ML20133B746
| ML20133B746 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/01/1985 |
| From: | Barnes P COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20133B708 | List: |
| References | |
| OL, NUDOCS 8508060250 | |
| Download: ML20133B746 (13) | |
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- Rf1ATED CORRESPONDfJQ July 30, 1985 Revised August 1, 1985 UNITED STATES OF AMERICA NUCLEAR RECULATORY C000tISS105 00tXE 4D usuc BEFORE THE AT0001C SAFETY AND LICENSING BOARD
'85 AUG -5 All :31 In the Matter oft ) cmc pgm u ,
Commonwealth Edison Company ) OLL Ptni 4 $1 b st
) Docket Nos. 50-456 f>H A NCH
) 50-457 (Braidwood Nuclear power )
station, Units 1 and 2) )
Applicant's First Partial Response to morea's First set of Quality Assurance lggrroaatories and Reeuests to Produce On July 2,1985, Intervonors moren, gi 31., ("Intervonors") filed their First set of Quality Assurance Interrogatories and Requests to Produce. On July 30, 1985, Commonwealth Edison Company (" Applicant") flied objections to certain of those discovery requests. This submission is Applicant's first partial response to Intervonors' discovery requests. Investigation continues for responses to all of the requests to which Applicant has not objected.
Mach document identified in Applicant's response or incorporated by reference into Applicant's response has been identified with a number. In addition, Applicant has provided indices for these documents organised by interrogatory number, which identify for each numbered document the date, author, recipient, and type of document. The indices will be updated with each partial response submitted by Applicant.
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i Documents which are incorporated by reference to answer interrogatories i are being provided to all porttee. Documents which are simply identified in answere to interrogatories, but not incorporated by reference, are available I for inspection and copying. Documents for which Applicant is asserting privilege have not been provided, and an indication een be found on the t indises as to whether the attorney client ("Ac") or attorney work product I
("WP") privilege is being asserted. f i
With regard to requeste for addresses and telephone numbers of i individuale employed by Comunonwealth Edison or its sentreetore, onette personnel can be located by contacting Braidwood puelear power station, l Bracev111e, 111& note 60407 (phone $15-454-2301). Other Commonwealth Beison personnel een be located by contacting 72 W. Adame St., p.0. Som 767, Chicago, l l
Illinets 60490 (phone 312-294-4321). Applicant le making a further review of .
individuale identified in response to speelfte interrogatories and will evpplement its answere to the extent that such individuale now have other addresses of telephone numbers. l t
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SPECIFIC INTER 30GATORY 9 please identify each deficiency in design and conettwetion as defined in 10 CFR Section 50.55(e) and for each indicate the classification of its significance (i.e., classified under which subsections, 50.55(e) (1) (1-iv);
the 10 CFR part 50 Appendix A General Design Criteria to Which each relates and the respects in which it reflects noncompliance, the report number, and date, if any; the names, titles, addresses, and telephone numbers of each person responsible for the deficiency, its discovery, its reporting, and its corrective action; a detailed description of the deficiency and its safety implications, a detailed description of its correction action.
Resp 0585 The NBC identified certain deficiencies referenced in the Contentions in Inspection Report (s) 82-05, 83-09, and 84-17. Applicant classified these same deficiencies as reportable under 10 C.F.R. 50.55(e). Section 50.55(e) Esports 82-07, 83-07, and 84-10 which Applicant is providing in response to the Interrogatory set forth most of the information requested. Applicant is unable to relate the deficiencies reported to the General Design criteria of 10 C.F.R. part 50, Appendix A since these deticiencies were not design deficiencies. Applicant does not use a system of classification of reportable deficiencies which corresponds one to one with the subcategories of 50.55(e)
(1). Applicant reported 50.55(e) Neport No. 42-07 in response to a specific ites of noncompliance in NRC Inspection Report No. 82-05 without specifically classifying the deficiency under 50-55(e)(1). In the case of 50.55(e) Report No. 83-07, Applicant reported the deficiency only as notentially reportable under 50.55(e) and has to date made no s18nificance determination. For 50.55(e) Report No. 84-10, the deficiency falls under subcateso ry (111). In addition, Applicant is unable to identify any specific individuals who were responsible for the specified deficiencies.
4-SPECIFIC .1ETERROGAMEY .12 Describe in detail each review of the traidwood quality Assurance Program by the NBC Staff. For each, please indicate the deficiencies found, the adjustments, modifications and improvements resulting or otherwise model the Commonwealth Edison position and response; the names, titles, addresses and telephone numbers of each person involved and a description of the involvement of each.
