ML20141J448
| ML20141J448 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/07/1986 |
| From: | Quaka T COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20141J437 | List: |
| References | |
| OL, NUDOCS 8604280139 | |
| Download: ML20141J448 (82) | |
Text
1 ORIG NAL UNITED STATES OF AMERICA k 1 2 NUCLEAR REGULATORY COMMISSION g APR 251986 2 m;cretna a 3 BEFORE THE ATOMIC SAFETY & LICENSING BOARD [$fff'DI '/p 2
4
'IN 5 - - - - - - - - - - - - - - - - - -x 6 In the matter of: : Docket Nos. 50-456 7 COMMONWF.:ALTH EDISON COMPANY : 50-457 8 [Braidwood Nuclear Power Station, :
9 Units 1 and 2) :
10 - - - - - - - - - - - - - - - - - -x 11 Isham, Lincoln & Beale 12 Three First National Plaza
,m 13 Chicago, Illinois 14 Friday, February 7, 1986 15 16 Deposition of: THOMAS E. QUAKA 17 called for examination by Counsel for the Intervenor, BPI, i
18 pursuant to notice, taken before Marilynn M. Nations, a Notary 19 Public in and for the Commonwealth of Virginia, when were 20 -------------------------------
21 ANN RILEY & ASSOCIATES, LTD.
22 1625 I Street, N.W. 293-3950 Washington, D.C.
.?
8604280139 860425 PDR ADOCK 05000456 T PDR 1
j
2 1 present on behalf of the respective parties:
2 3 APPEARANCES:
4 For the Licensee Commonwealth Edison Company 5 MICHAEL MILLER, ESQ.
6 Isham, Lincoln & Beale 7 Three First National Plaza 8 Chicago, Illinois 60602 i
10 For the Intervenors BPI, et al.:
11 ROBERT GUILD, ESQ.
12 109 North
Dearborn,
Suite 1300 13 Chicago, Illinois 60602 14
.r 15 F
16 17
- 18 19 .
20 21 -
22 i
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1
\
3 1 CONTENTS 2
3 Witness: Examination by: Page:
4 . THOMAS E. QUAKA Mr. Guild 4, 61 F' Mr. Miller 59 6
7 8 ***
9' EXHIBTS Page:
10 Exhibit No. 1: 5 11 Document dated January 30, 1986 entitled 12 "Intervenors Rorem, et al, Notice of Depositions."
/N 13 b
14 Exhibit No. 2A-2D: 6 ,
15 Group Exhibit. Retained by Counsel 16 Miller.
17 18 Exhibit No. 3: 40 19 Left-hand vertical column wich Bates 20 Number K-17243.
21 22 l
4 1 PROCEEDINGS O
k-
- 2 [9:55 A.M.]
3 Whereupon, 4 THOMAS E. QUAKA, 4
5 having been called for exami. nation by counsel for Intervenors, 6 and having been first duly sworn, was examined and testified 7 as follows:
8 EXAMINATION 9 BY MR. GUILD:
10 Q Mr. Quaka, would you state your full name and your 11 business address for the record, please.
12 A My name is Thomas E. Quaka. My business address is 13
( ) Braidwood Station, in Braceville, Illinois.
14 Q By whom are you employed, sir?
15 A I'm employed by Commonwealth Edison company.
, 16 Q In what capacity?
17 A My position with Commonwealth Edison is Site Quality l 18 Assurance Superintendent at the Braidwood plant.
19 Q Mr. Quaka, I am Robert Guild. For the record, I am 20 counsel for the Intervanors Rorem, et al, in the Braidwood 21 licensing proceeding. I have some questions to ask you this 22 morning with respect to Affidavits that you submitted in this O
5 1 proceeding supporting Applicant's Motion For Summary 2 Disposition.
3 Are you familiar with those Affidavits?
4 A Yes; I'm familiar with the Affidavits I prepared.
5 MR. GUILD: I would like the Reporter to please mark 6 this as Quaka Deposition Exhibit No. 1.
7 (Quaka Deposition Exhibit No. 1 8
, was marked for identification.)
9 BY MR. GUILD:
10 Q Mr. Quaka, this is a document dated the 30th of 11 January, 1986. It is entitled "Intervenors Rorem, et al, 12 Notice of Depositions." Among other persons, it is directed
} 13 to you. Are you familiar with this document?
14 A Yes; I an.
15 Q The document in its second page has a paragraph that 16 states "The deponents shall bring with them all documents in 17 tneir possession or subject to their control, which are the 18 basis for the witness' affidavit in support of Applicant's 19 December 20, 1985 Motion For Summary Disposition."
20 Have you brought with you any such documents 21 responsive to that request?
22 A Yes; I have.
O
6
-~ 1 Q Your counsel made available to me some documents 2 last night at the conclusion of our deposition yesterday. I 3 have a stack in front of me. I represent to you that is the 4 stack and the form in which it was given to me by your 5 counsel.
6 Are these the documents that are retponsive to that 7 request?
8 A Yes; they are.
9 MR. GUILD: I am going to ask that the Court 10 Reporter mark this stack of paper as Quaka Deposition Exhibit 11 No. 2 as a group exhibit.
12 MR. MILLER: I might just state for the record, Bob,
( ) 13 so there is no misunderstanding, the documents that I tendered 14 to you last evening are documents ~which are responsive to the 15 Notice of Deposition, which have not been previously made 16 available by way of document discovery.
17 I note for the record that there are certain audit 18 reports and surveillances that are referred to in Mr. Quaka's 19 Affidavit that have been turned over prior to that time. They 20 are present in our offices, if you wish Mr. Quaka to get them, 21 we can do that.
22 MR. GUILD: That's fine.
l
7
{ l (Quaka Deposition Exhibit Nos. 2A-2D ,
! 2 were marked for identification.] !
3 BY MR. GUILD:
4 4 Q Mr. Quake, what I would like you to do is go through 5 the stack and identify what the documents are that you have
^
6 made available.
7 A (Perusing documents.) You wish me to go through and 8 just ide".tify each document? i 3 9 Q Yes. Tell me what the documents are for the record, 10 please.
11 A The first document I'm looking at is a copy of our 12 QR-2.0 out of the Commonwealth Edison Quality Assurance 13 Manual.
! 14 Q What is QR-2.07 Is that an identifying number?
l i 15 A Yes. That's Quality Requirement number 2.0. As I 16 said, that is part of the Edison Quality Assurance Manual.
17 Q What is the subject of that particular part of the 18 Manual?
d i 19 A The subject of this particular part of this Manual 1
20 is the Quality Assurance Program.
?
, 21 Q Please continue.
22 A The second document is Reg Guide 1.144, which is
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_~ . . _ _ . . _ _ _ _ _ _ _ _ _ - _ - _ . _ _ . _ _ _ _ . _ . _ _ _... _ __ _ __._ _ _ . _ _ . _ . _ . . _ .
8 1 titled " Auditing of Quality Assurance Programs For Nuclear 2 Plants." It is Revision 1 dated September, 1980.
3 The next document is a copy of the same Reg Guide 4 1.144, dated January, 1979. There is a third copy of the same :
4 5 Reg Guide.
6 Q I noticed that one of those documents had "For 7 Comment" stamped on it. Is there any significance to that?
8 A- None, only that at the time I was assembling 9 documents, I wanted to get all of the information together on 10 Reg Guide 1.144.
[
- 11 Q I notice there are in several packages. You are 12 getting into a second package; right?
13 A Yes. The second package here are those documents
)
14 involving Comstock, which I used in my reviews and preparation 15 of testimony for Comstock. The first document is a copy of a 16 cross reference between the applicable 10 CFR 50 criteria and 17 the sections of their Quality Assurance Manual or procedures.
18 The second document in the group is a depiction by t
19 time line of Comstock auditor personnel and their
! 20 qualification at the site.
21 The next series of documents is different revisions 22 of Comstock's internal audit program, Procedure 14.1. The i
i O
1
,.m. ..m, , , . . - _ . . . _ , , , , ,.m_-.,,,_
9 1 first is Rev B. The second is Rev A. The third is Rev date O 2 10/18/82.
3 The next document is the proposed internal audit 1
4 schedule for 1983 for Comstock. The next document is a 5 revision to the internal audit schedule of 1983 dated August 6 10, 1983, followed by another document which is called the 7 "1983-94 Audit Schedule" dated 12/13/83.
8 The next document is the Comstock Quality Assurance 9 Audit Schedule. I believe it is the final marked up version 10 of the 1985 audit schedule for Comstock.
11 Q Do ycu see a date on that document?
12 A No; I don't. It appears it has been cut off.
( ) 13 Q It reflects 1985 dates?
14 A Yes. The audit schedule here reflects the first 15 audit as being the week of 1/7/85 and proceeds through the 16 year.
17 The next document is a 1985 internal audit schedule, i
3 18 again for Comstock, dated 8/8/85. The next document is a 1985 19 internal audit schedule dated 10/16/85.
20 Next is a memorandum referencing internal Audit 21 I-100-085, dated 5/13/85.
l 22 Q Is that on the subject of the stainless steel weld 9
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10
! S 1 procedure?
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2 A The subject is manual metal arc welding and 3 stainless steel. The next document is a Comstock memorandum 4 referencing the subject as I-101-085 BP 4.9.1, Rev D.
