., QUALITY ASSURANCE INTERROGATORIES AND REQUESTS TO PRODUCE, SECOND SET Pursuant to 10 CFR Sections 2.720(h)(2)(ii), 2.7 4 0 b , 2.741 l l and 2.744, Bridget Little Rorem, et al., ("Intervenors") hereby l serve their Quality Assurance Interrogatories and Requests to Produce, Second Set, upon the Applicant and the NRC Staff. These interrogatories involve Intervenors' amended quality assurance contention admitted June 21, 1985. Each interrogatory should be answered fully in writing, under oath or affirmation, and include all pertinent information known to the NRC Staff and the Applicant, including their officers, directors, em ployees , agents, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of the NRC Staff and the Appli-cant, including their officers, directors, employees, agents, advisors or counsel. In answering each interrogatory and in responding to each request, please recite the interrogatory or request preceding each answer or response., Also, please identify the person providing each answer or response. 8510240490 ADOCK O 85 g 56 - PDR PDR 0 1)SS J

These interrogatories and requests shall be continuing in nature. Thus, whenever information is obtained which renders any  ! previous response incorrect or indicates that a response was incorrect when made, a supplement should be made to the previous response to the appropriate interrogatory or request to produce. Supplements should be made to the responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. Intervenors are particularly interested in the names and areas of expertise of witnesses, if any. Such identification of witnesses is neces-sary if Intervenors are to be afforded adequate time to depose them. The term " documents" shall include any writings, drawings, graphs, charts, pho tog ra phs , and other data compilations from which information can be obtained. Intervenors request that at a date or dates to be agreed upon, the NRC Staff and the Applicant make available for inspection and copying, all documents subject to the requests set forth below. REQUESTS TO PRODUCE Pursuant to 10 CFR Sections 2.741 and 2 744, Intervenors request that the NRC Staff and Applicant make available for inspection and copying at a time and location to be designated, but as soon as possible, any and all documents, of whatsoever description, identified in the responses to the interrogatories below, including but not limited to: 2 s"

                                                                   -       n ,

(1) any written record of any oral communication between or 1 among Applicant, the NRC Staff, either of their l contractors, advisors, consultants, agents, attorneys and/or any other persons, including but not limited to

             ,- the NRC Staff, Applicant, Intervenors, and tneir advisors, consultants, agents, attorneys and/or any other persons; and (2)   any documents, correspondence, letter, memorandum, notes, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to workpapers, prior draf ts, and notes of meetings.

If NRC Staff and/or Applicant maintain that any documents should not be made available for inspection, they should specify the documents and explain why such are not being made available. This request extends to any such document, described above, in the possession of Applicant, NRC Staff and their advisors, consultants, agents or attorneys. INTERROGATORIES Pursuant to 10 CFR Sections 2.740 b , 2.720(h)(2)(ii), Inter-venors requests NRC Staff and Applicant, by and through their attorneys, to answer separately and fully in writing under oath or affirmation, by persons having knowledge of the information requested, the following interrogatories: 3

        .s "

A. General Interrogatories The following interrogatories apply severally to each part of the quality assurance contention admitted as issues in controversy in this proceeding. 1.,- Please state the full name, address, occupation and employer of each person answering the interrogatories or assist-ing in the preparation of such answers, and designate the inter-rogatory or the part thereof he or she answered.

2. Please identify each and every person whom you are considering to call as a witness at the hearing in this matter on-this contention, and with respect to each such person, please:

a. State the substance of the facts and opinions to which the witness is expected to testify;

b. Give a summary of the grounds for each opinion; and

c. Describe the witness' educational and professional background.

3 Is your claim or defense on the contention based on one or more calculations? If so:

a. Describe each calculation and identify any documents setting forth such calculation,

b. Who performed each calculation?

c. When was each calculation performed?

d. Describe each parameter used in such calculation and each value' assigned to the parameter, and describe the source of your data.

e. What are the results of each calculation?

4

         .s '

a

f. Explain in detail how each calculation provides a 1

basis for your claim or defense. l q

4. Is your claim or defense on the contention based upon conversations, consultations, correspondence or any other type of communibationswithoneormoreindividuals? If so:

a. Identify by name and address each such individual.

b. State the educational and professional background of each individual, including occupation and institutional affiliations.

c. Describe the nature of each communication with such incividual, when it occurred, and identify all other individuals involved.

d. Describe the information received from such individuals and explain how it provides a basis for the issue.

e. Identify each letter, memorandum, tape, note or other record related to each conversation, consultation, correspondence, or other communication with such individual.

i 5 l .. ' l I l

B. Specific Interrogatories

1. Please identify and describe in detail any and ,

all corrective actions, remedial measures, or other responses  ! which address the allegations, assertions, or other matters contained in intervenors' amended quality assurance contention. For each subpart, or item, of the contention (including the Quality Control (QC) Inspector Harassment Contention), please describe in detail any actions, programs or facts upon which you rely to show that the matter asserted in the contention does not evidence a significant breakdown in quality assurance 1 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.

