ML20093G139

Answers to Third Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20093G139
Person / Time
Site:	Byron
Issue date:	07/19/1984
From:	Becker B COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	JOINT INTERVENORS - BYRON
References
OL, NUDOCS 8407230337
Download: ML20093G139 (5)

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a REUgED CCaaESPONDUKA UNITED STATES OF AMERICA 00p c . _ '

NUCLEAR REGULATORY COMMISSION Ldi,ij!

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '04 JUL 23

?!? :15 In the Matter of: ) 7c -

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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 'O li?

) 50-455 C) [,

(byron Nuclear Station, )

Units 1 and 2) )

COMMC3 WEALTH EDISON COMPANY'S ANSWERS TO INTERVENORS' THIRD SET OF INTERROGATORIES Interrogatory No. 1: Were documents prepared or reviewed by or for Commonwealth Edison, or its agents, contractors or consultants, relating to the methodology and/or validity of the methodology, used to select inspectors and inspections included in the Byron reinspection program?

If so, please provide such documents. This request includes any review of methodology used in the Byron reinspection.

Answer: The documents responsive to this inter-rogatory encompass those in which the chronological listing of inspectors for selection for the Reinspection Program and the determination of those inspections within the Program was described and/or implemented. These materials include Edison's February 22, 1983, letter to the NRC Staff in which the Program was delineated, various internal memoranda generated at Byron pursuant to implementation of the Program, and the Reinspection Program itself. In addition, some of Edison's consultants have commented upon the methodology utilized in the Reinspection Program as part of their over-all comments. Except for those consultants' comments which have been withheld from production pursuant to Edison's work 8407230337 840719 PDR ADOCK 05000454 0 PDR i

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4 product privilege, all other materials responsive to this interrogatory have already been produced to Intervenors.

Edison is not in possession of any non-privileged documents which analyze or evaluate the methodology utilized to select inspectors and inspections included in the Rein-spection Program which have not previously been produced to Intervenors.

Interrogatory No. 2: Please state whether applicants possess recordings, including worksheets, which document or analyze the type, date, and findings of inspections performed by inspectors whose work was subject to 100 percent ainspection in the Byron reinspection program. If so, please provide such records. Included in this request are records of both original inspectors and reinspectors.

Answer: All records of both inspectors and reinspectors responsive to this interrogatory have already been made available to Intervenors. Specifically, the materials produced in response to Intervenors' Interrogatories 11 and 12 and Request to Produce 37 (Intervenors ' first sets of interrogatories and request to produce), plus the comparable materials produced for Pittsburgh Testing Laboratory, en-compass the documents requested in the interrogatory.

COMMONWEALTH EDISON COMPANY By: d Bruce D. Becker One of Its Attorneys Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500

CERTIFICATE OF~ SERVICE

'The undersigned,.one of the attorneys for Common-wealth Edison Company, certifies that"on this date he filed two copies (plus the original), of the attached pleading with the Secretary of the Nuclear Regulatory Commission and a

served a copy of'the same on each of the persons at the.

addresses shown on the attached service list.in'the manner indicated.

Date: L

/ i0 /YEf

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'CIvan W. Smith,-Chairman Ms. Diane Chavez Administrative Judge SAFE Atomic Safety and Licensing Board 528 Gregory Street

'U.S._ Nuclear' Regulatory Commission Rockford, Illinois 61108 Room 428, East West / West Towers 4350 East West Highway-Bethesda', Maryland 20814 Dr. A. Dixon Callihan Dr. Bruce von Zellen

. Administrative Judge Department of Biological Sciences Union Carbide Corporation Northern Illinois University P.O. Box Y DeKalb, Illinois 60115 Oak Ridge, Tennessee 37830 Dr. Richard F. Cole **Mr. Doug Cassel Administrative Judge BPI Atomic Safety and Licensing Board 109 North Dearborn Street U.S. Nuclear Regulatory Commission Suite 1300 Washington, D. C. 20555 Chicago, Illinois 60602 a

• • Region III U.S. Nuclear Regulatory Commission Ms. Patricia Morrison Office of Incpection of Enforcement 5568 Thunderidge Drive Rockford, Illinois 61107 799 Roosevelt Road Glen Ellyn, Illinois 60137 Ms.. Betty Johnson *Mr. Stephen-Lewis 1907 Stratford Lane Office of the-Executive Legal-Rockford, Illinois 61107  !

Director j U.S. Nuclear Regulatory Commission I

.7735 Old Georgetown Road .;

Room 9604' '

Bethesda, Maryland 20814 N,

-Jogeph Gallo,._ Esq., ,

Dr. Reginald L. Gotchy 1:

IEham,-Lincoln & Beale' Administrative Judge

' Suite 840' Atomic Safety and Licensing 1120 Connecticut Avenue, NW Appeal Board

' Washington, D. C. 20036 U.S.~ Nuclear Regulatory Commission 4350 East West Highway 3rd Floor - call 492-7663 Bethesda, Maryland 20814

, Atomic Safety and Licensing Alan S. Rosenthal, Chairman

-Board Panel Atomic Safety and Licensing

'U.S. Nuclear Regulatory' Commission Appeal Board Washington, D. C. 20555 U.S. Nuclear Regulatory Commission 4350 East West Highway 3rd Floor - call 492-7663 Bethesda, Maryland 20814 i

Atomic Safety and. Licensing

• service by Federal Express

Appeal Board Panel fU.S. _ Nuclear Regulatory Commission Washington, D. C. 20555 ** service by Messenger i

Docketing'&' Service Section Office.of the Secretary.

U.S. Nuclear. Regulatory Commission i Washingten,LD. C. 20555 t

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~ Howard A. Wilbur-Administrative Judge Atomic Safety & Licensing Board

-U.S. Nuclear Regulatory Commission

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Washington, D. C. 20555 1

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