5 Q Is that on the subject of the control of test and 6 measuring equipment?
7 A Yes; it is.
8 The next document is a co;y of the L. K. Comstock 9 Engineering Company Corporate Quality Assurance Audit Schedule 10 for 1983. The next document is a revised Corporate Audit i 11 Notification dated 12/2/85. The next document is an 12 L. K. Comstock Engineering Company Corporate Audit Schedule ;
, 13 for 1985.
14 Q What is the date on that one? Is there a date on 15 the cover memo?
16 A It was telecopied from Comstock to the site on 17 12/11. I don't see a specific date. December 11, 1985 is the 18 date it was telecopied.
19 The next document is a copy of an NRC Inspection 20 Report dated November 20, 1985. The next document is a i
21 Commonwealth Edison Company Audit Report number QA-20-85-540.
22 The Audit Report date is 8/7/85. The next document is a
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11 1 Commonwealth Edison Company Audit of Comstock number D
s_/ 2 QA-20-84-545, Report date 9/12/84.
3 The next document is a compilation of audits. It is 4 a handwritten compilation of audits that were performed at the 5 site by Comstock. It does not have a specific date, but 6 begins with Audit I-042.
7 Q How about the date of that audit? Is tnere a date 8 on there?
9 A The date that audit report was issued was 10/4. I 10 am sorry, 10/24/83.
11 ine next dccument is a copy of Comstock's list of 12 current procedures as of 7/24/85, followed by a document which
( 13 is a compilation of Comstock procedures reflecting their
}
14 revision date and issue date. This was prepared by 15 Commonwealth Edison Quality Assurance. I should say I believe 16 that document is prepared by Commonwealth Edison Quality 17 Assurance.
18 The next document is a listing of audits performed 19 by Comstock, the first audit number is I-001, and that was 20 performed on 7/12/82. +
21 Q How far does that run?
22 A It goes in series until the last number, 1-033.
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G-12 1 Q The date on that?
2 A It does not have a date. The final document is a 3 handwritten list of internal audits beginning again with I-001 4 and the date of that was 7/12/82, and the bottom of the page, 5 the last iter, I-026, dated 1/14/83.
6 Q Does that complete the documents that relate to the 7 L. K. Comstock Company?
8 A Yes. i 9 MR. GUILD: We will put a rubber band around this.
10 Maybe we could ask the Court Reporter to sort of put a tab at 11 this point in the exhibit.
12 MR. MILLER: We can call this pac): age 2A and this 13 package 2B.
%J 14 MR. GUILD: That is fine. The stack we have just 15 completed would be 2B. There will be a C and D.
16 THE WITNESS: The next set of documents deal with .
1 17 Phillips-Getschow. The first is a copy of the l 18 Phillips-Getschow Quality Assurance Manual, site supplement, 19 Braidwood, Revision 9/10/82. It is Section 16.
20 The next document is Phillips-Getschow Quality 21 Assurance Procedure QAP 12.1, titled " Internal Audits." It is 22 Revision 3 dated 7/21/83.
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13 1 The next document is Phillips-Getschow company 2 Quality Assurance Program Audit Schedule, number B84-1, 3 Revision 1, dated 8/9/84.
4 The next document is an interoffice communication, 5 the subject is procedure of PGCP-2, Rav. 3, and the date of 6 the memorandum is 8/8/84, I believe. The signature date is 7 dated 8/8/84.
i 8
The next document is another meno dated 8/8/84 and 9 it addresses procedure withdrawals, specifically Procedure 10 PGCP-2, Rev. 3.
11 The next document is a meno dated 9/19/84, and the 12 subject is PCCP-32. The next document is another interoffice 13 communication. The subject is audit schedule for calendar
{a')
14 year 1984 - Braidwood, dated 10/31/84.
15 The next document is a copy of the Phillips-Getschow 16 Quality Assurance Program Audit Schedule, No. B85-1, Revision 17 3, dated 10/1/85. The next document iu a memo dated 12/11/85, 18 and the subject is 1984 and 1985 Audit Schedule.
19 The next document is a Commonwealth Edison Company l 20 Quality Assurance Audit, No. 20-84-542, and the Audit Report 21 date is 10/22/84. The next document is a Commonwealth Edison 22 Company Audit Report, QA-20-85-546. The Report date is !
O 1
14 1 9/6/85. The next document is a Commonwealth Edison Company O 2 Quality Assurance Audit, No. 20-85-B, and it is dated 3 7/18/85. There is another copy of that same document that 4 follows, dated the same Report date. It is the same report.
5 That concludes the documents relating to Getschow.
l 6 BY MR. GUILD:
7 Q Mr. Quaka, the last two documents you looked at, one 8 appears to be a partial copy of a more complete version of the 9 same document. First you identified a document consisting of 10 three pages?
11 A Yes.
12 Q Second, eight numbered pages with an Attachment A,
() 13 five pages and Attachment B, three pages.
14 A Yes. That's correct.
15 MR. GUILD: That last series of documents relating 16 to Phillips-Getschow Company we will identify as Quaka 17 Deposition Exhibit No. 2C.
18 BY MK. GUILD:
19 Q The next package, Mr. Quaka?
20 A The next package of documents relates to Pullman.
21 The first document is a copy of their audit schedule for the 22 Braidwood field, signed and dated 8/2/83. The next document l
l l
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15 1 is a letter dated October 27, 1983, the subject is Audit ,
2 No. PCI-83-2/PFBR-12, conducted on August 29th through August 3 30, 1983, September 1, 15th, 1983.
4 The next document is dated November 17, 1983, titled 5 " Notification of Audit." It appears that attached to that is 6 all of the details, the actual audit report, and checklists 7
associated with Audit PCI-83-12/PFBR-13.
8 Q Is that largely in handwriting?
9 A Yes, the attachment is handwritten.
10 The next document is a March 8, 1984 memo with the 11 subject again being Audit PCI-83-12/PFBR-13. The memo is 12 dated Mr.rch 9, 1984. The subject is reference audit finding 13 report, No. AFR-PCI-83-12/AFR-1, from Internal Audit 14 No. PCI-83-12/PFBR-13.
15 Q Why don't you read me the date and some little I
16 description that will help me identify uniquely and skip the 17 long number.
18 MR. MILLER: Why don't you just give him the date 19 and the addresser and addressee.
20 THE WITNESS: Okay. The next document is dated 21 October 1, 1984. It is to Mr. Dave Grant, the site QA 22 Manager, from Thomas Collins. It is in regards to a re-audit O
16
,1 of an audit finding report.
2 The next document is a copy of the audit schedule, 3 Braidwood field, signed 1/10/84. The next document is an 4 audit schedule, Braidwood field, dated 8/21/84. The next 5 document is dated February 24, 1984, to Mr. Dave Grant from 6 Thomas Collins. It is in regard to Internal Audit PCI-84-1.
7 BY MR. GUILD:
4 8 Q That document transmits the audit report itself; 9 does it not? l 10 A Yes; that is correct.
11 The next document is dated October 1, 1984, to 12 Mr. Dave Grant from Thomas Collins. It transmits Internal 13 Audit No. PCI-84-12. The next document is dated December 21, 14 1984, addressed to D. L. Shaulin and T. E. Quaka. It is from 15 Michael Jarigese.
16 .MR. MILLER: That is a man's name we can never l
17 pronounce. It is spelled J-a-r-i-g-a-s-e.
l 18 THE WITNESS: A meno, transmits two copies of PCI 1
19 Corporate Audit of the Pullman site activities, Audit
- f. 20 No. PCI-84-16. The next document is addressed to Tom Brooks 21 and Dick Lawler. It is dated December 10, 1985. It is a 22 Notification of Audit, Internal Audit No. 85-10. Attached to l
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17 1 this document is an audit schedule dated 4/4/85.
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s_
i 2 The next document is a Commonwealth Edison Company 3 Audit Report, QA-20-85-549, Report date 8/29/85. The next 4 document is a copy of Pullman Audit Report dated September 3, 5 1985, Audit No. PCI-85-5.
6 BY MR. GUILD:
7 Q Is that one page, two pages?
8 A The document is two pages.
9 The next document is a Pullman procedure, 10 No. B18.1.F, Rev. 1, effective 10/4/85.
11 Q What is the title of that procedure?
12 A The title, the purpose of -- the title is " Audit."
13
( ) These sheets need to be attached.
14 Q They go with the last document, the procedurs?
15 A Yes; they do. They are consecutively numbered. The 16 procedure has 33 pages. There are several of the last pages 17 that are not attached.
18 The next document is an Audit Report, No. 85-01, 19 dated 4/30/85.
20 Q Is that one page?
21 A Consisting of one page. The next document is an 22 Audit Report, No. 85-02, dated 5/28/85. It is one page. The O
18 1 next document is again a Pullman Audit Report dated 7/8/85,
(_
- s. 2 Audit No. 85-03, consisting of one page. The next document is 3 a Pullman Audit Report, No. 85-04, dated 7/25/85, consisting 4 of one page. The next document is Pullman Audit Report dated 5 9/12/85, Audit No. 85-05, consisting of one page. The next 6 document is a Pullman Audit Report dated 10/2/85, Audit 7 No. 85-06.
i 8 The next document is a Pullman Audit Report dated 9 11/12/85, Audit No. 85-07, consisting of one page. The next 10 document is a Pullman Audit Report dated 11/18/85, Audit 11 No. 85-08, consisting of one page. The next document is an 12 Audit Report No. PC-85-3/PFBR-18. The audit is by Pullman
( ) 13 Construction Industries, Inc., and is dated March 26, 1985, 14 consisting of three pages.
