ML20023A852
| ML20023A852 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/11/1982 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20023A846 | List: |
| References | |
| NUDOCS 8210200083 | |
| Download: ML20023A852 (45) | |
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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
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In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.
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(Shoreham Nuclear Power Station, )
Unit 1) )
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SUFFOLK COUNTY RESPONSE TO PORTIONS OF LILCO'S MOTION FOR FURTHER BOARD DIRECTION ON THE CONDUCT OF QA CROSS-EXAMINATION By telephone notification on October 8, 1982, this Board directed Suffolk County to respond in writing by 9 :00 a.m. on October 12, 1982 to LILCO requests for relief numbered 1 and 3 contained at pages 14-16 of "LILCO's Motion for Further Board Direction on the Conduct of QA Cross-Examination," dated October 5,19 82. The two LILCO requests are:
- 1. The Board should prohibit the County from using any of the newly designated material contained in the County's September 30 and October 1 letters. This includes all of the LILCO OA Division audits, Courter audits and LILCO Field QA audits designated in the document control area, and all of the LILCO Fiell QA audits and Quarterly Reports in the storage / housekeeping area. This prohibition, of course, would be subject to the flexibility the Board has pre-viously indicated is appropriate; unexpected developments in cross-examination could warrant the use of a particular audit for a limited, specific purpose. See, e.g., Tr. 10,880.
(LILCO Motion, pp. 14-15) .
- 3. The Board should place a two week limit on the remainder of the County's cross-examination of the LILCO panel. No more than one week of the examination should involve Mr. Museler or Mr. Youngling. (LILCO Motion, p. 16).
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- ' The County opposes LILCO's requests . The materials designa-j_
ted for .use by the County are relevant and, indeed, LILCO P ere argues that these materials are not relevant. The proposed use
' of these materials resi ?.ts from the increasing focus of this pro-caeding on actual occurrences of alleged .QA breakdowns.-- a focus
. which did not become apparent until the hearing commenced. Under these circumstances, and given the steps taken by the County to ensure that the resumed hearing is streamlined, the Board should deny LILCO's. requests.
f I. LILCO REQUEST TO BAR USE' OF NEWLY-DESIGNATED AUDITS.
J Suffolk County has already set forth its basic position I
regarding whether it should be barred from using audits beyond the EA and FOC audits when it pursues the Storage / Housekeeping and Document Control pattern examinations. This position is set i forth in an October 6,1982 letter from the undersigned to j v. Mr. Earley. That October 6 letter is attached hereto. To avoid l needless repetition, its details will not be repeated. However, 1
certain points pertinent to LILCO's requests for relief are emphasized: -
- 1. The County agrees that prior to September 14 it did not designate for use the LILCO Field Audits, QA Division Audits or i Courter audits. Rather, the County intended to pursue cross-examination focused more closely on the LILCO prefiled testimony; i the '" pattern"_ examination was to focus on EA and FQC audits. !
I Contrary to LILCO's assertions , the County prepared diligently i for cross-examination during the weeks prior to September 14.
4 The fact that particular audits were not designated for use i
only is indicative of the then intended focus of the County's ;
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examination and does not indicate that the County's counsel l failed to utilize. those weeks in an effort to focus and streamline QA/QC examination.
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- 2. On September 15, the Board made comments which: (a) caused the County to cease examination on the LILCO testimony and immediately to pursue the " pattern" examination; and (b) caused the County to begin to reconsider the documents it intended to use in the pattern examination. Tr. 10,259-61.
o Indeed, as the County understood the Board's September 15 comments, the Board made' clear that it wanted the examination to concentrate on actual occurrences of alleged QA breakdowns. The County had not previously appreciated the focus of the Board's interest in-this regard. However, after recess during the remainder of September 15, the County departed from its intended examination and immediately commenced examination pertaining to alleged calcula-t tion problems.
- 3. On September 16, the undersigned did state in response to a Board inquiry that the County did not intend to use other large sets of documents like the EA and FQC audits comprising SC Exhibits 51 and 56. That was a truthful statement, made on the first morning of the " pattern" examination. As that examina-tion proceeded, however, counsel re-examined this position, in l view of the focus of the hearing on the " nitty-gritty. " This reappraisal started during the first two weeks of the hearing, as illustrated by the County's use of LILCO Field Audits during its E&DCR examination.
- 4. The Board directed the County by October 1, 1982 to designate the audits and particular findings to be utilized in 1
the remainder of its " pattern" examination. In preparing to-
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comply with the Board's direction, counsel and experts during the first recess week reappraised the QA/QC examination which had occurred during the first two weeks of the QA/QC hearing and decided to make the pattern inquiry the major focus of the entire examination (with the exception of the Operating QA area which naturally is more prospective in nature) .-1/ Accordingly, on September 30 and October 1, the County designated additional audits for use. These designations were accompanied by state-ments that the County would pursue c.ethods to streamline the examination the following week and also that the number of audits to be used in the document control area would likely be reduced.
- 5. Following up on its statements on September 30 and October 1, the County has taken steps to streamline the examina-tion process and to reduce any difficulties caused by designation of additional audits for use. These steps include:
(a) In an October 6, 1982 letter to LILCO (that letter is attached hereto), the County provided LILCO with summaries of the storage / housekeeping audit findings which the County had designa-ted for use. These summaries advise LILCO, in advance, of the precise portion of each audit upon which the County intends to focus. This October 6 letter also provided details regarding the ;
1 County's pattern theory regarding each storage / housekeeping group.
See letter, pp 7-9.
-1/ The County is not abandoning its cross plan on the prefiled l testimony in favor of solely a pattern inquiry, but expects that the pattern examination will substantially reduce the time required to be spent on the actual testimony. The l County understands that this was the Board's intention on September 15 when it requested the County to proceed directly to its pattern examination and to return to the prefiled testimony after the " pattern" examination only to address important points.
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(b) In the October 6 letter, the County also advised LILCO that it had decided not to use many of the audit findings in the document control area to which LILCO had objected. See October 6 letter, pp. 9-10 and attachment. As a result, more than half of the document control audit findings to which LILCO objected were deleted.-2/
(c) By letter dated October 7, 1982, the County sent LILCO audit summaries of the non-FQC, non-EA audit findings it intended to use in the dqcument control area.~3/ In that same October 7 letter, the County further reduced the number of audit findings in the document control area it intended to use.
(d) On Octodar 8, the County sent LILCO a detailed ~ proposal for expediting examination in the FSAR configuration area.
(e) Pursuant to the Board's direction, the County has filed a detailed breakdown of its position regarding patterns of QA )
l breakdowns in the storage / housekeeping, document control, FSAR l 2/ The County did not delete any of the LILCO Field Audits or Quarterly Reports to Management which it proposes to use in the storage / housekeeping area. As noted above, however, the County on October 6 provided summaries of each storage /
housekeeping audit finding (for FQC as well as Field Audits) ,
thus taking steps to reduce any difficulties caused by designa-tion of the new documents. .The County notes that the Field Audits all were transmitted to Mr. Gerecke and that the
, Quarterly Reports to Management are authored by Mr. Gerecke.
Further, many of-the Field Audits are signed by Mr. Kelley.
