ML20151X074

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Response to Intervenor Third Set of Interrogatories & Request to Produce.Affidavits of Ws Little & JW Muffett & Certificate of Svc Encl.Related Correspondence
ML20151X074
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/06/1986
From:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
ROREM, B.
Shared Package
ML20151X058 List:
References
OL, NUDOCS 8602120279
Download: ML20151X074 (37)
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Text

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'J5NRC UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION

'86 FE810 P3:11 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFici.

00CMEica,.;. 2 s[,. . ' .

'In the Matter of ) BRANC4

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COMMONYTALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Station, Units 1 end :!) )

NRC STAFF RESPONSE TO INTERVENORS' THIRD SET OF INTERROGATORIES AND REQUEST TO PRODUCE NRC Staff Responses ,

A. General Interrogatories

1. Please state the full name, addres's, occupation and employer of

, each person answering - the interrogatories or assisting in the preparation of such answers, and designate the interrogatory or the part thereof he or she answered.

NRC Staff Response W.S. Little General Interrogatories 1,2,4; Director, Braidwood Project Specific Interrogatory 1-7,9,10 U.S. NRC Region III 799 Roosevelt Road Glen Ellyn, IL 60137 J.W. Muffett Specific Interrogatory 8 Reactor Inspector (Mechanical)

U.S. NRC Region III 799 Roosevelt Road Glen Ellyn, IL 60137 The affidavits of Messrs. Little and Muffett are attached.

3. Is your claim or defense on the contention based on one or more calculations? If so:
a. Describe each calculation and identify any documents setting forth such calculation.

! b. Who performed each calculation?.

c. When was each calculation performed?

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d. Describe each parameter used in such calculation and each value assigned to the parameter, and describe the source of your data,
e. What are the results of each calculation?
f. Explain in detail how each calculation provides a basis for your claim or defense.

NRC Staff Response The Staff's " claim or defense on the contention" is in the process of being formulated by the Staff in consultation with its attorneys. The Staff understands its " claim or defense" to mean the position the Staff will take before the Licensing Board. In some instances, the ~ Staff's position may be based on evaluations of the adequacy of various .

components, systems, or structures. The bases for some of these evaluations may include the results of calculations. To the extent that calculations have been used to support the Staff's position, the results and bases of these calculations are reflected in the applicable inspection reports. These inspection reports have been, or will be, made available to Intervenor.

4. Is your claim or defense on the contention based upon convercations, censultations, correspondence or any other type of communications with one or more individuals? If so:
a. Identify by name and address each such individual.
b. State the educational and professional background of each individual, including occupation and institutional affiliations.
c. Describe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.
d. Describe the information received from such individuals and explain how it provides a basis for the issue.
e. Identify each letter, memorandum tape , note or other record related to each conversation, consultation,

. correspondence, or other communication with such individual.

NRC Staff Response The Staff's " claim or defense on the contention" is in the process of being formulated by the Staff in consultation with its attorneys. It is anticipated that the Staff's positions on the various parts of the contention may be based in part on communications with one or more individuals. To the extent that the communications on which the Staff will rely consist for oral communications, the Staff believes that such communications have been, or will be, memorialized in the relevant inspection report. The Staff further believes that Intervenor already possesses all relevant inspection reports that have been issued. I D. Specific interrogatories

1. In a May 7, 1984, letter to Commonwealth Edison transmitting Inspection Report 83-09, NRC Reglen III Administrator James G.

I;eppler observed that "(A) major factor contributing to the deficiencies were inadequate contractor programs and worknanship, inadequate licensee reviews of the contractor programs, and inadequate licensee quality assurance overview to ensura contractor activities met all requirements." What were the basic, or root causes, or reasons for the occurrence of the inadequacies identified in Mr. Keppler's letter, specifically the inadequate contractor programs and workmanship? The inadequate licensee reviews of the contractor programs? The inadequate licensee quality assurance overview to ensure contractor activities met all requiraments?

NRC Staff Response As indicated in the May 7, 1984 letter cited by Intervenors, the inadequacies identified in Inspection Report 83-09 suggested "the need for more aggressive CECO management involvement in and support of the CECO QA Program to ensure that all safety-related activities performed by

L contractor personnel are in accordance with the regulations, codes, t

l standards and license requirements." The Staff believes the reason that l

l the deficiencies identified in Inspection Report 83-09 were identified is

because the management and organi-ational changes instituted by t

Applicant and its contractors in response to Inspection Report 82-05 had not been fully implemented at the time of the inspection. Nor had Applicant identifed all of the problems that may have occurred prior to the adoption of these changes by the time Staff commenced the inspection activities which culminated in Inspection Report 83-09. Applicant's response to Inspection Report 83-09, also addresses the reasons why the s

identified deficiencies occurred. See Jbly 6, 1984 letter from Louis O.

l l Del George to James G. Keppler.

2. Describe in detail any and all studies, inquiries, investigations j or reviews undertaken to determine the validity of the I

observations of inadequacies made by Mr. Keppler as described in Interrogatory No. I above. Describe in detail any results l and conclusions.

! NRC Sinff Response The statement cited by Intervenora in Specific Interrogatory No.1 is based upon the NRC inspections documented in Inspection Report 83-09.

A copy of that document is, or should be, in Intervenors' possession.

The Applicant's response to Inspection Report 83-09 documents the s tudies ,' inquiries, investigations, or reviews conducted by it to evaluate the validity of Mr. Keppler's statenent and the inspection report l findings. See July S, 1984 letter from Louis O. De! George to James G.

i I eppler.

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3. Describe in detail any and all studies, inquiries, investigations or reviews undertaken to determine the basic or root causes, or

. reasons for the occurrence of the inadequacies identified in Mr.

Keppler's letter as described in Interrogatory No. 1, above.

NRC Staff Response The statements in the letter cited in Specific Interrogatory No. I were prompted by (a) the number of deficiencies and concerns identified

-in Inspection . Report 83-09; (b) the findings reported in various inspection reports, principa'lly Inspection Report 82-05; (c) the Braidwood SALP 2 Report issued March 22, 1984, which rated Braidwood Category 3 in two creas, and required increased management attention by the s

Applicant. The Staff, however, has not initiated any study, inquiry, investigation, or review for the express purpose of determining "the basic cr root causes, or reasons for the occurrence of the inadequacies identified in Mr. Keppler's" May 7,1984 letter.

4. In c February 2, 1983 letter to Commonwealth Edison transmitting Inspection Report 82-05, NRC Region III Administrator James G. Keppler observed that "(T)he results of the inspection indicate serious weaknesses in your management control systems as evidenced by a break:!own in your quality assurance (QA) program as it relates to the installation and installation inspection of mechanical safety-related equipment."

