ML20133E634

Response to Intervenor First Set of Interrogatories & Requests to Produce.Related Correspondence

ML20133E634
Person / Time
Site:	Braidwood
Issue date:	07/31/1985
From:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	NEINER, B. (BOB NEINER FARMS, INC.)
Shared Package
ML20133E626	List: ML20133E623 ML20133E634
References
OL, NUDOCS 8508070768
Download: ML20133E634 (37)

Text

L)- a b

July 31, 1985

%TED CORREsponogy UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00Cr.ETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 Aug 27 A10 :55 In the Matter of COMMONWEALTH EDIS0N COMPANY Docket Nos. 0- 5 h[fy7 gly (Braidwood Nuclear Power Station,

)

Units I and 2) )

NRC STAFF RESPONSE TO INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS TO PRODUCE RESPONSES TO GENERAL INTERR0GATORIES INTERROGATORY 1 Please state the full name, address, occupation and employer of each person answering the interrogatories or assisting in the preparation of such answers, and designate the interrogatory or the part thereof he or she answered.

ANSWER The following individuals participated in the preparation of answers to the interrogatories. Those individuals who either prepared the answer or made major contributions to specific interrogatories are further 4

identified.

J. G. Keppler Interrogatory 50 Regional Administrator U.S. NRC Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 W. S. Little General Interrogatories 1, 3, 4; Director, Braidwood Project Specific Interrogatories 5-8, U.S. NRC Region III 18, 23 and 60 799 Roosevelt Rd.

Glen Ellyn, IL 60137 w,.

A P

f. I

, -J. W. Muffett Interrogatories 24, 26, 27, Reactor Inspector, Mechanical 28, 31, 32, 36, 37, 38, U.S. NRC Region III 41, 42, 43, 44, 45, 46, 49 799 Roosevelt Rd.

Glen Ellyn, IL 60137 P. R. Pelke Interrogatories 12, 41 and 51 -

Project Inspector U.S. NRC Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 R. N. Gardner Interrogatory 24.a.

Project Inspector U.S. NRC Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 L. G. McGregor Interrogatories 24.a. and b.

Sr. Resident Inspector, Operations &

U.S. NRC Resident Office Braidwood Station Braceville, IL R. D. Schulz Interrogatories 32-35, 37-39 Sr. Resident Inspector, and 41-45 Construction U.S. NRC Resident Braidwood Station Braceville, IL J. M. Jacobson Interrogatories 25, 29, 33-35,

. Reactor Inspector, Mechanical 39, 47 and 48 U.S. NRC Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 John G. Spraul Interrogatory 12 Quality Assurance Engineer Quality Assurance Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

o All of the above (except Mr. Keppler) participated in telephone calls and meetings in which the interrogatories and answers were discussed. Therefore, the answers represent the composite knowledge of all of the above-named individuals (with the exception of Mr. Keppler, -

who is responsible for answering only Interrogatory 50.

INTERROGATORY 2

~

Please identify each and every person whom you are considering to call as a witness at the hearing in this matter on this contention, and with respect to each such person, please: ,

a. State the substance of the facts and opinions to which the witness is expected to testify; 5

b. Give a summary of the grounds for each opinion; and

c. Describe the witness' educational and professional b1ckground.

ANSWER The Staff will respond to this interrogatory by October 9,1985.

INTERR0GATORY 3 Is your claim or defense on the contention based on one or more calculations? If so:

a. Describe each calculation and identify any documents setting forth such calculation.

b. Who performed each calculation?

c. When was each calculation performed?

d. Describe each parameter used in such calculation and each value assigned to the parameter, and describe the source of your data.

e. What are the results of each calculation?

f. Explain in detail how each calculation provides a basis for your claim or defense.

O

, ANSWER The Staff is unclear what Intervenors mean by " calculations" in this contekt. In any event, the Staff has not determined its position on any of the subparts of the QA contention at this time. When the Staff determines its position, it will supplement this response, as appropriate, in accordance with clarification from Rorem as to the meaning of " calculations.".

INTERR0GATORY 4 Is your claim or defense on the contention based upon conversations, consultations, correspondence or any other type of communications with one or more individuals? If so:

a. Identify by name and address each such individual.

b. State the educational and professional background of each individual, including occupation and institutional affiliations.

c. Describe the nature of each communication with such individual, when it occurred, and identify all other individuals involved.

d. Describe the information received from such individuals and explain how it provides a basis for the issue.

e. Identify each letter, memorandum, tape, note or other record related to each conversation, consultation, correspondence, or other communication with such individual.

ANSWER The NRC Region III testimony will be based upon, inter alia, conversations, consultations and correspondence with those persons identified in the NRC inspection reports and correspondence related to the admitted contentions (see the answer to specific Interrogatory 12 for a listing of the inspection reports and related correspondence that the Staff currently intends to rel.v upon). In addition, Region III may

i

, depend on communications with some or all of the following in preparing our testimony: NRC Headquarters such as Office of Inspection and Enforcement, and Office of Nuclear Reactor Regulation; National Board of Boiler and Pressure Vessel Inspectors; and the State of Illinois. -

3. Responses to Specific Interrogatories INTERROGATORY 1 Do you agree that the Braidwood Quality Assurance (QA) Program must comply with each of the criteria of Appendix B to 10 CFR Part 50 in order to establish Applicant's entitlement to the licenses sought in this proceeding? -

ANSWER S

The Staff will respond to this interrogatory by October 9, 1985.

INTERROGATORY 2 If the answer to No. 1 is negative, please describe in detail the respects in which such compliance is not required and explain fully the factual and legal basis for your position.

ANSWER The Staff will .'espond to this interrogatory by October 9, 1985.

INTERROGATORY 3 Does the Braidwood Quality Assurance Program comply with each of the criteria of Appendix B to 10 CFR Part 50?