Under these circumstances -- and when combined with the summaries and other detail.s which -have . been provided -- the County submits that the additional documents to be used in the storage / housekeeping area are not a significant burden and would certainly not justify wholesale deletion of the documents .
-3/ Summaries of the EA and FQC document control audit findings were delayed due to illness of one person assisting in preparation of those summaries.
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. configuration and drawings areas. See Suffolk County Submittal of QA/QC Information, dated October 11, 1982.
I (f) By letter dated October 11, 1982, the County has reduced remaining areas. of inquiry concerning E&DCRs and also has provided LILCO with audit summaries concerning the one remaining E&DCR " pattern" area which the County will pursue --
the Courter area. These deletions will save time in the hearing process.
Suffolk County submits that a party must have flexibility to alter the focus of its examination in light of events which occur during the hearing. That is what has occurred in this instance, with the County substantially altering the focus of its examination in response to events on September 15 and the examination subsequent thereto. The County during the recess has taken steps to ensure that the examination, when resumed on October 12, proceeds as axpeditiously as possible. These steps ,
i include voluntary deletion of many audit findings and the sub-mittal of documents outlining in considerable detail the focus of the County's future-examination. Under these circumstances, the County submits that the Board should permit the use of the documents currently designated by the County for use.
II. LILCO REQUEST TO IMPOSE A TIME LIMIT ON COUNTY QA/QC CROSS-EXAMINATION.
The second LILCO-requested relief is that the County be required to complete all of its QA/QC cross-examination of the
l LILCO panel in two weeks, with no more than one week of that examination including questions to Mr. Museler or Mr.. Youngling.
The County opposes this request for the reasons described below.
The 'LILCO QA/QC panel has presented voluminous testimony and even lengthier attachments. Given that volume, it sb auld be clear that any estimates of how long it will or should take to complete examination are difficult to make. Nevertheless, LILCO makes much of the fact that the undersigned stated his hope that he could complete examination'of the LILCO QA/QC panel in two weeks. LILCO builds on that statement to suggest that a total of a four-week period, under all circumstances, should be ample.
LILCO ignores the fact that whenever estimates were made, they were couched with a high degree of uncertainty. The undersigned has no desire to prolong this examination but, in representing his client's interests, cannot agree to arbitrary limits which could seriously hamper the County's ability to fully examine the LILCO panel.
The LILCO request for a two-week limit appears premised on the view that Suffolk County's examination has been needlessly protracted. The implication is that the f ault r.ests on Suf folk County and, accordingly, that a time limit is appropriate. The County disagrees that any " fault" exists or, if there be fault, I that it is the County's . In these regards, the County notes:
(a) LILCO never suggests tiat the QA/QC data being pursued are irrelevant. Indeed, the Board has noted several times that the data are important, albeit the Board has also stressed its desire for a more streamlined approach. The County is not pursuing a course that prolongs examination, but it must strongly g - . .. .. i i .. ii i . i . .
oppose time limits which may bar presentation of relevant data.-4/
(b) If the County's examination during the initial two weeks was less streamlined than hoped for, it must be recognized 4
that counsel had prepared one line of examination and then, at i
Board request, pursued a different line of examination. The Board
. recognized the problems created by this switch and directed that steps be taken to ensure that the examination proceed more efficiently after the recess. The County has diligently taken steps to comply with this Board request. To impose a time limit without providing an opportunity to pursue examination after the recess would be highly unfair.
(c) The Licensing Board recognized that in many instances the witnesses ' answers were extremely long. This may be an inevitable problem when a large panel is presented, many of whom believe they have important points to make. Suffolk County did not attempt to cut off any answers, but the implication of LILCO's requested relief is the County was the cause for the relatively slow pace in the QA/QC examination. The County does not believe that to be true. Further, the County also points out that at times
-4/ The Board noted earlier that the examination could perhaps be streamlined further if complete audit reports (i.e.,
including responses and corrective actions) were produced.
The undersigned mentioned this in his October 6 letter to LILCO and indicated that the County is willing to review such complete reports in an effort to streamline examina-tion. See October 6 letter, p. 5. To date, the County has not~been provided with complete audit reports.
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the Board questioning was quite extensive. For instance, in the area of calculations, the Board pursued extended questioning on EA Audit 34 regarding the necessity for LILCO to have redone approximately 1800 calculations. The County certainly welcomes such Board questioning but objects again to the implication of LILCO's Motion that the pace of the proceeding is due solely to the County.
In sum, the County does not believe that the circumstances warrant setting an arbitrary deadline for the QA/QC examination i
to be completed. Rather, given the fact that the Board has directed new efforts to streamline the examination, the best 1 1
1 course is to proceed with the examination with the Board in a !
l position to evaluate the progress which is made.-5/ I LILCO also requests that Mr. Museler and Mr. Youngling should not be required to answer questions for more than one more week. The County has several comments in this regard. Firs t, Mr. Museler is a sponsor or co-sponsor of all of the testimony, with the exception of the Operating QA and procurement portions.
As such, LILCO must have been aware at the time testimony was filed in June 1982 that Mr. Museler's presence for an extended period of time might be necessary, particularly given the large
-5/ The County notes that LILCO includes in its two-week cutoff period all questioning on Operating QA. This seems highly inappropriate, since no questions at all have been pursued thus far on the Operating QA program.
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size of the LILC0 testimony. Thus, the County does not see how particular questions for Mr. Museler could be somehow limited to one week.-6/
Mr. Youngling is in a somewhat different situation. From the sponsorship page, Mr. Youngling appears to be the sponsor of only three pages of testimony (pages 197-99 of the Operating QA testimony) . The County has advised LILCO that is has no l objection to Mr. Youngling being absent until the examination focuses on the Operating QA program. In this regard, the County .
has also advised LILCO that if Mr. Youngling, upon review of the transcript, feels that he would have had useful comments to make on any of the portions which he misses, that the County will have no objection to receiving thase comments at a later time when Mr. Youngling can be present.
I In sum, the County does not believe that the proper exercise of discretion by this Board would be to set a date by which the County's QA/QC cross-examination must be completed.
The County's examination has proceeded in the manner requested by the Board, including the change in focus on September 15.
The County has also made a diligent effort to prepare audit 6f In this regard, the County notes that it has directed very few questions to Mr. Museler. Rather, the large majority of County questions have been directed to the QA personnel of S&W and LILCO. The fact that Mr. Museler believes he should assist in these answers or provide independent comments is something the County cannot control.
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summaries and other materials so that the examination on October 12 and thereafter can be as expeditious as possible.
However, it must be recognized that the answers have been long and the testimony itself, particularly combined with the attach-ments ,- is extremely vpluminous . Given these and related facts, a predetermined deadline would not be appropriate.-7/
Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
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Herbert H. Browni Lawrence Coe Lanpher Alan Roy Dynner KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.
