ML20137A707
| ML20137A707 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/22/1985 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| References | |
| CON-#485-298 OL, NUDOCS 8511260075 | |
| Download: ML20137A707 (243) | |
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UNITED STATES OF AMERICA D conhta.og%
U NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ED In the Matter of ) '6 5 g y 7 3 COMMONWEALTH EDISON COMPANY ) DocketjNosy 50-456 (Braidwood Station Units 1 and 2 )
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{b APPLICANT'S SECOND PARTIAL RESPONSE TO ROREN'S SECOND SET OF QUALITY ASSURANCE INTERROGATORIES AND REQUESTS TO PRODUCE On October 21, 1985, Intervenors Rorem, et d. ("Intervenors') filed their Second Set of Quality Assurance Interrogatories and Requests to Produce. Applicant filed a first partial response on November 15, 1985, responding to a portion of Specific Interrogatory 7 of Intervenors' Second Set. This submission, which is Applicant's second partial response, responds to the remainder of Specific Interrogatory 7 and to the remaining specific interrogatories of Intervenors' Second Set.
Each document identified in the response pr vided herewith has been listed in a Reference List provided with this tubmission. Each of these documents will be numbered and a numbered index will be provided to Intervenors in the near future. Further investigation is proceeding with regard to any other documents that may reflect the responses provided herewith. An updated index will be provided to Intervenors when this process is completed. Addresses and telephone numbers requested in Specific Interrogatory 2.have been provided in this response for only those individuals uhose addresses were not provided in reponse to Intervenors' First set of Interrogatories and Requests to Produce. ,
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Specific Interr*aatory 1 Please identify and describe in detail any and all corrective actions, remedial measures, or other responses which address the allegations, assertions, or other matters contained in intervenors' amended quality assurance contention. For each subpart, or item, of the contention (including the Quality Control (QC) Inspector Harassment Contention), please describe in detail any actions, programs or facts upon which you rely to show that the matter asserted in the contention does not evidence a significant breakdown in quality assurance or a failure of safety related parts, components or systems to meet applicable regulatory requirements or to be capable of performing their intended function in service. Please identify any documents which reflect this answer.
RESPONSE
Applicant has provided an identification and description of any and all corrective actions, remedial measures, or other responses which address the allegations assertions or other matters contained in intervenors' amended quality assurance contention in Applicant's response to specific Interrogatory 58/59 of intervonors' first set of interrogatories as well as in Applicant's response to Specific Interrogatories 2, 3, 4, 5, 6 and 7 of intervenors' second set of interrogatories. These responses provide a description of the actions, programs or facts upon which Applicant has or will rely to show that the matter asserted in the contention does not evidence a failure to meet applicable regulatory requirements or that the capability has been demonstrated of safety-related equipment to perform its intended function in service. To the extent deficiencies have been identified and acknowledged by Applicant in the referenced responses to interrogatories, those responses fully describe the actions undertaken to correct those deficiencies.
0528H/ November 22, 1985
specific Interromatory 1 In that regard, intervenors' QA contention is comprised almost exclusively of issues previously raised by the NRC staff in inspection reports issued between February, 1983 and May, 1985. It is Applicant's judgement that these issues do not individually or collectively evidence a significant breakdown in quality assurance, although certain of these issues have been acknowledged as indicating weaknesses in the overall quality program that required correction.
It is a generally accepted view, to which applicant subscribes, that deficiencies will be identified in the construction of a nuclear power plant, given the magnitude and complexity of such a project; and that some construction defects will be tied to quality assurances lapses. The fundamental questions that must be answered are whether all ascertained construction errors have been cured and whether there has nonetheless been so pervasive a breakdown in the quality assurance procedures as to raise legitimate doubt about the overall safety of the facility.
Applicant's responses to the concerns documented in the NRC inspection reports, to which intervonors make reference in their contention, demonstrate that those concerns either have been or will be cured based on documented corrective actions. Applicants' answers to interrogatories have identified and described these corrective actions and the bases relied upon to ascertain the effectiveness of those actions. Futher assurance that these concerns have been or will be cured can be derived from the NRC staff's ongoing inspection of Applicants' corrective actions.
0528H/ November 22, 1985
specific Interroaatory 1 With respect to whether a pervasive breakdown has occured in the quality assurance procedures sufficient to raise legitimate doubt aboint the overall safety of the facility, one must necessarily ascertain not only whether individual deficiencies have been identified but also, the extent to which applicants' quality assurance program and procedures have demonstrated the capability to identify deficiencies in construction and the capability to evaluate and effectively correct such deficiencies once identified. The construction deficiencies identified in intervenors' contention were in many cases, identified by applicant prior to the NRC 4 expression of concern. Moreover, the deficiencies were analyzed to determine their cause and potential programmatic implications. This ;
commitment to effectively resolve known deficiencies and prevent their recurrence is itself evidence that a pervasive breakdown did not occur.
The changes to and improvements in the Applicant's quality programs ,
described in answer to specific Interrogatories 24 and 51 of Set I have P
been and continun to be effective in identifying construction deficiencies. It is for these reasons that applicant contends that a significant breakdown in quality assurance is not evidenced by the issues raised by intervenors in their QA contention. !
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specific Interrommtory 2 With respect to the following subparts or iteins of intervenors' amendeo quality assurance contention 1.B. 1.C, 1.D, 1.E, 1.F.
the Quality Control (QC) Inspector Harrassment Contention, 5.A and 12.J. please dess:rlbe in detail the circumstances involved, including the name and address and telephone number (work and home) of each person involved, the manner in which the deficiency, weakness', finding, or observation was identified, investigated, evaluated for significance, root cause and generic implications; and the manner in which it was remedied and corrected, including any corrective action taken with regard to the existence of other related deficiency, weakness, finding or observation. set forth any facts up'on which you rely to show that the matter and its root cause have been effectively corrected. Please identify any documents Which reflect these answers.
Rg8PON83 Applicant's response is contained on the following pages.
0536H/ November 21, 1985
CONTENTION ITEM 1.5
- 1. Contrary to Criterion I, " organization" of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison has failed to effectively oversee the quality assurance activities of its site contractors for which it retains responsibility. Widespread deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors including the mechanic (piping ans supports / restraints) equipment and instrumentation installation contractor Phillips, Getschow company; the heating, ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal company; and the concrete contractor, G. K. Newberg Company.
B. On May 7, 1984, NRC Region III Administrator James G. Keppler cited Commonwealth Edison for serious quality assurance violations. involving Braidwood site mechanical contractor Phillips, Getschow Company; HVAC contractor, Pullman Sheet Metal Company; electrical contractor, L. K. Ccastock Company and Architect / Engineer, Sargent and Lundy. "A major factor contributing to the deficiencies were inadequate contractor programs and workmanship, inadequate licensee reviews of the contractor programs, and inadequate licensee quality assurance overview to ensure contractor activities met all requirements.
The violations indicate the need for more aggressive Commonwealth Edison company management involvement in and support of the commonwealth Edison Company Quality Assurance program to ensure that all safety-related activities performed by contractors' personnel are in accordance with regulations, codes, standards, an license requirements." (Keppler (IntC Region III) to O'Connor (CBCo), transmitting Inspection Report 83-09, Exhibit 5.)
These Quality Assurance deficiencies resulted in stop work orders and construction deficiency reports in the areas of small bore piping hangers, MVAC welding activities and piping material control. Deficiencies concerning piping material control resulted in teh quality of some installed piping being indeterminate and resulted in some materials being installed that did not meet design requirements. (Inspection Report 83-09, Exhibit 5.)
RESPONSE
In their Inspection Report No. 83-09, the NRC found a number of deficiencies concerning the verification of correct material for ASME piping components, control of HVAC welding activities, and
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RpSPONSE --
Cont'd design control of field run small bore piping and associated hanger installation activities. The NRC, in the transmittal letter for Inspection Report 83-09, cited the major factors contributing to the deficiencies and indicated the need for more aggressive Commonwealth Edison company management involvement in and support of the Commonwealth Ediscn Company Quality Assurance Program. It should be noted that the inspection activities which are covered by Inspection Report 83-09 took place from June, 1983 to February, 1984. During this period significant changes to and improvements in Commonwealth Edison Company's quality programs were taking place.
In this regard, the NRC acknowledged these Commonwealth Edison Company activities in Inspection Report 83-09, stating "We are encouraged by the personnel and organizational changes you described duringtheMarch7,1984,enforcementconferencehichindicatethat you recognize the need for increased sanagement involvement in the quality assurance program and have taken some positive actions in that regard". A comprehensive description of these personnel and organizational changes was provided in response to specific Interrogatory 51. Further, in response to Specific Interrogatory 24, a discussion of the contemporary reviews of construction quality, including the BCAP, is included which confirms the acceptability of previous work and the effectiveness of management actions taken in response to NRC specific findings.
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RESPONSE --
Cont'd Additionally, the NRC CAT Inspections "noted no pervasive breakdown in meeting construction requirements...or in the applicants project
, construction controls for managing the Braidwood Project" and
" observed that commonwealth Edison was implementing some good construction practices at Braidwood site" With respect to deficiencies identified concerning small bore piping hangers, HVAC welding activities, and piping material control the following actions were taken:
j 1.
- A stop work order issued in the area of small bore piping hangers. This issue is covered under the scope of NRC Items 456/83-09-09A and 456/83-09-08D (Contention Items 3.A.3.A and
, 14.B.4). These were addressed in the response to Interrogatories 58/59, 28, 37 and 38.
- 2. A stop work order issued in the area of HVAC weld activities.
This. issue is covered under the scope of NRC items 456/83-09-10A, 456/83-09-10B and 456/83-09-10C (Contention Items 3.A.1, 3.A.2, and 3.A.3). These were addressed in the responses to Interrogatories 58/59, 25, 29, 39, 47 and 48.
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Cont'd
- 3. A construction deficiency report (55E) issued on piping material control. This issue is covered under the scope of 55E report 83-07 and NRC items 456/83-09-04A and 456/83-09-04B (Contention Item 10.B). These were addressed in the responses to Interrogatories 58/59, 26, 30, 31, 36, 38, 41 and 42.
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(19064)
r CONTENTION ITEM 1.C l
- 1. Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison has failed to effectively oversee the quality assurance activities of its site l' . contractors for which it retains responsibility. Widespread deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors including the mechanical (piping and supports / restraints) equipment and instrumentation installation contractor, Phillips, Getschow Company; the electrical contractor, L. K.
Comstock Company; the heating ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal Company; and the concrete contractor, G. K. Newberg Company.
C. Deficiencies noted by the NRC CAT inspection in a number of hardware installations indicate a need for more management i attention. The deficiencies included examples of inadequate hardware inspection and examples of inadequate quality assurance and engineering review of deficiencies for general l application. The major areas of concern to the NRC CAT are:
- 1) the dependence on final walkdown inspections late in the l construction program to identify and resolve problems; and 2) the ability to manage the large number (over 20) of ongoing major corrective action programs and ensure that current work is correctly performed. (CAT Inspection Report 84-44/40, Exhibit 10.)
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RESPONSE
At the time of the NRC CAT Inspection, Commonwealth Edison continued i to place considerable management attention toward assuring prompt l
and effective attention to completion of corrective action efforts, l
j while simultaneously insuring that current work is correctly i performed. As a management tool and initiative, to assure that a I consistent high level of attention was directed by all levels of management, including the contractor organizations, Commonwealth l Edison developed a list of corrective action efforts that were underway at the time, which were monitored by the Project Manager.
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RESPONSE --
Cont'd That list included active corrective action programs involving each l of the major on-site contractors, and was used to focus attention to the need for overall high level management attention to quality related efforts and assure continued awareness of the importance of ;
quality related aspects of all construction activities. The complexity and stage of completion of each of the identified programs varied, and were chosen, in part, so that a program involving each major active site contractor was included. Most of those programs and others that were then underway are now completed ,
or substantially completed and have been effectively implemented.
The effective completion of these programs demonstrates that the l
concerns expressed in the CAT Inspection Report were unwarranted. !
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CONTENTION ITEM 1.D.1 l !
- 1. Contrary to Criterion I, " organization" of 10 C.F.R. Part 50, -
Appendix B, Comenonwealth Edison has failed to effectively l oversee the quality assurance activities of its site I
contractors for which it retains responsibility. Widespread
- j. deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors including the mechanical (piping and supports / restraints) L equipment and instrumentation installation contractor Phillips, ,
cetschow company; the electrical contractor, 1.. K. Constock F Company; the heating ventilation and air conditioning (HVAC) I contractor, Pullman Sheet Metal Company; and the concrete ,
contractor, G. K. Newberg Company.
D. The NRC CAT identified a number of construction program l weaknesses that require increased management attention. These l
- are: *
! i l 1. The effectiveness of first level quality control (QC) '
inspection activities needs to be improved, particularly I in the pipe support / restraint and welding areas. !
l The foregoing identified weaknesses require additional I
- management attention to assure that completed j l installations meet design requirements. (CAT Inspection )
l Report 84-44/40, Exhibit 10). 1 r
RESPONSE
l With respect to the need for increased management attention, refer s ,
l to the response to Specific Interrogatory 2, Set 2, contention Item i
! 1.C., and the response to Specific Interrogatory 58/59, set 1, Contention Items 10.C and 10.E. With respect to quality control (QC) inspection activities in the pipe support / restraint and welding i
areas, refer to the response to specific Interrogatory 58/59, Set l
! 2, contention Items 10.C and 10.E. j I !
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CGur.4 TION ITEM 1.D.2
- 1. Contrary to Criterion I, " Organization" of I C.F.R. Part 50, Appendix B. Commonwealth Edison has failed to effectively oversee the quality assurance activities of its site contractors for which it retains responsibility. Widespread deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors including the mechanical (piping and supports / restraints) equipment and instrumentation installation contractor Phillips, Getschow Company; the electrical contractor, L. K. Comstock Company; the heating ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal company; and the concrete contractor, G. K. Newberg Company.
D. The NRC CAT identified a number of construction program weaknesses that required increased management attention. These are:
- 2. A large number of final inspection activities are being included in a final walkdown, when greater difficulty will be encountered in identifying deficiencies because of interferences, accessibility and the pressure of schedule.
The foregoing identified weaknesses required additional management attention to assure that completed installations meet design requirements. (CAT Inspection Report 94-44/04, Exhibit 10).
RESPONSE
With respect to the need for increased management attention, refer to specific Interrogatory 2, Contention Item 1.C.
The implementation of final walkdowns in the mechanical, electrical and HVAC scope of work is an important part of checking the final acceptability of the completed plant when construction activities, in general, are very near completion. Final walkdowns have been very effectively utilized in the completion stages at our other
RESPONS8 --
Cont'd nuclear generating stations and are common in the utility industry.
Commonwealth Edison Company recognizes that final walkdowns are not a substitute for first-line quality control inspection activities and does not plan to carry out final walkdowns for that purpose. A list of planned and anticipated walkdowns is being generated for evaluation by management. Before walkdown activities are implemented, they will be evaluated to determine such things as whether the activity should be incorporated into other inspection activities, whether the purpose of the.walkdown is clearly defined, and whether the proper organization is performing the walkdown. In addition, all walkdowns will be performed to approved procedures or instructions. This evaluation process is being implemented to assure that the walkdowns performed are effective and that the concerns expressed by the CAT Inspection Report are minimized.
(1908d) s
4 CONTENTION ITEM 1.D.3
- 1. 1. Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, 4
Appendix B, Commonwealth Edison has failed to effectively oversee the quality assurance activities of its site contractors for which it retains. responsibility. Widespread deficiencies have occurred in the quality assurance activities
- and workmanship of the principal Braidwood site contractors including the mechanical (piping and supports / restraints)
- equipment and instrumentation installation contractor Phillips, l Getschow Company; the electrical contractor, L. K. Comstock Company; the heating ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal Company; and the concrete contractor, G. K. Newberg Company.
D. The NRC CAT identified a number of construction program
, weaknesses that require increased management attention. These are:
- 3. The identification and resolution of cable tray and i conduit electrical separation deficiencies is inadequate.
The foregoing identified weaknesses require additional management attention to assure that completed installations meet design requirements. (CAT Inspection Report 84-44/40, Exhibit 10). ,
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RESPONSE
l For the general resp nse to the need for increased management attention refer to Specific Interrogatory 2, Contention Item 1.C.
With respect to cable tray and conduit electrical separation deficiencies, refer to specific Interrogatory 58, contention Item 10.D.
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CONTENTION ITEM 1.D.4
- 1. Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison has failed to effectively oversee the quality assurance activities of its site contractors for which it retains responsibility. Widespread deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors including the mechanical (piping and supports / restraints) equipment and instrumentation installation contractor Phillips, Getschow Company; the electrical contractor, L. K. Comstock Company; the heating ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal Company; and the concrete contractor, G. K. Newberg Company.
D. The NRC CAT identified a number of construction p'rogram weaknesses that require increased management attention. These are:
- 4. An excessive number of incidents of damage to installed equipment has been caused by current construction activities.
The foregoing identified weaknesses require additional management attention to assure that completed installations meet design requirements. (CAT Inspection Report 84-44/40, Exhibit 10.)
RESPONSE
With respect to the general need'for increased management attention, refer to Specific Interrogatory 2, Contention 1.C.
Commonwealth Edison Company has reissued to all site contractors and other site organizations a comprehensive listing of construction guidelines on temporary supports, rigging and scaffolding to emphasize the importance of avoiding damage to installed equipment.
The primary purpose of these guidelines is to allow normal plant construction to proceed in an orderly and quality manner, yet avoid such damage.
Each site contractor has implemented these guidelines within their organizations. Commonwealth Edison Company is specifically following-up enforcement of these guidelines through their housekeeping and preventive maintenance procedure surveillance activities. Additionally, Project Construction Department Field Engineers enforce the guidelines during their day-to-day contacts with contractor personnel. Lastly, senior Commonwealth Edison Braidwood Project Management and contractor management review these implementation of construction guidelines during their plant tours.
Conunonwealth Edison Company believes this active participation by management personnel is the most effective method to preclude incidents of damage to installed equipment which may be caused by construction activities.
(1910d)
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CONTENTION ITEM 1.E
- 1. Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison has failed to effectively i oversee the quality assurance activities of its site i I
contractors for which it retains responsibility. Widespread deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors j including the mechanical (piping and supports / restraints) equipment and instrumentation installation contractor Phillips, Getschow Company; the electrical contractor, L. K. Comstock Company; the heating, ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal Company; and the concrete contractor, G. K. Newberg Company.
E. The NRC CAT Inspection found that contractor quality control (QC) inspections and site quality assurance programs have not been effective in assuring that installed pipe supports / restraints meet design requirements. The inspection and acceptance criteria provided for activities such as Quality control inspection and document review and control need to be strengthened and clarified. (CAT Inspection Report 84-44/40, Exhibit 10.)
RESPONSE
The response to this Contention Item is contained in Comiaonwealth Edison's response to Specific Interrogatory 2, Contention Item 1.D.l.
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CONTENTION ITEM 10F
- 1. Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B. Conunonwealth Edison has failed to effectively oversee the quality assurance activities of its site
. contractors for which it retains responsibility. Widespread deficiencies have occurred in the quality assurance activities and workmanship of the principal Braidwood site contractors including the mechanical (piping and supports / restraints) equipment and instrumentation installation contractor Phillips,
- . Getschow company; the electrical contractor, L.K. Comstock Company; the heating ventilation and air conditioning (HVAC) contractor, Pullman Sheet Metal Company; and the concrete contractor, G.K. Newberg Company. ,
D. The NRC CAT inspection concluded that additional management attention is required to improve contractor performance in the
- areas of contractor deficiency trending, and craft and quality control inspector training, i
l RESPONSE Following the NRC CAT team visit the Site QA Superintendent met with l
site Contractor QA/QC supervisors to review the various CAT Team conunents on contractor deficiency and trending activities. Pursuant to l Commonwealth Edison's review of the concerns addressed by the NRC CAT
. Team relative to contractor deficiency trending, further refinements of our existing trending programs were deemed warranted. In July 1985, 4 Commonwealth Edison Quality Assurance and Project Construction concurrently issued a letter BRD #16,997 to the applicable contractors (Phillips, Getschow, Pullman Sheet Metal, Pittsburgh Testing Lab, Midway, L.K. Comstock, G.K. Newberg, and NISCO) further defining desired l
. improvements in contractor trending suggested by the NRC CAT as well as i additional refinements deemed appropriate by Commonwealth Edison. The i l
uniform implementation of these trending guidelines is intended to l provide for prompt identification of areas where added attention can
. improve the quality of all activities. The results of the contractors l analyses can also be used to assess areas which may have potential impact on.the overall site.
i 0525H/ November 22, 1985 1
CONTENTION ITEN 1 F Additionally, the various contractors in conjunction with Commonwealth Edison have taken appropriate measure to enhance the training of craft and quality control personnel. These actions include:
enhancing existing training programs / procedures and providing more specialized training programs where appropriate; use of additional craft training instructors; addition of additional quality control training instructors; and development of specific training programs deemed appropriate based upon new programs, revised criteria, identified problem areas, etc. These measures further assure the quality of craft workmanship and quality control inspections.
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l 0525H/ November 22, 1985 l
9Q. INSPECTOR HARASSMENT CONTENTION Contrary to Criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B, ,
and 10 C.F.R. Section 50.7, Commonwealth Edison Company and its electrical contractor, L.K. Comstock Engineering Company have failed to i provide sufficient authority and organizational freedom and independence from cost and schedule as opposed to safety considerations to permit the effective identification of and correction of quality and safety significant deficiencies. Systematic and widespread harassment, intimidation, retaliation and other discrimination has been directed against Comstock QC inspectors and other employees who express safety and quality concerns by Comstock management. Such misconduct discourages the identification and correction of deficiencies in safety related components and systems at the Braidwood Station.
Instances of harassment and intimidation include at least the following:
- 1. At various time since at least August 1984, including in March 1985, more than twenty five (25) Comstock QC inspectors have complained to the NRC about harassment and intimidation by Comstock supervisors.
Such harassment and intimidation has been carried out or participated in by QC Manager Irv DeWald, Assistant QC Manager Larry Seese, QA Manager Bob Seltman and QC Supervisor R.M. Saklak. i Such harassment included widespread pressure to approve deficient work, to sacrifice quality for production and cost considerations and to knowingly violate established quality procedures. Harassment and retallatory treatment included threats of violence, verbal abuse, ,
termination of employment, transfer to undesirable joba or work in areau where quality deficiencies could not be noted, assignments to perform burdensome or monial "special projects" and other adverse treatment. Such discriminatory action was taken because -of the victim's expression of quality or Hafety concerns. Former Level II QC inspector John D. Seeders has knowledge' of these widespread instances of harassment. By letter of August 17, 1984, seeders complained to the NRC, Edison and Comstock management regarding instances of harassment directed against him. Subsequently, Mr.
Seeders was involuntarily transferred to the position of Engineering Clerk ' in retallation for his expression of quality concerns. Such assigntnent was intended by Comstock to keep Mr. Seeders away from sennitive work areas. Although QC Supervisor R.M. Saklak was finally terminated in 1985 for his mistreatment of QC inspectors and other misconduct, the effects of his harassment remain uncorrected and systematic harassment continues at Comstock to the present. The existence of widespread harassment impugns the integrity and effectiveness of on-going corrective action programs designed only to address other widespread QA failures at Comstock.
0451H/ November 22, 1985
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- 2. Coasteck manrgement, including QC M ntsse Irv DeWald cnd Cseparata QA Manrg r - Bob Macinn h0racted, discriminsted and retalistid estinst, and ultimately terminated Level TTI QC Inspector Worley O. Puckett because Mr. Puckett made numerous complaints about safety and quality i deficiencies which he identified in the course of his duties at Braidwood.
Mr. Puckett was hired by Comstock in May 1984 in the newly created position of Level III QC Inspector whose duties included conducting a review of Comstock procedures, tests requirements for the more than 50 Levnl TI QC Inspectors, review of the Level II's inspection work, and the resolution of inspection disputes. Mr. Puckett was highly ,
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quellfled with 20 years' nuclear Navy- and nine years' nuclear power !
experience. Emet, Resumo, Exhibit B. During the course of his employment with Comstock, Mr. Puckett was shocked by the widespread deficiencies in procedures, qualifications and workmanship. He identified numerous instances of laiproper construction procedures, improper qualification of welders, and material traceability
, deficiencies. He ultimately recommended a complete stop work order '
for all welding activity to permit effective corrective action. See, l Memos of August 10 and August 17, 1984 Exhibits C and D.
Finally, he warned QC Manager Irv DeWald that "we are approaching a complete breakdown in our QC program." August 22, 1984 Memo, Exhibit ,
E. Puckett was subjected to harassment and retaliation because he 4
raised these safety and quality concerns and was terminated on August
- 27, 1984 by DeWald on the pretext that he should havn scored higher than his 86% on a qualification test. He filed a complaint with the U.S. Department of Labor, alleging violation of the employee protection provisions of the Energy Reorganization Act, 42 USC 5851. l Letter, September 5, 1984 Exhibit F. The U . S . Department of Labor Area Dlrector sustained Mr. Puckett's cornplaint finding unlawful discrimination by Comstock against Puckett and ordered relief. Notes of Decision, November 6, 1984, Exhibit G. Mr. Puckett presented his case at a hearing before an Administrative Law Jmige on Coastock's appeal. See, complainant's Hearing Exchange, Exhibit H. Comstock settled Mr. Puckett's claim before putting on its case. The terms of settlement are subject to,a non-disclosure agreement between Comstock
, and Mr. Puckett.
! RESPONSE The QC Inspector Harassment Contention incorporates a general reference F
' to alleged claims of harassment or intimidation inade by somo 25 Comstock employees. Pending entry of a protective order by the Licensing Board, j Intervenora have doc 11ned to identify all but a few of _the individuals
+ alleging haranrnent and intimidation. Therefore, Applicant is unable to
! 0451H/ November 22, 1985 si
prsvid3 informaticn r gnrding tha general castrticns ralocd in th3 cententicn beyond the information supplied by Intervenors in their response to The information Interrogatory 9 of Applicant's first set of interrogatories.
pr ovided by Intervenors in response to Interrogatory 9 with regard to the
[ identified individuals (John D. Seeders, Worley O. Puckett, Rick Snyder, R.D.
E Hunter, Herschel Stout, and Dan Holley) is of such a general nature that it i does not provide a basis for Comnumwealth Rdison to respond to Intervenor's j request for information related to their allegations. Consonwealth Edison did investigate allegations brought by Comstock employees to the NRC on March 29, 1985. These investigations are described in documents numbered i
S0000082-S0000496 and A0013806-A0013810. The NRC's investigation into the i
Comstock employees' allegations of March 29, 1985 is documented in Inspection Report 85-021 dated November 4, 1985.
1 Intervenors' contention also identifies specific assertions of harassment and intimidation involving three former Comstock Engineering, Inc. employees and relating to their activities as QC inspectors at Comstock. The three
- specific alleged incidents involved John D. Secdera, Richard Snyder, and Worley O. Puckett. Intervenors themselves have defined harassment, intimidation, retallation, and discrimination as used in the contention as 4
- activities " intended to or having the effect of impeding, interfering with, or F
improperly influencing the performance of quality assurance duties by Braidwood site employees" (Intervenors' response to Interrogatory 8 of Applicant's first set of interrogatories). To the best of Commonwealth
. Edison's knowledge, none of the Comstock inspectors have asserted that their r
s 0451H/ November 22, 1985
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damlings with Coasteck manrgement er with Commonwenith Edis:n caused them to deviate from approved inspection procedures or otherwise compromise the adequacy of their QC activities.
Lohn D. Seeders r.
! Mr. Seeders h'as given deposition testimony in this proceeding which describes in some detall his claims of harassment at Comstock. In addition, Commonwealth Edluon has made available to Intervanors in response to prior ,
discovery requests numerous documents related to Mr. Seeders' claims and his
- . employment at Comstock.
t
- Thiring his employment at Comstock, Mr. Soeders was certified as a Level
! TI inspuel.or in both the calibrations and receipt inspection areas. He was responalble primarily for ensuring proper calibration of tools and equipment used by Comstock personnel. In May 1984, Commonwealth Edison's QA lusued an i
j audit report that included findings of deficienclus in Comstock's calibration
- ' records. (See Senders' Deponition Exhibit 5). In order to respond fully to the audit findings, Comstock management directed Mr. Senders to do a 100%
i
- review of the calibration records to determine if Inspection Correction j- Reports (ICRs) or. Nonconformanen Reports (NCRs) had been wrlthen and dispositioned properly when equipment was found to be out of calibration or when it was not calibrated according to the frequency required by procedure.
i.
At the time that Mr. S*eders was to do this 100% review, he was administering on the job training to Richard Snyder. Both Mr. Snyder and Myra j sproull, another Level TT in the calibrations area, were available to assist i
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- 0451H/ November 22, 1985
Mr. 8:ed:ra in the review and in completing n:cessary cngting work. l Manag* ment believod, and at the time Mr. Seeders agreed, that he could complete the-review in time to respond to the audit. finding in mid-August 1984.
