ML20111C139

Motion for Leave to File Addl Contention Re Qa,Per 10CFR2.714 Stds.Certificate of Svc Encl

ML20111C139
Person / Time
Site:	Braidwood
Issue date:	03/07/1985
From:	Cassel D ROREM, B.
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-011, CON-#185-11 OL, NUDOCS 8503140369
Download: ML20111C139 (23)

Text

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UNITED STATES OF AMERI A NUCLEAR REGULATORY COMMISSI0t! ffh' M BEFORE THE ATOMIC SAFETY AND LICENSING BOARD r ,,

,J '*n 7a In the Matter of: )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 0'

) 50 il57 0t (Braidwood Nuclear Stition, )

Unita 1 and P) )

MOTION FOR LEAVE TO FILE ADDITIONAL CONTENTION Intervenors Bridget Little Rorem, et al., by their underaigned counsel, pursuant to 10 CFR $ 2.714, move for leave to file the additional contention attached hereto. In support of their motion, intervenora state as follows:

1. Standards for Admitting Additional Contentions Section 2.714(a)(1)(1) through (v) sets forth five criteria which, under $2.714 and NRC case law, are the standards for admitting additional contentions. They are:

(1) good close, if any, for failure to file on t i. m e ,

(2) availability of other means to protect intervenors' interecta, (3) whether intervenors' participation may reaaonably analat in developing a nound record, (4) representation of intervenors' interents by existing parties, and -

(5) the extent to which the additional contentions will broaden the issues or delay the proceeding.

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r No one of these factors is controlling; rather they are to be considered "together." See Duke Power Co. (Catawba), 17 NRC 10141 at 1045 (1983). In applying them, the Board should balance intervenors' and the pu bli c's interest in a hearing "against the public interest considerations in the efficient and timely conduct of administrative proc eed i n gs." Id. at 10146 147 Here, for the reasons set forth below, intervenors and the public have. a strong int.erest in a hearing on the additional contention, and that hes. ring will not interfere with either the efficiency or timeliness of the proceeding.

2. Quality Assurance Intervenors' proposed quality assurance contention is as follows:

Commonwe alth Edison has not implemented, maintained and overseen an adequate quality assurance program for the constriution of Braidwood. Edison has not and does not adequately supervise the quality assurance programs of its construction contractors. This,is illustrated by, e.g.:

. the $100,000 fine imposed against Edtson for the faulty QA program of the Philips-Getschow Corporation;

. the non-compliance history of Edinon and its contractora at Braidwood;

. the NRC Regional Administrator's testimony in August,

, 19814, that there are " serious quality assurance questicns at Braidwood";

. the February, 1985 NRC CAT inspection report, which documented continuing quality assurance deficiencies, as well as inadequacies in the Braidwood Construction Assessment Program ("BC A P").

Because without an adequate QA program, Edison cannot show reasonable assurance that Braidwood will safety operate, no operating license may issue.

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The standards under $2.714 for filing this additional contention after the normal filing date are met, because it is based on both facts and evidence which arose after that date.

The original intervention petitions in this case were filed in 1979. Since then, there has been a long and continuing history of QA deficiencies at Braidwood. Without belaboring the many specifics, a succinct summary was provided by James Keppler, NRC Region III Administrator, during his August 1, 1984 testimony before the Atomic Safety Licensing Boar 1 on the Byron operating license. With respect to Byron, Mr. Keppler "tried to express to this Board the confidence that I have - more importantly the Board ought to be interested in the confidence my Staff has - and I say that because the Staff has had to contend with major qual ~ty problems at Zimmer, at M i d land ." (Tr. at 10,143.)

In contrast to Byron, M r. Kepple> assessment of Braidwood was quite different: "We've got serious quality assurance questions at Braidwood and at Clinton, and major reinspection efforts are underway to deal with these concerns." Id.

In other words, his staf f's confidence in Byron was, in Mr.

Keppler's opinion, all the more impressive because the Staff had shown its ability to detect " serious" quality assurance questions at Braidwood and other troubled plants.

