ML20028C755

Supplemental Testimony of E Greenman,D Caphton,G Napuda & N Blumberg Re QA (Suffolk County Contention 13).QA Program Implementation Insp on 821129-1203 Discussed.Prof Qualifications Encl

ML20028C755
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/10/1983
From:	Blumberg N, Caphton D, Greenman E, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20028C751	List: ML20028C750 ML20028C755
References
TASK-1.C.5, TASK-TM ISSUANCES-OL, NUDOCS 8301140069
Download: ML20028C755 (18)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Long Island Lighting Company Docket Number 50-322(0.L.)

(Shoreham Nuclear Power Station, Unit 1) i NRC STAFF SUPPLEMENTAL TESTIMONY, OF EDWARD GREENMAN, DONALD CAPHTON, i

GEORGE NAPUDA AND NORMAN BLUMBERG 1

REGARDING QUALITY ASSURANCE SC Contention 13,*

• Previous Staff Testimony has addressed SC Contentions 12-15. This testimony supplements previous Staff Testimony as regards SC Contention 13.

8301140069 830110 PDR ADOCK 05000322 T

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OUTLINE OF TESTIMONY

'P SC Contention 13 contends that the Quality Assurance (QNr. program for opera-tions does not comply with regulations. The licensee has committed in the FSAR to meet applicable regulations regarding QA for operations. The implementation i

of the QA program was reviewed by Region I during the period November 29 -

December 3, 1982.

This supplemental testimony discusses the results of that inspection.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CONiISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of k

l' Long Island Lighting Company Docket Number 50-322(0.L.)

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(Shoreham Nuclear Power Station,

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Unit 1) ll I

NRC STAFF SUPPLEMENTAL TESTIMONY 0F EDWARD GREENMAN, DONALD CAPHTON, i:i:

GEORGE NAPUDA AND NORMAN BLUMBERG REGARDING QUALITY ASSURANCE l

1 SC Contention 13 PART I INTRODUCTION Q.1 Will the panel members each please state your name, employer, job title, and responsibilities relative to the Shoreham project.

A.1 My nane is Edward G. Greenman, I am Chief, Reactor Projects Branch Number 1, Division of Project and Resident Programs, Region I, United L

States Nuclear Regulatory Commission.

I am responsible for supervision of regional and resident inspectors whose jobs are to inspect construc-tion, start-up, and operation of certain nuclear power plants in Region I, including the Shoreham Nuclear Power Station.

My name is Donald L. Caphton, I am Chief, Nanagement Programs Section, Engineering Programs Branch, Division of Engineering and Technical Pro-grams, Region I, United States Nuclear Regulatory Commission.

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4 re:ponsible for the supervision of regional inspectors whose jobs are to inspect the management. programs including Quality Assurance for the nuclear power plants in Region I, including the Shoreham Nuclear Power Station.

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My name is George Napuda, I am a Lead Reactor Engineer,' Management Pro-grams Section, Engineering Programs Branch, Division of Engineering and Technical Programs, Region' I, United States Nuclear Regulatory Commission.

I am responsible for the inspection of Quality Assurance programs-for the nuclear power plants in Region I, including the Shoreham Nuclear Power Station.

i My name is Norman J. Blumberg, I am a Lead Reactor Engineer in the Management Programs Section, Engineering Programs Branch, Division of Engineering and Technical Programs, Region I', United States Nuclear Regulatory Commission. I am responsible for the inspection of plant procedures for the nuclear power plants in Region I, including the Shoreham Nuclear Power Station.

Q.2 Has the panel prepared statements of educational and professional qualifications?

A.2 (All) Yes. Copies of our respective qualification statements are attached to this supplemental testimony.

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What is the purpose of this supplemental testimony?

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e (All) The purpose of this testimony is to further respond to Suffolk i

A.3 is County Contention 13.