Washington, D.C. 20036 (202) 452-7000 October 11, 1982 Attorneys for Suffolk County
~7/ The County believes that LILCO could take a step to assist in streamlining examination. The LILCO testimony attachments are very lengthy and, accordingly, it is di.fficult to assess which ones or parts are offered as evidence to document that Con-tentions 12-15 are incorrect. Thus , similar to data provided by.
the County regar ding its pattern examination, LILCO should provide a statement or cascription concerning what LILCO contends each attachment to its prefiled testimony demon-strates in terms of responding to Contentions 12-15. The statement or description should include what conclusions or findings LILCO proposes to draw from each attachment..
Finally, this statement should identify the particular portions or paragraphs of the attachments that it believes-are relevant. The County (or Board or NRC) examination could then focus on those portions mil.on the conclusions which LILCO asserts can be drawn from those portions. If these data were provided during the recess during the week of October 18, the hearing process should be assisted.
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e ErnirPATRICK, LOCKHART, HILL, CIIRISTOPIIER & PIIILLirs A PArrwansaxF Incz.cozzo A PaoFassiomAL ConsonArnow 1900 M Srnznx, N. W.
WAS1HNOTON, D. C. 20006 TELEFEONE (808) 459-7000 a. IN FITTSBURON CABLE: MIFN.1 EIREPATEJCE.I.CCIEART.J0aNeot & EUTCEISON TELEX 440909 MTFM Ug 1800 OI2VER BCIIBINO wmIT.. . nI==cr nI43. October 6, 1982 ,m..co. .TLvinu ==.
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- Anthony F. Earley, Jr., Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212
Dear Tony:
I am in receipt of your letters of October 1 and 5,1982.
The highly personalized tone of your October 5 letter is most uncharacteristic and, in my view, unfortunate. This case has proceeded with a minimum of personalized rhetoric, resulting in counsel being able to cooperate and work together. Your letter and remarks make such cooperation very difficult. I decline to respond to your personalized charges. I do respond below to your subs tantive concerns. I also set forth detailed proposals for expediting QA/QC examination in the storage area.
A similar proposal in the document control area is under prepara-tion. l_/
In earlier letters and conversations, I identified the audits and other documents the County likely would utilize in examina-tion of the LILCO QA/QC panel. The audits which I identified did not include LILCO Field QA, Courter, or LILCO QA Division audits.
Rather, the focus of the County's designation was on Stone and Webster EA and FQC audits. You assert that these earlier designations now preclude the County from utilizing LILCO Field QA, Courter, or LILCO QA Division audits, including those specific portions identified in my letters of September 30 and October 1.
I disagree. Prior to the September 14 commencement of the QA/QC hearing, the County's designations were made in the context l_/ During final editing of this letter, the County received !
"LILCO's Motion for Further Board Direction on the Conduct of QA Cross-Examination. " I do not specifically respond to that Motion herein because, in my view, it is preferable to get this letter to you so that you may consider the sub-stantive expediting proposals which are detailed in the letter.
KIRxPATRICK, LOCKHART, HILI., CHRISTOPHER & Purt.r.rrs l
Anthony F. Earley, Jr., Esq.
October 6, 1982 ;
Page 2 of a cross examination approach which did not focus initially on use of audits. Rather, the County intended to focus initially on the LILCO testimony, with examination of EA and l FQC audits to follow. In this regard, the County, prior to September 14, attempted to limit its areas of examination and thus ensure that you and your witnesses did not spend needless preparation time on materials which the County ultimately would not use. Such approach was a basis for my hope that the QA/QC examination could be completed in several weeks.
The Board on September 15 made remarks which resulted in a change in the County's cross exumination approach on OA/QC.
The Board made clear that it was less interested in generalities .
regarding what LILCO's QA/QC program was supposed to have been, l but rather wanted the County to focus its examination on actual j events / occurrences which, in the County 's view, represent QA/QC breakdowns. For instance, the Board stated:
1 Together we are going to find a better way of getting at the crux of what we think is potentially important in this QA area, and we want to get at it first, and that is the fact that in our view an important part of the bases, and in fact the bases for accept-ance of the contention, as well as the thrust of the substantive content of the allegations of contention 12 in totality and most, if not all, of contentions 14 and 15 are based on the allegation that through the nitty-gritty occurrences alleged there is a pattern of breakdowns and QA-QC problems that illustrate a failure in ability or attitude or both to want to correct the deficiencies. Tr. 10,259.
We want you to go to that point in the cross plan, get at these particular occurrences, incidents, series of incidents, so we can stay alert, stay keyed in with you, and '
follow along and hear the allegations. Tr.
10,261.
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KznxPATMICK, LOCKHART, Hzu, CHRISTOPHEa & PHzurrs Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 3 After going through everything you want to go through, provided it is material and important, you can then return to the area that I'm asking you to leave in the beginning of your cross plan, if you think there are some overall things in general about these documents and so on that further explanation in the record would be l useful in your findings, to tie up to the l incidents. But we want to see in the first
! instance the QA program as applied for these incidents that form the crux of the allegations and the admission of those contentions. Tr.
10,261.
The County has pursued the Board's requests in its exam-l ination commencing September 16, 1982. The Board's requests have further prompted'the County to reappraise its approach' and to designate additional audits which, to use the Board's words , get to the " nitty-gritty . " 2_/ In my opinion, counsel would be remiss if in the face of Board statements of interest, counsel were to pursue an examination course which did not key to the judges' clearly stated interests. 3/ Counsel did not appreciate the Board's interest prior to September 15. Accord-ingly, the fact that the County did not designate these audits prior to September 14 does not indicate a lack of diligent or good faith preparation but rather reflects the shifting focus of the trial.
You also cite my statement to the Board made on September 16 where I indicated (in response to the Board) that I did not
~2/ Such further designation occurred during the first phase of the QA/QC hearings when the County utilized LILCO Field Audits from 1977-78 in its examination on E&DCR problems.
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~3/ To be sure, the Board also is interested in a more expedi- l tious means of getting at the " nitty-gritty. " This is addressed later in this letter. l l
s0 KrmreArarcx, LocxHART, Hrz.x., Cunzaroruna & Part.x,res Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 4 foresee using large volumes of documents beyond the EA and FQC audits. See Tr. 10,308. Again, that was my intention at that time, the morning of the County's initial examination into the
" nitty-gritty . " However, as noted above, trial in the QA/QC area is not a static event -- as counsel proceeded, the perceived need to identify additional audits became apparent.
You also cited my September 7 and 10 letters to document your position that the County did not designate for use the LILCO Field QA, Courter or LILCO QA Division audits. Those letters, of course, speak for themselves. You have omitted, however, in your citations certain statements which relate to this matter. Thus , in my September 7 letter, I stated:
Notwithstanding the foregoing. . listing, the County naturally may determine at a later time to use other documents in its.examin-ation. Accordingly, the County reserves the right to use any documents in its cross-examination.
And, in my. September 10 letter, I state With respect to documents we intend to use in QA examination, I reiterate my oral statements to you that the County cannot definitively eliminate any documents from possible use in cross-examination. Th us , the County expressly reserves the right to use any documents, in-cluding those which I have indicated to you we do not presently intend to use.
We presently do not intend to use LILCO QA Division Audits or LILCO Field QA Audits. We will likely use CARS and E&DCRs only to the extent they are identified in other documents (like EA and FQC audits) that we use. We also do not presently intend to pursue LILCO LDRs, ,
Courter NCRs , and Courter audits . (emphasis supplied) .