M r. Keppler's testimony alone would afford a sufficient basis to justify a full hearing on the " serious quality assurance questions" at Braidwood. Unfortunately, recent evidence indicates that the QA questions to which he testified last August have still not been resolved at Braidwood.

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On February 20, 1985, the NRC Staff issued its Construction Appraisal Team (CAT) inspection report for Braidwood. (The Cover Letter, Executive Summary and Potential Enforcement Actions are attached heretc.)

While the CAT "noted no pervasive breakdown" (cover letter,

p. 1) (an opinion which intervenors do not share), it nonetheless noted enough quality assurance problems to justify continuing concern. For example:

. "The electrical contractor's quality control pro-gram was found deficient in that the inspection criteria was not sufficient to identify separation de fic ie nc i e s." (E.S. at A - 2. )

. " Contractor OC inspections and site QA programs have not been effective in assuring that installed pipe supports / restraints meet design requi rements."

'Id.)

. " Numerous examples of generally poor [ mechanical]

construction practices were observed." (Id.)

. "The NRC CAT inspectors do not consider that tha previously identified NRC concern regarding pipe co pipe and interdisciplinary clearances has been responded to in a timely or effective manner." (Id.)

. Although weld examination was generally proper, a number of undersized structural welds in pipe supports / restraints were found which "should have been identified during weld inspection by 0C."

Id. Moreover, engineering evaluation of these Undersized welds showed only that "most" remained adequate for their intended application. Id.

. Nonconformance reports issued by site contractors prior to 1983 need further review, because some were voided without documented justification, some dispositions were not routinely reviewed by appropriate engineers, and corrective actions "did not in some cases adequately resolve the nonconformances." (Id. at A-3.)

. While overall, management was " satis f actory,"

better quality control inspector training is needed. ( I_d . a t A - 4. ) In the text of the report (p. lx-9), the CAT team noted that the numerous 4

pipe support deficiencies " indicated poor craft performance and inadequate quality control inspec-tions," and that there were also numerous deficient electrical, instrumentation and struc-tural welds "that had not have [ sic] been identi-fled by first level quality control inspectors."

(Page IX-9 is also attached hereto.)

One might argue that the " serious" QA questions referred to by Mr. Keppler and the continuing problems identified by the CAT report will be cured by the ongoing " major reinspection" (BCAP) which, according to Mr. Keppler, is intended to " deal with these concerns." (Tr. 10, 143, above.)

However, BCAP is not - at least not yet - adequate to answer these concerns, for at least the following reasons:

1. BCAP is still underway. Its results and effectiveness are not yet known.

2. The CAT team found deficiencies in BCAP itself:

"In four of the six areas that were over-inspected, there was general agreement between BCAP and NRC CAT findings; in two areas, supports / restraints and piping runs, deficiencies were identified by the NRC CAT that were not identified by the BCAP inspectors. On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in the areas of supports / restraints and piping runs." (E.S. at A-1.)

3 The NRC CAT has a " major concern" over Edison's ability to manage the large number (over 20) of ongoing major corrective action programs [ including BCAP] and ensure that current work is correctly performed." (Cover letter at 1.)

4. The NRC CAT also has a " major concern" with respect to Edison's " dependence on final walkdown inspections late in the construction program to identify and resolve problems." (Id.) The CAT team elaborated, " System ' and arca walkdown inspections performed late in the construc-tion program must be recognized as only an additional level of assurance of proper installation and not a substitute for detailed, item specific first line QA i n s pec t i on s ." (E.S. a t A-2.)

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In sum, Braidwood's history of " serious" QA problems made it, as of August 1984 in the opinion of the NRC Regional Administrator, a plant in which the NRC Staf f had f ar less confidence that it had in Byron; that same history has given rise to over 20 ongoing major corrective action programs; additional QA deficiencies continue to be identified; and the NRC CAT has a

" major concern" over whether Edison can simultaneously correct all the past deficiencies and ensure correct performance of current work.