What are the basic, or root causco, or reasons for the " serious weaknesses" and " breakdown of your quality assurance (QA) program" identified by Mr. Keppler?

NRC Staff Response The Staff believes the primary reason for the weaknesses and

. breakdowns identified in Inspection Report 82-05 was the weaknesses in overall management by the Applicant and its contractors in ensuring the implementation of the QA/QC program.

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5. Describe in. detail any and all studies, inquiries, investigations reviews undertaken to determine the validity of the observations

.pf " serious weaknesses" and breakdown" made by Mr. Keppler -

as described in Interrogatory No. 4, above. Describe in detail any results and conclusions.

NEC Staff Response The statement cited in Specific Interrogatory No. 4 is based on the results of NRC inspections reported in Inspection Report 82-05.

Applicant's response to that inspection report describes the actions taken by it to address the validity of this statement and the findings in Inspection Report 82-05. See April 4, 1983 letter from Cordell Reed to James G. Neppler.

s G. Describe in detail any and all studies, inquiries, investigations or reviews undertaken to determine the basic or root causes, or reasons for. the occurrence of the " serious weaknesses" and breakdown" identified by Mr. Keppler as described in Interrogatory No. 4 above.

NFC Ftaff Response The basis 'for the statements referred to by Intervenor were the concerns and deficiencies identified in Inspection Report 82-05. No other studies were or have been undertaken by the Staff. The Applicant's response to Inspecticn Report 82-05 referenced in the Staff's response- to Specific Interrogatories 4 and 5, . supra, describes the efforts undertikcn .

by Applicant to address the c.atter referred to in the statement cited by Intervenor.

7. In the NRC Staff First Response to Intervencr' Second Set of Interrogatories, Novernber 15, 1985, pp. 5-7, in answer to Interrogatory No. 1, regarding contention sub-part 1D, the NRC Staff identifies " measures to strengthen the managerial effort of its contractors," and " extensive commitments to resolve the issues" identified in the second paragraph of sub-part IB,

on the pr.rt of applicant. Please describe in detail these

" measures" and " commitments" explain why they were believed

,to be effective to correct the problems identified by the NRC, and identify and produce any and all documents which reflect your answers including but not limited to the documents identified by the NRC Staff in the answer described above.

NRC Staff Response The measures taken by Applicant to strengthen the managerial effort of its contractors included changes in contractor management personnel, incrected staffing, and increased contractor overview by Applicant. See Applicant's Response to Interrogator" 51 of Intervenors' First Set of Interrogatories. At this time, the Staff believes these nessures have been effective. This belief is based upon the Staff's closure of eight of '

the twelve items in Inspection Report 83-09 that the Staff identified for followup and review (see Staff P.esponse to Interrogatory 2, Intervenor's Second Set of Interrogatories) and the fact that no new significant findings have been identified.

The bases underlying the Staff's ' position that the measures taken to strengthen the managerial effort of the Braidwood contractors have been effective is reflected in the Systematic Assessment of Licensee Performance (SALP) for Braidwood covering the period of January 1,1983 through June 30, 1984 (transmitted by James G. Keppler's letter to Corde!! Reed dated November 6, 1984), and in the Region III Management presentation to the ACRS on February 7,1985 regarding Braidwood. See C. E. Norelius' letter to H. :L. Thompson dated March 5,1985. The NRC SALP report rcflecting the Applicant's and contrac tor's management performance' since June 30, 1984 is being prepared at this time and is scheduled to be issued by February 28, 1986.

The " extensive commitments" undertaken by Applicant to resolve the issues " identified in Inspection Report 83-09 are described in those documents referenced in the Staff's response to Interrogatory No. I of the NRC Staff" First Response to Intervenor's Second Set of Interroga-tories. The bases underlying the Staff's position that these commitments are adequate are reflected in the following: (a) response to Interrogatory 1- Staff's First and Second Response to Intervenor's Second Set of Interrogatories, Subparts 1.B 6.B, 7. A, 10.B. 12.B and 14.B; (b) the SALP for Braidwood covering the period of January 1,1983 through June 30, 1984 (transmitted by James G. Keppler's letter to Cordell Reed dated s

November 6, 1984); and (c) Region III Management Presentation to the ACRS on February 7,1985 regarding Braidwood. The Staff will produce the materials which reltte to the presentation described in (c) above.

8. Describe in detail any and all studies, inquiries, investigations or reviews undertaken , and any results or conclusions, to determine the validity of and the basic, or root cause, or reason for the occurrences described in Inspection Report 82-05 at pages 8 and 9, in particular the " mechanical damage" to the

" steam generator support bolts," the use of " hydraulic torque wrenches, pneumatic operated impact wrenches, a six foot pipe extension handle on hand held wrenches (a so-called "chester bar") to install the bolts, and any identification of or reporting of such occurrences by concerned workers. Please identify any and all documents related to your answers.

NPC Staff Response As part of the review of this issue the NRC has acquired two of the steam generator support bolts mentioned on pages 8 and 9 of Inspection Report 82-05. These bolts have been visually examined by a Metallurgist (J. Jacobson) and a Mechanical Engineer (J. Muffet). Both of the bolts display damage to the Allen head sockets due to excessive force or the L

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use of improper wrenches. The bolts also display marks which appear to be caused by a hammer. The bolt marked L2 C 10 also displays extensive damage to_ the threaded _ portion. The bolt marked LP-4; C; B-2 displays only ninor damage to the threaded portion. The conclusion has been reached that the statements concerning the damage and its cause on pages 8 and 9 of Inspection Report 82-05 are basically valid. The Staff also believes based on inspections that the root cause of this occurrence to be either lack of proper training or lack of sufficient procedural controls.

Discussions have been held between W. S. Little, L. McGregor, and J. W.

Muffet concerning the identification of concerned workers and their s

reporting of this occurrence. We have not been able to determine at this-time the identity of any concerned workers. Mr. L. McGregor did state during the discussion that he believes that he acquired the information

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about the concerned worker report from Commonwealth Edison.

Mr. McGregor discussed this issue beginning on page 55 of his October 25, 1985 deposition.

9. With respect to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set, please provide any supplementation necessary in order to make your answers current and complete. Please identify any an all documents related to such supplementation.

NRC Staff Response The Staff has issued a number of inspection reports since the filing of the Staff's responses to Intervenors' Second Set of Interrogatories.

