ML20153D839
| ML20153D839 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/18/1986 |
| From: | Guild R GUILD, R., ROREM, B. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20153D822 | List: |
| References | |
| OL, NUDOCS 8602240269 | |
| Download: ML20153D839 (177) | |
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February '18,198dhCMETED USNRC UNITED STATES OF AMERICA a .. NUCLEAR REGULATORY COMMISSION 16 fB3 2) pj ;pf Before the Atomic Safety and Licensing Board 0FFICE 0T H 03t he 00CMETihG A SE6vni BRANCH In the Matter of: .
)
COMMONWEALTH EDISON COMPANY ) No. 50-456
) 50-457 (Braidwood Nuclear Station, )
Units 1 and 2) ) INTERVENORS ' ANSWER OPPOSING APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION INTRODUCTION Intervenors Forem, et al., oppose Applicant's December 20, 1985, motion for summary disposition regarding 19 subparts of our quality assurance contention on the grounds that a broad range of significant and genuine issues of fact raised by the subject contention subparts remain in dispute and require resolution through completion of discovery and hearing. Intervenors iden-tify portions of the testimonial af fidavits and exhibits filed in support of Applicant's motion which must be disregarded on the i grounds that the competence of the witnesses to testify to the matters stated has not been shown or that the f acts set forth would not be admissible in evidence. On the basis of Applicant's moving papers themselves, the incomplete discovery to date and the limited ability of Intervenors' to depose only five of Applicant's 20 supporting witnesses in the time available during the pendency of this 1 1 8602240269 DR 860218 1 g ADOCK 05000456 PDR ; i
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- motion'it is apparent -that' Applicant's factual claims are' simply _ ,
-unsupportable .in- many important respects. Factual contradic-tions, gaping holes in the material evidence and unsubstantiated ~
assertions abound. Further, in many instances Applicant's wit-nesses lack any personal knowledge whatever of the. material facts which they alone support. In some cases the witness arrived at the Braidwood site only years af ter the . events in ' question; :in others the only involvement.of the witness in the subject of:the-specific quality assurance failure was the preparation of his testimonial. affidavit in support of summary disposition. Final-ly, in many~of instances critical documents and reports which are claimed to support Applicant's position are not filed with the summary disposition motion. In some cases the document has never-even been identified in discovery or was made available only -at the witness' -deposition if at all. Pule 56(e) of. the Federal Pules of Civil Procedure requires that any such documents be served with the summary disposition motion as part of the movant's burden of proof.. 6 Moore's S56.22 il] Although the Commission rule is silent on the matter, such an obligation should be imposed upon Applicant here, particularly in light of the. complexity and scope of its motion. < Fundamentally, Applicant's motion for summary disposition is
-ill-founded. In seeking to summarily. dispose of contention sub- !
items each founded upon a specific historic NPC Staff finding -of quality assurance failure at Praidwood Applicant seems to ask this Board to erase each such historic f1'aw from the Braidwood quality assurance record "with no subcoquent opportunity for.
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. I n te rv eno'r s to use_ them- to' demonstrate patterns of inadequacids." .s
. Motion ~ and Supporting Memorandum of Commonwealth Edison Company for Summary Disposition on Pleadings as to Certain Subconten-l - tions, ' December 20,1985, (hereinaf ter Motion for Summary Disposition), p. 11.- Such an ' approach defies -not only-historic l experience but also-the guidance of the Appeal Board in United i
Electric Company (Callaway Plant, Unit 1), ALAB-740,-18 NRC 343, 346.(1985), which recuires that this'very record of quality
" implications" that assurance deficiencies txt evaluated for unidentified and uncorrected safety flaws' remain in the facility.
The existence of such a record of quality assurance deficiencies, as Intervenors believe has occurred at Braidwood, precludes the
" reasonable assurance" determination which must be established to entitle Applicant to the operating license it seeks.
As a general matter summary disposition is inherently inappropriate for the resolution of such critical and complex aspects of these contention subparts-as the significance of the OA failure, its rcot cause, generic implications and the effectiveness of any corrective action. E.g., 10 CPP _ S50.55(e); Part 50, Appendix B, Criterion XVI; Callaway, supra. Such aspects are akin to the ultimate issues in the proceeding. They are of high public interest and importance and can only. be - resolved through a thorough evaluation of.all the evidence in the proceeding including a complete record af ter full discovery ~and a review'of the demeanor and credibility of " live" witnesses subject.to cross examination in. a public hearing. The Nuclear Pegulatory Commission Rule providing for summary l l
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disposition is set out in 10 CFR S2.749. The Commission's summary disposition procedures have been analogized to Rule 56 of the Federal Rulee of Civil Procedure. Cleveland El{ctric Illiminating Co. et al. (Perry Nuclear Power Plant, Units 1 and
- 2) ALAB-443, 6 NRC 741, 753-54 (1977). In addition to the requirements of 10 CFB S2.749, various Licensing Board and the Appeal Board decisions set the standards for summary disposition.
The Appeal Board has stated that " summary disposition is a harsh remedy. It deprives the opposing litigant of the right to cross 1 i examine the witness, which is perhaps at the very essence of an 1 l adjudicatory hearing" Perry, supra. l l Summary disposition is only authorized where it is quite cicar what the facts are, and where no genuine issue remains for trial. In determining such a motion, the record will oc viewed in the light most favorable to the party opposing the motion. Gulf States Utilities (Piver Dend Station, Units 1 and 2) LBP 10, 1 NPC 246 (1975). Fven if no party opposes a motion for summar y disposi tion, the movant's filings must still establish , l the absence of a genuine issue of material fact. Adickes v. Kress & Co., 398 U.S. 144 (1970); Cleveland Electric Illuminating ] Co. et al. (Perry Nuclear Power Plant, Units 1 and 2) ALAB-443, 6 l NPC 741 (1977). ) i l DEFICIENCIES IN EDISON'S EVIDENTIARY AFFIDAVITS l l Pursuant to the provisions of 10 CPP S 2.74 9 ( b) , " Affidavits l l shall set forth such facts as would be admissible in evidence and l l i 4 l l j
l 1. - ... L i l- ~ 7shalli show af firmatively that the a f fiant Is . competent to testi-
-mony to the matters: stated therein."
L Pursuant ' to Pule 56(e) of the Federal Rules of-Civil Procedure, supporting and opposing affidavits shall be made j on personal knowledge, shall set forth such facts-as would be admissible in evidence, and shall show af firmatively that -the af fiant 'is competent to testify to the matters stated herein. Sworn or certified copies of all papers or parts thereof referred to in an affidavit shall be attached thereto or served therewith. I l Becauce numerous portions of Edison's affidavits in support of its motion for summary disposition conform neither to the reouirements of 10 CFR S2.749(b) nor to the standards of Pule 56(e) of the Federal Pules of Civil Procedute, any alleged
" material facts" based on such unreliable af fidavits should be disregarded.
A. Certain Of Edison's "Faterial Facts" Should Be Disregarded As Unreliable Because They Are Based
- On Portions Of Affidavits As To which Affiant Lacks Personal Knowledge And Competency To Testify, And Which Contain Conclusions Unsupported By Specific Facts In the absence of an af firmative showing of personal knowledge or competence to test ify to the matters stated, affida-vits should be disregarded along with any " material fact" which is supported by the affidavit. 10 CFP S2.749(b); American Radio M fg. Co., Inc. v. Hazel t ine Desea rch, Inc., 3 39 U.S. 82 7, 831 i
l (1950); Stevens v. Barnard, (CA 10th 1975)_512 P.2d 876 (affida-l vits must indicate on.their face that the information contained therein is upon personal knowledge; this requirement cannot be ! 5 , 1
., .. . . __ _ . . _ . . ~ - . _ _ - _ _. _ _ _ - -
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~1nferred); 6 Moore's ' S56.22 [1]. The absence'of an affirmative. 'l f . showing "... that the affiant is competent to testify to the
. . matters stated therein" vitiates the sufficiency of the af fida-i- vit. 10 CFR S2.74 9 (b) . See also Durovic v. Palmer, 342 F.2d 634 i (7th Cir. 1965). . J ! Moreover, af fiant's " belief" 'and mere conclusions do not' meet the requirements of 10 CFP S2.749(b) or the standards set i e t j by Bule 56(e). United States v. Manuf acturers Bank of Southfield, i' j 518 P.Supp. 4 9 5, 4 97 (E.D. M ich.1981). As the U.S. Cour t of 1 i i Appeals for the Seventh Circuit has-held, "[S]uch expressions (of 1 I opinion] are totally ineffectual, and are not to be given any I j consideration or weight wh a t soeve r ." G.D. Searlo & Co. v. Chas. 1 ! Pfizer & Co., 231 F.2d 316, 318 (7th Cir. 1956). i 1 1 j Accordingly, because the affidavits offered by Edison are i 1
; not based on affiants' personal knowledge of specific facts, but i are conclusory in nature, and because competency to testify is
!. not af firmatively demonstrated on the face of the affidavits, l i those affidavits should be found unreliable and disregarded as j j supporting a " material fact". i B. Certain of Edison's " Material Facts" Should Be l Disregarded As Unreliable Because They'Are Based l on Portions of Affidavits That Are Peplete With Inadmissible Ilearsay,'They Express Opinions on Ultimate Facts and Conclusions of Law, and They i Do Not Contain Sworn Or Certified (Or Any) Copies j of the Documents Referred To Therein. i
- Because Edison's affiants apparently have no personal a
- knowledge or competency to testify to much of the material
- contained in their affidavits, those affidavits are based in -
1 j l 6 1
large measure on inadmissible hearsay and opinions respecting the ultimate facts and cenclusions of law. 10 CFR S 2.74 9 ( b) and Bule 56(e) provide that affidavits affered in connection with summary disposition "shall set forth such facts as would be admissible in ev id e nc e." Therefore, those portions of Edison's af fidavits which rely on hearsay or express opinions on ultimate facts and conclusions of law should be disregarded, and any of Fdison's "nater ial facts" which rely on that unreliable testimony should be disregarded. Possi v. Trans World Airlines, Inc., (CA 9th, 1974) 507 P.2 d 404; Elliot v. Massachusetts Mutual Life Ins. Co. (CA Sth, 1968) 388 F.2d 362 (holding that statements of opinion, even if admincible in evidence, may not be considered on a motion fo r summary judgment because (1) statements based on opinion cannot at the same time be based on personal knowledge; and (2) consideration of opinion testimony is purely a function for the trier of f act); Waldie v. Schlesinger (CA DC 1974) 509 F. 2 d 508; 6 Moore's $ 5 6.2 2 [1 ] . Moreover, under the standard of Pule 56(c), the tallure of Pdison's a f fiants to at t ach to their af fidavi ts sworn or l certified copies of all documents referred to in the affidavits prevents the Board's and Intervenors' consideration of the testimony as it relates to those documents. United Staten v. Dibble, (CA 9th, 1970) 429 F.2d 598; 6 Moore's 556.22[1], (Professor Moore sta ted, "It is most i m po r t an t that copies of material documents accompany the affidavit, and Fule 56(e) requires that sworn or certified copies be attached thereto or served therewi th.") It is especially important bere, where 7 L
