ML20154B288
| ML20154B288 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/28/1986 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#186-260 OL, NUDOCS 8603040274 | |
| Download: ML20154B288 (18) | |
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. UNITED STATES OF AMERICA Occa;u '
Y'gg Y-NUCLEAR REGULATORY COMMISSION.
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szawcasunca SECT-URQ In the Matter of:
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-45 gg_
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50-457 (Braidwood Station,
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4 Units 1 and 2
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j SUPPLEMENTAL RESPONSE TO INTERVENORS' GENERAL INTERROGATORIES Applicant hereby supplements its January 24, 1986 response to Intervenors' General Interrogatory 2 by updating the list of the witnesses it currently intends to present in this proceeding.
1.
Subcontention 2.
Applicant may file in evidence the depositions of certain Comstock QC inspectors.
Applicant cannot determine at this time which depositions it will so designate.
I 2.
Contention item 3.A.4.
John Schimmels will not testify.
David Boone will testify on item 3.A.4.b.
He will discuss Applicant's provisions for assuring adequate clearance.
3.
Contention item 6.E.
Applicant's witness will-be James 4
Gieseker.
4.
Contention item 8.B.
James Gieseker will discuss the corrective action taken by Applicant with respect-to the NRC i
item of noncompliance regarding Vulkene wire.
Thomas Thorsell will discuss the engineering evaluation by S&L dispositioning NCR 707 regarding Vulkene wire.
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5.
Contention item 12.B.l.
David Boone will replace Gerry Groth.
Michael Gorski will address the specific incident described in this contention item.
Mr. Boone will discuss the review of past PGCo NCRs under PGWI 37.
6.
Contention item 12.B.2.
Larry Koch and Sarra Reece will replace Conrad Holt.
Mr. Koch will describe Pullman's use of correction notices.
Mrs. Reece will address the results of the analysis of Pullman correction notices performed in re-sponse to this inspection finding.
7.
Contention item 12.C.
Ernest Branch will replace William Cleff.
8.
Contention item 12.D.
George Marcus will replace Richard Netzel.
Kenneth Kostal will also testify.
9.
Contention item 14.A.
George Marcus will testify in addition to Eugene Fitzpatrick.
WIED CORRESPONDENCE 9
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s::nv:csranca sec u nc NAME:
Edward D. Fuller q
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BUSINESS ADDRESS:
S. Levy Incorporated 3425 So. Bascom Avenue Campbell, CA 95008 i
EDUCATION:
BA, Physics, San Jose State, 1962 MS, Nuclear Engineering, Stanford University, 1964 Advanced Engineering Course at General Electric PROFESSIONAL As Vice President of S. Levy Incorporated since 1978, EXPERIENCE Mr. Fuller has consulted with many utilities on regu-latory issues.
He has supported operating plants such as Duane Arnold, Rancho Seco, Brunswick, TMI, Monticello plants under construction such as WNP-2, Shoreham, Millstone Point 2,
and plants seeking construction permits such as Black Fox, Allen's Creek, and Skagit/Hanford.
He has worked on issues such as pipe cracks, fire protection, ATWS, hydrogen i
control, integrated planning, technical specification development, safety review programs, decontamination programs, and all TMI-related issues.
Mr. Fuller has been active in construction program quality reviews at the Clinton project for Illinois
- Power, the Duane Arnold Energy Center for Iowa Electric, and the Three Mile Island Unit 2 for General Public Utilities.
He serves on the Carolina Power and Light Safety Review Board and the Iowa Electric Safety Committee.
Prior to joining S.
Levy Incorporated, Mr. Fuller worked for General Electric for eighteen years in a variety of assignments including six years in concep-tual fuel design, two years as manager of the engi-neering training program, two years as technical leader for core management services, four years as fuel specialist and manager of fuel proposal engi-neering, two years as manager of BWR proposal engi-neering and two years as manager of domestic BWR licensing.
In the fuel management area for General Electric he organized and supervised the early station nuclear engineering course, directed the in-core fuel manage-ment analysis work for GE BWRs, defined in-core fuel performance capability of BWR proposals, developed j
and negotiated fuel performance and core management
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services contracts for General Electric.