15 The next document is Pullman Construction 16 Industries, Inc. Audit Report, dated March 7, 1985, Audit 17 No. PCI-85-1/PFBR-17, consisting of three pages. The final 18 document is a single page of the Pullman Construction 19 Industries Quality Assurance Program. The title is " Audits, 20 Section No. 18." The Revision is Rev. O, effective date 21 9/19/79.
22 That completes the package of documents for Pullman.
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19 1 Q That completes the documents you brought with you in l
2 response to the Notice of Depositions?
i 3 A Yes; that's correct.
B 4 MR. GUILD: That last package dealing with Pullman 5 should be identified as Exhibit No. 2D. .
- 6 BY MR. GUILD
7 Q Mr. Quaka, I have excerpts from a filing made by 8 Connonwealth Edison Company on December 20, 1985. The entire 9 filing was the Motion For Summary Disposition. We are going
! i 10 to be speaking this morning only about a small part of that, 11 dealing with subitem 14B of the Contention.
12 With respect to that subitam and the Motion For
() 13 14
-Summary Disposition, you submitted two Affidavits; did you not?
. 15 A Yes. I submitted two Affidavits.
. 16 Q The first of those Affidavits appears to be an one 17 page Affidavit with testimony to follow consisting of 12 18 pages. The heading reads " Affidavit of Thomas E. Quaka (on 4 19 Rorem QA subcontention 14B." Do you have a copy of that in 20 front of you?
21 A Yes; I do.
I 22 Q That is your Affidavit and your signature as it '
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20 f- .
1 appears on that page; is it not?
s 2 A Yes; it is.
3 Q The second Affidavit appears further down in the 4 package on 14B, and it consists of one page with testimony of 5 nine pages that follow; correct?
6 A Yes; that is correct.
7 Q The title on the Affidavit there is " Affidavit of 8 Thomas E. Quaka (On Rorem QA subcontention 143)," correct?
9 A That is correct.
10 Q That is your Affidavit?
11 A Yes; it is.
12 Q The subject of Contention 14B relates to items of
(-,
(s, 13 non-compliance that were identified by the Nuclear Regulatory 14 Commission and reported in Inspection Report 83-09; correct?
15 A That is correct.
16 Q That Inspection Report was publishe.d May 7, 1981; 17 correct? I will show you the document, if you like. ;
18 A Yes; that is correct.
19 Q The cover of that document reflects an inspection 20 that commenced June 20, 1983 and followed with various 21 dates up to the date of publication, on May 7, 1984; correct?
22 A Yes; that is correct. '
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21 1 Q What were you doing, in what capacity were you x 2 employed on June 20, 1983, Mr. Quaka?
3 A On June 20, 1983, I was the Site Quality Assurance 4 Superintendent at the LaSalle County Station.
5 Q When did you come to the Braidwood Station in the 6 Quality Assurance capacity?
7 A I came to Braidwood Station in a Quality Assurance 8 capacity in March, 1984.
9 Q What was your position at that time?
10 A At that time, my position was the Site Quality 11 Assurance Superintendent at Braidwood.
4 12 Q Inspection Report 83-09, Mr. Quaka, reflects that 13 the Nuclear Regulatory staff conducted an Enforcement
}
14 Conference with representatives of Commonwealth Edison and 15 Braidwood contractors first on December 20, 1983. Were you 16 present at that conference?
17 A No; I was not.
18 Q It further reflects that a subsequent conference was 19 conducted with representatives of Commonwealth Edison Company t
20 and perhaps others on March 7, 1984. Were you present at that 21 conference?
22 A No; I was not.
O
22 1 Q After the December 20, 1983 Enforcement Conference, 2 Commonwealth Edison Company communicated to the Region III NRC 1 3 staff with respect to the findings of the NRC, as of that 4 date, by' cover letter of Mr. Del George to Mr. Bert Davis, the 5 Assistant Region Administrator, dated January 12, 1984.
6 Did you have any involvement in the preparation of
- 7 that document, that response?
8 A No; I did not.
9 Q Subsequent to the publication of Inspection Report 10 83-09, which contained the violations of Criterion 18, with 4
11 respect to audits of Appendix B of 10 CFR Part 50, the ,
12 Commonwealth Edison Company responded to those notices of
() 13 violation by a cover letter by Mr. Del George with 14 attachments, dated July 6, 1984.
15 Were you involved in the preparation of that 16 response?
17 A I was invoived in the review of that response prior 18 to submittal.
l 19 Q I would like to identify what the extent and 20 particulars of your involvement was in that response, again, 21 the July 6, 1984 response to Inspection Report 83-09. I have 22 a copy of the document if you would like to review it.
i O
23 1 A My recollection of my involvement was in reviewing 2 the response in a general fashion and more specifically, 3 reviewing the response as it was prepared for the items 4 involving the non-compliance related to criterion 18.
. 5 Q Criterion-18, non-compliance, was the audit 6 violations that are the cited basis for Contention subitem 14B 7 that we are talking about today?
8 A Yes; that is correct.
9 Q At page 27 of that document, the following pages, 10 Mr. Quaka, does that appear to be the part you had reference 11 to, and that is the Company's response with respect to the 12 audit of Criterion 18 violations?
() 13 A Yes, item of non-compliance, number four.
14 Q Can you tell me, sir, how that response was prepared 15 and who participated in the preparation of that response?
16 A The response was prepared by personnel at the site,
, 17 in the same fashion other responses to non-compliances are 18 prepared. I'm not sure as far as the individuals involved 19 specifically in gathering the data at the point that a draft 4
20 document was prepared. I became involved in the review of the 21 information.
22 Q Can you tell me the identities of any of the persons
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.i i
24 1 who actually did the preparation of the response?
(m > 2 A My recollection is that an individual in my office, 3 Douglas Brown, was involved in the preparation of the items 4 relating to Comstock.
5 Q Who is Mr. Brown? What is his position?
6 A His position at the time this was being prepared was 7 Quality Assurance Supervisor.
8 Q Can you tell me of any others who participated in 9 the preparation of that response?
10 A Other than Mr. Brown, I am not sure exactly who else 11 was involved.
12 Q How about the subitems dealing with
)
13 Phillips-Getschow Company?
14 A I am not certain. It would be merely conjecture.
15 Q How about the subitems dealing with Pullman Company?
16 A I do not know.
17 Q How about subitam -- what has been identified in the 18 Contention as 14B(4), having to do with the piping hanger 19 selection?
20 A I believe that Mr. Hunsader was involved in the 21 preparation of that response.
22 Q What was Mr. Hunsader's position at the time?
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25 1 A Mr. Hunsader was the Quality Assurance Supervisor in
\
2 my office.
3 Q He held the same position as Mr. Brown?
4 A He held the same position, except that he was 5 responsible for the mechanical area.
)
6 Q How about Mr. Brown, what was his area of f 7 responsibility?
8 A Mr. Brown was, as part of his responsibility, 9 involved with Comstock.
10 _ Q The electrical area as a discipline or Comstock in 11 particular?
12 A I use the two terms synonymously. I would like to 13 state that at the specific time this was prepared, I au not 14 sure whether Mr. Brown's responsibilities were in fact still 15 Comstock. He was the Supervisor in the electrical area at the 16 time the inspection we have been discussing, 83-09, was being 17 performed at the site. I'm sure of that. I don't know at the 18 time this was prepared whether or not his responsibilities in 19 the organization had been shifted.
20 Q Did Mr. Brown participate in the preparation of the 21 company's response to the audit violation with respect to 22 Comstock?
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26 1 A My recollection is he did.
i C'T
>2 Q Would he have done that even if his duties had 3 changed?
4 A Yes.
5 Q Describe if you would, please, the nature and extent 6 of your review of the company's response of July 7th to the 7 83-09 audit violations.
8 A My involvement in the response as it relates to the 9 non-compliance in the area of auditing was primarily the 10 evaluation and decision relative to commonwealth Edison's 11 interpretation of Reg Guide 1.144, and Edison's position in 12 the matter of how Edison viewed.the requirements of Reg Guide 13 1.144.
14 Q I guess I didn't follow. Is there a distinction 15 between the two points that is important?
, 16 A Yes. I 17 Q Would you explain, please?
18 A As noted in my testimony, the position of 1 19 Commonwealth Edison prior to the item of non-compliance was i 20 that Edison did not interpret the phraseology, all applicable 21 elements of the Quality Assurance program to necessarily mean 22 that every individual procedure of the contractor had to be O
27 1 audited by him to comply with that requirement.
2 Q Mr. Quaka, I want to direct your attention to what 3 has been marked and identified as Quaka Deposition Exhibit 4 No. 2A, and that is the stack of documents that were first 5 discussed. The first of those documents you identified as 6 portions of Commonwealth Edison's Quality Assurance Manual, on 7 the subject of the Quality Assurance program.
8 Do those portions of the Manual speak to the Edison 9 interpretation of the Reg Guide provisions that you just 10 identified?
11 A Not specifically. The document that I am looking 12 at, QR No. 2.0 reflects a listing of Edison's commitments as
{} 13 far as the Reg Guides, specifically for Braidwood Nuclear 14 Station.
- 15 Q How, if at all, does'it relate to the interpretation 16 of regulatory requirements with respect to audit?