certain of Edison's affiants claim to rely on " comprehensive reviews"- to support a " material fact," yet the reviews referred to have not been completely disclosed to Intervenors in discovery; nor are they attached to the affiants' affidavits. l (Quaka Deposition Tr. 49; Schulz Deposition Tr. 332, 351-52.) Accordingly, because numerous portions of Edison's af fidavits contain inadmissible hearsay, opinions on ultimate facts and conclusions of law, and do not contain copies (let alone sworn or certified copies) of the documents referred to therein, those portions of the af fidavits should be found unreliable and incapable of supporting the related " material facts". CONCLUSION l What follows is Intervenors' answer on the merits as to each subpart of the OA contention subject to Applicant's Motion For Summary Disposition. For each subpart a statement of Facts In l Dispute is set forth with record references and exhibits , l attached, as appropriate, together with argument supporting our j position that, for good cause shown, Applicant's Motion For Summary Disposition should be denied. DATED: February 18, 1985 Respectfully submitted, l l Robert Guild l Douglass W. Cancel, Jr. Timothy W. Wr ig ht , ITI 109 North
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1 Suite 1300 Robedt Gu 1 Chicago, IL 60602 One of the A torneys for (312) 641-5570 Intervenors Rorem, et al. l l 8 1
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2/1 f0084ETED USNRC UNITED STATES'OF AMERICA NUCLEAR PEGULATORY COMMISSION W FE9 21 P4:27 4 4 FICE 0 9 A;w ] BEFOPE THF ATOMIC SAFETY AND LICENSING APPEAL B TihG a Si8viQ BRANCH 4 In the Matter of: )
)
- COMMONWEALTH EDISON COMPANY ) Docket No. 50-456 i ) 50-457 (Draidwood Nuclear Power )
Station, Units 1 and 2) ) l l i i CERTIFICATE OF SERVICE i-
. I hereby certify that I have served copies of Intervenors' J
5 Answer Opposing Applicant's Motion For Summary Disposition on j cach party to this proceeding as listed on the attached Service l I List, by having said copics placed in envelopes, properly s ) addressed and postaged (first class), and deposited in t he U.S. mail on this 18th day of February, 1986; except that the Licensing Doard and UFC Staf f Counsel Mr. Treby were served via l Federal Express overnight delivery and Edison counsel Mr. Miller i l was served by messenger. i-4 s , l d l 4 i ? i 4 1
DPAIDWOOD SERVICI: f,TST lierbert Grossman, Psa. ftichael T. Miller, Ecq. Chairman and Administrative Judge Peter Thornton, Eco. Atomic Safety and Licensing Board Isham, Lincoln & Peale U.S. Nuclear Begulatory Comminnion Three First National Plaza Washington D.C. 20555 Chicaon, Illinoin 60602 Pichard P. Cole Docketing & Service Section Administrative Judge Office of the Secretary Atomic Safety and I,icensing Board U.S. Puclear Pegulatory U.S. Nuclear Regulatory Comminnion commicsion Washington D.C. 20555 Wanhington t' . C. 20555 A. Dixon Callihan Administrative Judge 102 Oak Lane Oak Fidge, Tennecceo 37830 Stuart Traby, Enq. NFC Staff Counce1 U.S. Nuclear Pegulatory Comminnion 7335 Old Georgetown Road Dethesda, Maryland 20014 Joseph Callo, Paq. Icham, Lincoln & Deale 1150 Connecticut Avenue N.W. Suite 1100 Wanhington D.C. 20036 Region III Office of Incpection & rn fo rcemen t U.S. Nuclear Pegulatory Commicnion 799 Roocevelt Poad Glen Ellyn, Illinoic 60137 Atomic Safety and fIcensing Doard Panel U.S. Nuclear Regulatory Commisnion Washington D.C. 20555 Atomic Safety and T,1 censing Appeal Doard U.S. Nuclear Regulatory Comminnion Washington D.C. 20555
m-i f O Subcontention 3(C)
- 3. Contrary to Criterion II, "Ouality Assurance Program," ,
of 10 c.P.R. Part 50, Appendix B, Commonwealth Edison Company has failed to establish a cuality assurance program which complies with the requirements of Appendix
- D and which is documented by written policies, proce-dures, and instructions and is carried out in accordance with those instructions. Edison has failed to assure that its OA program provides controls over activities affecting auality and that auch activities are accom-pliched under suitably controlled conditione and are appropriately verified for quality by inspection.
I C. The Applicant's electrical contractor (Comstock) ! utilized Level I Quality Control Inspectors for inspec-l tion and acceptance of electrical welds. This involved l 14 different Level I innpectora over four years. l (Inspection Peport 85-06, Exh. 1 1. ) Facts In Dispute l ! Edison and its contractorn' use of unoualified Level I Quality Control inspectorn for the vicual incpection and acceptance of cafety related weldn evidences a siqnificant failure to establish and implement an ef fective cuclity assurance procram. Neither the " Level I Poverification program" now being developed nor the "Ouality Control inspector Peverification Program" which ic incomplete will accure that the Level i OC innpoctora were ef feet ively quali fled and that the welds in quest ion meet regulatory requirementn. For many yearn at D r a id wood cite cuality ansurance proceduren of the electrical contractorn, and perhaps othern, authorized the une of unqualified Level I Quality control Inapoctorn in the improper performance of visual weld inspectione and acceptance. Such ute of nubjective judgment in the evalua-1
v Y K tion of the acceptability of safety-related welds clearly exceeded their level of qualification as established by the applicable ANSI standard N4 5.2.6-1978. Failure of Edison and its contractors to identify this obvious deficiency reflects a serious flaw in the Braidwood quality annurance program. Only a 100% reinspection of the improper Level I inspections will ensure the quality of the work which they alone have inspected. In the absence of such a 100% reinspection, Edison has asserted that, first, the Ouality Control Inspector Deverification Program (OCIRP) will verify the cualifications of the Level I OC inspectorn; and, more recently, that a special Level I Peverifi-cation Program (LRP) w il l , in place of the OCIpp, establish the acceptability of the welds in guention. The adequacy of the LRP i in its design, organization, methodology, implementation, and results is a matter in dispute in thin proceeding. Pesolution of ! this dispute cannot be delegated to the NRC Staf f, but must be nubject to Intervenors' scrutiny and opportunity to be heard. Louisiana Power and Light Co., (Waterford Steam Electric Station, Unit 3), ALAP-732, 17 NPC 1076, 1103 (1983). Although the LDP i procedures remain in draft form and the incpectionn'have yet to begin, nerious deficiencien are already apparent in Edison's l deceription of the program in its nummary disposition papers. Plawn in the compling plan, the unreliability of Comstock quality documenta and the unrecolved harannment and intimidation innues which infect both the original and retro innpcetions by Comstock , inspectorn, all raise grave doubtc about the effectivenesc of the 1 ! LRP to accomplish Edinon's stated purpone for it. Intervenorn 2
~ r a believe that nothing short of a 100% reinspection of this Comstock weld work will suf fice. To summarily dispose of these serious questions as Edison suggests would require the Board to simply close its eyes to these r,afety problems. Applicant presents the af fidavit testimony of three witnesses in support of its motion for summary disposition with respect to subpart 3(C) - the Level I OC issue: Martin P. Frankel, a statistician; Kenneth Kostal, a Sargent & Lundy engineer, and James W. Gieseker, an Edison construction engineer. Mr. Kostal's involvement in the LDP was limited solely to the preparation of his af fidavit supportir.g summary disposition. Ife had no prior involvement. Ile has had no involvement since. (Kostal Deposition Tr. 21.) Mr. Kostal will have administrative responsibility for the S&L review of LRP results. (Kostal Tr. 23.) Ife has never reviewed the LDP program procedures (Kontal Tr. 27). Nor are there any unique S&L LHP policies or l procedures. (Kostal Tr. 27.) Kontal is unfamiliar with Comstock and Ernst weld inspection document practices (Kostal Tr. 37); and he is unf amiliar with the number of wolds documented on a weld inspection report. (Id.) In nhort, Mr. Kostal han virtually no knowledge of the proposed Level I Peverification Program, except that obtained solely for the purpose of preparing his affidavit supporting summary disposition. Mr. Kostal's testimony providen little support for Edison's position. The second witness supporting nummary disposition in Dr. Martin Franke) - a statistician. In the time available to us, Intervonors were unable to take Dr. Frankel'n deponition. No 3
e e matter, however, since his degree of involvement in the LRP is also slight, and is only marginally greater than that of Mr. Kostal. Dr. Frankel's involvement consisted of primarily tele-phone conversations with Edison's Mr. Gieseker. (Gieseker Deposition, Tr. 150.) Mr. Gieseker provided Dr. Frankel with what he described as the population size, e.g., number of weld inspection reports, although not welds. (Gleneker Tr. 155.) In response to this number - 9000 - (Gieseker Dep. Tr. 150), Mr. Frankel provided the sample size - 475. Dr. Frankel had no other I role in designing the LPP. 11e neither rought nor was given the Comstock visual weld inspection procedures. (Gleseker Dep. Tr. 156). In fact, Mr. Glencker erroneously informed Dr. Frankel that the range of welds per inspection report was between 2-10 (Gieseker Dep. Tr. 159), although Mr. Gioneker has since learned that as many as 1,215 welds are reported as inspected on a single inspection report document. (Giencker Dep. Tr. 160.) Thus, anido from preparinq his affidavit in support of the motion for summary disposition, Mr. Frankel's contact with the LRP consisted l of several telephone conservations with Mr. Gieseker in which he l provided a sample size number for the inspection report sample celection. Dr. Frankol's involvement in the LPP is obviously limited and any interpretation of his testimonial affidavit an endorning the reliability and confidence levels associated with inferences f rom the LDP must be weighed in light of the thin foundation of personal knowledge upon which it la based. Edison'n third witness is Mr. Gieceker, the Edison Project construction Department engineer principally responsible for the 4
y o l LRP's implementation. Mr. Gieseker acknowledges at the outset that even after the preparation of his December 20, 1985 t affidavit, he was uninformed as to the actual character of the Level I OC inspectors' work. Mr. Gieseker corrects his testimony to acknowledge for the first time "that the overall practice employed by LKC for use of Level I and II inspectors was not in conformance with the ANSI s t a nda rd." (Gieseker Deposition Exhibit 3.) Apparently, for the first time in early January 1986, Mr. Gieseker actually interviewed Comstock OC inspectors in the company of an NPC inspector and learned of the actual i practicca in failing to verify the inspections performed by the i Level I inspectors. (Gieseker Dep. Tr. 10-25.) Mr. Gieseker concluded: Oh, well, originally when I wrote the answer to the question in the motion for summary disposi-tion, I was at the point where I didn' t feel as strongly that the Level I reinspection program was required. After the interviews, when I realized an inconsistency in the implementation of the program, I felt stronger that the program was needed to determine the adequacy of the Level I's welds. (Gleseker Dep. Tr. 24.) It remains unexplained why Edison failed l to establish on its own, absent an NPC inspector's initiative, what the actual Level i OC inspector practice was, or why such information was not nought no far back an 1978 when the practice apparently began. (Gieseker Affidavit Exhibit 1.) It is unexplained why a simple reading of the L.K. Comstock Wold Inspection Procedure 4.0.3, Devision P, in effect prior the NFC identificat ion of this issue, would not have led to the same conclusion as that reached by Mr. Gioneker only weeks ago. That 5
Le . i . procedure provides explicitly that the weld inspection is to be l l performed by "the Level I or II welding in spec to r." Section l 3.24. "A Level II inspector shall review the checklist for , completeness and signify concurrence by signing and dating on the
' Level II Inspector' section of the checklist." Sec tion 3.24.1.