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E. D. Fuller
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Mr. Fuller's project experience includes two and one-half years as manager of BWR licensing which included responsibility for all of GE's domestic project licensing activities, including resolution of generic licensing issues.
LICENSE:
Registered Professional Engineer in the State of California ANS ACTIVITIES:
ANS Treasurer, Board of Directors, Executive Committee, Chairman Fuel Cycle
- Division, Vice Chairman Power
- Division, Chairman Professional Divisions Committee, Chairman Public Policy Committee i
PUBLICATIONS:
Author of many papers and published articles in the areas of plutonium recycle, in-core fuel management strategies, operating reactor physics calculational 1
- methods, advanced boiling water reactor systems, licensing, and integrated planning.
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RESUME MD CORRESPON fs ROBERT V.
LANEY
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')U 24 Trout Farm Lane t
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MAR 3-88sa 1 i
Phone: 617-585-8912 ncQC 4
C;nc;rnas uumcn Robert V. Laney is a consultant in nuclear energh
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'C' project management.
He has broad executive and technic xpg ence in power plant design and operation; in energy resea development; and in the construction and operation of large energy projects.
His working experience includes extensive periots in operating power plants for the U.
S. Navy; in the Navy nuclear power development program; in nuclear ship construction; in energy research and development; and in assessment of nuclear plant design, construc-tion, and operation.
While an officer in the Navy, Mr. Laney, in 1948, became one of a small group of engineers chosen by Admiral H.
G.
Rickover to assist him in developing nuclear power plants for naval ship pro-pulsion.
He served as Project Manager for the development, design, and construction of the land prototype of the Sea Wolf nuclear power plant and participated in the construction of the first nuclear submarines, the U.S.S.
Nautilus and Sea Wolf.
These were followed by responsibilities in applying nuclear power to surface ships and the first nuclear power station at Shippingport, Pennsylvania.
While Naval representative at the Bettis Laboratory in Pittsburgh, Mr. Laney developed the first comprehensive quality assurance program for the Navy's network of nuclear propulsion plant suppliers.
In 1959, as a civilian, Mr. Laney moved into nuclear ship construction at the General Dynamics Shipyard in Quincy, Massachu-setts.
In 1963, he was appointed Vice-President and General Manager.
In this capacity, he was responsible for the design and construction of a number of nuclear powered surface ships and sub-marines.
In 1970, he turned to the development of more advanced energy technologies when he was asked by the University of Chicago to be-come Associate Director of the Argonne National Laboratory, devoted to developing a range of new energy options.
He later became Deputy Director with additional responsibility for engineering development and Laboratory administration.
During this period he directed programs for developing breeder reactors, improved coal combustion, conservation technologies, high-efficiency batteries, and nuc] ear fusion.
He retired from Argonne in 1979 to become a private consult-ant in nuclear power.
Some of his recent activities are listed here:
1979-80 Participated as member of Senior Advisory Panel to the Chairman of Commonwealth Edison to evaluate the Company's nuclear energy program in light of Three Mile Island.
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1979-80 Participated as member of an Advisory Committee to the President of. General Public Utilities to evaluate per-j (
sonne 1' selection and training, man / machine interface, I
and communications at Three-Mile Island.-
.1980-81 Assisted the Department'of Energy to find suitable. ways to solidify and remove high-level radioactive wastes stored at West Valley,:NY.
1 1980-82 Led a team which evaluated and advised the Managing Director in ways to improve the nuclear engineering and-construction programs of the Washington Public. Power Supply System.
1981 Led a committee of experts formed to advise the' Depart-ment of Energy concerning the merits of various processes for vitrifying high-level nuclear waste.
1983 As consultant to Houston Lighting and Power Company, performed an evaluation of the Engineering Assurance Program for their South Texas nuclear station.
4' 1982-83 Led a panel which audited the Washington Public Power j
Supply System's program-for verifying the design and construction of their WNP-2 nuclear station.
1983 Assisted Admiral Rickover in preparing an assessment of j
GPU Nuclear Corporation's management competence to operate TMI-1.
I 1983-84 Participated as member of a special study group which advised the Nuclear Regulatory Commission on means to improve the design and construction quality of concer-cial reactor plants.
t 1983-Became a consultant to Commonwealth Edison to assist in 7
programs to evaluate the adequccy of construction of their Byron and Braidwood nuclear stations.