17 A QR 2.0 identifies the Reg Guide and revision 18 applicable to the Braidwood Station.
19 Q Which Reg Guide and revision is that?
20 A Relative to auditing, it is Reg Guide 1.144, ,
I 21 Revision 1. '
22 Q Following that document you identified earlier as ;
l O
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---wa- '- ---v--- em-s
28 1 part of Exhibit No. 2A, several revisions of that Reg Guide. l 2 Is there any material difference with respect to the audit 3 requirement between Rev. O and Rev. 1 that you have i
4 identified? !
l l 5 A I believe not. I would have to go through the '
6 documents in detail to determine that.
f 7 Q They are only three pages long. If you could take a l
4 8 moment and review the documents and identify if there is any l 9 material difference, with respect to the company's
\
10 interpretation of the Guide regarding auditing. l 11 [ Witness perusing documents.) l 12 In examining these two documents, Reg Guide 1.144,
! 13 Rev. 1, September 1980, and Reg Guide 1.144, dated January
)
j 14 '79, I believe, I'm looking specifically at paragraph 3(a) (2) 15 in the January '79 document and paragraph 3(a) (2) of the 1980 i 16 document, and the phraseology relative to design and i
17 construction phase activities is essentially the same. There 18 are a couple of additional sentences that are added in the !
19 1980 version. .
20 With respect to the Company's position regarding the '
l 21 83-09 violation, is there any material difference between the 22 Rev. O and Rev 1 provisions of the Reg Guide?
t t
s I
-M- , -,- ,,-,--,.v-w - - , ,---,.--w-- --we,-,,-wm-- -:--..--. , , - - , . . - - , - . - - - - - - - - - - - - - , . . ~ . - --,---+--.-,--e------
. - = ... - _ .. - -
29 1 A I don't think so.
.- () 2 Q Mr. Quaka, is there any documentation that reflects 3 Commonwealth Edison Company's asserted interpretation of those 4 provisions of the regulatory guide with respect to auditing as 5 that interpretation existed at the time of the NRC's 83-09 6 inspection?
7 A Not to my knowledge, not that I'm aware of, anyway.
8 Q Are there any written instructions, policies or 9 procedural requirements that communicated Commonwealth Edison 1
- 10 Company's interpretation of the reg guide respecting auditing i 11 to the Braidwood site contractors at the time of the 12 inspection conducted under 83-09?
13 A At this time I can think of no specific documents
)
14 that detail the interpretation of Reg Guide 1.144 as we have 15 been discussing.
16 Q When you participated in the review of Commonwealth 17 Edison Company's response to 83-09, do you believe that such 18 instructions or documentation would have come to your 19 attention had it existed?
20 A Not necessarily.
21 Q Did you inquire about the existence of such 4
22 instructions or documentation of the Company's interpretation
- O
. . . , - . - _ _ . _ _ . - - . _ - - _ - . _ _ _ . _ . -. - . - _ . . _ - ~ - _ _ _ _ _ . -
30 1 of the Reg Guide at that time?
2 A No, I did not.
3 Q Have you since?
4 A No, I have not.
5 Q Mr. Quaka, I am looking at and would like to direct 6 your attention to page 28 of the Company's July 6, 1984 7 response to Inspection Report 83-09 with respect to item 8 4a. There the Company states, " Commonwealth Edison Company 9 acknowledges that Phillips-Getschow Company did not audit each 10 of its implementing procedures. Rather, the Phillips-Getschow 11 Company quality assurance program required all quality 12 assurance manual" -- emphasis included - " sections to be
}
13 audited over the year period. This requirement met and 14 fulfilled ASME Code requirements."
15 Does that statement reflect the Company's then 16 interpretation of the requirements of the Reg Guide respecting 17 auditing?
18 A I would have to read the entire response to 19 determine that. The testimony that I provided indicated the 20 Commonwealth Edison position overall relative to this issue.
21 Q The entire response to item 4a is contained in one l
22 paragraph, Mr. Quaka, which appears at page 28. Of course, I O
- 31 1 would encourage you, if there is anything else that you think 2 is relevant in the document, to examine that, but please take 3 a moment and examine the Company's response to 83-09.
4 (Document proffered to witness.]
5 (Witness perusing document.]
6 Again, what I'm trying to identify is if that is the 7 relevant portion or other portion states the Company's 8 position with respect to the interpretation of the auditing 9 Reg Guide. ,
10 [ Witness reviewing document.]
E 11 MR. MILLER: Do you have the question in mind,
- 12 Mr. Quaka? It has been quite a while.
- -~
13 THE WITNESS: Could you repeat the question? '
14 BY MR. GUILD:
15 Q Sure. I pointed you to a sentence that appeared in 16 the Company's response to item 4a and I asked you whether '
17 that is the statement of the company's position with respect 18 to its interpretation of the Reg Guide, and if it isn't, is 1
19 there any other part of the response that communicates your 20 interpretation of the auditing Reg Guide 1.144.
21 A In answering your question, the response to item 22 4a in part reflects that interpretation. However, since the O
i
32 1 item of noncompliance in fact censisted of three examples, one 2 for Comstock, Pullman and Getschow, where in fact the issue 3 of auditing all active site procedures was brought up, item 4 "a" does not reflect the entire company policy. The 5 statements that I have provided in answer number 6 of my 6- testimony on 14B reflects the policy of Commonwealth Edison in 7' this matter.
8 Q Directing your attention to the Company's response 9 to Inspection Report 83-09, is the Company's policy with 10 respect to the interpretation of Reg Guide 1.144 communicated 11 in that response? -
12 / I would respond to your question by saying that
'( ) 13 Edison's acknowledgement of the item of noncompliance in each '
14 case reflects Edison's recognition of the difference of 15 interpretation and our decision to interpret the phraseology 16 of the Reg Guide, which is the applicable elements of the 17 quality assurance program shall be audited annually.
18 This response reflects our decision to adjust our i l 19 interpretation. l l
20 Q Is there any statement of your prior interpretation i 21 in the Company's July response to 83-09?
22 A Not specifically.
, O
33 1 Q Mr. Quaka, I want to show you a portion of O
k/ 2 s- Inspection Report 85-52 and 85-50. It's dated December 6, 3 1985. In particular -- actually, it appears to have a cover 4 date of December 5, 1985. In particular, that portion that 5 appears at.page 5 of the details that closes item 83-09, 08(a) 6 the item of noncompliance that related to the 7 Phillips-Getschow audit plan. I believe that's the same as 8 Contention sub-item 14B.1, or item 4a of the Inspection Report 9 83-09.
10 Have you seen that portion of the inspection report i
11 before?
12 A Yes, I have.
13 Q There the inspector -- and was that Mr. Schulz that
)
14 closed that item?
15 A I'm not sure. It would be reflected on the first 16 page.
17 Q Mr. Schulz and Mr. Kropp appear to have performed 18 the inspection. Do you know which gentleman performed that l 19 portion of the work?
i 20 A I believe it was Mr. Schulz but I can't be sure.
21 Q Again, back to page 5, the inspector notes, "A 22 comprehensive review was accomplished by the Licensee and
- O d
i
--r, ., , , _ . _ - - - - . - , --. - _ . , . - , ~ - . , , , , , , - - - - - . , . n. , . - - . - - . _ . , -n , , - -, . , - - - - ,.
f 34 1 piping contractor with regard.to past auditing activities.
2 E.5ch implementing procedure approved for use at the site was 3 analyzed against both the piping contractors and the Licensee 4 audits." And it follows.
5 Can you identify that review?
6 A I'm not sure what you are asking. Are you asking if 7 there is a document?
8 Q Well, that's one question. Is there a document?
9 A Yes, there is.
10 Q Can you identify it more particularly, please?
11 A It's a document -- I don't recall whether, in fact, 12 we covered those documents. It's a document that was
() 13 previously submitted.
14 MR. GUILD: Can you help?
15 MR. MILLER: Is it a memorandum?
16 THE WITNESS: It's a matrix that reflects the 17 results of that review.
18 BY MR. GUILD:
19 Q Is it a schedule or is it a report? Is it a study?
20 can you give me some more detail?
21 A It is a review that was done in response to the 22 question of the NRC person closing the item out.
O
, - - - - .. _ ~ - - . _- . - - -- - . _
35 1 Q Is it contained among the documents that you have 1-2 produced this morning and identified?
3' A No, I dcn't see it here in those documents. It was 4 submitted.
5 .MR. GUILD: If we could take a moment, perhaps we 6 could look at the Company's response to Interrogatory 58 where 7 there are identified documents.
8 (Discussion off the record.]
9 [Brief recess.)
10 BY MR. GUILD:
11 Q Mr. Quaka, before the recess, we were trying to
- 12 locate what Mr. Schulz or Mr. Kropp, the inspectors for the
) 13 NRC, characterized in Inspection Report 85-52 and 50 at page 5-14 as a comprehensive review conducted by Commonwealth Edison k 15 Company and Phillips-Getschow, and I believe you have laid l 16 hands on that document.
, 17 A Yes, I have.
18 Q And it bears an identifying number. Can you give me 19 that number for the record, please?
i 20 A Yes. The number on the document is K0017243.
21 Q All right. And it appears to be a matrix. Is that l
22' the way you describe it? )'
i O
36
-~. 1 A Yes.