- (Gieseker Deposition Exhibit No. 2, attached hereto as Exhibit A.) By design the LRP inexplicably defines the population for sampling not as welds themselves - which are the focus of the program's object which is verification of weld quality - but of inspcction reports, the Comstock Form 19's, or predecessor docu-ments, on which the OC weld inspector inspection results are documented. Without any logical support, Dr. Frankel, the stat-istician, appears to endorse the validity of inferences regarding ,
the population of welds drawn from a sample of weld inspection reports. (Frankel Affidavit, p. 10.) perhaps this conclusion f rests upon Mr. Gieseker's erroneous advice that the range of t welds reflected on an inspection report is 2-10 (Gieseker Dep. c Tr. 159), instead of the. actual range of 2-1,215 (Giesoker Dep. Tr. 160). The ef fect of such disparate weld inspection documen-tation practices on the LPp sampling plan is problematic. An example of a Form 19 reflecting an inordinately large quantity of wold inspections was produced by Edison in response to a discovery request by Intervenorn. In the depostion of a Comstock Level II inspector, Dan Holley, taken by Edison January 20, 1986, Mr. Holley described statements by the Comstock Quality Control Manager, Irv DeWald, in effect bragging that he had inspected over 1000 wolds in one day in the context of urging his inspec-6
o . l l tors to increase their production rates toward such example. Mr. l Ilo11ey testified that he confirmed Dewald's claims during the course of his weld inspection document review in the Comstock l auality assurance vault. Mr. Ilolley identified the drawing num-l bor involved and Edison produced several DeWald weld inspection checklists associated with that drawing. (Irolley Deposition Tr. 114-25, Exhibit B hereto.) Mr. DeWald's 1/30/81 Form 19 reficcts the performance of inspections on 233 welds. Whether these weld inspections were performed in one day or in ten is cimply unknown. DeWald inspection checklist for drawing 20E-1-3061IIL-P, 6-10, attached hereto as Exhibit C.) According to Comstock's former Level III weld inspector, Worley O. Puckett, since terminated for raicing safety and quality concerno, (See, claim i reflected in OC Inspector liarassment and Intimidation contention), the per formance of such a cuantity of welds in a single day is clearly unreasonable. (Puckett Deposition Tr. 299-303, Exhibit D hereto.) The DeWold Form 19 weld inspec t io'n l checklist appearc to reflect two other significant flows in the LHP: the use of a co-called " grid" identification nyctem, making it impossible to identify the actual weldn innpected; and the I apparent use of Level I weld inspectora by yet another nite contactor, Edicon's independent testor, Pittsburg Testing Laboratorien (PTL), who nhow a Level I inopec tor "D.L. Meredith" per forming the 2/4/01 nample over inopoetion of Mr. DeWald'n work. An Mr. Gleceker staten, the use of cuch grid referencen make reinnpection under the LDP program imponnible. (Gieseker Dep. I Tr. 7 9. ) In cuch cases, a grid deceript ion increction report in 7 l
o e simply excluded from the sample. (Gieseker Dep. Tr. 79.) For at least one of the Comstock Level I inspectors, all five of his inspection reports provide grid references only, thus eliminating l his weld inspection work completely from the LPP. (Gieseker Dep. Tr. 241.) The elimination of such welds and wold inspections f rom the LPP sample certainly skew the reinspection results, flow l likely is it that an inspector who deceribes his work imprecisely I through the grio description system also per forms inadaquate I l inspections and misses rejectabic welds? Ilow much more likely if the same innpector "innpects" 1000 welds in a single day? The I.RP will be further undermined by pervasive and cerious problems in L.K. Comatock ouality documentation reliability. Edicon identified thin subject an a 10 CPP 50.55(c) significant deficiency in a report January 31, 1984, and han in progrena a major corrective action program on thin subject. An of January 31, 1986, the review of 101,750 records have reflected the identification of 19,953 "unnattufactory" for a 20% defect rate. A program description and.statun report provided by Edison in responne to diccovery requests is attached hereto an Exhibit E. The LPP was developed for the npecific purpoco of recponding to Contention Item 3(C) in place of the existing Quality control l Innpector Peinnpection Program (OCIPP), which wan originally identified an the corrective action for the Level 1 OC incpector problem. The !.PP wan developed becaune OCIPP renultn are not i expected until early uummer. (Gleceker Affidavit, p. 4: Gionoker Dep. Tr. 126.) The Level ! Deverification Program (f.PP) reprenenta a 0
l l gravely flawed desperate ef fort to sweep programmatic problemo ! with serious hardware implications under the rug. The existence l l of haransment and schedule prennure allegations by Comstock inspectors, the existence of serious questions about Comstock l document reliability, the numerous methodological flawn in the LFP identified to date, the haste with which this significant program han been approached and the general absence of sufficient information about implementation and resulto, all considered, eliminate summary disposition of this innue an a rational remedy. { l l I ! 1 l 9 l
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p- # #_~ _ . I"^I"# 4'*' cAcE:7 l :. . . e 7." COMSTOCK O COMPANY. INC. ITEli 3C. EXilIBIT A
' 3.0 PROCEOURE - continued 3.21 Eate_ Cut Edgel l l '
Visually observed discontinuities over one (1) inch in' length on sheared or oxygen cut edges caused by entrapped slag, inclusions, ur gas pockets are unacceptable. 3.22 Verify that welder identification is stamped near the weld joint.
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3.22.1 The QC Inspottor shall signify acceptance of a weld connection by stamping his assigned symbol near that weld connection. Ref. Page 12 of 13.
't . 2 3 " REMARK 5" any remarks that may be needed to clarify inspection coverage or results may be added on the inspection checklist.
3.24 The Level I or 11 Welding Inspector who performed the inspection shall. complete the Weld Inspection Checklist, Form 19, and sign and dato over the "QC INSPECTOR
- section. Verify that the Wold Inspection Checklist and Welding Installation Record is completely Itiled out, and that the welder number is inserted en upper right blank of f'orm 19.
3.24.1 A level 11 In*,pector shall review the checklist f or comt.letenen and signif y concurrence by signing and dating on the " Level 11 Inspector" section of the checklist. 3.24.2 The cnmpleted Weld inspection Checklist Form 19 Shall be j attached to the Welding Installation Records, and Iiled in the LKC Q.C. Records area in accordance with LKC QC Hanual, Section 4.13.1. 3.24.3 the level 1 or 11 Inspector shall initiate on ICH or NCR per Sections 4.11.1 and 4.11.2 of the QC 'Hanual, f or any discrepancies found during inspection which do not conforfn to the welding code and engineering criteria. 3.24.3.1 the Lovel 1 or !! Inspector shall mark defects encountered during inspections at their locations using a black marker. The inspector will then attach a red ribbon un the hanger. l 3.24.3.2 1he fallowing terms and definitions shall be documented on the form 19, Form iga, Form 220 and mJrked up a'. closu as possible to the connections using, the following terminology: , l i us
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ITEM 3C. EXilIBIT B DEPOSITION OF DASSY R. Il0LLEY 1 1/28/86 g 30, o (,) 2 Q Did ho indicato any understanding or belief an to 3 the cause of your boing clow, as you anid? 4 A No. Wall, I tried to explain to him that I try to 5 be thorough. 6 Q All right. 7 A And, you know, ho took that ac reing good roanon. O Q okay. Itava you over heard of !!r. DeWald having l 9 parformod quality control inapoctiono himcolf at Draidwood? l 10 MS. KEZELIS: I think that'n boyond the scopo of any l 11 quantions I anked Mr. !! alloy. And I'm going to objuct. ! 12 tiR . GUILD: !!aybo and maybo not. But I would liko x 13 tho quantion anoworod. 14 WIT!!ESS: From my knowledge, !!r. DeWald wan an l 1 15 inopoctor a year or two beforo I got hero and then ho had lef t 16 the oito and then about a yonr after 1 got back he wan brought 17 back no a QC managor. la BY ltR. GUILD: 10 0 Okay. liad you over heard of Mr. DoWald performing a 20 largo number of wold inopoetionn in a ninglo day, or over n 21 very chort porlod of timo? 22 !!S . KC7,tLIS: Objection. That'n boyond the scopo I P t)
115 1 of what I asked Mr. !!olloy. g-() 2 MR. GUILD: I would liko you to anowor the quection 3 rogardless. 4 WITiiESS : Yeah, I guess it's cort of general 5 knowledgo. A lot of peoplo take it as a joko. A lot of the 6 wold inapoctora now, anyway, tako it no a joko that a thounand 7 wolds woru inopocted in a day or nomething. O BY MR. GUILD: l 9 0 And it was common knowledge among tho inspectora, l 10 you would say? 11 A Yosh. l 12 Q or a boliot, in any event? l 13 A A bolief. l l 14 MS. KlZULIS: I'm going to object to thin continuing l 15 lino of quoutioning, Mr. Guild. 16 BY 113. GUILD: 17 Q And had you over hoard Mr. DoWald speak about the 10 cubject? t !!ad ha over boon anked whethor that was truo or not? l 19 A llo . 20 0 I When you any it won treated ao a joko, how do you 21 know that, Mr. !!olloy? 22 A Wall, it'n cort of, I could almont nay, imponsiblo 1
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116 ( 1 , to correctly inspect.a thousand welda ih l day and not find i 1
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l F4 2 nothing wrong with any of them. ' And that was a belief that '
, sr 3 overybody had, that he had inspected,a tt usand welds in a day t
4 and didn't rejoct any. - l 5 . Q You said it was common knowledge. Is it your belief 6 that all of the quality control inspectors at comstock had the , 7 skro[undoratandingor'beliefabout.Mr.,DeWald'andthethousand 8 weldu? < ! 9 A I'wouldn'tnayalloftho'k,.butIwouldsaythe 10 major portion of them. ' '- i 11 , Q And -- 12 The wolding inspectorn, enyway. _A 13 Q And -- , 14 MS. !<CZELISt I'm going to object. You are also l 15 asking tho witn66s to engage in apoculgti'on about what other '
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16 incroctoru' beliefs are. 17 *BY ttR. GUILD: e , i la Q canyourecallhowyoulonrnIdofthisinformation?' l 19 A
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Rennarching in the vaul't,,othe;QC vault. We have to 20 4 reacarch to make ouro cortain hangers have been inspected t l 21 and no wo have accono to the inopoetion=rocords. 22 And-he has anv. oral inapection records in the. vault i . l ., w 6
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117 l 1 and one or more of them have more than a thousand welds 2 inspected in a single day. 3 Q How did you understand'that to be the case? 4 A It's documented. 5 Q Did you see the document?
- 6 A Yes, I did.
7 Q Okay. Do you recall --'I'm going to thumb through 8 Inspection Report 85-21, 22, November 4, '85. 9 Do you recall reviewing this report on the~ subject ., 10 of Mr. DeWald's performance of a thousand welds in a day -- 11 A I'm corry -- 12 Q -- or something to that offect? hh) 13 A -- I don't remember if it's, you know, in there or 14 not. l 15 l Q It's in hero. I wan just asking whethor or not you 16 recall reading it in here? l 17 A Well, if it was in thero I did read it. 18 MR. GUILD: I want to take a moment, counsel, I want 19 to find this if I can. 20 MS. KEZELIS: I want to make clear my objection to 21 this continuing lino of questioning continues f 22 ga, GUILo; yog, l l l i
O.