1984-Became a member of GPU Nuclear Board of Directors and Chairman of its Nuclear Safety Committee.
1984-Chairman of panel of experts responsible to evaluate Houston Lighting and Power ' Company's program for assuring the design adequacy of its South Texas nuclear station.
4 I
1984-Chairman of a panel of experts responsible to conduct a
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l' continuing evaluati,on of Virginia Electric Power's oper-I ation of the North Anna nuclear station.
2 Mr. Laney holds a B.S. degree.from the U.
S. Naval Academy, an M.S. degree from the Massachusetts Institute.of Technology,'and I
an MBA from the University of Chicago.
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I ROBERT V. LANEY Employment History January 25, 1984 to Present Member GPU Nuclear Board of Directors and Chairman of Board Committee'on Safety November 1, 1979 to Present Consultant in Nuclear Project Management 1972 to November 1, 1979 Deputy Director, Argonne National Laboratory, University of Chicago.
Responsible for all applied re-search and development, and'for Laboratory administration of-this 5300 person institution.
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1970 - 1972 Associate Director, Argonne National Laboratory, responsible for nuclear reactor research and development.
1964 - 1970 Vice President and General Manager of-Quincy (Massachusetts) l Shipyard Division of General 4
Dynamics.
(8500 employee.c)
I 1960 - 1964 Nuclear Design and Construction Manager of Quincy Shipyard of Bethlehem Steel' Company.
1 i
1 1954 - 1960 As U.
S.
Naval Captain, tech-nical representative of the Atomic Energy Commission at the Westinghouse Bettis Atomic Power Laboratory, Pittsburgh, i
1948 - 1954 Reactor Development Project Manager in the Naval Reactor.
Program of the Atomic Energy Commission and the Navy's Bureau of Ships, Washington, DC.
4 1939 - 1948 Active duty Naval officer; various duties at sea and ashore.
Engineer office on carrier, j
destroyer, and battleship.
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l y':Derience Record Sargent & Lundy Engineers Chicago, Illinois 1
Jan. 1977 Supervisor of Metallurev Section.
Supervision of to metallurgical staff involves control of work flow, present assignment of projects and field trips, initial approval of overtime, monitoring staff performance and. making.
final technical decisions unresolved by staff.
Other duties described below.
l 1972 to Weldinc Metallurgist.
The first year and a half, my l
1977 function was to provide welding and metallurgy assistance l
to fossil fuel and nuclear power plant projects.
l Specifically, the review of special process procedures (i.e., welding, heat treatment, etc. ), bid propo sal re-views, material substitutions, deviations from specifi-cations, resolution of shop and field fabrication problems, and failure analysis on operating stations.
Additional 1
duties progressed to include training of new personnel, welding and metallurgy portion of field personnel training, videotaping of " Welding Seminar" training program for project management staff, company representative on various A-1 subcommittees of ASTM, welding and metallurgy input on internal mechanical, structural and electrical standard specifications, and recommend Sargent & Lundy position on NRC Regulatory Guides that involve welding and metallurgy.
Graver Tank East Chicago, Indiana 1971 to Senior Welding Engineer.
Duties at Graver were to reduce 1972 costs through development of improved welding processes, perform-tests required for industrial and government codes or specifications, trouble-shoot welding problems in the shop and field, prepare welding procedures to ASME and API codes, and provide metallurgical and welding consult-ation to sales and cost departments.
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Resume of James T. Louden Page 2 r
Specifically..I worked on the development of the portable electroslag process for API tanks, submerged arc welding-processes, complete preparation and testing of Charpy "V"-
notch impact test specimens including notch traverse-studies to determine the critical (lowest value) notch location for heat-affected. zone specimens and statistical analysis of impact results through the use of a computer, radiographic examination of -laboratory welds, and ASME Section III nuclear procedures for_the welding of con-tainment liners.
Sciaky Bros., Inc.
Chicago, Illinois 1963 to Welding Engineer.
Responsible for'all sample work 1971 feasibility studies of commercial TIG and MIG welding applications.
In this area, worked with electronic' engineer who developed first solid state TIG welding control, collaborated with transformer engineers to develop first single phase-dual' secondary MIG welding transformer and dual inductors.
