ML20151Z238
| ML20151Z238 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/11/1986 |
| From: | Kruse G COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE |
| To: | ROREM, B. |
| References | |
| CON-#186-070, CON-#186-70 OL, NUDOCS 8602140106 | |
| Download: ML20151Z238 (150) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LMETED USNHC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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50-456hCMI
[ :/h,7; C000tONWEALTH EDISON COMPANY Docket Nos.
)
50-457 OL BRANCH (Braidwood Station Units 1 and 2
)
APPLICANT'S OBJECTIONS AND SECOND PARTIAL RESPONSE TO ROREN'S THIRD SET OF QUALITY
_ ASSURANCE INTERROCATORIES AND REQUESTS TO PRODUCE On January 24, 1986, Intervenors Rorem, et. al. ("Intervenors")
filed their Third set of Quality Assurance Interrogatories and Requests to Produce. This submission is Applicant's Second partial response.
4 This submission consists of Applicant's response to Specific Interrogatory 9.
For each docu:nont referenced or incorporated into Applicant's response a Bates number has been provided if that document was already made available.
Additional documents and their respective numbers will be provided by February 24, 1986.
Investigation continues on Specific Interrogatory 10 which Applicant will provide as soon as possible.
Documents for which Applicant is asserting a privilege will not be providad, and an index of privileged documents will indicate whether the attorney client ("AC") or attorney work product ("WP")
privilege is being asserted.
8602140106 860211 ADOCK 0%4y6 PDR i
0 0730H/ February 11, 1986
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SPECIFIC INTERROCATORY 9 With respect to Interrogatories 58 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set, please provide any supplementation necessary in order to make your answers current and complete. -Please identify any and all documents related to such supplementation.
Response
Supplemental or updated responses with respect to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervonors' Second Set are provided on the following pages.
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i 0692H/ February 7, 1985 l
Sp*cific Intarrogatory 9 UPDATED RESPONSE - THIRD SET TO INTERROCATORIES 58 AND 59 0F INTERVENORS' a
FIRST SET AND INT 3RROCATORIES 2 AND 3 OF INTERVENORS' THIRD SBT In its sixth Partial Response to Interrogatories 58 and 59 of Intervenors' First Set of Quality Assurance Interrogatories and Requests to Produce and its second Partial Response to Interrogatory 2 of Intervenors' Second Set, Applicant made a review of Intervenors' amended Quality Assurance Contention to identify each example of a violation, unresolved item or open item with respect to quality assurance. These examples, in fact, generally restate items reported by the NRC Staff as appearing to indicata dis:repancies with respect to specific ' provisions of 10 CFR 50 Appendix B.
Each of those items were addressed in the j
original response to these Interrogatories.
In addition, Applicant's original response to Interrogatories 58 and 59 was updated, where 4
necessary, in response to Interrogatory 3 of Intervenors' Second Set.
In this part of the Response to Interrogatory 9, Applicant is providing updated and current icformation with respect to the identification, investigations and corrective action taken for each Contention Item. Not all Contention Items have had a status change since the filing of Applicant's original and initial updated responses 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.
l l 0692H/ February 7, 1985
Sp*cific Int croKatery 9 For certain Contention Items, updated information, including references, is contained in formal reports Applicant has furnished Intervenors.
These instances are clearly identified in the updated response to the applicable Contention Item. A list of site Quality Assurance surveillances specifically performed on Contention Item issues since Applicant provided its original and initial updated responses to Interrogatories 58 and 59 and its original response to Interrogatory 2 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 Interre: stories 53 and 59 remains accurate unless specifically noted in Applicant's initial update or in this response.
- 0692H/ February 7, 1985 l
SPECIFIC INTERROCATORY 9 SITE QUALITY ASSURANCE SURVEILLANCES AND AUDITS TO SPECIFICALLY UPDATE CONTENTION ITEMS (ROREN QUALITY ASSURANCE INTERROCATORIES AND REQUEST TO PRODUCE THIRD SET SPECIFIC INTERROCATORY 9 CONTENTION NRC ITEN ISSUE ITEM 30 30.
SURVEILLANCE DATE 4A 456-84-07-02C 5175 12-12-85 5C A56-84-43-02 5278 12-16-85 68.4 456-83-09-02D 5191 12-3-85 6C 456-85-07-04 4254 2-7-86 6I 456-44-09-05 5192 12-20-85 8D 456-45-08-10C 5215 12-3-85 8E 456-85-08-108 5190 11-25-85 8F 456-45-04-10A 5214 12-3-85 9A 456-84-21-02 5314 12-31-85 9C 456-84-13-09 4680 12-23-85 9D 456-84-17-04 5361 1-7-86 10F 456-85-15-08 5186 12-23-85 11D 456-84-07-05 5206 12-13-85 135 456-84-43-01 5177 1-20-86 148.1 456-83-09-08A 5211 12-16-85 14B.4 456-43-09-00D 5286 12-31-45 0716H/ February 7, 1986
CONTENTION ITEM 1.A 1.
Contrary to criterion I, " Organization" of 10 C.F.R. Part 50, Appendix B, Comunonwealth Edison has failed to effectively oversee the quality assurance activities of t
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.
A.
On February 2, 1983 Commonwealth Edison Company was cited a $100,00 civil Penalties for severity level III violations at Braidwood " evidenced by a breakdown of your quality assurance (QA) program as it related to the installation and installation inspection of mechanical safety-related equipment." (Keppler (NBC) to O'Connor (CRCo) transmitting Notice of Violation and Proposed Imposition of Civil Penalties, Exh. 3.)
The serious f
quality assurance deficiencies involved activities by the l
site mechanical equipment. Installation contractor, Phillips, Getschow Company, and related to the installation of the four Unit 1 Steen Generators, the four l
Unit 1 and 2 Residual Heat Removal Pumps and the four safety Injection Pumps. Edison failed to take timely and effective corrective action after identifying related i
significant problems that occurred at its Byron station.
Edison failed to report this significant breakdown in the l
quality assurance program to the NBC as required by 10 C.F.R. 50.55(e)(1), although it had identified the problems with Phillips, Getschow Company over 2 years earlier (Exh. 3.).
UPDATED RESPONSE - THIRD SET During an inspection in October-November 1985, NRC Inspector R.
Schuls resteued actions taken to correct this Item as described in 4
j previous rangemees. These actions were found to be acceptable and the Item was closed. The closure review is documented in Inspection Report
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Nos. 50-456/85-52 and 50-457/85-50, dated December 5, 1985.
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0642H/ February 7, 1986
CONTENTION ITEM 1.A UFDATED REFERENCES - THIRD SET 1.
NBC Inspection Report Nos. 50-456/85-52; 50-457/85-50, dated December 5, 1985.
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. 0642N/ February 7, 1986
CONTENTION ITEN 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 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.
A.
A special NRC QA inspection reported May 7, 1984 that:
- Instructions were not appropriate to the circumstances in that welding procedures specifying the essential variables were not prescribed on drawings or welding sequences (travelers) for each specific NVAC 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 - THIRD SET As initially described in the original updated response to this Contention Item, pull testing under the silicon bronze weld part of the destructive testing program was completed in early November 1985.
Evaluation of the test results have now been completed. These results show silicon bronze weld strengths to be higher than design allowables.
A similar evaluation result had previously been reached under the non-silicon bronse weld part of the destructive testing program.
l The MC Staff is expected to review the results of the silicon bronze weld part of the testing program in the near future.
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-7 0643H/ February 7, 1906 t
EONTENTION ITEN 3.4,1 VFDATED REFER 85C58 - THIRD 337 1.
Test Report SL-7002 "MVAC silicon Bronse Wold Testing Report.
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0643N/ February 7, 1986
CONTENTION ITEN 3.A.2 3.
Contrary to Criterion II, " Quality Assurance program," of 10 C.F.R. Part 50, Appendix B, Conunonwealth Edison company has failed to establish a quality assurance program which complies with the requirements of Appendix 5 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 MVAC 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 D1.1-1977, Section 3, and the Edison QA Manual. Additionally, instructions to the quality control inspectors regarding fillet weld gaps g(igg welding were not appropriate to the circumstances in that the MVAC contractor Visual Wold Inspection procedure, 310.2.F, stated that a 3/16" gap was acceptable whereas AWB D1.1-1977, section 3.3, states that a 3/16" gap is allowed only if the les of the fillet weld is increased by the amount of the separation or the contractor demonstrates that the required effective throat has been obtained.
UpDAfsD RESPONSE - THIRD SET In addition to corrective actions taken on this Contention Item as described in previous responses, PSN, under Cosumonwealth Edison's direction, perforised a destructive testing program to address welds with a lack of fitup inspeation. Welds were selected on the basis of criteria agreed to totuosa cosemonwealth Edison and the NRC staf f.
These welds were cut out and pulled to destruction to verify strength. The results of this program showed that all welds tested were above design allowables. The NRC Staff has reviewed the results of the program and has found it to be acceptable. 0444H/pebruary 7, 1986
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CONTENTION ITEN 3.A.2 In addition, during an inspection in October - November 1985, NRC Inspector Jacobson reviewed actions taken to correct this item as described in previous responses. These actions were found to be acceptable and this item was closed. This review is documented in Inspection Report Nos. 50-456/85-50 and 50-457/85-48, dated December 27, 1985.
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10-0444N/ February 7, 1984
CONTENTION ITEM 3.A.2 UPDATED. REFERENCES - THIRD stT 1.
Test Report SL-7000 "NVAC Weld Testing Report" dated October 8, 1985, with letter from H.H. Hitseman to W.E. Vahle dated October 14, 1985.
's 2.
NRC Inspectlon Report Nos. 50-456/05-50 and 50-457/05-48, dated December 27, 1985.
. 0644H/ February 7, 1986
CONTENTION ITEM 3.A.3 3.
Contrary to criterion II, " Quality Assurance Program," of 10 C.F.R. Part 50, Appendix 5. Commonwealth Edison Company has failed to establish a quality assurance program which complies with the requirements of Appendix 5 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 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 - THIRD SBT During an inspection in the fall of 1985, NRC Inspector Jacobson reviewed actions taken to correct this Item as described in previous responses. These actions were found to be acceptable and this Item was closed. The closure review is documented in Inspection Report Mos. 50-456/85-40 and 50-457/85-39, dated November 22, 1985.
i 0645H/ February 7,1984
CONTENTION ITEN 3.A.3 UPDATED REFERENCES - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-40; 50-457/85-39, dated November 22, 1985.
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l l 0445N/ February 7, 1986
CONTENTIO7 ITEM 3.A.4.B 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 4
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:
- Edison's control of site designed small bore (2" and under) process and instrumentation piping systems was considered inadequate and ineffective based on the following deficiencies:
The Phillips, Getschow small bore pipe routing procedures lacked specific quantitative field design, installation, and inspection criteria to provide clearance and/or separation from equipment and components as required by S&L specification, F/L-2739, Paragraph 301.11.
UPDATED RESPONSE - THIRD SET In preparation for Hot Functional Testing, Commonwealth Edison Startup personnel, in conjunction with sargent and Lundy, have commenced walking down the applicable piping to identify and resolve potential thermal growth interferences at ambient temperatures.
This walkdown is being performed in accordance with Braidwood Procedure DwrT-EM-10. " Pre-Operational Test / Thermal Expansion-Primary Side (EN)" as noted in Commonwealth Edison's original response. All identified cases of potential interferences are being submitted to Sargent and Lundy for evaluation and resolution.
i l 0647H/ February 5,1986
CONTENTION ITEM 3.A.4.8 UPDATED REFERENCES - THIRD SET 1.
Braidwood Procedure BwPT-EM-10. " Pre-Operational Test / Thermal Expansion - Primary Side (EN)".
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s 0647H/ February 5, 1986
CONTENTION ITEM 3.A.4.C 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 provided 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:
Edison's control of site designed small boro (2" and under) process and instrumentation piping systems was considered inadequate and ineffective based on the following deficiencies:
-- Procedure Phillips, Getschow (sic) CP 22 requirements had not been completely followed for small bore piping calculations performed by Phillips, Cetschow (sic) for lines ICCE3AA-1/2", ICCE3BA-1/2", IDOD8BC-2", and 1DOD8BA-01.
UPDATED RESPONSE - THIRD SET In addition to the review of process piping support calculations that has already been performed by Sargent and Lundy (as described in Commonwealth Edison's response to Interrogatory 28 of Intervenors' First Set as cross-referenced in the original response to this Contention Item), Sargent and Lundy has recently cossaitted to perform a review of instrumentation piping /line support I
calculations.
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l 0648H/ February 7, 1986
CONTENTION ITEM 3.A.4.E 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 control 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:
Edison's control of site designed small boro (2" and under) process and instrumentation piping systems was considered inadequate and ineffective based on the following deficiencies:
-- The Phillips, Getschow training program was considered to be inadequate and ineffective based on the numerous errors identified in the Phillips, Getschow hanger calculations.
UPDATED RESPONSE - THIRD SET An updated response to this Contention item is provided in the updated response to Contention Item 3.A.4.C of this Interrogatory 9 and is incorporated by reference herein.
. 0650H/ February 7,1986
CONTENTION ITEM 3.B 3.
Contrary to Celterion II, " Quality Assurance Program", of 10 C.F.R Part 50, Appendix B, Commonwealth Edlson 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. The 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 RESPONSE - THIRD SET During an inspection in October - November 1985, NRC Inspector R. Schult reviewed actions taken to correct this Iten as described in previous responses. These actions were found to be acceptable and the Item was closed. The closuri review is documented in Inspection Report Nos. 50-456/85-52 and 50-457/85-50, dated December 5, 1985.
. 0652H/ February 7,1986
CONTENTION ITEN 3.B UPDATED REFERENCE - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-52; 50-457/85-50, dated
'7 December 5. 1985.
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! 0652H/ February 7, 1986
CONTENTION ITEM 4.B 4.