Mr. Seeders prepared a report dated July 28, 1984 which represented only a sample review of the calibration records. (pages 00002926-2942). On August 14, 1984, Rick Saklak, Mr. Seeders supervisor, received this report on the calibration records from Mr. Seeders and gave it to Mr. Seltmann. This report was found by Mr. Seltmann to be deficient. On the morning of August 17, 1984, Mr. Saklak approached Mr. Seeders concerning completion of the work necessary for the audit response. Mr. Suklak was dissatlafled with Mr. Seeders' response and directed him to the offica of Mr. Seese, Comstock's assistant QC manager. Later that day, after verification and furLher discussions, a written warning was issued to Mr. Seeders. (See Seeders' Deposition gxhibit 14).
On August 17, 1984 or shortly thercafter, Mr. Soeders was en11eved of responsibility for the 100% review of calibration records. The assignment to do the review was given to Mr. Snyder and Ms. Sproull. Their review revealed substantial problems with the calibration records, and subsequently Comstock prepared NCR 3419 to address the findings. (see Secdors' Deposition gxhibits 9 and 11). Mr. Seeders was transferred to L.K. Comstock & Co. , Inc. effective October 1, 1984.
0451H/ November 22, 1985
Mr. Seed:rc d:cumented ellegttions cf h:rannm:nt and intinid:: tion in en Augun t. 17, 1984 Jetter to Mr. Tev DeWold, Coastock's QC manager. (See Secders' Deposition Exhibit 13). Mr. Seeders allegations were investigated by
-Comntuck management as reflected in documents nu1.bered 00002012-00002038.
Commonwealth Edison personnel also responded to allegations by Mr. Seeders as described in Exhihtta 16 and 17 to Mr. seeders' deposition. The NRC invectigated the allegations of Mr. seeders and han found his claims of harassment and intimidation to be unsubstantiated. (Page A0002669).
At.ijelicant dentes that any of the matters complained of constitute harassment and intimidation (as defined by Intervenors or otherwise) of Mr. seeders.
E1 chard snyder An incident involving Mr. Snyder and Mr. Saklak led to the termination of Mr. Suk1Nk by Comstock management. This incident occurred on March 28, 1985.
The circumstances involved were that Mr. Saklak and Mr. Snyder disagreed '
concerning the need to obtain an engineering evaluation before closing an ICR for a welding machine found to be out of calibration. In the course of theit.-
discussions, Mr. Saklak made a statement to Mr. Snyder to the effect that "If beatings were legal, you'd be dead". Mr. Snyder reported this incident to the NMC reoident inspectors the next day. On that day , other QC personnel from Comstock also brought concerns reinted to allegations of harannment and intimidation to the attention of the NRC.
Constock's investigation into the snyder/.iaklak incident is described in documents numberod 000001568-000001598. In addlLion, Connonwealth Edison's
-6 0451H/ November 22, 1985
y own inv sLig tion into thic insident, lo d:::ribed in d:t:11 in the d:cuments numbered S0000354-S0000496 and A0013806-A0033810. As reflected in these documents, Mr. Saklak was terminated and restricted from all unfaty - related work at all Commonwealth Edison sites.
)[orley O. Puckett Tn early 1984, concerns were raised related to the training of Comstock welding perininrint in AWS code D1.1. Comptock had a Welding Engincor from its corporate office come to the Braldwood nita and review the welding program and give training to QC inspectors. This individual identified concerns in the welding area which are docurrented in a May 12, 1984 memorandum from Mr.
DeWald. (See pages S0000808-S0000811). Comstock then hired Mr. Puckett to continue the review of the welding program and to resolve problems or inconsistencies which had been identified previously.
Mr. Puckett came to the Draldwooti site nn May 29, 19f14 !!n had hnen employed previounty at 7.immer an a Wnid gngineer. Mr. Puckett was to be certified as a f.nyn1 Ill welding inspector. The scope of his employment by comstock included the identification and resolution of concerns with the Comstock welding program. Tn his attenpt to gain Level III certification, Mr.
Puckett was given five welding practical examinations. Three of these exams were not valid because the welds inspected had no rejectable items. Mr.
Puckett failed the other two exams. He never gained f.nyn1 III certification at Braidwood.
0451H/ November 22, 1985 1
In o s:rico cf memoranda from Mr. Puck tt, he refcreed to conc rns in the welding area and called for a total stop work of welding at Comstock.
However, Mr. Pucket1. did not offer either detailed evaluations of the deficiencies or solutions or remedies to the problems he described despite repealed indications from Comstock management that it was his job tu do so.
(See pages S0000581-585). Mr. Puckett was miclaken with regard to most of the deficiencies he claimed to have identified while an employee of Comstock. The one valid deficiency of some significance which he identified, a failure of Comstock to qualify certain stainless steel welding procedures and wolders, led to a stop work order by comstock management for that scope of work in accordance with Mr. Puckett's recommendation. (See pages S0000625-629; S0000794-795). The cLainless steel welding procedures and welders were requallfled, and the utop work order was lifted. Mr. Puckett's failure to perform the job he wan hired to do adequately, coupled with his failure to obtain bevel TII certification, resulted in his termination at the end of his ninoLy day probationary period.
Mr. PuckoLL'o cubstantive concerns about the welding, procedures and records at Comstock are documented in his memoranda to management and in lists obtained from the NHC inopoctor who investigated Mr. Puckett's allegations.
In addillon, Comstock and Commonwealth sdison personnel have reviewed Mr.
Puckett's claims, and HCRs have boon written related to some items which had boon of concern to Mr. Puckett. The !!RC found Lhal lho clnlm of harassment and/or intimidation brought by Mr. Puckett was unsubstantiated. Applicant donles that any of the malloro complained of constitute harasismont and intimidation (as defined by Intervenors or otherwise) of Mr. Puckett.
0451H/ November 22, 1985
P.ERSONS INVOLVED 4
John D. Seeders L.K. Comstock & Co., Inc.
Richard Snyder BESTC0 Worley O. Puckett Rick Saklak Robert Seltmann Comstock Engineering, Inc.
Irv n*Wald Comslock Engineering, Inc.
Larry Seese Comstock Engineering, Inc.
Daniel Shamblin Commonwealth Edison Company Jamco Closeker Commonwealth Edison Company Lawrence Tapella commonwealth Edison Company Len MacGregor NRC Region TII Robert Schulz NRC Region III ,
Jerry Schapker NRC 0451H/ November 22, 1985
REFERgNCES
- 1. Commonwealth Rdinon Audit Report QA-20-84-528, dated May 21, 1984 (Seodors' Deposition Exhibit 5).
- 2. Handwritten calibration report by John D. Seeders, dat ed .Tuly 28, 1984 (Pages 00002926-2942).
3.- Employee warning record for John Seedern, dated August 17, 1984 (seeders' Deposition Exhibit 14; Pages 00002028-2029).
- 4. Calibration Audit Report, dated September 7, 1984 by Richard Snyder and Myra Sproull (Seeders' Deposition Exhibit 9).
- 5. Comptock NCR 3419, dated October 11, 1984 (seeders' Deposition Exhibit 11). ,
- 6. f.et t er, dated August 17, 1984, from John D. Seedern to Irv DeWald (Seeders' Deposition Exhibit 13; Pages 00002026-2027).
- 7. Memo to File, dated August 22, 1984, prepared by James W. Gieseker (seeders' Deposition Exhibit 16; Pages 00002008-2009).
- 8. Memo to File, dated August 23, 1984, prepared by Lawrence J. Tapn11a and James W. Gieseker (Seeders' Deposition Exhibit 17; 00002010-2011).
- 9. Inspection report 84-34 (,' ages A0002662-2677).
- 10. Memo from I. DeWald to D. Shamblin, dated April 8, 1985, concerning .
R.M. Saklak Incident (Pages 00001564-1585).
- 11. Quality First file QF 85-1188 (Pages 30000082-207).
- 12. Quality First flie QF 85-1221 (Pages 30000208-211).
- 13. Quality First file QF 85-1229 (Pages 20000212-353).
- 14. Quality First file QF 85-2026 (Pages 20000354-496).
- 15. Memo from I. DeWald to C. Mennecke and T. Quaka dated May 12, 1944 (Pages s0000800-811).
- 16. Memo f rom I. DeWold dated September 25, 1984 concerning review of J.
seeders Letter dated August 17, 1984 (Pages 00002012-2023).
- 17. Memo from I. DeWald dated August 20, 1984 concerning J. Seeders Letter dated Auust 17, 1984 (Pages 00002024-2025).
- 18. Memo f rom R.M. Saklak to Trv DeWald concerning J. Seeders Letter dated August 17, 1984 (Pages 00002030-2031).
0451H/ November 22, 1985
REFERENCBE (Cont,)
- 19. Memo from L.G. Seese to I. D*Wald dated August 20, 1984 concerning John ,
Soeders (Pages 00002032-2033).
- 20. Response prepared by R. Seltmann dated August 20, 1984 (Pages 00002034-2038).
- 21. Memo from W. Puckett to R. Saklak dated April 15, 1984 (Page 300005R1).
??. Rond 4 Reply from W. Puckett to T. DeWald dated August 10, 1984 r (Pago 80000582).
- 23. Road & Reply from W. Puckelt to I. DeWold dated August 13, 1984 (Page 50000583).
- 24. Memo from W. Puckett to R. Saklak dated August 17, 1984 (Page 30000584).
- 25. Memo from W. Puckett to I. ,DeWald dated August 22, 1984 (Page 80000585).
- 26. Memo from I. DeWald to F. Rolan dated ' August 15, 1984 (Pagon 80000794-795).
- 27. Memo from F. Rolan dated August 17, 1984 (Pages 80000625-629).
- 28. Notes from Exit Meeting with J. Schapkar.
- 29. Handwritten notes of W. Puckett used in investigation by J. Schapker.
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1 0451H/ November 22, 1985
r CONTgNTION ITEM 5.A L The NRC CAT inspection concluded that in the area of [ control '
of design documents) the most significant finding was the failure to annotate unincorporated design changes on controlled ,-
design documents. The most significant finding in the area of ;
design change control was design change documents written against superseded revisions of the approved design drawings. ,
In at least one instance, this deficiency resulted in a pipe support being installed and inspected to other than the latest approved design. (CAT Inspection Report 84-44/40, Exh. 10.)
, (Note: Words in brackets added for clarification).
f SARGENT & LUNDY RESPONSE ,
I The above statement was excerpted from the CAT Inspection Report's ;
i executive summary. This response addresses the second part of the above f I
statement which deals with design change control.
3 r l' The details of the CAT inspection with regard to the above statement I concerning design change control are found in Chapter VII of CAT i
j i
Inspection Report 84-44/40.
I t
- The subject of design change documents written against superseded i
revisions of approved design drawings for large bore pipe supports has j been extensively reviewed by sargent & Lundy. There are over 14,000 large bore supports located in safety Related structures at the Braidwood ,
2 station. Between July 1984 and December 20, 1984, 1,275 supports fron l j selected subsystems were reanalysed in 54L's Chicago office in accordance !
1 with S&L procedures which called for reanalysis when a certain level of I
- field modifications had occured. Revised drawings taking account of any change required by the reanalysis were prepared and listed in the S&L l Support Information Management System Report, a document prepared monthly and distributed to the site. These subsystems were being reanalysed at 4
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i 0531H/ November 22, 1985 i
CONTENTTON. ITEM 5 A j the same time that S&L's field office was resolving field installation I
- problems with respect to some of the same supports. Engineering Change Notices (ECN's) were generated by S&L field office to resolve the field installation problems associated with these supports but were not communicated to s&L's Chicago office to determine if any outstanding drawing changes were being processed for the supports which were the subject of the RCN. An ECN is a document used to revise a drawing on an interim basis. The RCN allows the contractor to proceed with
)
construction. The changes to the drawing which are shown on the BCN are Inter incorporated on the original drawing. The RCN process is controlled by Sargent & Lundy's Quality Assurance procedure GQ 3.13, Engineering Change Notices.
i All support drawings issued for construction as a result of the reanalysis effort by S&L's Chicago office, before December 20, 1934, were re-reviewed versus the BCN Index and Status Report to identify any additional supports for which BCN's may have been issued against superseded revisions of the support drawings. Out of the 1275 reanalysed supports, a total of seven support drawings, including the instance identified by the NRC CAT inspectors, were identified where BCNs were
, issued assinet superseded revisions of the support drawings. Similar i
problems have not been identified in other areas. Therefore, the overall design change contol process has been effective, and these occurrences are isolated cases. The differences between the drawings and the RCN's were not significant. There were no hardware changes required. The i drawings were subsequently revised to incorporated the RCN's.
y !
0531H/ November 22, 1935 :
CONTENTION ITEN 5.A procedures existing at the time of the NRC CAT inspections would have identified these supports subsequent to support installation and inspection. S&L's project Instruction pI-BB-63 requires that S&L review the information contained in the piping installation contractor's close-out Letters issued by the piping installation contractor for each piping subsystem. Included in the letter is a " Subsystem closo-Out Listing of Component Support completions." This document lists each piping support installed in that subsystem along with the drawing rovinion and any ECNs used to install each support. As required by BRFI-26, "Braidwood Field Instruction for Subsystem Close-Out", S&L prepares a " Support Close-Out Review Form". This prepared, reviewed, and approved document compares the installed support drawing revision to the current drawing revision level. It also comparco ECNs used for support installation to current ECNs issued. The discropant revision levels betwoon ECNs and the latest support drawing revisions would be identified during the preparation of this document. Furthermore, in the process of incorporating the ECN on the support drawings, the preparer and/or reviewer would have noted the discrepant revision levels.
Additionally in December 1984, S&L implemented procedural changes to minimize the recurrence of this type of isolated discrepancy. C&L's "Braidwood Field Instruction for Resolution of llanger Fiold problema",
BRFI-4, has been revised to explicitly establish a system to identify support revisions prior to the monthly issue of the S&L Support Information Management System Report. The required stops in field problem resolution now include review of subsystems beinf, roanalyzed and, where support drawings have not boon issued, the field problem resolutions are being placed on hold until roccipt of the revised drawing.
0531lI/ November 22, 1985
CONTENTION ITEM 5.A REFERENCgs i
0Q-3.13 General quality Assurance Procedure, Engineering Change Notices.
l PI-SS-63 Procedure for (1) RNeelving and Handling Piping "As-Builts",
(2) Close-out Letter and/or contractor Select supports; (3)
Piping Clearance Walkdown Information (Braidwood only).
BRF1-4 Braldwood Field Instruction for Resolution of Hanger Field Problems.
BRF1-26 Braldwood Field Instruction for Subsystem Close-Out.
NaC Inspection Report Nos. 50-456/04-44 and 50-457/04-40.
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-4 0531H/ November 22, 1985
COMMONWRALTH RDISON RESPONSg It should be noted that the NRC construction assessment team (CAT) found that " Design change cont:ol' was determined to be generally in conformance with applicable requirements". The CAT observation in this area regarding control of design documents is based upon a few isolated cases found during review of several site contractors' controlled documents. No major or generic problems were identified by the CAT in this area.
All contractors performing safety related work at the Braidwood site have developed and implemented procedures to control design documents used for construction (drawings, specifications, etc.) and to control design change documents (gngineering Change Notices, Field Change Requests, etc.) before they are incorporated in these design documents by sargent & Lundy. These procedures insure that the most current design information is used for installation and Quality control inspection.
Implementation of these document control procedures used by the various site contractors is reviewed by internal site contractor Quality Assurance and/or Quality control audits and/or surveillances of actual documents in field and office locations. In addition, Commonw alth Edison Quality Assurance performs periodic audits and surveL11ances of document control actLvities to verify that contractor procedures are being effectively implemented.
All safety related work activities performed by Braldwood site contractors are subject to appropriate Quality control inspection. This i providos an opportunLty to verify that,the installed hardwaro has been j installed to the latest design information. In addition to this first 0532lt/ November 22, 1985
I goletolnigAt.TH gDIs0N ItgSPON5g line Quality Control inspection, Cgco site Quality Assurance performs various direct overview inspections of a sample of site contractors' completed installations (including Quality control inspection). This provides a further, independent, verification of completed installations against current design documents.
In the vast majority of cases, design changes are made at the request of the installing contractor to resolve a field interference, provide component access or resolve some other field installation problem. Hence, the contractor performing the installation work l's constrained to performing the installation to a design change document such as an gCN, since the design change document was requested by the contractor to make the installation practical and/or possible. Because of this need for a design change in order to make a partir.ular installation practical and/or possLble, it is expected that the contractor will perform the particular installation to the requested design change even in the unlikely event that the design change was not annotated on the appropriate drawing as required by contractor procedures. There is no safety impact in this situation when contractor document control procedures may not have been completely implemented (eg.
a requested design change not annotated on the appropriate drawing),
since the personnel performing the work in the field are required to have the design change document in order to perfom the installation, several site contractors perform a final document review on work and/or inspection documentation afLer the work La completed in the
- field. This final document review provides still another check to ensure 1
0532il/ November 22, 1905 L
COMMONWEALTH EDIS0W ltBSPON85 that work was performed to the most current drawing and any applicable design changes which may not have been incorporated in the drawing.
In order to further enhance the control of unincorporated design changes, Commonwealth Edison company is developing a computerized data base of outstanding design changes. This data base is presently available in the commonwealth Edison of fices and will be sande available ,
to site contractors in the near future. This computerized data base will provide frequent information updating as well as convenient and accurata access to unincorporated design changes.
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, 0532H/ November 22, 1985
CosaIONWEALTN EDISON Resp 0NSE j
REFERENCES
- 1. CAT Report 50-456/84-44; 50-457/04-40 pg. A-3.
- 3. CBCo QA Audit schedule, CBCo Surveillance schedule.
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j 4-0532H/ November 22, 1995
CONTENTION IT M 5.A I MAMES AND ADDRESSES i
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- 0. E. Groth Cosmonwealth Edison Company '
N. A. Oorski Commonwealth Edison Company T. E. Quaka Cosmonwealth Edison Company R. Seitmann Comstock Engineering, Ina.
l R. Donica 0. K. Newberg K. Krans Philliya, Geteehow Company C. Holt Pullman Sheet Natal I R. Leigh Midway Industrial l
D. A. Gallagher Sargent & Lundy I R. W. Hooks sargent & Lundy l N. G. Flynn Sargent & Lundy l 220 Third St. 55 Best Nearee St. I l Downers Grove, Illinois 60515 Chicago, 1111 nets 60603 (312) 963-0590 (312) 269-8300 .
J. R. Neleter Israent & Lundy ,
410 North Willie 55 saat Monroe St. I Nt. Prospoet, Illinois Chlasso, 1111 note 60603 l (312) 259-4943 (312) 269-8308 i C. Novak Nuclear Installation 3ervlees Co.
211 8. Hannes Besidwood Nuelear station Joliet, Illinois 40434 Braeev111e, Illinois 60607 (015) 725-7609 (015) 450-2001 ,
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0532H/ November 22, 1985 j
l spectrzc IsramanaArcar 2 i i
I 2. With respect to the following subparte er itene of interveners' I l amended quaikky assuranee sentention: . . 12.J, please l
deseribe in detail the circumstances involved, including the .
name and address and telephone number (work and home) of each ,
l person involved, the manner in which the defleieney, weaknees, i finding, or ebeervation woe identified, investigated, evaluated '
for significanee, rest cause and generie impliestional and the manner in which it wee remedied and eerrested, including any '
secreative action taken with regard to the suistenee of other i related defisteney, weakness, finding er observation, set forth -
any facts upon which you rely to show that the matter and ite :
root cause have been effeehively corrested. Please identify any l j desuments which refleet these answers. ,
M ,
An NGC Cenetruction Appraisal Team (CAT) inspection was perfetiend by l
the Offlee of Inspeetten and Bnforcement (IE) on December 10-30, itse and ;
January 7-18, 1935 at the Braidwood site. As noted in IE Report 50-454/se-44, 50-457/g4-40 (at p. A-1) i An offort was made by the NBC CAT to evaluate the enceing j Braidwood Cenetruetten Assessment Program (BCAP). The sehedule i for the BCAP inspeetten program was such that only limited hardware samples were available for sec CAT everinspeetten. It !
was possible to overinspeet a very emell easyle of hardware in i the areas of supports / restraints, piping runs. WAC supporte ;
and duste for welding, WAC ducts for eenfiguretten and eendu!L j rune. In four of the sin areas that were overinspected, there l l was general agreement between BCAP and NBC CAT findings in two l areas, supports / restraints and piping runs, defleieneles were i identified by the NGC CAT that were not identified by the BCAP '
inopoeters. On the bests of the limited sample overinspeeted.
14 appears that BCAP inspeetten effort needs to be Laproved in -
the areas of supports /reatesinte and piping evne. L r
i The defleieneles identified by the NaC CAT that were not identified by !
the RCAP inspeatnre are described at pp. III-2 and III-7 of IE Report !
50-454/84-44, 50-457/04-40. I l
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-1= f (eletN)/ November 23, Ital '
PPECIFIC INTgRROCATORY 2 The NCAP inspectors responsible for inspections of piping supports /
restraints and piping runs were highly qualified professionals certified to ANSI W45.2.6 Level II or greater. They received appropriate training and instruction prior to performing any inspections, and appropriate supervision during the RCAP effort..
The CAT inspectors' concerns relating to BCAP inspections were communicated to the BCAP Task Force before the CAT inspectors left the site in January 1985. These concerns were discussed with the BCAP mechenical/ welding inspection personnel on January 11, 1985, and all such inspection personnel were reminded to take the time to do a thorough and accurate reinspection with careful attention to all details.
With respect to piping runs, for the piping shown on Drawing 1A-AF-8 the CAT inspectors found one dimension accepted by the RCAP inspector which should have been rejected, and one rejected which was acceptable.
One of these incorrect measurements was attributable to an error by the BCAP inspector. In the other 43Ja, an error in the dimensions shown in the drawing contributed to an error by the gCAP inspector and also by the CAT inspector. The causes of both incorrect measurements were discussed with the NCAP inspector. Baked on the nature of the errors and the frequency of occurrence, it was determined that no additional action was necessary.
Desed on the information provided by the WMC staff, the BCAP Task Force identified four specific attributes or areas of concern relating to (0542H)/ November 22, 1985
SPECIFIC INTERROGATORY 2 pipe support / restraints. (See BCAP Memo #530, Attachment #1.) on January 18, 1985 the BCAP Task Force initiated a plan to reverify these four attributes or areas for all pipe support / restraint packages inspected by the BCAP through January 18, 1985. There were a total of 160 such support / restraint packages, in three construction categories:
Large Bore Rigid Pipe Supports (M0002), Large Bore Non-Rigid Pipe Supports (M0003), and Small Bore Pipe Supports (M0006). CSR inspection activities for pipe supports / restraints were immediately suspended pending completion of the reverification process.
On January 23, 1985, while the pipe support / restraint reverification program was underway, the NCAP Director (N. Katashal) decided that the BCAP would do a " midpoint look" into the CSR inspection activities.
Pending the completion of this " midpoint look," the BCAP Director temporarily halted all CSR inspections. (See BCAP Memo #546.) on January 24, 1985 the BCAP Director authorised continuation of CSR inspection except in three areas, une of which was pipe supports / restraints. (See BCAP Memo #551.)
The Reverification Plan for piping supports / restraints is set forth in Attachment 2 to BCAP Memo #530. Pursuant to this plan, checklists for reverification of the characteristics identical to or similar to the CAT inspectors' areas of concerns were developed by the BCAP Mechanical /
Welding Level III Supervisor (Ed Shev11n) and approved by the BCAP Inspection Supervisor (M.A. Clinton). Prior to performing any reverification inspection, the BCAP inspectors were appropriately trained 3
(0542H)/ November 22, 1985
SPECIFIC INTERROGATORY 2 in the objectives of the Reverification Plan, the attributes or areas to be reverified, and specific instructions applicable to each such attribute or area. No BCAP inspector reverified his or her own previously performed inspection. The BCAP inspectors who performed the reverification were not aware of the identitles of the original BCAP inspectors or the results of the original BCAP inspections.
The reverification for pipe supports / hangers resulted in only 20 new observations out of 640 (4 x 160) areas or attributes reverified.
Moreover, an analysis of the now observation showed that 12 of the 20 were not detected in the initial BCAP inspections for reasons other than inspector technique. None of the new observations was deemed to be significant. The BCAP Assistant Director determined that for future inspections, the BCAP inspectors should verify dimensions of vendor-supplied catalog items. During the initial BCAP inspections, the BCAP inspectors had not been instructed to do this. (see BCAP Memo
- 593). On January 30, 1985, the Mechanical / Welding Level III inspector met with BCAP mechanical / welding inspectors to discuss the new observations made during the reverification. Where a new observation was attributed to inspector technique, that finding was discussed in detail with the BCAP inspector responsible for the initial inspection. On January 31, 1985, a group meeting was held with the BCAP mechanical / welding inspectors to provide feedback on the results of the roverification. The checklist instructions to be used in the future were described in detail. BCAP inspections of pipe support / hangers resumed on February 1,1985 (see BCAP Memo #604).
4 (US A ?ll)/ November 22, 1985
gPECIFIC INTERROGATORY 2 BCAP Quality Assurance reviewed the BCAP CSR inspectors' qualifications and training, and their inspection checklists and l
I instructions, prior to any CSR inspections of pipe supports / restraints and piping runs being performed. In addition, BCAP Quality Assurance overinspected more than 10% of the pipe supports / restraints and piping runs inspected by the BCAP Task Force in the CSR. (At the time of the CAT inspection, BCAP quality Assurance had not overinspected the specific pipe supports / restraints and piping uns as to which the CAT inspectors identified deficiencies not identified by the BCAP Task Force inspectors.)
l l BCAP Quality Assurance established the acceptance criteria for comparisons between the BCAP Task Force inspections and BCAP Quality Assurance overinspections as 95% for objective attributes and 90% for subjective attributes for each construction category. The results we found in gxhibit C-3 of the Report on the Braidwood Construction Assessment Program (SCAP). For each construction category including pipe supports / restraints or piping runs, these acceptance criteria were met.
In addition, BCAp Quality Assurance used the overinspection results to evaluate individual FCAP Task Force inspectors' performance and concluded for each individual performing inspections of pipe supports / restraints or piping runs that his or her performance was acceptable.
CBCo is not aware of any 1500 observations with respect to the adequacy of BCAp piping support / restraint inspections or piping run (0542H)/ November 22, 1985 e
SPECIFIC INTERROCATORY 2 Ceco is not aware of any other NRC Staff inspection findings with respect to the adequacy of BCAP inspections of piping supports / restraints or piping runs. Ceco believes that this CAT inspection finding is currently classified by the NRC Staff as an open item.
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(0542H)/ November 22, 1985
SPECIFIC INTERROGATORY 2 Marinder N. Kaushal Home Address:
960 Monticello Dr19e Naperville, Il 60540 Telephone: Home - (312) 355-3496 Work - (815) 458-2801 Ext. 2654 George M. Orlov Local Address:
105 Twin Oaks Drive Apt. 309D Joliet, IL 60435 Telephone: (815) 729-2034 Home Address:
1844 Woodpine Lane Cincinnati, OH 45230 Telephone: (513) 231-0910 Robert L. Byers Home Address:
1807 Fair Oak Naperville, Il 60565 Telephone: Home - (312) 961-5405 Work - (815) 458-2801 Ext. 2782 i
Menzo A. Clinton Home Address:
! 205 Spring Hill Drive i simpsonville, S. Carolina 29681 Telephone: Home - (803) 967-2670 Work - (803) 281-4717 Neil p. Smith Home Address: ,,
9859 So. Bell Chicago, IL 60643 Telephone: Home - (312) 233-3327
, Work - 458-2801 Ext. 2635 I
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l l l (0542H)/ November 22, 1985
SPECIFIC INTERROGATORY 2 Ron Gardner Work Address:
U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Rd.
Glen Ellyn, IL 60137 Telephone: Work - (312) 790-5500 Ext. 38-85524 Pamala J. Thompson
.Home Address:
110 So. 17th Street Hanhattan, KS 66502 Telephone: Home - (913) 537-0085 Phil S. Jones Home Address:
6862 South Creek Ft. Worth, TI 76133 Telephone: Work - (817) 897-4881 Ext. 337 Ed Shevlin Home Address:
107 St.' Joseph St.
Joliet, IL 60436 Telephone: Home - (815) 729-0080 Work - (815) 458-2801 Ext. 2696 CECO is currently unable to identify the NRC CAT inspectors responsible for this observation.
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l (0542H)/ November 22, 1985
1 SPECIFIC INTERROGATORY 2 l
REFERENCES j l
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- 1. IE Report 50-456/8A-44, 50-457/84-40 (pages A0002984-A0003121). '
, 2. Report on the Braidwood Construction Assessment Program (page E0000731-E0000824).
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- 3. BCAP Pip Support Reverification Program (includes BCAP Memo #s 530, 546, 551 and 593) (pages E0000308-E0000524).