Worked in the field with automotive technical center toward the acceptance of the new single-phase MIG equip-ment.
Made service trips to customer's plants to solve-welding problems and to coordinate trial runs of consign-ment TIG and MIG welding equipment in automotive industry.
Demonstrated latest developments in welding, such as high frequency pulsation TIG welding, during open-house sales promo tions.
Wrote equipment specifications, provided metallurgical consultation to Electron Beam Welding Department, coordinated LTV-Lance Missile EB welding program and worked with Sundstrand Corporation tooling engineers in the development of the first high production Electron Beam Welding machine.~
j Worked on aerospace sample programs, plasma arc develop-ment, narrow gap MIG welding equipment, " Esso" prccess MIG welding pipe development and research contracts.
Remington Arms Company (Now DESA)
Park Forest, Illinois 1962 to Metallurrist.
Responsible for quality of all heat treated 1963 parts, established heat treat process specifications for atmosphere hardening,. tempering, carburizing and carbon-itriding.
Also investigated production problems-and assisted design engineers on selection of new materials.
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____,,____,,_______,__________________________________m.
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Resume of James T. louden Page 3 I.T.T. Kellogg Chicago, Illinois 1960 to Senior Metallurcist.
Controlled production process 1962 quality, established process and material specifications, investigated new methods of fabrication and materials.
Responsible for resolution of production problems.
Materials were ferrous and non-ferrous.
Acme Steel Company (Now Interlake Steel)
Riverdale, Illinois 1958 to Assistant Process Metallurcist.
Responsible for. sampling, 1960 testing and inspecting steel strip in accordance with Government specifications: investigation of production problems, and analysis of customer complaints.
1954 to Co-Onerative Student.
Alternated school and work periods.
1958 Recorded process data as observer in hot-and cold-rolling mills.
Determined thickness of hot dip and electroplated steel, performed chemical analysis of steel, and analyzed annealing furnace gas atmospheres as Chemical laboratory Technician.
Performed spark testing, physical testing and metallographic examination ao Metallurgical Laboratory Technician.
Education June 1958 Illinois Institute of Technology, Chicago, Illinois B.S.
Degree in Metallurgical Engineering Level II ASNT qualification in radiography, magneti4.
particle and liquid penetrant examination.
Publications Co-author of technical paper covering work performed on Air Force contract.
Technical Report AFML-TR-66-74
" Development of Manufacturing Methods for TIG Welding."
Paper presented at American Welding Society meeting in 1966.
Author of article on high production Electron Beam welding machine in Sciaky magazine.
Professional Societies Member of American Welding Society ( AWS)
Member of American Society for Metals ( ASM)
References Personal references available on request.
b.
SARGENTS LUNDY Resume I cf 3 James T. Louden P
1 Title Superviser, Metallurgy and Welding Section Quality Control Division pducation Illinois Institute of Technology - B.S. Metallurgical Engineering - 1958 Responsibilities Mr. Louden supervises and coordinates all activities of the Metallurgy and Welding Section, assuring that all work is performed in accordance with company policies and client requirements. He continuously reviews National Codes, Standards, and Regulatory Guides to provide technicalinput and recommend changes to Sargent & Lundy Specifications, Standards, and Procedures.
Experience Mr. Louden has extensive experience in quality control, welding, and metallurgy. Mr. Louden is currently assigned to a nuclear power plant construction site as a welding and materials specialist. He is providing technical support to a construction assessment team and is assisting in the resolution of nonconformance and installation problems.
Before this, he has reviewed welding procedures, resolved metallurgy and welding problems in the shop and field, and has provided materials selection, welding, and metallurgy services to Sargent & Lur dy project management on many fossil-and nuclear-powered station projects.
Prior to joining Sargent & Lundy in 1972, he was a senior welding engineer with a tank manufacturer, and a welding engineer or metallurgist for other firms.