ANSWER The Staff will respond to this interrogatory by October 9, 1985.

. l l

l INTERR0GATORY 4-What are the bases for your responses to Nos. 1-3? Please identify all documents, physical evidence, testimony or oral statements by any person and legal authority on which you rely in support of your position.

ANSWER The Staff will respond to this interrogatory by October 9,1985.

INTERR0GATORY 5 Does workmanship in the actual design, fabricatfor, construction and testing of safety-related structures, systems and components meet or exceed all ap; icable standards?

ANSWER No. Violations based upon deficient workmanship or that had the potential for causing deficient workmanship are described in the QA contention. However, in each instance the Licensee has taken action to correct the deficiency and to preclude recurrence, and these actions are reviewed and confirmed during Region III inspection. Prior to NRC Region III recommending the issuance of an Operating License Region III will have developed reasonable assurance that the actual design, fabrication, construction and testing of safety related structures, systems and components meet or exceed the Licensee's commitments to all applicable standards.

INTERR0GATORY 6 Please identify all sources of standards (e.g., FSAR, ASME Code) applicable to the actual design, fabrication, construction and testing of safety-related structures, systems, and components.

ANSWER 10 C.F.R. Q 50.55a, " Codes and Standards"; PSAR and FSAR.

. INTERR0GATORY 7' If the answer to No. 5 is negative, please describe in detail the respects in which such workmanship does not meet or exceed all applicable standards Br is indeterminate, and explain fully the factual and legal basis for your answer. ,

ANSWER 1

See re.sponse to interrogatory number 5.

INTERR0GATORY 8 What are the bases for your response to Nos. 5-7? Please identify all documents, physical evidence, testimony, or oral statements by any person and legal authority on which you rely in support of youf position.

I S

ANSWER The bases for the response to No. 5 are the inspection reports referenced in the QA contention and the corrective actions required, which are documented in the licensee's response to the violations and which will be reviewed by Region III.

INTERR0GATORY 12 Describe in detail each review of the Braidwood Quality Assurance Program by the NRC Staff. For each, please indicate the deficiencies found, the adjustments, modifications and improvements resulting or otherwise made; the Commonwealth Edison position and responses; the names, titles, addresses and telephone numbers of each person involved and a description of the involvement of each.

ANSWER The quality assurance (QA) program description for Braidwood was reviewed by the NRC Staff as part of the Byron /Braidwood FSAR licensing review. The review was performed by the QA Branch. The principal reviewers of the QA program for licensing Braidwood are J. G. Spraul a,nd ss W. L. Belke, QA E,ngineers.

1

. The review'of the initial FSAR submittal to determine its acceptability for docketing resulted in a request for additional informatioh (RAI) in 3 areas:

~

1. Which revision of the Commonwealth Edison topical report on QA would be applied during the operations phase.

2. Which revisions of the Regulatory Guides for QA would be applied during the operations phase.

3. Which items of the piant woulo be subject to the QA program controls during the operations phase. ,

After docketing, the FSAR QA program description was r9 viewed against the detailed acceptance criteria in chapter 17 of revision 1 of the Standard Review Plan, NUREG-75/087. This review and the review of Commonwealth Edison's response to the 3 areas questioned above resulted in an additional RAI. This RAI requested clarification of commitments regarding such items as the stop-work authority of QA, qualifications of the QA Manager, control of as-built drawings, control of consumables, and accuracy of measuring and test equipment. FSAR revisions, responses to RAIs, and the detailed staff review of items subject to QA program controls resulted ir additional clarification questions regarding Regulatory Guide conn.itments, QA responsibilities for preoperational and startup testing, and the identification of items subject to QA program controls during the operations phase.

The RAls have all been acceptably responded to, and the responses have been included in the docket. The RAIs and the responses are in the PDR as listed below.

, . RAI LETTER.c Date

• To From RAI Numbers October 20, 1978 Reed Boyd 421.1 - 421.3 May 15, 1979 Reed Varga 421.4 - 321.5 November 8, 1979 Peoples Rulenstein 421.6 - 421.81 March 16, 1981 Abel Tedesco 421.10 - 241.20 September 2, 1981 Del George Youngblood 421.21 November 18, 1981 Del George Youngblood 421.22 September 12, 1984 Farrar Youngblood 420.24 FSAR RESPONSES Date Amendment RAI Numbers

• January 1979 18 421.1 - 4fl.3 September 1979 22 421.4 - 421.5 July 1980 27 421.6, 421.8 - 421.18 October 1980 28 421.7 August 1981 32 421.20 October 1981 33 421.21 January 1982 36 421.19 May 1982 38 421.22 (Smith to Denton letter of October 15,1984)

In addition to the QA reviews described above, a review was also conducted by the QA Branch to determine the extent to which the Commonwealth QA program description meets the acceptance criteria in revision 2 of chapter 17 of the Standard Review Plan, NUREG-0800, issued July 1981. The results of this review are noted in section 17 of the Byron SER (NUREG-0876) which is referenced in section 17 of the Braidwood SER (NUREG-1002).

The results of the staff's review of the QA program description for 4

the operation of Braidwood are described in Chapter 17 of the Braidwood SER(NUREG-1002)which,asnotedabove,referenceschapter-17ofthe i

Byron SER (NUREG-0876).

The NRC Region III construction inspecticn program verifies, by means of inspections done on a sampling basis, that a nuclear facility (in this case the Braidwood facility) is constructed in accordance with NRC requirements and the Applicant's commitments. The keystone of those specific inspections is the verification that the Applicant has an adequate QA Program and that the QA Program is being effectively implemented. The NRC Program consists of (1) review of the Applicant's QA Program, from the corporate QA manual to the basic work and inspection procedures, including the QA programs of the various site contractors; (2) observation, on a sampling basis, of the actual work and inspection 5

activities in the field; and (3) review, again on a sampling basis, of the records which document both the work accomplished and the results of the QA/QC inspections and audits. The intent of the NRC inspections is not to identify every deficiency in materials or workmanship, but to insure that the QA Program in effect at the site is identifying and requiring correction of significant construction deficiencies. Each specific inspection identified in the Amended Contention as admitted is considered a partial. review of the Braidwood Quality Assurance Program.