Thus, from the outset the County has clearly apprised LILCO that its designations were not and could not be cast in stone. The events of the QA/QC trial demonstrate why it was necessary for i the County to reserve such rights. '
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KIMEPATRICK, lWART, Hus, Cumxsrorunn & Pux Ares Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 5
-You have also stated your concern that the' QA/QC trial for .the LILCO panel may go on for 6-10 more weeks. I do not share your pessimism, particularly if- LILCO responds favor-ably to the proposals set forth later in this letter and in the '
Attachments. I note, however, that the length of the examina-ti'on is not solely within my control. The Board noted on
- several occasions that the answers became extremely long. !'
The Board noted also that some examination might be avoided l if the County were provided full audit reports (i.e. including (
resolution / corrective action). The County is willing to review I such complete reports to determine whether they offer a means to shorten examination.
In summation of the foregoing, it is our position that the County has fairly, properly and in a timely manner, given the circumstances, provided LILCO with a precise designation of those audits which will be used in the QA/QC examination.
Pursuant to the Board's request, the County has designated the precise portions of audits which we intend to use and the particular purpose (s) for which those portions will be utilized.
Thus, for example, in the document control area, we have identi-fied six specific groupings, described as follows in my October 1 letter:
Group 1: Inadequate or missing procedures and similar problems Group 2: Distribution / transmittal problems Group 3. Problems with filing, indexing and other record keeping functions Group 4 : Legibility problems Group 5: Failure to keep documents up-to-date Group 6: Miscellaneous [this group will likely ,
be reduced on further review. I will advise you next week]. 4/
A similar designation was provided for storage-related documents.
This detailed designation constitutes a clear roadmap which O
4f See discussion, infra, re this reference.
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i ExxxPATRICE, LOCEMART, Hzzz, Cuarsrorama & PuzzArrs Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 6 complies with the Board's designation requirements and thus permits you and your witnesses opportunity for detailed preparation.
Let me turn now from responding to the criticisms in your letters to something more positive: discussion of steps which should shorten / streamline /and/or focus the QA/QC " pattern" examination in accordance with the Board's requests. In that regard, I am in receipt of your October 1 letter. In that letter, you state the following relating to this matter:
[W]e propose that you prepare a stipulation for filing with the Board that states the following:
(a) a statement or description of what the County contends each group of findings represents; (b) a statement concerning whether the County contends that the group of findings represents a pattern and, if so, what pattern is represented and how the County defines the pattern; and (c) whether the County contends the pattern represents a QA breakdown and, if so, the County's definition of what constitutes a QA breakdown.
Once this information is presented to the Board and given to LILCO, cross-examination of LILCO witnesses can focus on whether the LILCO witnesses concur with the County's conclusions and, if not, the reasons for the disagreement. Thus, this will, in large measure, avoid the need for finding-by-cross-examination. Note, however, that it might still be necessary to discuss a number of the I specific findings in the context of LILCO's disagreement with the County's conclusions. ,
Preliminarily, I note that item (a) has already been provided. In substance, I also believe items (b) and (c) have also been provided. Clearly, the County, by designating various audits in particular groupings , does. assert that QA/QC break-downs have occurred. The pattern is represented in each instance by the repeat occurrences of similar, and sometimes
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KraxFATRICK, LOCKHART, Hirm, Cantsroenza & ParrarPS Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 7 almost identical, failures to comply with internal QA/QC requirements and the failure of the QA/QC program, upon dis-oowny/ identification of such problems, to take effective action to prevent future recurrence.
Let me provide a concrete example. Storage / housekeeping Group II alleges a QA/QC breakdown in failing to protect equipment from weather-related damage and in failing to
- correct deficiencies in a manner which prevents recurrence.
! [In this regard,10 C.F.R. Part 50, Appendix B, Criterion XIII specifically requires storage measures to be estrblished and Criterion XVI concerns corrective action.] Our review of the storage Group II documents designated in my September 30 letter
, yields the " pattern" of breakdowns which is described in l Attachment I hereto. This pattern, in our view, shows the following:
(a) Repeated failures to store equipment in accordance with LILCO's (by LILCO I also include S &W, etc.) own.QA/QC requirements; (b) Failure to take effective corrective action to reduce or eliminate future storage problems of the same or similar type; (c) Items (a) and (b) lead to the conclusion that there has been a lack of disciplined compliance with QA/QC storage requirements, leading to a finding that Appendix B, Criteria XIII and XVI have not been satisfied.
In order for the County to establish the foregoing pattern, it is essential that the cited portions of the audits become part of the record. Thus, I must disagree with your October ~1 proposal, quoted earlier, which does not appear to include inclusion of the audits in the record. .
It is my view that we can materially shorten the QA/QC examination by the steps outlined above. To recapitulate:
(a) The County will describe the audit exerpts it is relying upon so that the context for i later questioning will be clearly understood. '
The Attachments hereto constitute such description in the storage area.
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KrRxPArarcx, LocxHART, Hra, CHRISTOPHER & PHruIPS Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 8 (b) LILCO will agree to admission of the' audit finding cited by the County and the County summary thereof (I think it makes sense to make both part of the record, with the audit finding speaking for itself, as amplified, as appropriate, by LILCO witnesses; the County summary would not be cited in proposed findings, but would provide a "roadmap" of where the exmmination was proceeding) .
(c) The examination would proceed primarily with LILCO witnesses either agreeing with the particular finding or providing amplification thereon.
(d) On redirect examination, LILCO counsel can pursue the witnesses ' views regarding whether any group or groups of audit findings represent a QA/QC breakdown.
In furtherance of this proposal, I include'the following additional attachments:
Attachment II: Storage Group I, summary of audit findings. This pattern concerns LILCO's failure a) to maintain storage cards as required and/or b) to carry out inspections or other activities noted on/ required by storage cards. Accordingly, the County alleges a breakdown in storage require-ments, recordkeeping and QA/QC controls as relates to storage cards. This violates Criterion XIII, as well as the recordkeeping requirements of Criterion XVII. The failure to take effective corrective action violates Criterion XVI.
Attachment III': Storage Group III, summary of audit findings. Group III is related to Group II
' in that it concerns protection.of equipment from damage. It differs in that it does not focus on weather-related storage problens , but rather on storage / protection of installed equipment, equip- ,
ment stored in place, or equipment stored inside.
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i X1RmPATm1CE, lW A*T, Hat.z., CuarsroPumm & Parr.l.IPS Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 9 Particular concerns include the failure to provide proper seals, particularly end caps.
The audits show repeated failures to comply with LILCO's own requirements, thus demon-strating violations of Criteria XIII (Storage) and XVI (Corrective Action).
Attachment IV: Storage Group IV, summary of audit findings. While related to both Groups II and III, this set of findings focuses narrowly on instances where proper environmental conditions (aside from ' weather) were not provided as required by specification, procedure or other requirement. [ Note that certain Group III find-ings, particularly those in the Quarterly Reports to Management, also apply to the Group IV pattern. ]
.This violates Criteria XIII and XVI.
l Attachment V: Storage Group V, summary of audit findings. The, audit findings document repeated failures to comply with housekeeping requirements, particularly regarding accumulation of trash and debris, reflecting a general lack of discipline and a failure to effect proper corrective action.