Based on this evidence - all of which has arisen since 1979

- there is both " good cause" for intervenors' filing of their QA contention later than the normal filing date, and a demonstrated need for a f ull hearing to air and examine the serious QA ques-tions which exist concerning Braidwood.

Moreover, with respect to the other 52.714 criteria:

. no other means are available to protect intervenors' interest, since no other forum for a hearing exists,

. intervenors' participation will assist in developing a sound record, given their longstanding commitment to Braidwood, as well as the experience of their counsel in litigating similar issues at Byron,

. no other party represents intervenors' interest, since the NRC Staff has not indicated its agreement with intervenors' contention, and in any event does not represent their particular interests, and

. this single additional contention will not unduly burden the issues or delay the proceeding. Ample time remains in the schedule to litigate the QA issue, and intervenors will make every good faith effort to litigate the issue in a timely fashion which need not delay the Braidwood fuel load date, in the event the Board were to reject our contention and issue a license. Moreover, the present schedule is likely more ambitious than necessary to meet the fuel load date. That date has repeatedly been postpcned in the past, most recently in December, 6

1984, and it is highly likely to be postponed again.

According to an expert study by utility analyst Charles Komanoff, more realistic in-service dates for Braidwood 1 and 2, rather than October 1986 and December 1987 as now projected by Edison, are July 1987 and July 1988, respectively. */

f CONCLUSION For,the foregoing reasons, the criteria of S2.714 are met and the quality assurance contention of Intervenors' Rorem et al.

should be admitted in this proceeding.

March 7, 1985 Respectfully submitted, f

Dougla s W. Cassel, Jr. y One of the Attorneys for Intervenors Bridget Rorem et al.

For Service: i l

Douglass W. Cassel, Jr.

Timothy W. Wright III 109 North

Dearborn,

1. 1300 Ch(cago, Illinois 60602 (312) 641-5570

• / "The Cost To Complete Construction of Commonwealth Edison's Braidwood and Byron Nuclear Power Plants," July 1984, by Charles Komanoff, filed in Illinois Commerce Commission docket 82-0855, at pp. 42-43 (copies of pp. 42-43 are attached hereto. If the Board or any party desires a copy of the full report, counsel will promptly provide it.)

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3/7/85 INTERVENORS' ROREM, ET AL. ADDITIONAL CONTENTION Quality Assurance Commonwealth Edison has not implemented, maintained and overseen an adequate quality assurance program for the construction of Braidwood. Edison has not and does not adequately supervise the quality assurance programs of its construction contractors. This is illustrated by, e.g.-

the $100,000 fine imposed against Edison for the faulty QA program of the Philips-Getschow Corporation; the non-compliance history of Edison and its contractors at Braidwoo d;

. the NRC Regional Administrator's testimony in August, 1984, that there are " serious quality assurance questions at Braidwood";

the February, 1985 NRC CAT inspection report, which documented continuing quality assurance deficiencies, as well as inadequacies in the Braidwood Construction Assessment Program

("BCAP").

Because without an adequate QA program, Edison cannot show reasonable assurance that Braidwood will safely operate, no operating license may issue.

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/ ,%, UNITED STATES 8 g

, E NUCLEAR REGULATORY COMMISSION WASm NCTON, D. C. 20555 w s a 5

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1 February 20, 1985 4

Docket Nos. 50-456 6

50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President P.O. Box 767 Chicago, IL 6C690 Gentlemen:

SUBJECT:

CONSTRUCTION APPRAISAL TEAM INSPECTION 50-456/84-44, 50-457/84-40 i

Enclosed is the report of the Construction Appraisal' Team (CAT) inspection conducted by the Office of Inspection and Enforcement (IE) on . December 10-20, 1984 and January 7-18, 1985 at the Braidwood site. The Construction Appraisal Team was composed of members of IE, NRC Region III and a number of consultants.