- 4. BCAP Memo #597 (includes BCAP Memo #530) (pages E0000525-E0000539).
- 5. - BCAP Memo #604 (page E0000540).
- 6. BCAP QA Special Instruction QASI-18, Rev. 3 (pages S0003544-S0003549)
- 7. BCAP QA Surveillance Report BQAS-IV-259 (pages S0003550-S0003567).
- 8. Untitled evaluation of BCAP Task Force inspectors' performance (pages S0003568-S0003578).
- 9. Handwritten memo from M.A. Clinton to R.L.' Byers dated January 19, 1985 (pages E0000715-E0000716).
- 10. Handwritten document entitled " Reverification Plan" by E.M. Shevlin (pages Eoooo717-E0000718).
- 11. Handwritten document entitled, " Areas of Question or Concern" by E.M. Shevlin (page E0000719(,
- 12. Handwritten notes by M.A. Clinton (pages E0000720-E0000721).
- 13. Memorandum dated 1/12/84 (Sic) to Menzo Clinton from Ed Shevlin ce NRC CAT findings (page E0000722).
- 14. Memo dated 1/11/85 to Menzo Clinton from Ed Shevlin re NRC CAT findings (page E0000723).
- 15. Employee evaluation forms fot Pam J. Thompson and Phil S. Jones (pages E0000724-E9000729).
- 16. Memo dated 1/11/85 to Menzo Clinton from Ed Shevlin re Mech / Weld Inspection Group meeting (page E0000730).
(0542H)/ November 22, 1985
, Sp*cific Int cr*a*_tery 3 ,
With respect to your answers to Interrogatory 58 of Intervenors' First Set of Quality Assurance Interrogatories and Requests to Produce, please provide updated and current information ;
regarding the identification, investigation and corrective action taken for each alleged deficiency and subpart or item.
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RESPONSE
In its sixth partial Response to Interrogatories 58 and 59 of Intervenors' First Set of Quality Assurance Interrogatories and Requests to Produce, Applicant made a review of Intervenors' amended Quality
- j. Assurance Contention to identify each example of a violation, unresolved I
item or open item with respect to quality assurance. These examples, in fact, generally restate items reported by the NRC Staff as appearing to 1
indicate discrepancies with respect to specific provisions of 10 CFR 50 Appendix B. Each of those items were addressed in the original response to these Interrogatories.
In this response, Applicant is providing updated and current information with respect to the identification, investigation and corrective action taken for each Contention Item. Not all Contention Items have had a status change since the filing of Applicant's original t'
response and therefore there was no need to update every Contention Item. No updated information exists for those items which are not included in this response. In addition, updated reference lists and names and address lists (the address of each individual is the Braidwood site) have been provided only where such updated information actually exists. For certain Contention Items, updated information, including references, is contained in Applicant's responses to other Specific Interrogatories filed by Intervenors in their Second Set of Quality
'(0533H)/ November 22, 1985 1
.. , -, - 4,
Sp'cific Interrzz+ tory'3 Assurance Interrogatories and Requests to Produce. These instances are clearly identified in the updated response to each Contention Item. A list of site Quality Assurance Surveillances specifically performed on Contention Item issues since Applicant provided its original response to Interrogatories 58 and 59 is also provided with this response. These Surveillances and other documents responsive to this updated response will be made available, upon reasonable notice, for Intervenors' inspection.
As was originally discussed in the introduction to Applicant's response to Interrogatories 58 and 59, Commonwealth Edison may not have agreed with the validity of the alleged discrepancy identified in each Contention Item as originally identified by the NRC. In those cases in which a discrepancy was acknowledged to exist, the specific item response so indicated. This statement and the remainder of the discussion contained in the introduction to Interrogatories 58 and 59 remains accurate unless specifically noted in this response or in Applicant's other responses provided to Intervenors' Second Set of Quality Assurance Interrogatories and Requests to Produce.
i (0533H)/ November 22, 1985
So cific Interr x+tery 3 SITE QUALITY ASSURANCE SURVEILLANCES AND AUDITS p
TO SPECIFICALLY UPDATE CONTENTION ITEMS (ROREM QUALITY ASSURANCE INTERROGATORIES AND REQUEST TO PRODUCE SECOND SETSPECIFIC INTERROGATORY 3)
SURVEILLANCE CONTENTION NRC TTEM or ISSUE
_' ITEM NO. NO. AUDIT NO. DATE REMARKS 3A2 456-100-83-09-10B QA-20-85-520 9-6-85 NOTE 1 3A2 456-100-83-09-10B 5066 10-25-85 4A 456-100-84-07-02B 5179 11-14-85 -
4A 456-100-84-07-02A 4991 11-15-85 -
6A 456-100-82-05-04 4988 10-3-85 -
6D 456-100-82-05-04 4988 10-3-85 -
6E 456-100-84-29-02 4748 8-9-85 -
6F 456-100-84-21-03 -5010 10-18-85 -
6G 456-100-84-17-01 4747 8-9-85 -
8B 456-100-84-44-03 5141 11-14-85 NOTE 1 9C 456-100-84-13-09 4680 8-9-85 -
9D 456-100-84-17-08 5002 11-8-85 NOTE 1 9D 456-100-84-17-06 4804 9-12-85 -
9E 456-100-84-08-01 4972 11-8-85 -
10B 456-100-83-09-04A QA-20-85-547 9-13-85 -
10B 456-100-83-09-04B QA-20-85-547 9-13-85 -
12A 456-100-82-05-05 4988 10-3-85 -
12A 456-100-82-05-05 5036 11-8-85 -
12F 456-100-85-006-01B 5189 11-21-85 -
12C 456-100-84-21-07 4915 9-18-85 -
14B2 456-100-83-09-08B 4852 10-6-85 -
1483 456-100-83-09-08C 5144 11-6-85 -
l NOTE 1: Surveillance or audit covers other subjects outside of the contention issued. Paragraphs in the report Which are
- pertinent to the contention are marked with a bracket and an identifier.
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1 (0533H)/ November 22, 1985
r- !
Specific Int cr*metery 58 & 59 - Interductirn Pages one through eleven (1-11).
UPDATED RESPONSE On page eleven (11) of the Introduction, the last paragraph is hereby deleted from the response.
0534H/ November 21, 1985
L
-CONTENTION ITEM 3.A 1
- 3. Contrary to Criterion II, " Quality Assurance Program," of
-10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to establish a quality assurance program which complies with the requirements of Appendix E and which is documented by written policies, procedures, and instructions and is carried out in accordance with those instructions'. Edison has failed to assure that its QA program provides controls over activities affecting quality and that such activities are accomplished under suitably controlled conditions and are appropriately verified for quality by inspection.
A. A special NRC QA inspection reported May 7, 1984 that:
- Instructions were not appropriate to the circumstances in that i
welding procedures specifying and essential variables were not prescribed on drawings or welding sequences (travelers) for each specific HVAC installation and Quality Control inspections during the welding process were not of adequate scope and frequency to assure the use of correct welding variables.
UPDATED RESPONSE As noted in the original response to the Contention Item, under Commonwealth Edison's direction, Pullman Sheet Metal is performing a destructive test program to demonstrate the adequacy of past field welding practices prior to September 1983 when the revision to PSM Procedure B9.4.F was implemented. A two part test program has been established by Commonwealth Edison after discussion with the NRC Staff.
One part of the program involves non-silicon bronze welding and the second part of the program involves silicon bronze welding.
Under the non-silicon bronze part of the program, 82 weld joints were removed from installed HVAC components in the plant. These welds were selected as having been performed by welders with a high rejection rate, multi-pass welds, welds with difficult configuration and full penetration welds which could not be inspected for fit-up. All 82 weld joints lacked documented base metal inspections and a specifically 1
0549H/ November 22, 1985
C"NTENTION ITEM 3.A.1 documented weld procedure. 25 of the welds could not be verified for fit-up. These welds were cut out and pull tested to destruction to verify strength. Test results showed all welds to be adequate.
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l Under the silicon bronze part of the program, a similar testing procedure is currently being used. Pull testing of these welds was completed in early November, 1985. The results of this program are currently being evaluated.
The NRC has reviewed the results of the non-silicon bronze' welding part of the program and has found it acceptable. It is presently waiting for the results of the silicon bronze welding part of the program prior to close out of the identified concern.
2 0549H/ November 22, 1985 1
CONTENTION ITEN 3 A.1 UPDATED REFERENCES
- 1. Test Report SL-7000 "HVAC Weld Testing Report", with letter from H.
Hitseman to W.E. Vahle, dated November 11, 1985.
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i 0549H/ November 22, 1985 1
i CONTENTION ITEM 3.A 1 UPDATED NAMES AND ADDRESSES J. Dierbeck Conunonwealth Edison Company i
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0549H/ November 22, 1985
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CONTENTION ITEM 3.A,2
- 3. Contrary to Criterion II, " Quality Assurance Program," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to establish a quality assurance program which complies with the requirements of Appendix B and which is documented by written policies, procedures, and instructions and is carried out in accordance with those instructions. Edison has failed to assure that its QA program provides controls over achives affecting quality and that such archives are accomplished under suitably controlled conditions and are appropriately verified for quality by inspection.
-A. A special NRC.QA inspection reported May 7, 1984 that:
- Quality Control was not required to examine the HVAC components for fit-up prior to welding on those components where fit-up tolerances cannot be determined after welding, such as all-around fillet welds and full penetration welds.
Consequently, there was lack of records documenting the conformance with the requirements of AWS Dl.1-1977, Section 3, and the Edison QA Manual. Additionally, instructions to the quality control inspectors regarding fillet weld gaps after welding were not appropriate to the circumstances in that.the HVAC contractor Visual Wald Inspection Procedure, B10.2.F. stated that a 3/16" gap was acceptable whereas AWS Dl.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by the amount of the separation or the contractor demonstrates that the required effective throat has been obtained.
RESPONSE
~ A partial updated response to this Contention Item is contained in Applicant's updated response to Contention Item 3.A.1 of Intervonors' Second Set.
Commonwealth Edison Nonconformance (NCR) Report No. 656 was issued to disposition welds which could not be inspected for fit-up after weld completion. One hanger was finally included on NCR 656. Sargent and Lundy, the project Architect Engineer, has reviewed and dispositioned these welds. For this one hanger, S&L determined, upon review of design drawings, that the hanger could not have been inspected for fit-up after welding had been-performed. For this hanger, that portion of the 0458H/ November 22, 1985 I
CONTENTION ITEM 3.A 2 connection detail between the horizontal and vertical members was involved. Evaluation of these connections indicated that additional weld was required to be added to the existing weld. This hanger was reworked by Pullman Sheet Metal and the S&L hanger drawing was revised.
Commonwealth Edison QA cond eted Surveillance No. 5066 from October 10 through 16, 1985, to verify that corrective actions for NCR No. 656 were completed. It was determined the safety-related hangers under the scope of this nonconformance had been properly repaired, and/or inspected. NCR No. 656 was subsequently closed on October 25, 1985.
0458H/ November 22, 1985
CONTENTION ITEN 3.A 2 UPDATED REFERENCES
- 1. Comonwealth Edison NCR 656 (closed).
- 2. Comonwealth Edison Surveillance No. 5066.
0458H/ November 22, 1985
CONTENTION ITEN 3eA 2 UPDATED NAMES AND ADDRESSES J. Dierbeck Comonwealth Edison Company i
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1 0458H/ November 22, 1985
CONTENTION ITEM 3-A 3
- 3. Contrary to criterion II, " Quality Assurance Program," of 10 C.F.R. Part 50,. Appendix B, Commonwealth Edison Company has failed to establish a quality assurance program which complies with the requirements of Appendix B and which is documented by written policies, procedures, and instructions and is carried out in accordance with those instractions. Edison has failed to assure that its QA program provides controls over activities affecting quality and that such achives are accomplished under suitably controlled conditions and are appropriately verified
. for quality 6, inspection.
A.- 'A special NRC QA inspection reported May 7, 1984 that:
- Quality control was not required to examine the base metal prior to welding to assure that surfaces and edges were free of discontinuities. Consequently, there was a lack of records documenting conformance with the requirements of AWS D1.1-1977, Section 3, and the Edison QA Manual.
UPDATED RESPONSE A partial updated response to this, contention Item is contained in Applicant's updated response to Contention Item 3.A.1 of Intervenors' Second Set.
During an October 24, 1985 NRC Inspection Exit Briefing, NRC Inspector J. Jacobson stated that he had reviewed the revision to PSM Procedure B10.2.F implemented to correct this item. Based on this review, the inspector indicated that this action was acceptable and that he would close this item. This closure review is to be documented in a forthcoming Inspection Report.
F 0459H/ November 22, 1985
CONTENTION ITEN 3.A.3 i
UPDATED NAMES AND ADDRESSES i
J. Dierbeck Comonwealth Edison Company 0459H/ November 22, 1985
4 CONTENTION ITEN 3.A.4.5
- 3. Contrary to Criterion II, " Quality Assurance Program," of 10 C.F.R. Part 50, Appendix B, commonwealth Edison Company has failed to establish a quality assurance program which complies with che requirements of Appendix B and which is documented by
- written policies, procedures, and instructions and is carried out in accordance with those instructions. Edison has failed to assure that its QA program provides controls over activities affecting quality and that such activities are accomplished under suitably controlled conditions and are appropriately verified for quality by inspection. -
4 A. A special NRC QA inspection reported May 7, 1984 that:
i
- Edison's control of site designed small bore (2" and under) process and instrumentation piping systems was considered j inadequate and ineffective based on the following deficiencies:
I The Phillips, Getschow small bore pipe routing procedures ;
- lacked specific quantitative field design, installation, and ;
inspection criteria to provide clearance and/or separation t from equipment and components as required by S&L '
- specification, F/L-2739, Paragraph 301.11. ;
l i UpDATBD Rg8p0NSE For updated information pertinent to this contention, see l I
Applicant's updated response to Interrogatory 58, contention Item 7.A.
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0461H/ November 22, 1945 [
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CONTENTION ITEN 305
- 3. Contrary to criterion II, " Quality Assurance program", of 10 C.F.R part 50, Appendix B, Commonwealth Edison Company has failed to establish a quality assurance program which complies with the requirements of Appendix B and which is documented by written policies, procedures, and instructions and is carried out in accordance with those instructions. Edison has failed to assure that its QA program provides controls over activities affecting quality and that such activities are accomplished under suitably controlled conditions and are appropriately verified for quality by inspection. .
B. phillips, Getschow piping crews failed to adequately control the modifications of beams. Tha Applicant had not established an inspection program for. structural beams that were modified during piping installations, and had not established an adequate craft training program with regard to nonsafety-related piping installation activities resulting in field design modifications to safety-related structural steel.
(Inspection Report 85-15/16, Exh. 17.)
UPDATED RESPONSB Sargent & Lundy reviewed Commonwealth Edison Nonconformance Report (NCR) 740 concerning unauthorized holes in the webs of structural beams in the Auxiliary Building. All discrepancies were evaluated and ,
determined to be acceptable when compared with design requirements and code design criteria. Sargent & Lundy recommended this NCR be accepted "as-is" with two exceptions. Although all the beams are acceptable, sargent & Lundy recommended that two of the beams be reinforced in order to restore design margin. Sargent & Lundy approved Field Change Request (FCR) L-19596 with comunents incorporating these reinforcement details.
The two beams were reinforced by C.K. Newberg per.S&L Engineering Change Notice 28509. Work was completed on october 29, 1985. The beam reinforcements were verified acceptable by Commonwealth Edison site quality Assurance and Ceco NCR 740 was closed on November 8, 1985.
0446H/ November 22, 1985
CONTENTION.ITEN_3,5 In addition, the references to Unit Concept Inspections, the Instrument Retrofit Verification Program and BCAP on page three (3) of the original response to Contention Item in Interrogatory 58 are hereby deleted.
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0466H/ November 22, 1985
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CONTENTION ITEM 3.5 UPDATED REFERENCES
- 1. CECO NCR 740 (closed).
- 2. CECO Field Change Request L-19596.
- 3. Sargent and Lundy Engineering Change Notice 28509.
- 4. Letter L.V. Jacques to W.E. Vahle, dated September 26, 1985.
1 0466H/ November 22, 1985
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CONTENTION ITEN 3.C -
- 3. Contrary to Criterion II, " Quality Assurance Program", of i 10 C.F.R. Part 50, Appendix B, commonwealth Edison Company has i
failed to establish a quality assurance program which complies with the requirements of Appendix B and which is documented by written policies, procedures, and instructions. Conunonwealth l Edison Company has failed to assure that its Q.A. Program I provides controls over activities affecting quality and that l such activities are accomplished under suitably controlled l conditions and are not appropriately verified for quality by inspection.
C. The applicants electrical contractor (Comstock) utilized Level I Quality Control Inspectors for inspection and acceptance of electrical welds. This involved fourteen different Level I Inspectors over four years (Inspection Report 85-06, Exhibit 11).
UPDATED RESPONSB An updated response to this contention Item which describes the contention-specific corrective actions being undertaken to resolve this issue is contained in Commonwealth Edison's response to specific interrogatory 6 "Lovel I Reverification Program" of Intervonors' Second i
set.
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0467H/ November 22, 1985 l
CONTENTION ITEN 4,A
- 4. . Contrary to Criterion II, " Quality Assurance Program", of 10 C.F.R. Part 50, Appendix 5. Commonwealth Edison Company has failed to effectively provide for the indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
A. Comstock failed to established program for identifying the
. required reading for weld inspectors and conducting practical tests. G.K. Newberg failed to implement the personnel indoctrination and training for QC inspector tests.
(Inspection Report 34-07, Exh.18.)
UPDATED RESPONSE During an inspection on June 24 through September 6, 1985, NRC Inspector W. Kropp reviewed actions taken to correct this item. These actions were found to be acceptable and this item was closed. This review is documented in Inspection Report Nos. 456/85-032 and 457/85-031 pages 4 and 5 and pages 6 and 7.
0468H/ November 22, 1985
CONTENTION ITgM 5.B
- 5. Contrary to criterion III, " Design Control," of 10 C.F.R. part 50, Appendix B, Commonwealth gdison Company has failed to establish measures to assure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions including provisions to assure that appropriate quality standards are specified in design documents and that deviations from such standards are controlled. Applicant has also failed to require that measures are established for the identification and control of design interfaces and for the coordination among participating design organizations, that the measures include the establishment of procedures among participating design organizations, that the measures include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design inttefaces; and that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
B. Repairs to coating by Midway Industrials in the Unit 1 and 2 containments were performed utilizing a coating system not qualified for the Design Basis Accident in accordance with Section 5 of ANSI N101.2 (1972). (Inspection Report 85-15, gxh. 17.)
UPDATg0 Rg8PONSg An updated response to this Contention Item is contained in Commonwealth gdison's response to Specific Interrogatory 4 of Intervenors' Second Set which provides a description of the " Nuclear Coating Applications" corrective action program.
In addition, during a November 14, 3085 NRC Inspection gxit Briefing, NRC Inspector W. Kropp stated that he had reviewed actions taken to resolve the item. Based on this review, the inspector indicated that these actions appeared to be acceptably implemented and that he would close this item in a forthcoming Inspection Report.
0470H/ November 22, 1985
CONTgNTION ITEN 5.C
- 5. Contrary to criterion III, " Design Control," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to establish measures to assure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions including provisions to assure that appropriate quality standards are specified in design documents and that deviations from such standards are controlled. Applicant has also failed to require that measures are established for the identification and control of design interfaces and for the coordination among participating design organizations, that the measures include th establishment of procedures among participating design organizations for tho review, approval, release, distribution, and revision of documents involving design interfaces; and that the design control measuras provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
C. Edison employed designs for safety-related HVAC duct supports based on chapter E36-0 of C&L's structural Standard Document which did not limit the slenderness ration for ceiling mounted duct supports. (Inspection Report 84-43/39, Exh. 19.)
UPDATgD RESPONSE During an October 24, 1985 NRC Inspection Exit Briefing, NRC Inspector J. Jacobson stated that Inspector J. Nuffett had reviewed actions taken to correct this item, found them acceptable and would close this item. This closure review will be documented in a forthcoming Inspection Report.
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l 0471H/ November 20, 1985
CONTENTION ITEM 6.A
- 6. Contrary to Criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
A. Approved procedures for the installation or installation inspection of mechanical safety-related equipment did not exist
, until July 16, 1980, although numerous pieces of this equipment were finally or partially installed prior to this date. I Equipment installed prior to July 16, 1980, included the four Unit 1 Steam Generators, the four Unit 1 and Unit 2 Residual Heat Removal Pumps and the four Safety Injection Pumps.
Further, the procedure developed by the installation contractor, Phillips, cetschow Company, subsequent to July 16, 1980, was not consistently implemented in that the four Unit 2 Steam Generators and seven of the eight Primary Reactor Coolant Pumps were installed without use of the installation procedure. This violation was in part the basis for the imposition of the 2/2/83 civil penalty for "a breakdown of your Quality Assurance (QA) program." (Exhibit 3)
UPDATED RESPONSE An updated response to this contention Item is contained in that part of Commonwealth Edison's response to Specific Interrogatory 7 of Intervenors' Second Sec which provides a description of the " Safety Related Mechanical Equipment Reinspection" corrective action program identified in Appendix B to the BCAP June 1984 program description transmitted by J.J. O'Connor to J.G. Keppler by letter of June 22, 1984.
0472H/ November 22, 1985
CONTENTION ITEM 6eBo1
- 6. Contrary to Criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R 50, Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that activities affecting quality are prescribed by documented instructions, procedure, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
B. A special NRC QA inspection reported May 7, 1984 that:
- Phillips Cetschow Company, Field Drawing M-2539C-4, Revision D, was not stamped with Field Change Request No. L-9194 and Field Drawing M-2542C-121 Revision A, was not stamped with Field Change Request No. 9988.
UPDATED RESPONSE During an inspection on June 24 through September 6,1985, NRC Inspector R. Schulz reviewed actions taken to correct this item. The Inspector requested that Commonwealth Edison evaluate the failure to stamp Field Drawings with Field Change Requests with regard to hardware installations and inspections. This review is documented in Inspection Report Nos. 456/85-032 and 457/85-031 page 8. Commonwealth Edison is currently conducting an evaluation in this area to assess the impact of the above item on actual PCCo hardware installations and Quality Control inspection activities.
0473H/ November 22, 1985
I CONTENTION ITEM 6cB 1 UPDATED REFERENCES -S' t '
} 1. NRC Inspection Report No. 456/85-032 and 457/85-031.page 8.
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0473H/ November 22, 1985 -
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CONTENTION ITEM 6 B 1 UPDATED P NAMES AND ADDRESSES M. A. Gorski Commonwealth Edison Co.
w 0473H/ November 22, 1985
CONTENTION ITEM 6.B.2
- 6. Contrary to Criterion V, " Instruction, Procedures and
' drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth
, Edison Company has failed to ensure that. activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
B. A special NRC QA inspection reported May 7, 1984 that:
- Edison's Quality Assurance Manual, Revision 77, Q.P. No. 7-1,
" Control of Procured Material and Equipment - Receiving and Inspection," section 5.2.1.5.7, " Dimensional," requires visual checks be performed on a random basis to assure that interface dimensions conform to drawings and/or specifications. However, random visual checks of interface dimensions of piping components were not being done.
UPDATED RESPONSE The two pieces of small bore pipe, one piece each from two heats, which were inspected in storage that did not meet the manufacturer's material specification requirements for wall thickness, sus referred to in the response to Specific Interrogatory 45 which was referenced as the response to Contention Item 6.B.2, have been documented on Phillips, Getschow Company Nonconformance Reports.5317 and 5318. These nonconformance reports are presently at Sargent and Lundy for disposition.
In addition, during an October 24, 1985 NRC_ Inspection Exit Briefing, NRC Inspector J. Jacobson stated that Inspector J. Muffett had reviewed-PGCo receipt inspection activities implemented to correct this item. Based on this review, the inspector found corrective actions to be acceptable and indicated he would close this item. This closure review is to be documented in a forthcoming Inspection Report.
0474H/ November 21, 1985
CONTENTIfN ITEM 6 B.2 UPDATED REFERENCES
- 1. Phillips, Getschow NCR Nos. 5317 and 5318.
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0474H/ November 21,.1985
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'CONTENTI"N ITEM 6.B.2 4
UPDATED NAMES AND ADDRESSES M. A. Gorski Commonwealth Edison Company
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0474H/ November 21, 1985
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CONTENTION ITEM 6.B.3
- 6. Contrary to Celterion V, " Instruction Procedures and Drawings," ,
of'10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company D has failed to ensure that activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
B. A special NRC QA inspection reported May 7, 1984 that:
- Contrary:to,Phillips, Getschow Company Quality Procedure, there was no documented record on los specifying that a calibrated instrument was used to measure numerous pipe bends.
for ovality requiring inspection measurements to the thousands of an inch. Examples include the bends on Drawings M-2546C-22, M-2546C-44, MC-2546C-42, and M-2546C-31.
UPDATED RESPONSE Phillips, Getschow Co. Nonconformance Report (NCR) No. 3962 (referred to in the response to Specific Interrogatory 45 which was referenced as a partial response to contention Item 6.B.3) was issued on March 8, 1985 to document seven items found to be discrepant during a
. sample inpection of 64 pipe bends for ovality requirements. Sargent and Lundy, the Project Architect Engineer, has evaluated the sample inspection results for the seven discrepant items. .Sargent and Lundy's i
evaluation determined that these inspection results clearly demonstrate that (1) the degree of ovality problems is only slightly above the ASME d
Criteria and_(2) the number of bends with excess ovality is reasonably low and consistent with expected measurement accuracles. Accordingly, Sargent and Lundy concluded the quality of pipe bending activities is judged.to be adequate to meet system design requirements. Based on this
" accept as is" disposition, Phillips, Getschow closed Nonconformance l
i- Report 3962 on October 11, 1985.
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CONTENTIO7 ITitM 6.B.3 On September 23, 1985, Commonwealth Edison Company Site Quality Assurance performed a routine quarterly follow-up surveillance No. 4961 4 of the corrective actions taken for (closed) CECO Audit No. 20-83-33 which had reconfirmed in Finding #2 that PGCo QC Inspectors were not recording the instrument control number of ca,lipers used to measure pipe bend ovality (p. 2 of original' response). During the course of this surveillance it was observed that corrective action had been effectively implemented for the recording of caliper control numbers for pipe bend ovality measurements.
In addition, during a November 14, 1985 NRC Inspection Exit i Briefing, NRC Inspector R. Schulz stated that he had reviewed corrective actions implemented to assure the recording of caliper control numbers j for pipe bend ovality measurements. Based on this review, the Inspector indicated that he would close this item. This closure review is to be
- documented in a forthcoming Inspection Report.
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F.
CONTENTION ITEM 608 3 UPDATED REFERENCES
- 1. Ceco QA surveillance No. 4961.
- 2. Phillips, Getschow NCR 3962 (closed).
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0475H/ November 21, 1985
CGuian4 ION ITEM 6.5,3 UPDATED NAMES AND ADDRESSED M. Gorski Conunonwealth Edison Contpany 0475H/ November 21, 1985 l
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l CGu a mm a ION ITEN 6.B. 4 l
- 6. Contrary to Criterion V,'" Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
B. A special NRC QA inspection reported May 8, 1984 that:
- Contrary to Phillips, Getschow Company Construction Procedure, Field Change Orders were not written for revisions involving ASME Section III, Subsection NF welds for component support Drawings M-1RH02017R, Revision I, and M-1SI16021K, Revision B.
UPDATED RESPONSE During an inspection on June 24 through September 6, 1985, NRC Inspector R. Schulz reviewed the formal withdrawal of PGCP-4, Rev. O.
Which was authorized by Commonwealth Edison on June 24, 1983 to resolve this item. This action was found to be acceptable and this item was closed. This review is documented in Inspection Report Nos. 456/85-032 and 457/85-031, pages 8 and 9.
0476H/ November 22, 1995
EU"'*8'4 ION ITEN 6 -8.4 UPDATED REFERENCEE
- 1. NRC Inspection Report No. 456/85-032, 457/85-031.
i 0476H/ November 22, 1985
CONTENTION ITEM 6.B.5
- 6. Contrary to Celterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that activities affecting quality cre prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
B. A special NRC QA inspection reported May 7, 1984 that:
- Contrary to L. K. Comstock Quality Assurance Manual, drawings located in site document Station Number 5 were voided in that they were up to four revisions old and were neither returned to document Control as volded drawings nor marked as being voided drawings for information only.
(Inspection Report 83-09, Exhibit 5.).
UPDATED RESPONSE A partial updated response to this Contention Item is contained in Commonwealth Edison's response to specific Interrogatories 6 and 7 of Intervenors' Second Set which provide descriptions, respectively, of the "L.K. Comstock Drawing Review Program" and the "L.K. Comstock Document Review Program."
commonwealth Edison Site Quality Assurance Department has continued to monitor drawing control activities of L.K. Comstock. Surveillance 4943 was performed on September 16, 1985. The surveillance concluded that L.K. Comstock continues to effectively implement corrective action necessary to preclude repetition in the area of drawing control.