The details for each quality assurance violation or unresolved or open item referred to by Intervenors in their amended quality assurance contention are provided in the inspection reports which are referred to in Intervenors' QA Contention. Below is a list of those inspection reports, together with Applicants' response to each inspection report.

. Inspection Date NRC CECO Response Report No. Issued Correspondence Correspondence 85015/85016 05/16/85 06/21/85 85006/85006 03/08/85 06/27/85 05/06/85 84007/84007 07/20/84 08/24/84 08/20/84 -

12/13/84 84043/84039 03/15/85 10/22/84 12/11/84 04/15/85 04/22/85 85007/85007 04/04/85 05/03/85 84031/84029 11/26/84 12/21/84 84021/84020 11/20/84 01/31/85 02/27/85 04/04/85 85011/85011 04/12/85 84017/84017 10/16/84 12/06/84 11/28/84 84040/84037 01/18/85 84009/84009 07/02/84 08/15/84 07/31/84 11/30/84 10/22/84 11/07/84 02/13/85 85008/85008 04/18/85 05/15/85 84013/84013 08/07/84 10/17/84 09/21/84 85005/85005 03/12/85 84008/84008 05/22/84 06/29/84 06/21/84 08/16/84 09/12/84 12/13/84 84039/84036 03/15/85 84044/84040 02/20/85 04/11/85 05/16/85 05/29/85 83009/83009 05/07/84 08/03/84 07/06/84 07/23/84 08/31/84 03/11/85 03/27/85 04/25/85 82005/82005 02/02/83 02/02/83 02/18/83 02/25/83 04/04/83 04/26/83 03/07/85 INTERR0GATORY 15 Does Commonwealth Edison and its contractors have a program which insures the integrity of the testing and qualification for Quality Control Inspector certification? If so, please describe in detail the program or programs, all variations and changes in the program since

. construction began, and describe in detail and identify any deficiencies  ;

found in such testing and qualification. l ANSWER CECO's and their contractors QA programs require periodic audits of ,

I all safety related activities including the training and qualification of

! QC inspectors. The NRC does not have in its possession the information to address the remaining questipns.

INTERR0GATORY 18 With respect to each NRC Staff inspection report regardin$ quality assurance at Braidwood, please identify, and make available for inspection and copying, all correspondence by and between tfie NRC Staff and Commonwealth Edison or its contractors regarding such inspection and any corrective action.

ANSWER All inspections at Braidwood are related to quality assurance. NRC inspection reports for Braidwood, and the requested correspondence are available in the NRC's Public Document Room.

INTERROGATORY 21 Does Commonwealth Edison or its contractors have policies or programs to encourage complaints or suggestions by workers regarding substandard workmanship, quality assurance deficiencies, deficiencies in plant design and construction, and harassment and intimidation? If so, please describe in detail.

ANSWER Yes. The Quality First Program is discussed in Inspection Report Nos. 456/84-31(DRP); 457/84-29(DRP) forwarded to Commonwealth Edison Company in a letter dated November 26, 1984. The report states-in part on Pages'5 and 6, "The licensee presented a Braidwood ... Quality First Program ... The Quality First Program is being established as a mechanism

. for employees to report any safety concerns to the licensee ... The Quality First Program will start in November with " exit interviews."

Anyone terininating employment at the site for any reason, i.e., voluntary

~

separations, lay-offs, reduction in forces, etc., will report to the Quality First facilities for an exit interview. It is anticipated that the program will be expanded to also address concerns expressed via phone, mail, or walk-in-visits ... These programs are positive steps that the licensee has taken to assure quality work at the Braidwood site."

Inspection Report Nos. 456/85-07; 457/85-07 states in Paragraph 5 that, "A " Quality First Program" has been established on thg site by the licensee. The program is a mechanism by which craftsmen, quality control inspectors, and office personnel may report safety-related concerns to the licensee. The licensee subsequently investigates the findings and takes the necessary corrective action. There is presently a staff of five assigned solely to Quality First, including a Quality First Director. Eleven concerns which were investigated by Quality First were reviewed by the inspector. The documentation methods for recording the concerns were satisfactory, and the investigation process involved considerable research and appeared to be thorough and justifiable. The identity of the individual providing the concern is protected and was not supplied to the inspector. Concerns were reviewed in both the production and quality control areas. For example, one craftsman complained that there are too many inspections which cause unnecessary rework.

Inspections are performed by first-line quality control inspectors, followed by a Pittsburgh Testing Laboratory Overview inspection, and, in many cases, a BC/P inspection. The complaint actually substantiates the

)

. positive aspect that deficiencies will not be overlooked. The multiple inspection effort assures hardware compliance with drawing and regulatory requirements."

INTERR0GATORY 23 What are the bases for your responses to Nos.13-22? Please identify all documents, physical evidence, testimony, or oral statements by any person and legal authority on which you rely in support of your position.

ANSWER The bases for the NRC response are described in the answef provided to each interrogatory. 6 INTERROGATORY 24 (a) Describe in detail any and all reviews of contractor performance conducted by or for Commonwealth Edison in response to the NRC findings reflected in the February 2, 1983 Notice of Violation and Proposed Imposition of Civil Penalties, EA 82-136, the $100,000 civil penalty.

Please identify any and all documents which reflect the results of such reviews, including any nonconformances found and any corrective action taken.

(b) Were these reviews adequate? If so, please set forth any and all facts which demonstrate the adequacy of such reviews. If not, please explain and set forth any and all facts which support such explanation.

