ML20138D324

First Response to Intervenor Second Set of Interrogatories. Related Correspondence

ML20138D324
Person / Time
Site:	Braidwood
Issue date:	11/15/1985
From:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Shared Package
ML20138D271	List: ML20138D269 ML20138D324
References
OL, NUDOCS 8512130193
Download: ML20138D324 (12)

Text

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November 15, 1985 UNITED STATES OF AMERICA 'hf((fD NUCLEAR REGULATORY COMMISSION .

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 012 g ,

In the Matter of )

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COMMONWEALTH EDISON COMPANY locket Nos. 50-456 50-457 (Braidwood Station, Units 1 and 2 NRC STAFF FIRST RESPONSE TO INTERVENOR'S SECOND SET OF INTERROGATORIES SPECIFIC INTERROGATORY

1. For each sub Control (QC)part, or item, of the contention (including the Quality InspectorHarassmentContention),pleasedescribein detail any actions, programs or factor 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 thic answer.

ANSWCO:

The vast majority of the items comprising Intervenor's Amended Quality Assurance Contention are taken directly from the Notices of Violation issued in connection with the Region III inspection reports. The Applicant's response to each of the Notices of Violation describes the actions taken to correct the problem and to preclude its recurrence.

In addition, the Applicant has submitted 10 C.F.R. 5 50.55(e) reports concerning several of the items described in the Notices of Violation which further describe corrective actions being taken by the Applicant.

8512130193 851115 PDR ADOCK 0500 6

, In addition to its regular inspection program, the Staff is monitoring extensively Applicant's adherence to the commitments made in its responses to the Notices of Violation and in its 10 C.F.R. 6 50.55(e) reports. The Staff will rely on its routine inspection program plus 4 its inspections of the Applicant's corrective actions in determining whether there is reasonable assurance that no pervasive breakdown in the Applicant's QA/QC program has occurred, and that all safety related parts, components and systems meet regulatory requirements and will perform their intended function in service.

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Subpart 1A - This part of the contention describes generally the

problems and issues identified in Inspection Report 50-456/8205; 50-457/8205("IR82-05"). The Staff's answers to Interrogatories 10 and 32 contain information related to this subpart. Subparts 6A, 8A. 10A, 11A, 12A, 13A, 14A were also derived from IR 82-05 Report.

The corrective actions taken by Applicant in response to the viola-tions noted in Inspection Report 82-05 are identified in the Appli-I cant's response to Interrogatory 58. The Staff will rely upon its evaluation of these corrective actions (which are not yet complete) in drawing any conclusions as to whether the problems described in subpart IA of the contention have been resolved satisfactorily. NRC Inspector J. Muffett has the lead responsibility for review and closure of this issue.

Part 1A of the contention addresses a failure on Applicant's part to

, file a 10 C.F.R. 6 50.55(e) report. This particular item was closed by the Staff in Inspection Report 50-456/85017; 50-457/85018 (Tracking i

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. Item No. 456/82-05-05;457/82-05-05). In addition an inspection of 4

the licensee's procedures for deficiency reporting and 10 C.F.R. 5 50.55(e) evaluations was conducted recently. This inspection resulted in the idcatification of no violations. See Inspection Report No. 50-456/85027; 50-457/85027.

I Subpart 6A - This part of the contention is derived from IR 82-05.

It has been assigned Region III Tracking Item No. 456/82-05-04; 457/82-05-04. NRC Inspector J. Muffett has the lead responsibility for review and closure of this item. As indicated above, the Staff will rely upon its evaluation of the corrective actions taken by i

Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 8A - This part of the contention is derived from IR 82-05 and has been assigned Region III Tracking Item No. 4546/82-05-04; t

457/82-05-04. NRC Inspector J. Muffett is responsible for the review and closure of this item. As indicated above, the Staff will rely upon its evaluation of the corrective actions taken by Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 10A - This part of the contention is derived from IR 82-05 and has been assigned Region III Tracking item No. 4546/82-05-04; 457/82-05-04. NRC Inspector J. Muffett is responsible for the 1

review and closure of this item. As indicated above, the Staff will rely upon its evaluation of the corrective actions taken by Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 11A - This part of the contention is derived from IR 82-05 and has been assigned Region III Tracking Item No.s 456/82-05-04; 457/82-05-04. NRC Inspector J. Muffett is responsible for the review and closure of the item. As indicated above, the Staff will rely upon its evaluation of the corrective actions taken by Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 12A - This part of the contention is similar to subpart IA and is tracked as Tracking Item No. 456/82-05-01; 457/82-05-01. NRC Inspector J. Muffett is responsible for the review and closure of this item. As indicated above, the Staff will rely upon its evalua-tion of the corrective actions taken by Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 13A - This part of the contention is derived from IR 82-05 and has been assigned Region III Tracking Item No. 456/82-05-04; 457/82-05-04. NRC Inspector J. Muffett is responsible for the i review and closure of this item. As indicated above, the Staff will

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rely upon its evaluation of the corrective actions taken by Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 14A - This part of the contention is derived from IR 82-05 and has been assigned Region III Tracking Item No. 456/82-05-04; 457/82-05-04. NRC Inspector J. Muffett is responsible for the review and closure of this item. As indicated above, the Staff will rely upon its evaluation of the corrective actions taken by Applicant in determining whether the problem identified in this part of the contention has been resolved satisfactorily.