This violates Criteria XIII and XVI.
Attachment VI: Storage Groups VI and VII, combined. These groups are being combined to '
focus on improper storage of items which require segregation from other items , either because of fire-related problems or because of procedures, etc.
which otherwise require segreated storage. This violates Criteria XIII and XVI. '
One last statement regarding storage needs to be made. By-designating six groups of alleged storage breakdowns, it must be recognized that there is overlap among the groups. These .
groups are primarily being presented to facilitate and hopefully expedite examination. They all are presented to support the County's position that .there has been a pattern of breakdowns.
concerning Criterion XIII and, related thereto, Criterion XVI.
In - the area of document control, I have several comments.
First, we are preparing a set of detailed group descriptions,
.imilar to those attached hereto for storage, which should materially expedite examination. Second, we have given careful l . . . . ~ .
I EIRXPATRICX, LOCXHART, Hzz.I., CuntsToenmR & PHII.I.TPS Anthony F. Earley, Jr., Esq.
October 6, 1982 Page 10 consideration to your concern about the number of audits being utilized beyond the FQC and EA audits. In that regard, we have decided to delete a large number of designations (without counting, it appears to be much more than half) which, in our - -
view, may be cumulative or not sufficiently important to require examination. Attachment VII hereto indicates those audits which we delete. I trust that this deletion assists in LILCO's preparation.
Finally, in the FSAR and Drawing areas, we will work the next several days to identify means by which the examination in those areas can be expedited.
I would appreciate a call at your earliest possible opportunity to find your reaction to our proposals.
Sincere yours, v
. Lawrence ce Lanpher LCL/dk Enclosures cc: Lawrence J. Brenner (5 copies)
Bernard M. Bordenick e
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ATTACHMENT I -
l STORAGE GROUP II: FAILURE TO PROTECT AGAINST WEATHER .
Audit Page/ ,
Audit Finding Date Description '
FQC 8 05782 &
page 3 3/74 Specs call for water tight doors, !
- but they are not provided.
- FQC 13 B.13 3/75 Traceability control number fading due to light exposure.
D.5 Storage area D-9 not well-drained.
FA 226 4.4 3/75 Storage Level D3 has poor drainage
- and puddling.
4.14 Some Storage Level C areas do not i drain properly because the yard does not have stone spread throughout the enclosure. Equipment is exposed ;
to unnecessary dampness.
FA 238 4.9 3/75 Motor leads are exposed to moisture and possible damage.
. FA 340 4.3 11/75 Steel plates (7) were found lying on the ground.
FA 371 4.1 2/76 A torn tarpaulin on a refueling platform funneled water on equipment.
4.2 A bundle of stainless steel piping was lying in a puddle.
4.3 Steel angle and plate stock r.aterials had ponded water trapped in some of 4
them. Also, unidentified bars were welded to others.
4.4 Steel stock material was lying on s the ground.
4 FA 376 4.4 3/76 The roof still leaks in one of the .
warehouses.
FA 425 4.1 7/76 Nine (9)' pieces of unidentified equipment are stored outdoors , un-covered, with torn or missing opening seals.
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- . Audit Page/
Audit Finding Date Description FA 425 4.3 7/76 Storage area roof leaks badly onto stored cardboard crates and cartons.
FA 444 4.1 9/76 A storage area had an accumulation of trash and cartons, a pile of structural steel in a rain puddle with no dunnage, and several stock stainless steel angles in contact with a carbon steel embedment.
4.2 Pipe hanger material had water ponded in structural steel shapes. Two turnbuckles had rust on their threads and machined swivel ball joints.
4.4 A painted structural steel assembly of the refueling platform was severely corroded.
FA 443 4.4 10/76 The Hydraulic Control Units (HCUs) for the Control Rod Drive (CRD) were not recovered with water barrier wrapping and rivulets of water came down on all sides of the units from coacrete curing above the level of the units.
FA 470 4.2 10/76 A storage roof leaks badly onto stored cardboard crates and cartons. The situation has worsened since issuance of earlier violation.
FQC 23 D.5(1) 9/77 Weather proof coverings not provided, allowing moisture and wind damage.
D.5(2) Turbine laggings and casings were rusted, contained water.
D. 5 ( 3) Heavy walled pipe not protected vs. weather.
D.6 Roof covering warehouse torn, resulting in crates of thermal sleeves becoming wet, conflicts with ANSI N45.2.2.
D.7 Cable reels in deep puddle cf water.
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Audit Page/
Audit Finding Date Description FA 64 8 4.3 10/77 The poly cover on a MOV was torn allowing water to come into contact with equipment. Also, the lamp providing local heat was not on.
The bulb needed to be replaced.
FQC 24 K.6 12/77 D.5 of FQC Audit 23 not all fixed.
K.7 D.6 of FQC Audit 23 not fixed although protective covering provided.
FQC 25 K.3 4/78 Some of D.5 of FQC Audit 23 just being fixed.
FA 803 3.1 8/78 Outdoor storage conditions were found to be barely satisfactory.
4.1 One motor operated valve and three air operated valves were being stored outdoors, not in a heated building.
Also, 2 of the AOVs were missing end caps.
4.2 Numerous bundles of reinforcing bard were not on dunnage and were in contact with the ground.
FQC 34 N.2 6/80 Plastic covering ripped, exposing pipe to elements.
FA 1183 4.1 10/80 Steel shapes not on dunnage and scrap material not in designated HOLD / REJECT area remain in those conditions.
4.2 Several containers of conduit collars do not have protective covers (the " poly" is severely weathered) . Several pieces of conduit and several conduit elbows
- did not have end caps.
- 4. 3. Several pieces of angle steel and "I" beam material were not on dunnage.
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Audit Page/
Audit Finding Date Description FQC 36 p. 1 and 1.3 12/80 Cable not properly stored.
FA 1275 4.2 5/81 A skid of fuel storage racks was l found without its protective cover !
intact.
FQC 40 1.3 12/81 Cable not properly stored including
. . in puddle.
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- ,- ATTACHMENT 1II STORAGE GROUP I
- STORAGE CARD DEFICIENCIES Audit Page/
Audit Finding Date Description FQC 13 D.4 3/75 Some NSS equipment in one warehouse doesn' t hava " Equip-ment History storage Cards" 1
D.7 Some cards don't indicate what
- maintenance checks are required, although some checks are being done.
FA 238 4.3 3/75 The Storage History Card megger-ing schedule for the windings
- of the Reactor Core Spray Pump violates specifications for electrical installation; also special handwritten QC instructions.
FQC 15 D.8 8/75 Storage card listed equipment in one location (Bay J) while it really was in Bay E.
FA 376 4.2 3/76 No copies of Storage History Cards
!* were found on 5 control panels stored in the Control Room.
i 4.7 No Storage History Card exists ,
- i. for RBCLCW Heat Exchangers stored i in reactor building. No S&W or manufacturer's procedure requires storage care or maintenance nor is there a provision for periodic inspection of these safety-related items.