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Q.4 What does Contention 13 state?

t A4 (All) Contention 13 states:

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"Suffolk County contends that the QA program description for the opera-l tion of Shoreham, as provided in the FSAR, does not comply with 10 CFR 50.34(b)(6)(11) and 10 CFR 50, Appendix B, Sections I to XVIII, with regard to:

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Failure to address, at a minimum, each of the criteria in Appendix B (a) l in sufficient detail to enable an independent reviewer to determine whether and how all the requirements of Appendix B will be satisfied; l

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Failure to provide for the adequate identification, reporting and f

(b) analysis of all equipment failures discovered during operation and maintenance at Shoreham and at other operating BWR stations with i

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similar equipment; I

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Failure to er.sure that replacement materials and parts of systems i

(c) f classified as components "important to safety" will be equivalent to l

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4 the original equipment, that replacements will be installed in accordance with adequate process procedures, and that the repaired.

or reworked structures, systems, or components will be adequately inspected, tested, and' documented in "as-built" drawings; and (d) Failure to provide an adequate number of qualifted QA/QC personnel on the operating staff, including the availability of QC personnel on off-shifts."

Q.5 Please summarize the staff's previous testimony regarding Contention 13.

4 A.5 (Greenman) The staff's previous testimony addressed the NRR review of FSAR Section 17.2 which incorporates the LILCO QA program description.

The testimony concluded that the FSAR QA program description provides the necessary controls describing how the program will be carried out 4

i to satisfy Appendix B to 10 CFR 50 and the acceptance criteria in the i

Standard Review Plan, Section 17.2.

The testimony included the NRR review and assessment of the LILCO program for feedback of operating experience. Although the final procedures had not been completed at the time of the NRR review, the testimony concludes that when the LILCO commitments are implemented in the Shoreham Administra-tive Procedures, the program for feedback of operating experience will satisfy Item I.C.5 of NUREG-0737.

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e The testimony.alse included the review of technical and quality assurance requirements for safety-related replacement materials and parts as well.

i as the review of whether there are adequate numbers of qualified QA/QC' s

personnel on the operating staff. The testimony concluded that the

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commitments in the FSAR Section 17.2 provided for the proper procurement

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documentation and control of those materials and components necessary for j'

t-plant maintenance and modification, which includes replacement materials and parts of safety-related plant items. The testimony further concluded

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n that the onsite QA/QC staff as committed to in FSAR Figure 13.1.2-1 is adequate to properly carry out the QA program.

r Did the previous staff testimony indicate that further Region I reviews Q.6 or evaluations would take place?

A.6 (Greenman)Yes. Previous staff testimony stated that:

a)

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2$7 Region I would review and evaluate both the QA Manual e,

and QA implementing procedures for acceptability and for conformance with both 10 CFR 50, Appendix B, and the FSAR commitments.

b)

(Answer 28) Region I would inspect Applicant's procedures for imple-menting feedback of operating experience in order to insure that they s

are prepared as described in Applicant's responses to Item I.C.5. of c,

NUREG-0737.

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c)

(Answer 33) Region I would review and evaluate Applicant's procedures for. procurement and spare parts control to ensure that they properly implement various requirements and commitments.

d)

(Answer 34) Region I would continually monitor through: inspections whether App 1tcant's OQA staff was adequate.

Q.7 Have the reviews and evaluations summarized in A.6 occurred?

A.7 (Greenman)Yes. During November 29 - December 15, 1982, as part of the routine inspection program, Region I conducted an inspection to assess the readiness of the applicant's Quality Assurance Program for operations.

The staff's findings are set out in Inspection Report 50-322/82-34. A copy of that report was previously provided to the Board and all parties-and should be marked as Attachment "A" to this testimony.

Q.8 Describe the scope of the inspection which resulted in the Inspection Report No. 50-322/82-34.

A.8 (All) The inspection evaluated the adequacy of the LILCO QA Program Manual and QA department implementing procedures for the operational phase to determine compliance with regulatory requirements and FSAR commitments.

The specific areas that were inspected are described in the inspection report summary.

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7-Q.9 Please summarize the staff's findings as a result of the routine in-spection conducted during November 29 to December 15, 1982.