RESPONSE
The Preliminary Safety Analysis Report ("PSAR"), the Final Safety Analysis Report ("FSAR"), and the Safety Evaluation Report ("SER") define the Braidwood quality Assurance Program as the Cosmonwealth Edison company Topical Report. Revision 0 of the Topical Report and the current Revision are i provided. In addition, Applicant has provided the applicable portions of ilconsing documents and the NRC reviews of and Commonwealth Edison's revisions to the Topical Report. These documents describe the reviews of the Braidwood quality Assurance program by the NRC and indicate any resulting deficiency findings, adjustments, modifications, or leprovements, as well as Commonwealth Rdison's position and responses. Commonwealth Edison personnel involved in the drafting and revision of these documents are identified in the correspondence by either name and/or title.
ME1FlC,1RTERROGAT0AL11 Flease describe in detall the selection, training, testing and evaluation program for Quality Assurance personnel and Quality Control Inspectors for Edison and for each contractor responsible for any safety related conettvetion at Braldwood from the commencement of construction until the present.
-s- l anspouss section 4 of Intervenors' 94 sentention refers to the training for Comstock weld inspectors and 0.K. Newbers QC inspectors. Applicant is g
providing sopies of the training progrene for Comstock weld inspectors and souberg gC inspectors at Braidwood from the start of construction to the present.
In light of the joint etipulation admitting section 2.c of the 94 sentention. Applicant will provide a response concerning the training, testing, and evaluation programe for the conetook QC inspectors at a later date, practr1C istnamesatomV is with roepeat to each unc staff inspection report regarding quality assuranse at traidwood, please identify, and aske ave 11able for inspection and copying, all sorroependense by and between the BBC staff and Commonwestth Edison or its sentractore regarding such inspection and any sortsetive action.
paspouss ,
correspondence between the WRC staff and App 11eent or between the BBC staff and App 11sant's sentractors relating to staff inspection reports is identified in the index for speelfie interrogatory number 18. These documents are ave 11able for inspection and copying.
I SPECIFIC INTERAGGateaY 15 Subsequent to these NRC findings, did pultman institute a stop work order involving NVAC werk? If so, please describe in detail and emplain Why this problem securred. Describe in detail any aerrective action taken, please identify any documents which refleet these answers.
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EESPONSE pullman instituted a stop work order involving MVAC work in 1983 when the BBC staff's conceme whiet were later set forth in Inspection Report $3-09 were made known to employees of Applicant and pullman as reflected in BBC Inspection Report 83-09 (page A0001501). This stop work order wee issued for all oefety related MVAC welding on August 3, 1933. The specifle issues are 1
described in Inspection Report findinge 83-09-10 (A)-(C). (See esp. pages A0001500-A0001501). Applicant's explanatione concerning and reopenses to the WBC's findings een be found in its correspondence with the W3C concerning Inspection Report 83-09. (see pages A0001529-A0001536 A0001573-A0001574, A0001579-A0001581, A0001654-A0001659, A0001662-A0001666).
Actions whleh were taken to resolve the concerns which led to the stop work are described in the ,memorends which are included at pages N0000250-N0000281.
These documents.ateo reflect the conditions under which the stop work order wee lifted. The approval of Revision 4 to Installation procedure 59.4.7 included the adoption of the weld procese sheet which was erucial to the lifting of the stop wa-k order. (see pages N0000035 N0000051). purther information on the m tailation procedure and the weld process sheet is provided in response to specifle interrogatory number 39.
,ppBC1p1C Iff5BAGG& TORY 29 pubsequent to these WRC findings, did pullman fall to institute sorrestive setten to establish semp11enes with AWS 01.1 inspection requirementet If so, please describe in detail the straumetences and emplain why this problem oseurred and sorrective action taken, please identify any doeunents which refleet these answers.
BRarWSE Applicant believes that this question relates to item 12.3.3 et the g4 sentention. This item of the contention is drawn from Inspection Report finding 83-09-07(B) found at page number 40001505 of the deeumente being provided. Item of noncomplianae 1.e. of Inspection Report 83-09 (page nusher A0001444) sess;;; M e to this leeue and sencerne the secreative action for pullman Bensenfermance Report 58-08. The BBC did not find that pullman failed to institute serreetive action for WCR 38-06, but rather identified a sensern relative to the adequacy of the serrective action. As seeerted in its response to nonceay11ance 1.c., Applicant believes the secreative action for BCR DE-08 wee adequeto. (See pages A0001516-A0001517, A0001658, A0001665-40001664) .
ppq$1p1C IEEERROGATORY St What traveler peekage centrel system for identifying welding precedures l and material seneumed for MAC camponente has been taptemented at Braidweedt
! le such a erstem an industry-wide standard practiset Nas the WBC ever i identified any defielenties in the traidwood MVAC program with regard to such a systemt If ee, please describe in detail, please identify any doeunents Whleh reflect such a system, such defleiencies any any reopense er eerrective seilen.