During an October 31, 1985 NRC Inspection Exit Briefing, NRC Inspector P. Pelke stated that he had reviewed actions taken to correct this item, found them acceptable and would close this item. This closure review is to be documented in a forthcoming Inspection Report.
0477H/ November 21, 1985
CONTENTION ITEN 6.B.5 UPDATED REFERENCES
- 1. Commonwealth Edison QA Surveillance Report No. 4943, dated 9/16/85.
NOTE: The following other Commonwealth Edison QA Surveillance Reports were discussed in the prior response but not included on the reference list for this item: No. 4212, dated 2/25/85 (pages B0002430-2432); No. 4451, dated 5/14&l5/85, (pages B0002438-2440); No. 4719, dated 7/31/85 (pages B0002447-2451).
0477H/ November 21, 1985
GONTENTION ITEM 6.C
- 6. Contrary to Criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, commonwealth ;
Edison Company has failed to ensure that activities affecting i quality are prescribed by documented instructions, procedures'; ' i or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
C. The piping contractor, Phillips, Getschow, did not have a procedure or documented instruction stipulating a systematic method for producing an accurate In-service Inspection drawing, including determining the number and location of all field welds and shop welds. (Inspection Report 85-07. Ethibit 14.)
UPDATgD Rg8PONSE During an inspection on June 24 through September 6, 1985, NRC Inspector R. Schulz reviewed the revision to PGCo Procedure PCD-25 issued to resolve this item. The inspector determined the Procedure revision which incorporated the PGCo ISI drawing checklist currently in use, did not address three points:
- The procedure does not require the checklist to be used and signed by the Phillips Getschow engineering personnel who produce the Inservice Inspection drawings.
The checklist does not indicate which attributes on the checklist require field examinations and which require documentation reviews.
- The method used to assure the accuracy of the drawings produced was not addressed by the licensee.
The inspector stated that this item would remain open pending licensee review of these factors. This review is documented in Inspection Report Nos. 456/85-032 and 457/84-031 pages 9 and 10.
Commonwealth Edison is currently evaluating necessary further action on this issue.
0478H/ November 20, 1985
CONTgNTION ITgN 6.D
- 6. Contrary to Criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison company has f ailed to ensure that activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, peceedures, or drawings.
D. Support plates were installed between the concrete pedestal base and the anchor bolt hold down plate for the Unit 1 and 2 containment spray pumps. However, they were not specified on the drawings and therefore these plates, including the size, type or grade of material, were not analyzed for design basis.
Furthermore, these additional plates were not identified during quality control installation inspections. (Inspection Report 85-07, Exh 14).
UPDATgD Rg8PONSE ,
Corrective action specified in Phillips, Getschow NCR's 3961 and 3963 (p. 2 of original response) were initiated on November 4, 1985 and will be completed by November 30, 1985. These actions include removing the four (4) Containment Spray Pumps and four (4) Residual Heat Removal pumps from their respective bases, removing their shims and reinstalling 4
the pumps without the use of the shins. A further update to this Contention Item is contained in that part of Commonwealth Edison's response to specific Interrogatory 7 of Intervenors' second set Which provides a description of the " Safety Related Nechanical Equipment Reinspection Program."
In addition, during an October 17, 1985 NRC Inspection Exit Briefing, NRC Inspector R. Schuls stated that he had reviewed actions taken to correct this item. Based on this review, the inspector indicated that these actions appeared to be acceptably implemented and that their completion should resolve and close this issue. This review is to be documented in a'n Inspection Report to be issued in the near future.
0479H/ November 22, 1985
CONTENTION ITEM 6,D UPDATED NAME8 AND ADDRESSES M. DouBherty Conunonwealth Edison Company I
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0479H/ November 22, 1985
CONTENTICE IT M 6.F l
- 6. Contrary to Celterion V, " Instruction, Procedure and Drawings," l of 10 C.F.R. Part 50, Appendix B, comunonwealth Edison company *
! has failed to ensure that activities affecting quality are *
- prescribed by documented instructions, procedures, or drawings, i and are accomplished in accordance with these instructions, {
procedures, or drawings. l t
F. In June, 1984, Phillips Getschow, piping contractor, found l piping that violated minimum well requirements. This defect ;
was not reported to owner in accordance with 10 C.F.R. 21.21. !
(Inspection Report 84-21/20, Ruhlbit 20.) :
4 j UPDATED RESPONSE An updated response to this contention Item is contained in l
j Cosmonwealth Edison's response to specific Interrogatory 4. Item Number f five (5) "small Bore pipe Wall Thickness" of Intervenors' Second Set.
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0481H/Wovember 22, 1985 r
i 90NTENTION ITEM 6.N
- 6. Contrary to criterion V " Instruction, Procedures and !
l Drawings," of 10 C.F.R. Part 50 Appendix 3 Comunonwealth i Edison Company has failed to ensure that activities affecting l quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these
- instructions, procedures, or drawings.
H. Sargent and Lundy did not prescribe clearance criteria for
. safety-related HVAC components or safety related large bore l
piping and electrical items in relation to other items such as equipment, conduit, etc. (Inspection Report 84-09, Exhibit 22).
UPDATED RESPONSE For updated information pertinent to this contention item, see Applicant's updated response to Interrcr. story St. Contention Item 7.A.
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0403H/ November 22, 1985 6
CONTENTION ITEN 7.A
- 7. Contrary to Criterion VI, " Document Control," of 10 C.F.R. part 50, Appendix 3. Commonwealth Edison Company has failed to ensure that measures are established to control the issuance of documents and these measures assure that changes to those documents are reviewed for adequacy and approved for release by authorised personnel and are distributed to and used at the location where the prescribed activity is performed.
A. A special NRC QA inspection reported May 7, 1984 that adequate measures had not been established to control field changes to drawings being made during the installation of ASME Soller and pressure Vessel Code, section III, Class 2 and 3, 2" and under piping. Craft personnel had been making field changes to the deswings by rerouting lines, assigning weld numbers, and adding material which resulted in a lack of necessary control of approving, updating, and releasing drawings. (Inspection Report 83-09. Exh. 5.)
UPDATED RESPONSE During an inspection on June 24 through September 6, 1985, NRC Inspector R. Schulz reviewed actions taken to correct this item. The inspector verified that corrective actions were acceptable. However, the inspector believes that one aspect still remains open. sargent & Lundy issued an enstneering change notice No. 22822, that defined installation clearance guidelines for components and materials. The guidelines included a current 3 inch clearance requirement for installed piping but did not require the clearance margin for past in1ta11ations. The engineering change notice, BCN, stated, "The requirements of this BCN are applicable upon the approval date of this RCN and are not retroactive."
The approval date was September 18, 1984. The inspector requested that the licensee evaluate the clearance requirements specified in ECW No.
22822 for past as-built drawings, prior to the september 18, 1984 approval date. This review is documented in Inspection Report Nos.
456/85-032 and 457/85-031 pages 8 and 9. Commonwealth Edison is addressing the issue of pipe clearance in its response to IE Report 0485H/ November 22, 1985
CONTENTION ITEM 7 &
83-09-09(3) (Contention Item 3.A.4.5) and related response to IE Report 84-09-01 (Contention Item 6.H). See Applicant's original response to Interrogatory 58. Contention Items 3.A.4.5 and 6.H.
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0485H/ November 22, 1985 i
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CONTENTION ITEM 7.A UPDATED REFERENCEE
- 1. NRC Inspection Report 456/85-032 and 457/85-031.
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CONTENTION ITEM 8 A i
- 8. Contrary to Celterion VIII, " Identification and control of Natorials, parts and Components," of 10 C.F.R. Part 50, Appendix 3. Cossaonwealth Edison Company has failed to ensure that measures are established for he identification and control of materials, parts and components including partially fabricated assemblies in order to prevent the use of incorrect or defective materials, parts or components. '
A. Identification of traceability records were not maintained as required for some of the large cap screws used to secure the steam senerator to its supporting columns. At least 19 of 192 screws were cut off and the identifying numbers were neither transferred nor marked on tags and records traceable to the screws. Further, adequate traceability records were not ,
maintained for several hundred of these screws which were !
transferred back and forth between the Byron station, the :
Braidwood station, Rockwell Engineering (for QC checks) and -
Telodyne Brown Engineering (the installation contractor). This violation was in part the basis for the imposition of the 2/2/83 civil penalty for "a breakdown of your Quality Assurance (QA) program." (Exhibit 3)
UpDATBD RRap0NSE An updated response to this contention Item is contained in Commonwealth Edison's response to specific Interrogatory 4, Item Number seven (7) " steam Generator Bolting" of Intervonors' second set.
In addition, during a November 14, 1985 NRC Inspection Exit i
Briefins, NRC Inspector R. schuls stated that he had reviewed actions '
taken to correct that portion of this item dealing with steam Generator !
bolting, as originally documented in Inspection Report Nos.
50-456/82-05-01, 50-457/82-05-01. Based on this review, the Inspector i
indicated that corrective actions appeared to be acceptably implemented and that their completion should be sufficient to close this issue as it relates to steam Generator bolting. This review is to be documented in e forthcoming Inspection Report.
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90staunas Ifat 8,a -
- 8. Contrary to Criterion VI!!, " Identification and control of ILaterials Parts and Components," of 10 C.F.B. part 50, '
Appendix s, Cosmonwealth Edison Company has failed to ensure that measures are established for the identification and control of materials, parts, and components including partially fabricated assemblies in order to prevent the use of incorrect or defective material, parts or components.
B. "10,500 feet of General Electric "WLaBNB" switchboard wire was received at Braidwood. Some of this wire has been installed without appropriate qualification to IEEE 343-1974. (CAT Inspection Report 84-44/40, Exh. 10.)
UPDATED RESP 0NSE A walkdown inspection program for inspection of safety-related electrical equipment located in potentially harsh environment areas has been developed and is in final review. This program will identify as "WLEENE" SIS wire installed in electrical equipment located in the harsh environment areas of the plant. Any unquallflod applications of this wire will be replaced utilisins qualified sockbestos "Firewall" sis -
wire. This program is expected to be implemeted by December 1, 1985 with a completion date not later than January 31, 1984.
Additionally, an omendment to sargent A Lundy speelfication L-2790 Electrieel Installation, was issued on september 20, 1985. This amendment incorporates BCW 27578 (8/9/85) which was issued to luontify approved suppliers of sis wire for the Braidwood site.
Durins an inspection on June 24 through September 6,1985, NBC Inspector W. Kropp reviewed actions implemented to correct this item. He indleated that these actions appeared to be acceptably implemented and completion of these actions should resolve and close this issue. This 0487H/ November 21, 1985
CONTENTION ITEM 8.B item will remain open with the NRC pending verification of the implementation of the remaining corrective actions. This review is l
documented in Inspection Report Nos. 456/05-032 and 457/05-031 pages 5 and 6.
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0407H/Wovember 21, 1985
CONTENTION ITEM B.B ,
UPDATED REFEREllCES i i
i 1. Sargent & Lundy Amendment to Specification L-2790 issued 9/20/85.
- 2. NRC Inspection Report No. 456/05-032 457/85-031.
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CONTENTION ITEM 8.C
( 8. Contrary to criterion VIII, " Identification and control of '
Naterials, parts and Components," of 10 C.P.R. Part 50, l
Appendix 5. Cosmonwealth Edison company has failed to ensure !
that measures are established for the identification and l control of materials, parts and components including partially l fabricated assemblies in order to prevent the use of incorrect '
or defective material, parts or components.
C. phillips-Getschow hangers in lower cable spreading room did not utilise ASTN A307 fasteners per Sargent & Lundy standard. Also battery racks had bolting material that did not meet the requirements of AsTN A307 (CAT Inspection Report 84-44/40, Ruhlbit 10).
UPDATED Resp 0NSE The initial bolt sample which was tested consisted of bolts taken t from the contractor warehouse stocks. An additional sample population of '
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, unmarked bolts was taken from various field installations of the affected l l contractors' job scope. This additional bolt sample was subjected to the teste required by ASTN A-307 and all samples proved acceptable. Based on ;
the results of these sampling programs, it is expected that NCR L-692 I will be ready for closure, not later than December 15, 1985. ;
In addition, during an inspection on June 24 through September 6, !
1985, NRC Inspector W. Kropp reviewed actions implemented to correct this !
item. He indicated that these actions appeared to be acceptably [
implemented and completion of these actions should resolve and close this !
Issue. This item will remain open with the NRC pending a review of the final disposition of NCR 692. This review is documented in Inspection ;
Neport Nos. 456/85-032 and 457/05-031 pages 5 and 6.
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CONTENTION ITEN 8.C In addition, a new CECO NCR (not yet issued) is presently being written to track the issue of A307 bolts on vendor supplied equipment.
The concern as to whether this equipment was supplied by the vendor with A307 bolts arose at Ceco's Byron Station. Because the vendor supplied equipment at Braidwood, which is the subject of this NCR concern, is identical to the Byron equipment Ceco project Fleid Engineering currently intends to utilize the results of inspections ~to test the hardness of bolts on the vendor supplied equipment which are presently on-going at Byron to disposition and resolve this NCR.
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CONTENTION ITEN 8.C UPDATED REFERENCES
- 1. Systems Material Analysis Department Report on the Evaluation of carbon steel Hex Head Bolts for Braidwood Generating Station:
N-4752-85, November 11, 1985.
- 2. NRC Inspection Report 456/85-032; 457/85-031.
0488H/ November 22, 1985
CONTENTION ITEM 8-D
- 8. Contrary to Criterion VIII, " Identification and Control of '
Materials, parts and Components " of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures are established for the identification and control of materials, parts and components including partially fabricated assemblies in order to prevent the use of incorrect or defective material, parts or components.
D. Shoe covers were not worn by personnel entering the recirculation sump area during BWPT EF-11 and some debris was noted in the sump water during preoperational test.
(Inspection Report 85-08, Exhibit 23.)
UPDATED RESPONSE During an inspection from September 3 through November 1, 1985, NRC Inspector T. Tongue reviewed corrective actions being implemented in the area of plant and equipment cleanliness. Based on this review, the inspector indicated that this issue would remain open. This review is documented in Inspection Report 456/85-045 and 457/85-044..
'N 0489H/ November 22, 1985 l
CONTENTION ITEN 8.D i
UPDATED REFERENCES
- 1. NRC Inspection Report 50-456/85-045 and 457/85-044.
0489H/ November 22, 1985
QONTENTION ITEN 8cE
- 8. Contrary to Criterion VIII, " Identification and Control of Materials, Parts and Components," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures are established for the identification and conteci of materials, parts and components including partially fabricated assemblies in order to prevent the use of incorrect or defective material, parts or components.
E. Permanent spool pieces for Residual Heat Removal Suction Lines and Containment Spray Pump Suction Lines were found with inadequate or non-existent coverings for protection against damage or deterioration of these components. (Inspection Report 85-08 Exh. 23.)
UPDATED RESPONSE A partial update to this contention Item is contained in that part of Commonwealth Edison's response to Specific Interrogatory 6 of ;
i Intervenors' Second Set which provides a description of the " Mechanical I
. Equipment Disassembly and Inspection Program." Commonwealth Edison Project Construction Department (PCD) has also discussed the adequacy of using tape as a protective covering method with NRC inspector D. Williams. Based on commitments made at CECO's Byron Station to use metal, plastic, wood or other durable material for protective coverings, PCD is currently evaluating the adequacy of tape as a protective covering.
In addition, during an inspection on September 3, through l November 1, 1985, NRC Inspector T. Tongue reviewed actions being implemented in the area of plant and equipment cleanliness. Basei on this' review, the inspector indicated.that this issue would reraain open.
.This review is docuAented in Inspection Report 456/85-045 and 457/85-044, at pp. 3-4. .
0490H/ November 22, 1985
CONTENTION ITEN 8-N UPDATED REFERENCES
- 1. NRC Inspection Report Nos. 456/85-045 and 457/85-044.
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CONTENTION ITEN 8.F
- 8. Contrary to Criterion VIII, " Identification and Control of l
l Materials, Parts and Components," of 10 C.F.R. Part 50, ,
Appendix B, Commonwealth Edison Company has failed to ensure l that measures are established for the identification and control of materials, parts and components including partially fabricated assemblies in order to prevent the use'of incorrect or defective material, parts or components.
F. During tours of the 1A positive displacement charging pump room, the following was observed: empty cans in the room cooler, plastic sheeting strewn about the area, partially eaten food items, accumulation of flammable material and a layer of dust on all equipment in the room. (Inspection Report 85-08, l Exh. 23.) i UPDATED RESPONSE During an inspection on September 3, 1985 NRC Inspection T. Tongue reviewed actions being implemented in the area of plant and equipment cleanliness. Based on this review, the inspector indicated that this issue would remain open. This review is documented in Inspection Report 456/85-045 and 457/85-044.
0491H/ November 22, 1985
~ CONTENTION ITEN 8.F UPDATED REFERENCES
- 1. NRC Inspection Report 456/85-045; 457/85-044.
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CONTENTION ITEN 9.A
- 9. Contrary to Criterion II, " Control of Special Processes," of 10 C.F.R. Part.50, Appendix B, Comonwealth Edison Company has failed to ensure that measures be established to assure that
'special processes, including welding are controlled and accomplished in accordance with applicable codes, standards, specifications, criteria and other special requirements.
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A. 127 safety-related structural steel fillet welds were painted prior to acceptance of the work and the welds were subsequently visually inspected for acceptance, with 79 accepted , in the painted condition. In addition, visual weld inspections.were not . performed on safety-related full penetration welds completed under the jurisdiction of Structural Specifications I F/L-2735 - and F/L-2722 prior to May 1, 1984. The welds were '
accepted based on other methods of nondestructive examination, but were not accepted in accordance with the requirements of Section 9.15, Quality of Welds, Visual Inspection. (Inspection Report 84-21/20. Exh. 20.)
UPDATED RESPONSE G.K. Newberg NCR 213-993 relating to reduced size (length) welds has been reviewed by Sargent & Lundy e'ngineering. This review determined that the reduced length of the welds was acceptable "as is", provided that fit up gaps for. these - welds met AWS Dl.1 code requirements.
Reinspection of welds in the unpainted condition previously performed by PTL and documented in PTL Visual Inspection Report VW 709 R/I confirmed that the fit up gaps for welds covered under NCR 213-993 were acceptable per AWS Dl.1 requirements. Based on S&L's engineering review and the confirmation that acceptable fit up gaps exist as documented on PTL report VW 709 R/I, G. K. Newberg NCR 213-993 was closed July 24, 1985.
No further corrective action is required.
In addition, during an October 24, 1985 NRC Inspection Exit
-Briefing, NRC Inspector J.-Jacobson stated that he had reviewed actions taken to correct the issue of inspecting welds through paint. These actions were found to be acceptable and this issue would be closed. This closure review is to be documented in a forthcoming Inspection Report.
0492H/ November 22, 1985
CONTENTION ITEM 9.A corrective actions related to the issue of full penetration weld visual inspections are ongoing.
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CONTENTION ITEM 9.A UPDATED REFERENCES
- 1. G.K. Newberg Nonconformance Report 213-993 (closed).
- 2. Pittsburgh Testing Laboratory Visual Inspection Report W 709 R/I.
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0492H/ November 22, 1985
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- CONTENTION ITEM 9.C
- 9. Contrary to Criterion IX, Control of Special Processes, of 10 C.F.R Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures be established to assure that i special processes, including welding are controlled and l accomplished in accordance with applicable codes, standards, l specifications, criteria and other special requirements.
l C. Nine L. K. Comstock filler metal withdrawal authorization forms documented the release of E7018 weld rod for cable pan welds between May 25, 1982 and July 28, 1982. (Inspection Report 84-13, Exhibit 24.)
UPDATED RESPONSE L.K. Comstock has re-evaluated NCR 3275 and has issued NCR 3275, Rev. 1. Aside from correcting some typographical errors, Rev. 1 to NCR 3275 deletes the required review of all L.K. Comstock weld filler metal withdrawal forms (Form 57) that have been issued since the start of the project. As indicated in L.K. Comstock Memorandum No. 85-02-09-04, which
- is included with NCR 3275, Rev. 1, Form 57 review is not necessary because E-60 series and E-70 series electrodes are compatible and because the E-60 series electrode material test reports showed that the tensile strengths were greater than 70,000 PSI which is equal to the minimum tensile strength of E-70 series electrode. The CECO Project Construction Department has concurred with the revision to NCR 3275 to eliminate the Form 57 review and has transmitted the revised NCR to the Site Quality assurance Department for review and concurrence.
l-0495H/ November 22, 1985
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CONTENTION ITEN 9 C UPDATED REFERENCES
- 1. L.K. Comstock NCR 3275. Rev. 1, dated November 7, 1985.
I 0495H/ November 22, 1985
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CONTENTIO9 ITEM 9.D
- 9. Contrary to Criterion IK, " Control of Special Processes," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has !
failed to ensure that measures be established to assure that 1 special processes, including welding are controlled and i accomplished in accordance with. applicable codes, standards, j specifications, criteria and other special requirements. !
D Quality structural steel was not approved for use by the Architect-Engineer, Sargent & Lundy, but was released for use in installation by the structural steel contractor and documented as being used for cover plate welds. Furthermore, the welder documented as performing the welding was not qualified. In addition, RPS Division loop B, reactor coolant flow, completed socket weld joints, have no piping records identifying the welder or weld filler metal utilized.
(Inspection Report 84-17, Exh. 21.)
UPDATED RESPONSE An updated response to the part of this contention Item dealing with the release of an unapproved G. K. Newberg flux core welding procedure for use in cover plate welding is contained in that part of Commonwealth Edison's response to Specific Interrogatory 7 of Intervenors' Second Set, which provides a description of the "Newberg Welding Program" corrective action program referenced in the April 8, 1985 letter from David H. Smith to James G. Keppler.
l 0496H/ November 20, 19P5
CONTENTION ITEM 10.A
- 10. Contrary to Criterion I, " Inspection," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a program for inspection of activities affecting quality was established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for t
accomplishing the activity, i
o A. An inspection program was not developed to verify the proper installation, including bolting, of the main steam generators in either'Braidwood Unit 1 or 2. Although the manufacturer's procedure for setting major nuclear steam supply system (NSSS) components, including bolt installation, was available and suggested that the installation contractor provide a detailed
. setting procedure for the manufacturer's review, such a procedure was not developed. No records exist indicating that travelers, or process sheets, were used or reviewed by the quality control department to establish either surveillance or hold points. As of August 1982, installation inspections o.f the majority of mechanical safety-related equipment were either not conducted, were inadequate, were incomplete or were not
-documented. This violation was in part the basis for the imposition of the 2/2/83 civil penalty for "a breakdown of your Quality Assurance (QA) program." (Exhibit 3)
UPDATED RESPONS'E An updated response to this contention Item is contained in j Commonwealth Edison's response to Specific Interrogatory 4, Item Number seven (7) " Steam Generator Bolting" of Intervenors' Second Set.
4 In addition, during an October 17, 1985 NRC Inspection Exit Briefing and a November 14, 1985 NRC Inspection Exit Briefing, NRC Inspector R.
Schulz stated that he had reviewed actions taken to correct this item, as originally documented in Inspection Report Nos. 50-456/82-05-01 50-457/82-05-01. Based on this review, the Inspector indicated that corrective actions appeared to be acceptably implemented and that their completion should be sufficient to close this issue. This review is to be documented in a forthcoming Inspection Report.
0499H/ November 22, 1985
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CONTENTION ITEN 10.B
- 10. Contrary to criterion I, " Inspection," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a program for inspection of activities affecting quality was established and e'xecuted by or for the organization 4 performing the activity to verify conformance with the i documented instructions, procedures, and drawings for accomplishing the activity.
B. A special NRC QA inspection reported May 7, 1984 that deficiencies concerning piping material control resulted in the quality of some installed piping being indeterminate and resulted in some material being installed that did not meet design requirements. A documented inspection program had not been implemented to assure correct material installation for 2"-and-under safety-related piping prior to July 1983; therefore, inspection records verifying correct material installation prior to that date do not exist. A documented inspection program had not been implemented to assure correct material installation for safety-related piping over 2" prior
! to November 1982; therefore, inspection records verifying
, correct material installation' prior to that date do not exist.
4 During the March 7, 1984, enforcement conference Edison described a verification program which will include a 100%
inspection of all installed piping and associated records. The results of that program and the completion of any necessary
- corrective actions that might result are required to ensure
! that all installed piping material meets design requirements.
Since the NRC will need to evaluate the results of this
- verification effort in order to fully assess the significance of the programmatic deficiencies, enforcement action was not being taken on this violation at that time. Following the NRC'c review of Edison's efforts, it will determine the appropriate enforcement action. Until that time, this matter is being classified as Unresolved Items. This violation is extremely serious and has been classified as a potential severity level II depending upon the extent of deficient hardware identified in the on-going corrective action program.
(Exh. 6.)
UPDATED RESPONSE An updated response to this Contention Item is contained in Commonwealth Edi, son's prepared detailed report with respect to the "Naterial Traceability Verification" corrective action program identified in Specific Interrogatory 7 of Intervenors' Second Set. This report has l already been furnished to the Intervenors. The report is incorporated herein by reference as a part of this Contention Item update.
, 0500H/ November 22, 1985
l CONTENTION ITEN 10.C and 10.E l
- 10. Contrary to Criterion I, " Inspection," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a program for inspection of activities ;
affecting quality was established and executed by or for l the organization performing the activitity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
C. Applicant's QA inspectors failed to identify areas Where Phillips-Getschow seismic category I and other pipe supports / restraints have not been constructed in accordance with design requirements. (CAT Inspection Report 84-44/40, Exh. 10.)
E. Program for inspection of activities affecting quality was not effectively implemented in that weld sizes in structural pipe support / restraints were not identified to l be proper weld configurations. (CAT Inspection Report 84-44/40, Exh. 10)
UPDATED RESPONSE An updated response to this Contention Item is contained in Connonwealth Edison's response to Specific Interrogatory 4. -Item Number three (3) " Pipe Support Installation and Welding" of Intervenors' Second Set.
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l 050lH/ November 20, 1985 I
CONTENTION ITEM 10.D
- 10. Contrary to Criterion X, " Inspection", of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a program for inspection of activities affecting quality was established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for 1
accomplishing the activity.
D. Applicant failed to provide an adequate inspection program in that electrical separation criteria were not sufflent to identity installations of raceway and cables by Comstock Report 84-44/40 Exh. 10.)
RESPONSE
An update to this Ccntention Item is contained in that part of Commonwealth Edison's response to Specific Interrogatory 6 of Intervenors' Second Set which provides a description of the " Cable Tray Separation Walkdown" currently being performed.
The revisions to L.K. Comstock's procedu;es regarding the Installation of and inspection of safety related cable trays are still in progress.
1 0548H/ November 22, 1985
m CONTENTION ITEN 10 F
- 10. Contrary to Criterion I, " Inspection" of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that.a program for inspection of activities affecting quality was established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
F. Electrical contractor, Comstock, inspected and accepted a jun-tion box which was later determined to have deficiencies in the location of the anchors used for mounting of the junction .
, box. Anchors were accepted even though they were 3" from the required location specified by Sargent & Lundy drawing 20E-1-3571.
4 RESPONSE.
Commonwealth Edison (CECO) Nonconformance Report (NCR) No. 4139 has been evaluated by Sargent & Lundy and has been dispositioned acceptable "as is" by S&L. The NCR is presently at L.K. Comstock for final review and close out.
i In addition to the resolution of NCR po. 4139, L.K. Comstock issued i 1
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NCR No. 4513 to disposition the fact that the original junction box equipment inspector failed to perfona a test torque on the cap screws on the junction box at issue and to address the completed reinspection of other safety related junction boxes inspected by this particular inspector. In accordance with NCR 4513, the cap screws will be torque tested. The CECO Project Construction Department has reviewed NCR 4513 and found these corrective actions adequate. NCR 4513 is currently at Ceco Quality Assurance for concurrence prior to being returned to L.K.
Comstock for final close-out.
4 During an inspection on June 24 through September 6, 1985, NRC
- Inspector W. Kropp reviewed actions taken to correct this item. These
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0502H/ November 22, 1985 l
CONTENTION ITEN 10 F actions were found to be acceptable and this item was closed. This review is documented in Inspection Report No. 456/85-032; 457/85-031, page 7.
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CONTENTION ITEM 10 F 4
UPDATED REFERENCES
- 1. L.K. Comstock NCR 4139, as dispositioned, s
l 2. NRC Inspection Report No. 456/85-032; 457/85-031.
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- 3. L.K. Comstock NCR 4513.
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. - . . _ . _ - - - - . . - _ . . _ . .- -.-.. - -._ . . _ _=__- _.._ ._. - -- - _ _ - - . . - _ . - - - _
_ _ - - -__ _ _ _._. _.m.-_ _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _. __ _. _ .__ _. .
