ML20053E598
| ML20053E598 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/02/1982 |
| From: | Crossman W, Stewart R, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20053E594 | List: |
| References | |
| NUDOCS 8206090057 | |
| Download: ML20053E598 (118) | |
Text
.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
TEXAS UTILITIES GENERATING COMPANY, Dockets Nos. 50-445
-et al.
)
50-446
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
AFFIDAVIT OF WILLIAM A. CROSSMAN, ROBERT C. STEWART AND ROBERT G. TAYLOR CONCERNING CONSTRUCTION OF THE COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2
[ Contention 5]
8206090057 820602 PDR ADOCK 05000445 0
PDR p
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING COMPANY, )
Dockets Nos. 50-445
-et al.
)
50-446
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
AFFIDAVIT OF NRC STAFF (REGION IV)
REGARDING CONTENTION 5 I.
INTRODUCTION Q.1.
Mr. Crossman, please state your n.ime and position with the NRC.
A.1.
My name is William A. Crossman.
I am Chief, Reactor Project Section B, Reactor Project Branch 1, Region IV, United States Nuclear Regulatory Comission, Arlington, Texas. A copy of my professional and educational qualifications is attached to this testimony.
Q.2.
What is the nature of the responsibilities you have had regarding Comanche. Peak Steam Electric Station (" Comanche Peak" or "CPSES").
A.2.
During the period relevant to this affidavit and up until March 7, 1982, I was responsible for the supervision of the project inspectors who inspected nuclear power plants under construction j
4 I in Region IV, including Comanche Peak.
I am now responsible for the supervision of project inspectors who inspect other nuclear power plants under construction in Region IV.
Q.3.
Mr. Stewart, please state your name and position with the NRC.
A.3.
My name is Robert C. Stewart.
I am a Reactor Inspector, U. S.
Nuclear R2gulatory Commission, Region IV (Arlington, Texas),
Division of Resident, Project and Engineering Programs, Reactor Project Branch 1, Reactor Project Section A.
I am responsible for coordinating all safety-related inspections for facilities assigned to me within NRC Region IV. A statement of my professional and educational qualifications is attached to this affidavit.
t Q.4.
What is the nature of the responsibilities you have had regarding the Comanche Peak Steam Electric Station?
t A.4.
I was the principal inspector from June 1974 to January 1978, during which time I had responsibility for coordinating all l
safety-related inspections of Comanche Peak construction.
1 During that period of time, I performed or participated in numerous inspections of Comanche Peak construction.
I also conducted special investigations concerning allegations of improprieties in Comanche Peak construction.
. Q.5.
Mr. Taylor, please state your name and position with the NRC.
A.S.
My name is Robert G. Taylor.
I am the Resident Reactor Inspector at the Comanche Peak Steam Electric Station, Glen Rose, Texas. A statement of my professional and educational qualifications is attached to this testimony.
Q.6.
What is the nature of the responsibilities you have had regarding Comanche Peak?
A.6.
I have been the resident reactor inspector since 1978. During that time, I have had responsibility for coordinating all safety-related inspection efforts by NRC Region IV at the site.
In addition, I maintain a field office, develop and recommend enforcement action, and act as a liaison with regional, state, and local agencies.
Q.7.
What is the purpose of this affidavit?
A.7.
(Crossman, Stewart and Taylor). This affidavit addresses Contention 5 of Citizens Association for Sound Energy (CASE).
Contention 5 states as follows:
i The Applicants' failure to adhere to the quality assurance / quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construction practices employed, specifically in regard to concrete work; mortar blocks; steel; fracture toughness testing; expansion joints; placement of the reactor vessel for Unit 2; welding; inspection and testing; materials used; craft labor qualifications and working conditions (as they may affect QA/QC) and training and organization of QA/QC personnel, have w--
_n
,.ng n--.
. raised substantial questions as to the adequacy of the construction of the facility. As a result, the Commission cannot make the findings required by 10 CFR 9 50.57(a) necessary for issuance of an operating license for Comanche Peak.
We have also been asked to determine if the facts presented in the Applic:- ts' " Statement of Material Facts As To Which There Is No Genuinc Issues To Be Heard," May 10,1982 (hereafter "Appli-cants' Statement of Material Facts") are correct and if the NRC Staff supports the Applicants' position.
Q.8.
Have you read the Applicants' Statement of Material Facts and do you concur with that Statement?
A.8.
(Crossman, Stewart and Taylor). Yes. We have read that Statement.
Paragraph 10 of the Applicants' Statement of Material Facts states that the unresolved matters concerning the concrete pour on the Unit 1 dome will be the subject of resolution following completion of standard structural integrity tests on both primary reactor containments of Units 1 and 2.
We wish to clarify that while structural integrity tests will be performed on both Units 1 and 2, the unresolved matter concerning Unit I will be resolved by i
the tests on Unit 1 only.
We concur with the other information presented in Applicants' l
Statement of Material Facts.
i l
Q.9.
How is this affidavit organized?
I
. A.9.
(Crossman, Stewart and Taylor).
In Section II, Mr. Crossman discusses the role of NRC Region IV during the construction phase of a nuclear power plant. Since the thrust of CASE Contention 5 relates to the adequacy of the quality assurance / quality control (QA/QC) programs during construction of Comanche Peak, he has also included a general surnary, in Section III, of the role that the NRC plays in reviewing the development and implementation of the QA and QC programs during construction, and the specific results of that inspection effort at Comanche Peak.
In Section IV, Messrs. Taylor and Stewart respond to specific concerns raised in CASE Contention 5, and summarize the results of routine inspect-ions and investigations conducted by Region IV of Comanche Peak construction.
In Section V, we all join in the conclusions regarding CASE Contention 5.
II. ROLE OF NRC DURING CONSTRUCTION Q.10. Describe the overall approach of the NRC licensing program.
l A.10.
(Crossman) Each NRC applicant is responsible for assuring that its nuclear power plants are built and operated safely and in con-formance with the NRC regulations. An applicant also is required to assure that its suppliers meet the applicable NRC criteria.
In this respect an applicant is responsible for functions such as product inspection and nondestructive testing of reactor components, structures, and systems even though it may, on occasion, delegate the actual performance of the activity to another organization.
I
-. - y -
--~c. _ m _-, n. --
- - - ~ ~ ~ ~ - -. -
.~.,,--
, NRC looks to the power plant owners, the utilities themselves, to take the leadership role in assuring the quality of their plants and operations. This requires careful attention to the selection of engineering specifications and Quality Assurance (OA) procedures and practices for each task and their implementation by the workers on the job. And, most importantly, there must be adequate resources of qualified personnel at management, operating, and staff levels.
The NRC places the highest emphasis on the active involvement of top management in QA programs. The NRC evaluates these programs, an applicant executes them, and the NRC assesses performance.
To meet the NRC's regulatory requirements, an applicant must develop and implement a pyramid control system which, at the bottom, assures, through detailed inspection and test programs, that all safety significant actions are properly done. These detailed verification programs require up to 100% inspection by an applicant's quality control personnel of a multitude of individual actions. These programs also provide the basis for accept / reject l
decisions on specific equipment, instrumentation, technician or operator actions, and procedures.
Moving up the pyramid, an applicant must have a quality assurance program which includes audits to oversee and test the adequacy of l
the performance of the detailed quality control tests and inspec-tions. These programs provide feedback to the lower level of this system in the form of specifying changes in training, modification of procedures, upgrading or improving testing methods or equipment,
. requalification methods, if required, and other programmatic improvements. This feedback assures and enhances the reliability of the program as a whole which, in turn, assures and verifies that all actions which are of safety significance have been, and will be properly carried out.
At the top of the pyramid, an applicant's management must provide adequate organizational independence and manpower for its quality assurance and quality control programs and provide policy guidance to all elements of an applicant's organization in order to assure quality perfonnance in all safety aspects of the construction and operation of its nuclear facility.
Another basic element of the NRC program is the defense-in-depth concept which requires multiple barriers and redundancy in equip-ment and operating options. This approach assures that, even if an item of equipment malfunctions or an incident of human error occurs, there will nevertheless be adequate protection of the public.
Q.11 What is the role of NRC Region IV in this program?
A.11.
(Crossman) Region IV's mission is to conduct inspections to assure that an applicant meets license and regulatory requirements as well as commitments in Safety Analysis Reports. Region IV takes i
enforcement action, where necessary, to obtain corrective action for specific or programmatic deficiencies. These Region IV activi-ties interface with the Office of Nuclear Reactor Regulation (NRR) l l
i whose mission is to evaluate the adequacy of an applicant's proposals and, upon approval, promulgate licenses and, where necessary, specify license conditions, amendments, and technical specifications. Simply stated, NRR evaluates what an applicant proposes, commits to, or is required to do, whereas the NRC regional offices inspect to determine that an applicant does what it is required or committed to do and takes enforcement action, if needed.
Q.12.
Is it the responsibility of the NRC regional offices to inspect each and every activity during the construction of a facility?
A.12.
(Crossman) No. The NRC regional offices are charged with providing assurance, through direct inspection, that an appli-cant's performance meets NRC's regulatory requirements and other commitments. Considering the extensive applicant control programs referred to above, the regional office inspection program may be viewed as the apex of the pyramid which provides overall assurances of adequate quality in the construction and operation of nuclear facilities. The object of the regional program is to assure that an applicant's program meets NRC regulatory requirements. The regional office inspection program is one of selective auditing and not 100% verification of all phases of an applicant's program. This inspection of hardware, observation of testing, review of procedures, and all other inspection activities are not aimed at approval of individual components, actions, or
. procedures, but rather, at evaluating whether or not an I
applicant's management control systams are working.
Whenever deficiencies are identified, the NRC requires an applicant to take action to prevent recurrence as well as to correct the specific deficiencies.
If the results of a single inspection, or a sequence of inspections, indicate a deterioration in the performance of an applicant's program in several areas, the NRC requires the applicant to examine its program in depth and upgrade the degree of control exercised at the highest level of the control system pyramid to assure that such deterioration is checked and the program as a whole returned to a satisfactory level of quality.
III. NRC INSPECTION OF QA/0C PROGRAM Q.13.
Please elaborate on the nature of the NRC regional inspection effort of QA and QC programs during construction.
A.13.
(Crossman) The NRC conducts periodic scheduled and unannounced field inspections of an applicant's QA program implementation as well as those of its contractors and suppliers. These inspections start prior to docketing of the application and continue throughout the construction phase, the preoperational test program, and the operating lifetime of the facility. The NRC inspection program is carried out by region based specialists and resident based
. int;pectors. The NRC inspection program is not designed to duplicate an applicant's QA program, or to perform a redundant, independent review of every accept / reject determination. Rather, it is a regulatory program aimed at determining, by spot checking and sampling, whether or not an applicant is in fact providing adequate assurance of quality in the construction and operation of its facility. The NRC audit or sampling program is not a statistical random sample. The specific areas reviewed in detail are selected from those considered to be the most important from a nuclear safety standpoint. By a specific spot checking and sampling review of QC actions we can, therefore, test whether an applicant's QA program is really working. Our review of the overall program gives considerable confidence that our spot checking and sampling review provides an accurate assessment of an applicant's perfonnance in meeting regulatory requirements.
The NRC enforcer..ent program complements the sampling or auditing inspection philosophy.
By assuring that upgrading of an appli-cant's program results from specific noncompliance identified by the inspector, continued reliance can be placed on the validity of NRC's inspections whicF place heavy emphasis on an evaluation of an applicant's quality assurance program.
Q.14. What areas are covered by the QA/QC inspection effort?
~, ~ _ - - -.
~ ~ _..
. A.14.
(Crossman)
Inspections conducted during the construction phase include:
(1) reviewing an applicant's QA performance including audits of an applicant's QA records and documentation; (2) witness-ing the construction practices and an inspection of the facility at various stages of construction; and (3) reviewing the qualifica-tions and training of the construction personnel (where require-ments exist) as well as those of the quality assurance and quality control (QA/QC) personnel.
Inspection reports, resulting from the above inspections, document inspection findings (items of noncom-pliance and deviations), as well as unresolved items. These items are entered in the Region IV tracking system and remain open until appropriately resolved.
Inspection of the implementation of an applicant's quality assurance program is a key element in the determination of its adequacy. This inspection activity, still a nonrandom sample, involves checking whether actual work activities are in accordance with procedures, license requirements, technical specifications, plans, and code requirements. NRC inspectors question craftsmen and operators to determine if they understand, and are adhering to, applicable limits and requirements. The NRC inspectors observe operating instruments and recorder charts to detennine that operations are being conducted within regulatory l
requirements. They observe instruments being calibrated.
Observations are made as equipment is started up, shutdown, or otherwise changed in the operating mode. These observations and
. l individual discussions with, and questions of, people actually doing the work provide a basis for determining how well an applicant is actually implementing its quality assurance program.
Q.15. What are the regulatory requirements against which QA/QC programs are inspected?
A.15.
(Crossman) The NRC's quality assurance requirements are contained in Appendix B to Part 50 of Title 10 of the Code of Federal Regulations, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." These criteria provide a basis upon which the NRC assesses the acceptability of QA programs. The criteria of Appendix B apply to all activities affecting scfety-related functions of nuclear power plant structures, systems, and components.
Q.16. Would you please describe what is meant by the terms " item of noncompliance" and " deviation", which appear in the NRC inspection reports?
A.16.
(Crossman) Yes, an item of noncompliance refers to an applicant's failure to comply with the various regulatory requirements of the NRC or the applicant's specificiations. During the time covered by this affidavit, such items were categorized into three levels of severity: violations, infractions and deficiencies. When any level of severity was found a Notice of Violation was attached to
_.___a
_e__ u ___.
. the Inspection Report wherein the item was reported and the level of severity was set forth.
A Violation was the most severe item of noncompliance and was issued when the fabrication, construction, testing or operation of a Safety Related Category I system was such that the function or integrity of the system was lost.
In contrast, an infraction was a less serious finding that a Safety Related Category I system was impaired, rather than lost.
A deficiency was an item of noncompliance in which the threat to the health, safety, or interest of the public was remote; defi-ciencies included such items of noncompliance as failure to follow procedures, and posting or labeling requirements which are not serious enough to amount to infractions.
In addition, at times an applicant would promise that certain controls or procedures would be implemented which were not required by the NRC. Nonetheless, when an applicant did not j
conform to its connitments to the NRC, even though such commit-ments were not regulatory requirements, such failure was cited and referred to as a deviation.
l The above classification system was revised in October 1980 to provide for six severity levels of violation.
(See the Federal Register, volume 45, No.196, October 7,1980). On March 9, 1982 l
l l
. the enforcement policy was revised to reduce the number of severity levels from six to five.
(See the Federal Register, volume 47, No. 46, March 9, 1982).
Q.17. Generally, what have been the results of the QA/QC inspections at Comanche Peak?
A.17.
(Crossman) The NRC inspections have identified items of noncom-pliance, deviations from commitments, and weaknesses in the QA/QC program, but in each instance the Applicants (Texas Utilities Generating Company, et al. or "TUGC0") have responded properly and taken adequate corrective action.
During December 1978, NRC regional inspectors performed an in-depth QA/QC inspection approximately mid-term through the construction period. No items of noncompliance or deviations were identified as a result of the inspection, which was documented in NRC Inspection Report 78-23.
i Assessments of the Applicants' performance on an annual basis have also determined that the Applicants have adequately developed and implemented a QA/QC program. The last Systematic Assessment of Licensee Performance ("SALP") for TUGCO, which is documented in NRC Inspection Report 81-20, reflected an overall Category I performance (the highest rating).