\ l
'~#
2 Q And it's a document of eight pages; correct?
3 A Yes, that's correct.
4 Q Has this review, this matrix been previous 5 identified, to your knowledge, by the Commonwealth Edison 6 Company in response to Intervanor's discovery requests?
7 MR. MILLER: Let the record reflect that I have put 8 before Mr. Quaka a copy of Applicant's second partial response 9 to Rorem's second set of quality assurance interrogatories and 10 requests to produce, which includes a revised answer to 11 Contention item 14B(1). I have opened it to page 3 of the 12 response, which refers to a matrix in the paragraph.
() 13 BY MR. GUILD:
14 Q Mr. Quaka, can you direct our attention to that 15 reference, if you see it, please?
16 [ Witness perusing document.)
17 A Could you repeat the question, please?
18 Q Can you direct my attention to the reference to that 19 review, that comprehensive review?
20 A In the updated response, in the first paragraph it 21 indicates corrective action taken included the establishment 22 by Getschow of an audit matrix to assure all Getschow O
37 1 implementing procedures would be audited.
-s 2 Q Is that the matrix that you have just identified?
3 A on the third page of the updated response to 4 Contention item 14B(1), the first full paragraph, it states 5 the results of the four-step evaluation are documented on a 6 matrix which indicates that for 1980 to August 1983, nearly 7 avery Getschow procedure was examined by PGCo and 8 CECO audits. So in this paragraph, this refers to the matrix 9 that we are discussing.
10 Q All right. Not the previous reference. Different 11 matrix?
12 A I believe the previous reference is not the correct f 13 one. This paragraph on page 3.
14 Q Following that answer, is there a list of reference 15 documents?
16 A Yes. On page 4 there is a list ,of reference 17 documents. The first reference document is PGCo 18 Procedures / Audit Matrix.
19 Q Now, which matrix is that, if you know?
20 A This matrix is the one that we are referring to and y 460 4hd8%
21 is numbered /0017243.
22 Q The updated reference list does not bear a Bates
38 1 stamp number by that entry, does it, for the matrix?
2 A No, it does not.
3 Q How do you know, then, that that is not the first 4 matrix that you read from the text? <
! 5 A I believe that it is, in fact, the same matrix. t a l This seems to discuss the chronology.
4 6 The matrix appears to 7 have been partially completed. The NRC guy looked at it and f 8 there were some additional steps that were taken to finish i 9 completion of the matrix. So I believe that it's the same 10 matrix; it's just a difference reference in terms of its 11 completeness.
} 12 Q The first reference, as I heard you read it, seems 13
( ) to refer to a matrix for future use to assure that all 14 procedures are covered, and I understood the review that the
- 15 inspector talked about to be a historical review of past 16 procedures covered, and that's the source of my difficulty, 17 Mr. Quaka.
I i
18 A Yes, you are correct. As I go back and read it now, ;
1 1
19 it says corrective action taken included the establishment by 20 Getschow of an audit schedule matrix to assure that all i 21 Getschow implementing procedures would be audited. That 22 reference refers, I suspect, to audit schedule matrices that i
a O .
l l
i, - _ -- - - . - - _ - -_ .-
/ 39 1 we discussed at the beginning of the deposition.
2 Q It appears to be a reference to a different matrix 3 from the historical matrix that you identified as the 4 comprehensive review.
5 A Could you restate the question?
6 Q There could be twc matrices referred to in that 7 updated answer. One is an historical analysis, and that is 8 the document that has the Bates stamp number on it that you 9 have previously identified as the comprehensive review that 10 the NRC identified in its inspection report; and the second 11 being a matrix that was developed according to the updated 12 answer to assure future audit coverage of all procedures;
, 13 correct?
14 A I believe that's correct. The matrix referenced in 15 the first paragraph, I believe that's a reference to the audit 16 schedules. Perhaps by examining the original submittal of the 17 response to this contention item, that question could be 18 cleared up.
19 MR. GUILD: Let's go off the record.
20 [ Discussion off the record.]
21 MR. GUILD: On the record.
22 BY MR. GUILD:
I
40 1 Q Mr. Quaka, there appear to be two separate matrices 2 that are described in Applicant's updated response with 3 respect to 14.B(1) ; correct?
4 A Yes, that is correct.
5 Q Now, the document that you have identified, with the 6 Bates stamp number of K-17243, is the second of those 7 matrices, and it is the one that Mr. Schulz or Mr. Kropp, the 8 NRC inspector, identifies as the comprehensive review in the 9 inspection report that closes this item; correct?
10 A Yes, that is correct.
11 Q Now, if . can examine that document.
i 12 A Surely.
) 13 MR. GUILD: If we could have this document, the 14 K-17243, identified as the next exhibit. I guess that would 15 make it Exhibit 3.
16 (Quaka Deposition Exhibit No. 3 17 was marked for identification.]
18 BY MR. GUILD:
19 Q Mr. Quaka, if you can help me identify what this
{
20 matrix consists of, Exhibit 3. It appears to be a lefu-hand 21 vertical column, and it reads on the first page -- well, it's 22 hard to read it. Can you make out the heading on that left l .
41 1 column?
2 A It appears to be "SQAM Section/ Procedure."
3 Q And what does the acronym mean? What is SQAM?
4 A I believe it is site quality assurance manual 5 section.
6 Q And is that a Phillips-Getschow manual?
7 A Yes, it is.
-8 Q And below that appear to be various sections or 9 procedures from their Getschow quality assurance manual?
10 A Yes. It appears to be a listing of their procedures 11 and thair QA manual sections.
12 Q The column, moving from left to right, reads
() 13 " Implementation Date," and do you know what that signifies?
14 A Yes. The implementation date indicates the point in 15 time that the procedure was actually used.
16 Q Is that the effective date of the procedure?
17 A I believe it is the effective date. I can't be '
18 sure.
19 Q Just hypothetically, if a procedure was formally 20 effective on date one but no work was done to the procedure 21 until date one plus six months, what date would be reflected 22 on the column reading " Implement Date," if you know?
O
P 42 1 A I would have to refer back to the updated response, 2 to 14B(1) .
3 Q Okay. We'll try and see if that answers the 4 question.
5 [ Witness perusing document.]
6 A At the bottom of page 1 to the updated response, 7 Contention itas 14B(1), it states, "First PGCo quality 8 assurance ccmpiled a listing of all PGCo implementing 9 procedures in effect prior to August 1983." It would be 10 conjecture for me to state whether it was the date that the 11 procedure was approved or whether it was the date that it we.s i
12 actually used.
13 Q Do you know how that date was determined, the date 14 that appears on the second column on Exhibit 3?
15 A Right now I don't recall.
16 Q There then appear to be a series of vertical columns l 17 headed by dates. Do you know what the significance is of the 18 time periods that are indicated in each of the columns? The 19 first, for example, looks like 5/77 to 4/78, but it's a little 20 hard for me to make out.
21 A I believe each of those columns corresponds to their 1
22 audit achedule.
O .
43 1 Q The Getschow audit schedule?
( 2 A The Getschow audit schedule.
3 Q It's an annual period?
4 A It's as it's reflected at the top of the column 5 there. Apparently in the first case the period is from 5/77 6 to 4/ -- I believe it is 78, and then it continues across.
r 7 Q In those columns that are headed with the audit 8 periods, there appear to be numbers in boxes opposite the 9 various manual and procedura sections. Can you identify what i
10 those numbers signify?
11 A The numbers in the boxes signify either a date that 12 the item was covered by an audit, or reflect an actual audit 13 number that addressed the manual section or procedure.
14 Q So if there is an audit number listed, do I 15 understand that that signifies that that audit covers the 16 respective procedure or manual section?
17 A That is correct.
18 Q Now, what does the date signify, if there is simply 19 a date?
20 A If it's merely a date, I believe it signif'es the 21 audit. It appears that in the early stages of the project, i
22 Getschow did not specifically assign audit numbers to audits i
O l
44 1 but rather identified them only by date.
2 Q But nonetheless, the date would then identify a 3 unique audit document?
4 A Yes. .
5 Q And then to the extreme right, there is a " Remarks" 6 column. What information is contained in the " Remarks" 7 column?
8 [ Witness perusing document.]
9 A The " Remarks" column appears to provide information 10 to indicate how a procedure or manual section was addressed 11 during a particular audit schedule period if there is not a 12 specific audit number that is referenced or an audit date.
13 Q When did you first see this matrix that has been 14 identified as Exhibit 3, Mr. Quaka?
15 A I saw the matrix sometime during the process of its 16 completion, or I guess its completion, when Edison quality 17 assurance was providing information for some aspects of the 18 document.
19 Q Who prepared the document?
20 A I don't know the individual's name who prepared the 21 specific document.
22 Q Do you recognize the handwriting?
45
,s 1 A No, I do not.
\~h 2 Q Is the author a Phillips-Getschow employee or an 3 Edison employee or other?
4 A I'm sure that the -- well, I assume that the 5 document was actually prepared by Phillips-Getschow.
6 Q Who provided you with the document, Mr. Quaka?
7 A I really don't recall. I may have gotten it from 8 one of the people in my office.
9 Q When you were trying to piece this together a few 10 moments ago, you described a process of preparation of this 11 matrix in part and then additional efforts made at the request 12 of the NRC inspector. Do you recall that description?
() 13 A Generally.