2. With respect to the following subparts or items of inte rvenors ' amended quality assurance contention: 1.B, l.C, l.D, l.E, l.F, the Quality Control (QC) Inspector Harrassment Contention, S.A and 12.J. please describe in detail the circum-stances involved, including the name and address and telephone number (work and'home) of each person involved, the manner in which the deficiency, weakness, finding, or observation was identified, investigated, evaluated for significance, root cause and generic implications; and the manner in which it was remedied and corrected, including any corrective action taken with regard to the existence of other related deficiency, weakness, finding or observation. Set forth any facts upon which you rely to show that the matter and its root cause have 6

t

    ~

been effectively corrected. Please identify any documents which reflect these answers. .

3. With respect to your answers to Interrogatory 58 of Intervenors' First Set of Quality Assurance Interroga-tories,and Requests to Produce, please provide updated and

! current information regarding the identification, investiga-tion and corrective action taken for each alleged deficiency and subpart or item.

4. Please describe in detail the corrective actions-or programs with respect to the following subjects which relate, as described at page 4 of the introduction to Applicant's Response to Intervenors' Interrogatory 58, to the identified items or subparts of the amended quality assurance contention:

1) Mechanical Equipment Ins tallation (l. A, 6.A, 13.A)

2) HVAC Welding (3.A.1, 3.A.2, 3.A.3)

3) Pipe Support Installation and Welding (10.C, 10.E)

4) Nuclear Coating Applications (5.B)

5) Small Bore Pipe Wall Thickness (6.F, ll.C)

6) Structural Steel Installation and Welding (9.A, 9.D, 9.E)

7) Steam Generator Bolting (10.A, ll.A)

8) Pipe Heat Number Reverification (MTV) (10.B)

As to each please detail the purpose and objectives, organi-zation, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effectiveness. Please identify any documents which reflect these answers, including 7 a l l I

program descriptions, procedures, organizational charts, data, observation, inspection or evaluation forms or documents, and interim or final reports, e

5. Please describe in detail the Unit Concept Inspec-tion P,rogram with respect to the following subjects which relate, as described at pages 8 and 9 of the introduction to Applicants' Reponse to Intervenors' Interrogatory 58, to the following subjects, items, or subparts of the amended quality assurance contention:

1) Electrical Penetration Terminations (ll.B) 1

2) Mechanical Equipment Installation (l.A, 6.A, 10.A, 13.A) l

3) Cable Routing (6.E) i

4) Reactor Coolant Pump Support Installation (9.B)

5) Small Bore Pipe Routing (3.A.4.a. 3.A.4.b)

As to each please detail the purpose and objectives, organiza-tion, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effectiveness. Please identify any documents which reflect these answers, including program descriptions, procedures, organizational charts, data, observa-tion, inspection or evaluation forms or documents , and interim or final reports.

6. Please describe in detail the corrective actions, programs or responses which are identified in Applicant's Response to Intervenors' Interrogatory 58, regarding items or subparts of the amended quality assurance contention:

8 t

Applicant Item Action, Program or Response Response Page General BCAP Introductidn, 11 3.B Quality Control Structural Steel Review Program 3 _ Unit Concept Inspections 3 Instrument Retrofit Verification Program 3 BCAP 3 3.C Braidwood Construction Assessment Program (BCAP) 1 Quality Control Inspection Reinspection Document B0006700 Program (OCIRP) attached to revised response of 10/15/85 4.B BCAP and other corrective action-programs 3 6.B.5 Comstock Document Review drawing review review of inspection checklists 3 6.D INPO 2 8.E Mechanical equipment disassembly and inspection , 2 10.D Cable tray separation walkdown 3 12.B.1 Piping Heat Number Material Traceability Verification Program (MTV) 3 Instrument-Retro Program (IRV) 3 As to each please detail the purpose and objectives, organization, methodology, procedures, staffing, implementation, results, con-clusions and evaluation of effectiveness. Please identify any documents which reflect these answers, including program des-criptions, procedures, organizational charts, data, observation, inspection or evaluation forms or documents, and interim or final reports. J

         'l '                              9 t
                                .w y..-      _

y ._ ~. __.m. _ , , - .