Memberships American Society for Testing and Materials
- A-1 Committee," Steel, Stainless Steel, and Related Alloys"
- Subcommittees A01.09, A01.10, A01.18, and A01.22 970,375 040535
3 Selected Ex y lence Record 2cf3 SARGENT E LUNDY 3ames T. Los n
v Power Plant Design Proiccts Rated Gross Operating Assignment Statian - Unit Fueel MW Date(s)
Client Assignment Date(s) u Braidwood 1,2 Nuclear
!!75 1987/1988 Commonwealth Temporary field assign-12-83 to present (each)
Edison Company ment to review structural steel traveler's from AWS DI.I code comphance, recommending specific quahfication test requirements as applicable; to serve as welding engineer for HVAC contractor; to work on construction assessment program as a welding and materials spe:ialist Zimmee !
Nuclear 839 Suspended The Cincinnati Gas &
Review of all special 10-73 to 1-84 Electric Company processes procedures (welding, beat treating, etc.) plus temporary field assignment to re-solve welder nonconfor-mances Quad Cities 1,2 Nuclear 850 1972 Commonwealth Review of welding and 2 75 to 12-83 (each)
Edison Company metallurgy procedures; resolution of field f abrication problems Dresden 2,3 Nuclear 850 1971 Commonwealth Review of welding and 2-73 to 12-83 (each)
Edison Company metallurgy procedures; resolution of field f abrication problems Zion 1.2 Nuclear 1035 1973/1974 Commonwealth Review of welding and 1-75 to 12-83 (each)
Edison Company metallurgy procedures; resolution of field f abrication problems La Salle 1,2 Nuclear
!!22 1982/1984 Commonwealth Review all shop and 1-74 to 12-83 (each)
Edtson Company field welding procedures; resolve contractor I
welding problems; review NRC Regulatory Guides, pertinent NUREG and IE Bulletins; attended C.E. BWR meetings to ensure state-of-the-art knowledge on IG5CC Schahier 17 Coal &
393 1983 Northern Indiana Review all shop and 12 79 to 2 83 Oil Public Service field welding procedures; Company resolve shop and field f abrication problems
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970,375 040585 1
Mected Expusence Record 3 CI 3 SARGENTS LUNDY James T. Louden e'
Power Plant Design Projects, Continued Rated Gross Operating Assi t
Station - Unit Fuel Mt Date(s)
Client Assignment Da Marble Hill 1 Nuclear 1175 Cancelled Public Service INPO evaluation of 10-82 to 11-82 InJiana nuclear power plant construction program Byron 1.2 Nuclear 1175 1985/1987 Commonwealth Review of welding and 8-73 to 4-78 Braidwood 1,2 (each) 1987/1988 Edison Company metallurgy procedures; resolution of shop and field fabrication problems l
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970,375 040585
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ILLINOIS INSTITUTE OF TECHNOLOGY BY AUTHORITY OF THE - BOARD OF TRUSTEES AND WITH THE CONCURRENCE OF THE FACULTY HEREBY CONFERS-ON
."AMES - T LOUDEN THE DEGREE OF BACHELOR OF SCIENCE IN METALLURGICAL ENGINEERING WITH ALL-THE HONORS RIGHTS AND PRIVILEGES THERETO PERTAINING GIVEN-AT CHICAGO-ILLINOIS THIS SIXTH DAY OF JUNE NINETEEN HUNDRED-AND FIFTY EIGHT
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CHAIRMAN OF VH BOARD-OF-TRUSHEs B
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PREstDENT h.
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Sara A.
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EDUCATION:
December 1980 rocxrnnos f8 Bachelor of Science SERVICE ERAI G /s Southern Illinois University
'(7 Carbondale, IL N/
Major:
Mechanical Engineering Technology G
EMPLOYMENT:
February 2, 1981 to 11/83 Commonwealth Edison Quality Assurance Engineer Braidwood Station Responsibilities:
2/81 - 10/81 Independent Testing Laboratory 2/81 to 11/83 Heating Ventilating and Air Conditioning Contractor 11/83 - Present General Instructor Commonwealth Edison Production Training Center Responsibilities:-
Reactor Operator Training Visual Examination Training Quality Assurance Training Coordinate Training for Pump Seminar - Non-Destruc-tive Examination TRAINING:
Magnaflux - Radiographic Interpretation 4/81
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Magnetic Particle Inspection 5/81 Liquid Pentrant Inspection 5/81 i
Carboline - Painting and Coating 12/81 i
CECO Training
. Auditing 3/81 Welding Technology 7/81 Codes and Standards 8/81 Pressurized Water Reactor Fundamentals' 10/81 I
Fire Protection 2/82 Visual Inspection 8/82 (VI,'VT-Basic, VT-1, VT-2, i
VT-3, & VT-4)
Westinghouse Materials consideration for a PWR 11/82 Energy Inc.