14 Q Can you explain how that came to pass? What was the 15 original purpose of preparing this review?
16 A could you ask the question again, please?
17 Q Eure. What was the original purpose of preparing 18 this review? i 1
19 A The purpose of preparing this review was to 20 demonstrate to the NRC inspector closing the item that our 21 stated position with him, that we had no concern as to the l 22 adequacy or completeness of coverage of the Phillips-Gotschow
]
([S) l
46 1 program prior to the date of the item of noncompliance, was in 2 fact the case.
3 Q Now, how was that purpose carried out and what 4 changes were'made in the way it was carried out in response to 5 the NRC inspector?
6 A Well, I don't know that the characterization of 7 changes is correct. He asked how we knew that, in fact, 8 everything was covered in the past. We stated that our 9 position was that we always required that all of the manual 10 sections or applicable criteria were, in fact, covered, and 11 that through that process, the active site procedures are 12 covered. And he requested some objective evidence to support
( ) 13 that position, and the matrix was prepared using that.
14 It required some additional work, as I mentioned 15 earlier, because of the noted difference of interpretation of 16 the phraseology " applicable elements of the quality assurance 17 program."
18 Prior to the date of the item of noncompliance, 19 Edison's position was that you could, in fact, cover the 20 quality assurance program by auditing the quality assurance 21 manual sections or the 18 criteria which are reflected in the 22 individual contractors' quality assurance program, and that to O
47 1 do that auditing, it necessitated a review or evaluation of
\s I 2 the procedures in performing those audits, and that in fact, 3 by approaching it that way, you effectively covered all of the 4 procedures or those significant procedures at the site, 6 5 Q And when was this matrix or this review prepared, 6 Exhibit 37 7 A I don't know the precise date. I believe it was 8 prepared in the November time frame when the NRC inspector 9 raised the question during his review of the item for 10 closeout.
11 Q November 19857 12 A ves.
() 13 14 Q And what is the date on the updated answer to discove.ry with respect to 14.B(1) that describes that review?
15 A The date on the updated response is November 22, 16 1985.
17 Q So is it accurate to infer that the document was 18 prepared sometime before November 22nd?
19 A Yes, that's correct.
20 MR. MILLER: The certificate of service indicates 21 that it was served on the parties and the Board November 22nd.
22 BY MR. GUILD:
r
l 48 l 1 Q The NRC inspector at page 5 of the inspection report
,\
x>
s 2 that closes this item, and that's again 85-52 and 50, states 3 with respect to this comprehensive review, "The evaluation 4 also took into account the nature of the task and retrofit 5 programs which have been implemented. The inspector examined 6 this comprehensive review and found it to be satisfactory for 7 resolving the question of past auditing activities in relation 8 to programmatic and regulatory compliance."
9 Mr. Quaka, how did the review marked as Exhibit 3, 10 if it did, take into account the nature of the task and 11 retrofit programs which had been implemented? '
12 There is the inspection report if you would like to
()13 study what Mr. Schulz' and Mr. Kropp's language is.
14 [ Witness perusing document.)
i 15 A Could you repeat the question?
16 Q I will try. ,
i 17 I'm referring to language that was contained in the 18 inspection report that you have had in front of you, and that 19 is as follows: "The evaluation also took into account the 20 nature of the task and retrofit programs which have been 21 implemented." That's with reference to the comprehensive 22 review that the inspector describes.
1
49 1 The question is: How did the comprehensive review 2 which you have identified as Exhibit 3, the matrix, take those 3 factors into account?
4 A I believe the answer to that would be reflected in 5 the comments column. I'm sorry, the " Remarks" column. If, in 6 fact, there was not a specific audit that was referenced, by 7 number or date, then the " Remarks" column provides an 8 exple"ation as to the way that the area was addressed or in 9 the period defined across the top of the page.
10 Q Are there any other documents, Mr. Quaka, that 11 reflect the comprehensive review that the inspector refers to 12' that was r.sserted to have been conducted by Commonwealth
) 13 Edison and Phillips-Getschow other than that which has been 14 identified as Exhibit No. 3?
15 A No. The document there reflects a composite of the 16 audit coverages by Getschow, and in certain cases, as was 17 noted in the updated response to 14B(1), Commonwealth Edison 18 audits covering that area.
19 Q All right.
20 I direct your attention back to the two affidavits i
21 that you supplied in support of Commonwealth Edison's Motion
, 22 for Summary Disposition on 14B.
O
50 1 Describe for me, Mr. Quaka, how these affidavits, 2 and in particular the testimony that they attest to, were 3 prepared.
4 A The affidavits were prepared by examination of 5 documents and personal knowledge of the subjects in certain 6 specific areas. If I did not have personal knowledge of an 7 item, I did the research and was able to satisfy myself by 8 examination of records and information.
9 Q Who participated in preparing the testimony that is 10 behind the affidavits, the two pieces of testimony?
11- A I'm not sure -- are you asking people, or --
4 12 Q Yes.
() 13 A Generally, in the preparation of these affidavits it 14 was done with the assistance of certain people in my office.
I 15 If I needed additional information or documentation, they 16 retrieved that for me or I retrieved it myself. There are 17 several people that provided various pieces of information or 18 retrieved documents for me. Do you wish the names of those 19 individuals?
4 20 Q Yes.
21 A All right.
22 The individuals in my office that provided O
51 1 documentation for me were Eric Stockhan --
I
( 2 Q Can you spell the gentleman's last name?
3 A I may have to have the organizational chart in my 4 hand. The last name is spelled S-t-e-c-k-h-a-n.
5 Q What is Mr. Stockhan's position?
6 A He is a QA engineer in the Site Quality Assurance 7 Department.
8 Q All right.
~
9 A The second individual was Wally Marcis. The last 10 name is spelled M-a-r-c-i-s.
11 Q And what is Mr. Marcis' position?
12 A He is also a QA engineer in the Site Quality 13 Assurance organization.
f>s v-14 Another individual was John Smentak. I believe it's 15 spelled S-m-e-n-t-e-k.
16 Q And his position?
17 A He is also a QA engineer in the Quality Assurance 18 Department.
19 And perhaps Steve Hunsader. The spelling on that is 20 as reflected in the 14B(4) affidavit.
21 The other individual was Bob Seltmann of Comstock.
22 The spelling, I believe, is S-e-1-t-a-a-n-n.
O
,w --- -- ----,,-n,-e-,w-.,-,e-,-- - - - ,,n-- , - -- - , - - --- ,-,-,----------------,----~-------e--,-,,------r-----
-,-+r-,-e,---, - - - , - ,- e
52 1 That is the complete list of individuals providing 2 information, as I recollect it now.
3 Q Did anyone other than yourself, Mr. Quaka, l
4 participate in drafting or writing the testimony?
5 A No. The actual writing of the testimony was by 6 myself.
t 7 Q You wrote the questions and the answers?
~
8 A As far as responding to the questions. I thought 9 you were asking me whether I drafted the answers. You are 10 correct that the questions, I did not write the questions.
4 11 The questions were provided to me by counsel.
5 12 Q Mr. Miller?
13 A Mr. Miller or members of his staff.
14 Q What other counsel provided you with questions or 15 answers for your testimony?
16 MR. MILLER: I object to the form of the question.
17 MR. GUILD: I probably didn't ask it right.
18 MR. MILLER: I think his testimony is that he did 19 the answers himself and we provided the questions.
20 THE WITNESS: I don't have complete knowledge as to 21 who prepared the questions the first time around. As far as j 22 the lawyers that I worked with relative to the preparation of l
1 i
O
. - . - - . . ~.. -=-- .- - - - --
53 1 the testimony, Lisa Stiles is the primary person that I worked 2 with, i
3 Q Did anyone other than yourself propose language for 4 inclusion in the testimony?
5 A I don't believe so.
6 Q Did you provide a draft of your testimony that 7 differed in any respects-from the final testimony that's 8 included in support of the Motion for Summary Disposition?
9 A As I_was going through the preparation of testimony, 10 I did provide drafts, and to the extent that additional
)
11 information was necessary or there were questions by counsel, 12 I went back and made revisions to my answers to respond to --
() 13' 14 or to assure that I responded completely to the questions they had provided.
15 Q Were the questions they provided identical to the 16 questions that are included in the testimony that has been 17 filed? -
18 A I believe so. It has been some time since I 19 prepared this.
20 Q When did you prepara it?
21 A I prepared this in early December. I would correct 22 that statement to say late or second half of November or early l
" - - - ~~.-awe-- . . , , - , - , .-,-r ,,e----> . . . - - = - - , = , - - - - , - - - - , - -----.--,----,--,,,----,_-w -
,---,n,- , , - , , , - _ , - - - -
54 1 part of December.
( 2 Q Was the comprehensive review, the matrix that has 3 been identified as Exhibit 3 complete when you prepared your
. 4 testimony?
5 A My recollection is that while I was preparing the 6 testimony, that was, in fact, going on, and at some point 7 prior to completion of the testimony, I believe the matrix was 8 finished. I don't know the exact relationship of time.
~
- 9 Q What changes were made in your testimony, Mr. Quaka, 10 between the draft that you submitted and the final version 11 that has been filed?
12 A In terms of substance, I really don't believe that 13 there has been any significant change. ,
14 Q How about any changes?
15 A I really can't think of specific examples that I 16 could cite. I'm sure the ability to place the English 17 language on the paper and how well one person does that as 18 opposed to the other, and intentions versus actual words are 19 such that sentences are rewritten to reflect exactly what I 20 want to say, but beyond that, I don't believe that there has 21 been any substantive change between the initial draft of my 22 testimony, unless, as I was preparing the testimony I was O
i
55 1 going back and examining documents and satisfying myself that 2 my statements were, in fact, accurate, and to the extent that 3 the document provided me some information, I would make the i
i 4 correction in my testimony.