ANSWER (a) Commonwealth Edison Company (CECO) responded to the Notice of Violation (NOV) and Proposed Imposition of Civil Penalties on April 4, 1983. This response, which is available for review in the Public Document Room (PDR), delineates the licensee's corrective actions, hnile the NRC has not closed all of the findings associated with the NOV, several of the findings have been documented as closed in subsequent NRC inspection reports. These NRC inspection reports are Nos. 456/84-33, l

457/84-31, 456/85017, and 457/85018. In addition, Region III Confirma-tory Action Letter of September 8, 1982 covers these issues.

On October 8, 1982, Ceco submitted a 10 C.F.R. 6 50.55(e) report regarding control of the erection of mechanical equipment at Braidwood -

Station. This document, which is available for review in the PDR, delineates the licensee's corrective actions. The NRC has not closed this report.

(b) A number of CECO reviews were conducted in response to the February 2, 1983, Notice of Violation. In response to violation A, t

example 1, all of the subject installation was rechecked using the updated procedure. In addition, the performance of all site contractors in this area was reviewed to determine if similar problems existed.

These reviews and other associated actions are documented in the April 4, 1983 letter to James G. Keppler.

INTERR0GATORY 25 Subsequent to these NRC findings,'id d Pullman institute a stop work order involving HVAC work? If so, please describe in detail and explain why this problem occurred. Describe in detail any corrective action taken. Please identify any documents which reflect these answers.

ANSWER We are unable to determine what NRC findings are referred to in your phrase " subsequent to these findings." The inspection report and February 2,1983 letter referenced in question 24 do not specifically refer to HVAC deficiencies.

t However, the Staff believes that the findings refer to Inspection Report 83-09. As stated in Inspection Report 83-09, a partial stop work order was instituted on June 28, 1983 "in an effort to correct past i work". The problems with past work had been identified by a CECO 100% -

inspection of safety-related installed components. As a result of the '

findings of Inspection Report 83-09, a stop work order was instituted for

! all safety-related HVAC welding on August 3, 1983.

Corrective actions taken are outlined in the following CECO

documents

Letter to J. Keppler from L. DelGecrge dated July 6, 1984 Letter to J. Keppler from E. Swartz dated July 23, 1984 Letter to J. Keppler fron E. Swartz dated August 31, 1984 Letter to J. Keppler from David Smith dated March 11, 1985 Letter to J. Keppler from David Smith dated March 27, 1985 Letter to J. Keppler from David Smith dated April 25, 1985 The corrective actions taken by Applicant are currently being evaluated by the NRC.

i INTERROGATORY 26 Subsequent to these NRC findings, was a 50.55(e) report made regarding verification of correct piping components for both large and small bore pipe? If so, please describe in detail the circumstances and explain why this problem occurred and corrective action taken. Please '

identify any documents which reflect these answers.

ANSWER We are unable to determine what NRC findings are referred to in your phrase " subsequent to these findings." The inspection report and February 2,1983 letter referenced in question 24 do not specifically refer to verification of piping components.

I However, questions 26, 27, 31, 36 and 42 deal with issues which the

,' Staff believes are addressed by the Material Traceability Verification l (MTV) program. The Staff's response to questions 26, 27, 31, 36 and 42 will be contained in our response to question 42. -

i i

INTERROGATORY 27 l i

l Subsequent to these NRC findings, was a supplemental 50.55(e) report made regarding piping components for specification break items? If so,

please describe in detail the circumstances and explain why this problem

occurred and what corrective action was taken. Please identify any documents which reflect these answers.

i ANSWER

< t We are unable to determine what NRC. findings are referred to in your l

phrase " subsequent to these findings." The inspection report and ,

j February 2,1983 letter referenced in question 24 do not specifically l

refer to verification of correct specification for piping components.

However, questions 26, 27, 31, 36 and 42 deal with issues which the j staff believes are addressed by the Material Traceability Verification

! (MTV) program. The Staff's response to questions 26, 27, 31, 36 and 42 will be contained in our response to question 42.

1 INTERROGATORY 28 Subsequent to these NRC findings, did Phillips-Getschow management l suspend the engineering department support selection program for process i and instrument piping and instrument tubing? If so, please describe in detail the circumstances and explain why this problem occurred and all i

corrective action taken. Please identify any documents which reflect

! these answers. .

18 -

ANSWER We are unable to determine what NRC findings are referred to in your phrase " subsequent to these findings." The inspection report and February 2, 1983 letter referenced in question 24 do not address this issue.

However, the Staff believes that the findings refer to Inspection i.

Report 83-09. Inspection Report 83-09 states:

" Subsequent to the inspection, PG management suspended the Engineering Department Support Selection Program for process piping and instrument piping and tubing in Category I

• Buildings on October 10, 1983, until the program could be evaluated for compliance S to S&L Specification L-2739 and PG Procedure CP-22. CECO letter, BRD No. 9627 "PG Co

! Letter B-B-531, dated 10/10/83," dated 1

October II, 1983, concurred with PG's decision, and requested PG to maintain this suspension until written concurrence to resume this activity was obtained from CECO."

7 The corrective actions to address these issues include:

(1) more specific installation tolerance and acceptance requirements, (2) upgrading of PG procedures to provide better feedback to  !

the A-E, (3) improvements in the PG hanger selection calculation format and review verification, and 1

(4) expanding the A-E and CECO engineers' role in field pipe routing design changes and overview of PG support selections.

+

a

-r,-w --e-----v-,+- ,---- - - -+= -- ,, - - , - - --

- 19 Region III management requested the licensee to:

(1) conduct comprehensive QA/ technical audits prior to the iifting of the stop work order, and, (2) perform a detailed evaluation by the A-E to determine effectiveness of PG improved design program, and adequacy of 1

the A-E design guidance and control.

