ML20125B745

Affidavit of Mj Wallace Re QA Contention.Scheduling of Programs Would Be Altered by Necessity to Support Currently Proposed Hearings Schedule.Certificate of Svc Encl

ML20125B745
Person / Time
Site:	Braidwood
Issue date:	06/07/1985
From:	Wallace M COMMONWEALTH EDISON CO.
To:
Shared Package
ML20125B738	List: ML20125B732 ML20125B745
References
OL, NUDOCS 8506110528
Download: ML20125B745 (8)

Text

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-p - ,. . On June 7, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ETED g gC In the Matter of: )

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-COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-4 56 Q6

) 50-457et. GFFICE 0r SECRt TAsy (Braidwood Nuclear Power ) $$fgjSEEVICI.

Station, Units 1 and 2) )

AFFIDAVIT OF MICHAEL J. WALLACE I, Michael J. Wallace, being first duly sworn, depose and state as follows:

I am employed by Commonwealth Edison Company as the Assistant Manager of Projects and as the Project Manager of Braidwood Nuclear Power Station. As Project Manager of Braidwood, I have primary responsibility for completion of the Braidwood Project, through fuel load of Unit 2, in-cluding the management of construction, testing, and op-erating activities. More specifically, my management re-sponsibilities' include, among other things, the scheduling and completion of construction activities, and verification and corrective action programs, giving due consideration to quality, budgetary, schedule and regulatory constraints.

In the course of my duties, I have been advised by 8506110528 850607 PDR ADOCK 05000456 g PDR 2

Commonwealth Edison's counsel in the Braidwood licensing proceeding that a quality assurance ("QA") contention may be admitted in that proceeding. Counsel advised that admission of such a contention could necessitate litigation of the

'following corrective action programs: the heating, ven-tilation, and air conditioning ("HVAC") configuration pro-gram, the HVAC duct fitting verification program, the HVAC housings and air risers program, the concrete expansion anchor ("CEA") inspection program, the safety-related mechanical equipment reinspection program, and the electri-cal document review. Counsel further advised that such litigation could not be undertaken and the record in the NRC licensing proceeding could not be closed on such a conten-tion until these corrective actions and programs have been implemented to the point where reasonably complete actions have been taken or reasonably final results are available.

I have prepared this affidavit to address how the scheduling of these program would be altered by the necessity to support the currently proposed hearing schedule. In addi-tion, I have included a discussion of the fuel load dates for Braidwood, Units 1 and 2.

A. Scheduling of programs in support of hearings.

For work on Braidwood Unit 1, the completion of the programs listed above is scheduled as follows: HVAC

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i hanger configuration by February 15, 1986; HVAC duct fitting verification program by December 15, 1985; HVAC housings and air risers program by February 15, 1986; CEA inspection

_ program in March 1986; reinspection of safety-related mechanical bquipment in March 1986; and electrical document review in December 1985. The current completion schedules for the programs were based upon engineering and management judgments made over the preceding 2 years as to the most

. efficient way to complete the corrective actions coincident with ongoing work, in terms of quality, schedule, and budgetary considerations.

I have reviewed each program to determine whether the completion dates could be advanced to support the

. currently proposed hearing schedule. Such rescheduling efforts would be constrained by a number of practical and l- managerial considerations. For example, the extent to which completion dates can be. advanced will depend upon the other responsibilities of the contractor's existing personnel, the availability of additional personnel, and the practical

[ constraints on how quickly such additional personnel can be integrated into the project so that they become productive.

-My estimates of the extent to which the completion dates for the corrective action programs can be advanced depend upon judgments as to these practical constraints as well as on maintaining appropriate levels of quality in the ongoing

construction activities.

The results of my review indicate that, even if the scheduling of work at Braidwood is revised to make the programs implicated by Intervenors' contention the first

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priority for completion at Braidwood, all of these programs

.cannot be completed in time to support the efforts of coun-sel in meeting the currently proposed hearing schedule. If, at the time the need for these corrective actions became apparent or even as recently as six months ago, I had been advised that the corrective actions would need to be com-pleted well in advance of their currently scheduled com-pletion dates in order to accomodate the scheduling needs of the hearing process, I would have scheduled the conduct of these programs differently.