- ~...--.-
--. a -
. Q.18. Would you comment on the contractors that performed construction of Comanche Peak?
A.18.
(Crossman) TUGC0 began construction at the Comanche Peak site under a Limited Work Authorization (LWA) on October 17, 1974.
Further construction activities were ccmmenced when construction permits were issued on December 19, 1974.
Brown & Root Co., Inc., (B&R) has constructor responsibilities and has American Society of Mechanical Engineers ("ASME")
certification.
During the first 6 months of 1978, TUGC0 made a series of organizational changes which were considered to have a positive impact on the CPSES QA program. At the same time, Texas Utilities Services, Inc. ("TUSI") implemented comparable changes to exercise greater control over engineering and construction. The active management of the B&R QA/QC staff was assumed by TUGC0 except for that work accomplished under the ASME code certification program.
This reduced B&R headquarters QA involvement in on-site activitites. Also, at that time, TUGC0 assumed management of the on-site ' soils and concrete testing laboratory, formerly under a subcontract. A revised program description for QA during design and construction of CPSES was submitted to the NRC on September 22, 1978, and accepted by NRR on November 3,1978.
Region IV's audit of the CPSES QA program was completed in
~...
. December 1978 and the results are contained in NRC Inspection Report 78-23.
Westinghouse Electric Corporation (W) is Nuclear Steam Supply System (NSSS) supplier for the two four-loop pressurized water reactors rated at 1150 MWe each.
The architect-engineer (AE) with responsibility for design and engineering of the facility is Gibbs and Hill, Inc.
Freeze and Nichols (F&N) and Mason-Johnson Associates (MJA) were responsible for design, inspection, and testing of the Safe Shutdown Impoundment Dam. Specifically, F&N supplied the design and construction specifications and perfomed oversight of the construction. MJA provided geotechnical and inspection functions.
Q.19. What are your overall conclusions regarding the implementation of the CPSES QA/QC program?
A.19.
(Crossman) Issuance of construction permits to TUGC0 for the construction of CPSES was contingent on development of a satis-factory QA program. Subsequent to issuance of the permits and during construction, implementation of the program has been monitored by the NRC by review of further procedure development and observation of work activities.
1 l
17 -
Based on experience gained in the implementation of this QA program, as monitored by the NRC, TUGC0 revised certain aspects of their QA program in early 1978. These revisions, in the form of organizational changes (see A.13.), have essentially been in effect since mid-1978. Work accomplished prior to that time included only early civil construction activities and was concluded to have been perfomed satisfactorily. Subsequently, the major construction phases, such as piping, electrical, etc.,
have been perfomed utilizing the improved organizat*on.
Since 1978, the Applicants have initiated minor program revisions which have strengthened quality control.
The TUGC0 QA program has, to date, been detennined to comply with NRC QA criteria established in 10 CFR Part 50, Appendix B,
" Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." The TUGC0 QA program is interpreted to include their prime contractors, subcontractors, and vendors.
i In most cases, the Applicants' own QA program has identified and corrected significant construction deficiencies within the context of 10 CFR 50.55(e).
Additional inspections of the Applicants' QA/QC program by the NRC are planned. The NRC will ensure that satety matters identified during the past and subsequent inspections will be adequately
'N m..
- p.. w em e*
=~
. resolved prior to authorization for the Applicants to load fuel or operate CPSES.
IV. SPECIFIC CONCERNS RAISED IN CASE CONTENTION 5 Q.20. Gentlemen, what aspect of Contention 5 do you address here?
A.20.
(Stewart and Taylor) We address the NRC inspection and investiga-tion findings concerning the adequacy of the. Applicants' Quality Assurance / Quality Control (QA/QC) program with respect to the con-struction activities specified in Contention 5.
Each of these activities is addressed below.
CONCRETE Q.21.
Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of Applicants' QA/QC program with respect to concrete?
A.21.
Yes. The NRC inspections of concrete construction activities involve both the direct work and the Quality Assurance / Quality Cont ol (QA/QC) tests and inspections, including the installation f
l of the reinforcing steel; the mechanical splicing of the rein-l forcing steel into continuous lengths (usually by the proprietary process called "Cadweld"); testing of aggregates and cement; operation of the concrete batch plant and transportation of the I
. fresh concrete; the testing of the fresh concrete; the fonmvork before and during placement; the actual placement and consolida-tion of the concrete; and finally, the curing of the newly placed concrete.
Such inspections also included materials that are embedded in the concrete such as steel structures for subsequent attachments and electrical conduits.
From early 1975 to date, there have been in excess of 45 inspections of these activities covering both Units 1 and 2.
There was no set frequency for the inspections, but every effort was made to arrange the inspections to occur at the times when major activities were in progress.
Q.22. What have been the inspection findings with respect to the adequacy of Applicants' QA/QC program concerning construction activities involving concrete?
A.22.
(Stewart and Taylor) Approximately 75% of the routine inspections resulted in findings that the Applicants and their contractors had l
l complied with their commitments to fulfill the requirements of the Safety Analysis Report and Appendix B of 10 CFR Part 50. The other 25% of the routine inspections revealed either items of noncompliance or deviations. As might be expected, five instances occurred in 1975 when the concrete work was just getting undemay.
During 1976, only two such instances were identified and, in 1977, none. With the advent of the resident inspector at CPSES, the 1
I L
o instances of noncompliance or deviation rose to three, which probably reflects the increased time that was devoted to direct observation of the work.
In 1979 and 1980, there was one instance of noncompliance or deviation each year. A brief description of the negative findings follows:
A.22.a. (Stewart) NRC Inspection Report 75-05 documented a finding that an inspection procedure was not developed and implemented for activitics related to the excavation for the reactor containment structures of CPSES, Units 1 and 2.
A.22.b.(Stewart) NRC Inspection Report 75-06 findings included the following:
Construction department personnel were performing QC inspection and acceptance activities which were not designated functions of that organization.
Implementing Brown and Root (B&R) QC procedures or instructions were not available that would verify conformance with the requirements prescribed in B&R Construction Procedure CP-QC-14, " Concrete Inspection I
and Testing," dated March 6, 1975.
i l
l
1 f
4 Batch Plant QC inspection activities were conduhted
[
\\
t by individuals reporting to an organization whose functional authority was not independent of undue influence and responsibility for schedules and co::ts.
~
I A.22.c.(Stewart) NRC Inspection Report 75-10 findings included A
the following:
?
During concrete placement of the Unit I containment basemat, procedural requirements were not adhered to.
y.
Complete consolidation of the concrete was not
/
achieved between two adjacent concrete lifts resulting in a concrete " cold-joint." The matter had been identified by the Applicants.
3 g
During concrete placement of the Unit 1 containmzot basemat, batch plant tickets indicated that
'b i
l additional water was added to the concrete during the transit time of six trucks without the approval V>
of the designated R. W. Hunt Company inspector.
This matter was identified by the Applicants.
A.22.d. (Stewart) NRC Inspection Report 75-13 documented a finding that measures for initiating corrective action; i.e., Deviation and Disposition Reports and Corrective c-
.n___,_,._.,_,_,_---.__nn-_-
~. s l
g 4
s>.
t hetkJ, Reports, did not result in prompt corrective action, nor did the measures provided pre:lude repetition.
s -
~
A.22.e. (Stewart) NRC Inspection Report 76-01 findings included
\\ thel.follr. dng:
\\
}
s L
/
) The Applicants' contractor installed containment 5
i 1 _. \\
l.
building s'eivnic category Class I pipe restraint
'\\
s i
embediwithout prescribed documented instructions or j
j s
N
' ~'
}/
,s
,N work procedures.
+
i 3 The Applicants' contractor conducted QC surveillance l
l of the containment building seismic Category 1 embeds
,s.,.
installations without prescribed documented instructions or procecuras.
3
~
Tne Applicants' contractor conducted QC surveillance of the containment building steel liner installation without precribed documented instructions or proce-k
dures.
\\
~
~_
t l
,The Applicants' contractors did not incorporate l
l approved design changes into the applicable design S
33y specification and work procedures, respectively, as precribed by the CPSES QA plan.
I 4
4 t
l l
L
~
. A.22.f. (Stewart) NRC Inspection Report 76-07 findings included the following:
Procedures were not found to be in effect for control or inspection of important parameters involved in welding of safety-related components in the B&R Miscellaneous Steel Fabrication Shop. The components were Cadweld sleeves being welded to steel plates for subsequent embedment.
The Texas Utilities Services, Inc. ("TUSI") Site QA Supervisor failed to exercise delegated stop-work authority in relation to a noncompliance of which he was aware.
A.22.g.(Taylor) NRC Inspection Report 78-07 documented a situation in which the frequency of testing of fresh concrete prior to placement was not performed at the frequency required by the applicable American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section III, Division 2 which incorporates the requirements of the American Concrete Institute (comonly referred to as ACI-359).
A.22.h.(Taylor) NRC Inspection Report 78-13 found that samples for certain tests of frash concrete were not taken twice L
l r
,....w..
. during the discharge of the concrete from the delivery truck as required by ACI-359. The samples were taken just once from the initial discharge.
A.22.1. (Taylor) NRC Inspection Report 78-16 found the craft
" helpers" doing substantially all of the work in making a Cadweld splice without having been qualified as required by ACI-359.
A.22.J.(Taylor) NRC Inspection Report 79-03 contained an obser-vation that concrete was being segregated by impinging on reinforcing steel during a placement of concrete in the Unit 2 containment wall.
A.22.k. (Taylor) NRC Inspection Report 80-08 documents that the Applicants had failed to notify the NRC under 10 CFR 5 50.55(e) of a substantial amount of honeycombing that i
had occurred in several locations in the Unit 2 contain-(
ment building interior walls.
Q.23. Did the Applicants take corrective action as a result of these findings?
i A.23.
(Stewart and Taylor) Yes. The Applicants made commitments to take corrective actions as follows for each negative finding.
l These commitments were reviewed by Region IV management and by the a
)
. inspector to assure that the corrective action as stated would be effective and of a nature that could be verified.
A.23.a. (Stewart) The Applicants' responded to the findings related in NRC Inspection Report 75-05 by letter dated April 8,1975, and telephone conversation on April 17, 1975, as documented in NRC letter to the Applicants of April 22,1975, wherein commitments were made to initiate document revisions consistent with the current administra-tive controls for Class I structure excavation.
A.23.b. (Stewart) The Applicants responded to the findings in NRC Inspection Report 75-06 by letter dated May 29, 1975, wherein they stated that B&R procedures were revised to require total receiving inspection by the B&R QC inspection personnel; to require B&R QA/QC to perform surveillance on concrete batch plant certification and associated testing and inspections performed by the R. W.
l Hunt Company; and to identify divisions of #unctional implementation by organization.
Region IV acknowledged the Applicants' letter by letter dated June 6, 1975.
A.23.c.(Stewart) The Applicants responded to the findings in NRC l
Inspection Report 75-10 by stating that the defect would be repaired; that additional training would be given to craft personnel and their supervisors; and that additional t
l l
~ - -
m._._
j
. QC personnel would be assigned to large concrete place-ments to effect improved controls. The commitments were made in the Applicants' letter dated September 5,1975, to Region IV. The response was accepted subject to verifica-tion as discussed in the Region IV letter dated September 10, 1975.
It should be noted that such acceptance is always sub'ect to such subsequent verification of effecti'le implementation.
A.23.d. (Stewart) The Applicants responded to the finding in NRC Inspection Report 75-13 by letter dated January 15, 1976, wherein they comitted to correction of the physical probleras with concrete aggregates and to implementation of a program to assure a more tiriely resolution of the Deviation and Disposition and/or Corrective Action Reports. Region IV accepted the response with reservations as documented by a letter dated February 12, 1976.
l l
l A.23.e. (Stewart) The Applicants responded to the findings of NRC
{
l Inspection Report 76-01 in their letter dated February 27, 1
l 1976, wherein they stated that necessary procedures had been implemented and were utilized for certain reinstallation efforts. Region IV acknowledged the Applicants' letter by a letter dated March 10, 1976.
r
27 -
A.23.f.(Stewart) The Applicants responded to the findings in NRC Inspection Report 76-07 in their letter dated Sept' ember 2, 1976.
Region IV acknowledged the Applicants' response by a letter dated 1ptember 17, 1976. The Applicants had stated that necessary revisions to QC procedures had been implemented and the site QA supervisor had reassessed his responsibilities.
A.23.g. (Taylor) The Applicants responded to the findings in NRC Inspection Report 78-07 in a letter dated June 5, 1978, in which they stated that they would change from a concrete mix testing control concept back to a placement control of testing concept. The Applicants also stated that their review of the test data indicated that the concrete had been batched consistently and therefore, was adequate.
Region IV acknowledged the Applicants' letter by letter dated June 20, 1978.
A.23.h. (Taylor) The Applicants responded to the finding in NRC Inspection Report 78-13 in a letter dated October 18, 1978, in which they stated that the field testing personnel had been instructed, imediately, to fully adhere to the published procedures. A documented training and recertification was also accomplished.
In addition, a programed surveillance of the field was to be instituted.
1
-m g,
gg mm--
+-m
-m h e eM'*
- ee
. Region IV acknowledged the Applicants' letter by letter dated October 24, 1978.
A.23.1.(Taylor) The Applicants responded to the finding in NRC Inspection Report 78 K in their letter of December 8, 1978, in which they stated that the use of " helpers" to do Cadwelds had been stopped and that henceforth, only fully qualified "Cadwelders" would be utilized. They also stated that the applicable B&R procedures would be revised to reflect this change.
Region IV acknowledged the Applicants' letter by letter dated December 21, 1978.
A.23.j. (Taylor) The Applicants responded to the finding in NRC Inspection Report 79-03 in their letter of March 6,1979, in which they stated that the observed problem was corrected when detected by the NRC inspector and that the QC inspection procedures had been revised to provide increased emphasis on the control of concrete falling into the fomwork. Region IV acknowledged the Applicants' letter by a letter dated March 13, 1979.
A.23.k.(Taylor) The Applicants responded to the finding in NRC Inspection Report 80-08 in their letter of April 21, 1980, in which they stated that the appropriate 10 CFR 6 50.55(e) report had been prepared and fomarded to the NRC by a separate letter. The Applicants also stated that
their organizational personnel associated with reporting significant construction deficiencies to the NRC had been given clarifying instructions. Region IV acknowledged the Applicants' letter by letter dated April 30, 1980.
Q.24 Did the NRC staff conduct follow-up inspections to detennine whether the Applicants in fact implemented the corrective actions they represented they would undertake?
A.24.
(Stewart and Taylor) Yes.
It is standard staff practice to follow-up on each negative finding to assure that the Applicants have fulfilled their commitments and further that the commitments have been effective. Generally, the inspector who originally identified a given problem would also be the inspector who follows-up on the matter although sometimes this is not possible due to the unavailability of a particular inspector. Each nega-tive finding discussed previously was followed-up in accordance with this practice and the follow-up documented as follows:
A.24.a. (Stewart) NRC Inspection Reports 75-06, 75-07, and 75-09 documented the follow-up on the findings contained in NRC Inspection Report 75-05. The inspector verified that appropriate procedures for rock blasting had been developed and implemented.