Contrary to Criterion II, Quality Assurance Program, of 10 C.F.R Part 50, Appendix B, 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 achieve and maintained.
B.
Four L.K. Comstock weld inspectors were not proficient in American Welding Society Structural Welding Code (Inspection Report 84-07, Exh.18).
UPDATED RESPONSB - THIRD SET During a January 24, 1986 NRC Inspection Exit Briefing, WRC Inspector W. Kropp stated that he had reviewed actions taken to correct this Item as described in previous responses. Based on this review, the Inspector indicated that corrective actions appeared to be acceptably implemented and that he would close the Item. This closure review is to be documented in a forthcoming NRC Inspection Report.
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- 0655H/ February 7, 1986 I
CONTENTION ITEM 5.5 5.
Contrary to Criterion III, " Design Control," of 10 C.F.R. Part 50,' Appendix B, Conunonwealth Edison Company has failed to establish measures to assure that applicable regulatory requirements and design bases are correctly translated into.spacifications, drawings, procedures, and instructions including provisions to assure that appropriate quality standards are specified in design documents and that deviations from such standards are I
controlled. Applicant has also failed to require that measures are established for the identification and j
control of design interfaces and for the coordination 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 i
involving design interfaces; and that the design control I
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 4
4 not qualified for the Design Basis Accident in accordance with Section 5 of ANSI N101.2 (1972).
(Inspection Report 85-15, Exh. 17.)
UpDATgD RESPONSE - THIRD SET i
In addition, during an inspection from October 21 to November l
30, 1985, NBC Inspector W. Kropp reviewed actions taken to correct this item as described in previous responses. These actions were found to be acceptable and this item was closed. This review is documented in Inspection Report Nos. 50-456/05-52 and 50-457/05-50, dated December 5, 1985.
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i 0656H/ February 7, 1986 i
CONTENTION ITEM 5.C 5.
Contrary to Criterion III, " Design Control," of 10 C.F.R.
i part 50, Appendix B, commonwealth Edison Company has failed to establish measures to assure that applicable i
regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and 1
instructions including provisions to assure that appropriate quality standards are specified in design i
documents and that deviations from such standards are controlled. Appilcant 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 organisations for the review, approval, release, distribution, and revision of documents involving design interfaces; and that the design control measures provide for verifying or checking the adequacy of i
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 S&L's structural Standard Document which did not limit the slenderness ration for ceiling mounted duct supports.
(Inspection i
Report 84-43/39, Exh. 19.)
UPDATED RESPONSE - THIRD SET l
During an inspection in the Fall of 1985 KaC Inspector nuffett reviewed actions taken to correct this Item as described in previous a
responses. These actions were found to be acceptable and the Item 4
was closed. The closure review is documented in Inspection Report Nos. 50-456/85-40 and 50-457/85-39, dated November 22, 1985.
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1 0657H/ February 7, 1986
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CONTENTION ITEM 5.C UPDATED REFERENCE - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-40; 50-457/85-39, dated November 22, 1985, t
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. 0657N/ February 7, 1986
CONTENTION ITEN 6.A 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 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. 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, Getschow 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 RESPCNSE - THIRD SET An updated response to this contention Item is contained in Commonwealth Edison's prepared detailed report with respect to the i
"Rainspection of Safety Related Nechanical Equipment" corrective action program as originally described in specific Interrogatory 7 of Intervenors' Second Set. This report has already been furnished l
to the Intervonors. The report is incorporated herein by reference as a part of this contention Item update.
l l 0658H/ February 5, 1986 l
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CONTENTION ITEM 6.B.1 6.
Contrary to Criterion V, " Inst'ruction, 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 Getschow Company, Field Drawing M-2539C-4, Revision D, was not stamped with Field Change Request No. L-9194 and Field Change Request No. 9988.
UPDATED RESPONSE - THIRD SET As noted in the original update to this contention Item, an evaluation was made by Commonwealth Edison of the hardware impact of the failure to stamp various field drawings with Field Change Requests or Engineering Change Notices. This evaluation demonstrated that, although the lack of proper annotation of unicorporated ECNs and FCRs on controlled drawings is a violation of PGCo document control procedures, this situation should not be expected to have any adverse' impact on the actual hardware installation activities. The evaluation was discussed with the cognizant NRC Inspector on January 10, 1985. This item remains open with the NRC pending the review of field installation documentation. 0659H/ February 7, 1986
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 Naterial 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 - THIRD SET During an inspection in the Fall of 1985, NRC Inspector Huffett reviewed actions taken to. correct this Item as described in previous responses. These actions were found to be acceptable and the Item was closed. The closure review is documented in Inspection Report Nos. 50-456/85-40 and 50-457/85-39, dated November 22, 1985.
l 0660H/ February 7, 1986
i CONTENTION ITEN'6.5.2 UPDATED REFERENCE - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-40; 50-457/85-39, dated November 22, 1985.
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l 0660H/ February 7, 1984
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CONTENTION ITEM 6.B.3 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:
Contrary to Phillips, Getschow Company Quality Procedure, there was no documented record on log specifying that a calibrated instrument was used to measure numerous pipe bands for ovality requiring inspection measurements to the thousands of an inch.
Examples include the bends on Drawings M-2546C-22, M-2546C-44, NC-2546C-42, and M-2546C-31.
UPDATED RESPONSE - TMIRD SET
.During an inspection in October - November 1985, NRC Inspector R. Schulz reviewed actions taken to correct this Item as described in previous responses. These actions were found to be acceptable and this Item was closed. The closure review is documented in Inspection Report Mos. 50-456/85-52 and.50-457/85-50, dated December 5, 1985.
. 0661H/ February 7, 1986
CONTENTION ITEN 6.B.3 t
UPDATED REFERENCE - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-52; 50-457/85-50, dated December 5, 1985.
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CONTENTION ITEM 6.B.5 6.
Contrary to criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth 4
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:
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 - THIRD SET A partial updated response to this Contention Item is contained in Commonwealth Edison's updated response to Specific Interrogatory 7 of Intervonors' Second Set which provides an updated description of the "L. K. Comstock Document Review Program".
Commonwealth Edison Site Quality Assurance Department has continued to monitor drawing control activities of L. K. Comstock.
Cormacnwealth 3dison Surveillance No. 5316 was performed on December 26, 1985. The Surveillance concluded that L. K. Comstock continues to effectively implement corrective action necessary to preclude repetition la the crea of drawing control, l
In addition, during an inspection on October 7 through November 1. 1985, NRC Inspector P. Pelke reviewed actions taken to~
l correct this item as described in previous responses.
These actions were found to be acceptable and this item was closed. This review is documented in Inspection Report Mos. 50-456/85-051 and 50-457/85-049, dated November 20, 1985. 0663H/ February 5,1986
CONTENTION XTE'M 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 quality are prescribed by documented instructions, procedures, 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. Exhibit 14.)
UPDATED RESPONSE - THIRD SET This Contention Item was initially updated in Commonwealth Edison's response to Interrogatory 3 of Intervenors' Second Set.
In that response, Procedure PCD-25 was inadvertently identified as a PGCo Procedure and not properly identified as a Commonwealth Edison Procedure.
As a result of the NRC Staff review described in the original and updated responses, on January 21, 1986, Commonwealth Edison Project Construction Department issued a letter (No. BR/PCD 86-64) to PGCo indicating that the checklist contained in PCD-25 should be t
used by PGCo Engineering personnel when' preparing ISI drawings.
In addition, Commonwealth Edison Project Construction issued a supplemental response to the NRC Staff on this Item describing its January 21, 1986 letter to PGCo and the actions the Commonwealth Edison Production Department Pre-Service /In-Service Technical Staff group are required to take when reviewing ISI drawings received from PGCo. 0664H/ February 7, 1986
CONTENTXON ITEN 6.B.5 UPDATED REFERENCES - THIRD SET 1.
Ceco Quality Assurance Surveillance 5316, dated December 26, 1985.
2.
NRC Inspection Report Nos. 50-456/85-051; 50-457/85-049, dated November 20, 1985.
. 0663N/ February 5, 1986
CONTENTXON ITEM 6.C Based on this additional information and on the corrective j
actions described in previous responses to this Contention Item, NRC Inspector R. Schulz indicated, during a January 24, 1986 NRC Inspection Rxit Briefing, that he would close this item. This closure review is to be documented in a forthcoming NRC Inspection Report.
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! 0664H/ February 7, 1986
CONTENTION ITEM 6.C UPDATED REFERENCES 1.
Commonwealth Edison Project Construction Department letter No.
BR/PCD 86-64, dated January 21, 1986.
2.
Commonwealth Edison Supplemental Response to NRC, on item number 50-456/85-07-08; 50-457/85-07-08, dated January 24, 1986.
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CONTENTION ITEM 6.D 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, i
procedures, or drawings.
D.
Support plates were installed between the concrete pedests1 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, rurthermore, these additional plates were not identified during quality control installation inspections.
(Inspection Report 85-07, Exh.
14).
UPDATED RES?ONSE - THIRD SET Corrective actions specified in Phillips, Getschow NCR's 3961 and 3963 (p. 2 of original response) were initiated on November 4, 1985 and were completed by November 30, 1985. These actions included removing the four (4) Containment Spray Pumps and four (4)
Residual Heat Removal Pumps from their respective bases, removing their shims and resinstalling the pumps without the use of the shims. Based on the completion of these actions NCR's 3961 and 3963 were closed on January 30, 1986.
Currently, this Item remains open pending a final document review by EBC Inspector W. Kropp who has assumed Ites responsibility from NRC Inspector R. Schulz.
0665H/ February 5,1986
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CONTENTI0~7 ITEM 6.D UPDATED REFERENCES - THIRD SET 1.
NCR 3961 (closed), dated January 30, 1986, 2.
NRC 3963 (closed), dated January 30, 1986.
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0465H/ February 5,1986 L
CONTENTION ITEM 6.F 6.
Contrary to Criterion V, " Instruction, Procedure and Drawings," of 10 C.F.R. Part 50, Appendix B, Connonwealth 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.
F.
In June, 1984, Phillips Cetschow, piping contractor, found piping that viola:et minimum wall requirements. This defect was not reported to owner in accordance with 10 C.F.R. 21.21.
(Inspection Report 84-21/20 Exhibit 20.)
UPDATED RESPONSE - THIRD SET Between August 2, 1985 and November 1, 1985, Phillips Catschow Quality Control as directed by Commonwealth Edison Project 3
Construction Department (PCD) performed a technical evaluation of selected closed PCCo NCR's, in accordance with Phillips Catschow Work Instruction PGWI-37, for technical adequacy, procedural compliance and potential reportability under 10 CFR Part 21.
The population of NCR's evaluated consisted of all closed NCR's between 1'
PGCo NCR 1 and NCR 1500 inclusive. These NCR's represent all closed i
PGCo NCR's generated between May 1976 and May 4, 1984 In addition, the evaluation included a random sample of 100 NCR's between PGCo NCR 1501 and NCR 4500 inclusive representing closed NCR's generated between May 4, 1984 and April 3, 1985. Commonwealth Edison reviewed those NCR's it had not previously reviewed and in all cases i
concurred inith the initial reportability evaluations of PCCo.
At this time, three Phillipe Getschow procedures govern Phillips Getschow's reporting and evaluation of defects to ensure compliance with 10 C.F.R. Part 21.21.
These procedures are i
i 1 0667H/ February 7, 1986
CONTENTION KTEM 6.F QAP/BR-12, Rev. 7, with Supplement Rev. 1, " Control of Nonconformance Reports"; QAP/BR-12.3, Rev. 2 with Supplement Rev. 1
" Control of Discrepancy Reports"; and QAP/BR-110, Rev. I " Reporting of Defects and Noncompliances" (which replaced QAP-110 Rev. 1).
When Phillips, Getschow identifies a deficiency, it documents this deficiency on a Discrepancy Report ("DR").
The Phillips Catschow QC Manager evaluates each DR for the necessity of upgrading the DR to an NCR and for potential reportability under 10 C.F.R. Part 21 and 10 C.F.R. 50.55(e).
If a DR is deemed potentially reportable the procedure requires that it be superseded by an NCR.
Phillips Getschow performs a documented review of all NCR's for reportability under 10 C.F.R. Part 21 per the requirements of QAP/BR-12. Rev. 7.
(Phillips Getschow began doing this review on May 9, 1985 under revisions made to the Phillips Getschow QA Manual. These changes were first incorporated in QAP/BR-12 on September 16, 1985.)
QAP/BR-110 Rev. 1 provides the evaluation requirements for this review. Those NCR's which Phillips Getschow deems reportable are 4
reported to Cosmonwealth Edison as required by QAP/BR-110, Rev. 1 on a Report of Noncompliance. Phillips Getschow has made additional revisions to QAP/BR-110, Rev.1 on December 20, 1985. These revisions enhance the directions to the responsible Phillips s
Getschow personnel concerning the evaluation of defects and noncompliances by providing more specific criteria than the previous procedure.
1 0667H/ February 7,1986
CONTENTION ITEM 6.F As noted in the original response to this contention Item, PGC0 submits to Commonwealth Edison NCR's which are most likely to have a reportable deficioney.
Since the implementation of QAP/BR-12, Rev. 7, with Supplement Rev.1, approximately 50 percent of the NCR's initiated by Phillips Getschow have been submitted to Commonwealth Edison. Phillips, Getschow submits these NCR's to Commonwealth Edison even if Phillips Catschow's Part 21 evaluation concludes that these NCR's are not reportable. As previously noted, this provides a check on contractor reporting of defects, as Commonwealth Edison reviews these NCR's for acceptability of the corrective actions initiated to resolve the identified deficiencies, for acceptability of the corrective cetions to prevent recurrence, and for reportability under 10 C.F.R. 50.55(e) as required by the current revisions of the Commonwealth Edison QA Manual and PCD-23
" Site Contractor Nonconformance Reports / Procedure Processing".