Those inspections are as follows:

Inspection Report Nos. Inspection Period Date Issued 456/85009; 457/P5009 March 5-November 7,1985 ll/?l/RS

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456/85033; 457/85032 ' August 1-November 30, 1985 12/24/85 456/85037;.457/85036 November 5-8, 1985 11/27/85 456;85038; 457/85037 September 9-October 18, 1985 11/27/85 456/85040; 457/F5039 August 19,22; September 17-19 11/22/85 October 3-4, 16-18, 24, 1985 456/85048; 457/85047 ' October 9-November 5,1985 1/27/86 456/85049 October 2-November 15, 1985 11/26/85

-456/85050;'457/85048 October 16-18, 29,30; 12/27/85 November 5-7,13,14, 1985 456/85051; 457/85049 October 7-11, October 28- 11/20/85 November 1,1983 456/85052; 457/85050 October 21-November 30, 1985 12/5/85 5 456/85053; 457/85031 November 2-30, 1985 12/16/85 456;85054; 457/85052 November 12-December 5,1985 1/27/86 456/85055 December 3-6, 10, 12, 1985 12/27/85

.456/85061; 457/85057 July 8, 9, 11, 25, 26; August 2/3/86 1, 2, 5; September 17, 25, 26; November 18, 19, 21, 26; December 10, 17, 1985; and January 9,1986 ,

Those inspection reports require the following supplementation of the Staff's Reponse to Interrogatory 1 of Intervenors' Second Set of Interrogatories:

Subpart IB - Applicant's piping material control corrective actions has been reviewed by the Staff and thic matter was closed by the Staff in Inspection Report Nos. 50-456/85061 and 50-457/85057.

Subpart IF - This contention is based upon a statement on Page A-4, Appendix A, Fxecutive Summary of the NRC CAT Reports

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Mo. 50-456/84-44;. No. 50-457/84-40 (IR 84-44/40). Since the concern was not identified in the Overall Conclusions of Appendix A or in the Potential Enforcement Actions of Appendix B of the same report, the Applicant was not required to respond to this concern. Although there is no specific regulatory requirement for trending programs, it is a commonly accepted method used to assist in the identification of trends that might result in significant problems. In order to determine whether the concerns identified by the CAT team are identified are indicative of a significant breakdown in quality assurance, the Staff will rely upon inspections performed during the past several years. These inspections did not s

uncover any significant deficiency which could be attributed to the concerns identified in the CAT report. In addition , the Staff is currently evaluating the contractor trending programs.

Subpart 2C -

This part of the contention deals with allegations from several individuals concerning possible harassment and intimidation of L. K. Constock (LKC) electrical QC inspectors. See August 8, 1985 Response to Interrogatory 55 for a summary of each of these e.11egations.

The Staff will rely on its investigatiens of these allegations to resolve the matters rais~ed in Subpart 2C. The actions taken by the Staff to date are summarized below:

Allegation RIII-84-A-0119: As stated in the Staff response to Interrogatory 55, this allegation was closed in Inspection Report No.

50-456/84-34; No. 50-457/84-33. The alleger was furnished with a copy of this report on January 21, 1985. The alleger did not then

and has not since indicated any dissatisfaction with the Staff's resolution of.his complaint. On September 11, 1985, Region III received certain information from the U.S. Department of Labor relating to certain statements purportedly made by the alleger which, in the Staff's view , warranted a reopening of this allegation. On September 13, 1985, the Staff requested additional information from the alleger. As of this ~ writing, however, the alleger has not responded to that request.

Allegation R-III-84-0123 : Inspection Report - No. 50-456/85009; s

No. 50-457/8509 (IR 8509) closed this allegation. This allegation had-27 parts. All parts but one were technical welding. issues with the exception alleging intimidation. Staff investigation into all of these issues did not reveal any instances of intimidation. The alleger had been terminated and had filed a complaint with the U.S. Department of Labor who had initially ruled in his favor. L. K. Comstock appealed the initial decision , however L. K. Comstock and the alleger reached an agreement out of court and a final decision was never issued. The staff is reviewing the initial decision and the hearing transcript to determine if additional action should be taken by the NRC.

Allegation RIII-85-05: This allegation was partially closed in Inspection Report No. 50-456/85044; No. 50-45"/85043. Interviews with QC inspectors did not reveal any instances of harassment or intimidation resulting in inadequate performance of inspections.

4 Additional inspections have been conducted concerning the base metal inspection portion of the allegation. That portion of the allegation was closed in IR 85009.

Allegation RIII-85-0067: This allegation was omitted inadvertently from the Staff's response to Interrogatory 55. This allegation was raised by an LKC QC inspector and has three parts: (1) QC inspector reprimanded for alleged failure to meet production quotas; (2) OC inspectors improperly trained in conduit specifications; and (3) L.K. Comstock's double flare bevel groove weld procedure was s used by welders before it had been properly qualified.

As discusred in Inspection Report No. 50-456/85071; No. 50-45~/85022, regional inspectors could not substantiate parts (1) or (2) of this allegation. Part (3) of the allegation involving welding will be addressed in a future inspection report.

Allegation RIII-PS-A-0068: This allegation was closed by Region III inspectors in Inspection Report No. 50-456/85021; No. 50-457/85022.

No iristance of harassment and intimidation resulting in procedural violations or the acceptance by LKC inspectors of discrepant work was identiffe , .

Allegation Rill-85-A-0072: This allegation, which consists of 17 parts or concerns, was closed in Inspection Report No. 50-456/85021;

' No. 50-457/85022. The report substantiated the claim that one L. K.

Comstock supervisor had engaged in intimidating conduct. This supervisor was terminated by L.K. Comstock as a result of an investigation conducted by the Applicant after the allegers came to the NRC. The staff's investigation did not reveal any instances in which the OC inspectors did not perform their inspections properly as a result of the alleged harassment and intimidation.

Subpart_3A - See NRC Staff First Response to Intervenor's Second Set of Interrogatories, Specific Interrogetory 1, response to subpart IB for the requested information. ,

Subpart 3B - This part of the contention concerns a violation identified in NRC Inspection Report No. 50-456/85015; No. 50-457/85016.. The violation (Region III Tracking Items No. 50-456/85015-01; No. 457/85016-01) was identified by Region III Inspector R. Schulz. The Applicant's response to thin violation is documented in CECO's letter to NRC dated June 21, 1985- from D. L. Farrar to J. G. Keppler. The v,folation involved uncontrolled cutting of holes in webs of safety-related beams. The Staff is relying en its inspections of the corrective actions committed to by the Applicant in the above referenced response. Region III Inspector R. Schulz closed this item in Inspection Report No. 50-45G/85052;-

50-457/85050 (IR 85052/50). Inspector J. Muffett reviewed the design calculations referenced in IR 85052/50. This appeared to be an isolated problem, and all of the affected beams were found to be structurally adequate.