   ~

7. Please describe in detail the following corrective actions, corrective action programs, or other actions with l regard to quality assurance, construction or procedural defi-ciencies at Braidwood:

           ~

A. Braidwood Construction Assessment Program (BCAP). B. The " top twenty" corrective action programs at Braidwood identified in the April 8, 1985 correspondence from David H. Smith to James G. Keppler. C. The " Ongoing Corrective Action Programs" identified in Append:.x 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 identify its relationship to the items or subparts of the amended quality assurance contention including the extent, if any, to which it is relied upon as evidencing the absence of a significant breakdown in quality assurance or the ability of safety-related parts, components or systems to meet regulatory requirements or perform their intended function in service. As to each please detail the purpose and objectives, organization, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effective-ness. Please identify any documents which reflect these answers, including program descriptions, procedures, organizational charts, data, observation, inspection or evaluation forms or documents,and interim or final reports. Dated: October 21, 1985. By: V # Robert Guild Douglass W. Cassel, Jr. One of the Attorneys for Robert Guild Intervenors Rorem, et al Timothy W. Wright, Jr. BUSINESS AND PROFESSIONAL PEOPLE FOR THE PUBLIC INTEREST 109 North Dearborn - #1300 Chicago, Illinois 60602 312/641-5570 10

    .                                                                                                                                                                              i ggtATW WR
                                                                                                                                  ~

21/85 3 I UNITED STATES OF AMERICA / j NUCLEAR REGULATORY COMMISSION g 1 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i i t .- i In the Matter of: )

                                                                                          )                                                                                        <

i COMMONWEALTH EDISON. COMPANY ) Docket No. 50-456 g

) 50-45 c4'*co i (Braidwood Nuclear Power ) tp 007 b- '

Station, Units 1 and 2) ) O

                                                                                                                            }                     / pag Qfx2:           ..

4 J/ b CERTIFICATE OF SERVICE [Q[-{h I hereby certify that I have served copies of Intervenors Rorem, et al., Quality Assurance Interrogatories and Requests to 1 Produce, Second Set, on each party listed on the attached Service j List by having said copies placed in envelopes, properly addressed I and postaged (first class), and deposited in the U.S. mail on ] ! this 21st day of October, 1985; except that Ms. Chan of the NRC Staff was served by Federal Express overnight delivery, and Mr. Miller, counsel for Edison, was served by personal delivery. ( b i l 4 4 4 4

                 ,e l
                 .                                                                         11

BRAIDWOOD SERVICE LIST 50-456/50-457 OL , Lawrence Brenner, Esq. Elaine Chan, Esq. Chairman and Administrative Judge NRC Staff Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington D.C. 20555 7335 Old Georgetown Road Bethesda, MD 20014 Dr. A. Dixon Callihan Administrative Judge Joseph Gallo, Esq. 102 Oak Lane Isham, Lincoln & Beale Oak Ridge, TN 37830 Suite 840 1120 Connecticut Avenue N.W. Dr. Richard F. Cole Washington D.C. 20036 Administrative Judge Atomic Safety and Licensing Board Docketing & Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington D.C. 20555 U.S. Nuclear Regulato.ry Commission Rebecca J. Lauer, Esq. Washington D.C. 20555 Isham, Lincoln & Beale Three First National Plaza Atomic Safety and Licensing Chicago, IL 60602 Board Panel U.S. Nuclear Regulatory bb. Bridget Little Rorem Commission 117 North Linden Street Washington D.C. 20555 Essex, IL 60935 Atomic Safety and Licensing C. Allen Bock, Esq. Appeal Board Panel , P.O. Box 342 U.S. Nuclear Regulatory Urbana, IL 61801 Commission Thomas J. Gordon, Esq. Waller, Evans & Gordon Michael 1. Miller, Esq. 2503 South Neil Isham, Lincoln & Beale ! Champaign, IL 61820 Three First National Plaza i Chicago, IL 60602 Lorraine Creek Route 1, Box 182 Herbert Grossman Manteno, IL 60950 Chairman and Administrative Judge Region III U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Office of Inspection & Enforcement Washington D.C. 20555 799 Roosevelt Road Glen Ellyn, IL 60137 s-i _ ._ _ ._ . , _ _ . _ . _ - _ . _ _ _ - - . _ . _ . _ , . . . .}}