INTERROGATORY 29 Subsequent to these NRC findings, did Pullman fail to institute corrective action to establish compliance with AWS D1.1 inspection requirements? If so, please describe in detail the circumstances and explain why this problem occurred and corrective action taken. Please identify any documents which reflect these answers.

ANSWER We are unable to determine what NRC findings are referred to in your phrase " subsequent to these findings." The inspection report and February 2,1983 letter referenced in question 24 do not specifically refer to HVAC deficiencies. However, the Staff believes that the findings refer to Inspection Report 83-09. Corrective actions taken are outlined in the Ceco documents listed in the Staff response to Interrogatory No. 25.

Pullman has instituted corrective action to establish compliance with AWS D.1.1 inspection requirements for work subsequent to the stop work order of August 3,1983. Work performed prior to this is currently being evaluated by the NRC.

i

L , INTERROGATORY 31 Subsequent to NRC identification of the need for Phillips-Getschow to involve Quality Control in heat number traceability and sample inspections, were problems identified requiring items of large and small bore pipe to be removed? Were problems identified with inaccessible pipe? Were problems identified with lack of documentation identifying l

components installed? If so, please describe in detail the circumstances

, and explain why this problem occurred and all corrective action taken.

Please identify any documents which reflect these answers.

ANSWER The activities and deficiencies mentioned in question 31 deal with l issues addressed by the Material Traceability Verification (MTV) program.

The Staff's response to questions dealing with MTV (Interrogatories 26, 27, 31, 36 and 42) will be contained in our response to Interrogatory 42.

INTERR0GATORY 32 Has Sargent and Lundy ever approved deficient contractor programs at Braidwood? If so, please describe in detail each instance and any and all corrective action taken with respect to such instance. Identify any and all corrective action taken with respect to such instance. Identify any and all documents which reflect such instances and such corrective action. Has the NRC ever identified such instances? If so, please describe in detail and identify any documents which reflect such instances and any corrective action taken.

ANSWER The Staff objects to answering the first three questions in this interrogatory, since the requed:d information is directly known to Applicants, who therefore S tb appropriate source for this information.

The Staff has identified eight instances of either deficient contractor programs or deficient implementation of contractor programs. (The Staff is making the assumption that the question refers to QC or QA programs.)

These instances are:

(1) Violation 3 in Inspection Report 83-09, which concerns lack of

' fit-up' inspection, the lack of base metal inspection prior to welding and lack of essential welding variables on drawings.

r .

(2) Violation 5 in Inspection Report 83-09, which concerns lack of control of field changes of piping.

(3) Violation 6 in Inspection Report 83-09, which concerns lack of -

l procedures and guidance concerning routing of piping. .

I i

(4) Unresolved items 4(a) and 4(b) in Inspection Report 83-09, which concern QC verification of traceability of installed piping components.

t-(5) Violation 3 in Inspection Report 84-21, which concerns the lack of a procedure for QC verification of Internal Cleanliness of Mechanical Equipment at the time of installation.

l (6) Violation 1 in Inspection Report 84-09, which concerns lack of procedural guidance concerning clearance between HVAC equipment, large bore pipe and various equipment.

(7) Violation 1 in Inspection Report 82-05, which concerns lack of procedures for installation of mechanical equipment.

(8) Unresolved item 50-456/82-05-03, which concerns lack of procedure for installation of Reactor Coolant Pump Supports.

The corrective actions associated with these items are as follows:

(1) Violation 3, 83-09: The corrective actions are found in the July 6, 1984 letter from L. O. De1 George to J. Keppler (The CECO Response to inspection report 83-09). These actions include revision of procedure 89.4.F, "in-process" surveillances, and revision of procedure 810.2.F.

In addition the following letters deal with this subject.

E. Swartz (CECO) to J. Keppler (NRC dated July 23, 1984 E. Swartz (CECO) to J. Keppler (NRC) dated August 31, 1984 David Smith (CECO) to J. Keppler (NRC) dated March 11, 1985 David Smith (CECO) to J. Keppler (NRC) dated March 27, 1985 t

David Smith (CECO) to J. Keppler (NRC) dated April 25, 1985 (2) Violation 5, 83-09: The corrective actions are found in the July 6, 1984 letter from L.0. DelGeorge to J. Keppler. These actions include revision of Phillips-Getschow Company procedure QCP-821 and instituting of procedure PGCP-40 for recording as-built routing.

(3) Violation 6, 83-09: The corrective actions are found in the July 6, 1984 letter from L. O. DelGeorge to J. Keppler. These actions include revision to S&L specification F/L-2739 also Phillips-Getschow Company revised their piping installation procedures to require contractor engineering review of proposed reroutes. In addition, the notation of piping installations within 3 inches of another installation per PGCP-40 will determine acceptability of previous installations.

-w- -,--* . - , g. w.

. (4) ' Unresolved items 4(a) and 4(b), 83-09: The corrective actions associated with these itens are part of the Material Traceability Verificatibn (MTV) program. The answer to interrogatory 42 contains the

~

Staff's position and information concerning this issue.

(5) Violation 3, 84-21: In response to this violation an inspection program was developed to evaluate the cleanliness of installed mechanical equipment. The program includes visible inspection of components where inspection ports are available, or when access can be obtained through a pipe or valve opening. A second visual aid is the use of a flexible borescope to gain access to more difficult areas.

Verification of system design pressures and flows will be monitored for indication of potential fouling. Should it become necessary to inspect or clean systems which have been welded together, selective cutting will be used to gain access.

(6) Violation 1, 84-09: The corrective actions are found in the July 31, 1984 letter from D. L. Farrar to J. Keppler. These actions include the development of Nonconformance Reports (NCRs) No. 621 (Unit 1) and 622 (Unit 2) to document the lack of specific guidance in this area and the development of specific guidelines for contractors. These corrective actions will be reviewed by the staff to determine adequacy.