_...... -.. ~. _.. - -..
. A.24.b.(Stewart) NRC Inspection Report 75-07 documented the follow-up for the two infractions and one deficiency con-tained in NRC Inspection Report 75-06. The NRC inspector verified the following:
(1) The B&R Procedure CP-QCP-14 was revised and the B&R site QC organization was realigned and the designated QC functions implemented.
(2) The revision of B&R Procedure CP-QCP-14 included implementing QC inspection procedures for inspection functions delegated to other organizations relating to concrete inspection and testing.
(3) The revision of B&R Procedure CP-QCP-14 established requirements for batch plant surveillance.
A.24.c.(Stewart) NRC Inspection Reports 75-12 and 75-13 document the follow-up of the infraction identified in NRC Inspection Report 75-10. The NRC inspector verified the following:
(1) The cold joint was repaired. Additional training was held and personnel coverage was to be increased on future large placements.
l
. (2) Documentation was reviewed to detennine that the water / cement ratio was not exceeded and compressive tests were witnessed by Gibbs and Hill QA staff and verified to meet design requirements. Additional training was held for construction personnel and the B&R civil engineering would undertake a first line inspection of the concrete truck discharge.
A.24.d. (Stewart) NRC Inspection Report 76-03 documented the follow-up on the finding contained in NRC Inspection Report 75-13. The inspector found that the Applicants had improved their perfonnance in the timely processing of Deviation and Disposition Reports and on Corrective Action Reporta. The effectiveness of the reporting system to prevent repetitiveness was also found to be improved.
A.24.e. (Stewart) NRC Inspection Report 76-03 documented the follow-up on the item in NRC Inspection Report 76-01 regarding the lack of installation and QC procedures for installation of containment embeds. The inspector verified that appropriate procedures had been utilized when the embeds were reinstalled.
A.24.f. (Stewart) NRC Inspection Report 76-10 documented the follow-up on the finding in NRC Inspection Report 76-07 l
l concerning the lack of welding process controls and the
l.
. failure of QA supervision to use "stop-work" authority.
The necessary procedures were found to be in place and effective. The supervisory situation was resolved by interview.
A.24.g. (Taylor) NRC Inspection Report 78-20 documented the follow-up on the finding in NRC Inspection Report 78-07 in regard to the improper testing of fresh concrete. The report documented a review of data generated by the Applicants which indicated that there was no technical consequence to the improper testing and that the concrete had been tested (although not in accordance with requirements). Observation of the practices followed by the testing personnel over a sustained period of time indicated that the requirements were satisfied.
A.24.h. (Taylor) NRC Inspection Report 78-20 also docusented the follow-up of the finding in NRC Inspection Report 78-13 in regard to the method of sampling fresh concrete for purposes of testing. The inspector reported that his l
observations over a 2-month period confirmed that the testing personnel were adhering to the procedures.
A.24.i. (Taylor) NRC Inspection Report 78-22 documented the follow-up on the finding in NRC Inspection Report 78-16 regarding use of Cadweld " helpers." The inspector m.
)
. reported that the " helpers" were no longer utilized and that governing procedures had been changed.
A.24.J.(Taylor) NRC Inspection Report 79-06 documented the follow-up of the finding in NRC Inspection Report 79-03 in regard to the segregation of free-falling concrete. The inspector reported that on the basis of his observations of subsequent concrete placements, the Applicants' comit-ment to enhance the awareness of their personnel in the placement practices had been effective.
A.24.k. (Taylor) NRC Inspection Report 80-11 documented the follow-up on the finding in NRC Inspection Report 80-08 in regard to the failure of the Applicants to report, in accordance with 10 CFR 9 50.55(e), the honeycomb problem in Unit 2 walls. The inspector established by interview of applicable personnel that they had gained a better understanding on the NRC requirements in regard to 50.55(e). The same report also included information concerning repair of the honeycomb condition and stated that the repairs had been effected in accordance with accepted methods.
Q.25. Do these inspection findings concerning construction activities involving concrete raise substantial questions as to the adequacy of construction?
. A.25.
(StewartandTaylor) No. In view of the corrective actions taken by the Applicants as a result of these findings, as verified by the NRC staff, these inspection findings do not raise substantial questions as to the adequacy of the construction of the facility.
Q.26.
In addition to the routine inspections described above, did the NRC staff conduct investigations of allegations of improprieties in construction activity involving concrete?
A.26.
Yes, in addition to the routine inspections described above, a number of investigations have been conducted of alleged impro-prieties in construction activities involving concrete.
Q.27.
Please describe the nature of the allegations investigated and the investigation findings.
A.27.a. (Stewart) NRC Investigation Report 77-02 discusses an allegation of the falsification of concrete air entrainment test records reported by the Applicants. NRC findings reflect that the R. W. Hunt inspector changed an air entrainment test record to read 4.0% rather than the i
l actual test reading of 3.9%.
This had little effect, if any, on the approximately 10 cubic yards of concrete placed. However, during the course of the investigation, mm
. two items of noncompliance and one deviation were identi-fied by the NRC inspectors. These items related to QA programatic matters and were not directly associated with the alleged falsification. These matters were as follows:
(1) The R. W. Hunt Co. had a Level I inspector perfonn concrete cylinder compression break tests and aggregate sieve analysis without evidence of demonstrated proficiency and approval in accordance with R. W. Hunt Co. procedure requirements.
In addition, the minimum information required to appear on the certificate of qualifications for onsite Level I and II inspectors, with regard to demon-strated proficiency, was not apparent.
(2) The R. W. Hunt Co. field representatives had not imediately reported verbally to Brown & Root Co. an employee's alleged falsification of test records, although the matter had been identified in a hand-written memo, dated January 20, 1977, and was con-tained in the individual's personnel record folder.
The R. W. Hunt Co. Procedures Manual requires that noncompliance matters shall be imediately reported, first verbally, and imediately thereafter, in a report form directly to the B&R QA Manager.
~
. (3) The R. W. Hunt Co., had in their manual, negated the two (2) year experience requirement for laboratory personnel, contrary to the CPSES PSAR connitment to the ASME Section III, Division 2 Code, which requires the completion of the 8th grade plus 2 years of experience as a minimum requirement.
The Applicants responded to the findings in the above NRC Investigation Report 77-02 by letter dated April 25,1977, (letter TXX 2303) wherein they stated that two Level I inspectors were temporarily removed from safety-related activites pending a review of personnel records; all training and certification records would be audited by B&R and updated as neces-sary; work perfomed by the Level I inspectors in question was found to be within specification requirements; B&R assigned a full time onsite civil QC engineer to work full time with R. W. Hunt Co.;
the B&R QA Manager directed R. W. Hunt Co. by letter to report immediately all test failures. The R. W.
Hunt Co. Procedures STCM 5.2, was revised to reflect the requirements of the ASME Code, i
l The response was accepted, subject to verification, by Region IV letter dated May 11, 1977.
.g-.
n
._~
. A.27.b.(Taylor) NRC In:pection Report 78-07 discussed an i
allegation that certain concrete laboratory test records were falsified. The investigation found no evidence that would substantiate the allegation, except in one case.
The one substantiated allegation related to the calibra-tion of a pressure gauge by an individual who was not properly certified. The test, hcwever, was found to have been properly perfomed by a competent person who was not, however, certified.
A.27.c. (Stewart) NRC Investigation Report 79-09 discussed allegations appearing in the Fort Worth Star Telegram on April 4, 5, 6, and 8, 1979, concerning concrete inspection and testing activities.
It was alleged that:
(1) Aggregate tests were falsified.
(2) Equipment used to test aggregate was unused.
(3) Shortcuts were taken on tests involving sizing of aggregate and moisture content.
(4) Truck drivers added excessive water to trucks in transit.
, _, r,,
r. -
m-
. (5) Concrete for turbine building placement was rejected, j
but placed anyway.
(6) Concrete for Unit 1 containment basemat was placed without testing.
(7) A truck load of concrete was placed in a containment building wall with a slump of 41" (4" maximum specified).
(8) Concrete cylinder compression strength test results were falsified at the direction of general foreman and laboratory manager.
(9) Concrete cylinder compression tests were run purposely faster than allowed.
(10) Recertification of R. W. Hunt inspectors were done "open book" with answers given.
The investigation of the ten allegations appearing in the news media was completed on May 7, 1979, and documented in NRC Investigation Report 79-07.
Eight of the allegations could not be substantiated, but a detailed investigation of all aspects of these allegations detennined that even if the practices in question had occurred, there would be L
_..m_
. no impact on the quality of concrete production. One remaining allegation was refuted. The other allegation was substantiated, but the practice involved had been previously identified and corrected.
A.27.d.(Taylor) NRC Investigation Report 79-11 discussed an allegation that a small amount of concrete was placed on the Unit 1 containment building dome under very unusual I
circumstances on a rainy evening in January 1979. The subsequent investigation substantiated the allegation and it was found that concrete was placed without the required inspection and testing of the concrete. A Notice of Vio-lation was issued to the Applicants for failing to fully implement their QA program. The Applicants responded to the findings in the above NRC Investigation Report 79-11 by letters dated June 12, 1979, (TXX 2998) and September 17, 1979, (TXX 3043).
In the June 12, 1979, letter, the Applicants stated that Texas Utilities Services, Inc. ("TUSI") engineering retained the services of an established materials and concrete consultant for the purpose of evaluating the inplace condition of that portion of the dome in question.
In addition, construc-tion concrete supervisory personnel were instructed to notify senior construction management prior to batching and placing concrete should a similar situation occur.
The Applicants stated in their letter of September 17, m-
. 1979, that the results of the investigation and evaluation by the consultant indicates the questioned concrete satisfies design requirements.
The responses were accepted, subject to verification, by Region IV letters dated July 5,1979, and October 10, 1979, respectively.
A.27.e. (Taylor) NRC Inspection Report 79-20, discussed an allega-tion, received in a letter to the Commission, that trash had been placed in concrete fomwork, and that concrete had been placed over the trash to cover it up. The building was identified as a containment building, but not which one.
It was alleged that the incident occurred during a drunken Christmas party in December 1978. The investigation revealed that the letter writer had heard the story from the father of the individual who was sup-posed to have participated in the party to the extent of driving the " drunks" home after work. The investigators interviewed the individual identified by the alleger as the source of the story, who promptly denied that the incident took place as alleged.
Further investigation determined that the alleged party had to have taken place on December 3,1978.
It was established that the source of allegation, although employed at the station, was, in fact, not at work that day. The interview with other
, persons known to have been associated with the concrete placement involved denied that there was a party during the placement. No items of noncompliance or deviations were identified.
Q.28. Did the NRC staff conduct follow-up inspections to determine whether the Applicants, in fact, implemented the corrective actions they represented they would undertake as a result of any adverse investigative findings?
A.28.
(Stewart and Taylor) Yes, as previously stated in A.23 above, it is standard staff practice to follow up on each negative finding to assure that the Applicants have fulfilled their commitments, and further, that the commitment has been effective. Generally, the inspector who originally identified a given problem would also be the inspector who follows up the matter although sometimes this is not possible due to the unavailability of the particular inspector. Each negative finding discussed previously was followed up in accordance with this practice and the follow-up documented as follows:
A.28.a. (Stewart) NRC Inspection Report 77-06 documented the follow-up on the finding contained in the NRC Investiga-tion Report 77-02. The inspector found that R. W. Hunt Co. had revised the certificates of qualifications for each inspector to reflect information as to each
- inspector's qualification and the basis used for certification.
It was also verified that R. W. Hunt Co.
Procedure STCM 5.2 was revised to reflect the requirements of Appendix VII of the ASME Section III Code, Division 2, and that the B&R QC Engineer conducted internal audits of R. W. Hunt Co. inspection personnel qualification records to insure compliance.
In addition, the NRC inspector found that the B&R QA Manager had directed, by letter dated March 7, 1977, the R. W. Hunt Co. Manager to report immediately all test failures. The NRC inspector also verified that B&R had assigned a full time QC engineer to assist R. W. Hunt Co. in maintaining project requirements.
A.28.b. (Taylor) NRC Inspection Reports 79-18 and 79-24 documented the follow-up on the findings contained in NRC Investigation Report 79-11. As documented in NRC Investi-gation Report 79-18, the NRC inspector interviewed the appropriate supervisory personnel involved and ascertained that necessary specific instructions had been issued and emphasized with regard to concrete batching and placing.
As documented in NRC Inspection Report 79-24, the resident reactor inspector (RRI) and the Region IV Engineering Support Section reviewed substantiating data provided by the Applicants, however, because of the unique sonic tech-nique used by the consultant engineer, the matter is being
.m..
. handled as an unresolved item pending further verification by the containment building structural integrity test.
Q.29. Do. the adverse investigative findings concerning construction activities involving concrete raise substantial questions as to the adequacy of construction of the facility?
A.29.
No.
In view of the corrective actions taken by the Applicants as a result of these findings, as verified by the NRC Staff, these inspection findings do not raise substantial questions as to the adequacy of the construction of the facility.
MORTAR BLOCKS Q.30. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC program with respect to mortar blocks?
A.30.
(Stewart and Taylor) No. The NRC inspection program for construction does not include an inspection of mortar blocks except as they relate to testing methods for cement and the water used in concrete. We are not completely familiar with the term "rortar block construction" but have assumed that it might be a reference to the use of precast concrete block construction sometimes referred to as " cinder block" construction. Such construction is frequently used in some parts of the country in k-6 4 WW68-M
- NO
-4= - -
. home construction and is used in nuclear plants, on occasion, to build walls of a somewhat temporary nature such as personnel shields covering entrances into potential radiation areas and as divider walls. Generally, they are not designed or used as structural members and carry little or no safety loads.
Mr. Taylor has done some research on this matter as it might concern Comanche Peak.
(Taylor)
Items 33 and 34 appearing on page 25 of CASE's answers to the NRC's Fourth Set of Interrogatories refer to mortar blocks in the walls of the control room.
I have reviewed the construc-tion drawings for the control room area to determine if there were any precast concrete blocks used and if so, the quality requirements imposed by the designer.
I found that for several walls, the engineer had spe:ified block walls as divider walls that in effect make small rooms out of a large roam. The large room is adjacent to the main control room and its walls are of reinforced concrete construction to seismic Category 1 standards.
Failure of the block walls within the large room would not jeopardize any of the equipment or personnel within the control room. The walls were not considered by the engineer to have any effect on safety and therefore, no quality assurance requirements were imposed on their construction.
Based on examination of the f
drawings and the rooms involved in the matter, I believe the engineer's action complied with NRC requirements.
L-
_ ~ - -.... _.. _..., _ _
m.
i STEEL Q.31. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC program in regard to steel?
A.31.
(Taylor) Yes, but let me clarify. Steel, along with concrete, is the most commonly used material of construction in a nuclear power plant. The reinforcing steel used in concrete construction is considered during the inspection of concrete work. Steel is used in piping systems and the support thereof and is considered during inspection of these elements. Likewise, a vast majority of the mechanical components are made of steel and that is considered during the inspection of the component and the related documentation.
In each case, the material quality is just <>ne relatively small phase of an overall inspection effort for a given category.
It is thus nearly impossible to estimate the number of inspections that have involved steel.