These corrective actions have been found to be acceptable by 4
the NRC staff and this Item has been closed. This review is documented in Inspection Report Nos. 50-456/05-07 and 50-457/85-07, dated April 4, 1985. 0667H/ February 7, 1986
CONTENTION ITEM 6.F UPDATED REFERENCES - THIRD SET 1.
PCCo Procedure QAP/BR-12, Rev. 7. " Control of Nonconformance Reports", with Supplement Rev. 1, implemented January 8, 1986, 2.
PGCo Procedure QAP/BR12-3, Rev. 2 with Supplement Rev. O
" Control of Discrepancy Reports," implemented February 3, 1986.
3.
PGCo Procedure QAP/BR-110, Rev. 1 " Reporting of Defects and Noncompliances", implemented December 20, 1985.
4.
NRC Inspection Report Nos. 50-456/85-07; 50-475/85-07, dated April 4, 1985.
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0667H/ February 7, 1986
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CONTENTION ITEM 8.A 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 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 generator 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)
UPDATED RESPONSE - THIRD SET An updated response to this Contention Item is contained in Commonwealth Edison's prepared detailed report with respect to the
" Reinspection of Safety Related Mechanical Equipment" corrective action program as originally described in Specific Interrogatory 7 of Intervonors' second Set. This report has already been furnished to the Intervonors. The report is incorporated herein by reference as a part of this contention Item update.
- 0672H/ February 5, 1986
i CONTENTION 8.B 8.
Contrary to Celterion 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.
B.
"10,500 feet of General Electric "VULKENE" switchboard wire was received at Braidwood.
Some of this wire has been installed without appropriate qualification to IEEE 383-1974. (CAT Inspection Report 84-44/40, Exh. 10.)
UPDATED RESPONSE - THIRD RESPONSE The following information provides updated information on the status of the "Vulkeen Wire" walkdown inspection program described in the original updated response to this Contention Item filed in Cosmonwealth Edison's response to Interrogatory 3 of Intervenors' Second Set.
PROGRAN IMPLEMENTATION DATE February 10, 1986 PROGRAN COMPLETION DATI-No later than March 15, 1986 4
s 0673N/ February 7, 1986
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CONTENTION ITEM 8.C 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.
C.
Phillips-Getschow hangers in lower cable spreading room did not utilize ASTN A3C7 fasteners per Sargent & Lundy standard. Also battery rackJ had bolting material that did not meet the requirements of ASTM A307 (CAT Inspection Report 84-44/40 Exhibit 10).
UPDATED RESPONSE - THIRD SET The following information is provided to update the last paragraph of the original updated response to this contention Item filed in Commonwealth Edison's response to Interrogatory 2 of Intervonors' Second Set.
CECO NCR 783 has been written to track the issue of A307 bolts on vendor supplied equipment. The concern as to whether this j
equipment was supplied by the vendor with A307 bolte arose at Ceco's Byron Station. Because the vendor supplied equipment at Braidwood, which is the subject of this NCR concern, is indentical to the Byron equipment, Ceco Project Field Engineering (PFE) currently intends to utilize the results of ir.epections which tested the in-place hardness of bolts on the Byron vendor supplied equipment. Byron inspections have been completed and are currently being evaluated by i
Sargent and Lundy to disposition and resolve NCR 783. This resolution is expected in the near future.
1 4 0674H/ February 10, 1986
CONTENTION ITEN 8.C UPDATED REFERENCES - THIRD SET 1.
Ceco NCR 783.
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CONTENTION ITEM 8.E 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.
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 - WIRD SET As previously discussed in the original updated response to this Contention Item filed in Commonwealth Edison's response to Interrogatory 3 of Intervonors' Second Set, the Braidwood Project Construction Department (PCD) was assessing the adequacy of using tape as a protective covering method.
PCD, by letter dated February 7, 1986, has directed Phillips, Getschow Company to only utilize tape as a protective covering for temporary storage of pipe, valves, etc. The letter directs PCCo to utilize metal, plastic, wood or other durable material which is adequately secured with tape or other qualified adhesive as protective covering for pipe, valves, I
etc. in non-temporary storage.
Phillips, Getschow Company is also instructed to initiate any necessary procedure changes as well as any remedial field work to upgrade pipe, valve, etc protective covers.
A further updated response to this Contention Item is provided in the updated response to Contention Item 8F filed in response to Specific Interrogatory 9 of Intervonors' Third Set.
This response l
I is incorporated by reference herein. 0676H/ February 7,1986
CONTENTION ITEM 8.E UPDATED REFERENCES - THIRD SET l
1.
Commonwealth Edison, Project Construction Department letter, dated February 7, 1986 (BR/PCD86-99) from D.L. Shamblin to T.
O'Connor PCCo Site Manager.
i i 0676H/ February 7, 1986
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CONTENTION ITEM 8.F 8.
Contrary to Celterion 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.
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 flamnable material and a layer of dust on all equipment in the room.
(Inspection Report 85-08, Exh. 23.)
UPDATED RESPONSg - THIRD SET As a result of this Contention Item remaining open with the NRC Staff and the related item of noncompliance concerning dust in electrical panels during removal of adjacent masonry block as documented in Inspection Report 50-456/85-045 and 50-457/85-44, Commonwealth Edison Company has taken the following actions.
Additional special measures to protact equipment were initiated by G.K. Newberg personnel involved in masonry block removal. These measures include better isolation of the immediate removal area to prevent dust spreading to clean areas.
Additionally, Braidwood contractor personnel assigned on an ongoing basis to all plant areas are continuing to maintain panel cleanliness in the event panels become dirty. Contractor personnel were also instructed to keep panel doors closed when they are not working in these panels and to also be more diligent in the performance of preventive maintenance surveillance activities in general. Lastly, mass communication signs recently erected on-site will periodically carry messages stressing housekeeping and equipment protection themes.
l 0677H/ February 7, 1986
i CONTENTION ITEM 9.A 9.
Contrary to criterion II, " Control of Special Processes,"
of 10 C.F.R. Part 50, Appendig B, Commonwealth 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.
i 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 ae.cepted 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 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 - THIRD SET During an inspection in the Fall of 1985, NRC Inspector Jacobson reviewed actions taken to correct the second part of this Item as described in previous responses. These actions were found to be acceptable and this Item was closed. The closure review is documented in Inspection Report Nos. 50-456/85-40 and 50-457/85-39, dated November 22, 1985.
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CONTENTION ITEM 9.A UPDATED REFERENCES - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-40; 50-457/85-39, dated November 22.-1985.
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CONTENTTON ITEM 9.C 9.
Contrary to criterion II, 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 special processes, including welding are controlled and accomplished in accordance with applicable codes, standards, specifications, criteria ~and other special requirements.
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 - THIRD SET The initial disposition of L.K. Comstock NCR 3275, which required a review of all past weld filler metal withdrawal authorization forms, has been re-evaluated. Revision 1 to NCR 3275 was issued on November 15, 1985 to eliminate the previously required review of all filler metal withdrawal forms. This revision was based on a review of the certified material test reports for the E60 series electrodes used by L.K. Comstock. The material review was deemed to be far more efficient than a review of all withdrawal forms issued since the beginning of the project, because the results of this analysis would validate the past use of either E60 or E70 series electrodes by L.K. Comstock for any kind of electrical welding. Based on this revised disposition, NCR 3275, Rev. I was closed on December 12, 1985. 0680H/ February 7, 1986
CONTENTION ITEM 9.C UPDATED REFERENCES - THIRD SET 1.
L.K. Comstock NCR No. 3275 (closed), dated December 12, 1985. 0680H/ February 7, 1986
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 accomplishing the activity.
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 manuf acturer'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 of 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 RESPONSE - THIRD SET An updated response to this Contention Item is contained in Commonwealth Edison's prepared detailed report with respect to the
" Reinspection of Safety Related Mechanical Equipment" corrective action program as originally described in Specific Interrogatory 7 of Intervenors' Second Set. This report has already been furnished to the Intervenors. The report is incorporated herein by reference as a part of this Contention Item update. 0683H/ February 5,1986
4 CONTENTION ITgM 10.B 10.
Contrary to Criterion I, " Inspection," of 10 C.F.R. Part 50, Appendix B, cosamonwealth gdison Contpany has failed to ensure that a program for inspection of activities affecting quality was established and executed by or for the organization perfocuing the activity to verify conformance with the 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 7
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. 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 i
prosessmatic deficiencies, enforcement action was not being taken on this violation at that time. Following the NRC's review of gdison'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.)
4 UPDATED
- TNIRD SET As a result of the MTV program, there are currently three Phillips, Getschow Company Nonconformance Reports that have not been f
resolved and closed. One of these nonconformanca reports relates to i
Unit 1 installations and the disposition instructions for this 1
Nonconformance Report are presently being implemented. The remaining 4 0684H/ February 7, 1986
CONTENTION ITEN 10.B two nonconformance reports relate to Unit 2 installations where work is not yet complete. Sargent and Lundy has released design documents that will allow acceptance of the items on the above two menti $ned nonconformance reports once work is complete.
In addition, during a January 9, 1986 NRC Inspection Exit Briefing, NRC Inspector Nuffett stated that he had reviewed actions taken to correct this Item as described in previous responses.
Based on this review, the Inspector indicated that corrective i
actions appeared to be acceptably implemented and that he would close this item. This closure review is to be documented in a forthcoming NRC Inspection Report.
J 0684H/ February 7, 1986
CONTENTION ITEM 10.C Ond 10.E 10.
Contrary to Criterion I, " Inspection " of 10 C.F.R. Part 50, Appendix B, Conunonwealth 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.
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 j
accordance with design requirements.
(CAT Inspection Report 84-44/40, Exh. 10.)
r 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 be proper weld configurations.
(CAT Inspection Report 84-44/40 Exh. 10)
UPDATED RESPONSE - THIRD SET An updated response to these contention Items is contained in Commonwealth Edison's updated response to Specific Interrogatory 4 of Intervenors' Second Set describing " Pipe Support Installation and Welding."
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, 0685H/ February 5, 1986
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CONTENTION ITEN 10.D 10.
Contrary to Criterion I, " Inspection," of 10 C.F.R. Part 50, Appendix B, Comonwealth 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.
D.
Applicant failed to provide an adequate inspection program in that electrical separation criteria were not sufficient to identify installations of raceway and cables by Comstock violating design requirements for separation.
(CAT Inspection Report 84-44/40, Exh. 10.)
UPDATED RESPONSg - THIRD SET An updated response to this Contention Item is provided herein in the updated response to Specific Interrogatory 6 of Intervenors' Second Set which described the " Cable Tray Separation Walkdown Program". That updated response is incorporated by reference in response to this Contention Item.
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CONTENTION ITEM 10.F 10.
Contrary to Criterion I, " Inspection" of 10 C.F.R. Part 50, Appendix B Commonwealth Edison Company has failed to 1
ensure that a program for inspection of activities
)
i 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 junction box which was later determined to have deficiencies in the location of the anchors used for l
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.
i UPDATED RESPONSE - THIRD SET In accordance with L.K. Comstock NRC No. 4513, the cap screws on the six remaining junction boxes (one removed) inspected by the inspector at issue in this Contention Item have been torque tested.
Testing verified that adequate torque for the cap screws had been achieved during installation. The NCR No. 4513 documentation for this installation was completed accordingly and the NCR was closed on December 6,1985.
Based on the Sargent and Lundy disposition to accept the junction boxes "as is" described in previous responses to 4
this Item, L.K. Comstock NCR 4139 was closed on December 2, 1985.
The identification of this Item represents an isolated case, for several reasons. First, no other discrepancies were found during LEC's reinspection of the other junction boxes inspected by the inspector involved in this discrepancy. Second, the NRC closed this item in Inspection Report Nos. 50-456/85-32 and 50-457/85-31.
Finally, the results of a routine NRC Inspection conducted on September 9 through October 18, 1985 further support this conclusion.
During the course of that inspection, three other i l 0687H/ February 7, 1986
CONTENTION ITEN 10.F installed L.K. Comstock junction boxes (1JB011A, 1JB005A, and 1JB015A) were inspected for compliance with established requirements, including that the installations be in accordance with current drawings and in the location specified. The NRC found that these three junction boxes were installed correctly.
Inspection Report Nos. 50-456/85-38 (DRP); 50-457/85-37, dated November 27, 1985.
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! 0687H/ February 7, 1986
CONTENTION ITEN 10.F UPDATED REFERENCES - THIRD SET 1.
L.K. Cosastock NCE 4513 (closed), dated December 6,1985.
2.
L.K. Comstock NCR 4139 (closed), dated December 2, 1985.
3.
NRC Inspection Report Nos. 50-456/85-38; 50-457/85-37, dated November 27, 1985.
i 0687H/ February 7, 1986 i
CONTENTION ITEN 11.B 11.
Contrary to Criterion IV, " Nonconforming Materials, Parts or Components," of 10 C.F.R. Part 50, Appendix B, Comunonwealth 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.
B.
For Penetration Nos. E2 (sic) and E51. L.K. Comstock Inspection Reports were found which documented loose crimps at the determination blocks. No corrective action documents were written to identify and track these nonconforming conditions. Additionally, the cables from Comstock were not terminated and were tagged with orange out-of-service cards which are not controlled by the QA 1
program.
(Inspection Report 84-39/36, Exhibit 26.)
i UPDATED RESPONSE - THIRD SET i
L.K. Comstock procedure 4.13.1.1, " Turnover Document Review" i
Revision B, was issued on September 12, 1985 to specifically incorporate General Inspection Reports.
]
The L.K. Comstock NCR's which were generated as a result of the additional review of Unit 2 containment electrical penetrations with i
t' outboard junction boxes which contain terminal blocks have been dispositioned to repair the discrepant items in accordance with existing site procedures. This disposition is documented on L.K.