(7) Violation 1, 85-05: The corrective actions are found in the April 4, 1983 from Cordell Reed (CECO) to J. Keppler (NRC). In addition a 50.55(e) report was submitted on October 8, 1982 from T. R. Tramm.

. l (8) Unresolved item 50-456/82-05-03: The adequacy of the reactor coolant pump support columns is still under review by the Staff.

INTERROGATORY 33 Has Commonwealth Edison management ever approved deficient contractor programs at Braidwood? If so, please describe in detail each instance and any and all corrective action taken with respect to such instance. Identify any and all documents which reflect such instances and such corrective action. Has the NRC ever identified such instances?

I ' so, please describe in detail and identify any documents which reflect such instances and any corrective action taken.

ANSWER The Staff has identified 8 instances of either deficient contractor o

programs or deficient implementation of contractor programs. The viola-tions and corrective actions taken are outlined in the Staff response to interrogatory No. 32. The Staff objects to answering the first three questions in this interrogatory, since the requested information is directly known to Applicant, who therefore is the appropriate source for this information.

INTERR0GATORY 34 Has Commonwealth Edison Quality Assurance ever approved deficient contractor programs at Braidwood? If so, please describe in detail each instance and any and all corrective action taken with respect to such instance. Identify any and all documents which reflect such instances and such corrective action. Has the NRC ever identified such instances?

If so, please describe in detail and identify any documents which reflect such instances and all corrective action taken.

ANSWER CECO Project Construction and Quality Assurance departments are responsible for the review of contractor programs. All QC or QA related programs are subject to CECO QA audits.

The Staff has identified 8 instances of either deficient contractor programs or deficient implementation of contractor programs.

]

The violations and corrective actions taken are outlined in the Staff response to interrogatory No. 32.

INTERR0GATORY 35 Has Commonwealth Edison Quality Assurance ever failed to identify deficient contractor programs at Braidwood where such programs have been subject to Commonwealth Edison Quality Assurance auditing? If so, please describe each instance in detail and any and all corrective action taken with respect to such instance. Identify any and all documents which reflect such instances and such corrective action. Has the NRC ever identified such instances? If so, please describe in detail and identify any documents which reflect such instances and any corrective action taken.

ANSWER CECO Project Construction and Quality Assurance departments are responsible for the review of contractor programs. All QC or QA related programs are subject to CECO QA audits.

The Staff has identified 8 instances of either deficient contractor programs or deficient implementation of contractor programs which are outlined in response te Interrogatory 32.

INTERR0GATORY 36 Please describe in detail any programs at Commonwealth Edison's LaSalle and Byron nuclear plants which provide for the field verification of correct piping components installed. Has su:h a program been required at Braidwood? If so, please describe in detail and identify any documents which reflect such a program. If not, please explain why not.

Has the NRC ever identified a failure to require such a program at Braidwood? If so, please describe in detail such identification and any response and any corrective action by Commonwealth Edison and identify any documents which reflect such identification, response and corrective action.

ANSWER It appears that certain programmatic differences existed between piping component 't,raceability verification at LaSalle (and Byron) and i

I

Braidwood. The. basic difference concerns a QC signature for verification of correct piping components at time of installation. The remaining portion of-this interrogatory concerns the Material Traceability Verification (MTV) program. The Staff's position on the various -

questions concerning MTV will be contained in our response to interrogatory number 42.

INTERR0GATORY 37 Please describe in detail any programs at Braidwood and Comonwealth Edison's LaSalle nuclear. plant for the re-route of small bore piping, including particularly any material differences between the programs now or in the past. Has the NRC ever identified any deficiencies in such a program at Braidwood? If so, please describe in detail such identification and any response and corrective action. Please identify any documents reflecting such programs, deficiencies, responses, and corrective actions.

ANSWER It appears that certain programmatic differences existed between the procedures for the reroute of small bore piping at LaSalle and Braidwood. Deficiencies were identified in Inspection Report 83-09 as violation 6. These deficiencies mainly concern approval and involvement of the engineering department. The corrective actions are included in the Staff's answer to interrogatory number 32.

INTERR0GATORY 38 Please describe in detail any problems identified by Phillips-Getschow with field rerouted pipe, small bore heat number traceability and lack of Quality Control or ANI review of field addition or deletion of pipe bends or welds in or about April,1983. What corrective actions, if any, were taken? Were these adequate? Please describe in detail and identify any documents which reflect such description. Has the NRC ever identified such problems or inadequacies? Please explain and identify any documents which reflect such identification and your response and corrective action, if any.

. ANSWER These deficiencies are documented in Inspection Report 83-09. The corrective

• actions are contained in the July 6, 1984 letter from L. O. DelGeorge (CECO) to J. Keppler (NRC). The corrective actions include a walk down of small bore piping, a reinspection to determine "as-built" conditions, and a reinspection for heat number traceability.

INTERR0GATORY 39 What traveler package control system for identifying welding procedures and material consumed for HVAC components has been implemented at Braidwood? Is such a system an industry-wide standard practice? Has the NRC ever identified any deficiencies in the Braidwood HVAC program with regard to such a system? If so, please describe in detail. Please identify any documents which reflect such a system, such deficiencies and any response or corrective action.

ANSWER Deficiencies in the HVAC welding control program are outlined in Inspection Report 83-09 and the associated Notice of Violation.

Corrective actions taken are outlined in the CECO documents listed in the '

Staff response to Interrogatory No. 25.

Pullman has instituted a traveler control system as a result of the above mentioned Notice of Violation. Work performed prior to this system being implemented is currently being evaluated by the NRC.