I Based on my review of the three HVAC programs being implemented by Pullman Sheet Metal, I estimate that it would not be possible to finish the hanger configuration program for Unit 1 until approximately December 1, 1985, while advancing the duct fitting verification program to October 1, 1985 and the housing and air riser program to November 1, 1985. I also reviewed the feasibility of advancing the CEA inspection program and the safety-related mechanical equipment reinspection program of the mechanical erection contractor, Phillips-Getschow. Realistically, I estimate that the CEA program could be advanced to completion J

by October.1, 1985, but the safety-related equipment program could not be completed until November 1, 1985. For the electrical contractor, L. K. Comstock, I reviewed the scheduling for the CEA inspection program and the electrical

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document re' view. These programs could probably both be completed by October 1, 1985.

If I had known of the need to expedite these corrective action programs soon after the issues arose in the-public record or even as recently as six months ago, additional personnel could have gradually been integrated into the project so that the programs could have been completed in time to support the proposed hearing schedule.

However, it now appears that it is not feasible to accelerate completion of the programs at this date so that the proposed hearing schedule can be me't.

B. Fuel load dates.

In its annual schedule and budget review in Decem-ber 1984, Commonwealth Edison Company estimated that fuel would be loaded in Braidwood Units 1 and 2 in April 1986 and July 1987, respectively. The Company uses these dates for planning purposes, although there are contingencies which could cause fuel load to occur later than the above dates.

If the QA contention is not admitted, I believe it is pos-sible to achieve an April 1986 fuel load date for Unit 1.

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There'are, however, a number of activities which must be concluded on an accelerated basis in order to achieve that date. _Recent experience leads me to believe that this will occur. However, it is also possible that unforeseen events

. may lengthen the construction process and accordingly the fuel load date could be extended beyond April by several months. -

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's Michae ." Wallace SUBSCRIBED AND SWORN to before me this 7 3 day of June, 1985.

,V w Notary Public Q My Commission Expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter-Of: )

COMMONWEALTH EDISON COMPANY UfNac

) Docket Nos. 50-456QL (Braidwood Nuclear Power ) 5 -45700 Station, Units 1 and 2) ) JW110 All:50 GFFICE OF 35cgg 7,,,

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CERTIFICATE OF SERVICE BRANCH I, Joseph Gallo, one of the attorneys for Common-wealth Edison Company, certify that copies of Applicant's Response in Opposition to Intervenors' Motion to Admit Amended Quality Assurance Contention have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 7th day of June, 1985, except where service was made this same day by hand delivery and Federal Express as directed.

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/ Soseph Gallo ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.

Washington, D.C. 20036 (202) 833-9730 DATED: June 7, 1985 L i

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SERVICE LIST l

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• Lawrence Brenner, Esq. Mr. William L. Clements Chairman- Chief,' Docketing and Services Administrative-Law Judge United States Nuclear Regulatory Atomic Safety and Licensin9 , Commission Board. . Office of-the Secretary l'

United States Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 C. Allen. Bock, Esq.

P.O. Box 342.

• Dr. Richard F. Cole Urbana, IL 61801 Administrative Law Judge Atomic Safety and Licensing Board Ms. Bridget Little Rorem United States Nuclear Regulatory 117 North Linden Street Commission P.O. Box 208 Washington, DC 20555 Essex, IL 60935 Robert Guild

• • Dr. A. ' Dixon Callihan Douglass W. Cassel, Jr.

l- Administrative Law Judge Timothy W. Wright, III 102 Oak Lane BPI Oak Ridge, TN 37830 109 North Dearborn Street Suite 1300 Chicago, IL 60602

• Myron Karman, Esq.

Elaine I. Chan, Esq.

Office of the Executive Legal Ms. Lorraine Creek Director Route 1 United States Nuclear Regulatory Box 182 Commission Manteno, IL 60950 Washington, DC 20555 Charles Jonen, Director Atomic Safety and Licensing Illinois Emergency Services Board Panel and Disaster Agency United States Nuclear Regulatory 110 East Adams L Commission Springfield, IL 62705

. Washington, DC 20555 Atomic Safety and Licensing

' Appeal Board Panel United States Nuclear Regulatory Commission Washington, DC 20555

• Hand delivery on June 7, 1985

• • Federal Express delivery

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