The inspection covered construction activities authorized by NRC Construction Permits CPPR-132 and CPPR-133.

i This inspection is the tenth of a planned series of construction appraisal.

inspections by the Office Inspection and Enforcement. The results of these inspections are being used to evaluate the management control of construction activities and the quality of construction at nuclear plants.

The enclosed report identifies the areas examined during the inspection.

Within these areas, the effort consisted primarily of detailed inspection of selected hardware subsequent to quality control inspections, a review of selected portions of your Quality Assurance Program, examination of procedures and records, observation of work activities, and an examination of your project management.

Appendix A to this letter is an Executive Summary of the results of this inspection and of conclusions. reached by this office. 'The NRC CAT noted no pervasive breakdown in meeting _ construction _ requirements in the samples of installed hardware inspected by the team or in the applicant's project construction controls for managing the Braidwood project.

However, deficiencies noted by the NRC CAT in a number of hardware installa-

.tions indicate a need for more management attention. The deficiencies

> included examples of inadequate hardware inspection and examples of inadequate quality assurance and engineering review of deficiencies for general applica-tion. The major areas of concern to the NRC CAT are: (1) the dependence on final walkdown inspections late in the construction program to identify and

' resolve problems; and.(2) the ability to manage the large number (over 20) of ongoing major corrective action programs ~and ensure that current work is cor-

'rectly performed.

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-w February 20, 1985 Comonwealth Edison Company .

The NRC team observed that CECO was implementing some good i.onstruction practices at the Braidwood site. These include active CECO management involvement in the construction of the project, the use of an independent test agency for inspection overview and unit concept review for construction adequacy, and the initiation of a Quality First Program.

Appendix B to this letter contains a list of potential enforcement actions based on the NRC CAT inspection observations. These are being reviewed by the Office of Inspection and Enforcement and the NRC Region III Office for appropriate action'. In addition, Region III will be following your corrective action for deficiencies identified during this inspection.

Inaccordancewith.10CFR2.790fa),acopyofthisletterandtheenclosures will be placed in the NRC.Public Document Room.. No reply to this letter is required at this time. You will be required to respond to these findings af ter a decision is made regarding appropriate enforcement action.

Should you have any questions concerning this inspection, please contact us or the Region III Office.

gMb James M. Taylor, virec r Office of Inspection and. Enforcement

Enclosures:

1. Appendix A - Executive Summary

2. Appendix B - Potential Enforcement Actions

3. Inspection Report cc w/ enclosures:

See next page g

APPENDIX A EXECUTIVE

SUMMARY

An announcec! NRC Construction Appraisal xTeam (CAT) i_nspection was conducted at Commonwealth Edison Company's (Ceco) Braidwo3d Station during the period December-10-20, 1984 and January 7-18, 1985.

Overall Conclusions

~ Hardware, Project Management and documentatinn for construction activities were generally in accordance with requirements and licensee commitments. However, the NRC. CAT did identify a number of construc tion program weaknes'ses that require increased management attention. These are:

1. The effectiveness-of first level quality control (QC) inspection'activi-ties'needs to be improved, particularly in the pipe support / restraint and welding areas.

2. A large number of final inspection activities are being included in a final walkdown, when greater difficulty will be encountered in identifying deficiencies because of interferences, accessibility and the pressure of schedul e.

3. The ideatification and resolution of cable tray and conduit electri-cal separatiun deficiencies is inadequate.

4. An excessive number of incidents of damage to installed equipment has been-caased by current construction activities.

The foregoin] identified weaknesses require additional management attention to assure that :ompleted installations meet design requirements.

An ef fort was made by the NRC CAT to evaluate the ~ ongoing Braidwood Construc-tion Assessment Program (BCAP). The schedule for.the BCAP inspection program ~

was such that only limited hardware cples were available-for.NRC CAT over-inspection. It was possible to overinspect a very small sample of hardware in the areas of supports / restraints, piping runs, HVAC supports and ducts for welding, HVAC ducts for configuration and conduit runs. -In four of the six areas that were overinspected, there was general agreement between BCAP and NRC CAT findings; in two areas, supports / restraints and piping runs,.deficien-cies were identified by-the NRC CAT that were not identified by the-BCAP inspectors. On the basis of the limited. sample overinspected,'it appears that BCAP inspection effort needs to be improved in'the areas of supports / restraints and piping runs.