Comstock NCR's #4107 through 4114, concerning electrical penetrations which contain safety related cables and NCR's numbers 4150 through 4157 concerning electrical penetrations which contain non-safety related cables. The close-out of these NCR's is currently in-process.
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CONTENTION ITEM 11.8 UPDATED REFERENCES - THIRD SET 1.
L.K. Comstock Procedure, 4.B.1.1 " Turnover Document Review'*,
Rev. B, dated September 12, 1985.
2.
L.K. Comstock NCR's 4107, 4108, 4110, 4111, 4112, 4113, 4114.
3.
L.K. Comstock NCR's 4150, 4151, 4152, 4153, 4154, 4155, 4156, 4157.
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. 0688H/ February 7, 1986
CONTENTKON ITEM 11.C 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 control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation.
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 addition, the rejected pipe was not properly dispositioned in that only 206, 744 feet of pipe was chemically cleaned.
(Inspection Report 84-17, Exh. 21.)
UPDATED RESPONSE - THIRD SET Jus updated response to this Contention item is contained, in Commonwealth Edison's prepared detailed report with respect to the "Braidwood Station - Units 1 and 2 Engineering Evaluation of the Pipe Corrosion Problem Identified in CICo NCR 633".
This report has already been furnished to the Intervenors. The report is incorporated herein by reference as a part of this contention Item update. 0689H/ February 7,1986
CONTENTION ITEM 12.A 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.
An 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.
A.
Edison did not assure that a matter potentially adverse to quality was promptly identified and corrected at the Braidwood Station.
Edison identified a significant problem with bolting of the steam generator supports that occurred at its Byron Station. Timely or adequate corrective action was not taken by Edison to prevent the same or a siellar problem from occurring at Braidwood Units 1 and 2.
It should be noted that Byron and Braidwood have a conunon FSAR, a common construction specification, a common system for drawings, ECNs and FCRs and a common architect engineer. Thus, the construction problem at Byron should have indicated a need for a more thorough evaluation for Braidwood. Nonconformity Report N,
,32 concerning this bolting problem was issued at Bt.idwood on December 2, 1981, yet effective corrective action was not taken unitl August 1942.
In addition, effective corrective action was not taken by Edison relative to Phillips, Getschow Company's failure to implement and utilize installation procedures (identified during Edison audits conducted June 20-July 9, 1980 and June 23-25, 1981), concerning installation and installation inspection of mechanical safety-related equipment. The same deficiencies were again identified during a surveillance conducted by Phillips, Getschow Company on February 19, 1982. 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."
(Euhlbit 3)
UPDATgD R M - THIRD SgT An updated response to this contention Item is contained in Commonwealth Edison's prepared detailed report with respect to the " Reinspection of Safety Related Mechanical Equipment" corrective action program as originally described in Specific Interrogatory 7 0718H/ February 7,1986
CONTENTION ITEM 12.A of Intervenors' Second Set. This report has already been furnished 1
to the Intervenors. The report is incorporated herein by reference as a part of this Contention Item update.
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i 0718N/Febmary 7,1986
CONTENTION ITEN 12.5.1 l
12.
Contrary to Criterion IVI, " Corrective Action," of 10 C.F.R.
part 50, Appendix 5. Conunonwealth Edison Company has failed to ensure that measures were established to assure that conditions adverse to quality, such as failures, malfunctions, t
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.
B.
A special NRC QA inspection reported May 7, 1984 that:
4
- 1/2" 5/80, SA-312 Type 304, ASME Boiler and pressure Vessel Code, section III, Class 1, NB pipe heat number 745107 were discovered in ::ection 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 1
the Nonconformance Report resulted in accepting the pipe, t-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 i
storage and installed, i
UpDAftD RESPONSE - THIRD SET 1
As of January 6, 1986, phillips, Getschow Company Nonconformance Report No. 4884 referenced in the original response has been reviewed, dispositioned, implemented and closed. The disposition and resolution of 4
this Nonconformance Report addresses the following itemet l
1)
Receipt inspection of both the schedule 80 and schedule 160 pipe.
2) proper documentation for both the schedule 80 and schedule 160 pipe.
3)
Besenciliation of quantities of schedule 80 and schedule 160 pipe received and issued.
4)
Determination of where schedule 80 and schedule 160 pipe was installed in the plant.
I 5)
Resolution of situations where the incorrect schedule of pipe was installed (a small percentage of the pipe installed was j
removed and replaced with pipe of the proper schedule).
0711H/ February 7, 1986 i
i
.._._.-__,____.______._,.______.m
CONTENTION ITEM 12.5.1 6)
A summary and resolution for corrective actions stated on Phillips, Getschow Company Nonconformance Report Nos. 789, 1128 and 1640.
The 100% review of closed PCCo NCR's Nos. I through 1500 was completed by Phillips, Catschow Company in November, 1985.
As a result of this review, Nonconformance Reports that were not adequately dispositioned and/or closed have been resolved, including the issuance of new Nonconformance Reports or Discrepancy Reports when required.
Furthermore, the results of this review demonstrated that various enhancements and revisions of Phillips, Cotschow Company Nonconformance Report processing procedures over time have improved the quality of Nonconformance review, disposition and closure. 0711H/ February 7,1986
COWTEH1QLIIEH 12,8,1 UPDATED REFERENCES - THIRD SET 1.
PCCo NCR No. 1640 (closed), dated January 6, 1986.
2.
PCCO Final Repcet
" Technical Evaluation of Previously closed PGCo NCR's Numbered 1-1500," with cover letter to D. L.
Shamblin, Ceco PCD, dated November 4, 1985.
1 0711N/ February 7, 1984 4
, ~ - - - - -,. - - - -. - -,, - - -. -, - ~ -,... - - - -, -.,
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i CONTENTION ITEM 12.5.3 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:
Corrective action was not adequate concerning Nonconformance Report No. BR-04, dated June 15, 1981, since the nonconforming welds completed by unknown welders were " accepted-as-is" after only a visual examination. The acceptance of the weld by visual examination pursuant to AWS D.1.1 is based on the fact that a qualified welder performed the welding in accordance with the qualified process.
(Inspection Report 83-09. Exh. 5).
UPDATED RESP 0NSE - THIRD SEI In addition, all welds made pursuant to AWS D1.3 for which the i
welder identification could not be established are either being reworked or replaced.
1 l
1 I
1
! 0729H/peburary 11, 1986
CONTENTION ITEM 12.C 12.
Contrary to Criterion XVI, " Corrective Action," of 10 C.F.R. part 50, Appendix B, Conunonwealth 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 i
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 ASME Section III, section NF.
(Inspection Report 85-15/16, Exh. 17.)
Up0ATgD R58 PONG 8 - THIRD Sg7 The following corrections are made to supplement the original response to this Contention Item provided in Cosmonwealth Edison's original response to Interrogatories 58 and 59 of Intervonors' First Set.
J 1)
Delete the first sentence of the last paragraph of page 3 1
of the original response and substitute the following:
"In order to assess the controls applied to items and materials used to construct component supports, and the effectiveness of those controls, pCCs Quality Assurance senducted special audit No. 85-BR4."
2)
Delete the last sentence of the carry-over paragraph (from page 3) on page 4 of the original response and substitute the following:
"One purpose of this procedure is to
]
identify problems similar to those identified in the item of non-compliance." '
0694H/ February 7, 1986
_. ~.... _,.
CONTENTION ITEN 12.C UPDATED REFERENCES - THIRD SET 1.
PCCo Quality Assurance Audit No. 85-BR6.
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-10 0694H/Febmary 7,1986
CONTENTION ITEM 12.F 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.
F.
In addition, 37 BCAP observations were invalidated by S&L even though the documented basis for the invalidations of the observations did not support the invalidations.
(Inspection Report 85-06, Exh. 11.)
UPDATED RESPONSE - THIRD SET Commonwealth Edison site Quality Assurance, at the request of BCAP Quality Assurance, performed Surveillance No. 4151, dated February 14, 1985, which identified deficiencies in PCCo's program for verification of " redline" drawings. The concern identified in the site Quality Assurance surveillance precluded BCAP invalidation of the 37 observations referred to in this contention Item.
The 37 observations written against " redline drawings" had final determination of "valld" and CECO BCAP NCR Nos. 6124 and 6127 ar,e currently being processed. These NCRs are in the process of being resolved on the same bases as the related surveillance finding, namely that (1) the BCAP Construction Sample Reinspection results showed that the redline drawings accurately reflect the piping configuration and dimensions with only a small percentage of minor discrepancies; and (2) based on PGCo work assignment records, Q.A. has established that the personnel who created the redline drawings in the field were appropriately trained Q.C. Inspectors, or 0695H/ February 10, 1986
CONTENTION ITEN 12.F were trainees participating in these activities and supervised by a Q.C. level II inspector. These records also show that each redline drawing was assigned to a Q.C. Foreman, with appropriate Level II certification, who supervised the activity in the fleid.
In addition, during a January 17, 1986 NRC Inspection Exit Briefing NRC Inspector Gardner stated that he had reviewed actions taken to correct this Item as described in previous responses.
Based on this review, the Inspector indicated that corrective actions appeared to be acceptably implemented and that he would close this Item. Thisclosurereviewistobedocumentedink forthcoming NRC Inspection Report.
, 0695H/Febevery 10, 1986
CONTENTION ITEM 12.F UPDATED Raramam,si - THIRD SET 1.
CBCo QA surveillance No. 4151, dated February 14, 1985.
2.
Ceco BCAP NCR's 6124 and 6127. 0695N/ February 10, 1986
CONTENTION ITEM 12.G
- 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 f ailures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance are l
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.
After an NRC Inspection (82-05) identified that the Applicant failed to implement a QA program for the erection of mechanical safety-related equipment, Phillips, Getschow contractor identified numerous pieces of equipment that had been installed without QC verification of internal cleanliness.
(Inspection Report 84-21/20 Exh. 20.)
UPDATED RESPONSE - THIRD SET Commonwealth Edison's generic flushing procedure Psu-200 is in the process of being revised tot i
1)
Explicitly allow use of a cleaning method previously only implied.
2)
Provide a clearer method of tracking connected documentation.
3)
Reorganise the procedure slightly to provide for smoother reading.
4)
Recognise the establishment of the newly established Unit 2 Flushing Organisation.
5)
Provide sabe flowibility in the performance of the " Post Construction / pre-Final Flushing" Cleanup Activity.
However, none of these revisions are being taken specifically to address the corrective actions for this Item nor do they affect these correative actions as established. The revision to PSU-200 is expected to be finalised shortly. Until that time, the Flush Program will continue under the current revision of PSU-200. 0696H/ February 7, 1984
CONTENTION ITEN 12.G In addition, NCR 614 was closed on January 30, 1986.
Further information on closure of NCR 614 is provided in the updated response to Interrogatory 6 of Intervonors' Second Set captioned "Nechanical Equipment Disassembly and Inspection (Mechanical Equipment Internal Cleanliness Verification)" incorporated by reference herein. 0696N/ February 7, 1984
t CONTENTION ITEM 12.H 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 nonconformance 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.
H.
Edison did not take appropriate corrective action with regard to Audit QA-20-80-22, in that an assessment of QC inspectors qualifications were not performed to address the potential impact on work performed prior to the audit finding.
(Inspection Report 84-07 Exh. it.)
UPDATED RESPONSE - THIRD SET To provide additional assurance that past work has been accounted for, the Q.A. review referenced in the original response to this item was extended to all 1981 audit deficiencies.
The review consisted of forty-two (42) 1981 on-site audits performed on various contractor organisations and Ceco Project Groups. Seventy-eight (78) deficiencies (findings and observations) were reviewed. Of these seventy-eight (78), fifty-six (56) or 12%
clearly address past work in the close-out surveillance or audit file or it was not applicable because of the subject deficiency.
The remaining twenty-two (22) or 20% were evaluated further. Fast work was either not a problem or would be resolved as part of an on-going Commonwealth Edison QA or PCD work program. All of the closed-out surveillances had acceptable corrective actions for the specifically identified problems.
The 1981 audit deficiency reviews did not necessitate any new corrective actions which would affect plant hardware. Moreover, the 1981 reviews showed a positive trend in initial consideration of 0704N/ February 7,1986
CONTENTION ITEM 12.H past work when' compared to the 1980 review. Therefore, further review of audits from other prior years is not warranted. Today, Braidwood Q.A.'s standard audit and response formats require an evaluation of the impact on previous work.
In addition, during a January 24, 1986 NRC Inspection Exit Belefing, NRC Inspector W. Ecopp stated that he had reviewed actions taken to correct this Item as' described in previous responses.
Based on thiu review, the Inspector indicated that corrective actions appeared to be acceptably implemented and that he would closethisItem) This closure review is to be documented in a forthcoming NBC Inspection Report.
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-11 0104H/ February 1, 1986
a CONTENTION ITEM 12.I 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.
I.
Edison QA identified inspection deficiencies but failed to take corrective action with respect to Napolean Steel Contractors' past welding inspection activities to assure that defects do not exist in multi-pass welds.
(Inspection Report 84-08, Exh. 25.)
UPDATED Resp 0 NEE - THIRD SET An updated response to this Contention Item is provided in the first three paragraphs of the updated response to contention Item 12H filed in response to specific Interrogatory 9 of Intervenors' Third set. This responee is incorporated by reference herein.
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-7s-0714H/ February 7, 1986 1
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CONTENTION ITEM 13.A 13.
Contrary to Criterion XVII, " Quality Assurance Records,"
of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that sufficient records were maintained to furnish evidence of activities affecting quality. The records are to include at least the following*
results of reviews. Inspections, tests audits, monitoring of work performance, and materials analyses.
Applicant has failed to make such records identifiable and retrievable.
A.
With few exceptions, official records were not generated 4
or maintained relative to the installation of mechanical safety-related equipment by either Edison or their erection contractor, L.E. Comstock Company (sic).