REarWSE pu11msn sheet Metal has a system for identifying welding precedures and materlate for MVAC field welding. This system to embodied in a process sheet which le identified in Installation precedure 59.4.p. (See pages - N0000001 -
W0000249). The presees sheet, whleh travete free the weld engineer te quality I Assurance, le legged and stamped " Controlled." Then the presees sheet goes to the produetLen finte personne1. QC inspestten is periegned as appropeiate and desumented on the appliestle inspeetten form. The protese sheet is forwarded to QC for inelueton in the applicable inopoetten record peekase. Applicant understande the presees sheet to f all within the ordinary meaning of the term
" traveler package control systen."
-g-l Applicant knows that a " traveler package sentrel system" for id.mtifying welding precedures and material eeneumed for MVAC cesponents was used at the i Byron Buelear Power statten. Applicant does not knew speelfically how the Presees sheet system sempares to other traveler systems in use in the industry. l Seatten 3.A. of the ga sentention makes reference to en item of nonceay11ance desumented by the Wec relating not to the traveler syst e , but !
rather to the adequacy of instruettene en weld " travelers". Applicent [
1 interprete Interveners' queetten se relating to this finding. The 5tC's sensern is desumented in Inspeckten Report finding 33 09-10(A) (page A0001500) ;
and is elseelfled as noneemplianae 3.a in the sesempanying Wettee of [
Vietetten. (pages A0001446-40001447). Doeunents whleh refleet the prosese l sheet system, the WBC's findings, and Applicant's reopense er secreative setten are identified in the snelesed indou of documente reopenelve to interrogatory 39.
l APECIFIC 1 & ltgB!, y i Mee the 5tc ever round that in the area of W AC the lack of speelfte weld precedures to be used by ereft has allowed ereft to seleet the precedure and !
technique to be used, reeutting in W AC welding settvikles of indeterminate '
qualityt If se, pledee desselbe in detall the straumetenees and explain why i these prettens esaurred and What serreettve setten has been taken. set forth !
any faste Whleh demonstrate that such serrective setten has been effeettve. l please identLfy any deeumonte whleh refleet these answers. ;
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anspons:
The answer to the initial question contained in this interrogatory le no. Newever, Applicant believes that this Interrogatory seeks information eenserning Enopection toport finding 83-09-10(A). (see pese number A0001500). In that finding the Nec did not find a leek of speelfie weld precedures in the area of WVAC, but rather found that, while there were wold precedures, the inettwetions on " travelers" or other such desumentation did not identify for the erettoman W deh weld precedure to use for a opostfic installation. The result woe that the erafhomen selected the weld precedure to be used for a spesifie installation. An explanation of the BBC's fandtage een be found in Inspecklen Boyert 83-09. A detailed description of
. Applicant's peeltlen on thte leeue and eerrective actione taken een be found in the roepense to 83-09, Item 3.a. (see page numbers A0001447, A0001500 A0001529-40001532, A00001579-A0001500, A0001659).
The findlnse of Commonwealth Edleon's gA surveillenee 3100 demonstrate the effeettvenees of Applicant's serreative setton. (see posee
, 00000660-30000661). The manner in whLeh the step work order referenced in answer to interrogatory 25 wee released gives additional eenfidense that the secreettve settens were effective. Werk activittee were resumed in stages and were initially subject to a 100E eurveillance by pullman QC Inspectore. (see posee N0000250-N0000281, A0001532-A0001533 for a full deserLption of this matter). In additten, an investigatten of weld filter metal has demonstrated that adequate weld iiller metal had been used (see pages A0001579-A0001S00).
} A program to slee underwer to test a number of rendomly selected items whleh will be out from the M AC installettene for the purpeee of eenfirming W AC l weld edequeay.
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SPECIFIC INTERROGATORY 48 Mas the BBC ever found that a lack of quality Control inspectione required by AME D1.1 prior to and during MVac welding operations has resulted in MVAC structural welding of indeterminate qualityt If so, please describe the circumstances in detail and explain why these problems occurred and what corrective action has been taken. set forth any facts which demonstrate that such terrective action has been effective. please identify any documents which refleet these answers.
3E8p0585 In Inspection Report 03-09, Items of Woncompliance 3.L and 3.c the NBC found a lack of recorde documenting conformance with the requirements of Aus D1.1-1977. The WRC did not make a finding of indeterminate quality. (see page number 40001447 and A0001500-A0001501). Applicant's position on this leeue, as well se corrective action taken, are identified in its response to inspec4Lon Report 83-09 at pasee A0001533-A0001536, A0001574, A0001581, A0001654-A0001661, A0001662-A0001644. Cortestive set 1on is effeeiave beeause the applicable welding procedure has been revised to incorporate the speelfic AWS D1.1 attributes referred to in the Inspection Report.