-I A.9 (All) When the NRC staff's routine inspection 50-322/82-34 was conducted, ll 0

LILCO stated.that Shoreham would be ready for a fuel load date of ji

'i February 23, 1983. What the inspectors found was that the overall com-

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plation status of the ' operations QA program for Shoreham did not support the stated date. The inspectors' opinion is that the inspection was con-ducted prematurely relative to the actual QA program completion status.

Numerous items were identified during this selective sampling inspection l

that require more work or corrective action by LILCO before a decision is made on the issuance of an operating license. These items are listed in the table at the front of the inspection report.

NRC Region I will examine LILCO's corrective actions in the future after the meeting held with the applicant, as requested in the Region I letter dated January 3, 1983, from T. T. Martin to M. S. Pollock, Vice-President-Nuclear, and

1) LILCO's Quality Assurance audits have been performed to determine readiness for operations, 2) LILCO's management has confirmed the adequacy of the corrective actions taken, and 3) has notified Region I of their determination, i

Q.10 As a result of the staff's inspection conducted during November 29 thru December 15, 1982, does the staff have an overall conclusion regarding i

l Contention 13.

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r A.10 (All) Our specific overall conclusions relative to SC Contention 13 are based upon our inspection efforts and findings as described in the Inspection Report and our answer to Q.9:

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(a) The overall independent determination is that the Applicant's OQA program is generally in agreement with regulatory requirements.

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Some parts of the Applicant's program were under development or in need of further revision. Specific items that require correction and further Region I review are listed in the table at the front of Inspection Report 50-322/82-34. The procedures listed in Inspection Report 50-322/82-34, paragraphs 4.2.3.1, 5.2, 6.2, 7.2, 8.2, 9.2.1, 9.3.1, 9.4.3, 10.2, 11.2, 12.2, and 13.2, were reviewed to determine whether they were consistent with both 10 CFR 50, j

Appendix B and FSAR commitments, as applicable. With the exceptions identified in the report and the corrective actions required of LILCO as discussed 1.i paragraphs 4.2.3.3.2, 5.4, 6.4, 7.4, 8.4.1, 10.4.1, 11.4.2, 11.4.3 and 12.4.1, the reviewed procedures were found I

to be in general agreement with applicable requirements of both 10

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CFR 50, Appendix B and the FSAR.

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(b) The Applic. ant's program fo: identification, reporting and analysis of failures discovered during operation and maintenance at Shoreham as E:

well as assembling other pertinent industry data, meet's regulatory F

50-322/82-34.

requirements based upon the sample taken during inspection

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9 As noted in Inspection Report 50-322/82-34, paragraph 9.4, the

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Shoreham Independent Safety Engineering Group (ISEG) program is established and in operation to receive, evaluate and screen industry.

operating experience information including information received from INPO "See-In"; Nuclear Power Experience; NRC bulletins, circulars and-information notices; and Shoreham LERs.

ISEG information output on industry operating experience goes to the plant manager and others, including the plant training supervisor for inclusion in a training reading list for operators as well as the training and retraining j

programs for the station operating staff.

(c) The licensee's programs for safety related replacement materials meet regulatory requirements based upon the sample taken during inspection 50-322/82-34 with the exception discussed in paragraph 12.4 and 12.4.1 of the report. Procedures for site procurement activities have been developed and are being implemented by the plant staff; however, the Engineering Departments' procurement proce-dures were draft documents. Although in draft form, the i

procedures were revised in response to inspector comments. The i

draft procedures were restructured to address whether. purchased materials, parts, and components associated with Safety related items would be: 1) purchased to codes and specifications at least equivalent to or better than those of the original equipment; 2) adequately documented to show compliance with applicable specifications, codes and standards; 3) manufactured or fabricated under quality control at least equivalent to that of the original equipment (source l

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10 inspection and vendor evaluation); 4) adequately inspected, d

identified and stored to provide protection against damage and f

misuse; 5) adequately controlled to ensure the identification, Assuming segregation, and disposition of nonconforming materials.

approval of these procedures, a satisfactory procurement program can I g

be acceptably implemented.