AREAS INSPECTED AND RESULTS Electrical and Instrumentation Construction

-The electrical and instrumentation samples' inspected generally met the applicable design and construction requirements'. However, construction and .j

. inspection deficiencies were identified in several areas including several

. items which will require additional NRC review and analysis.

A- 1.

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' Site implementation of electrical separation criteria is not consistent with I

the FSAR commitment.which, with several exceptions, endorses IEEE Standard 384-1974. Several items regarding the interpretation of separation criteria will require additional NRR review. The electrical contractor's quality

" control. program was found deficient in that the inspection criteria was not sufficient to identify separation deficiencies. As a result, a number of installations of non-Class 1E to Class 1E raceway and cable were found that did not meet the IEEE requirements and the FSAR commitments for minimum separation.

The majority of bnits used with raceway supports are of indeterminate material l as they do not contain the manufacturer's identification required by the ASTM i standard.

l Although the instrumentation sample was not sufficiently large because of an ongoing reinspection program to draw an overall conclusion, a number of instances were identified of items damaged during the erection of scaffolding.

Mechanical Construction Contractor QC inspections and site QA programs have not been effective in assuring that installed pipe supports /restaints meet design requirements. The inspection and acceptance criteria provided for activities such as QC inspec-tion and document review and control need to be strengthened and clarified.

Numerous examples of generally poor construction practices were observed.

The need to protect and maintain installed and accepted hardware needs to be reemphasized.

Piping, ilVAC, concrete expansion anchors and mechanical equipment were generally found to be installed in accordance with requirements or_ with deficiencies that had previously been identified. However, because of ongoing re-evaluations and reinspections, it was not possible to establish a complete and conclusive assessment of these areas.

The tac CAT inspectors do not consider that the previously identified NRC concern regarding pipe to pipe and interdisciplinary clearances has been

' responded to in a timely or effective manner. System and area walkdown inspec-tions performed late in the construction program must be recognized as only an' additional level of assurance of proper installation and not a substitute for i

detailed, item specific first line QC inspections.

Welding and Nondestructive Examination Welding and nondestructive-examination = activities were generally found to be-conducted in accordance with.the governing codes and specificatio~ns. However, a number of examples were identified where completed structural welds _in pipe supports / restraints did not have the weld sizes specified by the design' draw -

j ings. These undersized welds should have been_. identified during the weld inspection by QC. The licensee has performed an-engineering-evaluation con--

cerning this problem and concluded that most of these welds are adequate for the intended. application. In the area of vendor supplied ASME-tanks and heat l exchangers a- number of tanks were found to have undersized weld reinforcement in nozzle to shell and manway to shell welded joints.

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The NRC CAT inspectors also found radiographs which did not meet the specified acceptance criteria. The licensee's quality assurance procedures do not require that an independent interpretation of radiographs be performed prior to final storage in the vault. The NRC CAT believes that this lack of indepen-dent radiographic interpretation may have contributed to the Project's inability to detect deficient radiographs.

'ivil and Structural Construction

. Concrete quality was acceptable. Requirements for rebar around three of four inspected construction openings and cadweld testing frequency were not met.

Structural steel member sizes, configurations and connections had no major concerns identified. A few high strength steel bolts were found to be installed at below specified torque values.

In the area of masonry wall construction, a concern _was identified regarding the need to assure proper rebar anchorage prior to. replacement of masonry in the removed sections of masonry walls.

Material Traceability and Control

, The measures presently established for material traceability and control for 4

ongoing work appear to be adequate except for one area. During this inspec-tion, it was determined that 10,500 feet of switchboard wire not qualified to

IEEE 383-1974 was installed at Braidwood-Station.