Subpart 3C - This subpart concerns a violation identified in NRC Inspectiort Report No. 50-456/85006; No. 50-457/85006. This violation (Region III Tracking Items No. 50-456/85-06-02; No. 50-457/G5-06-02) was identified by Region III Inspector R. Gardner. The Applicant's response to' this violation is documented in CECO's letter dated May 6, 1985 from D. L. Farrar to J. G. Keppler. In its response the Applicant disagreed that this is- a valid violation . of regulatory requirements. Applicant cgreed, however, to take action to strengthen its program. The Staff is sctisfied with the Applicant's action to strengthen their program. This will be' confirmed in a future inspection report. ,

Subpart 4A - Thie subpart is derived from a violation consisting of three examples or parts . identified in NRC Inspection Report No. 50-456/84-07; No. 50-457/84-07. The item at issue was identified by NRC Inspector W. Kropp who is also responsible for its review and closure. The Applicant's response to this violation is documented in CECO's letter to the NRC ' dated August 20, 1984 from D. L. Farrar to J. G. Keppler.

The first part of this violation (Region III Tracking items No. 456/84-07-02(a); No. 457/84-07-02(a)) was . closed in Inspection Report No. 50-456/84-42; . No. 50-457/84-38. This inspection verified the Applicant's corrective actions described in their response referenced above. The inconsistencies upon which this violation was based is not

. indicative of a significant breakdown in Applicant's quality tsaurance

~ program.

s The second part of this violation (Region III Tracking Items No. 456/8.4-07-02b; No. 457/84-07-02b) was closed in Inspection Report No. 50-456/85-32; No. 50-457/85-31, as was the third part (Region III Tracking Itens No. 456/84-07-02c; No. 457/84-07-02c). The concerns upon which these two parts of the violation were based are not indicative of a significant breakdown in quality assurance.

Subpart 4B - This part of the contention also is derived from Inspection Report 84-07. The Applicant's response is also referenced under subpart 4A. This problem (Region III Tracking Items No. 456/84-07-04; s

No. 457/84-07-04) was identified by and will be resolved by NRC Inspector W. Kropp.

Subpart 5A - This part of the contention is derived from a statement made .on Page A-3 of the CAT Inspection Report (No. 50-45684-44; No. 50-457/84-40). The CAT Team did not regard this problem significant enough to highlight it under those items requiring additional management attention in the Overall Conclusion, (Appendix A), or to include it under the Potential Enforcement Findings, (Appendix B). Therefore, Applicant was not required to respond to this concern. Apparently, the CAT Team considered Applicant's commitment to modify S&L Braidwood Field Instruction (BRFI) 4 adequate to resolve this problem. (See Page VII-12 of the CAT report . Details). Region III will confirm that this field instruction was modified . The Staff does not believe that this one instance identified by CAT evidences a significant breakdown in quality assurance.

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-Subpart SB - This subpart is derived from NRC Inspection Report 85-15.

This violation (Region III Tracking Item No. 456/85015-07; No. 457/85016-06) was identified and was closed by ' NRC Inspector t

W. Kropp in IR 85052/50. The Applicant's corrective actions are described on Page 16 of Inspection Report 85-15. This issue was related to the repair of the coating on a small square footage of the containment surface and was not indicative of a significant problem.

Subpart SC. - This part of the contention concerns a violation identified in Inspection Report No. 50-456/84-43; 50-457/84-39 (Region III Tracking s

Item No. 456/84043-02; 457/84039-02). The Applicant's response to the violation ~, including corrective action, is documented in CECO's letter to the NRC dated April 15, 1985 from D. L. Farrar, Director of Nuclear Licensing, to J. G. Keppler, Regional Administrator. Inspector Muffett reviewed and closed this item in Inspection Report No. 50-456/85040:

50-457/85039 (IR 85040/39). Thic issue involving design requirements for EVAC supports did not result in deficient support designs that would not meet their design requirements.

Subpart 6A - This part of the contention is derived from Inspection Report 82-05. It has been assigned Region III Tracking Item No.

456/82-05-04;- 457/82-05-04. NRC Inspector J. Muffett had the lead responsibility for review and closure of this item. As indicated above, the Staff will rely upon its evaluation of the corrective actions taken ~by Applicant in determining whether the problem identified in this part of

. l the contention has been resolved satisfactorily. - A followup inspection is documenteJi in Inspection Report 50-451/85048 (IR 85050/48).

Subpart 6B - This subpart - relates to Violation 2.a. through 2.e..

identified in NRC Inspection Report 83-09. The Applicant's responses describing their corrective actions are documented in the Staff's

-interrogatory response relating to subpart ID.

Violatior. 2.a. was assigned Region III Tracking Items No. 456/83-09-02( A); No. 457/83-09-02( A) and was identified by ,

R. Schulz who also has the responsibility for review and closeout.

Inspection of this item is in progress. A followup inspection is documented in Inspection Report No. 50-456/85032; No. 50-457/85031.

Violation 2.b. was assigned Region III Tracking Items No. 456/83-09-02(B); No. 457/83-09-02(B). This violation involved the failure to make piping wall thickness measurements during receipt inspection. A supplemental response to this violation was submitted by

.the Applicant's letter dated September 25, 1985 from L. O. DelGeorge to

.'. G . Keppler. This letter also references the 30 day and supplemental reports submitted on this subject as 10 C.F.R. S 50.55(e) No. 84-10. All of these documents describe corrective actions that the Staff (Inspector J. Muffett) inspected to close this issue in IR 85040/39. This violation did not evidence a. significant breakdown in quality assurance, and not result in installed piping not being able to perform its design function.

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Violation 2.c. was assigned -Region III Tracking Items No.- 456/83-09-02(C); No. 457/83-09-02(C). R. Schulz identified - this violat;on and reviewed and closed it in IR 85052/50. This issue did not result in unacceptable - pipe bends and is not indicative of a significant breakdown in quality assurance.

Violation 2.d. was assigned Region III Tracking Items No. 456/83-09-02(D); No. 457/83-09-02(D). R. Schulz identified this violation and documented his review and closure of the iten in Inspection Reports No. 50-456/85032; No. 50-457/85031. The Staff's inspection of s

this item did not produce any evidence which would suggest that a significant breakdown in quality assurance had occurred. .