4.8 Storage History Card for a Control Panel indicates items have been in storage for almost a year but only inspection took place on i
day Storage 1Estory Card was pre-
- pared.
FA 443 4.4 10/76 'The Storage History Cards for the
- Hydraulic Control Units (HCUs) for the Control Rod Drive (CRD) (a) were.
5 not updated to reflect store-in-place status; (b) indicated units '
were packed in wooden boxes and on dunnage (later verified as corrected).
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-' - ,,_.,,a p,,m_.,y, y _y.y ,_,,# ,_..y,,,
Audit Page/
Audit Finding Date Description FQC 21 D.ll 4/77 4 of 12 pieces of Cat. I equip-ment didn' t have Storage History Cards.
D.12 Storage History Card didn't reflect where equipment wa's actually stored.
i FA 601 4.4 6/77 Numerous meters had missed inspections required by the Storage History Card.
FQC 24 B.4 12/77 Audit of 4 cards re electrical equipment didn't reflect FQC checks for 8 months. Supposed to be quarterly.
FA 721 4.4 3/78 Storage area surveillance inspections are not being per-formed by Courter QC personnel.
FQC 27 B.9 9/78 Cards being processed by CSI rather than QC procedure.
B.7, B.8 FQC couldn't document on storage cards that it had witnessed all required tests.
FA 101'6 4.1 10/79 The motors from three (3) motor operated valves (MOVs) were re-moved from storage and installed without meggering being performed as required by the Storage History Cards.
l 4.2 Storage History Cards for two (2) bearings indicate that they were not lubricated within a year's I time. Inconsistency of fan pre-lubrication (lack of necessity
- for storage lubricati6n) with l Storage History Card requirements should require change in Storage History Card requirements so only turnover lubrication requirement is in effect.
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Audit Page/
Audit Finding Date Description FA 1016 4.3 10/79 The required strip heater periodic inspection (s) was/were never performed; neither are the strip heaters installed in the compon-ents. Also, two components had no " poly" covering.
FA 1086 4.4 3/80 The Storage History Cards for 44 components do not indicate that they are safety-related.
FA 1213 4.1 1/81 The Storage History Card of a motor operated valve (MOV) did not record the performance of a megger test.
4.2 No documented guarterly maintenance checks had been performed on a panel in almost a year.
FA 1425 4.1 2/82 A piece of equipment requiring a quarterly storage inspection was not inspected in almost a year and a half.
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ATTACHMENT III STORAGE GROUP III: STORAGE PROBLEMS, PARTICULARLY RELATED TO COVERING AND CAPPING Audit Page/
Audit Finding Date Description FQC 13 D.8 3/75 Check valves not covered. Last 3 monthly construction dept. checks
.show same problem with same valves.
FQC 15 D.7 8/75 Five 10 " gate valves without protective end caps required by procedure.
FQC 17 D.4 3/76 Valves and heat exchangers lack required protective covers.
FA 376 4.1 3/76 A control panel was not protected against mechanical damage.
FA 425 4.4 7/76 Stored cardboard cartons are stacked so high that the bottom ones are crushed.
FA 443 4.1 10/76 Standby liquid control system pumps have rust surrounding the bolts and carbon steel lifting rings where
- they are threaded into a stainless steel housing.
FA 470 4.3 10/76 Stored cardboard cartons are still stacked so high tha: the bottom ones are crushed. This repeats an earlier violation.
4.9 A core spray header pipe was lying on the floor with its end cap missing.
FQC 20 D.4 1/77 Electrical cable protruding from concrete for grounding purposes not protected, violating spec.
FQC 21 D.7 4/77 Expansion bolts lacked temporary l protective covers required by spec.
D.8 Iron contamination to be prevented /
minimized by covering or isolating materials.- Contrary to spec. , this wasn't done.
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Audit Page/ <
Audit Finding Date Description FA 601 4.1 6/77 Two valve bodies were found with no visible identification and no end caps applied to them.
l 4.2 Valves were found without end caps l applied to them.
I 4.3 A valve kas found with no end cap applied to it.
t FQC 23 D.5(3)
- p. 2 of 3 D.8 9/77 Heavy walled pipe lacked end caps; numerous, repeated storage problems.
FA 656 4.2 11/77 Miscellaneous pieces of piping were found off dunnage and missing end caps. Several pieces of piping and sections of structural steel were also found off dunnage.
l FQC 24 D.3 12/77 Ends of cable reels not sealed with insulating varnish.
D.5 Damage to level control switch.
FA 721 4' 1 3/78 Fourteen piping spool pieces were found missing end caps, lacking identification and also were cluttered with debris.
4.2 A motor operated butterfly valve was found with an end cap punctured. A second motor operated butterfly valve was missing both end caps and mud had accumulated on the valve butterfly plate.
FA 740 4.1 4/78 A control room air conditioning ,
system unit had severe peeling l I
of the protective coating on the unit's inside surfaces. Also, one of the threaded pipes at the base of the unit is missing its screw-on cover and a length of 1/2" conduit has been broken away from a fitting near the top of the filter. Also, several other lengths of conduit are bent due to debris and ductwork being piled en top of' the unit.
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Audit Finding Date Description FA 740 4.2 4/78 The electrical terminations and' inside surfaces of an electrical panel box were extensively corroded.
4.3 Two tanks were found with two openings left uncovered.
FA 803 4.3 8/78 Numerous pieces of stock pipe were found with split, broken, or missing end caps.
4.4 Various temporary laydown areas had excessive litter and/or piping was off dunnage and udssing end caps.
FQC 27 D.7 9/78 Stored in place equipment lacks covers and other protection.
FA 934 4.1 4/79 A panel did not have the " poly" cover required by the Storage History Card.
4.2 A panel had several unplugged openings on the stainless steel lines.
4.3 Nine individually mounted instruments have unplugged openings. This is a generic problem.
4.4 The copper tubing on an air operated valve was found kinked and the copper tubing on a solenoid operated <-
valve was broken off. Two SOVs were missing their stainless steel identification tags.
FQC 30 N.1 5/79 Courter failed to cap piping, including one item installed in containment.
FA 980 4.1 8/79 None of four panels reviewed was -
covered with " poly. " This is a generic problem that has been noted on 3 previous instrumentation storage audits. I 4.2 Two pieces of equipment had conduit '
openings uncapped.
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( Audit Page/ -
Audit Finding Date Description i FA 980 4.3 8/79 Four valves had conduit openings ;
uncapped. Two of those valves ;
were not identified. -
FA 1016 4.6 10/79 The motor wiring'of a component presently stored in place has not been terminated and is lying loose out of the junction box with no cover on .!
the junction box. ,
FA 1026 4.1 10/79 A component had an uncovered conduit opening.
4.2 Five components had uncovered conduit t and tubing openings.
FQC 32 D.3 11/79 Covers of 5 portable heated electrobe containers were not closed. ;
e FQC 33 p. 2 of 3 D.4 3/80 Due to lack of or damage to covers, many instrumentation assemblies vulnerable to damage. Also lack of caps on tubing.
i FA 1086 4 .'1 3/80 A component was not covered with
" poly". The unit had been damaged ,
and an air filter and a gauge were missing.