In reviewing the CASE answers to the NRC Staff's Fourth Set of Interrogatories, the instances cited that were categorized as dealing with steel as a material actually deal with the installation of components made of steel. Three of the instances which relate to the installation of concrete embedments have been discussed in the answers to questions 22, 23, and 24. Another instance, i.e., the difference between the actual method used to install supports for the reactor coolant pumps and the steam generators and the method depicted in
_ ---- _.~ - -
n.
. the Preliminary Safety Analysis Report ("PSAR"), is a fairly common occurrence since the PSAR usually is conceptual in nature (this is one of the reasons why there is also a Final Safety Analysis Report or "FSAR"). The remaining specific instance used to support the contention dealt with a finding in 1975 that B&R had not fulfilled a procedural commitment to independently test reinforcing steel but rather accepted the supplier's test results.
The B&R procedural commitment was in excess of that required by the NRC or by the engineering specifications for the project and was subsequently deleted from the procedure. The item was resolved to the staff's satisfaction as indicated by NRC Inspection Report 50-445/76-03.
In conclusion, we are not aware of any inspection findings dealing with steel that would indicate a failure by the Applicants to adhere to their commitments to the NRC.
FRACTURE TOUGHNESS TESTING Q.32. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC program with respect to fracture toughness testing?
l A.32.
(Taylor) Yes, but again I must clarify. Fracture toughness is a characteristic of steel materials and generally relates to a determination as to the temperature at which the made of failure w
s m
. of the steel to withstand an impact changes from brittle to ductile and the impact energy required to cause failure. All steel materials used in nuclear plants do not require such testing, only those that have a likelihood of having to withstand impact loadings. This is an engineering evaluation. The staff inspects for compliance with this requirement as an element of the staff's evaluation of the steel which in turn is inspected as discussed in regard to " steel."
Referring again to the CASE answers to the NRC Staff's Fourth Set of Interrogatories, it appears that one of the >riginal intervenors in this proceeding was of the ophion an equipment supplier should not perform the tests for fracture toughness of the materials in the reactor vessels, steam generators or the pressurizer. As a general rule, these tests are actually per-formed initially by the steel mill supplying the steel to the component fabricator since this steel characteristic is affected by the composition of the steel, the melting practices involved, and by the heat treatments given the steel during and after processing into its final form, in this case, plate steel. The steel mill is by far the most qualified party to perform the tests. The test is again repeated when the weld procedure for joining the plates is qualified. Generally, this test would be performed on materials that are comparable but not identical to the materials used in fabrication. NRC inspections have not identified any specific deficiencies in the Applicants' QA/QC program for fracture toughness testing.
-.18 PLACEMENT OF REACTOR VESSEL FOR UNIT 2 Q.33. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of Applicants' QA/QC program with respect to the placement of the reactor vessel for Unit 2?
A.33.
(Taylor) Yes. Although not an inspection specifically, NRC Inspection Report 50-446/79-03 discussed the. initial discovery by the Applicants that the supports and the periphery structure around the Unit 2 reactor vessel were rotated approximately 45*
from a usable position. The Unit 2 structure was mirror imaged from Unit 1.
Mirror imaging is a.comon engineering method of developing a second design from an original design provided that everything is completely symetrical.
(If one component is not symmetrical, mirror imaging will not work).
In this case, the Unit 1 and 2 reactor vessels are identical units but need to be placed in position 180* in rotation. Following the determination that the physical. structure (the supports and the periphery struc-
~ ture around the Unit 2 reactor vessel) could be rebuilt in a relatively short time, the Applicants' engineer devised the method which was coordinated with the design review personnel of the NRC.
A comprehensive inspection of the rework effort was documented in NRC Inspection Report 50-446/79-07. There were several short follow-up inspections by this inspector, culminating in NRC Inspection Report 50-446/79-13.
The entire reconstruction effort l
+. -
. including the engineering aspects took approximately three (3) months, ending with the placement of the vessel on its supports in June 1979.
l It was not shown that any specific failure by design QA or with l
construction QA/QC had occurred. From a design standpoint, the error in design had been through the entire design review process including interface review by the nuclear steam supply system (NSSS) vendor. The facility area had been constructed in accordance with the original design even though that design was incorrect.
It appeared that a very basic drafting concept error had been made early in the design effort for Unit 2 and was not detected in subsequent reviews, perhaps because of its very simplicity.
The matter was reported to this inspector and through him to other components of the NRC, but was not the subject of a 10 CFR 9 50.55(e) report by the Applicants. That provision of the regulations requires notification of deficiencies in design and construction, which if uncorrected, could have adversely affected the safety of operations of the nuclear power plant.
In this case there could not have been a safety problem with the reactor because, with the vessel rotated from its correct position, the reactor could not have been assembled into a system.
Q.34.
Do the inspection findings concerning construction activities that
~
s,
related to the placement of the reactor vessel for Unit 2 raise substantial questions as to the adequacy of construction?
A.34.
(Taylor) No. Based upon the actions taken by the Applicants in this matter, as reviewed for design by personnel of the Office of Nuclear Reactor Regulation and verified by the personnel of Region IV, there is nothing that would indicate that the as constructed placement of the reactor vessel in Unit 2 is less than satisfactory or unsafe.
WELDING s
~
Q.35. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC l
program with respect to welding?
l A.35.
(5tewart and Taylor) Yes. The NRC reactor construction inspection program included inspections of all safety-related
>t welding. Such welding included welding of reinforcing steel used
[
in concrete work; the welding of the seams in the containment
(.
i N
building liners; the welding of piping system components; and the r
N.) i
/
veelding of structural steel into component supports and
~
restraints. The inspections included all aspects of the welding,
\\
from the materials invcived to the finished weld. Also included was the qualification testing of welders; the qualification of f
nondestructive testing personnel and the application and results l
\\
l l
l i
1 c..
~ ~ ~ _ - - - - - -.
, of nondestructive testing activities. The inspections vary somewhat in depth, mostly depending on the importance of the welding activity. There is no set frequency for the inspections but every effort was and is made to arrange to have the inspections conducted to coincide with the early phase of a new welding activity and to have additional inspections of each activity as the work progresses. During the cerstruction of Comanche Peak, the staff has conducted some sixty-five (65) inspections dealing with various aspects of the Applicants'.
program for quality assurance / quality control of welding.
Q.36. What have been the inspection findings with respect to the adequacy of the Applicants' QA/QC program concerning construction activities involving welding?
l l
l A.36.
(Stewart and Taylor) Approximately 83% of tha routine inspections resulted in findings that the Applicants and their contractor had complied with their commitments to fulfill the requirements of the Safety Analysis Report and Appendix B of 10 CFR part 50. Approxi-mately 17% of the routine inspections revealed either items of noncompliance or deviations. We should point out that while B&R.
as the principal contractor at Comanche Peak is directly responsi-ble for the vast bulk of the welding activities, other contractors i
have also been involved in welding, both on-site and off-site.
Such contractors include Chicago Bridge & Iron Company for the containment liners and for certain off-site fabricated welded u
-n
,g q_
g
- steel components and ITT-Grinnell for performing off-site fabrication of pipe assemblies.
The Brown and Root (B&R) scope of work is such that several different craft groups were involved in welding such as ironworkers, mi11 wrights, and pipefitters. The QA/QC scheme within B&R for control of welding is essentially the same regardless of the craft type, but the specific application has varied depending on the welding processes involved and the construction activity at that time. The present system of controls has evolved from a relatively complex method of documentation to a less complex but more effective system. We would also like to point out that there are two primary code systems dealing with welding. The American Welding Society (AWS) is a code widely used throughout industry and in the nuclear field for structural welding applications. The American Society of Mechanical Engineers (ASME) also has a code system for welding that is widely applied in the manufacture and erection of pressure retaining systems such as boilers for heating and power generation. The parts of the ASME Code most used in the nuclear power industry are Sections III, V, and IX. The differences between the two codes in regard to control of welding processes and the qualification standards for welders are relatively insig-nificant. There is, however, considerable difference in the two codes with respect to the criteria for acceptance of a given weld, l
u
.m
. -..- m. m.
. particularly since the ASME Section III Code has. several subdivi-sions, each with its own inspection and acceptance requirements.
Thus, a QA/QC program for control of welding is necessarily complex because of such a variables. The following is a summary of the negative findings obtained during routine inspections of welding.
A.36.a. (Stewart) NRC Inspection Report 76-07 found that certain process controls were not established in an on-site Miscellaneous Steel Fabrication Shop. The components involved were used in the containment concrete reinforcing steel system and therefore, have already been discussed in answer 22.f.
A.36.b. (Stewart) NRC Inspection Report 77-10 discusses
- 1) welding procedures that the NRC inspector found were not available to the welders at the location of work activities associated with the installation and welding of the component cooling water system in the auxiliary building and 2) welding procedures that were not available at the nearest weld data card control location in the turbine building.
A.36.c. (Stewart) NRC Inspection Report 77-10 discusses an accepted field weld within the component cooling water system that contained an improper abrupt ridge.
..__.___.___m
. A.36.d. (Taylor) NRC Inspection report 78-05 contains an observation that counterbores in the pipe adjacent to the weld were not tapered back as the ASME Code requires.
A.36.e. (Taylor) NRC Inspection Reports 78-12 and 78-13 discuss a finding that welders were moving their welding torch at a speed less than the minimum allowed by the welding pro-cedure, thus, increasing the heat input to the weld zone and that this practice was not being controlled by the welder monitoring program.
A.36.f. (Taylor) NRC Inspection Report 78-18 discusses the travel speed problem again.
A.36.g. (Taylor) NRC Inspection Report 79-18 contains a finding that automatic welding machines were not calibrated.
I l
A.36.h. (Taylor) NRC Inspection Report 79-31 contains an observa-tion that type 306 weld metal was being used to tack up a weld joint preparatory to full welding when 316 type weld I
metal should have been used.
A.36.i. (Taylor) NRC Inspection Report 80-01 contains a finding that engineering had specified a weld size that could not be achieved with the metal thicknesses involved and was accepted by Quality Control after undersized welds were installed.
1
. A.36.j. (Taylor) NRC Inspection Report 80-13 discusses a finding that an incorrect weld process had been used in relation to procedural requirements for several passes in one weld.
A.36.k. (Taylor) NRC Inspection Report 80-18 discusses a finding that the Applicants failed to report to the NRC a problem with undersized pipe fillet welds.
A.36.1. (Taylor) NRC Inspection Report 80-23 discusses the finding that certain welds in vendor supplied components were not full penetration, as required.
A.36.m. (Taylor)
In addition, NRC Inspection Report 50-445/80-17 found that the machining adjacent to the weld zone of certain pipe elbow sections for the reactor coolant system piping was not in accordance with the. vendor's approved drawing. This finding was subsequently withdrawn as documented in NRC Inspection Repcrt 80-18 since the inspector erred in his interpretation of the drawing versus his observation of the as-built condition.
Q.37. Did the Applicants take corrective action as a result of these findings?
A.37.
Yes. The Applicants made commitments to take corrective actions as follows for each finding. These commitments were revieweo by
__ m m
m
. Region IV management and by the inspector involved to assure that the corrective action as stated would be effective and of a nature that could be verified.
A.37.a. (Stewart) The Applicants responded to the finding of NRC Inspection Report 76-07 in their letter dated September 2, 1976. Region IV acknowledged the Applicants' response by a letter dated September 17, 1976. The Applicants had stated that necessary revisions to QC procedures had been implemented.
A.37.b. (Stewart) The Applicants responded to the findings of NRC Inspection Report 77-10 by their letter dated November 17, 1977. That response was not considered sufficient and was supplemented by another applicant letter from the Appli-cants dated January 3, 1978. The Applicants stated that necessary corrective action had been taken and that an audit program had been instituted to prevent recurrence.
I A.37.c. (Taylor) The Applicants responded to the finding of NRC Inspection Report 78-05 in a letter dated May 4, 1978, in which they stated that counterboring tools had been reshaped to provide an acceptable bore-end configuration.
The letter also stated that the counterbore configuration in components manufactured prior to the finding were acceptable. Region IV in a letter dated May 12, 1978,
..z
. asked that the Applicants provide additional information regarding the acceptability of the early manufactured components. The Applicants responded by letter dated July 18, 1978, wherein they stated that they had satisfied the requirements of a later version of the ASME Code in order to satisfy the requirements for inservice inspection as required by NRC regulations and ASME Section XI. The Region IV personnel reviewed the Applicants' position and agreed that there was no sound technical reason for concern about the early components. The letter indicated that the Applicants' corrective action was satisfactory, subject to later verification.
A.37.d.(Taylor) The Applicants responded to the findings regarding welding that appeared in NRC Inspection Reports 78-12 and 78-13 (that were reported to the Applicants by Region IV letter dated August 30,1978), in their letter dated September 21, 1978. Region IV asked for additional infomation by letter dated October 10, 1978. The addi-tional infomation requested was data that could be verified by NRC inspections. The Applicants responded to the request by letter dated November 6, 1978. Region IV acknowledged that letter with a final letter dated November 17, 1978.
l I
_... _ _ - - _ ~_-
. A.37.e. (Taylor) The Applicants initially responded to the finding in NRC Inspection Report 78-18 in their letter dated November 16, 1978. Region IV responded with a letter dated December 8,1978, requesting additional information. The Applicants provided the additional information in their letter dated Dacember 20, 1978.
Region IV responded finally with a letter dated January 4, 1979. By letter dated October 1, 1979, the Applicants modified their earlier commitments of corrective action by changing the site organization responsible for implementation. Region IV acknowledged this letter by letter dated November 2, 1979.
A.37.f. (Taylor) The Applicants responded to the finding in NRC Inspection Report 79-18 regarding the calibration of welding machines in their letter dated November 29, 1979, in which they redesignated organizational responsibilities for the calibration work. Region IV acknowledged with a letter dated January 16, 1980.
A.37.g. (Taylor) The Applicants responded to the finding in NRC i
Inspection Report 79-31 regarding the use of incorrect filler weld metal in their letter dated February 20, 1980, wherein they stated that the incorrect filler metal had been removed from the weld, provided training for personnel and made certain procedural revisions to achieve
- better clarity of requirements. Region IV acknowledged this latter by letter dated March 11, 1980.
A.37.h. (Taylor) The Applicants responded to the finding in NRC Inspection Report 80-01 in their letter dated February 19, 1980. The Applicants stated that the welding that had taken place was found by engineering analysis to be adequate, but did comit to implementation of program to assure that adequate interfaces were established between site engineering and the equipment vendors to assure the proper specification of site welding attachment of equipment. Region IV acknowledged this letter by letter dated February 27, 1980.
A.37.i. (Taylor) The Applicants responded to the finding in NRC Inspection Report 80-13 in their letter dated June 6, 1980, wherein they comitted to additional training for l
the welders to enhance procedural compliance. Region IV acknowledged the Applicants' response by letter dated l
June 19, 1980.
A.37.j. (Taylor) As noted earlier, the matter reported in NRC Inspection Report 80-18 involved welding problems identified by the Applicants' QC program that were of a 1
magnitude that should have been reported to the NRC via a 10 CFR @ 50.55(e) report. The failure to report was found I
. by the inspector to have been caused by a person in middle level QC supervision who was not aware of the requirements of 10 CFR 5 50.55(e) and who was given immediate training.
Under these circumstances, the Applicants were not required to responded separately.