-118
'l BY MR. GUILD:
2- Q Okay. I'm looking at Page_14 of that inspection. 3 report, Mr. Holley, and it's Concern Number 4 on that page. 4 Looking at Page 14 of the report, Mr. Holley,;and 5 the concern stated there -- and I will read it for the record 6 -- is as follows: QC inspectors allege that 93 hanger 7 inspections on one check list containing eleven hundred to 8 twelve hundred welds were signed off in one day by.an l 9 identified inspector. The allegers considered this to be too i 10 many inspections for a single inspector to make in one day 11 without the quality of the inspection suffering. 12 Delow appears what's entitled the "NRC Review." The 13 document itself, you know, identifies this as'the quality l 14 control nanager of Constock presently, or in depouition the 15 author of this report, Mr. Mendez or Mr. Neisler, identified 16 this individual as Mr. DeWald. 17 The NRC Review part reads: The identified person 18 was questioned regarding this issue, and he responded that to 19 his knowledge this did not occur. The LKC inspectors could 20 not provide an inspection report or date of the alleged 21 occurrence. Consequently, the inspection check lists where j 22 93 hangers were accepted by the'QC inspector who was the 1 L B) L_ 'l
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- 119 1 subject of the-allegation _was not located during.the QC h 2 trecords reviews by the NRC inspector.
3 First, did the NRC interview you,.Mr. Holley, 14 concerning this subject? 5 MS. KEZELIS: Well, let me interrupt here a minute. 6 Mr.-Guild, I think it makes more sense for you to givo th'at 7 page to Mr. Holley -- 8 MR. GUILD: I would be happy to. 9 MS. KEZELIS: -- and have him review both paragraphs 10 under NRC Review. 11 MR. GUILD: I would be-happy to. 12 MS. KEZELIS: Thank you. r 13 BY MR. GUILD: 14 Q I believe your answer was no, they didn't interview 15 you on the subject? 16 A No, I don't remember talking to them about it. 17 (Witness reviewing document.) 18 BY MR. GUILD: 19 Q Mr. Holley, have you had a chance to review the 20 document on that concern? 1 i 21 A Yes. l 22 Q My question is, you could identify the inspection M , l
120 1 reports that you have described that reflect 11r. DeWald's fh 2 inspections of over a thousand welds in a day, can't you? 3- A The one or more that I.saw, yes. 4 Q All right. Can you tell me how you came to identify 5 those documents, those inspection reports? 6 A Well, like I said, we had to do research when we 7 were inspecting the hanger to make sure all the welds are 8 inspected. 9 (Pause.] 10 Q I had asked you how you came to identify the weld 11 records that reflected Mr. DeWald's performance of over a 12 thousand welds in a day, and you were beginning to tell me. 13 A We had to -- when we were going to buy off a hanger 14 which includes a configuration, we also had to verify that all 15 the welds had been accepted, so we go to the QC vault and we 16 do our research, and if it hasn't been accepted we will go out 17 and inspect the wel'ds. The welds are inspected and with that 18 paper document we can use it.as such during research of one of 19 our hangers or something. 20 Okay. Q Now, I would like to try to identify those 21 documents, or that document, in enough detail so that I can 22 seek to have it produced by Comstock and Edison. n
J - 121
+t l1 Can you describe:it in nore~ detail, when it was 2 written, what kind of component it covered, what part of the 3 plant the conponent was in, that cort of information?
4 A Probably in '01, it would be,.I guess,. considered a 5 Form 19, that's a' weld inspection report.- I believe the 15 drawing number for a certain one that I've looked at is 7 1-3061. , 8 And several hangers could be -- I don't remember any 9 of the hanger numbers. But I'm still familiar -- if they have 10 not changed the QC vault system since I left, you could 11 probably look in that particular-folder'and find it in there. 12 Q In that folder is more than one hanger? l g 13 A Oh, there's --if I recall, yes. All'the hangers 14 . pertaining to that drawing would be a certain group of 15 folders.
- i 16 Q Okay. What's that -- that drawing-would-cover what, i 17 1-3061 --
4 18 A Yeah, 19 Q What does it cover? i 20 A Cable pan supports. I 21 Q Okay. What's the scope of work that's contained on 22~ that particular drawing? l
'l b
g- 122-1 A It's just all the supports in that area. 2 Q It's an area in the plant? 3 A Yeah.- Each area of the plant is -- there's drawings 4 for individual areas in the plant. 5 Q And how many -- can you estimate how many hanger 6 cable pan supports are included in either that packet or a 7 typical packet? 8 A Right now it's one per inspection report. It used 9 to be as many as we did per inspection report. 10 Q Okay. How about at the time.the '81 -- 11 MS. KEZELIS: Objection. I don't think this witness 12 is going to be competent to even testify as to what happened l 13 in 1981, 14 BY MR. GUILD: 15 Q Well, you've reviewed this packet? 16 A I've locked at it. And, like she said, I wasn't 17 quite aware of all the procedures and how they handled that 18 back in '81. 19 Q Okay. Do you know of anyone else who has a copy of 20 the weld records that are-referred to? 21 A We are not supposed to keep copics of~ inspection i 22 reports. { s
123 1 Q Okay. Do you know if anybody made a copy of-(-).
$v 2. Mr. DeWald's. reports?
3 A They are in the: vault. 4 -Q So, it's in the vault? 5 A It should be. 6 Q And there was more than one hanger that reflected 7 over a thousand welds. inspected in a day? 8 A Each hanger has a variance of welds from two:to 9 40 on each hanger. But the inspection report covered over 10 a thousand welds. So that would entail several hangers. 11 Q Now how do you know, if you do, that the inspections 12 weren't performed uier a longer period.of time and simply 13 dated on one day? 14 A There's only one date on the reports.
, 15 Q Okay. Did you tell anybody about the documents that 16 you had -- i i
17 A Several people. Like I said, there's several. 18 hangers so it's several people that reviewed them. 19 Q So other people have reviewed the same documents? -! 20 A Oh, yes. 21 Q And doing the same work that you were doing? 22 A' Yes. 4
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124! 1 Q Doing configuration inspections.
$h - 2 A Yeah.. Those reports, that's onenthing I do.have to o 3 give Comstock credit for. !They~ review th'e reports quite 4 thoroughly.
5 Q okay. Under the circumstances you are talking 6 about, when you are doing a configuration inspection you.go back and look at the weld records? 7 8 A Yeah, correct. 1 4 9 Q Did you identify any rejectable welds on the hangers 10 that Mr. DeWald had previously inspected?: 11 A No. 12 Q Are you aware of anyone else identifying'the I " g 13 defective welds? 14 A Not to my knowledge. No. 15 Q Did you raise any question about the validity of 16 Mr. DeWald's inspection results when you were performing your 17 ccnfiguration inspection? 18 A No, I never did. 19 Q Are you aware of-anyone else raising anyl questions' 20 about the-validity of Mr. DeWald's inspection results?- 21' A Other than:someone saying: Well, I' told,so.and so. 22 And I told so and so. It was just all. hearsay. j 4 [ ( ** l l 1
)
. .. 125-1 12 Okay. When you say I told so?an'd so, did_you h 2~ understand that they told somebody in nanagement1about it or 3 somebody in a responsible position?
4 A; Yeah, just talk. I don't think'anybody.ever took 5 any action on'it that I'm aware of. 6 Q Okay. -Ms. Kozelis asked you some' questions about 7 whether you had considered going to Quality first_with'any of a your concerns. 9 In that regard, were you aware of any others going. 10 to Quality first, any other-inspectors who said they'had gone 11 to Quality first? 12 MS. KEZELIS: I think I may have asked that. He may cg, 13 have answered it already. 51 14 MR. GUILD: I don't recall. We can try again. J[ ' ' 15 apologize if it has been asked. 16 WITNESS: I don't believe 80. l 17 BY-MR. GUILD: 18 Q All right. Was there any talk about-the 19 effectiveness of -- the effectiveness of going to-Quality-20 first? 21 MS. KEZELIS: Objection. Asked and answered. 22 BY MR. GUILD: i 1 ms n l-I
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Order No: CH.3175 * ^
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. Client: Commonwealth Edison Report No: 90 7 l/&/
Project: Braidwood Station REP 0RT
~
Report Date: c. . /,, Ji'~/ ~ of Visual Inspection of Structural Weldinfi Contractor: ZP"Oofm foc/ Page b ofd Drawing Weld Weld Weld Size Weld
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Client: Comonwealth Edison ReportNo:fd8//4/ Project: Braidwood Station REP 0RT
~
Report Date: c2- / P/ l of Visual Inspection of Structural Welding Contractor: 4NCeundac4 Page 3 of 3 prawing Weld Weld Weld Size Weld No. No. Tyoe Actual ISpeciitec Length Acc Rej Rei. Defects Notee c m L
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299
.WORLEY.O. PUCKETT DEPOSITION, 2/6/86 ITEM 3C, EXHIBITLD 1 rejectable?
E g 2 A I have no idea. 3 Q Now back to page 15, Allegation 3, where had you 4- overheard that Mr. DeWald had inspected 1000 welds in a day?
'S A From some of the other QC inspectors.
6 Q All right. 7 A They said that Mr. DeWald had told them -- this is 8 when they again mentioned the word " pushing for numbers." "I 9 know we can get this done, because I have inspected 1000 welds 10 in one day." 11 Q All right. You understood Mr. DeWald had said that?
. 12 A It's my understanding that somewhere on file at the 13 Braidwood project, there is records verifying that he, in 14 fact, did.
15 MR. GUILD: The record should reflect that in the 16 deposition of an inspector, Mr. Danny Holley, that Mr. Holley 17 so stated that he had reviewed such records, and we have 18 sought those records and asked that they be produced. 19 BY MR. GUILD: 20 Q Your understanding, to be clear, was that from'other 21 inspectors, that Mr. DeWald, in the context of pushing for 22 numbers, to use your phrase, had said to inspectors, "I know i
300 1 it can be done. I've done 1000'in one day myself?" h 2 A Yes. That was my understanding. I never actually 3 heard him say this. 4 Q All right. 5 A As I mentioned to NRC, it was hearsay when I heard 6 it. When I was passing it on to him, it was hearsay. 7 Q All right. And did you understand this from more 8 than one inspector? 9 A Yes. It was a big joke in the QC Department, 10 because they -- as an inspector, and a lot of the inspectors 11 were very good inspectors. I have no complaints with the 12 inspectors at all. They were inspecting to the procedures gig 13 that were provided to them. 7 Most of them were professionals. 14 But they were savvy enough that they knew that this could not 15 be done, inspect 1000 welds in one day. It just could not be 16 done. 17 Q All right.' Could not be done -- 18 A That is, correctly, you know. There ain't no way 19 you can make out the paper. It would take you two weeks to l i 20 make out the paperwork on the welds that you were inspecting. 21 Q What is your -- I'd like to get your opinion, if I 22 l can, Mr. Puckett, on what a typical number of weld inspections I$) 1 1
. . .301 1 per day might comprise.
h 2 Let's say one was inspecting cable tray hangers. 3 How many welds would a typical cable tray hanger contain? 4 A Well, it would depend. A cable tray, they run from l 5 Point A to Point B. There could be -- 6 Q How about a single hanger? 7 A A single hanger, mor's than likely there would be 8 anywhere from two to four welds. 9 Q All right. And how many hangers would a weld l 10 inspector typically inspect during a. day? 11 A lie would probably go -- a mediocre ~ inspector would
, 12 get six welds a day. A real hot-running inspector that really -- 13 like to work and kept on the ball, he might get as many as a i
I j 14 dozen. 15 Q Twelve welds or twelve hangers? i 16 A Twelve welds a day. l 17 Q All right.- 18 A Well, pardon me. l Twelve hangers. Twelve 19 inspections. Usually when they inspect, they inspect a l l 20 component, and they may get twelve components in a day. 21 Q All right. So a good inspector, one that was able 22 to make production, optimal production, twelve hangers with
-s,
- Y l
l { f
302 1 -four welds apiece, 40 or 50 wolds per day? M i .v' 2 A Oh, yes. 3 Q And inspector could do that and do, in your opinion, 4 a professional job? 5 A An adequate job. 6 Q All right. Could an inspector do an adequate job, 7 in your opinion, and do 500 welds a day? j 8 A No. No way. 9 Q Could an inspector do an adequate job and do 100 10 welds in a day? 11 A There's a possibility, if they were in the shop, and
. 12 he didn't have to go find these welds and climb up to them and 13 locate them, identify them and do the inspection that was 14 required to make out the paperwork. But an inspector could 15 not do those welds on the different componento.