4.2 Two filters are being used for storage of such items as a welder's helmet, piping, tubing, rain coats, .
I and various debris. Several conduits on top of the units had their openings L uncapped and there was an accumula-tion of debris behind one filter.
Also, the filters are not properly identified.
Q.R.* p. 1 5/80 FA 106 3, 10 70 & 1086 identify failures to provide adequate environmental protection for installed equipment. '
FQC 34 K.3 6/80 Some of D.4 of FQC Audit 33 not corrected.
N.2 Piping not protected, including lack of protective end coverings.
- Quarterly Report to Management. s
Audit Page/
Audit Finding Date Description Q.R. p.2 7/22/80 FA 1098, 4/80, identifies additional instances where there is lack of environmental protection for installed equipment, including failure to cover ~and cap.
FQC 35 p. 2 of 3, 2.3 9/80 Open ends of tubing identified as deficient in FQC Audits 33 and 34 still not properly protected.
FA 1180 4.1 10/80 Courter is not maintaining adequate valve storage conditions. A review of ten valves indicated deficiencies in five valves:
1 ucrapped position switch and missf.ag pressure gauge 2 uncapped solenoid valve and missing pressure gauge 3 damaged pressure regulator and missing pressure gauge 4 & 5 . uncapped openings.
4.3 An uncapped opening remains uncapped.
Q.R. p.1 11/13/80 FA 1133 and 1142 identify two failures to provide adequate environmental protection for installed equipment.
FQC 36 p. 1, item 3.1.2 and Obs. 1.2 12/80 Improper storing resulting in oil and water contamination and un-acceptable megger readings. Problem had been previously noted.
FA 1204 4.1 12/80 Two filters were not covered with
" poly" and the doors were removed exposing the internals of the .
filters to dirt and potential damage.
)
4.2 The identification of a component was not visible without removing the protective covers.
FA 1234 4.1 1/81 An instrument had an uncapped conduit .
opening. l l
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Audit Page/
Audit Finding Date Description Q.R. p.1 2/17/81 FA 1180 and 1204 identify further failures to provide adequate environmental protection for installed equipment.
FA 1301 4.1 6/81 Equipment was not covered with
" poly."
FA 1313 4.1 8/81 Two components were not covered with
" poly."
4.2 A component was not covered with
" poly" and the electrical box was damaged.
Q.R. p.2 8/31/81 FA 1275, 1297 and 1301 identify further instances of improper environmental protection of installed equipment, including failure to provide adequate covers and improper use of internal heaters.
FQC 40 1.3 12/81 Cable lacks covers.
Q.R. p.1 12/03/81 FA 1313 identified 3 additional instances wh'ere stored-in-place equipment not adequately covered.
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. ATTACHMENT IV STORAGE GROUP IV: ENVIRONMENTAL PROTECTION Audit Page/
Audit Finding Date Description FQC 13 D.9 3/75 Dessicant in main steam stop valves for humidity control purposes had <
not been checked. 6 FA 226 4.1 3/75 Two motor generator sets are in a r unheated-instead of a heated-indoor storage area.
FA 340 4.1 11/75 Control Rod Drive Pump Motors did not have their space heaters energized for 8 days while in s torage.
FA 376 4.3 3/76 "Leanto" area's heaters were not fully operational. Lack of heat has continued uncorrected throughout winter.
FQC 21 B.9 4/77 Humidity in storage area at 70%,
D.14 rather than maximum of 60% provided by procedure.
D.15 Items required to beheated and -
within building. Certain items didn't have strip heater energized and also the protective enclosure was torn and condensation noted.
D.16 Spring heaters being stored under ,
wrong conditions since building "
has no roof and protective plastic blown away.
D.17 Pump motors and pump stored in ,
wrong type of area. Failure to l correct from earlier inspection.
D.18 Rust accummulated on valve due to storage in uncontrolled area without .
protective covering.
FA 679 4.2 12/77 A pump was found not to have local heat applied in an unheated structure as required by the Storage History Card.
Audit Page/
Audit Finding Date Description FA 679 4.3 12/77 Rust is still evident in the threaded bolt holes surrounding the carbon steel lifting rings where they are threaded into the stainless steel housing for the Standby Liquid Control System Pumps. .This is a
, continuation of an earlier violation from Audit 555.
FA 699 4.1 2/78 The refueling platform, main hoist motor, and monorail hoist motor do not have local heat applied. The motors are also stored in an area different from the area required by the Storage History Card. ,
l FA 721 4.3 3/78 The twenty-five horsepower motor attached to the hydrogen recombiner did not have dhe internal heater operating.
FA 1301 4.2 6/81 Internal heaters were kept 31 F above the required temperature.
Since the primary purpose of the heat is to prevent condensation, the amount of heat applied is excessive.
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ATTACHMENT V STORAGE GROUP V: HOUSEKEEPING DEFICIENCIES l Audit Page/
j Audit Finding Date Description FQC 8 3 3/74 Trash barrels available but not being used. Deterioration since last audit.
FQC 11 3 10/74 Same finding as in FQC Audit 8.
FA 226 4.3 3/75 Garbage and food were found in a storage area, the Reactor Shroud Enclosure.
FA 425 4.2 7/76 Accumulations of trash and evidence of food / drink consumption were found in storage areas.
f FA 470 4.1 10/76 Accumulations of trash and evidence of food / drink consumption were still found in storage areas. Repeats an l earlier violation.
L 4.5 A box containing a refueling platform assembly hoist had an. accumulation of trash including old desiccant bags and an open can of unidentified liquid in its open crate. Also, there was no " poly" cover and one instrument was rusting.
FQC 20 D.5 1/77 Trash and litter allowed to accumulate, thus violating CSI-13.1.
FQC 21 D.13 4/77 Trash accumulation in storage areas, violating QC-17.1.
FQC 23 K.5 9/77 D.13 of FQC Audit 21 not fixed.
FQC 24 p. 2 of 3, 12/77 Housekeeping lack of attention is item 3.1.1 evident.
FQC 25 D.6 4/78 Housekeeping inspections not documentsd.
D.7 Housekeeping zone markers not posted.
FQC 26 K.4 6/78 Relating to D.6 of FQC Audit 25, finds procedure inadequate.' ,
FA 803 4.4 8/78 Various temporary laydown areas had excessive litter and/or piping was l off dunnage and missing end caps. l l
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Audit Page/
Audit Finding Date Description i FA 1086 4.2 3/80 Two filters are being used for storage of such items as a welder's helmet, piping, tubing, raincoats, and various debris. Several conduits on top of the units had their open-ings uncapped and there was an accumulation of debris behind one filter. Also, the filters are not properly id<antified..
FQC 34 N.2 6/80 Housekeeping deficient; debris and i dirt need cleanup.
FA 1275 4.1 5/81 A pipe storage area was found to have excessive litter and debris. Con-tinuation of a violation in Audit 1237.
FA 1325 3.2 8/81 A storage area continued to have excessive litter and debris.
Violation remains from audit 1275.
4.1 A storage area continued to have excessive litter and debris.
Violation remains from audit 1275. '
It was verified that a wooden floor has been installed but it appears that the area is not cleaned regularly.
