ML20133F536
| ML20133F536 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/08/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20133F516 | List: |
| References | |
| OL, NUDOCS 8510110083 | |
| Download: ML20133F536 (7) | |
Text
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
)
COMMONWEALTH EDISON COMPANY Docket Nos. 50-456
)
50-457 (Braidwood Station, Units 1 and 2 )
AFFIDAVIT OF JAMES G. KEPPLER I, James G. Keppler, being first duly sworn, depose and state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Comission as the Regional Administrator, Region III. Among other things, I am responsible for the inspection of all nuclear power plants under construction and in operation in Region III, including the Braidwood Nuclear Power Station.
2.
On June 21, 1985 a late-filed arrended quality assurance conten-tion was admitted by the ASLP. The quality assurance contention is thirty-one pages long and calls into question Applicant's compliance with virtually every aspect of 10 C.F.R. Part 50, Appendix B.
The contention consists of fourteen parts, thirteen of which allege a pervasive failure to carry out the required quality assurance program for twelve of the I
eighteen criteria of 10 C.F.R. 50, Appendix B.
One part alleges hars:s-ment and intimidation of L.K. Comstock QC inspectors.
The contention states that the failure to carry out each of the twelve criteria is evidenced by the violations identified in the Region III inspection reports of the last several years and the concerns identified in inspections 1
conducted in December 1984 and January 1985 by an NRC Construction 0510110003 051000 gDR ADOCK 0 % y 6
)
l 4
' Appraisal Team. The contention raises no new issues that were not already being addressed by the NRC.
i 3.
Braidwood Unit 1 is approximately 90% complete. NRC inspection efforts during these last stuges of construction are extensive to ensure that construction has been satisfactorily completed and the plant is ready to operate.
Region III reorganized in April 1985 to elevate the status of the Region III Braidwood Project to that of a Branch.
This reorganization has dedicated much more regional management and inspection resources to Braidwood than other comparable Near Term Operating License plants.
I 4.
I have undertaken an evaluation of the impact that the admission of the OA contention has had and will have on Region III resources. With the admission of the QA contention by the ASLB on June 21, 1905, Region III's workload has been increased substantially. This increase is attributable to the following:
A.
The nature of the contention itself. The contention focuses exclusively on matters identified in reports of NRC inspections conducted over a period of several years, j
Consequently, to address the concerns raised in the i
contention, the Staff would be required to reexamine this voluminous amount of materials to confirm the adequacy of Applicant's efforts to address the concerns expressed therein.
This effort is in addition to those required of the Staff in the ordinary course of litigation such as responding to interrogatories, submitting to depositions, j
reviewing the licensee's interrogatory responses, preparing written testimony, testifying, and assisting the i
NRC. legal staff in the cross examination of intervenor and applicant witnesses.
B.
The, hearing schedule imposed by the Licensing Board. The Board's scheduling order requires written NRC testimony to 1
be filed by January 15, 1986. This necessarily
~
accelerates our inspection program because certain I
_ inspections and evaluations which support the Staff's testimony will need to be completed in four to fhe months, approximately six months sooner than planned.
5.
Admission of the QA contention has had and will continue to have significant direct impact on the technical members of my staff.
For example, the Director of the Braidwood Project, who is responsible for the overall management of the Project through full power licensing, since July 1, 1985 has spent approximately 60% of his time researching the historical record of the violations listed in the contention; coordinating, reviewing and preparing responses to interrogatories; and assisting the NRC staff.
It is estimated that by the end of the hearing more than 75% of the Project Director's time will have been devoted to matters directly related to the hearing on intervenors quality assurance contention. This has and will take him away from his primary duty of managing the entire inspection effort at Braidwood to such an extent that we have found it necessary to take steps to assign an additional supervisor to supervise site inspection activities. This new supervisor, as is the Project Director, will be dedicated exclusively to the Braidwood Project.