16 Q Okay. In the field. 17 A Right, right. ; 18 Q And do an adequate job, in your opinion, l 19 A In my opinion, he could not. I 20 Q Did you explain to the NRC your source of this 21 information, that Mr. DeWald had done more than 1000 welds in 22 a day? l l l
. . 303 1 A No, I did not.
d!h 2 Q Did they ask you? 3 A No, they did not. 4 Q Do you know whether or not Mr. Schapker or anyone 5 else with NRC asked any other QC inspectors, including perhaps 6 those who had told you of. Mr. DeWald's prowess, whether they 7 knew -- 8 A I have no idea. 9 Q -- about Mr. DeWald's weld inspections? 10 A [ Nodding negatively.] 11 Q Page 16, Allegation L, does that accurately state
. 12 your concern?
(s 13 A Let's see. t . 14 (Witness reviewing document.) 15 Yes. 16 Q All right. Mr. Schapker states in the conclusion, ! 17 " Partially correct, but does not adversely affect welders' 18 identification records." 19 Do you agree with Mr. Schapker's conclusion? l 20 A What he's saying could be so. The thing about it 21 is, I only checked a half a dozen different records, and I 22 found discrepancies in all of them. That is, I found welder l
ITEM:3C, EX11IBIT E ,, .. BRAIDWOOD " TOP TWENTY *2 ASID "0N-COING'* CORRECTIVE ACTION PROCRAM L.K. COMSTOCK DOCUMENT REVIEW' The L.K. Comstock Document Review Program establishos prescribed-guidelinos for the review of L. K. Cnmotock quality control inspection records. The program encompasses a review of all L.K. Comstock quality control inspection records to ensuro that each inspection record is identifiable, completo and comprohoasivo and that all identified documentation deficiencies are reconciled. Tho history of the program developed as follows: As early as March, 1982. Commonwealth Edison Company (CECO) Quality Assurance audits and the Tochnical Support Group Evaluation of September 1982, identified deficienclos indicating the nood to improve the L.K. Comstock documentation / filing system. As a result of identified deficiencies, Commonwoalth Edison Company felt that improvements could bo mado in the areas of:
- 1. Timeliness of records retrievability.
- 2. Dottor accountability of the production records which support the status of installation.
~
- 3. Reconciliation of outdated f orms.
In October, 1982, it was detonmined that progross was poor in the document review. In November of 1982, a now L. K. Comstock Quality control Manager was hired and charged with improving the organization and retrievability of quality documentation. Itowever, poor progress in the document review continued. In March and April 1983, CECO project Construction Department (PCD) hold mootings with L.K. Comstock Corporate personnoi, including tho 0396H/Novembor. 15, 1985
- r. ,
- 'Corporato Quality Aacuranco Manager, to discuss the poor progress being made on the document review. As a result, L.K.'Comstock committed-to provide four inspectors to completo the document review and provide a plan for completion. A plan to comploto the review was submitted to CECO for concurrence on March 9,1983. The plan's scopo and depth was to reconcile audit deficiencies of document retrievability, as well as assuring record completeness and correctness.
In Juno, 1983, CECO PCD and Quality Accuranco met with L.K. Comstock to discuss the status of the document review. It was determined that - L.K. Comstock was not proceeding as scheduled to meet'their stated September, 1983, completion date. As a result of the Juno meeting, CgCo again obtained replacement of the L.K. Comstock Q.C. Manager to more adequately organize and comploto the document review under a new completion dato of February 1,1984. Corrective measureu taken at this timo to prevent incomplete or unacceptable documents from being filed included the use of a computerized document tracking system to document the status of installation and inspections and ausure record rotrelvability. In addition, L.K. Comstock Procedure 4.13.1 " Quality Control Documentation Roquirements of Quality Related Records," was, implementod during this i time frame to establish tho critoria for records retrievability and review. l On January 31~, 1984, Ceco notified the Nuclear Regulatory Commission Region III offico of the history and utatus of the L.K. Comstock Document 1 3 0396lI/ November 15, 1985 l ______.______________________.________________________.__.___.__________________J
Review Program under 10 CFR 50.55(o) and designated this item on 50.55(o) Report 84-01. L. K. Comstock was considered 100% complete with its review of all documents on filo by March 1984 and by January 1985 reconciliation of identified defielencies was nearing completion. !!o deficiencies had boon identified which required extensivo rework and only limited field work had been required. At that timo, PCD and BCAP concerns aroso regarding th9 thoroughness of the roconcilation effort and the complotonous of tho initial document review. As a result, Ceco PCD placed the Document Review Program on administrativo hold. In order to lift the administrativo hold, L.K. Comstock was directed to reviso its existing document review program in its entiroty. On March 29, 1985, L.K. Comstock, with approval of PCD, Sargent and Lundy and Sito Quality Assurance, issued Proceduto 4.13.1.1 " Turnover Document Rovicw" to govern its revised Document Review Program. Under this Proceduro, L.K. Comstock is performing a 100% review of all Quality Control inspection records. This review includes all past and futuro records generated. Implementation of Proceduro 4.13.1.1 in connection with the continuing implementation of Proceduro 4.13.1 resulted in CECO lifting its administrativo hold on April 17, 1985.
?rocedure 4.13.1.1 contains (1) tho training and testing requirements for L.K. Comstock document roview personnel to conduct initial document review; (2) tho methodology uued to rosolved inspection records determined to be unsatisfactory; and (3) specific checklists to 0396H/flovember 15, 1985
.___ - - - __ ~
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. . s review each type of Quality Control record generated. The chocklists contain the critoria used to determino the natlutactory or unsatisfactory condition of the particular type of inspo: tion record being reviewod.
Particular document review personnel are trained under one or more of the specific checklistu In order to provido greater exportico in the review of documents covered by that checklist. As document review personnel are appropriately trained and hosted under Procoduro 4.13.1.1, they are assigned to the L.K. Comstock Records Vault to begin their review of the records for which they have boon qualified. Records are filed in the Vault alphanumerically by design drawing and they are reviewed in tho came order as they are filed. After each record has been reviewod it is stampod por L.K. Comstock proceduro 4.13.1.1 as evidence of having boon reviewed. Satisfactory records are replaced in the filo, unsatisfactory recordu are logged on the document review log required by the proceduro and segregated in a filo awaiting corrective action as appropelato. All correctivo action under the program is performed by a Lovel II Quality Control Inspector cortified per L.K. Comstock proceduro 4.1.3, " Qualification Classification and Training of QC Personnol", in the disciplino appropriate to the record being reviewed. Onco unsatisfactory records are resolved by a Levol II inspector a roview of the resolution is porformed by an indopondent Lovel II inspector prior to the record boing replaced in tho filo. L.K. Comstock hired a Document Control Supervisor in March 1985 to oversoo the program. The supervisor currently has 9 document reviewors 0396ti/!Jovember 15, 1985
.i working in tho L.K. Comstock Vault reviewing records in accordance with l
Proceduro 4.13.1.1 (soo attached organization chart). f Ceco Site Quality Assuranco conducted Audit 20-85-522 and follow-up Surveillance No. 4735 of the L.K. Comstock Document Review Program in April 1985 and August 1985, respectively. As a result of minor concerns raised by Quality Assuranco concerning consistent implementation of the Document Review Program, L.K. Comstock has revised certain reference lists used in its program to roflect current practicos and procedures and, whero nocessary, reviewed again cortnin records. In addition..on August 5, 1985, L.K. Comstock Proceduro 4.13.1.1 was also revised to address concerns expressed in Audit 20-85-522 and follow-up surveillanco No. 4735. The review of records associated with Unit I and common areas is i scheduled for completion in December 1985 and the review of records i associated with Unit 2 is expected to be complete in March 1986. As of October 30, 1985, the status of the program is as follows: TOTAL RECORDS WITilIN T!!E SCOPE OF THIS PROGRAM 114,106 ' TOTAL RECORDS REVIEWED TO DATE 83,960 (73%) TOTAL RECORDS REMAINING TO REVIEW 30,146 (27%) TOTAL RECORDS FOUND SATISFACTORY TO DATE 67,097 (80%) TOTAL RECORDS FOUND UNSATISFACTORY TO DATE 16,863 (20%) Of the 16863 records deemed unsatisfactory, 1821 have boon reconciled by Lwvol II Inspectors. Of the 1821 reconciled, 145 required field ' inspection, 7676 offico correction. The majority of discre,6vicles noted 0396H/ November 15, 1985
7 s 'i i _ (, _ to dato have been primarily of an adniinist rativo and clerical naturo requiring minimal reinspecticn of tho hardware in t.he plant. Oncu the L.K. Com:;tock Cocument Roview Program to concluded, assuranco will exist that all L.K. Comatock inspoetion records are identifiable, congilet e, comprehencivo and roteluvablo. l l l 1 0 t' kit / fJovombeir l', , 19ets -
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- 7 REFERENCES ,
- I j . Licensing file on 50.55(e) report 84-01.
l ,
- 2. CECO Audit QA-20-82-35.
- 3. Ceco Audit QA-20-82-21. ,
i 4. . CECO Audit-QA-20-82-31.
- 5. L.K. Comstock Procedure 4.13.1.1, Rev. A Rev. B.
- 6. L.K. Comstock Procedure 4.13.1, Rev. D.
- 7. L.K. Comstock proceduro 4.1.3, Rev.'D.
- 8. Letter dated 2/6/85 from D.L. Shamblin to F. Rolan.
- 9. CSCo Audit QA-20-85-522.
- 10. CECO Surveillance Report 4688.
- 11. CECO Survoillance Report 4735, Rev. 1.
. 12. L.K. Comstock responce to Ceco Audit Q4 20-85-522.