Corrective Action The corrective action programs generally are being implemented in accordance with requirements. However, based on the results of this inspection, the controls for nonconformance reports issued by site contractors previous to 1983 need additional review. These include:

1. Some nonconformance reports were voided without documented justification.

2. Nonconformances dispositioned "Use-As-Is" or " Repair" were not routinely reviewed by the appropriate engineerin'g personnel.

3. 'he specified corrective actions did not in some cases adequately resolve the nonconformances.

. Design Change Control Design change. control was determined to be generally in conformance with applicable requirements. In the area of the most significant. finding was the failure to annotate. unincorporated design changes on controlled design docu-ments. :The most significant finding in the area of. design change control was design change documents written against superseded revisions of the approved.

design dra' wings. In at least one instance, this. deficiency resulted in a pipe

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support being installed'and inspected to other than the latest approved design.

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Project Management The overal1 project management effort is evaluated to be satisfactory to construct the project in conformance with quality standards. Additional management attention is required _to improve contractor performance in the areas.of contractor deficiency trending, and craft and quality control inspector training.

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I APPENDIX B POTENTIAL ENFORCEMENf ACTIONS As a result of the NRC CAT inspection of December 10-20, 1984 and January 7-18, 1985 at the Braidwood site, the following items are being referred to Region III as Potential Enforcement Actions (section references are to the detailed portion of the inspection report).

1. Contrary to 10 CFR 50, Appendix B, Criterion VII and Ceco Quality Assurance Manual, Quality Requirement No. 7.0, the measures to assure that equipment and services conform to the procurement documents were found to be ineffective in that vendor procured tanks and heat exchangers were accepted and installed with deficient welds. In addition, various vendors have supplied radiographs which did not have the required weld and film quality. (Section IV.B.1, 10)

2. Centrary to 10 CFR 50, Appendix B, Criterion VIII and CECO Quality Assurance Manual, Quality Requirement No. 8.0, the licensee failed to implement measures to prevent the following incidents:

a. 10,500 feet of General Electric "VULKENE" switchboard wire was received at Braidwood. Some of this wire has been installed without appropriate qualification to IEEE 383-1974. (Section VI.B.1)

b. Sargent & Lundy standard EB115.0 required the use of ASTM A307 bolting material for Class 1E seismic cable tray hangers. Hangers in the lower cable spreading room did not utilize ASTM 307 fasteners in some cases. Also, the generic qualification document for the Class IE storage batteries specified ASTM A307 bolts for the battery racks.

The battery racks were inspected and found to have bolting material that did not meet the requirements of ASTM A307. (Section VI.B.1)

3. Contrary to .0 CFR 50, Appendix B, Criterion X and Ceco Quality Assurance Manual, Quality Requirements No.10.0, the licensee's inspection programs have failed to identify areas where seismic category I pipe supports /

restaints and other seismic pipe supports / restraints have not been constructed in accordance with design requirements. (Section III.B.2)

4. Contrary to 10 CFR 50, Appendix B, Criterion X, and CECO Quality Assurance Manual, Quality Requirement No.10.0, the licensee fai, led to provide an adequate inspection program in that electrical separation criteria established in quality control procedures were not sufficient to identify installations of raceway and cables violating design requirements for separation. (Section II.B.1)

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S. Contrary to 10 CFR 50, Appendix B, Criterion X and the Ceco Quality Assurance Manual, Quality Requirement No. 10.0, the program for inspection of activities affecting quality was not effectively implemented in that the inspection programs have not identified that the specified weld sizes in structural pipe support / restraints have the required weld configura-tion. (Section IV.B.1)

6. Contrary-to 10 CFR 50, Appendix B, Criterion XVI and CECO Quality Assurance Manual, Quality Requirement 16.0, the licensee's electrical contractor's corrective actions for the following NCRs were found to be inadequate:

a. NCR 39, issued in April 1979, identified weld deficiencies in elpc-trical struts and hangers. The supporting documentation attached to the NCR identified that 90 percent of the welds were unacceptable.