This disruption also extends to the inspection activities of other members of my staff. Since July 1,1985, my project, reactor, and resident inspectors have devoted substantial amounts of their time to matters arising out of the litigation of Intervenor's quality assurcnce contention. This demand on their time has been and can be satisfied by 1
e devoting less time to their ordinary inspection activities. Finally, the Commission should note also that the hearing schedule set by the Licensing board will result in the acceleration of inspections relating
-a
'. to mechanical, electrical, instrumentation, and heating, ventilation, s
andairconditioning(HVAC)activitiesattheBraidwoodStation. This is necessary for Staff officials in the Engineering Materials and Processes, and Plant Systems Sections to be in a position to prepare and present testimony relating to the above areas by the January 15, 1986 deadline established by the Licensing Board. The consequence of accelerating these inspections, however, is the foregoing of certain inspections at other sites.
6.
It is my opinion that the litigation of the QA contention has and will increase the Region's workload on Braidwood approximately 50 man months. The impact of accelerating the inspections related to the QA contention is significant but is more difficult to quantify.
In my view admission of the late-filed contention has had a substantial and unexpected impact on the Staf f's ability to conduct its inspection activities at Braid. cod and other Region !!! facilities.
Q.
L M games 5. Kepplef U Sworn and sub's'tribed to before me this f % day of October. 1985 My Consission Expires:
?/ y'/i 9 v7si,1.tsimra.iriiiis
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE COMMISSION In the Matter of COMMONWEALTH EDISON COMPANY Docket Nos. 50-456 50-457 0
(BraidwoodNuclearPowerStation, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF BRIEF IN SUPPORT OF COMMONWEALTH EDIS0N COMPANY'S MOTION FOR EXEMPTION FROM COMMISSION REGULATION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, by deposit in the hsclear Regulatory Comission's internal mail system (*), this 8th day of October, 1985:
Lawrence Brenner, tsq., Chairman
- Comonwealth Edison Company Administrative Judge ATTN: Cordell Reed Atomic Safety and Licensing Board Assistant Vice President U.S. Nuclear Regulatory Comission P.O. Box 767 Washington, DC 20555 Chicago, IL 60690 Herbert Grossman, Chairman
- Thomas J. Gordon, Esq.
Administrative Judge Waller, Evans & Gordon Atomic Safety and Licensing Board 2503 S. Neil U.S. Nuclear Regulatory Comission Champaign, IL 61820 Washington, DC 20555 Dr. A. Dixon Callihan Region III Administrative Judge U.S. Nuclear Pegulatory Commission 102 Oak Lane Office of Inspection & Enforcement Oak Ridge, TN 37830 799 Roosevelt Road Glen Ellyn, IL 60137 Dr. Richard F. Cole
- Joseph Gallo, Esq.
Administrative Judge Isham, Lincoln & Beale Atomic Safety and Licensing Board Suite 840 U.S. Nuclear Regulatory Comission 1120 Connecticut Avenue, N.W.
Washington, DC 20555 Washington, DC 20036 Rebecca J. Lauer, Esq.
Isham, Lincoln & Beale Three First National Plaza Suite 5200 Chicago, IL 60602
. Ms. Bridget Little Rorem C. Allen Bock, Esq.
117 North Linden Street P.O. Box 342 Essex, IL 50935 Urbana, Il 61801 Douglass W. Cassel, Jr., Eso.
Atomic Safety and Licensing Board Timothy Wright, Esq.
Panel
- 109 ?! orth Dearborn Street U.S. Nuclear Regulatory Commission Suite 1300 Washington, DC 20555 Chicago, IL 60602 Atomic Safety and Licensing Appeal Erie Jones, Director Board Panel (8)*
Illiricis Emergency Services U.S. Nuclear Regulatory Commission and Disaster Agency Washington, DC 20555 110 East Adams Springfield, IL 62705 Docketing and Service Section*
Office of the Secretary l
Lorraine Creek U.S. Nuclear Regulatory Commission Route 1, Box 182 Washington, DC 20555 Manteno, IL 60950 I
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'Fregor~y AA n BqTi Counsel fy NRC4taff f
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