The findines of cosmonwealth season's QA survel11ance 3100 demonstrate the offsettveness of Applicaat's corrective setton. (see pages 30000660-30000641). The manner in whleh the stop work order referenced in enewer to interrelatory 25 was rolessed sLves additional confidence that the eorrestive setLons were effocttwo. Work octivitLee were resumed in a4 ages and were initiatir subject to a 100% surveillenee by pullman gc inspectors (see posee N0000250 N0000281 A0001532-A0001533 for a full description of thle matter). In addition, en investination of weld filter metal has demonstrated that adequate weld filler metal had been used (see pages A0001579-A0001580).
A program to also undervey to test a number of randomly selected itene Whleh will be eut from the MVAC installations for the purpose of confirming MVAC weld adequeer.
0034H
Affidavit of Perry L. Barnes I, Perry L. Barnes, being first duly swom, depose and state as follows:
- 1) I as asyloyed by commonwealth season company as a licensing engineer at the Braidwood Buclear Power Station.
- 2) Er business address is Braidwood Butlear Power Station, traseville, Illinois 60407,
- 3) To the best of my knowledge and belief, the statements sentained in the answers to speelfic Interrogatories 9, 12, 13, 18, 25, 29, 39, 47, and 40 of Applicant's First Partial Bosponse to Borea's First Set of quality Assurance interrogatories and sequests to Produce as revised on August 1,1945 are ime and correct. In some respects, these statements are not based on my personal knowledge but upon information fumished by other commonwealth Edison employees, consultants and contractors. such information has been reviewed in accordance with company praattaa and I believe it to be reliable.
Further affiant says not.
.44 4 MW PergL.Barnes sig sworn to before me this day of August 1985 h/C v .#4%0 ,
0039H
k August 1, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COIBLISSION REF_0RE THE ATOMIC SAFETY AND LICENSINC SOARD DCUETCC USNi4C In the Matter of: )
COMMONWEALTH EDISON COMPANY )
) Docket Nos. 50-456 '85 AUG -5 All :32 (Braidwood Nuclear Power ) 50-457 station, Units 1 and 2) ) cpy . g .
00Chtimu r. 5tsvi .i BRANCH CERTIFICATE OF SERVICE I Rebecca J. Lauer, one of the attorneys for comonwealth ,
Edison Company, certify that copies of the letter, dated August 1, 1985,
! from Rebecca J. Lauer to Douglass Cassel, the August 1, 1985 revised version of Applicant's First Partial Rooponse to Norom's First Set of Qua1Lty Assurance Interrogatories and Roquesto to Produce, and the Affidavit of Perry L. Barnes have been served in the above-captioned matter on those persons listed in the attached Service List by Unlied States mall, postage prepald, this let day of August, 1985.
Lawrence Brenner, Esq. Mr. William L. Clements Chairman Chief Docketing and services Administrative Law Judge United States Nuclear Regulatory ,
Atomic safety and Licensinf, Connteston i soard office of the secretary United States Nuclear Regulatory Washington, DC 20555 Cossatssion Washington, DC 20555 Dr. Nichard F. Cole C. Allen Bock, Esq.
Adminletrative Law Judge F.0, son 342 Atomia Befety and Licensing Urbana, Il 61801 Seard Unlted States suelear Regulatory Ms. Deldset Little Bores Conantes ton 117 North Linden Street Washington, DC 20555 P.O. Box 208 Wesex, 11 60935
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Dr. A. Dixon Callihan Robert Guild Administrative Law Judge Douglass W. Cassel, Jr.
102 Oak Lane Timothy W. Wright, III Oak Ridge, TN 37830 BPI 109 North Dearborn Street Suite 1300 Chicago, Il 60602 Stuart Treby, Esq. Ms. Lorraine Creek Elaine 1. Chan, Esq. Route 1 Office of the Executive Legal Box 182 Director Manteno, 11 60950 United States Nuclear Regulatory Cossaission Washington, DC 20555 Atomic safety and Licensing Charles Jones, Director Board Panel Illinois Emergency Services United States Nuclear Regulatory and Disaster Agency Comission 110 East Adams Washington, DC 20555 springfield, 11 62705 Atomic safety and Licensing Appeal Board Panel United States Nuclear Regulatory Conunission Washington, DC 20555
!$<u r- h Rebecca J. Iluer ISHAM, LINMLN & BEALE Three First National Plaza suite 5200 Chicago, Illinois 60602 (312) 558-7500 Dated: August 1, 1985 002.111