ML20205C584

Forwards First Installment of Util Rebuttal Testimony Which Describes Two Extensive Repeat Insp Programs,Const Sample Reinsp & Pittsburg Testing Lab Overinsp Program.Related Correspondence

ML20205C584
Person / Time
Site:	Braidwood
Issue date:	08/07/1986
From:	Steptoe P COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Callihan A, Cole R, Grossman H Atomic Safety and Licensing Board Panel
Shared Package
ML20205C591	List: ML20205C584 ML20205C594 ML20205C606 ML20205C612
References
CON-#386-296 OL, NUDOCS 8608120397
Download: ML20205C584 (4)

Text

-

y

,~ .. -

e ISHAM, LINCOLN & BEALE 00CKETED COUNSELORS AT LAW USNRC 1 REE nRSr ~ Arc ~AL RLAzA CHICAGO. ILLINOIS 606C2 86 ale 11 A10:39 EDWARD $ ISMAU 1872-1902 TELEPHONE 312 558-7s00 19 S LASALLE STREET ROBERT T UNCOLN 1872-1889 TELEX 2-5288 CHICAGO.ILUNois 60603 wu= G SEALS. ms-ma OFFICE Oc SELage 342 ss8-ssoo *

"sy"'uTE ER* " * * ' " August 7, 1986 $[AhCb# As0 Cou~ECriCut AeuE. w w wash. 2ocas r{n Herbert Grossman, Esq. ,,c,L, ,,;,,, ,,,,c, Chairman iam ss8-Administrative Law Judge Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, D.C. 20555 Dr. A. Dixon Callihan Administrative Law Judge 102 Oak Lane Oak Ridge, TN 37830 Dr. Richard F. Cole Administrative Law Judge Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, D.C. 20555 Re: In the Matter of Commonwealth Edison Company (Braidwood Station, Units 1 and 2)

Docket Numbers 50-456 and 50-457

Dear Administrative Judges:

Enclosed is the first (and largest) installment of Commonwealth Edison Company's (CECO's) rebuttal testimony. '

It is being filed early to expedite these proceedings.

The testimony describes two extensive repeat .

inspection programs, the Construction Sample Reinspection I (CSR), which was a part of BCAP, and the PTL overinspection program. (" Repeat inspections" is a term used to include both reinspections and overinspections.) These repeat inspection programs were conducted independently of each other and for reasons unrelated to intervenors' claims of harassment and intimidation. Nevertheless, the results of these two programs demonstrate that the alleged undue production pressure and the alleged acts of harassment and intimidation at LK Comstock had no impact on the effective-ness of Comstock QC inspections, and that the quality of Comstock QC accepted work is acceptable.

8608120397 860807 PDR ADOCK 05000456 fd

This rebuttal testimony involves twelve witnesses.

CECO will offer these witnesses in three panels. The first panel will sponsor the CSR data by explaining the design and methodology of the CSR and by describing the CSR results.

The second panel will sponsor in a similar fashion the PTL overinspection data. The third panel will evaluate the results of the CSR and PTL repeat inspections and relate those results to the issues in this proceeding. The three panels are:

Panel 1 (CSR) Panel 2 (PTL) Panel 3 (Evaluation)

Dr. Kaushal Mr. Marcus Mr. Marcus Mr. Kostal Mr. D' Antonio Mr. Del George Mr. Thorsell Mr. Forrest Dr. Frankel Mr. Shevlin Mr. Frazier Mr. Wozniak Mr. Smith This division of the testimony is inexact. For example, Mr.

Marcus appears on two panels because his testimony both sponsors and evaluates the PTL overinspection results. Dr.

Kaushal, Mr. Kostal and Mr. Thorsell certainly evaluate the CSR results. Nevertheless, these three panels seem to be the most efficient and useful way to present these witnesses, bearing in mind that their testimony is often interrelated and no one witness knows everything about either program.

This is not a situation where disputed issues of fact require the segregation and exclusion of witnesses.

CECO has not offered detailed testimony on the mechanics of how the CSR and PTL repeat inspection data was compiled. We hope to satisfy the other parties through informal discovery and discussions that such compilation was l properly performed. If technical legal objections are 1 interposed on this issue, CECO may be required to bring {

forward additional rebuttal witnesses to meet such objec- l tions. '

l f S$ncerh1(, /

' )x!y n Ph' lip P. teptoh PPS/cjh Enc.

s IsYdG CERTIFICATE OF SERVICE M ll 40:39

~

00c?[7 * "en.ym Philip P. Steptoe hereby certifies that he 5kVICE copies of the enclosed letter dated August 7, 1986, together

~

with the rebuttal testimony referred to therein, upon the individuals listed in the above Notice of Filing by causing true and correct copies thereof to be served by first class 4

mail, Federal Express

• or hand delivery,** on the 1 ' day of m b , 1986. q

'l  :

jl l lt //

Wjk

> i i

l I

r i

y w , , .---r,

- - -.,,n .,.,y-.. - - - - -

_ .~--.7 -,-~,-.w . ,e - - --- *- r +-

~

On t; 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, D.C. 20555 ,

Commission

• Washington, D.C. 20555 Ms. Bridget Little Rorem

, 117 North Linden Street Dr. Richard F. Cole P.O. Box 208 Administrative Law Judge Essex, Illinois 60935 Atomic Safety and Licensing ,,

Board Robert Guild United States Nuclear Regulatory Douglass W. Cassel, Jr.

Commission Timothy W. Wright, III Washington, D.C. 20555 BPI 109 North Dearborn Street

• Dr. A. Dixon Callihan Suite 1300 Administrative Law Judge Chicago, Illinois 60602 102 Oak Lane Oak Ridge, Tennessee 37830 Charles Jones, Director Illinois Emergency Services

,Stuart Treby, Esq. and Disaster Agency Elaine I. Chan, Esq. 110 East Adams Office of the Executive Legal Springfield, Illinois 62705 Director United States Nuclear Regulatory i Commission

• William Little, Director Washington, D.C. 20555 Braidwood Project Region III i Atomic Safety and Licensing United States Nuclear Regulatory Board Panel Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, Illinois 60137 Washington, D.C. 20555 Janice A. Stevens j Atomic Safety and Licensing United States Nuclear Regulatory l Appeal Board Panel Commission United States Nuclear Regulatory 7920 Norfolk Avenue j Commission Phillips Building i Washington, D.C. 20555 Bethesda, Md 20014 i FOR ADDRESSEE ONLY George L. Edgar, Esq.

Thomas A. Schmutz, Esq. Carolyn Jourdan, Esq.

Newman & Holtzinger, P.C. U.S. Nuclear Regulatory 1615 L Street, N.W. Commission Suite 1000 office of the General Counsel Washington, D. C. 20036 Washington, D. C. 20555

-- . . _ - - -