Records that failed to show compliance with quality assurance, design, and code requirements included:
(1) equipment releases to engineering for installation, (2) travelers or process sheets to identify required installation activities and inspections, (3) installation inspections, (4) pretensile loads for bolting, and (5) data on final equipment settings. 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."
UPDATED RESPONSE - THIRD SET An updated response to this Contention Item is contained in Commonwealth Edison's prepared detailed report with respect to the
" Reinspection of Safety Related Mechanical Equipment" corrective action program as originally described in Specific Interrogatory 7 of Intervenors' Second Set.
This report has already been furnished to the Intervenors. The report is incorporated herein by reference as a part of this Contention Item update.
- - 0719H/ February 7,1986 I
i
CONTENTION ITEN 13.B 13.
contrary to criterion KVII, " Quality Assurance Records,"
of 10 C.F.R. Part 50, Appendix B, Conunonwealth Edison Company has failed to ensure that sufficient records were
~
maintained to furnished evidence of activities affecting quality. The records are to include at least the following:
results of reviews, inspections, tests, audits, monitoring of work 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 - THIRD SET A January 24, 1986 Sargent and Lundy letter indicates that all remaining Structural Design Standards, including E7, E9 and E39, have been received by Sargent and Lundy's QA Department for mietofilming.
In addition, During an inspection from August 19 through October 24, in the Fall of 1985, NRC Inspector Huffett reviewed actions taken to correct this Item as described in previous responses. These actions were found to be acceptable and the Item was closed. The closure review is documented in Inspection Report Nos. 50-456/85-40 and 50-457/85-39, dated November 22, 1985.
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, 0703H/ February 7, 1986 i
l
l CONTENTION ITEN 13.5 I
l UPDATED REFERENCE - THIRD SET 1.
S&L letter dated January 24, 1986 from H.C. McCullough to W.J.
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- Marcis, i
- 0703H/ February 7, 1986
CONTENTION ITEM 148.1 14.
Contrary to criterion XVIII, " Audits," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure tha; 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:
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, Getsch)w QA Manual.
UPDATgD RESPONSE - THIRD SET During an inspection on October 21 through November 30 1985, NRC Inspector R. Schuls reviewed actions taken to correct this Item as described in previous responses. These actions were found to be acceptable and this Item was closed. This review is documented in Inspection Report Nos. 50-456/85-52 and 50-457/85-50, dated December 5, 1985.
i 0697H/ February 7, 1986
CONTENTION ITEN 14B.1 UPDATED REFERENCES - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-52; 50-457/85-50, dated December 5,1985
, 0697H/ February 7, 1986
l CONTENTION ITEM 14B.2 14.
Contrary to Criterion KVIII Audits of 10 C.F.R. Part 50, l
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.fL.C. 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 *.14.1, nor did they verify compliance with all aspects of the Quality Assurance Program.
UPDATED RESPONSE - THIRD SET During an inspection on October 7 through November 1, 1985, NRC Inspector P. Pelke reviewed actions taken to correct this Item as described in previous responses.
These actions were found to be acceptable and this Item was closed.
This review is documented in Inspection Report Nos. 50-456/85-51 and 50-457/85-49, dated November 20, 1985. 0698H/ February 7,1986
j CONTENTION ITEM 148.2 i
UPDATED REFERENCES - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-51; 50-457/85-49, dated November 20, 1985.
t 4
1 1 0698H/ February 7, 1986
CONTENTION TTEM 148.3 14.
Contrary to Criterion XVIII, " 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 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 l
- B 5.1.F.
HVAC Repair Adjustment
[
B 9.3.F, Expansion Anchor Installation B 10.2.F.
Visual Weld Inspection UPDATED RESPONSE - THIRD SET During an inspection on October 21 through November 30, 1985, NRC Inspector R. Schulz reviewed actions taken to correct this Item as described in previous responses. These actions were found to be acceptable and this Item was closed. This review is documented in Inspection Report Nos. 50-456/85-52 and 50-457/85-50, dated December 5, 1985.
4 0699h.' February 7, 1986
4 CONTENTION ITEM 14B.3 UPDATED RESPONSE - THIRD SET 1.
NRC Inspection Report Nos. 50-456/85-52; 50-457/85-50, dated December 5, 1985.
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! 0699H/ February 7, 1986
SPECIFIC INTERROCATORY 2 2.
With respect to the following subparts or items of Intervenors' amended quality assurance contention:
. 12.J. please describe 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 / t iciency, weakness, finding or observation.
Set forth ang tacts upon which you rely to show that the matter and its root cause have been effectively corrected.
Please identify any documents which reflect these answers.
UPDATED RESPONSE - THIRD SET The original response to this Item remains current as stated in Applicant's response to Specific Interrogatory 2 of Intervenors' Second Set.
However, certain minor necessary corrections are described herein.
In the first two sentences of the first full paragraph on page four of the original response, the 20 new observations should be changed to 21 and the 12 new observations not detected in the initial BCAP inspections should be changed to 13.
The number changes were due to a counting error and have no effect on the conclusions contained in this paragraph of the original response or on the overall conclusions presented in'the original response. 0693H/ February 10, 1986
UPDATED NAMES AND ADDRESSES - THIRD SET Neil P. Smith New work address Consonwealth Edison CompSny - Downtown
.New work telephone number 312/294-8641 Nacinder N. Kaushal Correct home address is 963 Nonticello Drive, not 960 Monticello Drive
. 0693H/ February 10, 1986
SPECIFIC INTERROCATORY 9 UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 4 OF INTERVENORS' SECOND SET Interrogatory 4 of Intervenors' Second Set requested detailed descriptions of corrective actions or programs which were believed to be related to certain Contention Items as discussed in the original responses to Interrogatories 58 and 59.
Commonwealth Edison's updated responses to these descriptions are provided on the following pages. Not all corrective actions or programs require updating. No updated information exists for those actions or programs not included in this response. 0700H/ February 6,1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 4 OF INTERVENORS' SECOND SET PIPE SUPPORT INSTALLATION AND WELDING As described in the original description of this item contained in Commonwealth Edison's original response to Interrogatory 4 of Intervenors' Second Set, Sargent and Lundy's disposition of generic NCR 705 on skewed tee fillet welds was to accept the past work in this area "as is" based on a verification of the design adequacy of the pipe supports at issue.
In addition, in order to provide more detailed guidance to Braidwood site contractors for future work in this area Sargent and Lundy issued Engineering Change Notices 25598 (for HVAC Work), 2599 (for E*ectrical Installation) and 25600 (for Structural Steel work). Also drawing M-999 (for mechanical pipe
~
supports) has been revised to provide PGCo with further clarification for establishing minimum weld size for skewed too joints on certain pipe supports / restraints. Based on this disposition, NCR 705 was closed on January 27, 1986.
Currently, all PGCo individual NCR's identified by the NRC CAT Team as pertaining to support / restraint discrepancies (which form the basis of Contention Items 10C and E) have been closed. As a result of these closures and closed NCR 705, Conunonwealth Edison is in the process of compiling all necessary documentation for presentation to the NEC Staff for review and closure of these items. 0700H/ February 6, 1986
UPDATED REFERENCES - THIRD SET 1.
Ceco NCR 705 (closed), dated January 27, 1986.
4 F
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92-0700N/ February 6, 1986 1
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UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 4 0F INTERVENORS' SECOND SET STEAM GENERATOR BOLTING An updated response to this Contention Item is contained in Connonwealth Edison's prepared detailed report with respect to the
" Reinspection of Safety Related Mechanical Equipment" corrective action program as originally described in Specific Interrogatory 7 of Intervenors' second Set. This report has already been furnished to the Intervenors. The report is incorporated herein by reference as a part of this Contention Item update.
9 l
t 0700H/ February 6, 1986
SPECIFIC INTERROGATORY 9 UPDATED 'ESPONSE R
TO SPECIFIC INTERROGATORY 5 OF INTERVENORS' SECOND SET
RESPONSE
Specific Interrogatory 5 of Intervenors' Second set' requested a description of Comunonwealth Edison's Site Quality Assurance Unit Concept Inspection Program. This description was provided in Conunonwealth Edison's second Partial Reponse to Intervenors' Second Set. An updated response to Interrogatory 5 is contained on the following pages.
t l
. 0706H/ February 6, 1986
1 i
UPDATED RESPONSE - THIRD SET I
SPECIFIC INTERROGATORY 5 OF INTERVENORS' SECOND SET UNIT CONCEPT INSPECTION PROGRAM i
The Unit Concept Inspection Program for Braidwood was established to be accomplished in two phases. The first phase consisted of performing inspections of safety-related Unit one i
components and areas and common components which are required for start-up of Unit one. These inspections began in September 1982.
The.second phase of the program is to cover those safety related I
components and areas which are required for Unit Two start-up.
On December 28, 1984, the Unit Concept Schedule for 1985 was established. This schedule which was approved on Jan. 2, 1985, and consisted of 174 units including those units previously completed, I
(i.e. this was a comprehensive schedule showing all units through 1985), provided for essentially complete coverage of all safety-related Unit one plant systems. Some Unit Two i
components / areas were included in this schedule but they were kept to a minimum. The major portion of the schedule provided for coverage of Unit One and Unit Two components required for Unit One start-up.
l On August 6, 1985, the schedule was revised to 161 units. This revision was the result of deleting units which were not required for Unit One start-up and units for which "like inspections" had already been performed.
a 3 0706H/Febevery 6, 1984
On November 15, 1985, the schedule was revised again to delete a unit which had been inspected in conjunction with closing a Nonconformance Report which covered the components in the Unit.
This reduced the 1985 schedule to 160 units.
In early December 1985, a fleid review determined that the areas to be covered by Units 159 and 160 did not have sufficient construction progress to warrant a meaningful Unit concept Inspection. As such they were rescheduled to March and April 1986.
With the exception of these two units, the first phase of the Unit concept Program has been accomplished. On December 18, 1985, the 1985 schedule was revised to reflect this change.
In addition, the 1986 schedule was also established. The 1986 schedule shows that the next Unit Concept Inspection. Which will be Unit 161, will begin September 1,1986 when it is expected that sufficient construction progress will be achieved for Unit Two components / areas.
4 0706H/ February 6, 1986
SPECIFIC INTERROCATORY 9 UPDATED RESPONSE - THIRD SET TO INTERROGATORY 6 OF INTERVENORS' SECOND SET Interrogatory 6 of Intervonors' Second Set requested detailed descriptions of corrective actions, programs or responses which were identified in certain contention Item respons'es to Interrogatories 58 and'59.
Commonwealth Edison's updated responses to these descriptions are provided on the following pages. Not all corrective actions, programs or responses require updating.
'No updated information exists for those actions, programs or responses not included in this response.
. 070lH/ February 6, 1986
\\
SPECIFIC INTERROCATORY 6 BRAIDWOOD CORRECTIVE ACTION PROGRAM MECHANICAL EQUIPMENT DISASSEMBLY AND INSPECTION (MECHANICAL EQUIPMENT INTERNAL CLEANLINESS VERIFICATION UPDATED RESPONSE - THIRD SET All pieces of mechanical equipment listed in Ceco NCR 614 have been dispositioned by one or more of the following methods:
(a) visual inspection for Internal Cleanliness, (b) use of previously performed flushes to verify Internal Cleanliness, as approved by Project Engineering, (c) individual deficiency reports which have been written to track flushes and to verify Internal Cleanliness Inspections on those pieces of equipment for which flushes have not been perforised, as approved by Project Engineering, or (d) performing visual inspection on pieces of equipment for which work is not yet complete. Specific equipment installation record line item sign-offs and Ceco QA Hold Points have been established for each piece of equipment on the NCR.
Based on this disposition, NCR 614 was closed on January 30, 1986. This closure was verified by Q.A. Surveillance No. 5457, dated January 27, 1986.
! 070lH/ February 6, 1986
UPDATED REFERENCE - THIRD SET 1.
NCR 614 (closed), dated January 30, 1986.
2.
'Q.A. Surveillance No. 5457, dated January 27, 1986.
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1 070lH/ February 6, 1986
UPDATED RESPONSE - THIRD SET SPECIFIC INTERROCATORY 6 0F INTERVENORS' SECOND SET CABLE TRAY SEPARATION WALKDOWN PROGRAM The following information is provided to update the last two paragraphs of the original description of this Program provided in Conunonwealth Edison's response to Interrogatory 6 of Intervonor's Second Set.
As of February 7, 1986, 100% of the areas containing safety related cable tray have been walked down. Of the total areas which have been 4
walked down, approximately 86% of the marked up drawings for these areas have been reviewed for violations of the separation criteria. Within the population of reviewed drawings, 424 installations have been identified j
with less than the required separation distances between safety related and non-safety related cable trays and/or raceway. 318 of these 424 installations were previously identified and addreased by S&L during its design process. The remaining 106 discrepancies identified to date during the walkdown have been submitted to 34L Project Engineering for processing as directed by PI-as-59.
The evaluation of these discrepancies is presently on going. All rework, if nectosary, will occur prior to program completion.
t The L.E. Coastock procedures regarding the installation and inspection of safety-related cable tray are still in the process of being updated.
4
-100-i 0722H/ February 10, 1986
SPEQIFIC INTERROGATORY 9 UPDATED RESPONSE - THIRD SET TO INTERROGATORY 7 0F INTERVENORS' SECOND SET Applicant's updated response to the descriptions of Corrective Action Programs originally provided in response to Interrogatory 7 of IntervenorsSecond Set is contained on the following pages. Not all Corrective Action Programs have had a status change since Applicant flied the descriptions of the programs in response to Interrogatory 7 of Intervonors' Second Set and therefore there was no need to update every description. No updated information exists for those descriptions which are not included in this response.