Violation 2.e. was assigned Region III tracking Items No. 456/83-09-02(E); No. 457/83-09-02(E). R. Schulz identified this violation and P. P_elke reviewed and closed out this item in Inspection Report No. 50-456/85051; No. 50-457/85049. The Staff's inspections of this item do not indicate a significant breakdown in Applicant's quality assurance program has occurred.

Subpart 6C - This subpart concerns a violation noted in Inspection Report No. 50-546/85-07; No. 50-45"/85-07. The Applicant's corrective action is documented in its response dated Afay 3,1985 from D. L. Farrar to J. G. Keppler. The violation (Region III Tracking items No. 456/85-07-08; No. 457/85-07-08) was identified by R. Schulz who also is responsible for review and closecut. A followup inspection was

i-documented in Inspection Report N'.

o 50-456/85032; No. 50-457/85031

'(IR 85-32L31). Inspection of this concern is in progress.

Subpart 6D - This subpart is a violation identified in the NRC inspection report referenced under subpart 6C above. The Applit ant's response is also referenced above. In addition the Applicant documented a supplemental response in the CECO letter dated September 9, 1985 from A. D. Miosi, Nuclear Licensing Administrator to J. G. Keppler. Regional Administrator. R. Schulz identified this problem and is responsible for review and closeout. It is assigned Region III Tracking Items s

No. 456/85-007-02; No. 457/85-007-02.

Subpart 6E - This subpart concerns a violation noted in Inspection Report No. 50-546/84-31; No. 50-547/84-29. The Applicant's corrective action is documented in its letter to NRC dated December 21, 1984 from D. L. Farrar to J. G. Keppler. This item (Region III Tracking Item No. 457/84-29-02) was reviewed and closed by NRC Inspector R. Schulz in Inspection - Report No. 50-456/85007;- No. 50-457/85007. This violation did not evidence a significant breakdown in quality assurance.

Subpart 6F - This subpart concerns a violation noted in NRC Inspection Report No. 50-456/84-21; No. 50-45"/84-20. The Applicant's corrective action is documented in its letter to the NRC dated January 31,1985 from D. L. Farrar to J. G. Heppler. This violation (Region III Tracking Items No. 456/84-21-03; No. 457/84-20-03) was identified by NRC Inspector R. Schulz. Inspector Schulz reviewed the corrective actions and closed

~.

this issue in Inspection Report No. 50-456/85-07; No. 50-457/85-07. This violation did not evidence a significant breakdown in quality assurance.

Subpart 6G - This subpart is a violation identified in Inspection Report No. 50-456/84-17; No. 50-457/84-17 (IR 84-17). The Applicant's corrective action is documented by CECO's letter dated Novertber 28, 1984

.from D. L. Farrar to J. G. Keppler. Inspector R. Schulz identified this item (Region III Tracking Items No. 456/84-17-01; No. 457/84-17-01) and closed it in Inspection Report No. 50-456/84-42; No. 50-457/84-38. The effect that chemical cleaning of the corroded pipe had on the pipe wall s

thickness is. being addressed by the corrective actions documented in the Applicant's 10 C.F.R. S 50.55(e) Report No. 84-10 submitted to the NRC on July 20, 1984.

Interim reports on the above S 50.55(e) report were submitted to the NRC on September 18, 1984; November 2, 1984; December 12, 1984; Februcry 27, 1985; and May 2, 1985. The final report, "Braidwood Station - Units 1 and 2 Engineering Evaluation of the Pipe Corrosion Problem identified in CECO IICR No. 633," January 1986 is being reviewed by Inspector J. Muffett who is responsible for review and closecut.

Subpart 6H - This subpart is a violation identified in Inspection Report No. 50-456/84-09; No. 50-457/84-09 (IR 84-09). The Applicant's corrective action is described in CECO's letter from D. L. Farrar to J. G.

Keppler dated July 31, 1984; October 22, 1984; November 7 1984; and February 13, 1985. This item (Region III Tracking Items

e C

No. 456/84-09-01: No. 457/84-09-01) was identified by R. Schulz and-review and followup responsibility has been assigned to J. hfuffett.

Subpart GI - This subpart is a violation identified in IR 84-09 by R. Schulz. The Applicant's responses are referenced under subpart 6H.

Mr. Schulz . reviewed and closed this item (Region III Tracking Items No. 456/84009-05; No. 457/84009-05) in Inspection Report No. 456/85-15; 457/85-16. The event did not evidence a significant breakdown in quality assurance.

s Subpart 7A - This subpart is a violation identified in IR 83-09 by R. Schulz. This issue (Region III Tracking Items No. 456/83-09-01:

No. 457/83-09-01) is part of the small bore piping issues addressed in the Applicant's responses referenced under Subpart 1B of the S taff's First Response to Intervenors Second Set of Interrogatories. Inspector J. Muffett is assigned review and closecut responsibilities for this item.

Subpart 8B - This subpart is a violation identified in IR 84-44/40. This iten (Region III Tracking Items No. 456/84-44-03; No. 457/84-44-03) was identified by CAT- and became a violation in the Notice of Violation (NOV) documented in NR C's letter dated April II, 1985 to CECO from C. E. Norelius to Cordell Reed. The Applicant's corrective action is documented in its letter to NRC dated May 16,198F from D. L. Farrar to J. G. Keppler. Inspector R. Mendez is responsible for the review and closure of this item.

r _

Subpart 8C -

This is a violation identified in IR 84-44/40. This item (Region II.! Tracking Items No. 456/84-44-04; No. 457/84-40-04) was identified by CAT and became a violation in the NOV referenced under Subpart 8B. The Applicant's corrective action is referenced under Subpart 8B. Inspector W. Kropp is assigned to review and followup this item. A fellowup inspection is documented in IR 85-32/31.

Subpart 8D, 8E, 8F - This is a violation consisting of three examples identified in Inspection Reports No. 50-456/85-08; No. 50-457/85-08. The Appliccut's corrective action is documented in CECO's letter to NRC dated s May 15, 1985 fror. D. L. Farrar to J. G. Keppler. Inspector D. Williams identificd and is responsible for review and closure of this item (Region III Tracking Items No. 456/85-08, 10a, -10b and -10c).

Inspection of .these items is in progress. A followup inspection is documented in Inspection Report No. 50-456/85045 (IR 85045).

Subpart 9A - This subpart is a violation with . two examples identified in Inspection Report No. 50-456/84-21; No. 50-457/84-20 (IR 84-21/20).