PEPSE 8/84 General Elec.
BWR Materials & Reactor Metallurgy Course 5/85 Corrosion and Corrosion Control in BWR's Course 5/85 Technical Seminars Inc.
Repairs, Replacement and Modifications to Operating Nuclear Power PlantsSection XI 6/85 6.
t TRAINING:
Arthur Anderson (cont.)
Co.
Effective Business Writing 12/85 Project Planning & Control 12/85 CECO Training Basic Instructor 12/83 Visual Examination (VT-B, VT-1, VT-2, VT-3, VT-4) 3/84 i
Boiling Water Reactor Introduction to Power Plant Operation 10/84 KT-Problem Solving /
l Decision Making 10/84 Advanced Instructor Course 11/84 PWR Indoctrination (Braidwood) 3/85 Lesson Plan' Seminar 5/85 Supervising'for Results 10/85 Academic Counseling Seminar 11/85 SAI-Management Communications 11/85 In-House Engineering Fluid Mechanics Seminar 12/85 L
r CECO Certifications:
Auditor O. A. Inspector Radiograph Interpretation Magnetic Particle Liquid Penetrant Visual Inspection (VI) t ANSI N45.2.23 ANSI N45.2.6 Level II SNT-TC-1A Level I SNT-TC-1A Level II
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SNT-TC-1 A Level II S NT-TC-1 A Level II Instructor Level II 12/84 I
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UNITED STATES OF AMERICA
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i NUCLEAR REGULATORY COMMISSION
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EFORE THE ATOMIC SAFETY AND LICENSING BOARD I
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4 In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456
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50-457 (Braidwood Station,
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Units 1 and 2)
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CERTIFICATE OF SERVICE I
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I, Peter Thornton, one of the attorneys for Commonwealth
~s Edison Company, certify that copies of Supplemental Response i
to Intervenors' General Interrogatories have been served in j
the above-captioned matter on all persons listed on the attached j
Service List by United States mail, postage prepaid, this 28th day of February, 1986 except where service has been made as otherwise noted.
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Peter Thornton l
i Isham, Lincoln & Beale Three First. National Plaza i
Chicago, Illinois 60602 (312) 558-7500 1'
I Dated:
February 28, 1986 i
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SERVICE LIST
- Herbert Grossman, Esq Mr. William L. Clements Chairman Chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Commission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Ms. Bridget Little Rorem 117 North Linden Street
- Dr.
Richard F.
Cole P.O.
Box 208 Administrative Law Judge Essex, IL 60935 Atomic Safety and Licensing Board United States Nuclear Regulatory
- Robert Guild Commission Douglass W.
Cassel, Jr.
Washington, DC 20555 Timothy W.
Wright, III BPI
- Dr.
A.
Dixon Callihan 109 North Dearborn Street Administrative Law Judge Suite 1300 102 Oak Lane Chicago, IL 60602 Oak Ridge, TN 37830 Charles Jones, Director
- Stuart Treby, Esq.
Illinois Emergency Services Elaine I.
Chan, Esq.
and Disaster Agency Office of the Executive Legal 110 East Adams Director Springfield, IL 62705 United States Nuclear Regulatory Commission William Little, Director Washington, DC 20555 Braidwood Project Region III Atomic Safety and Licensing United States Nuclear Regulatory Board Panel Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, IL 60137 Washington, DC 20555 Ms. Janice A.
Stevens Atomic Safety and Licensing United States Nuclear Regulatory Appeal Board Panel Commission l
United States Nuclear Regulatory 7920 Norfolk Avenue Commission Phillips Building Washington, DC 20555 Bethesda, MD 20014 l
~
(For ADDRESSEE ONLY)
By Messenger Delivery on 2/28/86 By Federal Express Delivery l
George L.
Edgar, Esq.
Thomas A. Schmutz, Esq.
Newman & Holtzinger, P.C.,
l 1615 "L"
- Street, N.W.
Suite 1000 l
Washington, DC 20036 l
l l
.