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-101-i 0702H/ February 7, 1986 l
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM ASME MATERIAL PROCUREMENT The final heat / lot number items being considered under the scope of this program were resolved on January 1986. Of the estimated total 4,300 heat / lot numbers, an estimated 2,200 required revised or additional documentation from the vendors or corrections to associated records.
397 of the total heat / lot numbers required additional corrective action to bring the documentation into conformance with ASME Section III requirements. Two heat / lot numbers require replacement in certain applications. The appropriate Commonwealth Edison and PCCo NCR's are currently in the process of being closed. Once these NCR's are closed, the program will be complete.
-102-0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM ASME NAMEPLATE DOCUMENTATION RETRIEVAL PROGRAM (NDRP)
As of January, 1985, a total of $68 spools examined have been identified as falling under the scope of NDRP (this is expected to be the final scope). Nameplate removal areas (or in some cases the nameplates themselves) have been located for 303 of these s; ool pieces.
In addition, identification has been established for all 568 spool pieces.
Situations where the nameplate removal area cannot be physically located are being dispositioned by Commonwealth Edison on PCCo NCR's which are currently in-process. Replacement of nameplates began in late 1985.
Howavar, with the concurrence of the Conunonwealth Edison authorized Nuclear Inspector, CECO has elected not to continue attaching replacement identification plates to the remainder of the installed spool pieces.
This decision was based on the fact that adequate traceability is provided by existing documentation alone under the program.
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-103-0702H/ February 7, 1986 l
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UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 OF INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM CEA INSPECTIONS The contractors have provided Sargent & Lundy with the additional inspection data needed to complete its evaluation for engineering significance as described on page 5 of the original response.
On December 18, 1985, Sargent and Lundy issued a letter to commonwealth Edison documenting the results of this engineering evaluation of the affected CEA's.
Sargent and Lundy concluded that there were no design significant discrepancies identified.
Furthermore, Sargent and Lundy stated that of the discrepancies
{
found, the majority were minor in nature. Although a few notable discrepancies (ones resulting in more than a 10% reduction in the capacity of the member) did exist, Sargent and Lundy's analysis l
showed that significant design margin remains in the as-built assembly. Moreover, the causes of the discrepancies were not related and thus were considered by S&L to be isolated cases. The December 18, 1985 Sargent and Lundy letter also recommended that four specific CIA assemblies be reworked in order to restore design margin. The necessary rework has been accomplished by the l
contractose.
Currently, Sargent and Lundy has cospleted dispositioning each individual identified discrepancy on the CEA Evaluation Transmittals submitted to it by the contractors and has transmitted these Forms to Cosumonwealth Edison Project Construction. After reviewing these
-104-0702H/ February 7, 1986
4 transmittals, Project Construchion will return them to the applicable contractors for closure of contractor documentation and subsequent close-out of Commonwealth Edison NCR's 658 and 659.
)
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-105-0702N/ February 7, 1984
UPDATED REFERENCE - THIRD SET 1.
Letter, dated December 18, 1985 from S.L. Wahlert, S&L Structural Project Engineer to N.N. Kaushal, Connonwealth Edison Field Engineering.
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-106-0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 TO INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM CONCRETE EXPANSION ANCSTORS IN REPAIRED CONCRETE AREAS.
The following information is provided to update the status of this Program.
Commonwealth Edison NCR 634 was closed on November 11, 1985, based on Quality Assurance review and acceptance of Sargent and Lundy's evaluation of CEA test results and conclusion that CEA's already installed in surface repaired concrete were acceptable. As of January 1986 G.K. Newberg is reviewing all patched area drawings for accuracy and completeness. However, changes, if necessary, to these drawings will have no effect on the Sargent and Lundy disposition or the closure of NCR 634.
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-107-0702H/ February 7, 1986
UPDATED REFERENCES - THIRD SET 1.
- Connonwealth Edison NCR 634 (closed), dated November 5,1985.
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-108-0702H/ February 7, 1986 I
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET 7 BRAIDWOOD " TOP WENTY" CORRECTIVE ACTION PROGRAM 1
CEA'S IN FINISHED SLABS The following information is provided to update the status of this Program.
As of February 4, 1986, the rework or revisions under the Program (as described in the original program description) are 99% complete.
PGCo has completed all 32 of its installations and L.K. Comstock has 1 assembly left to rework or revise. Once work on this assembly is completed, PCD will review all documentation for closure of NCR 617.
This review is expected to begin in the near future.
1
-109-0702H/ February 7, 1986
)
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 OF INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM WELDED AND BOLTED CONNECTIONS-BLOCK WALL COLUMNS The following information is provided to update the status of the program as described in the last paragraph of the original response.
On January 19, 1986, Comonwealth Edison Project Construction closed Ceco NCR No. L-434.
This NCR is currently in CECO QA for review and final closure. All corrections encompassed by the program have been reworked in accordance with Sargent & Lundy design documents and are acceptable. A total of 1048 blockwall column and Tee members with bolted and/or welded connections, 75 members with bolted and/or welded connections in miscellaneous structural steel platforms in the Auxiliary Building and 64 external fixes to walls have been completed and the associated quality documents have been reviewed by C.K. Newberg QA and have been found acceptable.
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-110-0702H/ February 7, 1986
UPDATED REFERENCES - THIRD SET 1.
Ceco NCR No. L-434 (PCD closure), dated January 19, 1986.
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-111-0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROGATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" AND "0N-GOING" CORRECTIVE ACTION PROGRAM HVAC INSTALLATION TOLERANCES The following information provides an update on the status of this Program.
Reinspection and approval work as describe >d in the original Program description has continued to proceed steadily since the Fall of 1985. To date, approximately 75% of the hangers and related items have been configuration reinspected and approved, i.e. reworked or as-built, to existing design tolerances. As noted in the original response, completion of all reinspection and back fit work for Unit 1 is expected I
by fuel load and Unit 2 work is expected to be completed thereafter.
Completion of the reinspection program, together with program enhancements under revised procedure B10.3.F. Rev. 2 will assure that all safety-related NVAC hangers will conform to approved design tolerances.
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-112-0702H/ February 7, 1986
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UPDATED RESPONSE - SECOND SET TO SPECIFIC INTERROCATORY 7 OF INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM SOUTHWEST FAB RADIOGRAPHS The following information is provided to update the status of this Program.
As noted in the original program description provided in Conunonwealth Edison's First Partial Response to Interrogatory 7 of Intervenors' Second Set, the review and repackaging of Southwest Fab supplied radiographs was begun in early November 1985. Through January 1986, 40% of the Southwest Fab film has been reviewed. Results to date are consistent with those initially obtained, i.e., less than 0.1% of the total population exhibits signs of visible yellowing. These results have been obtained through a sampiing program to determine the magnitude of the concern.
In addition, it should be noted that only minimal cases of flim found not to be interpretable were identified. Comunonwealth Edison 2
NCR No. 606 remains open pending completion of Program review.
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-113-1 0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP WENTY" CORRECTIVE ACTION PROGRAM PTL RADIOGRAPHIC DENSITY 1.
The following information is provided to update the status of the Program with regard to the 104 PGCo production weld radiograph packages discussed in the original description of the Program provided in Commonwealth Edison's First Partial Response to Interrogatory 7 of Intervenors' Second Set. This information replaces the first paragraph on page four of the original description With regard to the PCCo pr W.ction weld radiograph packages, 84 of the 104 welds found unacceptatie have been repaired and/or re-radiographed. A balance of 20 welde/ packages still remains which require attention. Nineteen of these 20 welds / packages are associated with the Unit II containment spray and will not be accessible until after January 2, 1986 when needed scaffolding is moved from Unit 1.
The remaining weld package is currently being dispositioned on PCCo NCR No.
]
6196 to determine whether any repair and re-radiography is needed. These corrective actions are currently underway. Of the 9 remaining production welds packages (one cutout) needed to account for all PCCo production weld radiograph packages, the five packages which were not located have been re-redlegraphed.
2.
The following information is provided to update the status of the program.
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-114-0702H/ February 7, 1986
t The balance of corrective actions required to resolve the concern with radiograph density are:
1.
Complete repair and/or re-radiography of the remaining 19 PCCo production weld radiograph packages.
2.
Close-out of Phillips, Getschow NCR No.~5209 and No. 6196.
3.
Determine actions required to resolve Power System Inc. welder qualification radiograph packages and implement corrective l
actions.
Upon completion of these remaining activities, the concern with radiographic density will be resolved. The corrective actions currently I
are intended to be complete in early 1986.
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-115-0702H/ February 7, 1986
UPDATED REFERENCES - THIRD SET 1.
PGCo NCR No. 6196.
0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 OF INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM ELECTRICAL CONDUCTOR EXTENSION BUTT SPLICES The following information is provided to update the status of the program as described in the last paragraph of the original response.
As of January 31, 1986, the Program is approximately 97% complete.
There have been 254 conductor extension butt splices identified (2SI-Unit 1 and 3-Unit 2) of which 241 in Unit 1 have been replaced. The remaining 10 are being evaluated by Ceco operations Analysis Department for out of service availability and retest requirements. At the completion of the program, the electrical equipment which had safety-related cable terminations prior to May 1, 1984 will have been inspected, and all conductor extension butt splices installed in safety-related applications prior to establishment of the acceptance criteria will have been replaced. No further corrective action or analysis will be required.
In addition, the L.K. Comstock inspector whose certification was suspended while management reviewed his other inspections has subsequently been terminated by L.K. Comstock based on the unsatisfactory nature of these inspections.
4
-117-0702H/ February 7,1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 TO INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" AND "0N-GOING" CORRECTIVE ACTION PROCRAM STRUCTURAL STEEL INSTALLATION TRAVELER (SSIT)
The followinE information is provided to update the status of this proEram:
TOTAL NUMBER OF SSIT TRAVELERS WHICH HAVE BEEN REVIEWED TO DATE UNDER SSIT DOCUMENT REVIEW 7227 NUMBER OF SSIT TRAVELERS REVIEWED AND ACCEFTED "AS IS" 5471 NUMBER REVIEWED AND AWAITING i
RESOLUTION 1756 The current anticipated date for proEram completion is now March 31, 1986. To date, no hardware deficiencies have been identified as a result of documentation defielencies uncovered by the ProEram.
-118-0702H/Feb 9aary 7,1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" CORRECTIVE ACTION PROGRAM NEWBERG WELDING PROGRAM The following information is provided to update the status of results under this Program.
The SSIT Final Document Review has currently identified a total population of approximately (7800) SSIT Travelers which require review because of documentation deficiencies being tracked in 50.SS(e) report i
84-15 and under Ceco NCR 646.
The current status of the document review program is that 7227 of the SSIT Traveler packages have been reviewed.
5471 of these have been reviewed and accepted. The remaining 1756 of 7227 are awaiting final review afher approval of generic C.K. Newberg NCR's.
The current anticipated date for completion of the program is March 1986. As previously noted, once review has been completed, there will be assurance that all documentation deficiencies concerning C.K.
Newberg SSIT Traveler packages have been identified and resolved.
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-119-0702H/ February 7, 1986
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UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROGATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" AND "0N-GOING" CORRECTIVE ACTION PROGRAM NVAC HOUSINGS AND AIR RISERS The following corrections are made in the first full paragraph on page 3 of the original response describing this Program as contained in Commonwealth Edison's First Partial Response to Intervonors' Second Set.
1)
In the third line of the first sentence of the paragraph insert the words "which were determined not to be clear as is" after
~
the words " inspection records".
2)
In the last sentence of the paragraph change the word
" reinspection" to " inspection".
These changes indicate that those inspection records which Commonwealth Edison Project Construction reviewed and found to be sufficiently clear were not recreated and reinspected under the Program.
1 The following information is provided to update the statusaof this Program.
To date, PSM Production and Quality Control personnel have completed approximately 35% of the configuration / weld quality inspections for the Auxiliary Building (VA System) Exhaust Filter Housings and approximately 45% of the inspections for the Unit 1 (VP System) Reactor Containment Fan Cooler Housings and associated Return Air Risers. Unit 1 inspection work is expected to be concluded by fuel load, with Unit 2 inspection work to be completed thereafter. As noted in the original response describing 1
I
-120-0702H/ February 7,1986 r
J this Program, upon Program completion, all welds and as-built configurations for these housings and air risers will have been corrected I
and Quality Control verified in accordance with existing approved 4
Braidwood design drawings.
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i 0702H/Pebruary 7, 1986
1 UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET nRAIDWOOD " TOP TWENTY" AND "0N-GOINC" CORRECTIVE ACTION PROGRAM l
HVAC DUCT FITTINGS The following information is provided to correct the otatus of this program:
1)
In the fifth and sixth paragraphs of the original response, the total number of fittings reviewed by PSM for compliance with the revised duct brochure and/or S&L approved design drawings is 2.814, not 2.823 as reported in the original response describing this Program. Of the 2,814 PSM determined 1849, not 1852, fittings completed with S&L approved design.
2)
In the seventh paragraph of the original response, 965, not 971, fittings have been identified as not in conformance with design. Approximately 568, not 620, fittings have been as-built by PSM.
Based on S&L's review, 67, not 70, fittings i
require repair or rework. Finally the additional 330, not 351, fittings are to be reworked to achieve design conformance.
The following information is provided to update the status of the program.
I To date, approximately 80% of the 397 (330 + 67) fittings requiring rework have been completed. Once rework is achieved, the entire population of 965 (not 971) fittings now identified as not meeting design will be QC inspected. The program is currently expected to be complete for Unit i fittings by May 1986 and for Unit 2 thereafter.