5 Q Who participated in editing the drafts of.your 6 testimony?
7 A The editing of the drafts of my testimony was done 8 in conjunction with Lisa Stiles.
9 Q Anyone else besides Ms. Stiles?
10 A No, not to my knowledge.
11 Q Can you recall any changes that were made to your 12 testimony after the draft that you submitted? Take a moment r
( )h _
13 and examine it if you need to.
i 14 (Witness perusing document.)
15 A The only change that comes to mind was in preparing 16 my response to 14B(2).' When I was examining the records, the 17 actual Comstock quality ass *rance program and the response 18 that Commonwealth Edison suomitted to the NRC, the original 1
19 draft of my testimony addressed manual sections, as our 20 response did, and when I went and examined the commitment in 21 the Comstock Corporate Quality Assurance manual, in fact the 22 responsibility for Comstock is to audit all 18 of the l l
, l
~- - _ _ _ . _ . _ _ - _ _ _ . _ . . . ,
56 i
1 criteria, and since that was the commitment and in fact that 2 was the nature of the citation that was identified in the NRC 3 report, I changed my testimony to more accurately respond to 4 the issue that the NRC raised, which was you didn't cover all 5 18 criteria of 10 CFR 50, Appendix B.
6 I found that when I examined, as I said, the 7 Comstock manual and the NRC report, they were talking about l
8 criteria. I was talking about manual sections, and I felt it 9 was more logical for me to talk in terms of apples and apples.
10 Q Did counsel participate in the drafting or editing 11 of your testimony with respect to the answer to question 11, 12 which begins on page 10 to the first set of testimony on 14B, 13 Mr. Quaka?
( }
14 A Your question was did counsel --
15 Q Participate in the drafting or editing of your 16 testimony in answer to question 11.
17 A I would say that the involvement in the answer to 18 question 11 was in my mind not any different than the answers 19 or the involvement in any of the other questions. It doesn't 20 stand out in an particular fashion.
21 Q Did counsel participate in the drafting or editing 22 of your answer to question 11?
I i
57 1 A If you mean by drafting or editing did counsel ask
) 2 questions and ask me to more clearly state the basis for some 3 of my presentation, the answer is yes.
4 Q Did your answer to question 11 change from the 5 original draft which you prepared?
6 A I don't believe that it changed substantively.
7 Q Did it change at all, the language used?
8 A Perhaps slightly in terms of phraseology and 9 sentence construction, but the substance of the statement or 10 the responses is, in fact, the same.
4 11 Q Mr. Quaka, I want to direct your attention to 12 sub-item 14B(4), identified as B(4). I will show you a copy 13 of the text of that item. >
14 Are you familiar generally with the subject of that 15 portion of the item of noncompliance?
16 (Witness perusing document.)
17 A Yes, generally I'm familiar with the item you are 18 referring to, which deals with Pullman audits.
19 Q The last bullet there.
20 A Ch, I'm sorry.
21 (Witness perusing document.)
22 Yes, I have very general knowledge of that subject b
v 1
. .~ .- - _- - . . . _ - _ - - _ _ _ _ . . - _ _ _ .
58 1 area. -
(' 2 Do you agree that Commonwealth Edison Company N. Q 3 disagreed with the NRC's findings with respect to that item of 4 noncompliance?
5 A Yes, I'm aware of that.
6 Q Is it Commonwealth Edison Company's position with 7 respect to that sub-item that has been referred to as 14B(4),
l 8 is it commonwealth Edison Company's position that with respect '
9 to that item, Edison's audits were effective?
10 A I think the detailed analysis of that item is -
11 reflected in Mr. Hunsader's testimony,'but my review of the 12 facts relating to this particular item lead me to agree with
( }
13 the position stated in Mr. Hunsader's testimony that~in fact 14 the audits were timely and adequate. I believe that's the way 15 we characterized this item in our response to the NRC and 16 subsequently in Mr. Hunsader's testimony. .
17 Q Try my question again, if you would.
18 Is it Commonwealth Edison's Company's position, 19 Mr. Quaka, that with respect to item 14B(4), Commonwealth 20 Edison audits were effective?
21 A I would have to answer yes.
23 MR. GUILD: That is all I have.
~
59
, 1 Thank you very much.
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60
-1 EXAMINATION 2 BY MR. MILLER:
3 Q Mr. Guild asked you, Mr. Quaka, whether there were '
4 any documents that reflected the Commonwealth Edison Company 5 interpretation of Regulatory Guide 1.144 in 1980, and I think 6 you responded to him that there were none, to your knowledge.
7
~
When you were quality assurance superintendent at 8 LaSalle, did you have occasion to interpret that regulatory 9 guide for the contractors that were conducting audits at that 10 power plant? ,
11 A The answer is yes, as part of the quality assurance 12 organization in my position as superintendent, I was involved
( ) 13 in the policies relative to Commonwealth Edison auditing 3 14 practicas and Commonwealth Edison's interpretations of things-15 such as the reg guides as they related to auditing l 16 specifically in this case. !
17 Q To your knowledge, was the interpretation of Reg l 18 Guide 1.144 the same or different than the interpretation at f 19 the Braidwood station, which was found to be improper by the i
20 NRC when it assessed the item of noncompliance that we have l i
21 been discussing this morning? i l
22 A The Commonwealth Edison interpretation of the reg i
O .
f
E 61 ,
i.
1 guide was, in fact, the same. I say that because when we were O 2 preparing our response to 83-09 -- as I mentioned, I think, in 3 my testimony -- I was in contact with Corporate Quality 4 Assurance because I noted that this represented in my mind a 5 difference in interpretation from what I had previously 6 understood as Commonwealth Edison's position during my time in 7 quality assurance.
8 MR. MILLER: I have no further questions.
9 j - 10 11
- 12 O> 14 1
15 16 17 18 19 20 ;
21 22
'O 4
62 1 FURTHER EXAMINATION 2 BY MR. GUILD:
3 Q You lost me a little bit there, Mr. Quaka. Maybe 4 some clarification, t t
5 In preparing which testimony did you contact 6 Corporate QA7 7 A In preparing -- I think I stated that in preparing 8 our response, the Braidwood site response to 83-09, I ,
9 contacted and discussed with Corporate Quality Assurance the 10 fact that the particular NRC citation reflected an 11 interpretation of requirements, the way in which the 12 applicable elements of the quality assurance program must be
- 13 addressed to be able to demonstrate that you had, in fact, 14 audited the entire program.
15 At the point that I was involved.in the review of 16 the item of noncompliance, I contacted the corporate office 17 because I wanted to understand if, in fact, you were going to 18 change our position on this matter.
1 19 Q So sometime after March of '84 but before July of 20 '84, you contacted Corporate QA. '
21 A Yes.
22 Q And that was because, I think I heard you say, the i
O
,, _ ,._,. _ ,,_ , , - , . - , , . - . . . _ . - - . . . , - - . - - . . , . - . . - . . , , ,-.n,
aL._--e 63
,s 1 interpretation at Braidwood was different than your
\~ 2 understanding of what the company policy had been.
3 A I think what I was saying was that the item of 4 noncompliance as written by the NRC and their statement that 5 to be able to demonstrate that all applicable elements of the 6 quality assurance program must be audited annually meant that i
7 in fact you had to demonstrate that all of your active 8 implementing procedures had to be audited and you had to have 9 documented,. objective evidence to show that you had covered 10 all of them was different from my understanding of Edison's 11 policy relative to what constituted auditing of the complete 12 program by a contractor on an annual basis.
()13 Q So you are saying the NRC's interpretation differed
. 14 from your own.
15 A That's correct.
16 Q And your own was consistent with the position that 17 the company has expressed subsequently.
18 A Yes. When I contacted the Corporate Quality 19 Ansurance organization, they acknowledged that, in fact , the l
20 position as stated in the item of noncompliance was different i 1
21 from what we believed to be a reasonable interpretation of all 22 applicable elements audited on an annual basis. '
l 4
, . ,- , , - + , , -
-- -. ,,, , . ,,--. ..,. - . - --,--- - , - - - - - - , -, . , ~ , -----,-.--a,, , , , - - ,,n -
64 1 Q Who did you contact at Corporate QA?
2 A I believe the individual that I contacted was George 3 Marcus.
4 Q Why did you have a question about what the Corporate 5 QA position was on this?
6 A I had a question because to me it reflected that if, 7 in fact, Edison agreed to the NRC's interpretation at 8 Braidwood, it in fact represented a change in policy or view, 9 and to that extent, my experience in the department as a QA 10 superintendent on matters of policy, Corporate Quality 11 Assurance is involved.
12 So I went to them to get some guidance, and that's 5 13 the reason I contacted them.
14 Q And it was Corporate QA's position that you should 15 dispute the interpretation that the NRC applied to the reg 16 guide?
17 A No, that is not correct. I guess I would 18 characterize it more as our saying this is a little different 19 way of looking at it than we have in the past but it doesn't 20 represent in our mind any difference in terms of the audits I
21 and the auditing practices, in our view. We felt that our 22 interpretation, which was to audit all applicable sections of O
65 1 the quality assurance manual or the 18 criteria on an annual 2 basis as well as selected or the more significant work 3 procedures, in fact achieved the same thing.