CONTENTION ITEN 11.C
- 11. Contrary to criterion XV, " Nonconforming Materials, Parts or Components," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to control materials, parts, or components which do
!- not conform to requirements in order to prevent their inadvertent use or installation.
i C. 337,500 feet of safety-related pipe was received in 1977 and rejected on April 9, 1979 due to rust, scale, and failure to cap pipe ends. Some of pipe was installed in plant. In i addition, the rejected pipe was not properly dispositioned in that only 206,744 feet of pipe was chemically cleaned.
(Inspection Report 24-17, Exh. 21.)
i t UPDATED RESPONSE
, With respect to an updated response to this Contention Item, Commonwealth Edison is preparing a detailed report which will provide i
updated information. That report will issue in the near future and will be furnished as an updated response to this Contention Item.
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0505H/ November 20, 1985
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. _ - _ _ . . . _ - - , _ . -.-m. _. . -___ . _ _ _ _ _ _ . _ _ _ _ _ . , ., .- - - . _ _ _ . , _- - - _ - - - _ - - - - ,
CONTENTION ITEM 110D
- 11. Contrary to Criterion IV, " Nonconforming Materials, Parts or Components," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to ensure that measures were established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertant use or i installation.
D. Comstock weld inspectors allowed craft personnel to repair / work weld defects identified during final QC inspections.
(Inspection Report 84-07. Exh. 18.)
UPDATED RESPONSE
~ During an inspection on June 24 through September 6, 1985, NRC l Inspector W. Kropp reviewed actions taken to correct this item. These i 1
. actions were found to be acceptable and this item was closed. This l
review is documented in Inspection Report Nos. 456/85-032 and 457/85-031 page 6.
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0506H/ November 20, 1985
'CGusmaaION ITgN 12.5-1~
- 12. Contrary to Criterion IVI, " Corrective Action," of 10 C.F.R. Part 50 Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. And in the case of significant conditions adverse to quality, '
Applicant failed to ensure that the cause of the condition is determined and corrective action taken to preclude repetition.
1 B. A special NRC QA inspection reported May 7, 1984 that:
- 1/2" S/80, SA-312, Type 304, ASNE Boiler and Pressure Vessel Code,Section III, Class 1, NB pipe heat number 745107 were discovered in Section III installations without material test reports or records of receiving and receipt inspections by either Commonwealth Edison Company or Phillips, Getschow Co.
as identified by Phillips, Getschow Co. on September 17, 1982, on Nonconformance Report No. 789. The disposition of the Nonconformance Report resulted in accepting the pipe, ,
after only obtaining material test reports, without examining i the pipe, initiating and maintaining receipt inspection records, or determining the total quality of the pipe in storage and installed.
UPDATgD Rg8PONSg Phillips, Getschow Company Nonconformance Report 4884 which was referenced in the response to contention Item 12.B.1 has been evaluated and dispositioned by Phillips, Getschow Company Engineering. The evaluation and disposition for this nonconformance report addresses:
(1) Receipt inspection of 1/2 inch diameter schedule 80 and schedule 160 pipe with heat number 745107; i (2) Quantities of pipe installed and pipe issued; (3) Determination of whether schedule 80 or schedule 160 pipe was installed in field installations; (4) Evaluation by Phillips, Getschow Co. Engineering of schedule of pipe installed for compliance to design requirements specified by Sargent and Lundy.
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0508H/ November 22, 1985
CONTENTION ITEN 12.5 1 Based on the above evaluations Nonconformance Report 4884 has been dispositioned by Phillips, Getschow Co. to accept the installed 1/2 inch pipe with heat number 745107 "as is".
Phillips, Getschow NCR 4884 is currently under review by Commonwealth Edison Company Project Construction and Quality Assurance Departments.
0508H/ November 22, 1985
CONTENTION ITEN 120B,1 UPDATED REFERENCES
- 1. PGCO NCR 4484, dated June 18, 1985 with Final Disposition, dated 11/11/85.
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l 0508H/ November 22, 1985 1
CONTgNTION ITEN 120C
- 12. Contrary to Criterion KVI, " Corrective Action," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to assure that conditions ,
adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. And in the case of significant conditions adverse to quality, Applicant failed to ensure that the cause of the condition is determined and corrective action taken to preclude repetition.
C. The Applicant's site QA organization inappropriately closed Nonconformance Report No. 600 and as a result did not assure that conditions adverse to quality were corrected. The inspector subsequently identified two supports detailed in Report 600 and one support not detailed which were not procured '
and examined in accordance with ASKE Section III, Section NF.
(Inspection Report 85-15/16, Exh. 17.)
UPDATED RESPONSE .
Following the August 27, 1985 response to contention item 12C, an NRC inspection was conducted on September 6, 1985 which reviewed preliminary corrective actions implemented to close this item. The NRC determined that the scope of corrective actions should resolve this item and the corrective actions started were acceptably implemented. These l Inspection results were documented in NRC Inspection Report Nos.
456/85-032 and 457/85-031 (page 5).
f Nearly all the corrective actions needed to resolve the concerns associated with the inappropriate closure of Ceco Nonconformance Report (NCR) 600 and the procurement and inspection requirements involving ASME Section NF supports detailed on Ceco NCR 744 are complete. Corrective actions which are still incomplete, include installation of all the supports identified on NCR 600, engineering evaluation of materials utilized in the supports covered by NCR 744, and site Q.A. verification that these actions were properly performed. The progress on all of the corrective actions are summarized in the paragraphs below:
0511H/ November 22, 1985
CONTENTION ITEM 12.C Ceco site Q.A. performed an independent review of 10 Ceco NCR's closed in the same time period as NCR 600 to determine if the inappropriate closure was an isolated case. This was a detailed review which included verification that the specified corrective actions were complete and which examined the effectiveness of site Q.A.'s review of the NCR for closure. The review also addressed proper identification, documentation, and disposition on the NCR. As a result of this review, four of the 10 NCR's were found completely acceptable while the remaining 6 had minor document discrepancies which were elarified and resolved.
None of these discrepancies had any effect on the disposition, corrective actions, or closure of the nonconformance report. These results substantiate that the original inappropriate closure of NCR 600 was in fact an isolated case.
A special training session was presented to all site Q A. personnel who may be involved with NCR verifications and closure. This training session highlighted the circumstances of NCR 600 and proper closure of nonconformance reports. The training session also covered, the minor documentation discrepancies noted in the ten NCR reviews. The session stressed the importance of not closing NCR's until corrective actions are completed and the effectiveness of programmatic controls verified. The training was conducted on June 27, 1985 with make-up sessions on June 28, 1985 and September 5, 1985.
0511H/ November 22, 1985
CONTENTION ITEN 12.C Initially the scope of NCR 600 encompassed 20 supports; however, due to design changes six have been deleted. A final check to determine the latest drawing revision for each of.the remaining supports is underway by Project Engineering, while Phillips, Getschow completes the installation of the last three supports. When these activities are finished, site Q.A. will verify proper installation of each support.
In order to assure that NCR 600 support deficiencies were not prevalent with other ASME supports,' Phillips, Getschow was requested to perform a special audit of all ASME supports not previously covered by NCR 600. The audit resulted in the issuance of six PGCo NCR's which are identified in Ceco NCR 744.
Based on the material utilization deficiencies which were identified by the PGCo special audit, Phillips, Getschow performed an engineering review of component support ASME auxiliary steel. The review determined
'what materials were installed and evaluated the ASNE materials for compliance to ASME Section NF code requirements. Phillips, Getschow has completed this review and has provided the results to Ceco engineering for additional evaluation. When the engineering evaluation is completed and the remaining PGCo NCR's are closed, the corrective actions for Ceco NCR 744 will be finished. Site Q.A. will verify that the corrective measures are complete and effective prior to the closure of NCR 744.
0511H/ November 22, 1985
CONTENTION ITEN 12 C UPDATED REFERENCES
- 1. .NRC Inspection Report Nos. 456/85-032 and 457/85-031.
0511H/ November 22, 1985
CONTENTION ITEM 12.C l
UPDATED NAMES AND REFERENCES Eric Stockhan Commonwealth Edison Company
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l CSNTENTIOJ ITEM 13.B l
- .13. Contrary to Criterion IVII, " Quality Assurance Records," of 10 l C.F.R. Part 50, Appendix B, Commonwealth Edison Company has- !
failed to ensure that sufficient records were maintained to !
furnished evidence of activities affecting quality. The l records are to include at least the following: results of reviews, inspections, tests, audits, monitoring of work j performance, and material analyses.' Applicant has failed to ,
make such records identifiable and retrievable.
B. Sargent & Lundy Engineers calculations which provided the original justification for the factor design methodology and magnitude were not retrievable. (Inspection Report 84-43/39,
. Exh. 19.)
UPDATED RESPONSE During an October 24, 1985 NRC Inspection Exit Belefing, NRC Inspector J. Jacobson stated that Inspector J. Nuffett had reviewed
. actions taken to correct.this item, found them acceptable and would close
-this item. This closure review will be documented in a forthcoming Inspection Report.
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4 4 0519H/ November 20, 1985
CONTENTION ITEN 14.B.1
- 14. Contrary to Celterion IVIII, " Audits," of 10 C.F.R. Part 50,
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Appendix B, Commonwealth Edison Company has failed to ensure
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that a comprehensive system of planned and periodic audits is '
carried _out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The Applicant also failed to ensure follow-up action, including reaudit of deficient areas.
B. A special NRC QA inspection reported May 7, 1984 that:
- Mechanical contractor Phillips, Getschow Co. has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a period (sic) basis to determine the effectiveness of the program in accordance with the Phillips, Getschow QA Manual.
UPDATED RESPONSE An NRC inspection was performed from. June 24 through September 6, 1985 to review actions implemented to correct this item. Corrective Actions taken included the establishment by Phillips, Getschow (PGCo) of an audit schedule matrix to assure that all PGCo implementing procedures would be audited. Although the actions appeared adequately implemented, NRC Inspector, R. Schulz, determined that an evaluation of PGCo's failure to audit implementing procedure < ,.
- lor to August 21, 1983 was necessary.
The results of the NRC in'pe 'eser ere documented in NRC Inspection Reports Nos. 456/85-032 and 457/85-031 (page 8).
The process usc.' to evaluate PGCo audit coverage of procedures involved PGCo and Commonwealth Edison (CECO) Quality Assurance and Project Construction Departments. A four step approach was utilized.
First, PGCo Quality Assurance compiled a list of all PGCo i
implementing procedures in effect prior to August, 1983. An extensive 0521H/ November 22, 1985
CONTENTION ITEM 14.B.1 review of each PGCo site and corporate audit performed prior to August i
21, 1983 was then completed to determine the applicable Quality Assurance Manual Section, Procedure, or subject matter examined by the audit.
Second, in conjunction with the PGCo review, CECO Site Quality Assurance performed a detailed study of CECO Site QA audits of PGCo.
CECO audits generally focus on the programmatic implementation of the Ceco and contractor Quality Assurance Program; however, adherence to specific contractor procedures is also investigated. A total of 46 CECO Quality Assurance audits were conducted during the period prior to August 21, 1983. Each of these 46 audits were specifically checked to ascertain if procedure compliance and implementation was verified for each particular PGCo procedure. CECO audits which covered a PGCo procedure, were then used to supplement those time periods.vhich were not specifically covered by PGCo audits.
Third, for those time periods in which a particular PGCo procedure had not been covered by either a PGCo or CECO audit, PGCo and the CECO Project Construction Department determined if on-going oversight work covered the scope of these activities on-site and have provided verification of compliance to the particular aspects of the PGCo Quality Assurance Program not audited.
Finally, for PGCo procedures not covered in certain time periods in accordance with one of the above three methods, an impact assessment was jointly performed by PGCo and CECO to determine if the absence of an 0521H/ November 22, 1985
CONTENTIO7 ITEM 14 B.1 audit for a procedure had a detrimental effect on the work performed.
Each of these analyses demonstrated that PGCo's failure to audit certain implementing procedures during certain time periods prior to August 21, 1983 had no adverse impact on the quality of work or the effectiveness of j l
the PGCo quality assurance program.
The results of this four-step evaluation are documented on a matrix which indicates that from 1980 to August 1983, nearly every PGCo procedure was examined by the PGCo or CECO audit program. In addition. l l
for those few time periods in which a particular PGCo procedure was not audited, sufficient evidence exists to conclude that no adverse quality impact resulted from the coverage of the PGCo Quality Assurance Program in a programmatic rather than a procedure-oriented manner.
The results of this evaluation were presented to the NRC on November 21, 1985 and CECO is currently expecting an NRC decision on item closure in the near future.
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0521H/ November 22, 1985
CONTENTION ITEN 14.B.1 UPDATED REFERENCES
- 1. PGCo Procedure / Audit Matrix
- 2. Letter from S. Forbes to D. Boone, dated November 20, 1985.
- 3. NRC Inspection Report 456/85-032; 457/85-031.
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0521H/ November 22, 1985
!' CONTENTION O ITEN 14 D.1 U_PDATED NAMES AND ADDRESSES l
E. Stockhan Commonwealth Edison Company D. Boone Commonwealth Edison Company l
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CONTENTION ITEN 14.B.2
- 14. Contrary to criterion IVIII, Audits of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a comprehensive system of planned and periodic audits is carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The Applicant also failed to ensure followup action including reaudit of deficient areas.
B. A special NRC QA inspection reported May 7, 1984 that:
Electrical contractor L.K. Comstock Co./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 ,
l 4.14.1, nor did they verify compliance with all aspects of the l Quality Assurance Program.
UPDATED RESPONSE The updated response to this Contention Item includer several corrections to the original response provided to Interrogatory 58 and 59 as well as other current information.
The fourth paragraph of the original response should be revised to read as follows:
L.K. Comstock Corporate Quality Assurance completed audits of the six QA Manual Sections. Four of the six sections were covered specifically by the audits. Section 1.0.0 (Policy Statement) and 1.0.1 (QA and QC Program) are generic program sections identifying commitments which are implemented throughout other procedures in the L.K. Comstock Program. These sec6.lons were covered by auditing the portions of the Comstock Program which execute the commitments found within those sections.
The fifth paragraph of the original response should be revised to read as follows:
0522H/ November 22, 1985
CONTgNTION ITEM 14.B-2 Comstock also completed audits of all six work procedures identified by the NRC as unaudited by December 1984. Specifically, Procedures 4.3.16 and 4.3.13 were audited by L.K. Comstock Corporate prior to the week of January 9, 1984 and Procedure 4.1.2, which is normally audited by Corporate auditors, was audited in June 1984. In addition, some of the referenced procedures would not have been audited at the time of the NRC inspection even under a 100%
procedure audit schedule. Specifically, Procedures 4.3.3.1 and 4.10.4 were originally issued in December 1983 and were not required
, to be audited until December 1984. Audits of these procedures were completed by December 1984. Procedure 4.3.23 was not audited at the time of the NRC inspection because it is an infrequently performed operation that requires a 100% Quality control Inspection for safety related items. However, an audit of this procedure was completed in December 1984.
The first sentence of the sixth paragraph of the original response should be revised to read as follows:
"To ensure continued audit schedule compliance, L.K. Comstock placed a certified lead auditor on site fulltime in September 1983 to fill i l
a vacant QA Engineer position. A second QA Engineer was placed on site fulltime in November 1983 and was subsequently certified to perform suditing functions.
I The following updated information is available for the contention Item.
0522H/ November 22, 1985
CONTENTION ITEN 14.B.2 In August 1985, Commonwealth Edison (Ceco) Site Quality Assurance !
l instituted a documented review of the L.K. Comstock audit schedule and I
. audit reports. The review of the LKC audit schedule examines, on an on-going basis, any changes which occur in the L.K. Comstock audit schedule while also verifying that all applicable procedures are being addressed. LKC audits are also reviewed to verify that the areas scheduled to be audited have been performed in accordance with the approved L.K. Comstock audit schedule. The review documents Q.A.'s concurrence or comments relative to these documents. Comments generated as a result of the Ceco Site Quality Assurance reviews have required a response from L.K. Comstock and several adjustments by L.K. Comstock in order to maintain audit schedule commitments to address all aspects cf its Quality Assurance Program. As a result of this activity, the four reviews performed to date by site Quality Assurance have verified that all aspects of the L.K. Comstock Quality Assurance Program are currently being addressed on the annual Comstock audit achedule and that the schedule is being met. Site Quality assurance surveillance No. 4852 issued on October 6, 1985 also verified the adequacy of L.K. Comstock corrective actions on this item.
In addition, the NRC performed a follow-up inspection on this item
. in October 1985. During the Inspection Exit Briefing, NRC Inspector P.
Pelke indicted that he had found the corrective actions taken by L.K.
Comstock to resolve this item to be acceptable and that the item would be closed. The closure will be documented in a forthcoming Inspection Report.
0522H/ November 22, 1985
CONTENTION ITEN 14 B.2 UPDATED REFERENCES
- 1. Connonwealth Edison Site Quality Assurance Document Review Sheets, dated August 19, 1985; September 9, 1985; September 26, 1985 and November 11, 1985.
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0522H/ November 22, 1985 l.
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CONTENTION ITEM 140B03 i
- 14. Contrary to Criterion IVIII, " Audits," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure j that a comprehensive system of planned and periodic audits is carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The Applicant has failed to ensure followup action, including reaudit of deficient areas.
B. A special NRC QA inspection reported May 7, 1984 that:
- HVAC contractor 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 UPDATED RESPONSE An NRC inspection was performed from June 24 through September 6, 1985 to review actions implemented to correct this item. Corrective actions taken included Pullman Sheet Metal (PSM) performing audits in August and December, 1983 which covered all sections of the PSM Quality assurance Program and assessed compliance with all PSM implementing procedures; and PSM implementing an audit schedule matrix listing Appendix B criteria, QA Manual sections, and procedures to be covered for future audits. Although the actions appeared adequately implemented, NRC Inspector, R. Schulz, determined that an evaluation of PSM's failure to audit the five implementing procedures prior to the implementation of this corrective action was necessary. The results of the NRC inspection are documented in NRC Inspection Report Nos. 456/85-032 and 456/85-031 (page 8).
0523H/ November 22, 1985 1
CONTgNTION ITEM 14.5-3 In order to perform the evaluation required by the NRC, CECO Site l l
Quality Assurance reviewed PSM's and Ceco's Quality Assurance Programs for the years 1980'through 1983. Specifically, the review entailed an assessment as to whether the PSM and CECO Quality Assurance Programs covered the five procedures identified by the NRC as unaudited. Based on the results of this review, it was concluded that three of the PSM procedures (Design Control (B3.1.F), General Installation (B.9.4.F) and Visual Weld Inspection (B.10.2.F) have been examined extensively through either PSM or Ceco audits or Site QA surveillances. For the remaining two procedures which were found to have no Quality Assurance Pr'ogram coverage for certain periods from 1980 through 1983, sufficient evidence exists to conclude that, due to various on-going oversight work covering the scope of these activities on-site, no adverse quality impact resulted I from the coverage of the PSM Quality Assurance Program in a programatic rather than a procedure-oriented basis. This review is documented on Ceco QA Surveillance No. 5144 dated November 4, 1985.
s The results of this evaluation were presented to the NRC on November 21, 1985 and Ceco is currently expecting an NRC decision on item closure in the near future.
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0523H/ November 22, 1985
CONTENTION ITEM 14.B.3 UPDATED REFERENCES
- 1. Commonwealth Edison QA Surveillance No. 5144
- 2. NRC Inspection Report 456/85-032; 457/85-031.
0523H/ November 22, 1985
CONTENTION ITEN 14.B.3 UPDATED NAMES AND ADDRESSES E. Stockhan Coaumonwealth Edison Company 0523H/ November 22, 1985
Specific Interroaatory 4 Please describe in detail the corrective actions or programs with respect to the following subjects which relate, as described at page 4 of the introduction to Applicant's Reponse to Intervenors' Interrogatory 58, to the identified items or subparts of the amended quality assurance contention.
- 1) Mechanical Equipment Installation (1.A 6.A. 13.A)
- 2) HVAC Welding (3.A.1, 3.A.2, 3.A.3)
- 3) Pipe Support Installation and Welding (10.C, 10.E)
- 4) Nuclear coating Applications (5.8)
- 5) Small Bore Pipe Wall Thickness (6.F. 11.C)
- 6) Structural Steel Installation and Welding (9.A 9.D. 9.E)
- 7) Steam Generator Bolting (10.A, 11.A)
- 8) Pipe Heat Number Reverification (MTV) (10.8)
As to each please detail the purpose and objectives, organisation, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effectiveness. Please identify any documents which reflect these answers, including program descriptions, procedures, organizational charts, data, observation, inspection or evaluation forms or documents, and interim or final reports.
RESPONSg As a part of the response to Specific Interrogatory 58 and 59, a reference was made to the site Quality Assurance organization's Special Project Group. This group was established to provide for specific Quality Assurance monitoring of selected on-site activities such as non-conformance reports, corrective actions for NRC items of noncompliance, and 10CFR50.55(e) actions. This group's attention is focused on work activities that deal with past installations that had deficiencies, such as corrective actions described in site generated non-conformance reports. The group checks via audits and surveillances that requirements 0535H/ November 22, 1985
Specific Interrogatory 4 related to these activities, as detailed in governing procedure documents, are being implemented and completed in an acceptable manner.
The sicht items listed on page 4 of the response are examples of activities that are monitored.
i It should be emphasized that work activities subjected to special monitoring by this group are not necessarily large scale corrective action programs as may have been implied in the original response.
However, each of these work activities are undergoing or have undergone rework or reanalysis and the special Projects Croup is responsible for assuring that such rework or reanalysis is properly implemented.
Generally this group does not have responsibility for new work being performed in these areas. They are fully dedicated to the rework activities.
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0535H/ November 22, 1985
SPECIFIC INTERROCATORY 4
" MECHANICAL EQUIPMENT INSTALLATION" The corrective action program undertaken in response to the issues identified in Contention Items 1.A. 6.A and 13.A is described in the portion of Applicant's response to Specific Interrogatory 7 of Intervenors' second set captioned " Reinspection of Safety Related Mechanical Equipment".
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0447H/ November 20, 1985
SPECIFIC INTERROCATORY 4 "HVAC Welding" The corrective actions taken with respect to the issues identified in Contention Items 3.A.1, 3.A.2 and 3.A.3 are explained in applicant's response to Specific Interrogatory 58 of Intervonors' first set, conten-tion Items 3.A.1, 3.A.2 and 3.A.3. Further details are provided in applicant's response to Specific Interrogatory 3 of Intervenors' second set.
0544H/ November 22, 1985
SPECIFIC INTERROCATORY 4
" PIPE SUPPORT INSTALLATION AND WELDINC" Corrective Actions taken in response to this item were described in Applicant's response to Specific Interrogatory 58 of Intervenors' first set, Contention Item 10.C and 10.E. Further details are provided in this response.
The previous response stated that Ceco Nonconformance Report No. 705 was issued to track the investigation and evaluation of skewed tee fillet welds on a generic basis. This NCR was issued on January 17, 1985.
NCR 705 identified that Phillips, Getschcw Co. (PGCo) did not invoke the appropriate criteria for establishing minir.um weld size for skewed tee joints on certain pipe supports / restraints. In order to provide more detailed guidance to PCCo for future implementation of this criteria, Sargent & Lundy (S&L) issued a revision to Drawing M-999.
In order to ascertain if there was any detrimental effect on the affected pipe supports / restraints as a result of the deficiency, S&L reviewed sixty (60) pipe supports / restraints involving skewed connections. These 60 supports were chosen on the basis of engineering judgment and represented a cross section of pipe support / restraint types, e.g. knee braces, cantilevers, etc., and various piping subsystems. The sample was conservatively chosen by not including skewed connections where the skew angle is between 60' and 90*. In such cases, weld sizes would be greater than assumed in the original design. As a result of the 0445H/ November 22, 1985
review..S&L concluded that all sampled supports / restraints except for two (2) cantilever type supports, were adequate from both design significance and engineering significance considerations. The two cant 11evers were considered indeterminate due to uncertainties involved regarding the effective throat achieved in fillet weld- with such small (or large) skewed angles (less than 30* and gree e than 135*). In order to determine the effective throat to be used in the assessment of these two supports, S&L requested PGCo to perform a supplemental weld qualification for a specified joint detail and to determine the effective throats of the resulting welds.
The results of the supplemental weld qualification were reviewed by s&L. Using the effective throats obtained in these qualifications, S&L verified the design adequacy of pipe supports / restraints having skewed connections. Subsequently, Ceco NCR 705 was dispositioned to accept the past work in this area.
Completion of the evaluation of skewed tee fillet welds, the resolution of the individual deficiencies on the identified pipe l
l supports / restraints described in Applicant's response to Specific Interrogatory 58 of Intervenors' first set, contention Items 10.C and 10.R. and the actions taken to improve the effectiveness of first level quality control personnel described in Applicant's response to Specific Interrogatory 2 of Intervenors' second set, Contention Item 1.D.1. Will assure the adequacy of all safety related pipe supports / restraints at Braidwood.
0445H/ November 22, 1985
REFERENCES
- 1. NRC Inspection Report 50-456/84-44; 50-457/84-40 (pages A0002984-A0003121).
- 2. C. E. Norelius letter to Cordell Reed dated Apell 11, 1985 transmitting notice of violation (pages A0003122-A0003126).
- 3. D. H.' Smith letter to J. G. Keppler dated April 25, 1985 (pages A0001665-1667).
- 4. D. L. Farrar letter to J. C. Keppler dated May 16, 1985 (pages A003127-A0003144).
- 5. Commonwealth Edison NCR 705 (pages 50004972-5012).
- 6. Licensing File on Item 84-44-05, Cont. 10.C (pages A0008621-A0008654).
0445H/ November 22, 1985
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6 044SN/ November 22, 1985 i
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SPSCIFIC INTERROCATORY 4 "NUCLgAR C0ATING APPLICATION 8" This response supplements the information regarding corrective actions undertaken in connection with this issue that was provided in Applicant's response to Specific Interrogatory 53 of Intervenors' first set, contention Item 5.3.
Nidway Industrial Contractors, Inc. NCR Nos. 23, 24, 25 and 26 were generated to document the nonconfoming condition identified in Inspection Report 85-15. Midway's review as part of the preparation of these NCR's identified all areas where the two-part coating system was applied over a power-tooled surface and determined that there were no wide spread implications of this nonconfomance. In addition, Nidway's review showed that this repair method had not been used since 1979.
ANSI N101.2 " protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities", requires quellf1 cation of coatings to Design Basis Accident (DgA) conditions. ANSI N101.4, " quality Assurance for Protective Coatings Applied to Nuclear Facilities", provides a cessen basis for the quality assurance of protective coatings. ANSI N101.4 recognises the impracklesbility of imposing all the requirements of this standard and allows deviations. ANSI N101.4, Section 1.2.4, states "Because of the impracticab(11ky of imposing all the requirements of this standard on certain specific items (requiring only a small quantity of coating material), the owner, consistent with his formal quality Assurance Program, may accept affidavits of certification attesting to the quality of a shop or flead coating." This allowance is based on small quantitles of coating materlat and assurance of acceptable work 1
0530N/ November 22, 1985
I I
SPECIFIC INTERROCATORY 4
" NUCLEAR COATINC APPLICATIONS" quality. The NRC Inspection Report acknowledges deviations from qualified coatings provided it is documented in a coatings exception list.
Commonwealth Edison Company has taken the following corrective action. The Midway Industrial contractors. Inc. Procedure QCP-3A dated March 3, 1985, entitled " Procedure for Repair of Carbo-Zinc 11 and Carbo-Zinc 11/Phenoline 305 Finish" has been revised to specify a coating system qualified to ANSI N101.2 to prevent recurrence. Secondly, CBCo engineers in the system Material Analysis Department performed a field documentation review of Midway Industrial Contractors QC documents to determine the extent and location of the unqualified coatings during the month of October 1945. This review determined the amount of area affected to be 127 square feet per unit, out of approximately 100,000 square feet of coated containment liner. Finally, a coating exception list has been initiated by Ceco. The areas of unqualified coatings associated with this noncompliance identified during the field documentation review are being documented on this list. As a result, Midway NCRs 23 and 24 were closed on September 10 and 20, 1985, respectively, and Midway NCRs 25 and 26 were closed on october 28, 1985.
The NRC has accepted this corrective action, as stated in Inspection Report 85-15.
2 0530N/ November 22, 1985
F SPECIFIC INTERROCATORY 4 j " NUCLEAR COATING APPLICATION 3" l
UPDATED REFERENCES I
I
- 1. Nidway Industrial NCR's Nos. 23, 24, 25, 26 (closed).
- 2. Internal S&L Nemorandum from T. Rudaitis to L.V. Jacques, dated October 24, 1985, regarding " Unqualified coating surface Area Inventory".
1 0530H/ November 22, 1985
SPECIFIC INTERROCATORY 4 "SMALL BORE PIPE WALL THICKNESS" commonwealth Edison was incorrect in referencing Contention Item 6.F in relation to the subject of "Small Bore Pipe Wall Thickness" on page 4 of its response *to specific Interrogatory 58 of Intervonors' first set.