INTERR0GATORY 41 Has the NRC ever found that quality assurance deficiencies at Braidwood have resulted in construction of indeterminate quality in any area (s), but particularly including piping, electrical or HVAC? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any documents which reflect these answers.

l ANSWER The NRC has determined a number of quality issues which have the potential to render the quality of components indeterminate. It is important to note that a number of these issues deal with the lack of -

documentation of QC verification of certain qualities or variables and in cases where these qualities or variables can be determined after the discovery of the programmatic deficiency the components quality may be judged acceptable. The issues with potential to render quality indeterminate are:

1 Inspection Report Issue 82-05 Reactor Coolant Pump Support Columns 83-09 HVAC Welding Controls 83-09 Material Traceability 83-09 Routing of Small Bore Piping 83-09 Piping Bends 83-09 Dimensional Checks of Piping l

84-17 Piping Minimum Wall 84-09 Clearances of Installed Components in Relation to other Components The corrective actions concerning issues in Inspection Report 83-09 are contained in the July 6, 1984 L. O. DelGeorge (Ceco) letter to J. Keppler (NRC). Corrective actions relative to Inspection Report 84-17

are contained in the November 28, 1984 letter from D. L. Farrar (CECO) to J. Keppler (NRC). The corrective actions relative to Inspection Report 84-09 are contained in D. L. Farrar (CECO) letters of October 22, 1984 and July 31, 1984 to J. Keppler (NRC). Additional corrective actions for -

the " clearance" issue which was identified in inspection report 84-09 may be required pending NRC review.

INTERR0GATORY 42 Has Commonwealth Edison ever identified incorrect or indeterminate piping items installed at Braidwood? If so, was such identification through a sample inspection? Is it true that the Braidwood program did not require independent verification of all piping components installed?

Was there ever a potential for inadequate quality of installed piping which could result in failures during plant operation? If so as to any of these questions, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any documents which reflect these answers.

ANSWER The Staff understands that Comonwealth Edison has instituted an extensive program to determine the acceptability of piping components installed in the field. This program is called the Material Traceability Verification (MTV) program. This issue was identified in Inspection Report 83-09andalsoCommonwealthEdisonsubmitteda50.55(e) report.

In addition, Commonwealth notified in a supplement to the original 50.55(e) the so called specification break issue (lack of adequate delineationofdesignclasschange). The details of the MTV program are directly known to Applicant, who therefore is the appropriate source for the more detailed information on the MTV program.

INTERR0GATORY 43 Has the NRC ever found that the accuracy of as-built (field re-routed) piping drawings is unknown due to lack of quality control verification? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been -

taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any documents which reflect these answers.

ANSWER Inspection Report 83-09 (violation 6) identified a number of deficiencies in the Phillips Getschow program for the field routing of small bore piping. The basic issue concerned the lack of involvement by the engineering department, t

The corrective actions are included in the Staff's answer to Interrogatory 32 (item 3).

INTERROGATORY 44 Has the NRC ever observed that design acceptability of field re-routed pipe cannot be determined? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any documents which reflect these answers.

ANSWER InspectionReport83-09(violation 6)identifiedanumberof deficiencies in the Phillips Getschow program for the field routing of small bore piping. The basic issue concerned the lack of involvement by the engineering department. The corrective actions are included in the Staff's answer to Interrogatory 32 (item 3).

INTERROGATORY 45 Has the NRC ever found that due to a lack of random measurements during piping receipt inspections there exists a potential for minimum

. wall violations ~wnich could result in piping failure during plant operation? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any documents which reflect these answers. ,

ANSWER Inspection Report 83-09 (violation 2) identified a lack of receipt inspection of piping and piping components as required by CECO's QA manual. Although the lack of receipt inspection does increase the probability of an incorrect component being installed, these components are subject to a number of other inspections and these components are produced under the manufacturers QA program. The installed components i are subjected to hydrostatic testing which should identify minimum wall thickness violations which could result in failure during operation.

The corrective actions dealing with this deficiency are contained in the July 6, 1985 letter from L. O. DelGeorge (CECO) to J. Keppler (NRC).

These actions will be reviewed and the results inspected by the Staff.

INTERR0GATORY 46 Has the NRC ever found that incorrect hanger calculations at Braidwood result in pipe support capability which is indeterminate? 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 corrective action has been effective. Please identify any documents which reflect these answers.

ANSWER Inspection Report 83-09 identified a number deficiencies associated l

l with design calculations for pipe hangers. These deficiencies had the potential to render the quality of the installed items indeterminate.

l

1

. 1 The corrective actions dealing with this d ficiency are contained in the July 6,1985 letter from L. O. De1 George (C Co) to J. Keppler (NRC) which details CECO's response to inspection report 83-09. These actions

~

will be reviewed and the results inspected by the staff.

INTERROGATORY 47 Has the NRC ever found that in the area of HVAC the lack of specific weld procedures to be used by craft has allowed craft to select the procedure and technique to be used, resulting in HVAC welding activities of indeterminate quality? If so, please describe in detail the circum-stances and explain why these problems occurred and what corrective action has been taken. Set forth any facts which demonstrate that such corrective action has been effective. Pleaseidentifyanygocuments which reflect these answers.

ANSWER Inspection Report 83-09 documents deficiencies in the area of welding program controls. Corrective actions taken are outlined in the CECO documents listed in the Staff response to Interrogatory No. 25. It is important to note that though a programmatic deficiency existed, it does not necessarily follow that the welding is of indeterminate quality.

The corrective actions taken are currently being evaluated by the Staff.

INTERROGATORY 48 Has the NRC ever found that a lack of Quality Control inspections required by AWS 01.1 prior to and during HVAC welding operations has resulted in HVAC structural welding of indeterminate quality? 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 corrective action has been effective. Please identify any documents which reflect these answers.

1 ANSWER Inspection Report 83-09 documents deficiencies in the area of welding program controls. Corrective actions taken are outlined in the CECO documents listed in the Staff response to Interrogatory No. 25. It is important to note that though a programmatic deficiency existed, it may be possible to determine the acceptability of specific components.