A.37.k. (Taylor) The Applicants responded to the finding in NRC Inspection Report 80-23 in their letter dated November 12, 1980. The response indicated that several of the components involved would be reworked to revised engineering standards and that future inspections would be based on engineered drawings rather than shop fabrication drawings. The Applicants' response was acknowledged by Region IV letter dated December 23, 1980.
Q.38.
Did the NRC staff conduct follow-up inspections to determine whether the Applicants in fact implemented the corrective actions they represented they would undertake?
A.38.
(Stewart and Taylor) Yes. As stated in response to question l
A.9., it is standard practice on the part of the staff to l
follow-up on the implementation of corrective actions committed to l
by the Applicants in response to inspection findings. These l
l followup ir.spections were documented as follows:
l
\\
l l
ec
~
_.n
._..a.~.-.
.._.._-.,-......-...-,m_
.~
. A.38.a.(Stewart) NRC Inspection Report 78-01 documented the follow-up inspection of the finding in NRC Inspection Report 77-10. The NRC inspector reported that he found that the surfaces of welds were found to be satisfactory and that the surveillance schedules were being adhered to.
A.38.b. (Taylor) NRC Inspection Report 78-13 documented the follow-up inspection of the fihding in NRC Inspection Report 78-05. The NRC inspector reported that the counterboring tools had been modified and were adquately controlled.
A.38.c. (Taylor) NRC Inspection Report 78-20 documented the follow-up inspection of the finding in NRC Inspection Report 78-12 regarding the failure to follow welding procedures. The NRC inspector found that welders were made to understand the importance of compliance with the weld procedures; that the monitoring of welding had been improved, that the weld procedures had been revised to allow somewhat slower travel speeds, and that the QA/QC procedures had been revised and clarified.
A.38.d. (Taylor) NRC Inspection Report 79-01 documented the follow-up inspection of the finding in NRC Inspection Report 78-13 regarding the monitoring of welding operations. The NRC inspector found that monitoring was l
l
..~
. being performed at an increased frequency and was apparently effective.
A.38.e. (Taylor) NRC Inspection Report 79-01 also documented the follow-up on the finding in NRC Inspection Report 78-18 regarding failure to follow welding procedures. The NRC inspector reported finding that certain weld procedures had been revised to allow more latitude for the welders without sacrificing quality and that.the surveillance controls over welding had been enhanced.
A.38.f. (Taylor) NRC Inspection Report 80-01 documented the follow-up inspection of the finding in NRC Inspection Report 79-18 regarding the calibration of welding machines. The NRC inspector reported finding that the Applicants had fulfilled their commitments.
A.38.g.(Taylor) NRC Inspection Report 80-13 documented the follow-up inspection of the finding in NRC Inspection Report 79-31 regarding the failure to follow weld l
procedures. The NRC inspector reported that according to i
records, the commitment to provide additional training had been fulfilled and that QC personnel were verifying that proper weld materials were being utilized.
. A.38.h. (Taylor) NRC Inspection Report 80-11 documented the follow-up inspection of the finding in NRC Inspection Report 80-01 regarding the welding of equipment to the structure. The NRC inspector reported finding that the engineering procedures had been revised and implemented.
A.38.i. (Taylor) NRC Inspection Report 80-18 documented the follow-up inspection of the finding in NRC Inspection Report 80-13 regarding the use of a weld process other than that required by the weld procedure. The inspector found that additional training had been given to the welders and their supervision, as committed to by the Applicants.
A.38.j. (Taylor) NRC Inspection Report 81-14 documented the follow-up inspection of the finding related in NRC Inspec-tion Report 80-23 in regard to the lack of full penetration welds on vendor supplied items. The NRC inspector reported that the components requiring rework had been reworked and that other components were satisfactory from a strength standpoint even though they were not reworked based on engineering calculations.
Q.39.
Do the inspection findings concerning construction activities involving welding raise substantial questions as to the adequacy of construction?
. A.39.
(Stewart and Taylor) No.
In view of the corrective actions taken by the Applicants as a result of the NRC staff findings, which have been verified by the staff, these findings do not raise substantial questions as to the adequacy of the construction of the facility.
Q.40.
In addition to the routine inspections described above, did the NRC staff conduct any investigations of allegations of improprieties in construction activities involving welding?
A.40.
(Taylor) Yes, in addition to the routine inspections of welding activities discussed above, the NRC staff has conducted investi-gations of alleged improprieties that involved welding activities.
The nature of these ailegations and the investigative findings were documented in the following inspection reports:
A.40.a (Taylor) NRC Inspection Report 79-12 reported on the investigation of allegations by a former clerk in the site office of the Brown and Root (B&R) Project Welding Engineer. The clerk alleged that the clerk was under-qualified to perfonn the duties assigned, that a program for the random radiography of each pipe welder's work was being improperly administered, and that the clerk had been directed to develop false reports of welder performance. The investigation indicated that the clerk was if anything, over-qualified for the work level
0 8 assigned; that the random radiography program was misadministered due to the very nature of the pipe welding activity; and that the falsified report was a management infonnation report of little importance. While the allegation was largely substantiated, the matter was found to be unimportant since the random radiography program was not used to determine the acceptability of any given weld; was not a requirement imposed by the NRC nor a commitment contained in the Safety Analysis Report.
A.40.b. NRC Inspection Report 79-15 reported an investigation of a series of six interrelated allegations concerning the welding of the stainless steel liner system in the fuel handling facility spent fuel storage pools. The allega-tions, simply stated, indicated that welding conditions l
were very poor; that welders were unqualified; that QC inspections were inadequate; that welding procedures were not followed; and that at least one weld seam was largely rust and concrete. The investigation inuicated that the allegations concerning poor welding conditions were sub-stantially true and that some of the welds might well be of relative low strength. The allegation about unquali-fied welders was found not to be the case in a technical sense, since each welder had passed the necessary tests.
It was apparent that the alleger meant that the welders were c.ot competent in his opinion. The matter of QC l
s
__..-.:.,,.m...
._..m.-..,_-..-.
. inspections and welding out of procedure could neither be substantiated nor refuted since it was just one person's word with no other confirmation.
In any case, the matter was considered to be unimportant since the welds in question were seal welds rather than strength welds and not of any safety significance.
A.40.c. (Stewart) NRC Investigation Report 79-22 related to allegations by a former Comanche Peak employee which appeared in a news article of the University of Texas at Arlington " Shorthorn," dated July 18, 1979. The alleger stated that he was told that improper welds were made on the primary coolant system and that he was told that a 6" check valve weld deficiency had been repaired without correct procedural instructions. Subsequent interviews with the alleger and on-site investigations by NRC inspec-tors established that the allegations either had no merit or could not be substantiated.
A.40.d.(Taylor) NRC Inspection Report 80-02 discussed an investigation of cliegations that had appeared in a local l
newspaper. The allegations were reported to have been by three Authorized Nuclear Inspectors who had left the site due to dissatisfaction with B&R's " lax QC procedures" and were further reported to have records and photographs to support contentions that poor welds in the reactor coolant l
li
- ~ _ -.. _ _,,
_ _ _ ~. _ _ _ - - _ _.
O
- piping existed.
Interviews with the allegers revealed no specific facts that could be further investigated. The allegers stated to the investigators that their concerns did not appear to have any safety consequences.
A.40.e. (Taylor) NRC Inspection Report 80-22 discussed an investigation of allegations to the effect that B&R QA management was not enst. ring that corrective actions were taken for documented nonconformances; that nonconformance reports were disapproved and subsequently destroyed; and that vendor components with documented defects were being deliberately released for shipment to the site by QA management. The allegation concerning lack of corrective actions was not substantiated, although the matter of the disapproval / destruction of nonconformance reports was.
One specific case where components with unacceptable weld surfaces was verified, but the allegation that QA manage-ment had knowingly allowed the shipment was not. The administrative handling of disapproved nonconfonnance reports was corrected so that records were maintained of such actions for auditing purposes. The management action, which allowed shipment of defective components, was shown to have been caused by the use of the wrong reporting document by the QC inspector, who originally identified the problem, and that management was thus not aware of a problem. The matter of the unacceptable weld g e e.. eD m+
e s
o surfaces was the subject of a Notice of Violation that was part of NRC Inspection Report 80-20.
Q.41. Has the only negative inspection finding resulting from the investigations (Notice of Violation that was part of NRC Inspection Report 80-20) been resolved to the satisfaction of the NRC staff?
A.41.
(Taylor) The Applicants responded to the Notice of Violation by their letter dated October 20, 1980, in which they comitted to reinspecting all of the involved components and to reworking them as necessary to assure satisfactory weld surfaces. The Applicants further comitted to perfonning fully documented inspections of all shipments from the involved vendor until completion of the subcontracted work. Region IV acknowledged the Applicants' letter by a letter dated November 5, 1980. A followup inspection was made and documented in NRC Inspectic. Report 80-23.
t Q.42. What could have been the potential safety consequences of the l
l unacceptable weld surfaces (Inspection Report 80-20) had the matter not been broucht to light by the allegation?
[
f A.42.
(Taylor) The unacceptable weld surfaces were unacceptable from the standpoint that a meaningful nondestructive weld examination could not have been done as required by the engineering drawings i
l for the components. The rework observed by the inspector was I
. almost entirely that of grinding the surface more smooth.
Some rewelding had to be done after the initial grinding since in some cases the welds became undersized as a result of the grinding.
EXPANSION JOINTS Q.43. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC program with respect to expansion joints?
A.43.
(Stewart) Yes.
Inspection of expansion joints is included as a part of the nonnal inspection of concrete placement.
Q.44. What have been the inspection findings with respect to the adequacy of the Applicants' QA/QC program ccncerning construction activities involving expansion joints?
A.44.
(Stewart) There have been no negative inspection findings with respect to expansion joints.
Q.45. Did the NRC staff conduct investigations of allegations of improprieties in a construction activity involving expansion joints?
i
. A.45.
Yes. An investigation was conducted of an alleged impropriety in construction activities involving an expansion joint.
Q.46. What was the nature of the allegation investigated and the investigation findings?
A.46.
(Stewart) NRC Inspection Report 77-13 discusses the nature of the allegation, wherein the Applicants informed the NRC Region IV office on November 23, 1977, by telephone, of a call on November 22, 1977, from an unidentified woman. She was apparently concerned with the workmanship at the site regarding the use of rotofoam as a temporary spacer in construction to maintain the required air space between Category 1 seismic structures. During that inspection, the NRC inspector reviewed the allegation and found that contrary to the woman's belief, all temporary rotofoam blocks had been removed from the subject areas. The B&R QA/QC inspection staff had initiated an inspection and documentation program to assure that the required 1" gap between Category 1 seismic structures was being maintained in the as-built condition.
This matter was treated as an open item pending NRC review of the B&R QA/QC inspection results.
Q.47.
Did the NRC staff conduct follow-up inspections to determine whether the Applicants, in fact, implemented the corrective actions they represented they would undertake?
,.._........~ -....._..
. A.47.
(Stewart and Taylor) Yes. As stated previously, it is standard staff practice to follow up on unresolved matters or findings to ensure that the Applicants have fulfilled their commitments and further that the commitments have been effective. Generally, the inspector who originally identified a given problem would also be the inspector who follows up on the matter, although sometimes this is not possible due to the unavailability of the particular inspector. The finding discussed previously was followed-up in accordance with this practice and documented as follows.
(Stewart) NRC Inspection Report 78-01 documented the follow-up on the findings contained in the NRC Inspection Rc) ort 77-13. The NRC inspector conducted a follow-up review of the B&R inspection and documentation program which was initiated to ensure that all temporarily installed rotofoam blocks had been removed from between Category 1 seismic structures after concrete placement.
The NRC inspector found that the procedural requirements were being implementad and considered this item closed.
INSPECTION AND TESTING Q.48.
Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC program with respect to inspection and testing?
-m_--_-
. A.48.
(Stewart and Taylor) The answer to the question is both yes and no.
First, to explain the yes portion of the answer, the essential element of any quality control program is the performance of inspection or testing, or both, for the purposes of determining whether a function or a product satisfies the requir ments established for the function or product. Nearly all of the criteria of Appendix B of 10 CFR Part 50 relate in some way to a function or product inspection to verify performance.
Therefore, nearly any NRC inspection relates in some way to inspection and testing. The no part of the answer is due to the fact that NRC inspections, during the construction phase, do not specifically reference one or more inspections related to inspection and testing. The NRC inspections are directed to general activity areas such as civil or structural (concrete) type construction activities and are carried out to determine conformance with the requirements stipulated in the regulations and/or committed to in the Safety Analysis Reports. The same is true for the broad activity areas generally designated as mechanical and electrical. Thus, it can be seen that an obser-vation that a test of fresh concrete was not properly performed could readily be assigned to the area of " inspection and testing" I
wht reas we have assigned that type of finding to " concrete" becaese that was the activity area inspected.
r l
l We have assigned seven of our inspection findings to this aspect of Contention 5.
These findings do not relate to more specific
. categories such as concrete or welding, but relate to the mechanical and electrical areas of our inspection program. These findings are as follows:
A.48.a. (Taylor) NRC Inspection Report 78-11 discussed a finding that B&R Pipe Department foremen were not assuring the cleanliness of piping runs as required by the B&R procedures.
A.48.b. (Taylor) NRC Inspection Report 79-04 discussed an observation that equipment was not being maintained in accordance with established requirements.
A.48.c. (Taylor) NRC Inspection Report 79-04 also discussed a finding that wiring within the main control boards was not separated as required by the Final Safety Analysis Report (FSAR) even though the components had been inspected and accepted.
A.48.d. (Taylor) NRC Inspection Report 79-06 discussed a finding that inspections of safety class electrical cable tray supports were not being done in accordance with FSAR requirements.
A.48.e. (Taylor) NRC Inspection Report 79-28 discussed a finding that electrical equipment inspection instructions were not
~-
.. -. ~,.,.
1
, sufficiently complete to assure an acceptable final installation.
A.48.f.(Taylor) NRC Inspection Report 80-11 discussed an observation that piping systems were being inadequately supported after installation.
A.48.g. (Taylor) NRC Inspection Report 81-15 identified a finding that the inspection of coatings applied to steel components in the reactor buildings was not properly documented.
Q.49. Did the Applicants take corrective action as a result of these findings?
A.49.
(Taylor) Yes.
In each instance the Applicants have made written commitments to take corrective action regarding the specific finding and have made comitments to prevent similar situations from recurring. The written comitments are reviewed by Region IV management and the finding NRC inspector for probable effective-ness, and if acceptable, are acknowledged by letter. The nature of the corrective actions for each of the above findings and references to relevant correspondence are as follows:
A.49.a. (Taylor) The Applicants responded to the finding in NRC Incpection Report 78-11 by letter dated July 28, 1978, in
. which the Applicants comitted to a complete reinspection of all then fabricated piping runs for assurance of cleanliness. The Applicants also comitted to retraining their pipe department personnel and to instituting a formalized surveillance over the area. Region IV acknowledged the Applicants' letter by a letter dated August 4, 1978.
A.49.b.(Taylor) The Applicants responded to the finding in NRC Inspection Report 79-04 involving the maintenance of equipment in their letters dated March 20 and April 12, 1979. The Applicants stated that the specific components identified as being improperly maintained were corrected and further that they had completely revised the maintenance control administrative system to assure the maintenance functions were perfomed as scheduled.
Region IV responded to the Applicants' letter by letters dated April 2 and April 26, 1979.