Subpart 18 -

This part of the contention is based upon a concern expressed in a May 7,1984 letter from James G. Keppler, NRC Regional Administrator to James J. O'Connor, Ceco President and Chief Execu-l tive Officer, which transmitted NRC Inspection Report No. 50-456/83-09; 50-457/83-09. The first paragraph of subpart 18 addresses the I

Staff's concern with an apparent lack of adequate oversight on Appli-cant's part of its contractors. The second paragraph of subpart IB sets forth certain NRC identified deficiencies in the following areas:

, small bore piping hangers, HVAC welding activities and piping -

material control.

To resolve the concern expressed in the first paragraph of subpart 18, the Staff will rely on the commitments made by Applicant in Attachment C to its July 6,1984 response to Inspection Report

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No. 50-456/83-09; 50-457/83-09. Because the Staff did not determine that its concern with Applicant's possible lack of sufficient over-sight of its contractors in itself constituted a violation, no tracking number was assigned to this concern. It should be noted, however, that subsequent to the issuance of the May 7,1984 letter, the Staff's concern regarding Applicant's oversight of its contrac-tors has been alleviated in large part. In this regard, Applicant pledged to take appropriate measures to strengthen the managerial effort of its contractors. A meeting between Applicant and Region III management was convened to consider and evaluate those measures, the results of which are documented in an April 25, 1985 letter from David H. Smith, Ceco Nuclear Licensing Administrator, to James G.

Keppler, Regional Administrator. As of this writing, Region III is satisfied with the measures instituted by Applicant to strengthen management. Moreover, during its inspection activities at the site, the Staff has not observed anything to indicate that Applicant's effort has not been successful. The Systematic Assessment of Licensee Performance (SALP) report for the period of July 1,1984 through November 30, 1985 is scheduled to be issued on February 19, 1986. This SALP report will provide additional information relating to the performance of Applicant's management in the problem areas identified in Inspection Report No. 50-456/83-09; 50-457/83-09.

Applicant made extensive commitments to resolve the issues dis-cussed in the second paragraph of Subpart 18. These commitments

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, are documented in the following 9 50.55(e) reports and letters to Region III:

July 6, 1984 letter from Louis 0. DelGeorge to James G. Keppler July 23, 1984 letter from E. Douglas Swartz to James G. Keppler August 31, 1984 letter from E. Douglas Swartz to James G. Keppler March 11, 1985 letter from David H. Smith to James G. Keppler March 27, 1985 letter from David H. Smith to James G. Keppler April 25, 1985 letter from David H. Smith to James G. Kepoler August 13, 1985 letter from A. D. Miosi to James G. Keppler 10C.F.R.950.55(e) Report 83-07 In addition to its routine inspection efforts, the Staff will rely on special inspection efforts to confirm that the above comitments have been met. These special inspection efforts will be undertaken by:

J. Muffett - Small bore piping hangers and piping material control.

J. Ja;abson - HVAC welding activities.

A report documenting the results of these special inspections will issued.

r Subpart IC -

This part of the contention is derived from a Febr uary 20, 1985 letter from J. M. Taylor, Director, Office of Inspection and Enforcement to C. Reed, CECO Vice President, which transmitted the report of the Construction Appraisal Team (CAT Report No. 50-456/84-4;50-457/84-40). Subpart IC states two concerns expressed in the February 20, 1985 letter: (1) Applicant's dependence on final walkdown inspections late in the construction program to identify and resolve problems; and (2) Applicant's ability to manage the large number (approximately 20) of ongoing corrective action programs in addition to its current construction activities.

The Applicant responded to this concern on May 16, 1985. See Letter D. L. Farrar, Director of Nuclear Licensing, to J. G. Keppler, Regional Administrator, transmitting Applicant's response to Inspec-tion Report No. 50-456/84-44 and 50-457/84-40. The Staff's inspec-

, tions and contacts with Applicant up to this time indicate that Applicant is adequately staffed to carry out any necessary final walkdown inspections. The Staff will rely on inspections to resolve the concern cited in Subpart 1C of the contention.