Item 6.F was not an appropriate reference, because it does not apply to small Bore piping but to an isolated nonconformance on one section of a Large Bore pipe. The corrective action taken in response to Item 6.F was fully explained in the response to Interrogatory Number 58 and has no relevance to Contention Item 11.C. The " Corroded Pipe" corrective action program referenced in the Apr11 4, 1985 letter from David H. Smith to James G. Keppler identified in subpart B of specific Interrogatory 7 of Intervenors' second set relates to contention Item 11.C. A final report regarding that corrective action program will be issued in the near future and will be provided to Intervonors.
1 0449H/ November 20, 1985
SPECIFIC INTERROCATORY 4
' STRUCTURAL STEEL INSTALLATION AND WELDIH_G2 The corrective actions taken in response to the issues identified in Contention Items 9.A, 9.D and 9.E were explained in Applicant's response to Specific Interrogatory 58 of Intervenors' first set, Contention Items 9.A. 9.D and 9.E. Further details regarding Contention Item 9.A are provided in Applicant's response to Specific Interrogatory 3 of Intervonors' second set. In addition, the "Newberg Welding program" corrective action program described in Applicant's response to Specific Interrogatory 7 of Intervonors' second set is relevant to Contention Item 9.D.
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0448H/ November 20, 1985
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i SPECIFIC INTERROGATORY 4
" STEAM GENERATOR BOLTING" The installation and installation inspection of steam generator bolts have been addressed in the Ceco corrective action program
" Reinspection of Safety Related Mechanical Equipment", described in response to Specific Interrogatory 7 of Intervenor's Second Set, because installation of steam generator bolts is a subset of mechanical equipment
! installation. In addition to this overall corrective action program, Ceco has implemented certain corrective actions specifically addressing
) the steam generator bolting issue. These corrective actions are I
i described in the following response. Additional details have been l provided in Applicant's response to Specific Interrogatory 58 of j Intervonor's First Set, Contention Items 1.A, 6.A 8.A 10.A. 11.A. 12.A and 13.A.
The first shipment of steam generator bolts (cap screws) was '
received at Braidwood on March 10, 1978. These cap screws were supplied l by Telodyne Brown as part of the NSSS support package. Byron also e
received the same type of cap screws from Telodyne Brown, which was the cosmon supplier of that portion of the NSSS support package for both sites. Between June 24, 1978 and June 14, 1979, a number of these cap screws were shipped between Byron and Braidwood, as current construction needs dictated.
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0443H/Novemoer 22, 1985 i
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At Byron some problems were encountered with the installation of the cap screws. As a result a field change request (FCR 591) was initiated at Byron on November 13, 1978 to resolve those installation difficulties by allowing shortening of the cap screws. To take account of the problem I
- l encountered at Byron, the Sargent & Lundy structural drawing that specifies these cap screws at Braidwood (Rev. K of Sill 2) was modified to incorporate FCR 591, allowing shortening of the cap screws. as necessary, to facilitate installation.
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Phillips, Getschow Co. Quality Control personnel inspected all the cap screws in stock at Braidwood and on February 9,1979 initiated PGCo NCR 334, which required cleaning and special inspections prescribed by Westinghouse for the cap screws. Purchase Orders 722186 and 727837 were issued to Rockwell Engineering Co. on March 27, 1979 and June 14, 1979, respectively, for the cleaning, special inspection, and shortening of all cap screws on site, both those originally received from Telodyne Brown and those shipped from Byron. These actions were similar to those taken at Byron. The last shipatat of cap screws from Rockwell af ter cleaning, inspection, and shortening was received on site on June 27, 1979. Bolts that were considered unacceptable by Rockwell after inspection were scrapped and new bolts were ordered from Telodyne Brown to take their place.
Between May of 1979 and January of 1981 the cap screws were completely trial fit in the Unit 1 and partially trial fit in the Unit 2 steam generators prior to the setting of the steam generators.
Subsequently, it was determined by Phillips, Getschow Co. that some of 0443H/ November 22, 1585
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the new cap screws received from Teledyne Brown required shortening. !
l During the shortening operation, which was carried out by Phillips, '
l Getschow Co., the material heat traceability identification numbers on 19 cap screws were not properly transferred. On October 13, 1981, PC9o initiated PCCo NCR 612 to correct this condition. It was determined that all 19 cap screws came from the same material heat and the disposition of NCR 612 was to reapply the proper heat number. '
During installation of the cap screws, certain problems were encountered. On December 12, 1981, Ceco NCR 332 was initiated to i document the fact that a number of cap screws could not be fully engaged. NCR 332 also referenced the same loss of material heat traceability identification subsequently corrected under NCR 612, as ,
described above. The disposition of NCR 322 required the removal, reinspection, and replacement of all steam generator cap screws which could not be fully engaged. In addition, after removal of the bolts, the
-NCR required inspection of the hell-coils, which are thread inserts that can be removed if installations problem occur. The last shipment of cap screws used'for replacements at Braidwood was received on January 1, 1982 from Telodyne Brown.
A routine NRC safety inspection was conducted during the period April 19 through July 20, 1982, and a special NRC inspection was
-conducted on September 8-10, 1982, of activities at Braidwood Station.-
Units 1 and 2. The retults of the inspections were discussed during an enforcement conference conducted at the NRC Region III office on August 31, 1982, and at the Commonwealth Edison Company Corporate offices in 0443H/ November 22, 1985
Chicago Illinois on November 19, 1982. The reports setting forth the results of the inspections and the enforcement conferences are documented in Inspection Report 50-456/82-05; 50-457/82-05. As a result of these inspections and,as discussed at the enforcement conferences, the NRC inspector expressed concern in relation to the installation of the Steam Generator cap screws. This concern, as stated in NRC inspection report 82-05, dealt with the areas of damage to the cap screws, installation methods, cap screw traceability, cap screw installation procedures and timeliness of corrective actions regarding the cap screws.
In response to this concern, Commonwealth Edison committed to remove and. reinspect all the cap screws and replace the ones which were not acceptable. Phillips, Getschow Procedure PGCP-33 controlled the cap screw removal and Procedure PGCP-34 their reinstallation. Additionally, the bolt holes and hell-coils were also to be inspected and the hell-coils replaced if necessary. This inspection and replacement were also controlled by PGCP-33 and PGCP-34, respectively.
Concurrently, CECO NCR 413 documented some problems with the alignment between the steam generator pads and the vertical supports which are joined by the cap screws. The disposition of NCR 413 directed that the top support plates be slotted to facilitste bolt installation.
The disposition of this NCR, when finally implemented, solved the remaining cap screw problems. The removal and reinstallation of the Unit
, 2 bolts started in October of 1982 and finished in April of 1983. The removal and reinstallation of the Unit 1 bolte started in August of 1983 and finished in January of 1984.
0443H/ November 22, 1985 l
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l The other area of concern which had been expressed by the NRC during the previously referenced inspections and enforcement conferences dealt with traceability documentation for cap screws which were transferred from Byron to Braidwood and from Braidwood to and from Rockwell Engineering. Records exist on site which establish traceability and control of the steam generator support cap screws transferred to and/or i
from Braidwood and track those bolts and their respective movements back and forth. At the time of NRC Inspection 82-05, the proper records correlation had not been accomplished, so that the data was not readily auditable by the NRC inspector. A correlation to establish traceability of the steam generator bolts utilized at Braidwood has since been accomplished. Results of this correlation establish that, for all bolts transferred to and/or from Braidwood, records were maintained and exist today which demonstrate control and traceability. No transfers of bolts between Braidwood and either Byron or Rockwell Engineering occurred after June 27, 1979. The only steam generator bolts received at Braidwood after June 27, 1979 were new purchases from Teledyne Brown Engineering.
The correlation for all steam generator bolts utilized at Braidwood is complete at this time.
Through the above cap screw traceability correlation and the !
documented bolt removal / reinstallation in accordance with PGCo procedures PGCP-33 and 34, the acceptability of all 384 bolts currently installed in the Braidwood Unit 1 and Unit 2 Steam Generators has been positively I affirmed.
0443H/ November 22, 1985
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REFERENCE LIST l
- 1. Phillips, Getschow NCR 334 (page K0015104-K0015127).
- 2. Rockwell Engineering Co. Purchase Orders 722186 and 727837 (pages l C0003286-C0003292).
- 3. Phillips, Getschow NCR 612 (pages K0011650-K0011664).
- 4. Connonwealth Edison NCR 332 (pages B0006071-B0006092).
- 5. NRC Inspection Report Number 80-456/82-05, 80-457/82-05 (pages A0001005-A0001018).
- 6. Phillips, Getschow Procedure PGCP-33 (pages K0015400-K0015404).
- 7. Phillips, Getschow Procedure PCCP-34 (pages K0015388-15399).
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- 8. Conunonwealth Edison NCR 413.
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d443H/ November 22, 1985
SPECIFIC INTERROGATORY 4
" PIPE HEAT NUMBER REVERIFICATICN (MTV)"
The corrective action program undertaken in response to the item identified in contention Item 10.B is described in the detailed " Material
~
Traceability Ver1fication" report which has been furnished to Intervenors and incorporated in Applicant's response to Specific Interrogatory 7 of Intervenors' second set.
0446H/ November 20, 1985
SPECIFIC INTERROGATORY 5 Please describe in detail the Unit Concept Inspection Program 1 with respect to the following subjects which relate, as l described at pages 8 and 9 of the introduction to Applicants' Response to Intervenors' Interrogatory 58, to the following subjects, items, or subparts of the amended quality assurance contention:
- 1) Electrical Penetration Terminations (11.B)
- 2) Mechanical Equipment Installation (l.A. 6.A. 10.A, 13.A)
- 3) Cable Routing (6.E)
- 4) Reactor Coolant Pump Support Installation (9.B)
- 5) Small Bore Pipe Routing (3.A.4.a. 3.A.4.b)
As to each please detail the purpose and objectives, organization, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effectiveness. Please identify any documents which reflect these answers, ' including program descriptions, procedures, organizational charts, data, observation, inspection or evaluation forms or documents, and interim or final reports.
RESPONSE
The Unit Concept Inspection Program was voluntarily established in i
september, 1982 by Commonwealth Edison (Ceco) Site Quality Assurance.
The intent of the program is to provide an additional level of assurance in the work performed by the Braidwood site contractors during plant construction and to verify the quality of vendor equipment inshlled throughout the plant. Personnel assigned to the Unit Concept Inspections visually examine site contractor installed items and vendor supplied equipment with the objective of assuring that the work and equipment in a
-given area generally conforms to established design drawing requirements. Unit Concept inspections are not intended to provide a final acceptance of contractor installations, but rather serve as a Quality Assurance management tool providing an overview of these 4 0537H/ November 22, 1985 l
SPgCIFIC INTgRROGATORY 5 installations which can, in turn, be used to identify recurring concerns related to continuing plant construction. The Program as administered provides an additional Quality Assurance check at the Bealdwood Site.
The Unit Concept Program is administrated by the CgCo Site Quality Assurance organization, as demonstrated on Attachment A, which has direct responsibility for the program, thereby allowing the conduct of inspections to be independent from inspections performed by the site contractors quality and production organizations. Actual inspections are performed by Pittsburgh Testing Laboratories (PTL), the Braidwood Site Independent Testing Agency, under the direct supervision of CgCo Site Quality Assurance. The PTL Unit Concept Group consists of one (1) Level II Inspection Supervisor, five (S) Level II Inspectors who are responsible for performing initial inspections and two (2) Level II Inspectors Vno are responsible for performing reinspections, as necessary. These inspectors are qualified to perform their respective inspection responsibilities in accordance with ANSI N45.2.6-1978, with each individual inspector having multiple certifications. During an individual inspection, an inspector is only assigned to review those contractor installations for which he holds a valid certification.
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The accompanying chart (Attachment A) reflects the orEanization of i
the PTL Unit Concept Group and also illustrates the interface between the 1
groups most affected by the Unit Concept Inspection Program. Although PTL performs the inspections, CgCo Site Quality Assurance functions as liaison between PTL and all other parties on-site. The liaison function b
0537H/ November 22, 1985 I
SPECIFIC INTERROGATORY S performed by Ceco Site Quality Assurance includes such actions as accepting contractor responses to Unit Concept Inspection Reports, obtaining clarifications to acceptance criteria, and acting on concerns which may be under dispute between PTL and the site contractors. Within the Ceco Site Quality Assurance Department, one Senior Quality Inspector has been assigned responsibility to coordinate and implement these liaison activities.
The basic purpose and objectives of the Unit Concept inspections have remained the same since inception of the program in the Fall of 1982. However, in June 1984, the format of the field reviews performed 4
by the PTL Unit Concept Group was enhanced from inspections conducted under . a surveillance format to those performed under more formal
~ inspection criteria. The change generally did not alter the manner in which field reviews were performed, but did proceduralize the manner in which these field reviews were documented and the acceptance criteria against which inspection results are assessed. ,
1
. Under the earlier surveillance format, inspection acceptance criteria were informally contained in the various site design documents, specifications, codes and standards applicable to the installations under review. In addition, PTL inspection personnel were only required to record inspection results directly on the design drawings used in the performance of field reviews. This practice did not allow for a comprehensive record of all elements reviewed in a particular inspection. To improve the program in these areas, inspections beginning l
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0537H/ November 22, 1985
d SPECIFIC INTERROGATORY 5 in June 1984 have been. performed to four (4) PTL Site Quality Assurance Instructions. These approved Instructions include PTL General Instruction (IS-BRD-22-UC) which describes personnel responsibilities, development of inspections, inspection scope, reporting format, tracking of identified concerns,- if any, and necessary reinspections to assure compliance with identified corrective actions under the Program. The inspection disciplines under the Program are governed by individual Electrical (IS-BRD-24-UCg), Mechanical /HVAC (IS-BRD-25-UCM), and Civil (IS)BRD-26-UCC) Instructions. Thes6 Instructions contain acceptance criteria and-checklists which delineate the formal inspection attributes ,
I to be verified in each inspection and provide a formal record for l
documentics inspection results.
In general, Unit concept inspections are performed on plant areas in which construction has progressed to a point in which the inspections can be meaningful. The preferred approach is that the items reviewed have received final Quality Control inspections by the contractors' quality organizations. However, in actual practice, all installed items within the defined inspection area are reviewed during the Unit Concept Inspection regardless of the status of contractor inspection. (concerns.
identified for items in which construction is on-going are tracked within the Unit Concept Group for closure in the same manner as those for which construction is identified as complete.) The " Units" inspected may be of a specific plant component, a specific room or area, a spatial cube of a building or area, or a specific generic concern within the plant.
0537H/ November 22, 1985
SPECIFIC INTERROCATORY 5 The Unit Concept inspections are of predefined scope as set out in an established yearly Inspection Schedule developed by CECO Site Quality Assurance and PTL. Inspections are scheduled by reviewing construction progress in the various areas of the plant, with the intent being to schedule inspections that provide coverage primarily of safety related components and/or areas. Revisions to the Inspection Schedule are made as necessary to compensate for changes in construction progress. Prior to comunencing an inspection, the PTL Unit Concept Groups prepares an inspection package defining the boundaries or areas, components, i acceptance criteria, and the inspectors to be involved in the particular inspection, thereby establishing the minimum requirements to be met in each inspection. Available design documents such as vendor drawings, Architect Engineer basic desigr. drawings, design change documents, project specifications and applicable codes and standards to be utilized
, by PTL inspection personnel in the conduct of each inspection are included in the inspection package. Upon Ceco Quality Assurance approval
. of this inspection package, the PTL Unit Concept Group performs the inspection by visually examining the component and/or items within the inspection scope and assessing them against the attributes contained on the applicable checklists.
f When the inspection is completed the PTL Unit Concept Group submits a formal Inspection Report to CECO Site Quality Assurance. This Report summarises inspection results and details any defielencies found. Site Quality Assurance, in turn, reviews and evaluates the Inspection Report for completeness and appropriateness of corrective actions to be 0537H/ November 22, 1985
SPECIFIC INTERROCATORY 5 undertaken. When related deficiencies or generic deficiencies are identified, separate actions can be initiated to investigate the cause.
Upon approval by Site Quality Assurance, the Report is transmitted to the cognizant site contractor (s) and to responsible Commonwealth i Edison management. The applicable contractor (s) are then requested to respond to Site Quality Assurance with specific corrective actions for deficiencies identified as their responsibility. Site Quality Assurance evaluates these responses for acceptance. Thereaf ter, PTL tracks the
, deficiency status and progress of established corrective actions. When notified by the contractor that the corrective actions are complete, PTL performs and documents a reinspection of the deficiency to verify it has been acceptably corrected. Once all corrective actions are completed, PTL issues a closed Reinspection Report. Open Reinspection Reports require an additional contractor response and the item continues to be tracked pending completion of acceptably implemented corrective actions and final closure and issuance of the required closed Reinspection Report.
As the description set out above indicates, the focus of the Unit Concept Inspection Program is on assessing the quality of a plant area or
" Unit" as a whole. Thus, to the extent the five Contention Item areas 4 described in the Introduction to Ceco's response to Intervenors' Specific Interrogatories 58 and 59 are included in Program coverage, they are included only as part of this broader Unit Concept Inspection Program Scope. Moreover, it must be remembered that the purpose of the Unit concept Inspection Program is to provide an additional overview function 1
0537H/ November 22, 1985 l
SPECIFIC INTERROGATORY 5 and that the inspections are not intended to serve as the final quality acceptance check for installed hardware. With this in mind, the following Unit Concept information can be provided on the five items for which information has been requested by Intervenors.
- 1) Electrical Penetration Termination (ll.B)
Unit Concept Inspections performed to date have reviewed the area of electrical penetrations for such attributes as design , drawing conformance of physical dimension and configurations, condition and termination of external safety related cables to the penetration, pressurization of assembly and tightness of external bolting. To date, the Unit Concept Program has issued eleven (11) reports documenting inspection results for twenty-six (26) electrical penetrations which were reviewed in light of the aforementioned attributes. Any concerns identified during the inspection of these electrical penetrations were addressed and have been or are being tracked under the program to a satisfactory conclusion.
These concerns were not found by the Unit Concept Group to be recurring in nature and therefore the overall evaluation of electrical penetrations reviewed under the Unit Concept Inspection Program indicates the acceptable nature of these installations.
The specific loose crimps identified in contention Item ll.B were of venuor terminated internal wiring. The Unit Concept Program, although including electrical penetration inspections within its scope, did not specifically address this internal vendor wiring electrical penetration 0537H/ November 22, 1985
SPECIFIC INTERROCATORY 5 l
concern. In addition, the L.K. Comstock cables identified in Contention Item 11.B which were not terminated, but were tagged with orange out-of-service cards, would have been considered incomplete construction and would therefore not have been addressed by a Unit Concept Inspection. As previously noted, the structure of a Unit concept Inspection does not directly verify the implementation of a contractor's quality program. As such, Unit Concept inspections of electrical penetration terminations would not verify whether or not the L.K.
Comstock orange out-of-service cards referenced in this contention item were a part of L.K. Comstock's quality program.
- 2) Mechenical Equipment Installation (1.A. 6.A. 10.A. 13.A)
The NRC concerns identified in the above Contention Items address apparent quality program inadequacies and a failure to perform documented quality inspections. The Unit Concept Inspection Programs as structured provides a verification of the component or item installation and not an evaluation of the implementation or adequacy of the quality program governing the installations.
The Unit concept inspections performed to date have reviewed such attributes of mechanical equipment installation as location and orientation, foundation bolting, bolted connections, equipment damage, design drawing confomance of the equipment physical dimensions and configuration and equipment welds. It should be noted that equipment welds are generally painted by the vendor prior to shipment and as such 0537H/ November 22, 1985 l I
SPECIFIC INTERROCATORY 5 were not included in the scope of the Unit concept Inspection Program j until September, 1984, from that date, they have been inspected for length, location, size and obvious defects.
To date, the Unit Concept Program has issued sixty-eight (68) l reports documenting the inspection results of (130) mechanical equipment '
installations which were reviewed in accordance with the aforementioned attributes. The (12) Unit I components identified in the referenced Contention Items are included in the population of mechanica) equipment inspected under the Program. Identified Unit 2 components have not yet been inspected as, to date, the " Unit Concept Inspection Program has focused primarily on Unit 1 equipment.
4 The concerns identified during the inspection of the mechanical
- equipment installations were addressed and are being or have been tracked to a satisfactory conclusion under the program. These concerns were not
, found to be recurring in nature. The overall Unit Concept evaluation determined that those mechanical equipment installations reviewed were
. acceptable.
- 3) Cable Routina (6.E.)
Unit concept inspections of safety relcted cable prior to 1985 pertained primarily to the condition and training of the cable. The Unit Concept Electrical Instruction IS-BRD-24-UCE was revised in January 1985 to add cable routing to the list of attributes to be verified in safety related cable inspections. This revision also made the verification of 0537H/ November 22, 1985
SPECIFIC INTERROCATORY 5 cable routing a specific checklist element, thereby providing documented evidence of reviews performed. Since the inception of this routing verification in January 1985, eleven (11) Unit Concept Reports have been issued which contain cable routing verifications within the scope of their inspection reviews. These Reports provided evidence of (241) verifications of cable routing. All of these verifications were found to be acceptable. These Reports were of " Units" inspected in diverse areas of the plant, thereby assuring that a relatively broad sample of cable routing was reviewed. Based on these Unit Concept Inspections the (2) cables identified as miscouted in the referenced Contention Item are considered to be isolated occurrences.
- 4) Reactor Coolant Pump support Installation (9.B)
The four Unit Concept inspections performed to date on the Reactor Coolant Pumps (RCP's) have reviewad the installation of RCP support steel for design drawing conformance. Inspections have included verifications of dimensions and configuration, sizes and types of support steel materials, bolting and welding. This verification has been performed for-the four (4) Unit 1 Reactor Coolant Pumps, but not for the four (4) Unit 2 RCP's because, to date, the Unit Concept Inspection Program has been, focused primarily on Unit 1 installations.
The design change which revised the support steel for the Reactor Coolant Pumps support, and precipitated the original NRC concern identified in the referenced contention Item was initiated on Field 0537H/ November 22, 1985
SPECIFIC INTERROCATORY 5 Change Request (FCR) L-506 for the Unit-1 RCP's. This FCR was incorporated into the applicable design drawing S-1109 in Revision 'P',
dated August 18, 1980. The four Unit Concept inspections of the Unit 1 RCP's support steel were performed after this date, utilizing a subsequent revision of the aforementioned design drawing, thereby demonstrating that the design change in question was verified.
Overall, the inspections found the four (4) Unit-1 RCP's support steel installations acceptable. The inspections of the support steel for Unit 1 Reactor Coolant Pumps 1 and 4 identified isolated concerns unassociated with the subject design change. These concerns were addressed and have been or are being tracked to a satisfactory conclusion by the PTL Unit Concept Group. The inspections of the support steel for Unit 1 Reactor Coolant Pumpa 2 and 3 supports were found to be acceptable. Based on the results of these Unit Concept inspections, it would appear that tha quality concerns identified in the referenced contention Item did not adversely impact on the Reactor Coolant Pump support steel as installed.
- 5) Small Bore Pipe Routina (3A.4.A. 3.A.4.B) l As previously noted, the Unit Concept Inspection Program does not evaluate the contractors' qutlity pectrams, but rather the contractors' installations within the plant. Accordingly, Unit Concept inspections do not address the adequacy of small boes pipe routing design or design control. However, because the Unit Cc,acept inspectisns are verifications 0537H/ November 22, 1985
SPECIFIC INTERROCATORY 5 of installations to the applicable approved design drawings, inspections would assure that the field routing of small bore piping was in accordance with the applicable isometric design drawings.
Unit Concept inspections verifying small bore pipe routing to isometric drawings were instituted in March 1984. To date, thirty-seven (37) Unit concept Inspection Reports have been issued documenting these inspections. In addition, the Unit Concept Program has been assuring adequate clearance between the small bore pipe and unrelated components for some time. This is evidenced by inspection reports dated December i
- 23. 1983 and March 21, 1983 documenting instances in which pipe supports were in contact with unrelated items. In October 1984, inspection for such conditions became a formal part of the Program. Since that date, sixteen (16) Unit Concept Reports have been issued of inspections utilizing the established "no contact" criteria.
Any concerns identified during the above inspections were addressed and are being or have been tracked by the PTL Unit Concept Group to a satisfactory conclusion. Ceco Site Quality Assurance which monitors these activities on an on-going basis identified that they were not found to be recurring in nature. The Unit Concept Inspections performed provide evidence of the overall acceptability of the small bore pipe field routing and that instances of small bore piping in contact with unrelated components were isolated concerns.
1 1
0537H/ November 22, 1985
SPECIFIC INTERROGATORY S In conclusion, the Unit concept Program is an effective management tool which has provided additional assurances of the quality of contractor installations'within Unit 1 of the plant. As can be seen in the responses to the above items, the program has not remained static, but rather has been refined numerous times in an attempt to make the independent Unit Concept Program overview inspections as meaningful as possible. The Unit Concept inspections will continue to be performed in order to provide similar assurances of contractor installations in Unit 2 of the plant.
OS37H/ November 22, 1985
SPECIFIC INTERROCATORY 5 REFERENCES
- 1. Ceco Quality Assurance Department memorandum #9 - Unit Concept Surveillance Inspection.
- 3. PTL Instruction IS-BRD-24-UCE, Electrical Instruction Sheet for Unit Concept Inspection.
- 4. PTL Instruction IS-BRD-25-UCN, Nechanical Sheet for Unit Cone pt Inspection.
- 5. PTL Instruction IS-BRD-26-UCC, Civil Instruction Sheet for Unit Concept Inspection.
t
- 0537H/ November 22, 1985
November 21, 1985 ATTACHMENT A Site Contractor l
l l
CECO - --l Quality Assurance ,
I I
I Ceco Project Construction Department 1
Unit Concept Inspectior Supv.
Level II - Elec., Mech.
Initial Inspectors Reinspection Inspectors (Level / Position / Certifications) (Level / Position / Certifications)
Level II Lead Inspector: CIV, STR, Level II Inspector: STR, VWI, ELE ELE, CIV, Level II Lead Inspector: STR, MEC MEC Level II Inspector: ELE, VWI Level II Inspector: ELE, MEC, Level II Inspector: STR, CIV VWI Level II Inspector: MEC, VWI
= Direction CIV - Civl
_---- = Interface STR - Structural ELE - Electrical MEC - Mechanical VWI - Visual Weld (3535A)
So cific Int +rr gatory 6 P10000 d scribe in detail the corrective actions, programs or responses which are identified in Applicant's Response to Intervenors' Interrogatory 58 regarding items or subparts of the amended quality assurance contention:
Applicant Item Action. Program or Response Response Page General BCAP Introduction 1 3.B Quality Control Structural Steel 3 Unit Concept Inspections 3 Instrument Retrofit Verification Program 3 BCAP 3 3.C Braidwood Construction Assessment 1 4 Program (BCAP)
Quality Control Inspection Reinspection Document B00067 Program (QCIRP) attached to revised response of 10/15/85 4.B BCAP and other corrective action programs 3 6.B.5 Comstock Document Review drawing review Review of Inspection Checklists 6.D INPO 3 8.R Machanical Equipment Disassembly and 2 Inspection 10.D Cable Tray Separation Walkdown 3 12.B.1 Piping Heat Number Material Traceability 3 Verification Program (MTV)
Instrument-Retro Program (IRV) 3 ,
As to each please detail the purpose and objectives, organization, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effectiveness. Please identify any documents which reflect these answers, including program description, procedures, organizational charts, data, observation, inspection or evaluation forms or documents, and interim or final reports.
RgSPONSg Applicant's response is contained on the following pages.
(0538H)/ November 21, 1985
SPECIFIC INTERROCATORY 6 BCAP BCAP is addressed in Applicant's response to Specific Interrogatory 7 of Intervonors' second set.
0546H/Novembe/2'2,1985
SPECIFIC INTERROCATORY 6 CONTENTION ITEM 3.B Applicant's updated response to Specific Interrogatory 58 Intervenor's first set, Contention Item 3.B. provided in response to Specific Interrogatory 3 of Intervenors' second set, deletes the reference in the original response to " Unit concept Inspections", the
" Instrument Retrofit Verification Program" and BCAP.
The " Quality Control structural Steel Rtview Program", the
" Instrument Retrofit Verification Program" ann BCAP are addressed in Applicant's response to Specific Interrogatory 7 of Intervenor's second set. " Unit Concept Inspections" are addressed in Applicant's response to specific Interrogatory 5 of Intervenors' second set.