A.49.c.(Taylor) The Applicants responded to the finding in NRC i
Inspection Report 79-04 involving the electrical wiring problem in their letter dated March 20, 1979. The Appli-j cants comitted to a complete reinspection of the control I
(
board wiring and further comitted to an audit of the supplier and to revisions in the site QA procedures for l
l
inspection of electrical equipment. Region IV responded to the Applicants' letter by letter dated April 2,1979.
A.49.d.(Taylor) The Applicants responded to the finding in NRC Inspection Report 79-06 by their letter dated June 5, 1979, in which they committed to a complete review of all previously inspected electrical cable tray supports. The Applicants also stated that the QA procedures had been revised to clarify inspectior. requirements. Region IV responded by letter dated June 20, 1979.
A.49.e.(Taylor) The Applicants responded to the finding in NRC Inspection Report 79-28 in a letter dated February 8, 1980, in which they stated that the instructions I
pertaining to the instance cited had been revised and implemented. The letter also committed to providing additional training to the engineering personnel developing the instructions and to providing a full l
overview by quality engineering. Region IV responded to l
the Applicants' letter in a letter dated February 20, 1980.
A.49.f. (Taylor) The Applicants responded to the finding in NRC l
Inspection Report 80-11 dated May 5, 1980, in which they stated that the specific instance cited had been corrected j-and that an engineering analysis indicated that no damage l
l
3 had occurred as a result of the incident. The Applicants also committed to reinspecting all then existioq pipe runs for similar situations and to revise craft procedural instructions. No response was required of the Applicants since the actions connitted to were verified as completed during the period of the inspection.
A.49.g. (Taylor) The Applicants responded to the finding in NRC
~
Inspection Report 81-15 in their letter dated November 19, 1981. The Applicants committed to performing a
[
comprehensive review of the then existent inspection records for coatings, to performing reinspections in any suspect areas, and to repairing any actually defective areas. The Applicants also committed to clarifying both the construction and quality procedures to provide more y
.,s' specific instructions or requirements. Region IV responded to the Applicants' letter by letter dated January 19, 1982.
i
,t Q.50. Did the NRC staff conduct follow-up inspections to determine whether the Applicants in fact implemented the corrective actions they represented they would undertake?
A.50.
(Taylor) Yes, with one exception (in regard to NRC Inspettion Report 81-15 which will be discussed later). The follow-up inspections are as follows:
/
/
Y s
, A.50.a.(Taylor) NRC Inspection Report 78-13 documented the fellow-up inspection of the finding reported in NRC Insoection Report 78-11. The inspector reported that his continued observations of the cleanliness control for pipin'g indicated effective implementation. He also reported that the appropriate procedures had been revised and that surveillance schedules by QA were being adhered l
to.
f A.50.b. (Taylor) NRC Inspection Report 79-18 documented the follow-up inspection of the finding reported in NRC Inspection Report 79-04. The inspection found that the
. equipment had been reinspected with appropriate corrections made, that the administrative procedural changes had been implemented and that the inspection procedures had been revised as committed to.
f A.50.c.t(Taylor) NRC Inspection Report 79-06 documented the follow-up inspection made relative to the finding in NRC
/
Inspection Report 79-04 on control board wiring separation
\\
and found that the Applicants had made the necessary e
/'.
correction based on the reinspection conducted.
3.;
p l:.,,,
pf uA.50.d. (Taylor) NRC Inspection Report 79-19 documented the l
follow-up inspection of the finding in NRC Inspection a
Report 79-06. The NRC inspector reported that he had r
a
_ = - -
-mm
.eh
- n.w.. -.. a.... a
.... -. ~..
o
. reinspected a small sample of the tray supports in question and found them to be acceptable. He also verified that procedural revisions had been made and that training had been given to the inspection personnel.
A.50.e. (Taylor) NRC Inspection Report 80-13 documented the follow-up inspection of the finding in NRC Inspection Report 79-28. The NRC inspector reported finding that the installation instructions had been revised appropriately.
The inspector verified that engineering personnel had been given additional instruction and training on the preparation of the installation instructions.
A.50.f. (Taylor) As noted in response to the previous question, the finding involved in NRC Inspection Report 80-11 was verified to have been corrected during the reporting period.
A.50.g. (Taylor) There has as yet been no final follow-up relative to the finding in NRC Inspection Report 81-15 l
since the nature of the Applicants' corrective action will take a substantial amount of time and from a construction scheduling standpoint, is not of high priority. The final follow-up inspection of this item will take place at a future time deemed appropriate by Region IV.
l Q.51. Do the routine inspection findings concerning construction activities involving inspection and testing raise substantial questions as to the adequacy of construction?
A.51.
(Taylor) No. Considering the nature of the findings and the Applicants' corrective actions, as verified by the NRC Staff, these findings do not raise substantial questions as to the adequacy of construction.
Q.52.
In addition to the routine inspections described above, did the NRC staff conduct investigations of allegations of improprieties in construction activities involving inspection and testing?
A.52.
(Taylor) Yes. The NRC staff conducted an investigation of allegations that might be assignable to this area of Contention 5.
The investigation was documented in NRC Inspection Report 81-04 and involved allegations that electrical inspectors were directed by their supervision not to follow procedures; that electrical i
inspectors had not performed required inspections; that certain electrical inspectors were not qualified to do the inspections to which they were assigned; and that electrical drawings utilized for inspections were, in some cases, obsolete.
Q.53. What were the results of the investigation?
A.53.
(Taylor) None of the allegations were substantiated. The investigation did reveal that one of the QC senior supervisors for
. electrical inspections had required that all nonconformance reports be approved by him prior to being logged in.
It was not shown, however, that he refused to approve any nonconformance reports even though he had technically violated the procedures for reporting nonconformance. Under these circumstances, no NRC enforcement action was taken since there was no demonstrated program breakdown.
MATERIALS USED Q.54. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of Applicants' QA/QC program with respect to the " materials used"?
A.54.
(Steward and Taylor) Yes. The materials used in any phase of construction which become part of the permanent installation are inspected as an element of the overall specific area inspected.
As an example, when an inspection of concrete activities is made, the constitutent materials of concrete such as cement, coarse and fine aggregates, and the water will be inspected via review of test records generated in accordance with the specifications.
Whenever possible the inspectors will observe this type of testing to establish the credibility of the testing organization.
Review of our adverse findings in regard to construction at Comanche Peak indicate no instance where materials as such were unsatisfactory.
l l CRAFT LABOR QUALIFICTIONS AND WORKING CONDITIONS t
Q.55. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of the Applicants' QA/QC program with respect to craft labor qualifications and working conditions?
A.55.
(Taylor)
In general, there are no NRC regulatory requirements or policy concerning the qualifications of the craft labor force or the conditions which may be imposed on the labor force during construction. The NRC has, however, established or adopted quali-fication standards for welders and for persons performing reinforcing steel splicing, usually referred to as Cadwelding.
The NRC requires that the Applicants commit to constructing pres-sure retaining components under one of the appropriate parts of the American Society of Mechanical Engineers (ASME) Code for Boilers and Pressure Vessels. The NRC also reouires that the Applicants connit to use the American Institute for Steel Construc-tion (AISC) Code for most other applications of steel construction where the ASME code is not applicable. Both codes contain direct or referenced requirements for the testing of welders prior to production work. The ASME code for concrete reactor containment buildings contains a requirement for the qualification testing of Cadweld splicers. NRC staff inspections covered implementation by Applicants of these requirements concerning the qualification of welders and Cadwelders.
{
_ =.- _ ~ A
e Q.56. Have the NRC staff inspections revealed any adverse findings in regard to the qualification of either welders or Cadwelders?
A.56.
(Taylor) There have been no findings that would indicate that welders have not been qualified as required by the applicable code. One instance was identified where Cadweld spi-icer helpers were not fully tested and qualified. That matter was discussed previously in the testimony in regard to the finding contained in NRC Inspection Report 78-16. The discussion appears in answer to questions 22, 23 and 24.
Q.57.
In addition to routine inspections concerning the qualifications of welders and cadwelders, did the NRC staff conduct investigations of allegations that involved the qualifications of the welders and Cadwelders?
A.57.
(Taylor) Yes. The NRC has conducted investigations of allegations that welders were unqualified. NRC Inspection Reports 79-15 and 79-22 discussed, among other charges, an allegation that welders were unqualified.
In each instance the investigation revealed that the particular welders had been qualified in accordance with the applicable requirements. As stated above, our inspections and investigations have revealed no instance where a welder performing production welding had not been qualified by the testing methods stipulated by the codes.
nh
~-
.a
. w - --
a
- TRAINING AND ORGANIZATION OF QA/QC PERSONNEL Q.58. Did the NRC staff conduct inspections of Comanche Peak construction to determine the adequacy of applicant's QA/QC program with respect to the training and organization of QA/QC personnel?
A.58.
(Taylor and Stewart) Yes. The training of the QA/QC personnel is examined during most of the routine inspections since training is one factor in the determination of the qualifica-tion of a given person to perform an inspection and in the determination of the acceptability of what is inspected. The inspection of the organization is performed much less frequently since it is generally reasonably static.
Emphasis is placed on the organizational aspect of QA/QC in the period prior to issuance of a construction permit and again, at about the mid-point in the construction period. Changes in QA/QC organization, such as the changes which occurred at Comanche Peak during 1978 (as discussed by Mr. Crossman), are examined in greater detail by the regional inspectors and by the NRC headquarters personnel who are responsible for assuring that an adequate organization is presented by the Applicants in the Safety Analysis Report.
In our opinion, the ability and the integrity of the persons in an organization is generally far more important than the exact structure of the organization and generally can only be determined n
0 e by continued, long-term observation rather than by specific inspections.
The following are adverse inspection findings that appear to fit this aspect of Contention 5 rather than any other aspect.
(Generally, this part of our testimony covers all adverse findings not previously discussed).
A.58.a. (Stewart) NRC Inspection Report 76-08 contains the following findings: drawings were found in the field that were not the latest revisions; an in':.cim change notice to a construction procedure was not available at the location of the subject procedure; and the TUSI site surveillance inspector had observed an item of noncomforwance, however, he had not documented this matter as prescribed in the TUSI QA plan.
A.58.b.(Taylor) NRC Inspection Report 78-12 documented a finding that the QC procedures had not been followed in regard to segregation and identification of nonconforming materials and that the documentation of the nonconformance also did not identify the quantity of componente involved.
i A.58.c. (Taylor) NRC Inspection Report 79-18 documented three findings indicating that QC personnel were not adequately trained and/or that management did not have adequate l
l
. controls over the QC personnel. The first was a finding that QC personnel in the electrical arer were not actually inspecting the work phase assigned; the second was a finding that stamps used to identify QC inspectors on documentation had not been controlled such that personnel no longer assigned to QC functions retained identifier stamps while other persons had lost such stamps; the third finding was that QC personnel were documenting acceptance inspections on records well after the inspections presumably had been perfonned.
A.58.d. (Taylor) NRC Inspection Report 79-27 documents two findings concerning this aspect of Contention 5.
The first was a finding that several QA/QC procedures had become obsolete in that the responsiblity for the performance of various functions had been significantly changed although the functions were still being performed.
The second was a finding that the labor force had inade-quate procedures for handling heavy equipment during the installation process.
A.58.e.(Taylor) NRC Inspection Report 80-03 documented a finding that personnel of the labor force were pulling an electrical cable through a conduit in such a way that damage could have occurred to other cables that had already been pulled.
87 -
A.58.f. (Taylor) NRC Inspection Report 80-08 contains a finding that a safety-related cable that had been damaged was repaired in an unauthorized manner and that neither the damage or the repair had been reported as required by site procedures.
A.58.g.(Taylor) NRC Inspection Report 80-13 documented a finding that electrical QC inspectors were not fully inspecting work as required by procedures.
A.58.h.(Taylor) NRC Inspection Report 80-15 documented a finding that many drawings for pipe supports contained references to specifications and procedures that were not available for use on-site by the labor force or by QC. This same inspection report also documented a finding that the Applicants had failed to implement a QA/QC program for a class of seismic category 1 pipe supports.
A.58.i. (Taylor) NRC Inspection Report 81-02 contained a finding that pipe and valve components already installed were not supported properly.
Q.59. Did the Applicants take corrective action as a result of these findings?
-==
=e.
e a - we a <> mem a
_..w.-
-=
m% e w += *,
. WM
o
. A.59.
(Taylor) Yes. The Applicants committed to take the corrective actions as stated below:
A.59.a. (Stewart) The Applicants responded to the findings in NRC Inspection Report 76-08, by letter dated September 21, 1976, (TXX-1913), wherein they stated that computerized lists were being distributed weekly to all document recipients. These lists reflected distribution and current revision information which allowed recipients to survey their files for accuracy on a weekly basis. Also, lists of change notices and affected procedures were distributed to all document recipient personnel. Such personnel were instructed to audit their construction procedures for accuracy and outstanding change notices.
All recipients had notified the Document Control Center that this audit had been completed.
In addition, the Applicants indicated that possible engineering involvement of the Freeze and Nichols QA Manager was identified in l
site surveillance report dated August 27, 1976.
Further identification of nonconformances by the Applicants' site surveillance inspector would be identified in sita surveillance reports or other means provided by the CPSES QA plan. The initial response was acknowledged by Region IV letter, dated October 8, 1976; which asked for additional information. The additional information was provided to the NRC by the Applicants' letter dated
o j October 26, 1976. Their response was accepted subject to verification by Region IV letter dated November 23, 1976.
A.59.b. (Taylor) The Applicants responded to the finding in NRC Inspection Report 78-12 in a letter dated September 21, 1978, in which they stated that the specific nonconformance report involved had been revised; the materials involved had been properly identified; and that they would provide detailed training-to the QC force in the procedure for control of nonconfonning materials.
Region IV responded to the Applicants' letter by a letter dated October 10, 1978, which requested that more definitive connitments on training the labor force on the subject be furnished along with the implementation of a surveillance effort by QA. The Applicants responded by letter dated November 6,1978, in which they essentially committed to the additional actions recommended by Region IV. Region IV acknowledged the Applicants' complete series of response letters by a letter dated November 17, 1978.
A.59.c.(Taylor) The Applicants responded to the findings in NRC Inspection Report 79-18 by stating that they had initiated a comprehensive evaluation of the electrical QC group which would result in an improved training program and the reassignment of personnel to positions more fitting to l
l
their capabilities.
In addition, Applicants comitted to revision of the inspection instructions in a more detailed format, and finally, to the assignment of more qualified levels of supervision.
In regard to the use of inspection stamps, the Applicants rescinded the use of such stamps and examined previously stamped records very extensively to identify any misuse of such stamps. The final area of the multiple findings in this report was addressed by a commitment to implement a revised control system for inspection records of the type involved and to implement a QA surveillance to assure future compliance. Region IV acknowledged the Applicants' letter by letter dated January 16, 1980.
A.59.d.(Taylor) The Applicants responded to the two findings contained in NRC Inspection Report 79-27 by separate letters. The first, dated December 18, 1979, comitted to
?
revision and redefinition of the measures to be used in regard to the hoisting of heavy equipment during the i
l installation process.
In the second letter, dated i
December 21, 1979, the Applicants comitted to review of I
the QA/QC procedural system to assure that it was current and to stronger management controls to assure that changes l
were not made prior to the publication of the associated i
procedure.