-122-0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET BRAIDWOOD " TOP TWENTY" AND "0N-COINC" CORRECTIVE ACTION PROGRAM L.K. COMSTOCK DOCUMENT REVIEW The followinE updated inforination provides the status of the program as of January 31, 1986:
TOTAL RECORDS WITHIN THE SCOPE OF THIS PROGRAM 107,057 TOTAL RECORDS REVIEWED TO DATE 101,758 (95%)
TOTAL RECORDE REMAINING TO REVIEW 5.299 ( 5%)
TOTAL RECORDS FOUND SATISFACTORY TO DATE 81,805 (80%)
TOTAL RECORDS FOUND UNSATISFACTORY TO DATE 19,953 (20%)
of the 19,953 records deemed unsatisfactory, 18,255 have been reconciled by Level II Inspectors. Of the 18,255 reconciled, 173 required field inspection, 18,082 office correction. Again, the majority of discrepancies noted to date have been primarily of an administrative or j
clerical nature requiring minimal hardware reinspection.
- The original larger count of 115,106 records within the program scope identified in the original response has been revised downward because it included certain CEA traveler packages and rework packages which required no review and old Forn 7 packages which have been replaced with new Forn 7's under Cosmonwealth Edison NCR's 708 and 709.
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-123-0702H/ February 7, 1986 1
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i UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 0F INTERVENORS' SECOND SET REINSPECTION OF SAFETY RELATED MECHANICAL EQUIPMENT l
An updated response to this contention Item is contained in comonwealth Edison's prepared detailed report with respect to the
" Reinspection of Safety Related Mechanical Equipment" corrective action program as originally described in Specific Interrogatory 7 of Intervonors' second Set. This report has already been furnished to the Intervonors. The report is inicorporated herein by reference as a part of this Contention Item update, a
1 I
0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROGATORY 7 0F INTERVENORS' SECOND SET QUALITY CONTROL INSPECTOR REVERIFICATION P E *AM The field inspections associated with the QCIRP are nearing completion and are expected to be complete for all contractors in the program by mid-February. Once the field inspections are complete, analysis of the results will be performed prior to program closure. This analysis is expected by May 1986.
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-125-0702H/ February 7, 1986
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l UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 OF INTERVINORS' SECOND SET BRAIDWOOD "0N-COING" CORRECTIVE ACTION PROCRAN QUALITY CONTROL STRUCTURAL STEEL REVIEW (OCSSR)
C.K. Newberg has completed the two action items required by Sargent and Lundy in its June 20, 1985 letter summarizing its review of as-constructed conditions under the QCSSR Program. Replacement of A-307 bolts with high-strength A-325 bolts in Napolean erected steel friction connections in the Containment was completed on September 22, 1985.
These bolts have been tightened in accordance with design drawings.
Installation of missing bolts in connections was completed on, January 21, 1986.
Individual G.K. Newberg NCR's generated as a result of the program will be closed based on the issuance and dispositioning of a Commonwealth Edison NCR to close-out the QCSSR Program. This NCR will be issuad in the near future.
-126-0702H/ February 7, 1986
UPDATED RESPONSE - THIRD SET TO SPECIFIC INTERROCATORY 7 OF INTERVENORS' SECOND SET BRAIDWOOD "0N-COING" CORRECTIVE ACTION PROGRAM INSTRUMENT RETROFIT VERIFICATION PROGRAM (IRV)
The following information is provided to update the status of this program.
In September 1985, Conunonwealth Edison Site Quality Assurance performed Surveillance No. 5062, dated September 30, 1985 to define the scope and items needed to complete the IRV Program. The Surveillance concluded that based on QA reviews performed of documentation included in d
the program and the fact that the IRV Program's scope can be readily determined /re-created by reviewing Ceco NCR 715 (which contains a listing
)
of all safety-related instrument installation and related isometric drawings (ISO's) encompassed by the program) no additional los of ISO drawings need be kept. Should a question arise as to why a given a
instrumentation was not included in the program, the production data package for the instrumentation ISO may be reviewed to determine when Revision 0 of the drawing was approved for construction.
As of January 1986, Phase I & II IRV walkdowns and engineering involvement are couplete.
PCCo engineering has forwarded all IRY docunentation packages to PCCo Quality Control for final document review. Essed on this and PCCo's subsequent documentation review, CBCo WCR 715 was closed on January 16, 1986. The appropriateness of the closure is doctamented in Commonwealth Edison QA surveillance No. 5373, dated January 3, 1986.
Sy letter dated January 21, 1986, Commonwealth Edison informed the ERC Rag'.on III that all reinspection, rework and documentation review under the IEV Program has been cog leted.
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-127-0702H/ February 7,1986
R UPDATED REFERENCES - THIRD SET 1.
Ceco QA Surveillance No. 5062, dated September 30, 1985.
2.
CICo NCR 715 (closed), dated January 16, 1986.
3.
Ceco QA Surveillance No. 5373, dated January 3, 1986.
4.
Ceco letter, dated January 21, 1986, from A.D. Miool to J.G.
Keppler, NRC Region III.
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-128-0702H/ February 7, 1986
.~.
UNITED STATES OF AMERICA NUCLEAR REGULATORY C000tISSION
^
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
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C00st0NWEALTH EDISON COMPANY
)
Docket Mos. 50-456
)
50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF DAVID A. BOOWE I
I, David A. Boone, being first duly sworn, depose and state as follows:
1.
I an employed by Conunonwealth Edison Company as a Consultant at j
Braidwood Nuclear Station.
I 2.
My business address is Braidwood Nuclear Power Station, Bracev111e, Illinois 40407.
3.
I have participated in the preparation of the response to i
specific Interrogatory Number 9 flied by Interveners Rorea 3L, gL, in their Third set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated infomation on Commonwealth Edison's responses to Interrogatories 58 and a
59 of Intervonors' First set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular. I have responsibility for the l
updated information on Interrogatories 58 and 59, Contention Items 6F.
3A.4.5, 10C and 10E, as updated, the updated portions of the response to specific Interrogatory 4 captioned " Pipe Support Installation and Welding", and the updated portion of the response to specific I
Interrogatory 7 captioned "CEA Inspections".
4.
To the best of my knowledge and belief, the updated information 1
I contained in the response to specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
subscri to and sworn before me this day of February, 1986 U
g i
Ny comunission empires on
/0,/3 n /R9 1
i 0710H/0 i
UNITED STATES OF AMERICA NUCLEAR RECULATORY C000tISSION BEFORE THE ATOMIC SAFETY AND LICENSINC BOARD In the Matter of
)
)
C00000lndEALTH EDISON CONFANY
)
Docket Nos. 50-456
)
50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF JAME8 W. GIE55KER I, James W. Cieseker, being first duly rworn, 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, Bracev111e, Illinois 40407.
3.
I have participated in the preparation of the response to specific Interrogatory Number 9 filed by Intervenors Bores gL, gL, in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on comunonwealth Edison's responses to Interrogatories 58 and 59 of Intervonors' Pirst Set and Interrogatories 1 through 7 of Intervonors' Second Sat.
In particular I have responsibility for the updated information on Interrogatories 58 and 59, Contention Items 115, 9C and 10F, as updated, and the updated portions of the response to Specific Interrogatory 7 entitled " Quality Control Inspector Reinspection Program".
4.
To the best of my knowledge and belief, the updated information contained in the response to specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
0 1% h).
Q Subec to and Sworn before me this day of February, 1986 l
0 6
My commission owpires on
/t, / % /M, 0710H/1
UDITED STATES OF AMERICA NUCLEAR REGULATORY ColetISSION BEFORE THE ATOMIC SAFETY AND LICENSINC BOARD In the Matter of
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C00010NWEALTH EDISON COMPANY
)
Docket Nos. 50-456
)
50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF GEORGE F. P_Aw1J3 I, George F. Marcus, being first duly sworn, depose and state as follows:
1.
I an employed by Comanonwealth Edison company as Assistant to the Manager of Quality Assurance 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 Interrogatory Number 9 flied by Intervonors Rorem & i in their Third set of Quality Assurance Interrogatories and Request to produce.
This Interrogatory requests supplemental and updated information on Cossoonwealth Edison's responses to Interrogatories 58 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the updated response to specific Interrogatory 5.
4.
To the best of my knowledge and belief, the updated information contained in the response to specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
- 6. <44 m. fin V
Subsce to and Sworn before ma this day of February, 1986 b
4 a
s My comunission empires on 16hn/fG 0710H/12
UNITED STATES OF AMERICA NUCLEAR REGULATORY Cole (ISSION 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 N.A. SCHRYER I, M.A. Schryer, being first duly sworn, depose and state as follows:
1.
I an employed by Conunonwealth Edison Company as a Consultant 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 Interrogatory Number 9 filed by Intervenors Rores & & in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Cosunonwealth Edison's responses to Interrogatories 53 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular I have responsibility for the updated portions of the response to Specific Interrcgatory 7 captioned
" Electrical Conductor Extension Butt Splices".
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
l LW' l
SubscylpdayofFebruary,1986 to and Sworn before me this /
klA
~ o s
My comunission expires on 10hoM9 0710H/15
UNITED STATES OF AMERICA NUCLEAR REGULATO2Y CONNISSION 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 Gemarn E. GROTH i
I, Gerald E. Groth, being first duly sworn, depose and state as follows:
1.
I an employed by Commonwealth Edison Company as Assistant Project Construction Superintentent 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 Specific Interrogatory Number 9 filed by Intervenors Rorem th, al. In their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on comunonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' second Set.
In particular, I have responsibility for the updated infor1 nation on Interrogatories 58 and 59, Contention Item 60 as updated.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
f-, k l
3
/
Subse_r pi to and Sworn before me this*)Dr day of February, 1994
~
U
[
My cossaission expires on lo136129 0713H/4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BgFORg THg ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Mos.
50-456
)
50-457 (Braidwood Station Units 1 and 2 )
AFFIDAVIT OF PERRY L. BARNES 1
I, Perry L. Barnes, being first duly sworn, depose and state as follows:
i I
1 1.
I an employed by conononwealth Edison Company as a licensing engineer at the Braidwood Nuclear Station.
2.
My business address is Braidwood Nuclear Power Station, i
Braceville, Illinois 60407.
I 3.
I have participated in the preparation of the response to l
Specific Interrogatory Number 9 filed by Intervenors Rorem et. al. In their Third Set of Quality Assurance Interrogatories and Request to Produce.
In particular, I was responsible for providing updated information on whether the NRC has changed the status of the Items contained in Intervonor's Quality Assurance contention since Applicant filed its response to specific Interrogatories 58 and 59 from Intervenors' First Set of Quality Assurance Interrogatories and Request to Produce as updated in Interrogatory 3 of Intervenors' Second Set. To the best of my knowledge and belief, the updated information concerning the WRC status of Contention Items contained in Applicant's response to Specific Interrogatory 9 of Intervenors' Third Set of Quality Assurance Interrogatories and Request to Produce is true and correct.
In some respects, my determinations are not based on my personal i
knowledge but upon information provided by other Commonwealth Edison employees, consultants and contractors. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Further affiant sayeth not.
w subscri ed to and sworn before me
(/
this day f February, 1986 Y
I 0
t My connission expires on 10/so k9 0710H/2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j
BEFORE THg ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos.
50-456
)
50-457 (Braidwood Station Units 1 and 2 )
1 AFFIDAVIT OF CLIFTON D. GRAY III I, Clifton D. Gray III, being first duly sworn, depose and state as l
follows:
l 1.
I an employed by Conunonwealth Edison Company as the Project Structural Supervisor, Project Construction Department 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 9 filed by Intervonors' Rorem, et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This *aterrogatory requests supplemental and updated information on Coat o.. wealth Edison's responses to Interrogatories 58 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervonors' Second Set.
In particular, I have responsibility for the updated portions of the response to Specific Interrogatory 7 captioned
" Welded and Bolted Connections in Block Wall Columns".
4.
To the best of my knowledge and belief, updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
Subscri ed to and Sworn before as this da of February 1986 b'
9 i
My connaission expires on inf30/ W 0710H/13
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 MARK A. POLAND I,
Mark A.
Poland, being first duly sworn, depose and state as follows:
1.
I am employed by Cosmonwealth 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 specific Interrogatory Number 9 filed by Intervonors Rorem et. al. in their Third set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervonors' Second Set.
In particular, I have responsibility for the updated portions of the response to specific Interrogatory 7 captioned
" Quality control Structural Steel Review (QCSSR)".
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
I W
Subscri d to and Sworn before as this day f February, 986 (M
/
4 My commission exp/g 9 ires on
/0/30 0710H/17 l
l 1
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 BRUCE L. TANOUYE I,
Bruce L. Tanouye, 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 l
Specific Interrogatory Number 9 flied by Intervenors Rorem et. al. In their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through -7 of Intervonors' Second Set.
In particular, I have responsibility for the updated portions of the responses to Specific Interrogatory 7 captioned "CEA's in Repaired Concrete", "CEA's in Finished Slabs", and " Structural Steel Installation Traveler".
4.
To the best of my knowledge and belief, the updated information
- contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
M fM Subsc to and Sworn before me this day of February, 1986 Af %. 0 WM 0
'~d My comunission expires on I()l30 [T@
0710H/10
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 ANTHONY J. D' ANTONIO I, Anthony J. D' Antonio, being first duly sworn, depose and state as follows:
1.
I am employed by Commonwealth Edison Company.
Through February 3, 1986, I was the Level III N.D.E. Inspector in Ceco's QA Department 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 specific Interrogatory Number 9 filed by Intervenors Rorem et. al. in their Third set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the updated portions of the responses to specific Interrogatory 7 captioned
" Southwest FAB Radiographs" and "PTL Radiographic Density".
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory 9 identified above is true and correct.
Further affiant sayeth not.
r Subscrib to and Sworn before me this day of February, 1986 M
8 i
My comunission expires on
/g/snsq 0710H/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 WALTER J. MARCIS I, Walter J. Marcis, being first duly sworn, depose and state as follows:
1.