An inspection of this area will be required to verify the adequacy of the licensee's procurement program.

Operating QA/QC staff are qualified in accordance with regulatory (d) requirements and adequately staffed with respect to the Fruvisions have been responsibilities delegated and duties assigned.

Reference to established to assure QC availability on off-shifts.

the inspection report 50-322/82-34, paragraphs 4.2.1, 4.2.2.1, 4.2.3.2.1, 4.2.3.3, 4.2.4, 4.2.5 and 4.2.6.

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PROFESSIONAL QUALIFICATIONS OF EDWARD G. GREEIMAN EXPERIENCE:

. November 1982 -to Present: Branch Chief, Projects Eranch 1. Division ~of Project and Resident Programs, Region I, NRC Responsible for and management of a Branch involved in resident inspection.-

at power reactors and. construction sites to assure safety and verify ccm-pliance with regulatory requirements.

Project Branch inspection respons-ibil'ities include management systems, test programs plant systems, operations and coordination of regional specialist inspections.

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. March to November 1982: Acting Section Chief. Facilities Radiation Protection j

~Section, Division of Engineering and Technical Programs, Region I HRC i

Responsible for management of inspection program for inspection of radio-i logical protection areas at power and test reactors, fuel facilities and j

reactors in construction status.

1 June to November 1982: Technical Assistant, Division of Engineering and Technical j

. Programs, Region I, NRC

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4 Responsible for assistance in formulation of Division m11cies, guidance'.

SALP and assessment / evaluation of technical issues wit 11n the Division. Con-ducted and/or supervised assigned special projects, inspections, safety 4

analyses or investigations. Responsibility for appraising and making recomendations for improving the effectiveness and efficiency of the Regional inspe: tion and licensing program. Advised the Director on technical policy i

and administrative matters.

1981 - March 1982: Chief, Reactor Projects Section 2A, Division of Project and Resident Programs, Region I, NRC i

Responsible for management' of a project section for inspection by and l

supervision of a resident section for safety inspections of four power reactor sites including two facilities under construction, including integration of j

regional inspections and evaluation of findings.

1980 - 1981:

Chief. Nuclear Support Section No. 2 (Supervisory Nuclear Engineer)

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Reactor Operations and Nuclear Support Branch, Region I NRC t

i Responsible for supervision of a section p'oviding engineering support on r

reactors in operation and test status. Supervised research reactor projects.

j Specialized inspection in Quality Assurance, Surveillance, Calibration and j

operating procedures.

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PROFESSIONAL QUALIFICATIONS-GREE! MAN 1978 - 1980:

Senior Resident Inspector "each Bottom Atomic Power Station. Reactor Operations and Nuclear Support Branch. Region I. MRC Implemented initial Resident Inspection Program at site. Responsible for conducting safety inspections, managing the inspection program, coordinating the efforts of other NRC inspectors at the Peach Bottom Atomic Power Station.

Provided supervision of two resident inspectors and resident office.

Participated in evaluation of Quality Assurance and Perfonnance Appraisal activities.

l ProjectInspector-ProjectSectionNo.2.Reactordperationsand 1972 - 1977:

Nuclear Support Branch. Region I. NRC Responsible for coordination, review and conduct of power and research reactor inspections. Project assignments included six power reactors and various research reactor projects, and evaluated and conducted operational Quality Assurance inspections. including Millstone and Oyster Creek.

Developed preoperational test program for Columbia Triga Reactor.

1962 - 1972: Associate Instructor. US Atomic Energy Commission. Iowa State University Institute for Atomic Research - Iowa State University - Chief Operator Ames Laboratory Reactor Supervisor. Developed fuel handling manuals and Radiation Protection Program for PWR utility. Reactor Operator.

Senior Reactor Operator.