Region IV responded to the Applicants' letters i
J
- by letters dated Janaury 2,1980, and January 11, 1980, respectively.
A.59.e. (Taylor) The Applicants responded to the finding contained in NRC Inspection Report 80-08 by letter dated March 5, 1980, in which they stated that cables that had been installed in the conduit where pulling damage might have occurred had been withdrawn from the conduit and examined, beth by visual inspections and by testing, and confirmed that no actual damage had occurred.
Preventive actions committed to were that there would be a foreman present at any time that personnel of his crew were pulling cable to provide more expert instructions and that cable oulling lubricants would be used for conduit pulls in accordance with procedures. Region IV acknowledged the Applicants' letter by a letter dated March 11, 1980.
A.59.f. (Taylor) The Applicants responded to the finding in NRC Inspection Report 80-08 regarding the repair of electrical cable in a letter dated May 14, 1980. The Applicants stated that the damaged cable had been removed and replaced with a new cable and further, that all construction force levels of supervision down to and including foremen had been given four (4) hours of training emphasizing the need to maintain procedural
. compliance at all items. Region IV acknowledged the Applicants' letter by a letter dated April 30, 1980.
A.59.g. (Taylor) The Applicants responded to the finding in NRC Inspection Report 80-13 regarding the electrical inspection in their letter dated June 6,1980, in which the Applicants comitted to reinspection of the connectors in question on a sampling basis. The Applicants also comitted to revision of the applicable it.tpection procedures to clarify the requirements and to training the using personnel in regard to the changes. Region IV acknowledged the Applicants' letter in a letter dated June 19, 1980.
A.59.h. (Taylor) The Applicants responded to the findings in NRC Inspection Report 80-15 in their letter dated August 18, 1980. The Applicants comitted to imediate implementation of a QA program for the pipe supports in accordance with revised specification criteria. The matter of notes on the drawings was determined to be applicable only to a specific vendor facility and not to site work. A record change on-site was processed to clarify this position. Region IV acknowledged the Applicants' letter by a letter dated September 12, 1980.
. A.59.i. The Applicants responded to the finding contained in NRC Inspection Report 81-02 in their letter dated March 19, 1981. The Applicants stated that their review of the matter indicated that the problem had occurred as a result of a lack of communication between the various crafts in the labor force. The Applicants stated that the pipe section was being evaluated at the time of their letter for potential damage and that they had revised a key construction procedure to require that all temporary pipe supports be secured in such a way as to prevent easy and usually accidental removal of the temporary supports.
Applicants also stated that other guidelines for the craft had been generated and that training for all craft personnel was planned. A comprehensive walkdown of the plant was in progress at the time of their letter to identify any similiar situations. Region IV acknowledged the Applicants' letter by letter dated April 2, 1981.
l l
Q.60. Did the NRC staff conduct follow-up inspections to determine whether the Applicants in fact, implemented the actions they
(
represented they would undertake?
i l
A.60.
(Stewart and Taylor) Yes. Again, it is staff policy to make one or more follow-up inspections to verify that the Applicants have implemented their commitments and that the commitments have been l
m--
..w --
m-en
o.a.
s om m,,
. i I
effective. The follow-up inspections in this area were documented as follows:
A.60.a. (Stewart) NRC Inspection Report 76-11 documented the 4
follow-up on the findings contained in NRC Inspection Report 76-08. The inspector found that the Applicants had implemented the computer printouts of up-to-date revisions and required periodic file verification.
In addition, the inspector reviewed the TUSI QA documentation of surveillance activities and had no further questions regarding this matter.
A.60.b. (Taylor) NRC Inspection Report 78-20 documented the follow-up inspection of the finding in NRC Inspection Report 78-12 regarding the control of nonconforming materials. The inspector reported that by random observations, it was verified that nonconforming material l
identification procedures were being properly implemented.
The inspector also verified that the training committed to by Applicants had been given and that the surveillance program in the area had been implemented.
A.60.c. (Taylor) NRC Inspection Report 80-01 documented the follow-up inspection of two of the three items included in NRC Inspection Report 79-18. The inspector reported that he had observed that steps taken to improve the training
. and supervision of the electrical QC personnel appeared to be effective and that.imch improved inspection procedures had been issued and implemented. The NRC inspector also stated in the same report that the measures committed to by the Applicants in regard to improvements in another type of inspection instruction had been effective and that inspections were being performed and documented in a timely manner. NRC Inspection Report 80-11 documented the follow-up inspection of the matter in NRC Inspection Report 79-18 regarding use of inspection stamps. The NRC inspector found that the use of such stamps had been discontinued and the stamps collected. The records that might have been stamped by somecne using a lost stamp were retrieved and examined by the Applicants under the surveillance of the NRC inspector with no indication that improper usage of the lost stamps had occurred.
A.60.d.(Taylor) NRC Inspection Report 80-18 documented the follow-up inspection of the matter reported in NRC Inspection Report 79-27 concerning the hoisting of equipment. The NRC inspector reported that the appropriate procedures had been revised and that detailed instructions for specific situations were being issued.
NRC Inspection Report 80-01 documented the follow-up of the matter in NRC Inspection Report 79-27 concerning the obsolete procedures. The NRC inspector found that the i
- - - -. - ~.
D i affected procedures had been revised or deleted as appropriate and it appeared that the management measures to control such changes had been effective.
A.60.e.(Taylor) NRC Inspection Report 80-08 stated that by several inspections, the NRC inspector had verified that the Applicants had fulfilled their commitments concerning the matter reported in NRC Inspection Report 80-03. Con-cerning the potentially damaged cables, the NRC inspector stated that he verified by appropriate interviews that the cables had in fact, not been damaged.
A.60.f.(Taylor) NRC Inspection Report 80-11 documented the follow-up inspection of the finding in NRC Inspection Report 80-08 concerning the damaged cable and its repair.
The NRC inspector indicated that the specific cable involved was replaced along with oti'rs in the same duct that were damaged in the process of removing the original cable. The NRC inspector also had reviewed records to substantiate that the training committed to by the l
Applicants had been given.
A.60.g. (Taylor) NRC Inspection Report 80-18 documented the follow-up inspection of the finding in NRC Inspection Report 80-13 concerning the failure to perform certain electrical inspections complet21y. The NRC inspector i
I f
1
. found that the Applicants had performed a complete reinspection in the affected area rather than a sampling inspection and established by review of records and ir.terviews with the QC personnel that the reinspection verified the correction of all defective components. The procedures pertaining to future work were also verified to have been revised.
A.60.h.(Taylor) NRC Inspection Report 80-27. documented the follow-up inspection of the finding in NRC Inspection Report 80-15 concerning the notes on drawings. The NRC inspector verified that the documentation relative to the use of the notes had been issued and further, that instructions had been issued to the drawing / drafting personnel to effect removal of the notes at the next revision to the drawing. NRC Inspection Report 80-18 documented the follow-up inspection in regard to the lack of a QA program for certain pipe supports as reported in NRC Inspection Report 80-15. The NRC inspector found that the necessary procedures had been issued and that preliminary indications were that the procedures were properly implemented. This matter was returned to the routine NRC inspection program as part of the on-going inspection of all pipe support systems.
w_3 a., s____
_ - - _ _. ~._ __
..m
l A.60.i.(Taylor) NRC Inspection Report 81-05 documented the follow-up inspection for the finding in NRC Inspection Report 81-02. The NRC inspector found that the Applicants had implemented their commitment in regard to the use of semi-permanent pipe supports and that procedures and training had been given.
Q.61. Do the inspection findings concerning construction activities involving training and the organization of QA/QC personnel raise substantial questions as to the adequacy of construction?
A.61.
(Stewart and Taylor) No.
In view of the corrective actions that have been taken by the Applicants, as verified by NRC staff inspections, these findings do not raise substantial questions as to the adequacy of the construction of Comancha Peak.
Q.62.
In addition to the routine inspections described above, did the NRC staff conduct any investigations of allegations that either the training of QC personnel was inadequate or that there were improprieties in the organization of the QA/QC personnel?
A.62.
(Taylor) As documented in NRC Inspection Report 81-12, the Staff has investigated allegations that 1) QC personnel were not performing their prescribed inspection of fastening devices referred to as "Hilti" bolts in a correct manner; 2) QC personnel were careless or had lost control of an inspection marking media
. called " Torque Seal," and 3) a repair was made to concrete without the knowledge of QC personnel after a "Hilti" bolt was removed.
Q.63. Were any or all of these allegations substantiated by the investigation?
A.63.
(Taylor) The investigation did not substantiate any of these allegations.
HAYWARD-TYLER PUMPS Q.64.
In addition to the above inspection and investigative findings concerning the Applicants, has the NRC Staff recently conducted an investigation of allegations of improprieties by one of Appli-cants' vendors, the Hayward-Tyler Pump Company?
A.64.
(Taylor) Yes. The NRC Staff has investigated allegations of problems in the manufacture of pumps by the Hayward-Tyler Pump Co.
This investigation has not yet been completed.
Q.65. Are there any Hayward-Tyler Company pumps at Comanche Peak?
A.65.
(Taylor) Hayward-Tyler delivered four pumps used in the safety-related service water system at Comanche Peak. Review of vendor data packages in the possession of the Applicants indicates that Hayward-Tyler apparently only tested for final performance the two l
l t
- 100 -
pumps associated with Unit 1.
These records indicate that nearly all of the manufacturing, assembly and non-destructive testing activity on these pumps was accomplished by AMPC0 Metals Division of the AMPCO-Pittsburgh Corporation under the auspices of Babcock
& Wilcox Canada Limited, with whom the Applicants had placed the original contract for the pumps. Most of the pressure boundary parts for the Unit 2 pumps appear to have been manufactured under the same circumstances, but the records indicate that Hayward-Tyler may have fabricated some of the non-pressure boundary parts. Hayward-Tyler appears to have assembled as well as tested the Unit 2 pumps.
Q.66.
Is there any indication that these pumps may be defective?
A.66.
(Taylor) No. There is no indication in the vendor data records which I reviewed that the pumps are defective. However, Hayward-Tyler reported to the NRC pursuant to 10 CFR Part 21 that a spare part (pump shaft) may be defective.
l The two pumps for Unit 1 have been operated intermittently since March 1980 to supply service water in performance of certain tests and to supply cooling water to assist in the cooling of the Unit 1 containment building during times of peak heat to provide a more agreeable working environment for the construction labor force.
One of the pumps for Unit 2 was temporarily substituted for one of the Unit 1 pumps when the Unit 1 pump had to be taken 7;; of service 1
101 -
for examination following a maintenance error. To date, the pumps have performed satisfactorily, but a substantial amount of test-ing for all of the pumps remains to be done prior to issuance of operating licenses for Comanche Peak. Any findings concerning the Comanche Peak pumps resulting from the investigation of Hayward-Tyler will be followed-up as necessary.
EXPIRATION OF BROWN AND R00T'S ASME CERTIFICATES OF AUTHORIZATION Q.67. What are the NRC requirements with regard to the American Society of Mechanical Engineers ("ASME") Code?
A.67.
(Taylor) The NRC requires the application of all aspects of Section III of the Code to that part of a nuclear power plant which is defined by regulation as being within the reactor coolant pressure boundary. The particular version of the Code which applies is specified by 10 CFR 50.55a, " Codes and Standards".
In addition, the NRC has promulgated Regulatory Guide 1.26, which specifies the use of portions of Section III that should be con-sidered by an applicant for systems other than the reactor coolant pressure boundary and to which the NRC staff expects an applicant to connit in its Safety Analysis Report. Although the NRC has adopted Section III of the ASME Code for reactor coolant pressure boundary work, the NRC specifically deleted the requirement that the "N" stamps be applied.
(The "N" symbol stamps indicate that construction has been built strictly in accordance with the pro-
+meh
" ~*
- O"M
_a
-^^ '^
m y
m.3
.&Mi b-m.- GGmu 9s-6 E
h a+
- 102 -
visions of tne ASHE Boiler and Pressure Vessel Code.) Thus, there is no NRC requirement that an applicant have an ASME certificate of authorization to possess or use "N" stamps. Also, the NRC will consider means other than the ASME Code of assuring quality work.
The primary basis for ASME enforcement is the adoption of the Code by a legal jurisdiction, such as the state in which a nuclear power plant is being built. The State of Texas, in which Comanche Peak is located, has adopted the entire ASME Code (including Section III of the Code).
The ASME requires that an organization called an Authorized Nuclear Inspection Agency be involved in all work perfonned under the Code. The inspectors for the Agency are referred to as Authorized Inspectors, or in the case of the nuclear industry, AuthorizedNuclearInspectorsor("ANI"). The ANI are persons who are trained and qualified by the National Board of Pressure Vessel Inspectors and derive their authority through certification by the local jurisdiction.
Q.68. What is an ASME Certificate Holder?
A.68.
(Taylor) An applicant for an ASME C2rtificate of Authorization enters into an agreement with an Authorized Inspection Agency and makes application to the ASME for a certificate of authorization before actually starting work. The ASME generally will conduct a
s
- 103 -
survey shortly after the submittal of the application to review the applicant's ASME Quality Assurance (QA) manual for the work.
If that manual is found to be acceptable, the ASME conducts a survey of the implementation of the approved manual and may require changes, as necessary, to assure its effectiveness. The work accomplished in the interim period between the time an applicant files for a certificate of authorization and receipt 'of such a certificate is entirely at the risk of the applicant, if the work is technically unacceptable under the ASME code. The certification process is repeated every three (3) years.
The holder of a ASME certificate of authorization h3s the authority to perform work pursuant to the ASME Code and to certify such work as complying with all the applicable requirements of the Code.
ASME certificates of authorization permit the stamping of an item with an ASME Code Symbol Stamp ("N" stamp) following completion.
These stamps are issued only upon a demonstration to the ASME that i
an acceptable QA prooram exists for the work to be performed pur-suant to the requested authority.
I Q.69. Are you aware that the ASME Certificates of Authorization that
[
l Brown & Root had been issued in 1978 by the ASME were allowed to expire on January 8, 1982 and that new certificates were issued on March 15, 1982?
l l
l
m.
O
- 104 -
A.69.
(Taylor) Yes.
I was aware of this situation, as was the management and supervisory staff of Region IV.
Q.70. Are you aware of the findings reported by the ASME Survey Team at the October 12-14, 1981 Survey?
A.70.
(Taylor) Yes.
I attended the October 14, 1981 exit meeting, at 4
which time the ASME Survey Team reported that they found the Brown
& Root QA manual vague. The Survey Team also provided a limited number of examples of inadequate implementation of the QA program and the detailed requirements of the Code.
Q.71. What was the NRC staff position regarding the ASME finding that the QA Manual was vague?
A.71 (Taylor) The ASME Manual is one of the basic enforcement tools available to the ASME and to the ANI. Once approved, the manual can only be changed with the approval of the Authorized Nuclear Inspection Agency. Thus, the manual is the main basis for audit-ing by the ANI. Procedures implementing the manual can be changed by the certificate holders provided that the requirements of the manual or the Code are not specifically violated.
It is thus important to the ASME that the manual contain considerable detail.