- 13. :L.K. Comstock responso to Ceco Surveillance 4735 Rev. 1.
j t r
- l 1
1 l l . f 0396H/ November 15, 1985
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.c*h \ >-.nn UPDATED RESPONSE - THIRD SET ,,
TO SPECIFIC INTERROCATORY 7 0F INTERVENORSL SECOND SET DRAIDWOOD " TOP = TWENTY" AND "0N-COING" CORRECTIVE ACTION PROGRAM , L.K. COMSTOCK DOCUMENT REVIEW t /
' (: r The following updated infnemation prodidos th'o st tus of the program as of January 31, 1986':
i
<. %r TOTAL RECORDS WITHIN THE SCOPS OF THIS PROGRAMi- '
107,057
- TOTAL RECORDS REVIEWED TO DATE 101,758 (95%)
' TOTAL RECORDS REMAINING TO REVIEW ,
5,299 ( 5%) TOTAL RECORDS FOUND SATISFACTORY TO DATE 81,805 (80%) TOTAL RSCORDS FOUND UNSATISFACTORY TO DATE .19,953 (20%) Of the 19,953 rocords deemed unsatisfactory, 18,255 have been'esconciled by Lovel II Inspectors. Of the 18,255 reconciled, 173 required field , inupection, 10,062 office correction. Again, the majority bf discreponelos noted to date have boon primarily of an adminictentive or diarical nature coquiring minimal hardware reinspection. / I "
,f ? (
*The original larger count of 115,106 records within the program scope identiflod in the original responco has been revised downward because it included certain CEA travelor packages and rowork packages which required no review and old Form.7, packages which have been replaced with new Form 7's under Commonwoalth Edison NCR's 708 andg 709.
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~123-0702H/ February 7,1986 ,*
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.Subcontention 5
.5. Contrary. to' Criterion III, '" Design Control," of- 10 C.F.R. Part 50,, Appendix'B, Commonwealth Edison Company' has failed to' establish measures to . assure .that. appli- 4 cable regulatory _ requirements 'and . design basesD are cor-rectly. translated-into specifications, drawings, proce -
dures, and instructions including. provisions'to assure that appropriate guality' standards are:specified-in design documents and that deviations from such'~ standards are controlled. Applicant has also . failed to require: , that measures are established for the . ident'ification ?and control of design interfaces land for the coordination ^ among participating design _ organizations,- that the mea-sures include the establishment ~of procedures among participating design organizations for the review, . approval, release,-distribution, and revision of docu-ments involving design interfaces; and that the design control measures provide for~ verifying or checking the. - adequacy of design, such as- by. the _ performance' of design-reviews, by the use of alternate or simplified calcula-tional methods, or by the performance of _ a suitable testing program. Facts In Dispute Edison, _its architect / engineer and its contractors' evidence T significant failure to establish design control measures to assure that applicable regulatory requirements and design-bases are correctly translated into specifica tions, . drawings, procedures and instructions where they have failed - to annotate anincorporated design changes on controlled design documents;. have _ written design change documents against superseded ' drawings; have failed to require a nuclear ' coatings repair procedure: which . is-: qualified 'for Design Basis Accident Conditions; have omitted'
' code-required slenderner 3 ratio limits-from duct support specifications; have employed a phi ' factor -design methodology based upon: incomplete, inadeguate 'and-non-retrievable engineering l
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._._2______
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v 5 calculations; and have improperly invalidated BCAP observations regarding lack of quality control field verification of " redline" piping drawings. Edison has understandably sought to eliminate completely from consideration in this proceeding all claims in subparts 5, including 5(A), (B) and (C), which implicate Edison, its architect / engineer Sargent & Lundy, and other contractors, in violations of 10 CPR Part 50, Appendix B, Criterion III, " Design Control." Violations which Edison characterizes as " trivial" " isolated" or
" unrelated to design" in reality evidence a troubling pattern of sloppiness, lack of attention to detail, and irresponsibility on the part of those charged with establishing and implementing design control measures necessary to assure that applicable regulatory requirements and design bases are translated correctly into specifications.
In addition, two other instances of .loncompliance evidence design control failures: contention subparts 12(F) involving Fargent & Lundy improper invalidation of BC AP observations; and 13(B) involving improper use of a phi factor design methodology based upon incomplete, inadeguate and non-retrievable engineering calculations. These deficiencies not only evidence additional violations of Criterion III but reflect, further, the significant implications of the design control violations cited in contention < subpar ts 5( A), (B) and (C). The merits of subpar ts 12(F) and 13(B) are addressed below under their respective portions of this Answer. We dispute Edison's claims that subpart 5 should be 2
.d a eliminated for.so-called " generic" reasons. We turn to the merits of 5( A), 5 (B) and 5(C) .
We 3
i ~ Subcontention 5(A)
- 5. Contrary to Criterion III, " Design Control," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to establish measures to assure that appli-cable regulatory requirements and design bases are cor-rectly translated into specifications, drawings, proce-dures, and instructions including provisions to assure that appropriate cuality standards are specified in design documents and that deviations from such standards are controlled. Applicant has also failed to require that measures are established for the identification and control of design interfaces and for the coordination among participating design organizations, that the mea-sures include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of docu-ments involving design interfaces; and that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calcula-tional methods, or by the performance of a suitable testing program.
A. The NRC CAT inspection concluded that in the area of the most significant finding was the failure to annotate unincorporated design changes on controlled design docu-ments. The most significant finding in the area of design change control was design change documents writ-ten against superseded revisions of the approved design drawings. In at least one instance, this deficiency resulted in a pipe support being installed and inspected to other than the latest approved design. (CAT Inspec-tion Peport 84-44/40, Exh. 10.) Pacts In Dispute
- 1. Sargent & Lundy's procedures for re-enalysis of piping subsystems and field engineering changes failed to ensure that field engineering change notices (ECN's) were not issued against superseded revisions of support drawings which we re under re-analysis.
j
- 2. L.K. Comstock and Edison Project Construction Department failed to ensure that Engineering Change Notices (ECN's) and 1
Field Change Peauests were annotated on the appropriate design drawings. The NRC Construction Assessment Team (CAT) identified the two contention subpart 5(A) deficiencies as "significant find ing s" reflecting design control deficiencies. Inspection Peport 84-44/40. The first event reflects Sargent & Lundy's failure to provide for and ef f ectively implement procedures to assure that engineering field changes were not made to super-seded support drawings under re-analysis. Ed~. son offers the affidavit of Sargent & Lundy engineer Ken Kostal in support of its motion for summary disposition in this matter. In deposition testimony, Mr. Kostal acknow1 rages that he had no involvement in this matter until his preparation of the summary disposition affidavit. (Kostal Deposition Tr. 4 4.) Mr. Kostal relies on the knowledge of others who were involved in the review of this matter. (Kostal Tr. 50.) Mr. Kostal himself was unable to identify the person responsible for the discrepancies, the review conducted, if any, to determine root cause of the discrepancies, (Kostal Tr. 50), or the specific language of the formal procedure under which the deficiencies occurred (Kostal Tr. 54). Mr. Kostal is simply incompetent to speak to the subject due to lack of personal knowledge. Applicant has further failed to submit material documents, particularly the previous revision of the subject procedure which was revised assertedly to correct the deficiency. Applicarat has failed to make out a case for summary disposition on this item. 10 CFB S2.749. The second portion of subcontention 5(A) relates to 2
~
s / r._.~,.y
. additional. CAT findings of significant deficiencies in design
; change control which' involved instances ofLfailureJto annotate appropriate design drawings for Engineering- Change: Notices (ECN's) - and . Field Change : Requests (FCR's). In support:of its summary disposition motion with respect to this item, Edison offers.the affidavit testimony of Michael A. Gorski, a construction' field engineer for Edison. . Notable among M r. -
Gorski's duties is that of " assisting the licensing organization: on issues relating to that process." (Gorski Affidavit, p. 3 . ) -- Notably absent from his affidavit, however, is any affirmative reflection of his competence 1to testify based upon' personal knowledge to the matters which are stated therein. Due to the. constraints of' time and resources, Intervenors did not depose Mr. Gorski. Nonetheless, the absence from his af fidavit of the af firmative showing of competence eliminates Mr. Gorski's support for Applicant's motion for summary disposition. There is simply no basis for determining why these deficiencies occurred, what.
! their root cause was, what generic implications. are presented by 4
such cause, and whether corrective actiore can be' deemed adequate. Summary disposition should be denied. e s y vi-e ! 3
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H Subcontention'5:B)'
- 5. Contrary to Criterion III, " Design Control," of '10 -
C.F.P. Part 50, Appendix B, Commonwealth Edison Company has failed to establish measures to assure that appli ~ cable regulatory requirements and design' bases are .cor-rectly translated into specifications, drawings, proce-dures, and: instructions including. provisions to' assure that appropriate quality standards are specified in design documents and that deviations from such standards are controlled. Applicant has also failed to require that measures are established for the identification and - control of design interfaces and for the coordination among participating design organizations, _ that the mea-sures include the establishment of procedures among - participating design -organizations -for the review, approval, release, distribution,_and revision of docu-ments involving design inter faces; and that the design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate _'or simplified calcula-tional methods, or by the performance of a suitable-testing program. B. Pepairs to coatings by Midway Industrials in the Unit 1 and 2 containments were performed utilizing a coating system not qualified for the-Design Basis Accident in accordance with Section 5 of ANSI N101.2 (1972). (Inspection Peport 85-15, Exh. 17.) Facts In Dispute Edison, Sargent & Lundy and the nuclear' coatings contractor, Midway Industrial Contractors, failed to establish and implement a coatings repair procedure which is qualified for Design Basis Accident Conditions as required by ANSI N 101.2. Corrective action has not ef fectively assuced that design requirements have been met. This item of noncompliance reflects a failure by Edison and Sargent & Lundy to. require a qualified procedure for a repair to containment liner coatings qualified for Design. Basis Accident 1 1
conditions in accordance with the applicable ANSI standard.
. Edison characterizes-this issue as not implicating a Criterion -
.IIILdesign control. issue. We disagree. The clear fact avoided by i
Edison's position on subpart 5(B) is that the Applicant and its architect / engineer failed to assure-that proper procedure was in . 4 place for such repairs; and, further, failed to assure that the repairs which were actually made were appropriately qualified through the standard. Further, the extent of:the' unqualified { coatings repair was not contemporaneous 1y documented 'and no j j- ef fective design analysis has been per formed of the discrepant 1 i coating conditions. l Applicant offers only the af fidavits of two demonstrably i incom pe tent witnestes in support of its position on this issue:
- Sargent & Lundy engineer Ken Kostal, again, who acknowledges that
, he relies solely upon the personal knowledge of a subordinate engineer, one Ted Pudaitis, who performed the actual field l documentation review and analysis. (Kostal Deposition Tr. 5 6.) 1 4 Mr. Fichard Leigh arrived at Braidwood in January,1984, some f five years after the unqualified coatings' repairs were made.- i (See excerpt from Midway NCF 23, Kostal Deposition Exhibit No. 8, L Exhibit A hereto.) Edison's response, in 1985, was to attempt to estimate the i I extent of the unaualified coating repair in the absence of any l contemporaneous documentation of the repair areas. .Apparently on the principal basis of a terse April 25, 1985, note from former i 1 Midway OC inspector, Anthony Salem, Sargent & Lundy assumed that . all ungualified repairs were in a two-l'nch strip along the liner 'l l
\
i 2 i I'
plate weld seams. See-Exhibit A, Attachment A;-Kostal Affidavit,
- p. 5; Kostal Deposition Tr. 74.).