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ATTACHMENT VI STORAGE GROUPS VI AND VII: STORING ITEMS !
7.N WRONG AREAS T
Audit Page/ ',
Audit Finding Date Description FQC 8 3 and f A.O. 05786 3/74 Flamable materials r.Jt segregated; !
precautions not taken. A repetition [
of earlier finding. [
l FQC 17 D.5 3/76 Outdated epoxy stored in Category I ;
section.
l FQC 13 D.6 3/75 Accepted, rejected, hold and i uninspected goods are intermixed. l FQC 15 D.2 8/75 Different types of welding electrodes l stored together in violation of specs. t i
FA 340 4.2 11/75 Highly volatile Tylox cement was :
stored among vital items. !
FA 376 4.6 3/76 A flammable liquid storage container in the middle of a steel receiving area.
FA 425 4.5 7/76 Three tanks of propane gas were found ;
in a storage area.
t FQC 23 D.5(5) 9/77 Gas stored in wrong area.
FQC 32 D.3 11/79 oven contained two types of electrodes; also, wire types not segregated.
FQC 34 U.2 6/80 Instrumentation assemblies not properly segregated.
9 l
e ADDITIONAL AUDITS REPORTING DOCUMENT CONTROL PROBLEMS ,
H H
[ NOTE: Document portion to be us,ed and Group Category noted with each audit.]
g I. LILCO QA Audits z
h Audits of subcontractors and. internal audits, by LILCO QA auditors, arranged O ,
by year.
E4 E4 1970 Stone & Webster (S&W) II"~ L-le-~
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LILCO Internal Audit #3A - Follow-up of 53, , _ ,_"-" ' "
7___'-- IV. g 2, & 4, 1972 LILCO Internal Audit # 4 - Purchasing Depa_-tment, p. 4, #4, p. 9, fl, Group 5 Site QA Audit 51 - Feceiving Inspection, Finding 1, Group 1; Findings 2-12, Group 6 l
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'2- Finc ing 3C, Group 6 Site QA Audit 57 - Site Purchasin'g, Findings 2 and 3 (a-d), Group 4 IAE_et.V A TAVdi1,.; ikv-ewuhEui%.nuhv_bAudiTtXsz A nmi,.wihG fyum Z-S&W Procurement Quality Control, Findings 1-3, Grou 6; Finding 4,' Group 1 Fourth Audit of LILCO Purchasing Dept., Findings 2, Group 1 .
1974 ,
l Site QA Audit #9 - Non-destructive Testin p. 2 fl(b), Group 5 l QA Audit #4 - SNPS S&W Project, IV. 1, rou 5; AM W.lo, Shoreham Project Audit, III.B.4,. Group 4 1975 -
S&W Field Quality Control (QC) Audit $1, Findings A.1, A.3, Ww%werd C.5-6, Group 1; Finding C.1-3, Group 6 ;
S&W Procurement Quality Contr.ol Audit il, Attachment 1, p. 1, ww .-n-inus Group 1 Follow-up of LILCO Purchasing Department Audits #4 and 5 (1973, 1974), III.A.2; Group 1 Follow-up of S&W Field QC Audit #1, III.B.1, Group 1 r3 QA?AV6i ciO_, d NEMwiih'roi dt'twr i1fdinU Sni ikTM curoHDXX; 771 nrn na rr. _ u ronDRth DNiAudi'tIIf 1=G5-i5 r=DSEWWrocaremen trQC_,991TI7B-M'2 37 Group;Dh QA Audit #5 - LILCO Shoreham Project, Finding 3, Group 2 .
QA Audit #6 - LILCO Purchasing Department, Finding a & Recommendation a, Group 1; Finding B, Group 2 1976 -
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1977 KmtAuntgi /-O -,- amun5AWcuerroi ecL;a'inu.a.nm,mruupa QA Audit #77 S&W, Findings 3 and 4, Group 1 QA Audit #77 S&W Field Extension Office, Finding 5, Group 3 QA Audit 178 Field QA and Engineering QA, III.B, Group 1
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QA Audit #78 S&W Site Extension Office, p. 9, Group 3 pa yaudi uf'l 8Mr-- alds,Cvvahvr_chcun eht v.ivvi ndindL ie,Ma.m.,uw 6 QA Audit 178 S&W, Findings 2 and 5, Group 1 QA Audit #78-2, 78 S&W PQC offices, Atlanta & Pittsburgh, 1.1 g Group 2; 1.3, Group 3 J
1979 ,,
QA Audit i79 S&W, Finding 1, Group 1; mm a:-aun . ,^m.are n ; e 1981 QA Audit #81 LILCO Shoreham Project, lb, Open Item 1, Group 1, s p e w :.a c e .# c la, & 3, Group 6 QA Audit #81 LILCO Purchasing Department, Fi ding 1 and Open Item 1, Group 1; Finding 2, Group 6 r
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II. LILCO Organizational Audits - Courter and Company Audits of Courter and Company, by LILCO QA auditors, in chronological order:
Audit No.' Date O JLQ ^r-97 1/23/80 1.~1, d Group' 6 i.3;3- w u,w w w i&3inus ErlfMa% W 198 7/80 - 9/80 _
Conclusion, Group 6 5,7 meux _ <au/12972 u- r ipmi>=
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O.29w x...ag)27D78 Glyrhuroupp gp ,m' Q.535T2XMT:;9272318 ' O rT W A & o n n -
OIb ' wo r 2MmV1SP7R 145 4/ 3/81 6 Groua 5; 11, Group 6; 25 (a-c) , Group 3
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~160 7/21/81~ Findings 10, Group 3; Findings @ llb, @ llf, 14, 1 Group 2 (tip cc.u u ran.-- 7 m Wit]*N i *'5[/4Q,Y U h b E.177aEnnx , d o d iis isrY _
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2- -
Year' Field Audit No.
1980 (E531DB 9 pep =0469meppeupuu6m W
- emposeenimes tm2!B N tttsn coopme===pme EGGS N '
1195 4.3, Group 6 1981 (January 1-July 31) .s M N
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1207 4.1, Group 6 ,
(August 1-December 31) .
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III. LILCO FIELD AUDITS -
Audits of all activities and companies involved in the Shoreham Project. Individual audits have a single, specific subject activity and organization.
Audits were conducted by the LILCO Field QA Division. They are listed by year:
Year Field Audit No.
uripirr;: r2:r::.rrm ring (($}{rjnEhy@
1974 87 -.. , m. m y J, 4.2, 4.3, Group 6; W -
Sf2i". --3> M W S "$'
1975 fggfr15g f , , , . . _ _ . , _ _
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228 4.2, Group 3 M N 1976 359 4.1, Group 3 '
6 6 433 4.1-4.4, Group 3 1977 563 4.1-4.4, Group 3; N 636 ,
4.1, 4.2, 4.4, 4.6, Group 3 tEZ3 h m ,--,, , ,.,, ...,_:_
W m .., ,.s, uuvue s N
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1979 str1 S tii#:D ., .. , r., mmy; r
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990 4.1, Group 3; E
1015 4.1, 6 Group 6 trg333 ,
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