1961 - 1962: Reactor Operator - Argonne National Laboratory Design and construction of Janus Reactor. Qualified CP-5 and EBWR reactor operator. Developed and published Reactor Operator Training Program.

EDUCATION:

Graduate Study (Nuclear Engineering. Iowa State University. 1970-1972)

BS - Industrial Engineering - Iowa State University 1970 BS - Industrial Adninistration. Iowa State University 1970 PROFESSIONAL SOCIETIES:

Society of Technical Writing 3.. * *

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DONALD L. CAPHTON PROFESSIONAL QUALIFICATIONS REGION I U.S. NUCLEAR REGULATORY COMISSION a

My name-is Donald L. Caphton.

I as a professional Engineer.

I am Section Chief in the Engineering Programs Branch, Division of Engineering & Technical Programs, assigned to the Philadelphia, Pennsylvania Region I office. As Section Chief I'have current responsibilities for supervising inspections of reactors in Region I in the area of Management Programs and Quality Assurance.

J I served in the U.S. Arg in 1946 and.1947 assigned variously to the Signal Corps, l

Military Police and Ariqy Intelligence.

I was graduated in 1951 with a Bachelor's degree in Mechanical Engineering from, Clemson University.

to work at the Savannah River Plant (SRP)y from 1951 through 1968 and was assigned I was employed by the E. I. DuPont Compan as follows:

DuPont Engineering Department (1951) - Construction Division as a construction engineer in the construction of a heavy water manufacturing plant, as a principal construction engineer in the construction of SRP heavy water nuclear reactors and included quality inspections to vendor plants supplying reactor equipment.

DuPont Engineering Department (1953) - Development Engineering Division as a design and developmental engineer for reactor components and systems; i

DuPont Works Technical Department (1955) - Reactor Technology Section as an engineer providing engineering support and doing process improvement studies relative to the operations of heavy water reactors; l

DuPont Production Department (1956) - as a reactor supervisor and performed various responsibilities including the operation of heavy water nuclear reactors, participated with others and was a principal in the design and development of the procedural system used by SRP reactors, including the procedural bases, performed safety audits of operating reactors, and developed and conducted reactor oriented training programs-to SRP reactor operating personnel.

l In August 1968. I joined the Atomic Energy Connission's Division of Compliance as a Reactor Inspector.

During sqy time in this assignment I was the principal inspector for Qyster Creek, Saxton, Maine Yankee, Pilgrim I, Shoreham, PeachBotton 2 and 3, and a number of research reactors.

In November 1972 I was promoted to Senior Reactor Inspector and in January 1976 to Section Chief.

During this time I have had project responsibility for supervising the inspections of all Operating Boiling Water Reactors in Region I.

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In 1977 I assumed insp:ction responsibilities for the Region I Nuclear Support Inspection Program for reactors in the preoperational and power testing phase, containment testing, reactor engineering, seismic restraints and supports and refuelings.

In 1981, I assumed inspection responsibilities for the Management Programs and QA area for reactors in, Region I.

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PROFESSIONAL QUALIFICATIONS

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-l GEORGE NAPUDA

. d Management Reactor Inspector / Lead Reactor Enoineer (Quality Assurance anEvalu coerience Programs). NRC-RI. King of Prussia. Pennsylvania _.

ce Program and assess adequacy of implementing procedure 974-83 t tup and operations program implementation during the design, construction, s arPartic and i

phases of power reactors. Performance Appraisal Team (1981 tem for region based QA Program inspections and member of in t

Areas of responsibility included design change / modifications dits.

organization, inspection, surveillance, records and au

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Quality Assurance Engineer, pSE&G Co., Newark. N.J. (Salem j

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audits and surveillance of construction activities, superv se h AEC inspectors.

i 1972-74 to develop permanent records system, and was liaison wit k force visit-Performed corporate audits of PSE&G site QA, participated in tas A

ual.

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ing other similar sites, and co-authored operations Q man Offical.