4 Q So an I understanding you correctly that it was 5 Edison's position that the differing interpretation of the reg 6 ' guide, which ultimately was adopted by Edison subsequent to 7 the item of violation, called for no change in your auditing a practice?
9 A I would say that it required more complete 10 documentation and accountability on the part of the 11 contractors, but at the time of our response, we didn't view 12 that it was going to significantly change the auditing or the 13 results of our audits.
14 I think the NRC's citation relative to Pullman, 15 Getschow and Comstock in fact demonstrate that even though the 16 interpretation that we had and we had communicated to the 17 contractor was changed slightly as a result of Edison's 18 response to the item of noncompliance, in fact the contractors 19 were auditing essentially all of their implementing procedures 20 anyway.
21 And in fact, I can think of an example of Comstock, 22 in their proposed 1983 audit schedule, the final page of that O
66 1 document reflects the fact that the site person who prepared 2 that schedule said that these are all of the procedures that 3 are in effect right now -- and I'm paraphrasing of course --
4 that these are all of the procedures that are in effect right 5 now, and to the extent that any new ones are issued, we will ,
6 include them in our audit schedule.
7 If you examine Pullman, you find that the NRC only 8 identified -- I don't know the exact number, but only a couple 9 of procedures that in fact they had not audited. Similarly in
]
10 the case of Getschow, my reading of the item noncompliance 11 reflects not that they weren't auditing their procedures but, 12 in fact, they did not have them on the audit schedule.
() 13 So in fact, we did not view the difference in 14 interpretation as really a very substantive difference in what 15 would occur by way of the auditing by the contractors.
16 Q How did you communicate your new interpretation and 17 any implementing instructions of that new interpretation to 18 the site contractor?
i 19 A We basically told them to make sure that from now on 1
20 their audits did, in fact, audit all active site procedures. ,
21 Q And is that instruction or communication reflected l l
22 in any document?
l O
67 1 A I would have to look at our response to 83-09, but 2 that is alluded to. I think the communication to the 3 contractors was verbal, and in fact, it was reflected by way
- 4 of their each revising their procedures -- or I'm sorry, i.
j 5 revising their audit schedules to account for any procedures ..
I j 6 that were not, in fact, on the schedule previously. 1 7
7 Q Are you aware of any documentation, other than in i '
8 the response to the NRC, of the change in Commonwealth
) 9 Edison's interpretation of the regulatory guide's requirements r
10 or any implementing instructions as a consequence of that 1
11 changed interpretation?
12 A Not specifically generated by Commonwealth Edison,
() 13 but in addition to changes in certain of the contractors'
] 14 audit procedures as a result of this new guidance, I believe
)l 15 that, at least in the case of Getschow, they also made a 16 revision to their quality assurance manual.
]
17 Q Help me identify one thing, and that is this ,
l 18 Comstock '83 proposed audit schsdule that you just referred
.19 to. Is that included in the documents that you brought with 20 you?
i 21 A Yes, it is. It would be in the other pile.
22 Q This is Exhibit 2B.
l t
1
)
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- l i
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~ , _ . , _ _ _ _ _ _ _ _ .___._. _ .____ _ ___ _ __._ _ _._._ _ _
68 1 (Witness perusing document.)
2 A The document that I am 1 coking at is titled l
3 " Proposed Internal Audit Schedule for 1983," dated 12/1/82.
4 ,
It consists of four pages, and on the fourth page it states, I
{
l 5 "The above schedule includes all Braidwood procedures written 1 6 to date. The months of May and December have been left l 7 comparatively open to take care of the procedures to be 8 written." And there are some more words there, but those are 9 the phrases I was referring to.
10 MR. GUILD: I have no further questions.
11 Might I suggest as a way of handling these documents 12 that since you have seemed to Bates stamp the documents 13 already, that we substitute a Bates-stamped version for the 14 unmarked version.
15 MR. MILLER: If you will turn over custody of 16 Exhibit 2 to me, I will substitute the Bates-stamped version 17 and return them directly to the reporter, and she can affix new 18 reporter's identificetion stamps to the documents.
l 19 MR. GUILD: That will be fine.
i 20 Thank you, Mr. Quaka.
21 (Whereupon, at 12:47 p.m. the taking of the l 22 deposition was concluded.)
lO
69 1 CERTIFICATE OF DEPONENT 2
i 3 I, THOMAS E. QUAKA, do hereby certify that I have 4 read the foregoing transcript of my deposition testimony, 5 and, with the exception of additions and corrections, if any, 6 hereto, find it to be a true and accurate transcription 7 thereof.
8 9 .._h ^
10 THOMAS E. QUAKA y 11 12 &!
v
/t >_ /T86 13 DATE 14 ***
l l
15 CERTIFICATE OF NOTARY PUBLIC l 16 Sworn and subscribed to before me, this the 17 day of
,DfYf ,
19&.
18 i 19 . ,
20 '% ^^
21 NOTA 1E PUBLIC IN AND FOR 22 My commission expires:
/h /fN O
70 1 CERTIFICATE OF NOTARY PUBLIC 2
I 3 I, MARILYNN M. NATIONS, the officer before whom the 4 foregoing deposition was taken, do hereby certify that the 5 witness whose testimony appears in the foregoing deposition 6 was duly sworn by me; that the testimony of said witness was 7 taken by me and thereafter reduced to typewriting by me or 1 8 under my direction; that said deposition is a true record of 9 the testimony given by the witness; that I am neither counsel 10 for, related to, nor employed by any of the parties to the 11 action in which this deposition was taken; and further, that I 12 am not a relative or employee of any attorney or counsel
( ) 13 employed by the parties hereto, nor financially or otherwise 14 interested in the outcome of the action.
15 l
16 M 17 MARILYNN M. NATIONS I 16 Notary Public in and for the 19 Commonwealth of Virginia 20
'21 My Commission expires January 15, 1989.
22 O f J
! I
~
t r 1/30/86 N,a)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
)
COMMONWEALTH EDISON COMPANY ) Docket No. 50-456
) 50-457 (Braidwood Nuclear Power )
Station, Units 1 and 2) )
NOTICE OF DEPOSITT5N F l
Pursuant to 10 C.F.R. $2.740(a), Intervenors Rorem, et al.
(T hereby give notice that they shall take the depositions of the .
following witnesses, who are employees of Commonwealth Edison Company or its contractors: James W. Geiseke; Kenneth T.
Koscal; Edward M. Shevlin: George Orlov and Thomas E. Quaka.
The depositions shall commence on Wednesday, February 12, 1986, at 10:00 A.M., and shall continue thereafter until completed, at the offices of Isham, Lincoln and Beale, Three First National Plaza, Chicago, Illinois; or at such time and place between February 12-14, 1986 as the parties may agree. The depositions shall be taken before a certified court reporter, and shall be on the subject of the witnesses' knowledge of the quality assurance deficiencies at the Braidwood nuclear power station alleged in Intervenors' Amended Quality Assurance Contention.
V < .
EXHISif
&baw
<i s e u q
p '
The deponents shall bring with them all documents in their !
possession, or subj ect to their control, which are the basis 1 i
for the witnesses' affidavit in support of Applicant's December 20, 1985, Motion For Summary Disposition.
DATED: January 30, 1986 Submitted by, sk Robert Guild One of the Attorneys for f
Intervenors Rorem, et al.
)
Douglass W. Cassel Robert Guild Timothy W. Wright, III 109 North Dearborn Suite 1300 Chicago, Illinois. 60602 (312) 641-5570 4
0
p 1/30/86
(
UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
) .
COMMONWEALTH EDISON COMPANY ) Docket No. 50-456
) 50-457 (Braidwood Nuclear Power )
Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that I have served copies of Intervenors Rorem, et al. Notice of Depositions on each party listed on the attached Service List by having said copies placed in envelopes, properly addressed and postaged (first class) and deposited in the U.S. mail at 109 North
Dearborn,
Chicago, Illinois 60602, on this 30th day of January, 1986; except that NRC Staff Counsel Mr. Treby was served via Federal Express overnight delivery and Mr. Stahl, counsel for Edison, was served by messenger on Friday, January 31, 1986.
Yhy% hiu%
I r/
I
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y~
( BRAIDWOOD SERVICE LIST x_
50-456/50-457 OL Herbert Grossman 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 Washington D.C. 20555 Dr. A. Dixon Callihan Administrative Judge Joseph Gallo, Esq.
102 Oak Lane Isham, Lincoln & Beale
. Oak Ridge, TN 37830 Suite 840 1120 Connecticut Avenue H.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 Regulatory Commission Rebecca J. Lauer, Esq. Washington D.C. 20555 Isham, Lincoln & Beale
. ~'T Three First National Plaza Atomic Safety and Licensing
(/
N- Chicago, IL 60602 Board Panel U.S. Nuclear Regulatory Ms. 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 Washington D.C. 20555 Thomas J. Gordon, Ecq.
Waller, Evans & Gordon Michael I. Miller, Esq.
2503 South Neil Isham, Lincoln & Beale Champaign, IL 61820 Three First National Plaza Chicago, IL 60602 Lorraine Creek ,
1 Route 1, Box 182 Manteno, IL 60950 Region III U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement 799 Roosevelt Road Glen Ellyn, IL 60137 l
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