The Applicant's corrective action is documented in CECO's letter to the NRC dated January 31, 1985 from D. L. Farrar to J. G. Keppler. These items (Region III Tracking items No. 456/84-21-01: No. 457/84-20-01; No. 456/84-21-02; No. 457/84-20-02) have been assigned to NRC Inspector J. Jacobson for review and closure. Item No. 456/84-21-01:

No. 457/84-20-01 was closed out in Inspection Report No. 50-456/85040;

'No. 50-457/85039. This item did. not evidence a significant breakdown in quality assurance. The second item is not ready for closure.

Subpart 9B -

This subpart is a violation identified in IR 84-21/20 The Applicant's corrective action is documente'd under Subpart 9A. Inspector J. Muffett has been assigned responsibility for review and closure of this iten (Region III Tracking Items No. 456/84-21-08: No. 457/84-20-08).

Subpart DC - This subpart is a violation identified in Inspection Report No. 50-456/84-13; No. 50-457/84-13 by R. Schulz. The Applicant's ,

- corrective action is described in CECO's letter to NRC -dated September 21, 1984 from D. L. Farrar to .'. G. Keppler. Inspector K. Ward reviewed and closed out this violation in Inspection Report No. 50-456/85-05: No. 50-457/85-05. This violation did not evidence a significant' breakdown in quality assurance and did not result in deficient welds.

Subpart DD - This subpart is a violation consisting of two examples identified in IR 84-17. The corrective action is documented in IR F4-17 and no response was required. Inspector K. Ward closed these items in Inspection Report No. 50-456/84-40; No. 50-457/84-37 (Region III tracking Items No. 456/84-17-06: No. 457/84-17-06; No. 456/84-17-08:

No. 457/84-17-08). These violations did not evidence a significant breakdown in quality assurance. or in a component being incapable of performing its intended purpose.

Subpart 9E - This subpart is a violation identified in Inspection Report No. 50-456/84-08; No. 50-4576/84-08. The Applicant's corrective action is documented in CECO's letter to the NRC dated June 21, 1984 from D. L. Farrar to J. G. Keppler. Inspector K. Ward reviewed and closed this . violation in Inspection Report No. 50-456/85-05; No. 50-457/85-05.

The Staff's inspection did not reveal evidence of a significant breakdown in quality assurance. The lack of a specific requirement documenting weld fit-up verification did not appear to have resulted in unacceptable welds.

s Subpart 10D - The subpart is an unresolved item (Region III Tracking Items No. 456/83-09-04( A); No. 457/83-09-04( A) and No. 456/83-09-04(D);

No. 457/83-09-04(B)) identified in IR 83-09. This part of the contention consists mninly of quotations from the NRC letter transmitting IR 83-09 to the Applicant. All of the related documentation is referenced in the respense to Specific Interrogatory 1, Subpart 1B, NRC Staff First Response to Intervenor's Second Set of Interrogatories. This unresolved item was identified by NRC Inspector R. Schulz. NRC Inspector J. Muffett is rcsponsible for review and closure. To resolve this issue the Applicant committed to carry out the Material Traceability Verification Progran (MTVP). The final report of the MTVP has been issued and was transmitted to the Staff by letter dated November 20, 1985 from L. O. Dc! George to J. C. Keppler. Staff followup inspection of the MT1'P are documented in inspection Reports No. 50-456/84-09; No. 50-45"/84-09:

No. 50-456/84-21; No. 50-457/84-20: No. 50-456/84-31; No. 50-457/84-29:

No. 50-456/84-34; No. 50-457/84-32: No. 50-456/84-42; No. 50-457/84-38:

No. 50-456/85007; No. 50-457/85007: No. 50-456/8515; No. 50-457/85016:

No. 50-456/85043; No. 50-457/85042. This issue was closed in Inspection Report No. 50-456/85061; 50-457/85057. The MTVP results indicate that no materials were installed that would not perform their intended safety function.

~

Subparts IOC,10D, and 10E - This contention is a violation consisting of three parts identified in the CAT (IR 84-44/10). The Applicant's corrective action is documented in the letter referenced in subpart 8B.

s Subpart IOC (Region  !!!' Tracking Items No. 456/84-44-05; No. 457/84-40-05) has been assigned to Inspector P. Kaufman for review and closttre. Subpart 10D (Region III Tracking Items No. 456/84-44-06; No. 457/84-40-06) is the same as Subpart ID. See the NRC Staff First Response to Intervenor's Second Set of Interrogatories for the response to subpart ID. Subpart 10E (Region III Tracking Items No. 456/84-4407; Fo. 457/84-40-07) has been assigned to P. Kaufman for review and closecut.

Subpart 10F - This subpart is a violation identified in IR 85-15/16. The Applicant's corrective action is documented in the June 21, 1905 letter referenced under subpart 3H. Inspector 11. Kropp closed this item (Region III Tracking Item No. 456/85018-18) in Inspection Report No. 85-32/31. This violation appeared to be an isolated incident which did not evidence a significant breakdown in quality assurance.

Subpart 11B - This contention is a violation identified in Inspection

' Report No. . 50-456/84-39; No. 50-457/84-36. Inspector P. Pelke identified this item (Region III Tracking Item No. 457/84-36-01) and is responsible

. for its review and closure. The Applicant was not required to respond to the violation as the inspector was satisfied with the corrective action

-taken prior to the completion of the inspection. Additional followup by the Stcff in this area will be conducted when NRC Bulletin 82-04 is closed for Braidwcod Unit 2.

Subpart 11C - This contention is a violation identified in Inspection s Report No. 84-17. The licensee's corrective actions arc included in the documents referenced under subpart 6G. The violation (Region III Tracking Item No. 456/84-17-02; No. 457/84-17-02) and has been assilened to J. Muffett for review and closecut.

Subpart 11D - This contention is a violation identified in Inspection Report No. 84-0" by Inspector W. Kropp (Region !!! Tracking Itens No. 456/84-07-05: No. 457/84-07-05). Mr. Eropp is responsible for review and closcout of the Applicant's corrective actions documented in CECO's letter dated August 20, 1984 referenced under subpart 4A. This violation was closed in Inspection Report No. 85-32/31, and did not evidence a significant breakdown in quality assurance.

Subpart 12A - This part of the contention ic similar to Subpart 1A and is tracked as Tracking Item No. 456/82-05-D1: 457/82-05-01. NRC Inspector Muffett is responsible for the review and closure of this item. As

' indicated above, the Staff will rely upon its evaluation of the corrective actions taken by . Applicant in determining whether the ' problem identified in this part of the contention has been resolved satisfactorily. Inspection Report 50-456/85052; 50-451/85050 (IR 85052/50) documents the removal and reinstallation of all of the steam generator support bolts using bolts of the correct material.

