ML20133F593

Affidavit of JW Gieseker Supporting Util Response to Specific Interrogatories 58 & 59 Filed by Intervenor as Part of QA Contention.Related Correspondence

ML20133F593
Person / Time
Site:	Braidwood
Issue date:	09/19/1985
From:	Gieseker J COMMONWEALTH EDISON CO.
To:
Shared Package
ML20133F591	List: ML20133F588 ML20133F593 ML20133F597 ML20133F600
References
OL, NUDOCS 8510110136
Download: ML20133F593 (5)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 35 GCT -9 p; ;59 l

I In the Matter of: ) 0FF:q ggs. ,g ,

COMMONWEALTH EDISON COMPANY ) UCX,ETfN37'3gygy-(Braidwood Station,

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Docket Nos. 50-456 50-457

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Units 1 and 2) )

AFFIDAVIT OF JAMES W. GIESEKER I, James W. Gieseker, being first duly sworn, hereby depose and state as follows:

1. I Em employed by Commonwealth Edison Company as a Project Construction Field Engineer at Braidwood Station.

2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.

3. I have participated in the preparation of the response t'o Specific Interrogatories Nos. 58 and 59 filed by Intervenors Rorem, et al. These interrogatories pose specific questions with respect to the 68 separate items of Intervenor's QA Contention. In particular, I have responsibility jointly with Mr. Robert V. Seltmann for the Responses to Items 4.B., 9.C., 10.F., ll.B., and ll.D. I also have responsibility jointly with Mr.

Seltmann (i) for the portion of the Response to Item 4.A related to Comstock and (ii) for Item 6.E.

except for the last paragraph which is supported by Mr. Hoffer.

4. The Responses to Items 4.A. as corrected below, 4.B.

as corrected below, 6.E. as corrected, 9.C. as corrected below, 10.F. as corrected below, ll.B. as corrected below, and ll.D. are true and correct to the best of my knowledge and belief.

5. In the middle paragraph on page 3 of the Response to Item 4.A., correct the reference to read "50-456/84-07-2A and 50-457/84-07-02A".

8510110136 851000 6 DR ADOCK O

4 Affidavit of James W. Gieseker Page 2

6. a. In the third paragraph of the Response to Item 4.B., change the word " specifications" in the last sentence to read " procedure".

b. Revise the fourth paragraph to read:

Although Comstock Procedure 4.8.3 always incorporated AWS D1.1-1975 as interpreted in S&L Specification L-2790, that procedure was revised to further clarify the weld inspection requirements of.AWS D1.1-1975 as interpreted in S&L Specification L-2790. In addition, after the NRC finding, Comstock weld inspectors received on-site training on S&L Specification L-2790 and weld inspection requirements by the Level III Corporate Welding Engineer of L.K.

Comstock Engineering Inc. Moreover, Comstock Procedure 4.1.3 (Qualification Classification and Training of CC Personnel) was revised subsequent to the NRC finding to specify which inspectors were required to read AWS Dl.1-1975 and S&L Specification L-2790,

c. Delete the last paragraph.

7. a. In the third paragraph of the Response to Item 6.E., delete the words " Commonwealth Edison directed that" from the first sentence and change the word "be" appearing after " cables" to read "were".

b. In the References, correct no. 9 to read

" Commonwealth Edison Company QA Surveillance 4647".

8. a. In the fourth paragraph of the response to Item 9.C., delete the words "and Sargent & Lundy".

b. In the fifth paragraph, item 1., revise the first sentence to read:

o Affidavit of James W. Gieseker Page 3 "LKC NCR 3275 has been issued to identify and disposition the violation of procedure 4.3.10."

c. Delete the last paragraph.

9. a. In the first paragraph of the Response to Item 10.F., correct the reference to read "50-456/85-15 (DRP) " .

b. Add the following sentence to the second paragraph:

"Sargent & Lundy is now performing an engineering evaluation to determine dispositioning of NCR 4139."

c. Revise the last sentence in the third paragraph to read:

. "The matter is being reviewed by Commonwealth Edison and Comstock."

d. Delete the last paragraph.

10. Revise the sixth paragraph of the Response to Item ll.B. to read:

Subsequent to the NRC finding, Comstock generated Inspection Correction Reports 8067 and 8068 to address the hardware deficiencies. In addition, a review of the remaining quality control files for Unit 2 electrical penetrations was performed. As indicated on a Comstock Memorandum (copy enclosed) from Mr. Hii to Mr. DeWald, NCR's were written to track the items where corrective action documentation was lacking.

Document review procedures require the review of all quality control documentation to verify the existence of corrective action documentation for deficiencies indicated on inspection reports.

General Inspection Reports are currently being reviewed under procedure 4.13.1. In addition, 4.13.1.1 is being revised (Rev. B) to specifically incorporate General Inspection Reports. This revision ~will require a review of General Inspection

i

.. I l

Affidavit of James W. Giesek'er Page 4 i

Reports to assure that there are no additional '

discrepant items that are not being tracked through the nonconformance system.

Further affiant sayeth not.

(b . 11/1/$h J4mes W. Gisheker LJ Subscribe and sworn to before me this + ay of September, 1985 e - -

G.,

^!9E4 ,,_e m -,4. 7A4-Notary Public My Commission Exp:res April 19,1988

- My Commission expires on .

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k(.J...FE...- .3W Comstock Engineering, Inc. .

1 Memorandum To: I. F. DeWald Offia: Braidwood From J ., P . Hii

Subject:

NRC Concern on Unit II Penetrations Date: 06/07/85 l l

Control No. 85-06-07-01 The following are the results of an NRC concern dealing with discrepancies noted on Form #104's (general inspection reports) for the Unit II penetrations.

The G.I.R.'s were written describing various problems with the penetrations.

However, an ICR or NCR was not generated to identify the discrepancy as outlined in Procedures 4.11.1 and 4.11.2.

1. A review of all Unit II penetration packages was performed.

2. The review resulted in 16 penetrations found where an ICR or NCR had not originally been generated.

3. Of the 16 penetrations, 8 have since had NCR's generated

'for the discrepancies outlined cn the G.I.R.

Penetration I.D. NCR # Penetratier. I.D. NCR #

2LV05E 4152 25IO5E 4109 2LV06E 4114 25IO6E 4110

. 2LV07E 4151 25IO7E 4111 2LV08E 4157 25108E 4112

4. Of the remaining 8 penetrations, all have since been remodified and the Form #200's are within the package to saov inspection i results.

l Penetration I.D. Date remodified Penetration I.D. Date remedified 12/01/8; 2AP85EA 02/04/85 2 RD16 E 11'21/8; 2AP85EC 12/01/84 2RD17E 2APSSED 10'16/84 25I01E 10/16'S-10/16/84 25IO2E 11/30/8; 2RD13E At /

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