The corrective actions taken are currently being evaluated by the Staff.

INTERR0GATORY 49 Has the NRC ever found a lack of required comprehensive audits by the Braidwood electrical contractor, Comstock, the piping centractor, Phillips-Getschow, and/or the HVAC contractor, Pullman? If so, please describe in detail the circumstances and explain why these problems occurred and what corrective action have been taken. Set forth any facts which demonstrate that such corrective action has been effective. Please identify any documents which reflect these answers.

ANSWER Inspection Report 83-09 identified a deficiency in the area of auditing. Examples of this deficiency include:

a. Phillips, Getschow Company had not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program

in accordance with the PG QA Manual, Section 16.

1

b. L. K. Comstock Company /L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by QA Program Manual Section 4.14.1, nor did they verify compliance with all aspects of the Quality Assurance Program.

c. Pullman Construction Industries, Inc., did not meet their yearly schedule for audit activities required by their QA Manual, Section 18, in that the following implementing procedures were not audited: -

. B 3.1.F. Design Control -

. B 5.1.F HVAC Repair Adjustment

. B 9.3.F, Expansion Anchor Installation

. B 10.2.F. Visual Weld Inspection

d. The licensee's audits of the installation of small bore instrumentation and process piping were inadequate in that problems with contractor hanger design calculations were not identified for more than two years.

The corrective actions dealing with this deficiency are contained in the July 6, 1985 letter from L. O. DelGeorge (CECO) to J. Keppler (NRC) which details Ceco's response to inspection report 83-09. These actions will be reviewed and the results inspected by the Staff.

INTERROGATORY 50 In a February 1, 1984 Chicago Tribune article, NRC Region III Administrator James G. Keppler said, in part, with regard to Commonwealth Edison and Braidwood: "One has to question whether the workload has become unmanageable for the staff they have, and I've raised that for management to consider. But I have to be concerned that they are spread thin at the top..." Did Mr. Keppler or the NRC raise this matter with Commonwealth Edison? Or did Edison otherwise identify such deficiencies?

If so, please describe in detail the circumstances, Commonwealth Edison's

. - - . . _ . . _. - = . - - .

35 -

response and any corrective action taken and the results. Please identify any documents which reflect the answers to these questions.

ANSWER On more than one occasion Mr. Keppler raised the concern of whether ,

Commonwealth Edison had sufficient management oversight of their

, operating nuclear stations. Commonwealth Edison Company did retain a management consultant to study the management of their operating i

stations. (It is not known whether this effort was in response to NRC's l stated concerns.) Based upon this study, changes were made in the i management structure of each station elevating the importance ind j responsibility of the Station Manager. The Company documented these changes to the NRC in Commonwealth's letter dated July 6, 1984, Attachment C in response to report numbers 456/8309; and 457/8309.

4 i

INTERROGATORY 51 In Inspection Report 83-09, at page 4, the NRC observed that Common-

wealth Edison and the NRC Region III Staff discussed during enforcement

i conferences or otherwise, " CECO Personnel and organizationa' changes to strengthen the construction project management team and to increase the emphasis on quality assurance." Please describe in detail any such changes made at that time or since. Identify specificall) the names, job <

titles and duties, qualifications, and objective performar:e evaluations for all persons involved in such " personnel and organizational chinges,"

including those both before and after such changes were mtde. Pluase identify any documents which reflect these answers.

ANSWER l Organizational changes are discussed in Commonwealth Edison's letter dated July 6, 1984, Attachment C, Pages 53-58, in response to Report Nos.

456/83-09; 457/83-09.

t 1

0

- -_r_.. . . _. , . - _ , _ . - , _ , . . , . , - - -

..-.r _,__..__,.___-,,y._.,_m , , _ . - _ , ,_m,y-,, , _ , . _ _ , , . , , _.

~ ,,,,_

l l

INTERROGATORY 60 Has any member of the NRC Staff ever expressed any dispute, disagreement, or dissenting views or submitted on " inspector or inspection evaluation report" (see, Warnick Deposition, Tr. 204) with respect to any quality assurance deficiency or finding about Braidwood?

If so, please identify the circumstances and persons involved, including -

names and addresses, and identify any documents reflecting such instances and their resolution.

ANSWER Following any inspection, such as those conducted at Braidwood, discussions within the Region II staff will be held to discuss the inspection findings, their significance and proposed enforcement action.

During these discussions, disputes, disagreements or dissenting views may a

be verbally expressed; however, we have no record of these. If this normal interchange does not resolve safety issues, the inspector is encouraged to submit to Regional Management an Inspector Evaluation Form (IEF) first, and if that does not resolve the issue to his satisfaction he may submit a Differing Professional Opinion (DP0). When the IEF was first initiated the inspector was required to submit the completed form whether he had an issue to be discussed or not. Later the procedure was changed to encouraged the IEF submittal if the inspector desired to do so.

On November 23, 1982, Region III Inspector, L. G. McGregor submitted an IEF on Inspection Report 50-456/82-05, in which he expressed concerns that he believed were not being effectively dealt with by the licensee.

He did not indicate any disagreement with Region III actions.

On January 19, 1983, Region III Inspector J. M. Hinds sulmitted an IEF expressing a concern with a perceived attitude of the licensee.

On June 3, 1983, Region III Inspector, L. G. McGregor submitted an IEF related to Inspection Report 50-456/83-07 in which he expressed

. l concerns about Class 1 piping, two inch and under. He indicated on the IEF that he believed Region III was effectively dealing with all safety Concerns. .

Region III Inspector, J. Peschel submitted an IEF in late Summer, -

1982 expressing a concern. He indicated he believed both the licensee and Region III were effectively dealing with his concerns.

A total of 18 IEFs have been submitted on Braidwood, but only the four listed above expressed concerns over the inspection findings. No Differing Professional Opinions have been submitted on Braidwood.

.