O:- Now, your, assumption is that-th'e weld repair' area, the
~
area subject to the improper coating -repair, 'was no greater than two inches wide on a vertical seam;-isn't that correct? One inch on either side of the weld seam? A: That's correct. Id-In fact, however, reference to ' the only contemporaneous documentation of the repair work per for'med, - the Midway NCP's, reflects at page 2 of.5 that after grinding the liner plate
" painters #1, #3, #5 were instructed on mixing, spray techniques
... each then sprayed areas approx. S sguare on' liner plate."
This hardly seems to describe a coating repair to a two inch. wide weld seam area. Mr. Kostal acknowledges that no Design . Basis Accident analysis has been performed for Braidwood reflecting an analysis of potential detrimental effects from coating particles in the sump fluid systems. (Kostal Dep. Tr. 94-95.) Nor has.any coupon. qualification test been performed for the n<ni qualified coating repair technioue. (Kostal Dep. Tr. -- 9 6.) Finally, Midway'only adopted a coating repa,ir procedure in 1982. The' repairs in question were performed prior to the adoption of any repair procedure. Sargent & Lundy reviewed all Midway coatings proce-dures; however, M r. Kostal's position is that "it's not Sargent & Lundy's role to define all the procedures that a contractor needs to develop." (Kostal Tr. 97-100, at 100.) Sargent & Lundy simply evades responsibility for the programmatic OA failure that 3
is reflected in contention subpart 5(B). Edison's motion for summary disposition is unfounded and should be denied. 4
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- 5. Contrary to Criterion III, " Design Control," of 10 C.F.B. Part 50, Appendix B, Commonwealth Edison Company has failed to establish measures to assure that applica-ble regulatory requirements and design bases are cor-l rectly translated into specifications, drawings, proce-l dures, and instructions including provisions to assure -
l that appropriate cuality standards are specified in design documents and that deviations from such standards are controlled. Applicant. has also failed to require that measures are established for the identification and control of design interfaces and for the coordination among participating design organizations, that the mea-sures include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of docu-ments involving design inter faces, and that the design control' measures provide for verifying or checking the adequacy of design, such as by the performance of design r ev ie ws , by the use of alternate or simplified calcula-tional methods, or by the performance of a suitable testing program. C. Edison employed designs for safety related ifVAC duct cupports based on chapter E3 6.0 o f S& L's Structural Standard Document which did not limit the slenderness ratio for ceiling mounted duct nupports. (Inspection Feport 84-43/39, Exh. 19.) Facts In Dispute l Sargent & Lundy failed to specify the American Institute of Steel Contractors (AISC) Code required slenderness ratio (Kl/r)' limits in its Structural Standard Document (SSD) Chapter E36.0 for safety-related flVAC duct supports. Th i r ty-e ight hangers at Byron and 41 at Droidwood were identified which did not meet the AISC specified limits. The hangers at Dyron were reworked. At Braidwood S&L simply indicated an exception to the AISC limit. On the basis of allegations raised by engineer Charles Stokes in the Byron licensing proceeding, the'NBC Staff i 1 identified the derign deficiency by Sargent & Lundy that is applicable to both Dyron and Braidwood. S&L had failed to reflect the slenderness ratio (K1/r) limit of the ATSC manual in its design standards. The NBC identified 38 hangers at Byron and 41 at Braidwood which will experience experience compressive loads and have K1/r values in excess of the AISC reouirement of 200. The Byron hangers were reworked prior to fuel load. However, a design change reflecting an " exception" to the AISC l K1/r limitation was adopted for Braidwood. Inspection Peport 84-l 43/39, March 14, 1985. Mr. Kostal's a f fidavit evidences no personal knowledge of the factual matters which are contained therein. Specifically, the only reference to the cause of the omission of slenderness l l ratio limits from the design speci fication states that such omission was "through inadver tence." (Kostal Affidavit, p. 3.) l There is no showing of any basis for Mr. Kostal's testimony on this fact. The corrective action which was not simply to incor-porate the omitted slenderness ratio limitation, but to take exception to it and specify a limit which would avoid the neces-l sity for rework at Draidwood as had been necessitated at Dyron l simply evades the issue. What was the root cause of the omission of the design standard? What corrective action is necessary to address this deficiency? What are the implications of this deficiency for design control by Sargent & Lundy and Edison? These issues are the most important involved in this matter and they remain wholly unaddressed in Edison's filing. Applicant's motion for summary disposition should be denied. l l l 2 s. Subcontention 6(F)
- 6. Contrary to Criterion V, " Instruction, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Common-wealth Edison Company has failed to ensure that activi-ties af fecting quality are prescribed by documented instructions, procedures, or drawings, and are accom-plished in accordance with these instructions, proce-dures, or drawings.
F. In June, 1984, Phillips-Getschow, piping contractor, found piping that violated minimum wall requirements. This defect was not reported to owncr in accordance with 10 C.F.R. 21.21. (Inspection Peport 84-21/20, Fxhibit 20.) Facts In Dispute Edison and the mechanical contractor Phillips-Getschow Co. failed to establish and implement an ef fective procedure to assure the reporting of defects in basic components which, if uncorrected, could create a safety hazard. Phillips-Getschow Co. failed to r e rzo r t to Edison its identification of piping which violated minimum wall thickness specifications; and Edison, once it learned of the defects, failed to promptly inform the material supplier of the defect. In June of 1984 Edison's mechanical contractor Phillips-Getschow Co identified a portion of 8-inch schedule 120 pipe which failed toimeet the minimum wall thickness requirements of the material specification. (Schulz Dep. Tr. 378.) The matter was brought to the attention of the NPC inspector by "an anony-mous t ip" that a safety concern existed and that the defects should nave been reported pursuant to 10 CFP Part 21 to Edison management. (Schulz Dep. Tr. 369.) In doing so, Phillips-1 1 , <= Getschow . failed to understand that such a defect . posed " potential generic implications to other sites. And that's what a 21 1anically is. The purpose is not just for that site, to see-if it could af fect other sites." (Schul z Dep. Tr. - 3 68.) At the time of the observation the Phillips-Getschow nonconforming item procedure did not reouire a Part 21 evaluation to be made. (Boone Af fidavit, p. S.) Even af ter the defect was finally reported to Edison via the Phillips-Getschow Co. NCF of 9/9/84, Edison still failed to report the defect to the supplier for evaluation of generic implications for material at other sites. According to Edison's Mr. Boone, Edison Project Field Engineer-ing " indicated that the item was too small a sample to determine if the component deficiency should be reported to other users." (Doone Affidavit, p. 10. ) of course, any minimum wall problem in a pipe would have a potential impact on the piping system, regardless of the defect's size. (Schulz Dep. Tr. 376.) Ulti- f mately, Edison informed the supplier of the defect, but only after the NFC expressed concern about the matter to Phillips-Cetschow. (Poone Affidavit, p. 9.) Nowhere in Fdison's supporting affidavit is the root cause of this problem identified. Why didn' t Phillips-Getschow's NCP procedure require a Part 21 evaluation? Why didn't Edison itself report the defect to the supplier when it learned of the problem instead of waiting for the NDC action? Mr. Boone's competence to sponsor the testimony presented appears narrowly limited to his statement at page 8, "I personally recall reviewing NCR 1615 for reportability under 10 CFR Par t 21." Of course, no such report 2
- j. ,
was made. In general, Mr. Poone appears to be a licensing and compliance man (Poone Af fidavit, p. 2), with no stated personal knowledge of the matters in issue with the exception of the specific action referred to. On. February 14, 1986, Intervenors requested production of Phillips-Getschow Company's review of closed NCR's which review had only recently been identified in discovery. Neither this document nor any other documents were appended to Applicant's motion for summary disposition with respect to subpart 6(F). This PG Co. review has not yet been made available to Intervenors. Material issues of fact remain for hearing. Summary disposition should be denied. i .i 3 u___.____.______---_--- ^ (7 s~. Subcontention 6(G) l 6. Contrary to Criterion V, " Instruction, Procedures and ! Drawings," of 10 C.F.P. Part 50, Appendix 0, Common-wealth Fdison Company has failed to ensure-,that activi- - l ties affecting quality are prescribed by documented instructions, procedures, or drawings, and are accom-plished in accordance with these instructions, procc-dures, or drawings. G. Applicant placed purchase orders with an unapproved bidder, H.H. Howard Corp. of Chicago, that did not have an approved OA. program. Purchase orders were for clean-ing . of 206,744 feet of safety-related piping. (Inspec-tion Peport 84-17, Exhibit 21.) Facts In Dispute Edison failed to establish and implement of fective procedures to assure that activities affecting quality are appropriately controlled where the cleaning of over 200,000 feet I of corroded safety-related pipe was per formed by a vendor. without an approved quality assurance program in an uncontrolled manner with indeterminate effects on the integrity of the pipe. Due to apparently improper outdoor storage practices, over 200,000 feet of safety-rekated pipe experienced severe rust and corrosion. Edison improperly contracted on unapproved commercial vendor,, t he 11. 11. Iloward Corporation, for the performance of a chemical cleaning procces. This vendor did not have an approved OA program and the pipe was subscouently chemically cicaned j through an uncontrolled process. The effects of the corrosion 1 ! and uncontrolled c1 caning process on the integrity'of the pipe itself remains open with the NDC. It in the subject of contention of nubpart 11(c) - a matter not the nuhject of summary l l ! l 1 L l I disposition. .Among the unanswered questions concerning this
- matter is why Edison stored this safety-related pipe outdoors in 1
i an uncovered condition. Why did Edison decide to employ a chemi-I cal cleaning process in order to install this corroded pipe in the plant? And why did Fdison employ- an unapproved vendor with-1 l .out a quality assurance program to perform this critical task on l l a safety-related component? None of these matters are addressed in the only af fidavit supporting Applicant's motion for summary disposition on this matter. project Construction Field Engineer-Michael A. Gorski's primary responsibilities are in support of licensing matters ( Af fidavit, p. 3). There is no indication of personal knowledge of any of the matters stated in his affidavit testimony. Such statements as "it was decided to clean the pipe" (p. 1), and "Fdison believed they would not adversely affect the pipe" are obviously not founded upon established competence. If Edinon did not look into the quention of root cause, neither did the NPC. Mr. Schulz, in closing the item of noncompliance, apparently believed that the counc of the deficiency was unimpor-tant (Schulz Tr. 383-84). The cause, significance and implica-tions of Edison's slipshod handling of a vast quantity of safety-related material must be addressed on the merits. Summary disposition is inappropriate and should be denied. 2 3 6 Subcontention 6(T)
- 6. Contrary to Criterion V, " Instruction, Procedures and Dra wings," of 10 C.F.R. Part 50, Appendix B, Common-wealth Edison Company has failed to ensure that activi-ties af fecting quality are prer.cribed by documented instructions, procedures, or drawings, and are accom-plished in accordance with these instructions, proce-dures, ot drawings.