4 4
0452H/ November 22, 1985
SPECIFIC INTERROCATORY 6 CONTENTION ITEM 3.C Applicant's amended response to Specific Interroga'iory 58 of Intervenors' first set, contention Item 3.C, submitted on October 15, 1985, deleted the reference to BCAP from Applicant's original response, BCAP is addressed in Applicant's response to Specific Interrogatory 7 of j
{
Intervonors' second set. The reference in the amended response to the '
" Quality Control Inspector Reinspection Program (QCIRP)" is hereby deleted because a more appropriate contention-specific corrective action program is being implemented by Conunonwealth Edison Company. That program is described in this response in the section captioned "Lovel I Reverification Program". The " Quality Control Inspector Reinspection Program" was addressed in Applicant's response to Specific Interrogatory 7 of Intervenors' second set.
l 0453H/ November 22, 1985
1 SPECIFIC INTERROCATORY 6 LEVEL I REVERIFICATION PROGRAM I
l Commonwealth Edison (Ceco) has instituted the Level I reverification Program (LRP) to provide additional confidence in the adequacy of welds inspected by L. K. Comstock (LKC) weld inspections during the time they were certified as Level I inspectors. In December of 1984, CECO directed LKC to use only Level II inspectors as weld inspectors. The LRP is designed to demonstrate that welds inspected by LKC Level I weld inspectors contain no design significant deficiencies.
An NRC inspection of the Braidwood Construction Assessment Program (BCAP) activities conducted by Mr. R. N. Cardner on February 4 through March 4, 1985 identified a concern with regard to LKC weld inspection.
The results of the NRC inspection were reported in Inspection Report 50-456/85-006 and 50-457/85-006. This issue, contained in Contention Item 3.C. focuses on the fact that, under the provisions of ANSI M45.2.6-1978, when a Level I weld inspector inspects a weld a Level II weld inspector must review the Level I's inspection checklist to determine final acceptability. The lack of documented objective evidence on the weld inspection checklists prepared by the LKC Level I inspectors leaves unclear the method used by the Level II inspector to establish weld acceptability. In order to address the accepta5tlity of the welds inspected by LKC Level I inspectors, Ceco decided to perform the LRP.
n vn _z_
0543/ November 22, 1985 1
CgCo is developing a project management procedure to define the scope of LRP. The program will provide for:
- 1. Determining the LKC inspectors who were certified as Level I weld inspectors.
- 2. Determining, from completed inspection checklists, the I population of welds inspected by each Level I inspector during l the time he was certified as a Level I.
- 3. Defining the sampling process to be used for the selection of ,
inspection checklists. These checklists identify the component to be reinspected.
- 4. Describing the reinspection process. This includes determining whether the component has been subsequently reworked or deleted or is inaccessible. If, for these reasons, a component cannot be reinspected,' a substitute component will be randomly selected. For components selected, welds will be reinspected by a currently certified Level II weld inspector other than the original inspector. The identity of the original inspector will not be provided to the reinspector.
- 5. Defining the acceptance criteria for the weld reinspections.
The reinspection will use the criteria that was in effect at the time the original insp2ction was performed. Additional inspection criteria to clarify and interpret the original inspection requirements will be provided in the project procedure.
- 6. The results of the reinspections will be recorded on a weld basis. The results of the progrart will be expresed in terias of the number of discrepancies, if any, which are design significant.
7 sample expansion will occur after the existence of a design significant discrepancy is established.
At the present time, it has been determined that fourteen inspectors were certified by LKC as Level I weld inspectors. Of these fourteen .
( eleven inspectors actually performed weld inspections. A review of the i
LKC QC files indicated that the eleven inspectors generated approximately 11,000 inspection reports.
0543/ November 22, 1985
r Because this program is still being developed, there are as yet no preliminary or final conclusions. When the program is complete, it will enable CECO to make a statement regarding the existence of design significant discrepancies in components or equipment inspected by LKC Level I inspectors and the ability of the inspected components to meet their intended design function.
(
0543/ November 22, 1985
i l
-SPECIFIC INTERROCATORY 6 CONTENTION ITEM 4.B )
I Applicant's amended response to Specific Interrogatory 58 of i l
Intervenors' first set, Contention Item 4.B submitted on October 15, 1985, deleted the reference to "BCAP and other corrective action programs" from Applicant's original response. BCAP is addressed in Applicant's response to specific Interrogatory 7 of Intervenor's second set. The "other corrective action programs" are addressed in the
" Quality Control Inspector Reinspection Program" portion of Applicant's response to specific Interrogatory 7 of Intervenor's second set and in Applicant's response to contention Item 3.C provided in this response to specific Interrogatory 6 of Intervenor's second set.
0464M/N'ovember 22, 1985
SPECIFIC INTERROCATORY 6 Contention Item 6.B.5 The " review of inspection checklists" was addressed in the portion of Applicant's response to Specific Interrogatory 7 captioned "Comstock Document Review." The "Comstock Document Review drawing review" is addressed in the response below captioned "Comstock Drawing Review."
0545H/ November 22, 1985
..:p BRAIDWOOD CORRECTIVE ACTION PROGRAM L. K. COMSTOCK DRAWING REVIEW In April 1984, the Nuclear Regulatory Commission performed a site
' inspection on Braidwood electrical contractor L.K. Comstock Company.
During its inspection, the NRC noted that L.K. Comstock had no proceduralized method to review approved design changes to electrical drawings. In response to this expressed concern and to assure that once an approved design change is made to a drawing it is installed in the field and properly inspected, Commonwealth Edison (Ceco) instituted the following corrective actions.
'First, CECO Project Construction Department instructed L.K. Comstock to institute a formal program to review approved design drawing changes for all future work. On March 29, 1984, L.K. Comstock initiated Procedure 4.3.24, " Rework", to encompass a plan to review all appecved' design drawing changes to existing fleid installations and to ensura . hat such changes are implemented in the field. Under Procedure 4.3.24, all changed design drawings approved and issued by Sargent and Lundy which affect existing installations are forwarded to appropriate L.K. Comstock site Engineering personnel for review and initiation of proper paperwork to assure field rework. L.K. Comstock Engineering then issues a Rework 4 Report, covering the required design change to the existing installation. This report is then routed to L.K. Comstock Production and Quality control personnel for implementation and subsequent Q.C.
inspections. Revisions to design drawings which require 0397H/ November 22, 1985 4
I l
new field installations are being-tracked by L.K. Comstock to assure actual installation and inspection through developed computer programs which will verify all required installation necessary for system and area i l
turnover.
In addition to assuring that the quality of future work conforms to the latest approved design change, CECO Project Construction Department
, (PCD) together with Site Quality Assurance also instructed L.K. Comstock to. develop a program to assure that revisions to approved electrical drawings made prior to April 1984 have been properly i implemented / corrected in the field and Quality Control inspected. CECO l 1
determined that the scope of the program should include the installation of electrical supports, cable pan, conduit, electrical equipment and 1 junction boxes.
CECO PCD and Project Field Engineering (PFE) in conjunction with L.K. Comstock Engineering / Quality Control and Sargent and Lundy personnel are currently in the process of addressing this drawing review concern.
- To date, no-final determinations as to methodology have been reached. If i
field installations are found to be not installed and inspected to the latest design revisions, rework and/or Quality control inspections will i
l i
be implemented in accordance with current site procedures.
At the present time no exact results or conclusions are available because the program has not been formalized or implemented.
i 0397H/ November 22, 1985
_4_
REFERENCES
- 1. NRC Inspection Reports 50-456/84-17, 50-457/84-17; 50-456/84-06, 50-457/84-06 (pages A0002020-A0002035, A0002303-A0002324).
- 2. L.K. Comstock Procedure 4.3.24 " Rework" Rev. C.
- 3. Ceco NCR 708 and Revision 1.
- 4. Letter dated 5/21/85 from T.E. Qualka to D.L. Shamblin concerning corrective action for NCR 708 Rev. 1.
- 5. Ceco NCR 709 and Revision 1.
- 6. Letter dated S/21/85 from T.E. Quaka to D.L. Shamblin concerning l correction action for NCR 709, Rev. 1. l
- 7. Letter dated 3/31/85 from T.E. Quaka to F. Rolan and I. DeWald.
- 8. Letter dated 4/1/85 from D.L. Shamblin to T.E. Quaka.
- 9. Letter dated 2/8/85 from A.J. D' Antonio and T.E. Quaka to W. Vahle.
_4_
0397H/ November 22, 1985
CONTENTION ITEM 6.D RESPONSg The Institute of Nuclear Power Operations (INPO) is a non-profit organization established by the nation's nuclear utilities to promote the highest standards of excellence for operating nuclear electric generating stations. INPO is a direct response by the nuclear utility industry to the accident at the Three Mlle Island Nuclear Plant on March 28, 1979.
The utility industry formed INPO to apply the lessons learned from that 2
experience and to help improve overall safety in the operation of nuclear plants.
INPO members are utilities that own or operate nuclear plants for the purpose of generating electricity. Every U.S. utility with an operating license or a construction permit for a nuclear power plant is a membee.
INPO's primary functions are the following:
0 to establish and disseminate performance objectives and supporting criteria designed to support safe and reliable
, operation of nuclear Power plants.
O to conduct evaluations of nuclear operations to assist utilities in identifying areas in which improvements can be made 0 to assist members in upgrading their operations by developing and disseminating good practices and operating guidelines 0 to identify generic safety problems and precursors by reviewing and analyzing nuclear plant operating experiences and communicating this information to members to reduce the possibility of similar occurrences at other plants 0 to assist members in developing and maintaining high quality, effective training programs 0440H/ November 22, 1985
CONTENTION ITEM 6.D 0
to aid nuclear utilities in the development and maintenance of effective radiological protection and chemistry programs and emergency response capabilities 0
to provide a forum for the exchange of operational information among domestic utilities, domestic nuclear designers and suppliers, and operators of non-U.S. nuclear plants INPO currently has a Construction Project Evaluation Program. Under i
this program, performance objectives and criteria were developed for evaluating quality in the design control and construction of nuclear plants.
One of INPO's goals is to assist member utilities in achieving the highest standards of excellence in nuclear plant construction. They
, provide recommendations in each area which are based on best practices, rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are reconunended are not necessarily indicative of unsatisfactory performance.
INPO conducted an evaluation of the Braidwood Nuclear Power Station construction project and the Sargent and Lundy Engineers design offices during the weeks of June 4, 11, and 25, 1984. This evaluation was conducted at the site and the principal design office, Sargent and Lundy Engineers, to evaluate the control of design and construction processes and to identify areas needing improvement. Inforination was assembled a
from discussions, interviews, observations, and reviews of documentation.
- The INPO evaluation team examined organization and administration, design control, construction control, project support, training, quality, and test control. The team observed actual work performance and test 0440H/ November 22, 1985
-. - . . = . . - .
CONTENTION ITEM 6.D performance. A portion of the evaluation focused on a detailed vertical path examination at several points. The team at the design office reviewed the design control, and the team at the project site examined, in some detail, the installed equipment.
INPO is not a corrective action, program, or response. The description in Applicant's reponse to Specific Interrogatory 58, Contention Item 6D of Intervenors' first set response is clear that IMPO identified an issue, and does not indicate that INPO is a corrective action, program or response.
Confidential and restricted distribution field notes, a draft response, and the final INPO report were provided by counsel to Mr. Robert Guild, counsel for Intervenor Rorem, et. al. on November 14, 1985. Those confidential, restricted distribution documents were masked to reveal only information deemed by counsel as relevant to the Quality contention.
i 0440H/ November 22, 1985
BRAIDWOOD CORRECTIVE ACTION PROGRAM MECHANICAL EQUIPMENT DISSASSEMBLY AND INSPECTION 1 (MECHANICAL EQUIPMENT INTERNAL CLEANLINESS VERIFICATION)
During their review of the documentation of the retrofit inspection of safety related mechanical equipment performed in reponse to NRC Inspection Report-item 82-05, the resident NRC inspectors identified a concern regarding the internal cleanliness inspection signoffs for some of the equipment.
During the course of the retrofit inspection conducted between September 1, 1982 and December 31, 1982, it was found that many-pieces of equipment had its piping already attached and the internal cleanliness inspection required by Phillips, Getschow (PGCo) procedure QCP-B22. " Installation / Inspection of Mechanical
'Iquipment," could not be performed without dismantling the piping.
h This problem was discussed between PGCo and Commonwealth Edison (Ceco) Project Construction Department (PCD). Subsequent to these discussions, Ceco issued a letter to PCCo dated September 24, 1982 which stated "The item for internal cleanliness check may be waived i
on an individual basis since construction flushing procedures will 4 assure internal cleanliness of equipment. Notation shall be made on the appropriate QCP-B22 Form 22-1 to this effect".
l
! After receiving this directive, PCCo proceeded to waive the internal cleanliness inspections for 110 of the 216 pieces of equipment in the Mechanical Equipment Reinspection Program based on planned flushing activities.
1 i
0405H/ November 22, 1985
The resident NRC inspectors identified that ANSI M45.2.8,
" Supplementary Quality Assurance Requirements for Installation Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," requires visual cleanliness inspections and the waiver of these inspections did not address the ANSI requirement. In addition, the waiver letter did l
l not have the concurrence of the CECO Project Field Engineering Department or Sargent and Lundy the Architect-Engineer for the Project. In response to this concern, CECO PCD initiated Ceco Nonconformance Report (NCR) 614 on April 4, 1984. This item also was cited as an item of noncompliance in NRC Inspection Report No.
84-21.
Ceco NCR 614 identified that Ceco PCD had authorized the waiver of internal cleanliness inspections based on the planned flushing of the system without engineering concurrence of this deviation from the ANSI requirements. Ceco and Sargent and Lundy Engineering evaluated NCR 614 and directed PCD to perform, where practical, visual inspections for internal cleanliness on each of the 110 pieces of equipment at issue. This inspection was to encompass a visual check of the interior of certain equipment and a check of equipment connections to assure the absence of construction debris.
Engineering was to be contacted on a case-by-case basis for equipment connections which could not be visually inspected without extensive disassembly of-the equipment or cutting of the attached piping.
0405H/ November 22, 1985
i- Two basic types of equipment connections were sent to Engineering for dispositioning. The first category encompassed certain one~(1) inch and under vents, drain and instrument 11nu.
l The disposition for these equipment connections was not to inspect, but to use the flow verification process that would be performed during construction flushing. The second category encompassed other !
I individual equipment connections that could not be practically inspected due to the installed nature of the equipment. Each individual piece of equipment falling into this category was dispositioned on separate IR's on a case-by-case basis. Engineering resolved these IR's by accepting the use of flow verification performed during construction flushing to assure that these equipment connections were free from debris.
The disposition and resolution of NCR 614 is being carried out i
by PGCo as part of the Safety Related Mechanical Equipment Retrofit Program which is being conducted thru the implementation of PGCo Procedure QCP-B22 " Equipment Installation Procedure". (See separate i description of the broader corrective action program in Applicant's response to Interrogatory 7.) To date, 94 of the 110 pieces of equipment which require internal cleanliness inspections under NCR 614 have been completed. Upon completion of the inspection of the remaining 16 pieces of mechanical equipment, the internal cleanliness of all 216 pieces of equipment will have been assured.
It is anticipated that the equipment identified on NCR 614 will all be completed or'dispositioned by Engineering by December 1985.
l
! 040$H/ November 22, 1985
REFERENCES l
- 1. Inspection Report 50-456/84-21; 50-457/84-20 (pages A0002364-A0002384). I
- 2. D.L. Farrar letter to J.G. Keppler dated January 31, 1985 transmitting Commonwealth Edison's reponse to the Notice of Violation (pages A0002385-A0002396).
- 3. D.L. Farrar letter to J.G. Keppler dated February 27, 1985 transmitting an amendment to Consnonwealth Edison response of January 31, 1985 (pages A0002397-A0002399).
- 4. D.L. Farrar letter to J.G. Keppler dated April 16, 1985 transmitting Supplemental Response to NRC (pages A0002400-A0002401).
- 5. CECO NCR 614 (pages B0005803-B0006024).
- 6. Ceco Project Procedures PSU 206, PSU 200, Rev. 3 (pages B0005628-5637, B0005570-5627).
- 7. Phillips - Getschow procedure QCP-822 " Equipment Installation Record" Revision 0, 1, 2, 5 and 7 (pages K0015128-15387).
]
l 0405H/ November 22, 1985 l
C_ABLE TRAY SEPARATION WALKDOWN PROGRAM NRC Construction Appraisal Team (CAT) Inspections were performed by
, the Office of Inspection and Enforcement on December 10-20, 1984, and January 7-18, 1985. The inspectors involved were Mr. Steven Stein and Mr. Daniel Ford. The results of the inspections were recorded in NRC Inspection Report Numbers 50-456/84-44; 50-457/84-40. A review by the NRC CAT inspectors of L. K. Comstock's Quality control inspection procedures indicated that the 12" vertical and 3" horizontal cable tray separation requirements between safety-related and non-safety related cable trays were not included.
I Maintenance of required cable tray separation distances at Braidwood is governed by Sargent & Lundy (S&L) electrical installation drawings prepared and reviewed in accordance with the S&L Cable Separation Design Criteria and electrical. contractor L. K. Coastock's cable tray installation and inspection procedures. At the time of the CAT
- Inspections, the installation tolerances included in L. K. Coastock's cable tray installation procedure, if exercised, had the potential for resulting in cable tray separations that were less than the minimum f
electrical separations committed to by Conunonwealth Edison (Ceco) in the Braidwood FSAR. Since a large portion of cable tray had already been installed by L. K. Comstock, Ceco convaitted to performing a field walkdown of all L.K. Comstock previously installed cable tray. The walkdown will verify that the previously installed cable tray system is (0541H) November 22, 1985
.--.w.- - , , e-,,.e--, e. - - , - -. - , - + - - -_.,.,,-,,-%.,,.. ..,-.,-.v.--,----,---n--~~- - . - - - - - - - . , , , - - - - - - - - - - - - < - . , - - + . - - , . - - , -
in conformance with the FSAR electrical separation connitments. CECO had
-been formulating this walkdown program prior to the CAT inspection.
In early 1985. Ceco formally requested S&L to perform the 100% field walkdown examination of all safety related cable tray installed by L. K.
Comstock, in order to determine its conformance with the FSAR cable tray separation requirements. The program requires a walkdown of all installed safety related cable trays in order to identify any cable tray that has less than the basic separation distance (12" vertical and 3" horizontal), required between safety related cable tray and non-safety related cable tray and/or raceway. Sargent & Lundy Project Instruction PI-85-77, " Cable Tray Separation Walkdown Procedure", dated October 12, 1984, establishes the responsibilities and instructions for the field walkdown program. Under PI-BB-77, S&L Electrical Design and Drafting Division (ED&DD) personnel are performing these separation walkdowns under the supervision of the S&L ED&DD Electrical Project Supervisor and Commonwealth Edison. S&L ED&DD walkdown personnel have been trained in the performance of PI-BB-77 requirements, the appropriate electrical separation design criteria required between safety related and non-safety related cable tray and/or raceway and all project instructions and procedures relative to cable tray design. In addition, L. K. Comstock Quality Control personnel accompany ED&DD personnel during the walkdown to perform cable tray hanger configuration inspections.
S&L began its field walkdown of installed safety related cable tray on March 2, 1985. Field walkdowns are currently being performed on an area-by-area basis. Plant areas for the walkdown are defined by the (0541H) November 22, 1985
}
l l
boundaries shown on existing S&L cable tray plan design drawings. These '
plan drawings are used by S&L and L. K. Comstock walkdown personnel as a guide for the examination of the cable tray system. As each area of the plant is examin'ed, the walkdown personnel mark-up the applicable cable tray drawings to identify installations with less than the required i
electrical separation distance between safety related and non-safety related cable tray and/or raceway. After the walkdown of each plant area has been completed, the marked-up drawings are reviewed by the S&L ED&DD Cable Tray Separation Coordinator to identify installations with less than the required separation. Identified separation discrepancies which R&L previously analyzed and found acceptable during its formulation of plant design are eliminated from further processing under the program.
Separation discrepancies which were not previously identified and dispositioned by S&L during plant design, e.g., those resulting from the use of L. K. Coastock's installation procedure tolerances, are not eliminated from the program. These discrepancies are processed pursuant to S&L Project Instruction PI-BB-59, " Documentation of Cable separation Criteria Violations". Processing involves the forwarding of cable tray separation discrepancies to an S&L Electrical Project Engineer responsible for electrical cable tray separation for review and dispositioning. The S&L Project Engineer is responsible for analysing t the separation discrepancies to determine whether they are acceptable or whether rework of the cable tray is required.
As of November 7, 1985, approximately 80% of the Unit 1 areas containing safety related cable tray have been walked down. Of the total areas which have been walked down, approximately 55% of the marked up (0541H) November 22, 1985
drawings for these areas have been reviewed for violations of the separation criteria. Within the population of reviewed drawings, one hundred and seventeen, (117) installations have been identified with less than the required separation distances between safety related and non-safety related cable trays and/or raceway. Eighty-one of these 117 installations were previously identified and addressed by S&L during its design process. The remaining thirty-six (36) discrepancies identified to date during the walkdown have been submitted to S&L project Engineering for processing as directed by pI-BB-59. The evaluation of these discrepancies is presently on going.
The cable tray walkdown program, when completed, will include an examination and review of 1001,of all previously installed L. K. Comstock safety related cable tray to ensure that the cable tray system will be in conformance with existing electrical separation cosmitments. Completion of the walkdown phase of the program is expected by January 1986 and evaluations and rework, if necessary, will be completed thereafter. In addition, L. K. Comstock procedures regarding the installation and inspection of safety-related cable tray are currently being revised to expand and clarify the electrical separation requirements. The revisions will address the maintenance of the electrical separation criteria with respect to installation tolerances.
(0541H) November 22, 1985
REFERENCES l
- 1. NRC Construction Appraisal Team Inspection Report 50-4.56/04-44, 50-457/84-40 (pages A0002984-3121). 1
- 2. C.g. Morelius (NRC) letter to Cordell Reed, dated 4-11-85, transmitting Notice of Violation (pages A0003122-3126).
- 3. Sargent and Lundy Project Instruction PI-BB-77, " Cable Tray Walkdown Procedure", Revision 0, dated 10-12-84.
- 4. Licensing file on Item 84-44-06, Cont. 10.D (pages A0008655-8694).
- 5. Sargent and Lundy Project Instruction PI-BB-59, " Documentation of Cable Separation Celteria Violations".
(0541H) November 22, 1985
SPECIFIC INTERROGATORY 6 CONTENTION ITEN 12.B.1 The " Piping Heat Number Material Traceability Verification Program (NTV)" was addressed in the detailed "Naterial Traceability Verification" report provided to Intervenors and incorporated in Applicant's respose to Specific Interrogatory 7 of Intervenors' second set. The " Instrument Retrofit Program (IRV)" was addressed in Applicant's response to Specific Interrogatory 7 of Intervonors' second set.
\
0455H/ November 20, 1985
Specific Interr~gatery 7 Please describe in detail the following corrective actions, corrective action programs, or other actions with regard to quality assurance, construction or procedural defielencies at Braidwood:
A. Braidwood Construction Assessment Program (BCAP)
B. The " top twenty" corrective action programs at Braidwood identified in the April 8, 1985 correspondence from David H. Smith to James C. Keppler.
C. The " Ongoing Corrective Action Programs" identified in Appendix B to the BCAP June 1984 program description transmitted by James J. O'Connor to James C. Keppler by letter of June 22, 1984.
As to each please identify its relationship to the items or subparts of the amended quality assurance contention including the extent, if any, to which it is relied upon as evidencing the absence of a significant breakdown in quality assurance or the ability of safety-related parts, components or systems to meet regulatory requirements or perform their intended function in service. As to each please detail the purpose and objectives, organization, methodology, procedures, staffing, implementation, results, conclusions and evaluation of effectiveness. Pleare identify any documents which reflect these ansv9rs, including program descriptions, procedures, organizational charts, data, observation, inspection or evaluation forms or documents, and interim or final reports.
RESPONSg Applicant's First Partial Response to Intervenors' Second Set of Interrogatories and Requests to Produce addressed the portion of this interrogatory which requests Applicant to describe the identified corrective action programs. The following response addresses the remainder of Specific Interrogatory 7. Applicant denies that there was or is a significant breakdown in quality assurance at Braidwood as asserted in the interrogatory. The NRC staff inspection reports, on which the Quality Assurance Contention is largely premised, make no finding of a "significant breakdown of quality assurance." Moreover, the (0529H)/ November 22, 1985
I l
Specific Intercrantory 7' !
I l
1 matters described in the subparts of the contention either considered l l
singly or as a whole do not constitute such a breakdown. I&g Inspection !
Report 82-05 refers to "a breakdown of your quality assurance (QA) l program as it relates to the installation and installation inspection of mechanical safety-related equipment" which occurred in 1982. The Applicant's response to the issues identified in Inspection Report 82-05 is found in its response to specific Interrogatories 24, 51, and 58 and 59, Contention Items 1.A, 6.A. 8.A 10.A 11.A. 12.A, and 13.A of Intervenors' first set. "Certain " corrective actions" and " corrective action programs" initiated in response to Inspection Report 82-05 are discussed below.
Specific Interrogatory 7 requests Applicant to " identify [the corrective action's or corrective action program's] relationship, if any, to the items or subparts of the amended quality assurance contention."
The relationship between a corrective action program and Intervenors' amended quality assurance contention depends on the evidentiary presentation made my each party and the scope of the contention allowed by the Board. In its Memorandum and Order Admitting Rorem, 31_31 Amended Quality Assurance contention, LBP-85-20, NRC (June 21, 1985), the Licensing Board ruled thats t
i "The limits of the contention are controlled by the specific
- alleged occurrences of deficiencies set forth in the lettered paragraphs, despite broad language in the preamble and the i numbered paragraph which introduces each of the 14 Appendix B
! criteria groupings of alleged violations."
(0529H)/ November 22, 1985
. . . , - - , ,,,a.,~.-, ,---,---...--.--,-,,,,,_n,__.,,___,_,_-n_,,n,r,,,.n,--_,,_,,,n , - . . , , - , , - , - , - , - - -
Specific Interroastery 7 :
LBP-85-20 (slip op. p. 7, n. 3). See also ID. (slip op. p. 12. n. 6).
On this basis, specific contention items are identified to which an identified " corrective action" or " corrective action program" is related.
i i
The purpose and objectives, organization, methodology, procedures, staffing, implementation, results, and conclusions of BCAP are detailed in the " Report on the Braidwood Construction Assessment Program (BCAP)"
- dated November 1985. Applicant's evaluation of the effectiveness of BCAP is stated in the report on the Program transmitted by letter from Mr.
Louis 0. De1 George to Mr. James Keppler dated November 18, 1985. In 4
-addition Applicant's Quality Assurance Department has provided an evaluation of the effectiveness of the BCAP, which is sununarised in Appendix C of the Report on the Braidwood Construction Assessment Program.
i.
The subparts of the Amended Quality Assurance Contention which have
! a relationship to BCAP are 1.B. 125, 12F, and 12J.
Ceco presently intends to rely upon the fact that the BCAP was performed, and that the BCAP was performed subject to quality assurance oversight, in responding to contention item 18. These facts will be used as evidence of Ceco's management's involvement in and support of the Ceco QA program, and as evidence of management's conunitment to ensure that all safety-related activities performed by contractors' personnel are in accordance with regulations, codes, standards, and license requirements.
l 4
(0529H)/ November 22, 1985 ,
.,n---. ,, - -.,,,_..,m. . . _ , . , . _ _m.. . . , , ,_,,n.,--., ., -____,,-..,.,.,,,m,,..
Specific Interrogatory 7
, Ceco also intends to make an evidentiary presentation in response to contention items 12E, 12F, and 12J. (More detailed information with respect to these contention items was presented in Ceco's response to Rorea's First Set of Quality Assurance Interrogatories and Request to produce (Specific Interrogatories 58 and 59) and in Ceco's response to Rorea's Second set of Quality Assurance laterrogatories and Requests to Produce, (Specific Interrogatories 2 and 3).)
Ceco does not presently intend to rely upon the BCAP results and conclusions as evidencing the ability of safety-related parts, components, or systems to meet regulatory requirements or perform their intended safety functions. This intention is based on an understanding of the issues raised in the contention and the ASLB's ruling, described above, limiting the matters in controversy in this case. This position could, of course, change in whole or in part over time as Ceco's affirmative case is developed and Ceco may rely on portions of the data accumulated in the BCAP program to demonstrate that safety-related parts, components and systems meet regulatory requirements or perform their intended safety functions. Notice of any such change will be provided promptly to the parties and the Board.
Even though Ceco does not presently expect to rely on the BCAP results and conclusions in its affirmative case responding to any contention item, it may have to perform a limited comparison of its '"
affirmative case (as that case is developed) with the BCAP findings and
-4 (0529H)/ November 22, 1985
Specific Interromatory 7 l
1 observations to comply with the duty of full disclosure, as articulated by the Appeal Board in Duke Power Company (Williams B. McGuire Nuclear Station, Units 1 and 2) ALAB-143, 6 ABC 623 (1973). Ceco has not yet performed the review necessary to determine its disclosure obligation, and cannot do so until it further develops its affirmative case.