Since the NRC staff had found that the procedures and instructions implementing the manual were generally effective, it was not i
important to the NRC staff that such procedures and instructions
y w ~ -..
o r
4 - <
- 105 -
were not in the manual itself. The Brown and Root ASME QA Manual was revised, in accordance with the findings of the ASME survey, by incorporating many of the detailed instructions already contained in the implementing procedures and by editorial re-arrangements to achieve greater clarity.
f Q.72. What was the NRC staff's position concerning the ASME finding of inadequate implementation of the Brown and Root ASME QA program?
A.72.
(Taylor) Based on my attendance at the October 14, 1981 meeting, I determined that although the examples of inadequate implementa-tion of the QA program indicated technical violations of the provisions of one subsection of the Code, such examples did not i
indicate poor quality construction.
j Q.73. What were the ASME findings reported by the ASME Survey Team at the January 18-20, 1982, resurvey of the Brown and Root ASME QA program?
A.73.
(Taylor) According to the inspector who attended the January 20 meeting, the ASME Survey Team stated that they would recommend that new certificates of authorization be Wd by the ASME pro-vided that certain corrective actiont.m W -n and verified by the ANI.
o t
106 -
Q.74. Did the NRC staff take any enforcement action against the Applicants as a result of the ASME findings leading to expiration
/
of the certificates of authorization?
A.74.
(Taylor) Based on the findings reported by the ASME survey team at both the October 14, 1981 meeting and the January 20, 1982, meeting, the staff determined that these findings did not warrant any enforcement action in accordance with the NRC enforcement policy in 10 CFR Part 2, Appendix C.
It should be noted that, as previously stated, there is no NRC requirement that "N" stamps be applied, and thus nc NRC requirement for certificates of authori-zation to possess - use such stamps.
In addition, although the ASME.had the aut'rsrity to immediately withdraw the certificates and stamps followinj the October survey, the ASME did not do so.
It merely allowed the certificates to expire on January 8,1982.
Alta, on January 20, 1982', just eight (8) days after expiration of the certificates, the ASME Survey Team indicated that they would recommend issuance of new certificates.
Finally, the ANI personnel continued to perform their functions through the entire period from October 1981 until the certificates were re-issued in March 1982. The only site activity that was precluded was final ASME certification of completed components or systems and appli-cation of the "N" stamps, neither of which was essential during this period. The net effect of the ASME action was that Brown and R60t reverted to the status of an interim certificate holder until the certificates were re-issued on March 15, 1982.
l l
+
.,,n,-
n
.. n
~
-..m
-mn~.'
,w
- 107 -
V.
CONCLUSION Q.75.
Gentlemen, what are your overall conclusions regarding Contention 57 A.75.
Our inspection and investigation findings at Comanche Peak to date do not substantiate the allegation in Contention 5 that there are substantial questions as to the adequacy of the construction of the facility. Specifically, we conclude the following:
A.75.a. Our inspections and investigations, as well as assessments of the Applicants' performance on an annual basis, have determined that the Applicants have adequately developed and implemented a QA/QC program meeting NRC requirements.
A.75.b. The inspection and investigation findings that were indicative of actual defects in construction were resolved by correction of the defective construction, as necessary, along with correction of the underlying QA/QC program deficiency. All but two of the matters raised in the Inspection Reports cited in support of Contention 5 as negative findings have been resolved and that resolution verified by the NRC Staff. These two matters relate to
- 1) a small amount of concrete of indeterminate quality in i
the Unit 1 containment which will be finally resolved by the containment structural integrity test and 2) coatings i
l l
N
- h
- -, - = * -
-h
- 108 -
in both containments that have been and are being reinspected and repaired, as necessary, by the Applicants.
A.75.c. The negative findings in the Staff's inspection reports that were essentially programatic in nature (i.e., no actual construction deficiency was identified) occurred early in each given phase of construction and were corrected in a timely manner such that there is little likelihood that any significantly defective construction has not been detected.
A.75.d. Although the construction of Unit 1 of the Comanche Peak Station is essentially complete, additional final con-struction testing ren.ains to be done, along with system tests that are prerequisites to the issuance of operating licenses. These tests are designed to reveal any defi-ciencies in either the design or construction of the facility that could adversely affect the safe operation of the facility at a future time. Additional inspections of both Units 1 and 2, including monitoring of these tests, will be conducted by the NRC Staff to ensure that safety-related construction mr;tters identified will be adequately resolvd prior to recommending authorization for the loading of fuel and the operation of Comanche Peak.
l l
iww...
- - -.m e. -..-
-, w.. -
u.
-r mm s.
- 109 -
The above statements are true and correct to the best of our knowledge and belief.
!d t b e m.
William A. Crossman
/
~)
ikhXl C k :
Gobert'Cs. Stewart- '
~
.m tf.:
'l t.d M /
,lo3ert G. Taylor Subscribed and sworn to before me this day of June, 1982.
/
&n Notary Public My Commission expires: /-4 /d ewe a
e me em a
=.m.
PROFESSIONAL QUALIFICATIONS J
OF WILLIAM A. CROSSMAN I
UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Crossman is Chief, Reactor Project Section B, Reactor Project Branch 1, Region IV, Nuclear Regulatory Commission, Arlington, Texas. Mr. Cro.,ssman har held this position in Region IV sirce May 1974, and in the course of his responsibilities he has reviewed, approved, and performed inspections and investigations of nuclear facilities under Region IV jurisdiction.
In this position, he was responsible, from May 1974 to March 1982, for the
~
supervision of the project inspectors who inspect the Comanche Peak Project.
Mr. Crossman received a Bachelor of Science degree in chemical engineering from the University of Texas in 1950. He is a registered Professional Engineer in Nuclear Engineering in the State of California.
Prior Work History 1974 - Present Chief, Reactor Project Section, Region IV - Responsible for direction of inspection personnel with review and approval of scope and report of inspections and investigations performed.
Participate in direct evaluation of activities related to reactor construction with occasional contact with ACRS at subcommittee meetings.
(AEC/NRC) 1973 - 1974 Chief, Reactor Project Section, Region II - Responsible for direction of inspection personnel with review and approval of scope and report of inspections and investigations performed.
Participate in direct evaluation of activities related to reactor construction with occasional contact with ACRS at subcommittee meetings.
(AEC) 1968 - 1973 Reactor Insoector - Served as a member of the technical staff of Region II with responsibility for inspection of assigned power, research, and test reactors during construction, test and startup, and operation.
(AEC) 1965 - 1968 Reactor Operation - Various supervisory responsibilities for Nuclear Reactor Operation, including ref~ueling activities, health physics, maintenance, planning and scheduling, and design changes.
(Douglas United Nuclear, Inc.)
\\
L
~
1
- 1958 - 1965 Reactor Ooeration - Various supervisory titles and respon-siD111 ties for nuclear reactors, including operations supervisor, refueling, health physics and maintenance.
(General Electric Co.)
1950 - 1958 Reactor Fuels Processing - Various supervisory titles and responsibilities for nuclear ~ related work, including plutonium and uranium recovery, irradiated fuel processing, plutonium production, radioactive waste management, and health physics.
(General Electric Co.)
M e
4 1
e
Statement of Professional Oualifications Name:
Robert C. Stewart
Title:
Reactor Inspector Employer:
Division of Resident, Projects, and Engineering Programs, Region IV, United States Nuclear Regulatory Commission.
I am a Reactor Inspector in the Projects Branch #1, Project Section A in the Division of Resident, Projects.
and Engineering Programs, Region IV, located in Arlington, Texas.
In this position, I am responsible for inspections and coordination of all safety-related inspections for facilities assigned to me within Region IV jurisdictTon.
I held this assignment for the Comanche Peak Steam Elec-tric Station during the period July 1974 to January 1978.
Education:
Farragut College, Farragut, Idaho (Univ. Idaho)1946-48 Mechanical Engineering / Nuclear Engineering Heald Engineering School, San Francisco, Calif. (night 1953)
G.E. School of Nuclear Engineering, Richland, Wn. (night 1943))
G.E. School of Nuclear Engineering, Richland, Wn.
(night 1954
' (night 1967-68)
. Pierce College, Woodland Hills, Calif.
Engineering Management l-NRC' Training Courses NRC' Training Center Courses:
Concrete Technology & Codes Refresher Courses September 1981 Nondestructive Examination Refresher Course June 1980 Electrical Technology & Codes July 1979 BWR 4, Reactor Systems and operations May 1973' BWR 6, Feb. 1973 PWR W, April 1975 NRC Teactor inspection t,echniques Dec. 1977 Ohio State University Columbus, Ohio Welding technology and Codes Oct. 1977 Portland Cement Association
'Skokie, Ill.
Concrete Technology and Codes Feb. 1977 Convair School fo.r Nondestructive Testing General Dynamics 'Convair Aerospace Div.
San Diego, California Jan. 1976 S
S S
^ -
e 2+
,-.we a
.sm ir--
. 4-.s
.m.
-me
- s. e
--.n am m
-2 University of Texas at Arlington Graduate course: Huclear Power Engineering Fall 1977 Advanced Problems in ME Solar Energy Spring 1978 Experience:
1971-Present:
Reactor Inspector, Region IV, U.S. tiuclear Regulatory Comission In this position I am responsible for project inspection of nuclear facilities under Region IV jurisidiction.
1955-1971
. Rockwell International (fonner.dy Atomics International, Inc.) Canoga Park, California.
Senior Facilities Project Engineer:
Assigned to the Program Office of the Fast Flux Test Facility (FFTF) Reactor fuel handling systems design and manufacturing. Responsible at project level to coordinate, plan, and program the conceptual designs, and testing of the FFTF.
Duties also involved an assignment as Construction Manager, Sodium Component Test Installation (SCTI).
Senior Research Engineer:-
II Assigned to SNAP Compact Power Systems, Testing, and
!.aunch Team. As a member of the SNAP 10A launch team, coordinated the transporation handling, launch vehicle interfacing, and pre-launch and post-launch testing of the world's first nuclear reactor to be orbited in space.
Reactor Construction Engineer / Senior Research Engir.eer:
Overseas on-site representative in the construction of four, 50 KW, research reactors; Tokai-Mura, Japan; Frankfurt, Germany; Berlin, Gennany; and Milano, Italy.
l subsequent to the overseas assignments, I was assigned as a merber of the Reactor Testing unit of the SNAP experimental reactor group in the successful demonstratios of the feasibility of the SNAP II, 50 KW-NAK coolant reactor concept. -
. Senior Reactor Construction Engineer:
Senior Site representative (Construction) responsible at project level to coordinate, plan, program and supervise the construction of a 40 MWe Organic Moderated Reactor (OMR) for the city of Piqua, Ohio. The assignment also included the' supervision of maintenance, in charge of
~^
.--.-2.
-=
' Time-and Material contract, in completing repairs and o
design changes and modifications.
Reactor Construction Engineer:
As the on-site representative, supervised reactor i
ihsta11ation and associated components of first sodium cooled nuclear power reactor, Santa Susana, California.
Duties involved direct supervision of construction forces in the installation and erection of the reactor containment, reactor vessel and associated components /systens. Duties also included the development of installation and testing procedures.
KaiserEngineersan'dAtkinson& Jones,Richland,dashington.
1947-1955:
Assistant Department Engineer - Mechanical Assigned to t.he on-site construction project manager's staff in the crastruction and preoperational testing of five plutonium production eactors at Richland, Washington.
My duties involved the coordination of all work programs of the field and. field engineering staff; direct field design.
layouts required to simplify various phases of project con-struction; and establishment of testing programs / procedures and supdrvision of final systems / component acceptance testing.
i
\\
O i
l O
PROFESSIONAL QUALIFICATIONS OF ROBERT G. TAYLOR 0FFICE OF INSPECTION AND ENFORCD4ENT, REGION IV
. UNITED STATES N0 CLEAR REGULATORY COMMISSION Steam Electric Power. Station.Mr. Taylor is currently the Resident Reactor Inspec i
In this position, he serves to: coordinate all safety related inspection efforts relative to the NRC region and the site.
In addition, he maintains a field office, develops and recomends enforce-ment action, and acts as a liaison with regional, state and local agencies.
Prior to being the Resident Reactor Inspector at Comanche Peak, Mr. Taylor was the construction project reactor inspector at the South Texas Project from 1976 to.1978.
Mr. Taylor is a registered Professional Engineer in the State of California, specializing in quality control engineering.
Frior Work History 5
1978 - PRESENT Resident Reactor Ins'oector, Comanche Peak Huclear Power Sta tio n.
Duties include coordinating all safety related inspection efforts relative to the HRC region and the site, as well as, maintaining a field office and being a liaison with regional, state and local agencies.
1976 - 1978 Construction Project Reactor Insoector,' Arkansas Nuclear Power Unit No. 2 and South Texas Project. Duties included inspection of the Sourn Texas Project wnile under construc-tion to ascertain whether this facility confomed to the provisions of the construction pemit and relevant specifications.
1974 - 1976 Reactor Insoector, Vendor Inspection Branch, Project Inspector for Stone and Webster Corp. and Combustion Engineering, Inc.
1958 - 1974 Senior Quality Assurance Enoineer, Fort Calhoun Nuclear Power Station. Mr. Taylor was the Senior Quality Assur-ante Engineer for Gibbs and Hill, Inc.
1962 - 1968 Senior Quality Assurance Enoineer, A!!F Inc.
Duties in-cluded various quality assurance positions ~in regarti to ballistic missile construction projects.
- q m
m -
.m_
i 2-1960 - 1952 Construction Section Suoervisor, Quality Control, Titan 1.
Denver, Colorado United States Air Force.
1953 - 1950 Electronic Section Suoervisor, Quality Control, Chicago Air Procurement District United States Air Force.
f e
e 9
9 e
e e
e e
O e'
08 e
90 e
e S
e e
G g
e
,e d
4 9
9 e
e
y
-~
l
~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
TEXAS UTILITIES GENERATING COMPANY, et al.
Docket No. 50-445
)
50-446 (Comanche Peak Steam Electric Station,
)
Unites 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S ANSWER SUPPORTING APPLICANTS' MOTION FOR SUtHARY DIS?0SITION OF CONTENTION 5" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, or, as indicated by a double askterisk, by hand delivery, or, as indicated by a triple asterisk, by Express Mail or Overnight Delivery, this 2nd day of June, 1982:
Marshall E. Miller, Esq., Chairman **
Mrs. Juanita Ellis***
Administrative Judge President, CASE Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Comission Dallas, TX 75224 Washington, DC 20555 David J. Preister, Esq.
Dr. Kenneth A. McCollom***
Assistant Attorney General Administrative Judge Environmental Protection Dean, Division of Engineering, Division Architecture and Technology P.O. Box 12548, Capital Oklahoma State University Division Stillwater, OK-74074 Austin, TX 78711 Dr. Richard Cole **
Nicholas S. Reynolds, Esq.
l l
Administrative Judge Debevoise & Liberman l
U.S. Nuclear Regulatory Comission 1200 17th Street, N.W.
l Washington, DC 20555 Washington, DC 20036 t
i Atomic Safety and Licensing Board Docketing Service Section Panel
- Section (1)*
U.S. Nuclear Regulatory Comission Office of the Secretary l
Washington, DC 20555 U.S. Nuclear Regulatorj Comission Washington, DC 2055
p
.- Atomic Safety and Licensing Appeal Board Panel
- U.S. Nuclear Regulatory Comission Washington, DC 20555 Lucinda Minton, Esq.**
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D.C.
20555 M & 1A.1% % cle1d Marjorie U, Rothschild Codnsel for NRC Staff l
l I
l l
_