The corrective action block on the NCR was marked "N/A" and contained a statement identifying the welds as acceptable. There was no documentation supporting this corrective action statement on the NCR.

(Section VIII.B.1)

b. NCR 293, issued in May 1981, identified weld deficiencies on back to back B-line strut and spaced back to back strut. The corrective action was to rework the deficient welds on the back to back strut and return the spaced back to back strut to the vendor.

Inspection of installed spaced back to back strut identified numerous weld deficiencies. Based on the weld deficiencies noted in the installed strut, the corrective action for this NCR was ineffective. (Section VIII.B.1) 4 l

l F .B-2 r

to be a lack of training schedules and programs to improve craft workmanship.

The control of measurement and test equipment for the site contractors Phillips Getscnow, G. K. Newberg, L. K.

Comstock and Pittsburg Testing Laboratories was reviewed.

Procedures, calibration certifications, out of tolerance reports, corrective actions and the physical equipment was reviewed. In L.K. Comstock's crib no. 4 in the Auxiliary Building, two portable weld rod carriers were identified with calibration stickers indicating they were beyond their' calibration due date. In the G.K.

Newberg fabrication shop, three poetable weld rod carriers were located that did not have any identifying-calibration stickers nor hold tags. A log entry for one of the carriers indicated it had been taken out of service.-

A CECO QA audit in 1984 had previously identified a number of deficiencies in both L.K. Comstock and G.K.

Newberg control of measurement and test equipment programs and both contractors were in the process of taking corrective action.

Craft performance and effective contractor first level quality control inspections need improvement. As documented in Section III of this report, numerous pipe support / restraint deficiencies were identified by the NRC CAT inspectors that_ indicated poor craft performance and inadequate contractor quality control inspections. In Section IV of this report, the CAT inspectors identified numerous deficient welds in the areas of electrical supports, instrumentation supports and structural steel that had not have been identified by first level contractor quality control inspectors.

TableisIX-1 each lists CECO and site contractors and the work performing. In addition, the table indicates the number of craft workers, the size of the QA/QC staff, the existence of QA/QC organizational independence, the presence of QA/QC supervisory position descriptions and if there is periodic review of the contractor's QA program.

(5) Management and Supervisory Support of QA/QC The NRC CAT inspector conducted interviews and discussions with CECO and contractor QA/QC management, engineers, auditors and inspectors to determine if CECO is committed to the support of quality assurance efforts to build a quality plant. The following observations were made:

IX-9

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,- T!!E COST TO COMPLETE CONSTRUCTION OF COMMONWEALTil EDISON'S BRAIDWOOD AND BYRON NUCLEAR POWER PLANTS i

l July, 1984 Charles Komanoff Komanoff Energy Associaten 451 Broome Street

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New York, NY 10013 l

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m. s y +ei+ w -p s.9 --p- gc w. p

4 Projecting an in-service date for Braidwood is a more com-plex task. As the table below illustrates, even since the award hk of NRC construction permits, Edison has repeatedly postponed the expected service dates for Braidwood and Byron:

Edison's Projected Service Dates */

Date of Projection In-Service date p ro j e c t.ed for:

Braidwood Byron Unit 1 Unit 2 Unit 1 Unit 2 1/76 10/81 10/82 10/80 10/82 12/76 " "

3/81 "

1/78 " "

9/81 "

6/79 10/82 10/83 10/82 10/83 jg 2/80 10/83 10/84 " "

6/80 10/85 10/86 10/83 10/84 12/81 " "

2/84 2/85 1/83 " " "

8/85 6/83 " "

6/84 11/85 1/84 4/86 4/87 1/85 4/86 As this table shows, Edison's record of over-optimism in p ro j ec t. i nt; in-service dates for Braidwood and Byron is comparable to its record of over-optimism in project,ing costs. Braidwood is already four and rne half years behind the schedule proj ec t.ed following its receipt of a construction permit; Byron is likewise almost four years behind its post-construction permit schedule.

1/ Source: See note page 8 above.