Subpart 12B - This contention is Violation 1.a. ,1.b.. and 1.c. identified in the Inspection Report No. 83-09 Notice of Violation. NRC Inspector R. Schulz identified this violation. The Applicant's corrective actions are s

in documente referenced in Subpart 18 Specific Interrogatory 1, NRC First Response to Intervenor's Second Set of Interrogatories.

Violation 1.a. (Region III Tracking Items No. 456/83-09-07( A):

J No. 457/83-09-07( A)) has been assigned to NRC Inspector J. Muffett for 1

i review and closeout.

Violation 1.b. (Region III Tracking items No. 456/83-09-07(D):

No. 457/83-09-07(B)) has been assigned to NRC Inspector J. Jacobson for review r.nd closecut.

Violation 1.c. (Region 111 Tracking items No. 456/83-09-07(B):

l-No. 457/83-09-07(D)) has been assigned to NRC Inspector J. Jacobson for review and closecut.

I

4 Subpe.rt 12C - This subpart is a violation identified in Inspection Report

.No. 85-15/16 (Region !!! Tracking item No. 456/85015-06). The Applicant's ' corrective action is documented in the June 21, 1985 letter referenced under Subpart 3B. A followup inspection is documented in Inspection Report No. 85-32/31.

Subpart 12D - This subpart is Violation 4.a. and 4.b. identified in the Notice of Violation of Inspection Report No. 84-44/10. These items (Region !!! Tracking items No. 456/84-44-08; No. 457/84-40-08; and No. 45E/64-44-09; No. 457/84-40-09) were identified by CAT and are assigned to NRC Inspector p. Kaufman for review and closeout. The Applicant's corrective action is referenced under subpart 8B.

Subpart 12E - This subpart is Violation 2.a. Identified in inspection Report No. 85-06/06. This violation has been withdrawn. See June 27, 1985 letter fror: C. E. Norelius to Cordell Reed.

Subpart 12F - This subpart is a violation identified in Inspection Report No. 50-456/85006; No. 50-457/85006. The Applicant's corrective actions are documented in CECO's letter to NRC dated May 6, 1985 from D. I,. Farrar to J. G. Keppler. and in NR C's letter to CECO dated June 27, 1985 from C. E. Norelius to Cordell Reed. NRC Inspector R. Gardner is responsible for review and closecut of this item (Region !!!

Tracking items No. 50-456/85006-01(B); No. 457/85006-01(D)).

J

.- 3 ,

Subpart 12G - This subpart is a violation identified in Inspection' Report No. 50-454/84-21; No. 50-451/84-20. The Applicant's corrective action la described in Ceco letters to NRC from D. L. Farrar to J. G. Keppler ,

~

dated January 31, 1985, Februar;* 27 1985, April 4.1985, and April 16 1985. The Staff conducted a followup inspection documented in Inspection Report No. 50-456/85-11; No. 50-457/85-11. NRC Inspector T. Tongue has been assigned responsibility for final review and closecut of this item (Region !!! Tracking items No. 456/84-21-07; No. 457/84-20-07).  :

. Subpart 1211 - This subpart is a violation identified in Inspection' Report g l No. 84-07 (Region !!! Tracking items No. 456/84-07-06; i

No. 457/84-07-06). Mr. Kropp is responsible for review and closeout of r the App!! cant's corrective action documented in CECO'n !ctter dated f

August 20, 1084 referenced under subpart 4A.

Subpart 121 -

This subpart is a violation identified in IR 84-08 (Reglen !!! Tracking items No. 50-456/84-08-02; No. 50-457/84-08-02).

The Applicant's corrective action is documented in CFCo's letters to the l NRC from D. t.. Farrar to J. O. Koppler dated June 21, 1984; September 12, 1984 and December 13, 1984. NRC Inspector J. Jacobson .

In responsible for review and closeout of this item.

Subpart 12J - This subpart is a concern stated by the CAT in the last i paragraph, Overall Conclusions, Appendix A, IR 84-44/40. The Applicant was not required to respond to this concern in writing. IR 85-02, Report Details. Page 7 documents steps taken by the Applicant to resolve this m---y.-~ ,rw wwww,w,e--+-w+- _ . - e- e _---m-e-

t concern (Region !!! Tracking items No. 50-456/84-02-03; No. 457/84-02-03). This issue is addressed in internal NP.C memoranda dated Liarch 1, 1985 and April 12, 1985 from C. E. Norelius, Director, Division of Reactor Projects to J. G. Keppler, Regional Administrator which are attached to IR 85-0G and IR 85-18 respectively. NRC Inspector R. Gardner is responsible for review and closcout of this item. Followup inspections, are documented in Inspection Reports No. 50-456/85002; 50-457/85002 50-456/85006; 50-457/85006: 50-456/85018; 50-457/85019.

Srbpart 13_D - This subpart is a violation identified in Inspection Report 5 No. 50-456/84-43; No. 50-457/84-39 (Region !!! Tracking items No. 456/84-43-01: No. 45 7/84-39-01). The Applicant's corrective action is documented in the following CECO's letters to the NRC:

October 22, 1984 lettor from L. O. DelGeorge to J. G. Keppler December 11, 1964 letter from T. R. Tram to J. G. Keppler April 22,1985 letter from T. R. Tram to J. G. Keppler NRC Inspector J. Muffett reviewed and closed this violation in IR 85-40/30. This violation did not evidence a significant breakdown in quality assurance.

Subpart 14B - This contention is Violation 4.a. through 4.d. In IR 83-09. -

(Region !!! Tracking items No. 456/83-00-08( A), (II), (C), (D);

No. 457/83-09-08( A), (B), (C), (D)). The Applicant's documento describing their corrective action are referenced in subpart 18,

?

l c i

?  !

l Interrogatory 1. NRC Staff First Response to Intervenors Second Set of Interrogaleries.

r Violation 4.a. wks identified by NRC Inspector R. Schultz. A followup

! inspection is documented in IR 85-32/31. The issue was closed sa documented .in in 85052/50. The violation did not evidence a significant breakdown in quality assurance.

l

. Violation 4.b. was identified by NRC Inspectors T. Vandel and P. Pelke is assigned responsibility for review and closecut. Inspection Report s No. 50-456/85051; No. 50-457/85049 closed this item. The violation did not evidence a significant breakdoun in quality assuranen.

Violation 4.c. was identified by NRC Inspector R. Schulz. ., A followup Inspection in documented in IR 85-32/31. The issue was closed as documented in IR 85052/50. The violation did not evidence a significant breakdown in quality assurance.