C!uality Assurance Specialist. DCAS-D00. Sp i

that facility that manu-

1969-72 manufactured nuclear components, and also at multi-plantDevelop c

j Quality Assurance Representative. DCAS-D00. Sprinoffeld. N.J._

factured aerospace items.

l commodity items.

non-resident field inspector for Nav-Ships, medical and genera Program 1967-69 Developed and maintained the government Procurement Qua for over 40 assigned vendors. Presented administrative / management syste at vendor facilities.

Tool. Die and Gagemaker. Picatinny Arsenal-MUCOM Dover. N.J Weapons to other inspectors.

Leader of machinists / toolmakers i

1Fesearch, development and manufacturing.

1963-67 under a work groups system of job assignments.

aid trial Education Fairlef ah Dickinson University, Florham-Madison, N.J._

M - n us BA-Liberal Arts, Psychology,1971.Fairlef ah Dickinson University. Florham-Madison, N.J Journeyman Toolmaker Certift-l

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1963.

Picatinny Arsenal Toolmaker School. Dover N.J_.cat 1968.

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Pre-Dental (38 credits), 1951.

Franklin and Marshall College. Lancaster. Pa._

Bio-Chemistry (17 credits),

penn State University. Schuylkill County Campus. Pa.

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1949.

PSE&G/NRC, Nuclear Power Plants, 420 hours0.00486 days <br />0.117 hours <br />6.944444e-4 weeks <br />1.5981e-4 months <br />,1972-83.

D0D/AS0C/PSE&G/NRC, Quality Assurance / Control and Man Training D00, Welding and Nondestructive Examination, 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br />, 1 280 hours0.00324 days <br />0.0778 hours <br />4.62963e-4 weeks <br />1.0654e-4 months <br />, 1967-81.

@, Inspection and Measuring Techniques 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br />, 196 Operational-QA Societies American Society of Quality Control, active member of Committee and Configuration Management Sub-Committee.

250-1500-1, and Army Materials Qualified by Naval Examiner to Nav-Ships 1468-9 as Liquid Research Center Examiner to Military Standa I Test l

Certificates Inspector. 1971-72.

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PROFESSIONAL QUALIFICATIONS OF NORMAN BLUMBERG U. S. Nuclear Regulatory Commission Region I Division of Engineering and Technical Programs n

Experience Lead Reactor Engineer, Management Programs Section - Plans and April 1982 to performs inspections of reactor plants to determine adequacy of licensee's controls and provisions for overall operational safety; Prasent and evaluates licensee management, organizational controls, pro-

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cedures and practices to ensure operational safety and observance

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Acts as lead inspector during team of regulatory requirements.

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inspections and supervises activities of other inspectors during i~

Prepares reports of inspection activities (NRC).

inspections.

Reactor Inspector _- Conducted inspections of operating reactor plants to assure safe operation and for adherence to NRC regulations 1978 - April 1982 and plant operating and quality assurance requirements within scope p

of their license (NRC).

Nuclear Power Engineer - Norfolk Naval Shipyard, Portsmouth, VA.-

For seven U) years served as a test engineer and chief test engineer 1967 - 1978 Qualified on overhauls and refuelings of various nuclear submarines.

In charge of establishing all reactor on $5W and 53W reactor plants.

plant overhaul conditions, system operations, and reactor plant startup,

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testing, and operations and preparations of reactor test and operating For four (4) years served as quality assurance engineer procedures.

performing audits', analyzing nuclear procedures and work methods, and developing and improving shipyard quality control program concerned with overhaul of nuclear powered ships (NNSY).

First LT. - U.S. Air Force - Speciality in nuclear weapons maintenance.

Served with Defense Atomic Support Agency in capacity of technical 1962 - 1966 manual review, worldwide inspections, operations and plans, and quality assurance and maintenance at Depot level for nuclear weapons storage.

Active duty stations include Sandia Base New I4exico and Greece (USAF Engineerint Aide - National Bureau of Standards Washington, D.C.

Summer aide in soils and concrete testing laboratory (NBS).

l 1959 - 1961 B.S. Chemical Engineering, University of Maryland,1962 Education

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