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m As recently as June of 1979, Edison was projecting that all four Braidwood and Byron units would be in-service by last year; as it turns out none is in service.

Equally striking in the table is Edison's remarkable optimism in recent years about Braidwood's in-service date. From June 1980 through the end of 1983 -- a period during which Edison increased its Braidwood cost estimate twice, from $2.6 billion to

$ 3.1 billion -- the company steadfastly maintained that Braidwood units 1 and 2 would be completed by October 1985 and October 1936, respectively. Only this year has Edison belatedly conceded that a further six-month slippage will occur.

Even apart from its assumption that real construction expen-ditures on Braidwood will be far below any realistic forecast, p Ed i son's current Braidwood schedule is simply not credible.

For purposes of calculating future AFUDC on Braidwood, in my judgment it is reasonable to assume that Braidwood 1 and 2 will enter commercial service in July 1987 and July 1988 respectively.

This reflects a delay of 15 months in the company's current April 1986 and April 1987 scheduled in-service dates. Such a delay amounts to a 45 percent lengthening of the company's expected remaining schedule. A 45 percent incremental schedule delay for a 93 percent incremental real cost increase (both calculated from a January 1, 1984 base) appears reasonably consistent with gen-eral nuclear industry experience in recent years, where overruns in (real) dollars appear to be a small integer multiple of over-runs in time, s, For purposes of these calculations, 'I have also assumed that 43

UNITED STATES OF AMERICA t'.. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD,

~

In the Matter of: 1)

. .)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

.. ) 50-457 (Braidwood Nuclear Station, )

UnitsE1 and 2) , )-

CERTIFICATE OF SERVICE -

I hereby certify that I have served copies of, [Intervenors']

Motion For' Leave To File Additional Contention on each party listed on the attached Service List by having said-copies placed in envelopes, properly addressed and postaged.(first class) and deposited in the U.S. mail-at 109 North

Dearborn,

Chicago, Illinois on this 7th day of March,.1985; except that Messrs.

Brennen, Callihan, Cole and Gallo, and Ms. Chan were served via Federal Express overnight delivery, and -Mr. Miller via hand delivery on Ma.'ch 8, 1985.

M "

f.

Attorney.

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l 9

BRAIIMOOD SERVICE LIST Lawrence Brenner DockTting & Service Section Michael I. Miller, Esq. Qqtman Office of the Secretary Isham, Lincoln & Beale Adninistrative Law Judge of the Camission Atanic Safety & Licensing Bo. U.S. Nuclear Regulatory Three First National Plaza U.S. Nuclear Regulatory Carm Commission 52nd Floor Washington, DC 20555 Chicago, IL 60602 Washington, DC 20555 Rebecca J. Lauer Dr. Richard F. Cole Dr. A. Dixon Callihan Isham, Lincoln & Beale Administrative Isa Judge Three First National Plaza Adninistrative Iaw Judg United States Bhiclear 52nd Floor h Regulatory Cormission Chicago, IL 60602 P O' Bo 7335 Old Georgetom Rd.

Oak Ridge, TN 37830 Bethesda, BD 20814 Ms. Bridget Little Rorem Joseph Callo 117 North Linden Street Isham, Lincoln & Beale Essex, IL 60935 1120 Connecticut Avenue IU Suite 840 Washington D.C. 20036 Elaine Chan, Esq.

C. Allen Bock, Esq. NRC Staff 0)unsel P.O. Box 342 U.S. Nuclear Regulatory Urbana, IL 61801 Cmmission 7335 Old Georgetom Road Bethesda, MD 20014 s

Thmns J. Gordon, Esq.

Waaler, Evans & Gordon Atomic Safety & Licensing 2503 S. Neil Appeal Board Panel Champaign, IL 61820 U.S. Nuclear Regulatory Camassion Washington, DC 20555 Atomic Safety & Licensing Lorraine Creek Board Rout #1, Box 182 Nanteno, IL 60950 U.S. Nuclear Regulatory Cmmission Washington, DC 20555

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