I am employed by Conunonwealth Edison Company as 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 9 filed by Intervenors Rorem et. al. in their Third Set of Quality Assurance 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 second Set of Interrogatories and Request to Produce, as updated in response to Specific Interrogatory 3 of Intervenors' Second Set. This Interrogatory requests supplemental and updated information on Conunonwealth Edison's responses to Interrogatories 58 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervonors' Second Set.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
D6444Er T
Subscri ed to and Sworn before me this /
day of February, 1986 Al A Y 0x lb,, fM, y
My connaission expires on
/N 3D/f9 0713H/2
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 HENRY A. ZIMMERMAN I, Henry A. Zimerman, being first duly sworn, depose and state as follows:
1.
I an employed by Comonwealth Edison Company Project Material and Parts Coordinator for Project Construction at Braidwood Nuclear Station.
2.
My business addrece is Braidwood Nuclear Power Station, Braceville, Illinois 60407.
3.
I have participated in the preparation of the response to Specific Interrogatory Number 9 filed by Intervenors Rorem et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Comonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for'the updated information on Interrogatories 58 and 59, Contention Item 12G as updated.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
j bWlb Subscri to and Sworn before me this day of February, 1986 N3 Di.
fM4
~
/
~~d My comission expires on
/Of%I 7 Tf 0713H/6
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BgFORE THg 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 PHELAN I, James Phelan, being first duly sworn, depose and state as follows:
1.
I an employed by Conunonwealth Edison Company as a Project Field Engineering 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 Specific Interrogatory Number 9 filed by Intervenors Rorem et. al. In their Third set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the updated information on Interrogatories 58 and 59, Contention Items 88, 8C, and 10D, as updated and the updated portions of the response to Specific Interrogatory.6 entitled " Cable Tray Separation Walkdown Program".
l 4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
l m
7 subscribed to end sworn before me
( w /d day of this ob ry, 1986 174,0% r
(
l l
l My connaission expires on m%Egiros AprgIg 3,ggg i
0713H/8
\\
l I
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 1
(Braidwood Station' Units 1 and 2 )
AFFIDAVIT OF MICHAEL R. DOUGHRRTY I, Michael R. Dougherty, being first duly sworn, depose and state as follows:
1.
I am employed by Connonwealth 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 9 filed by Intervenors Rorem et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce. This Interrogatory requests supplemental and updated information on Conunonwealth Edison's responses to Interrogatories 58 and 59 of Intervonors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the updated information on Interrogatories 58 and 59, Contention Items 6A, 8A, 10A, 12A and 13A, as updated, the updated portions of the responses to Interrogatory 4 captioned " Steam Generator Bolting", the updated portions of the response to Interrogatory 6 captioned " Mechanical Equipment Disassembly and Inspection", and the updated portions of the response to Interrogatory 7 captioned " Reinspection of Safety-Related Mechanical Equipment".
4.
To the best of my knowledge and belief, the updated information contained in the response to specific Interrogatory Number 9 identified above is true and correct.
Furthee affiant sayeth not.
As oh Subscrib to and Sworn before me thisI day of February, 1986 0 DL A 5 M
()
ru My connaission ~ expires on ro/2n/R9 i
/
0710H/6
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BgFORE 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 DAVID L. JONES I,
David L.
Jones, being first duly sworn, depose and state as follows:
1.
I am employed by Commonwealth Edison Company in the position of Construction Supervisor for Instrumentation 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 specific Interrogatory Number 9 filed by Intervenors Rores et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on ccanonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 throu*;h 7 of Intervenors' Second Set.
In particular, I have responsibility for the updated portiont-of the response to specific Interrogatory 7 captioned
" Instrument Retecfit Verification Program".
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.'
Further affiant sayeth not,
>Mn t
i
~ l l
Subscri to and Sworn before me this /A day of February, 1986 AAdLMOM 8
(
My connaission expires on
/0/30/v9 0710H/18-
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 DEAN A. HOFFER 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, Bracoville, Illinois 60407.
3.
I have participated in the preparation of the response to Specific Interrogatory Number 9 filed by Intervenors Rorem et. al. In their Third Set of Quality Assurance Interrogatories and Request to Produce. This Interrogatory requests supplemental and updated 1
information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the second paragraph of the updated information on Interrogatories 58 and 59, Contention Item 6B.5, as updated.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
[
h/'M U
Subscri to and Sworn before me this[6 day of February, 1986 OA Y
~
g
(
My conunission expires on lofAo/RG 0710H/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 STEVEN C. HUNSADER I, Steven C. Hunsader, being first duly sworn, depose and state as follows:
1.
I an employed by Commonwealth Edison Company as Site Quality Assurance Supervisor at Braidwood Nuclear Station.
2.
My business address la Braidwood Nuclear Power Station, Braceville, Illinois 60407, f
3.
I have participated in the preparation of the response to Specific Interrogatory Number 9 filed by Interveno,1 Rorem et. 41, in their Third Set of Quality Assurance Interrogatorias and Request to Produce.
This Interrogatory requests supplemental and updated information on commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervonors' Second Set.
In particular, I have responsibility for the updated information on Interrogatories 58 and 59, Contention Item 12F.
4.
To the best of my knowledge and belief, the updated information i
contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
-[
..m 1
Subscri to and Sworn before me j
this b
February, 1986 AA W
e f
i My constission expires on
/0/3c)/W l
0713H/7 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 WALLY BRUNS I, Wally Bruns, being first duly sworn, depose and state as follows:
1.
I am employed by Cosmonwealth Edison Company as a Project Constmetion Department Field Engineer at Braidwood Nuclear Station.
2.
My business address is Besidwood Nucisse Power Station.
I Braceville, Illinois 60407.
3.
I have participated in the preparation of the response to the Specific Interrogatory Ihamber 9 filed by Intervenors Rorem et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Intertsgatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the I
updated portions of the response to Specific Interrogatory 7 captioned "Newberg Welding Program".
j 4.
With these changes, to the best of my knowledge and belief, the I
updated information contained in the response to Specific Interrogatory i
Number 9 identified above is true and correct.
Further affiant sayeth not.
d subscribed to and Sworn before me this/ d day of February, 1986 b
b M
o o
My conmission expires on 16,l'66 lR 9 i
f 0710H/16 l
.. ~....
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0KMZSSION 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 SCOT T. FORBES I, Scot T. Forbes, being first duly sworn, depose and state as follows:
1.
I am employed by Phillips Cetschow Company as a Site Quality Assurance Coordinator 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 Specific Interrogatory Number 9 filed by Intervenors Rorem et. al. In their Third Set of Quality Assurance Interrogatories and Request to Produce. This Interrogatory requests supplemental'and updated information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the i
updated portions of the response to Specific Interrogatories 58 and 59, contention item 12.C.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
w Further affiant sayeth not.
)
/
><v Scot T. Forbes Subscri to and Sworn before me this day of February, 1986 hA
%.DhfM o
o My commission expires on
/o / 3d/SQ
/
0710H/19
UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
)
)
COMMONWEALTM EDISON COMPANY
)
Docket Nos. 50-456
)
50-457 (Braidwood Station Units 1 and 2 )
1 l
AFFTDAVIT OF MICHAEL J. KOPP I, Michael J. Kopp, being first duly sworn, depose and state as follows:
l.
I an employed by Commonwealth Edison Company as Project Construction Engineer at Braidwood Nuclear Station.
2.
My business address is Braidwood tuclear Power Station, Braceville, Illinois 60407.
3.
I have participated in the preparation of the response to specific Interrogatory Number 9 flied by Intervonors Rorem et. al. In their Third Set of Quality Assurance Interrogatories and Request to Produce. This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' second Set.
In particular, I have responsibility for the updated portions of the response for Specific Interrogatory 7 captioned "Comstock Document Review".
4.
To the best of my knowledge ~and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
- W f'/
//
i subscri to and Sworn before me this day of February, 1986 N /l N
9 y
My commission expires on tr)/Ao/W i
0710H/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 EDWARD M. SHEVLIN I,
Edward M. Shevlin, being first duly sworn, depose and state as follows:
l.
I am employed by Daniel International Corporation.
I am currently acting as a contract employee in Phillips, Getschow Quality 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, Braceville, Illinois 60407.
3.
I have participated in the preparation of the response to Specific Interrogatory Number 9 filed by Intervenors Rorem et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Consmenwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have~ responsibility for the updated information on Interrogatories 58 and 59, Contention Item 12J.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
1 f 6Hbh/ 6 Subscri ed to and Sworn before me this/ - xday of February,1986 WA N
o o
My connaission expires on
/d/ 3c)/ M 0713H/1
1 UNZTED 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 MICHARL A. GORSKI I, Michael A. Gorski, being first duly sworn, depose and state as follows:
1.
I am employed by Commonwealth Edison Company as a Project i
Construction Field Engineer at Braidwood Nuclear Station.
2.
My business address is Braidwood Nuclear Power Station, Bracev411e, Illinois 60407.
3.
I have participated in the preparation of the response to Specific Interrogatory Number 9 filed by Intervonors Rorem et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce. This Interrogatory requests supplemental and updated infomation on Commonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervonors' Second Set.
In particular, I have responsibility for the updated information on Interrogatories 58 and 59, contention Items 3A.4.C. 3A.4.E, 68.1,10B and 125.1, as updated, and the updated portions of the responses to Specific Interrogatory 7 entitled "ASME Material Procurement" and "ASME Nameplate Documentation Retrieval Program (NDRP)".
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
Subscribed to and Sworn before me this /CA day of February, 1986 A
M
-(
g My commission expires on in.t a n /89 0710H/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 )
l 1
AFFIDAVIT OF DANIEL L. SHAMBLIN i
I, Daniel L. Shamblin, being first duly sworn, depose and state as follows:
1.
I an employed by Commonwealth Edison Company as s' Project Construction 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 Specific Interrogatory Number 9 filed by Intervenors Bores et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Commonwealth Edison's responses to Interrogatories 58 and j
59 of Intervenors' First Set and Interrogatories 1 through 7 of i
Intervenors' Second Set.
In particular, I have responsibility for the updated information on Interrogatories 58 and 59, contention Items 6C, 85, and 8F, as updated.
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further afflant sayeth not.
l 0.
Subscri to and Sworn before me this of February, 1986 A
M G
'~~f l
~
My connaission expires on Io,lso /R9 0713H/3
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 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 Department 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 9 filed by Intervenors Rorem et. al. in their Third Set of Quality Assurance Interrogatories and Request to Produce.
This Interrogatory requests supplemental and updated information on Consonwealth Edison's responses to Interrogatories 58 and 59 of Intervenors' First Set and Interrogatories 1 through 7 of Intervenors' Second Set.
In particular, I have responsibility for the updated information on Interrogatories 58 and 59, contention Items 3A.1, 3A.2 and 12B.3, as updated, and the updated portions of the responses to Interrogatory 7 captioned "HVAC Installation Tolerances", "HVAC Housings and Air Risers", and "HVAC Duct Fittings".
4.
To the best of my knowledge and belief, the updated information contained in the response to Specific Interrogatory Number 9 identified above is true and correct.
Further affiant sayeth not.
1
[ -_ -
b8 U
u Subscribed to and Sworn before me this M day of February, 1986 A
h My commission expires on a-//-4 0710H/3
SEAATED CORRESPONDEN,CR UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 000HEiED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD USWC In the Matter of
)
'86 FEB 13 #0 50
)
COMMONWEALTH EDISON COMPANY
)
Docket Note. g 0.-456.
g,
)
O t#7fA SOGi; f.
(Braidwood Station Units 1 and 2
)
BRANCH CERTIFICATE OF SERVI _C_E I, Gary A. Kruse, one of the attorneys for Consonwealth Edison Company, certify that the following persons have been served in the above entitled matter with copies of Applicant's Second Partial Response to Intervonors' Third Set of Interrogatories and Request to Produce by deposit in the U.S. Mail on February ll, 1986 unless otherwise indicated.
SERVICE LIST Herbert Crossman, Esq.
Mr. William L. Clements Chairman chief, Docketing and Services Administrative Law Judge United States Nuclear Regulatory Atomic Safety and Licensing Comunission Board Office of the Secretary United States Nuclear Regulatory Washington, DC 20555 Washington, DC 20555 Dr. Richard F. Cole Ms. Bridget Little Rorem Administrative Law Judge 117 North Linden Street Atomic Safety and Licensing P.O. Box 208 Board Esser, Il 60935 United States Buclear Regulatory Washington, DC 20555 Dr. A. Dixon Callihan Charles Jones, Director Administrative Law Judge Illinois Energency Services 102 Oak Lane and Disaster Agency Oak Ridge TN 37830 110 East Adams Springfield, Il 62705 0735H
._. I i
Stuart Treby, Esq.
William Little, Director Elaine I. Chan, Esq.
Braidwood Project Office of the Executive Legal Region III Director United States Nuclear Regulatory United States Nuclear Regulatory Connaission comunission 799 Roosevelt Road Washington, DC 20555 Glen Ellyn Il 60137 Atomic Safety and Licensing Janice A. Stevens Board Panel (For Addressee only)
United States Nuclear Regulatory.
United States Nuclear Regulatory Comunission 7920 Norfolk Avenue Washington, DC 20555 Phillips Building Bethesda, MD 20014 Atomic Safety and Licensing George L. Edgar, Esq.
Appeal Boar:t Panel Thomas A. Schmuts, Esq.
United States Nuclear Regulatory Newman & Holtsinger, P.C.
Comunission 1615 "L" Street, N.W.
Washington, DC 20555 Suite 1000 Washington, DC 20036
- Robert Guild Douglass W. Cassel, Jr.
Timothy W. Wright, III BPI 109 North Dearborn Street Suite 1300 j
Chicago, Il 60602
- Messenger delivery on February 11, 1986.
-caryi. pus.-
Isham, Limosaa & Beale Three First Entional Plaza suite 5200 Chicago, Illinois 60402 (312)558-7500 Dated:
February 11, 1986 0735H
- - _,