Violation 4.d. was identified by NRC Inspector I. Yin and is assigned to NRC Irispector J. Muffett for review and closeout.

, 12. Described every oral or written communication which efficers and directors and managers of Commonwealth Edison Company (including but expre, soly not limited to Chairtaan James 0"Connor and Quality Assurance Manager Walter Shewski) have had which refer or relate to each or any subpart of the Intervenors' quality assurance contention, the underlying NRC findings or observations, or the quality assurance program at or for the Braidwood nuclear station.

As to each oral communication state:

I

i i

o

a. the date;
b. whether the communication was on the telephone or in l person;

! c. the subject matter of the communication; and l d. the identity of all persons participating therein.

As to each written communication or memorandum or document I

reflecting an oral communication state:

l- a. the date;

b. the author and addressee;
c. the subject matter;
d. the length in pages;
  • s l c. the location and custodian.

Please make available any such written communication or memorandum of oral communication for inspection and copying.

You may exclude all such communications to or from Intervenors' counsel or in which Intervenors' counsel have participated.

NRC Staff Response

?.fany of the subcontentions comprising Intervenors' Amended Quality Assurance Contention are drawn directly from NRC Staff inspection reports. Therefore not surprisingly, the Staff has received correspondence from Applicant relating to some or all of the subcontentions. All such correspondence received by the Staff is already in the possession of Intervenors or is available in the NRC Public Document Room.

, ga2asiv UtilTED STATES

f. '., AJCLEAR REGilLATORY COMMISSION

$ S REGION lit j

3 t no noosevett mono g g cou. sotyn. itu=ois ..i n

-- NUCLEAR REGULATORY COP 911SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)>

COMMONWEALTH EDISON COMPANY l Docket No. 50-456 h 50-457 (Braidwood Nuclear Power Station I Units 1 and 2 AFFIDAVIT OF WILLIAM S. LITTLE I, William S. Little, being first duly sworn do depose and state:

1. I am e.nployed as the Director, Braidwood Project, in the Division 5 of Reactor Projects. U. S. Nuclear Regulatory Consnission, Region III, 799 Ro3sevelt Road, Glen Ellyn, Illinois, 60137.
2. I have provided the answers to General Interrogatories 1, 3 and 4 and specific Interrogatories 1 through 7 and 9 of the Rorem Quality Assurance Interrogatories Third Set. These answers are true and correct to the best of my knowledge, information, and belief.

William 5. Little Swornto4'ndsubscribjd,beforeme this 8- dayof.4tSua.,1985 C L_; .n,:A &: A ue- ~

Notary Public My Connission Expires MIComamiotEr;imNat.27,1533 l.t

. . vaarse erana

/p.'e aa.g\ NUCLEAR REoULATORY COnemestON r.

j nacion in too mooseveLy none

  • ettes stovm.ittinois eesar g
  1. MUCLEAR REGULATORY COIMISSION BEFORE THE ATOMIC SAFETY AND L_ICENSING 90ARD In the Matter of )

COMMOMWEALTH EDISON COMPANY Docket No. 50-456 50-457 (Braidwood Nuclear Power Station Units I and 2 AFFIDAVIT OF JAMES W. MUFFETT I, James W. Muffett, being first duly sworn do depose and state:

1. I am employed as a Reactor Inspector. in the Materials and Processes Caetion. Engineering Branch Divicion of Resotse Safety, Reginn 111. U. S. Nuclear Regulatory Coussission, 799 Roosevelt Road, Glen Ellyn, Illinois. 6013/.
2. I have provided the answers to Interrogatory 8 of the Rorem Quality Assurance Interrogatories. Third Set. This answer is true and correct to the best of my knowledge, information, and belief.

%0 h

James W. Ruffett Sworn tp and subscribe before me Qs/ /,6 day of

) La w x1.

)985 1 t L' Motary PubFic My Comission Expires .a //, /M

31 i

l ***S%tetg 00LMEIE0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

~

BEFORE T}iE ATOMIC SAFETY AND LICENSING BOARD FFICL v n n.

In the Matter of ) BNkc

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood ' Station, Units 1 and 2 )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF OBJECTIONS TO INTERVENORS' THIRD SET OF INTERROGATORIES AND REQUEST TO PRODUCE" and "NRC STAFF RESPONSE TO INTERVENORS' TIIIRD SET OF INTERROGATOPIES AND REQUFST TO PRODUCE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 7th day of February, 1986:

Herbert Grossman, Esq., Chairman

  • Commonwealth Edison Company Administrative Judge ATTN: Cordell Reed Atomic Safety and Licensing Board Assistant Vice President U.S. Nuclear Regulatory Commission P.O. Box 767 Washington, DC 20555 Chicago, IL 60690 Dr. A. Dixon Callihan Region III Administrative Judge U.S. Nuclear Regulatory Commission 102 Oak Lane Office of Inspection & Enforcement Oak Ridge, TN 37830 799 Roosevelt Road Glen Ellyn, IL 60137 Dr. Richard F. Cole Joseph Gallo, Esq.

Administrative Judge Isham, Lincoln a Beale Atomic Safety and Licensing Board Suite 840 U.S. Nuclear Regulatory Commission 1120 Connecticut Avenue, N.W.

Washington, DC 20555 Washington, DC 20036 Michael I. Miller, Esq.

Elena Z. Kezelis, Eby.

Isham, Lincoln a Beale Three First National Plaza Suite 5200 Chicago, IL 60602

\

, -.2 -

Douglass W. Cassel, Jr., Esq. Atomic Safety and Licensing Board Timothy Wright, Esq. Panel

  • Robert Guild, Esq. U.S. Nuclear Regulatory Commission 109 North

Dearborn Street Washington,

DC 20555 Suite 1300 Chicago, IL 60602 Atomic Safety and Licensing Appeal Erie Jones, Director Board Panel

  • Illinois Emergency Services U.S. Nuclear Regulatory Commission and Disaster Agency Washington, DC 20555 110 East Adams Springfield, IL 62705 Docketing and Service Section*

Office of the Secretary Lorraine Creek U.S. Nuclear Regulatory Commission Route 1, Box 182 Washington, DC 20555 Manteno, IL 60950 Ms. Bridget Little Roren H. Joneph Flynn, Esq. 117 North Linden Street Associate General Counsel Essex, IL 60935 FEMA 500 C Street, S.W., Suite 480 George L. Edgar Esq.

Washington, DC 20472 Newman & Holtzinger, P.C.

1615 L Street, N.W.

Suite 1000 Washington, DC 20036 D e O7ft'Q't (, btT Stuart A. Treby /

Counsel for NRC Staff

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