It is not clear from the CAT inspection report which corrective action programs the CAT Team considered to be " major." A recent comparison of the number of 10 C.F.R. 9 50.55(e) reports submitted for Braidwood I with other single unit sites or the first unit of a two unit site in Region III indicates that Braidwood I has submitted 61

. reports versus an average of 96 for those nine other sites and I submitted fewer 10 C.F.R. 5 50.55(e) reports than six of the nine Region III units. Other than the Materials Traceability Verifica-tion Program (MTVP) and the programs to resolve the issues raised in Inspection Report No. 50-546/82-05; 50-457/82-05 relating to the installation of safety related mechanical equipment, Region III staff does not consider the items reported in the other 10 C.F.R. 6 50.55(e) reports to be " major" in terms of number or signifi-cance. _In any event the Staff will inspect and evaluate each of the corrective actions undertaken by the Applicant. The Staff believes at this time that the Applicant is adequately staffed and managed to satisfactorily complete this program.

Subpart ID - This part of the contention consists of four parts and is derived from the Executive Summary (Appendix A) of Inspection Report No. 50-456/84-44; 50-457/84-40. The second part is identical to the first part of Subpart IC and has been addressed above.

The first part of subpart ID relates to the CAT Team's concern regarding the effectiveness of QC inspections by Level QC inspectors in the area of pipe support / restraint and welding. The Applicant's response to the CAT report dccuments the actions being taken by Applicant to address this matter. See May 16, 1985 letter from D.

L. Farrar to J. G. Keppler; April 25, 1985 letter from D. H. Smith, Nuclear Licensing Administrator to J. G. Keppler, Regional Admini-strator. The Staff will rely on its routine inspection program

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to ensure the Appi: cant's commitments have been met and to ensure that as-built conditions meet design requirements. Recent inspec-tions of piping and pipe supports in Inspection Report 50-456/85032; 50-457/85031 did not' uncover any problems in this area.

The thi'rd part cf subpart 10 deals with the CAT Team's concerns

- about. cable' tray and conduit electrical separations. The Appli-

-cant's response to this concern is documented in the previously s referenced iesponse to the CAT inspection report. This concern has been refer, red to the NRR Office,of Nuclear Reactor Regulation (NRR)forresdlution. Region III Inspection Report No. 50-456/82058; 50-457/85028 and a CECoiletter dated July 15, 1985 from B. J.

Youngblood, NRR Branch (hief to D. L. Farrar, CECO Director of Nuclear Licensfhg, docunent an NRR visit to Braidwood resulting in a request for additional technical analysis from CECO. NRR will reviewtheanalysiswtlichfiasbeen,submittedandissuea. supplemental

. Safety Evaluation Report (SSER). '

The fourth part of subpart ID deals with the CAT Team's concerns about a excessive r,smber of iricidents of damage to installed equip-ment. The Applicant's response'to this concern is documented in the previously referenced response to the CAT inspection report.

. The Staff will continue to monitor this area, and take enforcement action to prevent recurrence. The Staff will rely on its inspections of plar't conditions and Applicant's preoperational test program to 4

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. ensure that safety related equipment is not damaged and will operate as required.

Subpart IE - This part of the contention is derived from problems with the QC inspection of seismic Category I pipe supports restraints identified by the CAT Team. This subpart is the same as the first part of subpart ID and the information submitted in that part of this answer to Specific Interrogatory 1 applies. This concern resulted in a Notice of Violation transmitted in an NRC letter dated April 11,1985 from C. E. Norelius, Division Director, to C. Reed, CECO Vice President. Applicant responded to the violation is its May 16, 1985 response to the CAT report. NRC Inspectors P. Kaufman and J. Muffett will perform the inspections to resolve this issue.

This item has been assigned Region III Tracking Item No. 456/84-44-05; 457/84-40-05.

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NUCLEAR REGULATORYiC0 MISSION f I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  ;

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,j In the Matter of , , . , , , , , _ _ . ,__

Docket No. 50-456

):. COM)NWEALTH EDISON COMPANY

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b 50-457 lj (Braidwood Nuclear Power Station Units 1 and 2) h 3

AFFIDAVIT OF WILLIAM S. LITTLE d

I, William S, Little, being first duly sworn do depose and state:

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1. I am amployed as the Director, Braidwood Project, in the Division of f - Leactor Projects, U.S. Nuclear Regulatory Connission, Region !!!,

1 799 Roosevelt Road, Glen Ellyn. Illinois, 60137. ,

9 2. I have provided the answers to Specific Interrogatory 1 of the' Staff's First Partial Response to Rorem's Second Set of Quality Assurance Interrogatories.- These answers are true and corrt.ct to '

i the best of my knowledge, information and belief.

4 5 ' -

.j William 5. Littl V Sworn to p d sub cribed bef re me

l. this /0 day of s1985

$4 Notary Public

'J My Comission Expireso"?!d[#6 i

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