The BCAP documents called for by the last sentence of this
- interrogatory are voluminous (hundreds of file drawers). Indices will be provided in the near future. All the requested BCAP documents (other than privileged documents) will be made available upon reasonable notice for Intervonors' inspection at the Braidwood site or, in the case of certain Sargent & Lundy documents, at Sargent & Lundy's Chicago office.
IfM The MTV Program relates to amended QA contention subitem 10.8 and it is Applicant's present intention to rely on it as evidencing the ability of safety-related components to meet regulatory requirements. Two other corrective action activities ASME Material Procurement and A8ME
- nameplates, have an indirect relationship to this contention item since i ;
they were relied upon in part to support the conclusions of the MTV program.
CORRODgD PIPS The corroded Pipe corrective action program is related to Contention i
Item 11.C and it is Applicant's present intention to rely upon it as i
l (0529N)/ November 22, 1985
Specific Interrogatory 7 evidencing the ability of safety-related components to meet regulatory requirements.
SAFETY PELATED NECHANICAL EQUIPMENT The Safety Related Mechanical Equipment corrective action program is related to Contention Items 1.A. 6.A. 8.A. 10.A. 11.A. 12.A and 13.A. It is Applicant's present intention to rely upon it as evidencing the ability of safety-related components to meet regulatory requirements.
4 NEWBERG WELDING PROGRAN The Newberg Welding Program is a part of the Structural Steel Inspection Traveler (SSIT) Program. The former is related to contention Item 9.D and it is Applicant's present intention to rely upon it as evidencing the ability of safety-related components to meet regulatory requirements.
ELECTRICAL DOCUMENTATION REVIEW The Comstock Document Review corrective action program is related to contention Item 6.5.5 and it is Applicant's present intention to rely upon it as evidencing the ability of safety-related components to meet regulatory requirements.
IRY.
The Instrument Retrofit Verification (IRV) is related to Contention Item 12.B.1 and it is Applicant's present intention to rely upon it as (0529H)/ November 22, 1985
Specific Interroaatory 7 evidencing the ability of safety-related components to meet regulatory requirements.
OC885
)
The Quality control Structural Steel Review is related to Contention item 3.5 and it is Applicant's present intention to rely upon it to support the conclusion that the discrepancies discussed in Contention Item 3.3 were isolated.
l contention It--- 1.5 and 14.5 In regard to contention Item 1.B. the following corrective action programs are bases for management confidence that safety related activities performed by contractor personnel are in accordance with regulatory requirementet BCAP, MTV, Corroded Pipe, safety Related Mechanical Equipment. Welded and Bolded Connections - Block Wall Columns, Quality control Structural Steel Review (QCSSR), and Instrument Retrofit Verification (IRV).
In regard to Contention Item 14.5, there may be instances in which certain corrective action programs were relied on as a substitute for audits that did not cover certain quality assurance procedures for certali periods. In such cases, Ceco is not relying on the results of the corrective action program in question to demonstrate the ability of safety-related parts, components or systems to meet regulatory requirements or perform their intended function in service.
(0529H)/ November 22, 1985
Specific Interroaatory 7 Other Corrective Action pronrams It is the Applicant's position that the remaining corrective action programs described in Applicant's previous response to Specific Interrogatory 7 are not related to any of the items or . abparts of the Amended Quality Assurance Contention, r
i 1
1 8
(0529H)/Wovember 22, 1985
UCITED STATES OF AMERICA NUCLEAR RECULATORY COMMTSSION l
BEFORE THE ATOMIC SAFETY AND LICEN3ING BOARD In the Matter of )
)
ColeIONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood station Units 1 and 2 )
AFFIDAVIT OF LOUIS 0. DELGMMY I, Louis 0. DelGeorge, being first duly sworn, depose and state as follows:
- 1. I an employed by Commonwealth Edison company as an Assistant Vice President.
- 2. My business address is One First National Plaza, P.O. Box 767, Chicago, Illinois 60690.
- 3. I have participated in the preparation of the response to the second set of Quality Assurance Interrogatories and Requests to Produce filed by Intervenors Rorem 31 31 In particular, I have responsibility for the responses to specific Interrogatories 1 & 7 and the portion of the response to specific Interrogatory 6 dealing with INFO.
- 4. To the best of my knowledge and belief, the responses identified above are true and correct.
Further affiant sayeth not.
,Q Louis 0. De1 George
[
Subs bed to and Sworn before me thi y of Novembe 1985 Q -
ht.4u ,
.v w My consilssion expires on MNemmlesionEmp'res April 19,1944 0444N/13
UNITED STATES OF AMERICA l NUCLEAR REGULATORY COf911SSION BEFORE THE ATOMIC SAFETY AND LICENSIWG BOARD In the Matter of )
)
COf900NWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF KENNETH T. KOSTAL I, Kenneth T. Kostal, being first duly sworn, depose and state as follows:
- 1. I an employed at Sargent & Lundy, the Architect-Engineer for the Braidwood Nuclear Station, as Assistant Manager of the Structural Department and project Director for the Braidwood Nuclear Station.
- 2. My business address is 55 East Monroe Street, Chicago, Illinois 60603,
- 3. I have participated in the preparation of the response to specific Interrogatories Numbers 2 and 4 filed by Intervenors Rorem et. al in their Second Set of Quality Assurance Interrogatories and Requests to produce. In particular, I have responsibility for the portion of the response to specific Interrogatory 2 dealing with the Sargent & Lundy response to contention Item 5.A and the portion of Specific Interrogatory 4 captioned " Nuclear Coating Applications."
- 4. To the best of my knowledge and belief, the portions of the response to specific Interrogatories 2 and 4 identified above are true and correct.
Further affiant sayeth not.
. /
,, f
( I / 't
'Kenneth T. Kostal k
Subscribed to and Sworn before me this 2 ;f/ day of Nove ber 1985
.L06.m < nh My commission expires on My Currtrinten fu,Vrn Aorl!19.1998 (0120C)
.. - . ._ - - . _ _ _ . -.- -- . _ . . . - - - - - - .~ _
n a
UNITED STATES OF AMERICA NUCLEAR REGULATORY C00511SSION E
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
,# )
C01500NNEALTH EDISON COMPANY ) Docket Mos. 50-456 1
) 50-457 (Braidwood Station Units 1 and 2 )
i AFFIDAVIT OF EDWARD M. SHEVLIN i
I, Edward M. Shevlin, being first duly sworn, depose and state as follows:
, 1. I an employed by Daniel International Corp. I am currently acting as a contract employee in Phillips, Getschow guality control compliance Group. From July 1984 to July 1985 I was assigned as the BCAP Lead Mechanical / Welding Inspector (ANSI
- Level III).
- 2. My business address is Braidwood Nuclear Power Station, Bracev111e, Illinois 60407.
- 3. I have participated in the preparation of the response to i
specific Interrogatory Number 2 filed by Intervenors Rotes 3L,
& in their Second set of Quality Assurance Interrogatories and Request to Produce. In particular, I have joint responsibility (with Robert L. Byers) for the portion of the response to j specific Interrogatory 2 addressing BCAP Task Force activities
, related to contention Item 12J.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 2 identified above is true and correct.
Further affiant sayeth not.
m) (Ybb Subscribed to and sworn before me this.7#so day of ember 1985 b,u N 3xdv 4 My commission expires on MyCommission tapires April I9, I948 (0123C)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL A. GORSKI I, Michael A. Gorski, being first duly sworn, depose and state as follows:
- 1. I an employed by consonwealth Edison Company as a Project Construction Department Field Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of.the response to Specific Interrogatory Number 2 filed by.Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the portion of the response to specific Interrogatory 2 dealing with Commonwealth Edison's response to Contention Item 5.A.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 2 identified above are true and correct.
Further afflant sayeth not.
%LJa.Lh Michael A. Gorski subscribed to and Sworn before me this ;24 day of November 1985 tb>i , , e t" l
My conmission expires on
~
Mo~minissien Expires April 19.1938 Y
0547H/10
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l l
In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
. - ) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF JAMES W. GIESEKER I, James W. Gieseker, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as a Project Construction Department Field Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407,
- 3. I have participated in the preparation of the response to the 4
Specific Interrogatory Number 2 filed by Intervenors Rorem et. al. in i their Second Set of Quality Assurance Interrogatories and Request to Produce.
I have responsibility for the portion of the response which concerns the QC Inspector Harassment Contention.
2
- 4. To the best of my knowledge and belief, that portion of the
, response to Specific Interrogatory Number 2 identified above is true and correct.
Further affiant sayeth not.
(A).
pas)W. Giesinker subscribed to and Sworn before me this M'May of November 1985 h
l i l:-rLt :> I-, , c (G 4
My commission expires on 6bission Exp*res' April 1p,1933 0444H/14
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL J. WALLACE I, Michael J. Wallace, being first duly sworn, depose and state as follows:
- 1. I am employed by Consonwealth Edison Company as the Project-Manager at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
3.. I have participated in the preparation of the response to Specific Interrogatory Number 2 filed by Intervenors Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Requests to Produce. .In particulaI, I have responsibility for the portion of the response to specific Interrogatory 2 1ealing with Contention items 1.B.
1.C, 1.D 1.E and 1.F.
{- 4. To the best of my knowledge and belief, the portion of the response to specific Interrogatory Number 2 identified above are true and correct.
Further affiant sayeth not.
) '
Michael J. We ace Subscribed to and Sworn before me this d2,2 Zday of November 1985 y }6lt a , '., 106- -
My connission expires on My Commiaton Expires AprilIpjipeg l
l 0547H/11 l
i l
1 UNITED STATES OF AMERICA l NUCLEAR RPGULATORY COPMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l In the Matter of )
)
COfMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 l
) 50-457 (Braidwood Station Units 1 and 2 )
I AFFIDAVIT OF NEIL P.-SMITH I, Neil P. Smith, being first duly sworn, depose and state as follows: ,
- 1. I an employed by commonwealth Edison company as Site General Supervisor Quality Assurance at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 2 filed by Intervenors Rorem et.
al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. In particular, I have responsibility for the portion of the response to Specific Interrogatory 2 addressing BCAP Quality Assurance activities related to contention Item 12J.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 2 identified above is true and correct.
Further affiant sayeth not, b f/ ,/ .t
, Subscribed to and Sworn before me this d h h day of November 1985
/Ju,u.Y A My commission expires on MExpires April 19,1988 (0122C)
UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION l
. I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l l
l In the Matter of )
) l COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
^ ~
) 50-457 (Braidwood Station" Units 1 and 2 )
AFFIDAVIT OF KEITH A. MILLER I, Keith A. Miller, being first duly sworn, depose and state as follows:
- 1. I am employed by Comonwealth Edison Company as a Quality Assurance Inspector at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, ,
Braceville,-Illinois 60407. '
- 3. I have participated in the preparation of the response to specific Interrogatory Number 3 filed by Intervenors Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which
. updates Applicant's response to Interrogatories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Item 9.A.
- 4. To the best of my knowledge and belief, the portion of the ,
response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
l
,- D, _" , , --
DJ
, Subscribed to and Sworn before me thisL @ day of Nov ber 1985 1$t+v My comission expires on l Idh Coeurdssion Empires AprH 1p, I p88 l
)
0444H/7 l l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF DAVID A. BOONE I, David A. Boone, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as a Consultant at Braidwood Nuclear Station.
- 2. M/ business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 3 filed by Intervenors Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervonor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Items 6.F, 10.C and 10.E.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
o Subscribed to and Sworn before me :
thiefiG'iday of November 1985 '
N -
rX_ .; f.? >?1 . , mn& \
l l
My commission expires on MssionExpires April 19,1933 0444H/l w _
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7 In the* Matter of )
} I COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 i
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF ERIC S. STECKHAN I, Eric S. Stockhan, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as a Quality Assurance Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station.
Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 3 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Items 12.C, 14.B.1 and 14.B.3.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
} &
.?G .
Subscribed to and Sworn before me thisI b day of November 1985 Q kM vika o mus Ecininialinheires Aedl19dtpa
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Hatter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL R. DOUGHERTY I, Michael R. Dougherty, being first duly sworn, depose and state as
.follows:
- 1. I am employed by Conunonwealth Edison Company as a Consultant at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station,
, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 3 filed by Intervonors Rorem et. al. in their Second Set of Qu;:lity Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Itams 6.A 6.D 8.A and 10.A.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
6t1
/
Subscribed to and Sworn before me this #thay of Nov , e 1985 Q. . /:
- A_;{c,a W . s-nt/ v My conunission expires on My Coinininidn Expires April 17,1988 0444H/3
. . _ _ _ _ m UNITED STATES OF AMERICA
] NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
i
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 l- (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF DEAN A. HOFFER k I, Dean A. Hoffer, being first duly sworn, depose and state as follows:
- 1. I an employed by Commonwealth Edison Company as Quality Assurance Supervisor at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville Illinois 60407.
- 3. I have participated in the preparation of the response to the i Specific Interrogatories Number 3 filed by Intervenors Rorem et. al. in i their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatory 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Item 6.B.S.
- 4. To the best of my knowledge and belief, the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
eo s , h , sh./N Dean A. Hoffer /
Subccribed to and Sworn before me this72Wday of Novesaber 1985
~
f 'y M~ (;. a v ..:, . )js-w/ -
My connaission expires on kCemminienExp*res Api:19, Ipa 8 0444H/12
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF JAMES W. GIESEKRR I, James W. Gieseker, being first duly sworn, depose and state as follows:
- 1. I an employed by Commonwealth Edison Company as a Project Construction Department Field Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparat. ion of the response to Specific Interrogatory Number 3 filed by Intervonors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Items 3.C, 9.C and 10.F.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
!1d'L1bi YAbVEkit.
/
Subscgibed to and Sworn before me t s# E"/ day of November 1985
', uf&
~ ?;& ,t t , -/ hm/s My coamission expires on My Commission Empires A,cril 19,1988 0444H/5
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
?
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF WALTER J. MARCIS I, Walter J. Marcis, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as Quality
- Assurance Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I am responsible for the list, provided with Applicant's response to specific Interrogatory 3 of Intervenor's Second Set of Interrogatories and Request to Produce, which identifies the Site Quality Assurance Surveillances and Audits performed on Contention item issues since Applicant's response to Specific Interrogatories 58 and 59 of Intervenor's First Set of Interrogatories and Request to Produce.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above are true and correct.
Further affiant sayeth not.
WOA.<. 2 Walter J.(jharcis Subscribed to and Sworn before me thisA'k'9 day of Novem e 1985
- is ,a - &"
My connaission expires on M9'Cemminion Ex'p3rei Asrii19; 19sa l l
l 0547H/12 l
1
l UNITED STATES OF AMERICA !
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF THOMAS E. QUAKA I, Thomas E. Quaka, being first duly sworn, depose and state as follows:
- 1. I am employed by consonwealth Edison Company as a Quality Assurance Superintendent at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to specific Interrogatory Number 3 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervonor's First. Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to contention Item 14.B.2.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
w 0
l" Subscribed to and Sworn before me thisdM d day of No ember 1982 Ecc h My conmission expires on My CommiEon Expires April 19,198g 0444H/9
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
, COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL A. GORSKI I, Michael A. Gorski, being first duly sworn, depose and state as follows:
- 1. I an employed by Connonwsalth Edison Company as a Project Construction Department Field Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 3 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Items 6.B.1, 6.B.2, 6.B.3, 8.E and 12.B.l.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not.
N.
Subscribed to and Sworn before me this d hday of No her 1985
- e. 4
- __, L Q ,wr e t ' -> r u l" My conmission expires on 4 Qe'Jnissien Expires April 19,1988 i
0444H/6
UNITED STATES OF AMERICA 4
NUCLEAR RSCULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSTNG BOARD In the Matter of )
) i COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 i
) 50-457 j (Braidwood Station Units 1 and 2 )
i AFFIDAVIT OF RICHARD J. FARR I, Richard J. Farr, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as a Project Mechanical Construction Supervisor at Braidwood Nuclear Statien.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 3 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Items 3.B and 6.B.4.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
Further affiant sayeth not, m
t'* M&f /~~dsy
&7 Subscribed to and Sworn before me thia # B day of November 1985
(^ Q /. /s' V, . < /
/ / l't ,,c r
- - %: .>n /Q_,
My commission expires on
~
WComTm sienExifres A.erlf19,I988 0444H/4
- -_ -- _ .- - - - _ =
- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF PERRY L. BARNES I, Perry L. Barnes, being first duly sworn, depose and state as follows:
- 1) I am employed by consonwealth Edison company as a licensing engineer at the Braidwood Nuclear Power Station.
- 2) My business addaess is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3) I was responsible for providing updated information on whether the NRC has changed the status of the Items contained in Intervenor's Quality Assurance contention since applicant flied its response to Specific Interrogatories 58 and 59 from Intervonors' First Set of Quality Assurance Interrogatories and Request to Produce. To the best of my knowledge and belief, the updated information concerning the NRC status of Contention Items contained in Applicant's response to Specific Interrogatory 3 of Intervonors' Second Set of Quality Assurance Interrogatories and Request to Produce is true and correct.
In some respects, my determinations are not based on my personal knowledge but upon information provided by other Consonwealth Edison employees, consultants and contractors. Such information has been '
reviewed in accordance with Company practice and I believe it to be reliable.
Further affiant says not.
.,4+6'$ e' PerryM.. Barnes Signed and Sworn to before me this [ i day of, November 1985 C , w wA ,
- 'i b4u N a m/-
My conmission expires Jny Comminion Empires April 19, I 988, 5
0456H l
i
l l UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L
In the Matter of )
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 l ) 50-457 I
(Braidwood Station Units 1 and 2 )
l l- AFFIDAVIT OF JAMES PHELAN I, James Phelan, being first duly sworn, depose and state as follows:
4
- 1. I am employed by Connonwealth Edison Company as a Project Field Engineering Supervisor at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
l.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 3 flied by Intervenora Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Request to l Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrogatories 58 and 59 from
,. Intervenor's First Set of Quality Assurance Interrogatories and Request
(, to Produce as that response pertains to Contention Items 8.B. 8.C and l 10.D.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 identified above is true and correct.
l Further affiant sayeth not.
Subscribed to and Sworn before me this 2 0'idsy of November 1985 1: c~ ak.)' ~n ,
hy cotunission expires on My Commission Exp'res April 19,1733 0444H/8
1 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION i 1
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i 4
In the Matter of ) i
) !
, COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456 ;
!' ) 50-457 ;
(Braidwood Station Units 1 and 2 )
- l AFFIDAVIT OF JOSEPH D. DIERBECK I, Joseph D. Dierbeck, being first duly sworn, depose and state as
- follows:
- 1. I am employed by Commonwealth Edison Company as a Project Construction Departner.t HVAC Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to
( Specific Interrogatory Number 3 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce. I have responsibility for the portion of the response which updates Applicant's response to Interrovtories 58 and 59 from Intervenor's First Set of Quality Assurance Interrogatories and Request to Produce as that response pertains to Contention Items 3.A.1, 3.A.2 and 3.A.3.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 3 idc.hifled above is true and correct.
Further affiant sayeth not.-
0 ?
v u Sub.sc ibed to and Sworn before me thi 4/ day of No em 1985
_1 t%, i sd-My commission expires on Mf Commission Empires April 19,1988 i
l l- 0444H/2 i
UNITED STATES OF AMERICA 4
NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD d
In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 l (Braidwood Station Unita 1 and 2 )
AFFIDAVIT OF DAVID A. BOONE I, David A. Boone, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as a Consultant at Braidwood Nuclear Station. ,
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407,
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 4 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the portions of the response to Specific Interrogatory 4 captioned " Pipe Support Installation and Welding" and "Small Bore Pipe Wall Thickness".
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 4 identified above are true and correct.
Further affiant sayeth not.
Ib David A. Boone Subscribed to and Sworn before me this d oday of November 1985
- r. Le , o +
Yk.%> .elv My commission expires on Wy Commieskin Emp;res April 19,1988 0547H/9
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Mos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF GEORGE F. MARCUS I, George F. Marcus, being first duly sworn, depose and state as follows:
- 1. 'I am employed by Conunonwealth Edison Company as Assistant to the Manager of Quality Assurance at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 4 filed by Intervonors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the Introductory portion of the response to Specific Interrogatory 4.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 4 identified above is true and correct.
Further affiant sayeth not.
rgeW. Marcus subscribed to and Sworn before me this U raday of No , ember 1985 O/'tlen_c + - n t*
My commission expires on 45Conuninion Expires April 19,1988 0547H/1
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL R. DOUGHERTY I, Michael R. Dougherty, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealt? Edison Company as a Consultant at Braidwood Nuclear Station. l 1
2.- My business address is Braidwood Nuclear Power Station,
-Bracev111e, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 4 filed by Intervenors Rorem et. al. in their Second set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the portion of the response to Specific Interrogatory 4 captioned " Steam Generator Bolting".
- 4. To *he best of my knowledge and belief, the portion of the response to specific Interrogatory Number 4 identified above are true and correct.
Further affiant sayeth not.
k .1 k MichaelR.D%herty subscribed to and Sworn before me thimU % dday of N ember 1985 h.A jj L ti "J\'-/' 3
' tlV \
My commission expires on My CommhelonEmpires April 19.1988 0547H/6
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF WILLIAN L. HARTIG I, William L. Hartig, being first duly sworn, depose and state as follows:
- 1. I an employed by Conunonwealth Edison Company as Senior Quality Inspector at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the responses to the Specific Interrogatories filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Request to Produce.
In particular, I have responsibility for the response to Specific Interrogatory 5 which provides a description of the Braidwood Site " Unit Concept Inspection Program".
- 4. To the best of my knowledge and belief, the response to Specific Interrogatory 5 as described above is true and correct.
Further affiant sayeth not, s ,
t William L. Hartig Subscribed to and Sworn before me thisMo day of November 1985
' , (t,r1 - rrsiv .
My consission expires on DMN*res April 19.198a 0444H/11
I UNITED STATES OF AMERICA I 4
NUCLEAR REGULATORY COMMISSION i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
l In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF JAMES F. PHELAN I, James F. Phelan, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as Project Field 4
Engineering, Electrical Engineering Supervisor at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Bracev111e, Illinois 60407.
- 3. I have participated in the preparation of the response to the Specific Interrogatories Number 6 filed by Intervenors Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Request'to Produce. I have' responsibility for the portion of the response to Specific Interrogatory 6 captioned " Cable Tray Separation Walkdown Program".
- 4. To the best of my knowledge and belief, the response to Specific Interrogatory Number 6 identified above is true and correct.
Further affiant sayeth not.
' ~
x James F. Phelan Subscribed to and Sworn before me this ^g Dday of ov e 1985 Lt.x. e t&
l
} My comunission expires on My Comminion Expires April 19,1988 0444H/15 I
UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL R. DOUGHERTY I, Michael R. Dougherty, being first duly sworn, depose and state as follows:
- 1. I am employed by Consonwealth Edison Company as a Consultant at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 6 filed by Intervenors Rorem et. al. in their Second Set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the portion of the response to specific Interrogatory 6 captioned " Mechanical Equipment Disassembly and Inspection".
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number 6 identified above is true and correct.
Further affiant sayeth not.
l k l n. a Michael 'R. Do g erty Subscribed to and Sworn before me this<22tOlay of November 1985 eieae . . a-n r t u My conunission expires on
~
My Comini lein Q Ap,,, ypj g pg, 0547H/5
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF MICHAEL J. KOPP I, Michael J. Kopp, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as Project Licensing and Compliance Superintendent at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 6 filed by Intervenors Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the portion of the response to Specific Interrogatory 6 captioned "Comstock Drawing Review.
- 4. To the best of my knowledge and belief, the portion of the response to Specific Interrogatory Number f. identified above is true and correct.
Further affiant sayeth not.
cy p Michael J. $ opp Subscribed to and Sworn before me this4%', day of Novembem1985 G (M
' 7' ei /Ec-ir t A . s > -e .k My commission expires on E '
- Empires April 19,1988 0547H/3
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l In the Matter of )
- )
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
i 4
AFFIDAVIT OF JAMES W. GIESEKER s
I, James W. Gieseker, being first duly sworn, depose and state as follows:
- 1. I am employed by Commonwealth Edison Company as the Project Manager at Braidwood Nuclear Station.
I
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific Interrogatory Number 6 filed by Intervenors Rorem et. al. In their Second Set of Quality Assurance Interrogatories and Requests to Produce. In particular, I have responsibility for the portions of the response to Specific Interrogatory 6 dealing with Contention Items 3.C and 4.B and the "Lovel I Reverification Program".
- 4. To the best of my knowledge and belief, the portions of the response to Specific Interrogatory Number 6 identified above are true and correct.
l Further affiant sayeth not.
, i W WJ1b> k &
l
\
! jdasfes W. Gieseker Subscribed to and Sworn before me l I
1,s h day o em ,1985
? Ocret 'n- 1 ,,t & 1 l
My commission expires on My Commission Empires April 19,1988 0547H/13
- _ -.-... . - . - . __ _ ___- _ =__---.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATONIC SAFETY AND LICENSING BOARD In the Matter of )
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF WALLY BRUNS I, Wally Bruns, being first duly sworn, depose and state as follows:
- 1. I am employed by Conunonwealth Edison Company as a Project Construction Department Field Engineer at Braidwood Nuclear Station.
- 2. My business address is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
- 3. I have participated in the preparation of the response to Specific .
- Interrogatory No. 7 filed by Intervenors Rorem, et. al. In their Second set of Quality Assurance Interrogatories and Request to Produce. Interrogatory 7 requests, in part, detailed descriptions of certain corrective action programs being undertaken at the Braidwood Site. In particular, I have responsibility for the description of the "Newberg Welding Program" corrective action program as identified in the April 8, 1985 correspondence from David H. Smith to James G. Keppler and/or in Appendix B to the BCAP June 1984 program description transmitted by James J. O'Connor to James G. Keppler by letter of June 22, 1984.
- 4. Some of the numbers provided for the SSIT review program on page 5 of the description referenced above should be changed to reflect further progress in the program since I initially draf ted the response. Specifically, on line 2 of page 5 "5023" should read "5300"; on line 3. "2383" should read "3849"; also on line 3, "2640" should read "1451"; on line 4, "5023" should read "5300".
- 5. With these changes, to the best of my knowledge and belief, the description of this corrective action program is true and correct.
Further affiant sayeth not.
1 hWally(LllLl Bruffi '
LU4b>0 ,
V Subscribed to and Sworn before me this O c9 day of November 1985 Q ..-l J k:.40 J LL IA W My Comunission expires on
-,-c.-
4 s .__.AnAt10_1oma 4
0427H L
Ncvembsr 22, 1985 l-I.
l UNITED STATES OF AMRRTCA I
NUCLEAR REGULATORY COMMISSION I
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of: )
COMMONWEALTH EDISON COMPANY )
) Docket Nos. 50-456 (Braidwood Nuclear Power ) 50-457 Station, Units 1 and 2) )
l CERTIFICATE OF SERVICE l
I Lisa C. Styles, one of the attorneys for Commonwealth Edison Company, certify that Applicant's Second Partial Response to Rorea's Second Set of Quality Assurance Interrogatories and Request to Produce dated November 15, 1985 have been served in the above-captioned mattne on those persons listed in the attached Service List by United States mail, postage prepaid, this 22nd day of November, 1985, except where service has been made as otherwise noted.
1 l 1 Mr. William L. Clements Herbert Grossman, Chairman Chief, Docketing and Services Administrative Law Judge ,
United States Nuclear Regulatory Atomic Safety and Licensing Board l Comunission U.S. Regulatory Conunission Office of the Secretary Washington, D.C. 20555 l Washington, DC 20555 l l
I Dr. Richard F. Cole Ms. Bridget Little Rocam ,
Administrative Law Judge 117 North Linden Street '
Atomic Safety and Licensing Board P.O. Box 208 U.S. Nuclear Regulatory Connaission Essex Il 60935 Washington, D.C. 20555 j l
l l
i I
i f 0433H L
l
Dr. A. Dixon Callihan
- Robert Guild Administrative Law Judge Douglass W. Cassel, Jr.
102 Oak Lane Timothy U. Wright, III Oak Ridge, Tn 37803 BPI 109 North Dearborn Street Suite 1300 Chicago, Il 60602 Stuart Treby, Esq. William Little Elaine I. Chan, Esq. Director of Braidwood Project Office of the Executive Legal Region III Director United States Regulatory Conunission United States Nuclear Regulatory 799 Roosevelt Road Comunission Glen Ellyn, Illinois 60137 Washington, DC 20555 4
Atomic Safety and Licensing Charles Jones, Director Board Panel Illinois Emergency Services ,
United States Nuclear Regulatory and Disaster Agency '
Cosumission 110 East Adams Washington, DC 20555 Springfield, Il 62705 Atomic Safety and Licensing Jan Stevens Appeal Board Panel United. States Nuclear Regulatory United States thaelear Regulatory Commission
- Commission 7920 Norfolk Avenue Washington, DC 20555 Phillips Buliding Belhesda, Maryland 20014
- Messenger delivery on November 15, 1985.
Y2Q m
isa C. Styles My 1
ISHAM, LINCOLN & BEALE
- Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 Dated: November 15, 1985 4
0433H
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