I. Material installed for the pipe whip restraint plate was not of proper specifications. (Inspection Peport 84-09, Exh. 2 2. ) Facts In Dispute i Edison and Phillips-Getschow failed to provide for and impicment an ef fective procedure to assure that material of proper specifications was installed where improper pipe whip restraint plate material was installed in Chicago Dridge & Iron l (CD&I) fabricated restraints. The root cause of the improper material substitution has not been identified. The NFC identified an example of improper material substitution involving a plate added to a vendor-supplied pipe whip restraint. A subsequent follow-up identified eleven additional restraints with the wrong material installed. (Poone l Affidavit, p. 5.) Neither of Edison's summary disposition af fiants appear competent to support the testimony presented. l Mr. Boone is primarily a licensing man; his affidavit reflects no personal knowledge or involvement in the matters of concern. Mr. Stewart, who has been a Phillips-Getschow project engineer since August of 1983, describes the Phillips-Getschow Company response to the matter but does not set for th the basis for his 1 i competence. Nor does he address the cause of the improper material substitution. Mr. Doone, on the other hand, boldly asserts that the "cause of the improper uses of material uncovered during the pipe whip restraint data pack review was either the Superintendent requesting incorrect material, or the warehouse man failing to fill the store's request as wr it ten." (Boone Affidavit, p. 7.) Neithes the basis for such a conclusion nor Mr. Doone's competence to rectify on such subject is set forth. Mr. Schulz, the NRC inspector who opened and closed the item, hypothesizes as follows: And maybe the -- my hypothesis would be, he felt that this was as good enough -- as good a material as the other material appeared I mean, steel plate is steel plate period, and f rom his point of view -- maybe f rom a fitter's point of view, which is not a strong engineering point of view, this plate l would serve the same purpose. And I wouldn't consider that deliberate and I haven't found that in all my innpectionn of the caso and working with fitters out there, that anything was done j deliberately and I talk to them continually. l Schultz Deposition Tr. 395. In any event, Mr. Schulz disclaims any substantial concern about the cause of the improper material substitution: l The bottom line again, if every violation, every unresolved item, every open item we had we found ! it was -- we inspected it like an allegation to l find out if it was deliberate or not, we'd be -- l we wouldn' t get our normal inspection activities done. 1 Schulz Deposition Tr. 394. Knowing and deliberato use of improper material in a nucicar narcty applicat ion in a norioun matter, regardlenn of the belief 2 t . .o of the individual that the substitute was " good enough". Both Edison and the NRC Staff would have this issue closed without' addressing, let alone resolving, this violation. l I l f r l l l L l l 3 I r e- fe Subcontention 9(A)
- 9. Contrary to Criterion IX, " Control of Special P r oc e s se s ," of 10 C.F.P. Part 50, Appendix B, Common-wealth Edison Company has f ailed to ensure that measures be established to assure that special processes, includ-ing welding are controlled and accomplished in accordance with applicable codes, standards, specifications, criteria and otter special requirements.
A. 127 safety-related structural steel fillet welds were painted prior to acceptance of the work and the welds were subsequently visually inspected for acceptance, with 79 accepted in the painted condition. In addition, visual weld inspections were not per formed on safety-related full penetration welds completed under the jurisdiction of Structural Specifications F/L-2735 and F/L-2722 prior to May 1,198 4. The welds were accpeted based on other methods of nondestructive examination, but were not accepted in accordance with the require-men ts o f Sec t ion 0.15, Quality of Welds, Visual Inspec-tion. (inspection Peport 04-21/20, Exh. 2 0.) Facts In Dispute Edison and its independent tenting contractor, Pittsburg Testing Laboratorten (PTL) failed to assure that special processes such as welding were effectively controlled where Fdison improperly instructed PTL and PTL improperly performed final visual inspections and accepted 127 nafety-related structural steel fillet welds in a painted condition. The root cause of this i m pr ope r instruction and inspection have not been identified. At least in 1960 Pittsburgh Testing Laboratories (PTL) weld inspectors inspected and accepted safety-related structural steel fillet welds in a painted condition. In the known, documented instances such inspection was performed at the direction of Fdison. The nubject weld innpection report identified by an NRC 1 ..gea inspector in the PTL vault in May, 1984, included " inspected through paint per CECO OA." (Forrest Affidavit, p. 3.) Mr. Forrest, Edison's sole a f fiant in support of summary d!sposition on this subcontention was present at the time of the NPC inspection and speaks from apparent personal knowledge es to the investig'ation that was conducted in 1984. However, Mr. Forrest only arrived on site in 1982 (Forrest Affidavit, p. 6), and, thus, has no personal knowledge or competence to speak to events occurring at the time of the improper inspections in 1900. The PTL investigation of this issue consisted primarily of reviewing other inspoet ion documents for similar cuotations regarding inspections through paint. Six additional inspection reports were identified. ( F.o r r e s t Affidavit, p. 3.) Altogether they reflected the inspection of 127 welds in painted condition. The deficiencies in this response are glaring indeed. No explanation whatever is provided for the apparent assumption that in all instances where the weld was inspected through paint the per formance of such an improper inspection would be duly documented on the inspection report itself. How can we excInde the possibility that the two inspectors who documented this practico did so to evidence their protest at such instructions, or perhaps because they were especially diligent. The practice itself is obviously improper; and given so, its documantation should not be nat urally assumed. Irow many other velds were inspected through paint at the direction of Ceco OA or otherwise hut not documented as such on the subject inspection reports? l Two equal 1y fundamental questions also arise. Firat, why 2 c: x' . .-- f .s o , 4 'would CECO OA so instructaPTLweld'inspectorinclearvk,olation of inspection procedures and acceptance criteria? Second, the logical corrollary, why .would an effectively qualified and trained ~ PTL weld.: inspector follow such improper dirdNtion,' whether documented or-not?- No answers appear to any of these' questions in Edison's . c ,. summary disposition papers. Nor is there even an acknowledgement that these issues need to be resolved. Summary dispo?ition is \ clearly an inappropriate remedy in the face of r,uch guestions. I r t 9 v 9 y ( 1 g . t J Y g 3 1 , t '______.________.__._m______ .__;__.__._____.__._._____ _ . . _ _ _ _
- 1. .
Subcontention 9(C)~
- 9. Contrary to Criterion -IX, '" Control: of. Special Processe s ," of 10 C.F.F. Part 50, Appendix.B,' Common-wealth Edison Company has . failed to ensure that measures
- - be established to assure that special processes, includ-l ing welding are controlled and accomplished in i accordance with applicable ' codes, ' standards,' specifica-l- tions, criteria-and other special reouirements.
l i C. .Nine L.K. Comstock filler metal withdrawal authorization ! forms documented the release of E7018 weld rod for . cable L pan welds between May 25, 1982.and July 28, 1982. (Inspection Peport 84-13, Exhibit 24.) Facts In Dispute ' l Edison and its electrical contractor L.K. Comstock (LKC) l failed .to assure that special processes such as welding were ef fectively controlled where they failed .to provide for and ef fectively implement procedures to assure for the proper control of weld rod for cable pan wolds. The qualit y of such safety-related, welds is indeterminate where LKC failed- to complete the 100% weld rod documentation review to which it had committed and the quality of welds performed with the wrong weld rod cannot be assumed. One facet of the widespread Comstock quality document reliability problem is the indeterminate character of weld rod withdrawal authorization forms which are required to document the t use of specified weld rods for particular safety-related welding applications. Comstock employed Worley O. Puckett in the spring t of 1984 ' as the f.evel III weld inspector with the assignment of t ! identifying and resolving quality problems including document ! , traceability problems for weld filler material. The results of , 1 M r. Puckett's investigation of Comstock weld rod withdrawal forms < is documented in memoranda dated April 15 and 17,1984. In the latter document Mr. Puckett identifies a " generic" traceability problem for weld filler material records stretching back to 1982. He recommended "a more thorough review be performed on all the rod slips so as to have an in-house identification of any major problems we may have." Mr. Puckett was subsequently terminated by Comstock in retaliation for his expression of safety and cuality concerns. See, e .g . , QC Inspector. Harassment and Intimidation Contention and incorporated reference documents. Mr. Puckett's generic weld rod document concern is the subject of Comstock nonconformance report No. 3275 ano as revised, No. 3275 Rev. 1, dated 11/7/85 to which his April memos are attached. (Exhibit A hereto.) The original disposition of the Comstock NCR committed to a review of "all filler metal withdrawal forms for. discrepancies in heat number and rod type." A recurring problem reflected in the weld rod withdrawal forms was the listing of 4 heat numbers for E7018 electrodes and the issuance of E6013 electrodes. l Ultimately, the disposition of the NCR was changed,- Rev. 1,. i to eliminate the 100% review of withdrawal forms for discre-pancies. In place of such a review, the problem was simply " engineered away" by the Comstock -0A welding engineer, who stated that "the components welded utilizing either of these electrodes meets or . exceeds the strength requirements specified by AWS Dl.1-7 5." (Exhibit A hereto, April 15, 1984. meme attached.) This disposition is wholly inadequate to address and resolve the 2 e ,.,m, , discrepancies in Comstock quality documents or to establish the quality of what remains indeterminate welding. It should be obvious th'at this NCF disposition does nothing to resolve what was indisputably characterized by Mr. Puckett and those Comstock managers who originated the NCR as a " generic" problem. No effort whatever is expended in attempting to determine the root cause-of the document discrepancy problems. One is simply lef t to wonder why the wrong heat numbers or rod type specifications were listed on the quality documents. Further, a genuine issue as to the workmanship quality and weld acceptability exists where the specified weld filler material was not, in fact, employed. Even Applicant's affiant, Mr. Kurtz, acknowledges that "when using an E70 electrode on galvanized material, additional surface preparation is required." Given such preparation, he asserts, "[I] f a properly qualified welder follows a suitable welding procedure, a sound weld should result with either electrode ser ies." (Kurtz Affidavit, p. 3. ) That's a lot of "if's", "and's", and "but's." Comstock's former Level III inspector, Worley O. Puckett explains the workmanship and quality concern: 0: And do'you agree that when you use the E7018 filler material in such an application, on galvanized cable pan base metal, a welder would i likely get rejectable porocity and cracking? ' A: I would say that he could get porosity and , cracking. He wouldn' t necessarily get that. Your i E7018 is a low-hyd rogen rod, and if it becomes -impregnated wiks the galvanize that burns off-your sheet metal it very well could show visible porosity or.there could very well be cracks that . l 3 I were surface or sub-surface.- This is, I think, -the specification come from Sargent & Lundy; telling Comstock to use 6013 rods.- (Puckett-Deposition.Tr. 335.) ' THE WITNESS: Yes. Well, I was a nuclear component welder in the' Navy.for.14 years. I worked on numerous power plants. I welded all components. I was well qualified, and'I think my oualifications reflect.as much. I.would say that it would be more appropriate to use the E6013 rod. if for no other reason because it was stipulated by Comstock procedures and by Sargent & Lundy procedures. I do know that there are engineering reasons behind using the E6013 over E7018. .I don't know all their reasonings. I do know in my-past experience in welding galvanized with E7018 rod that you sometimes do receive porosity, that you can receive surface and sub-surface cracking. . There is a possibility that you will receive some good welds out of this. (Puckett Tr. 337.) You are more likely to receive a defective weld. However, if you do get a weld that does not reflect porosity or surface cracking visual to the eye where you can see it, you have a prettier weld. It's easier to inspect and easier to accept. With the E6013 rod you have a very. rough surface. The surface is hard to clean because of the slag. With the E7018, the surface is much more easy to clean and you get a better .looking. weld. 0: Alright. But that better looking weld with the E7 material may nonetheless be rejectable due to sub- , surface' porosity or cracking? A: There is a good possibility of.that, yes. 0: Might some of that rejectable condition, the porosity and sub-surface cracking remain undetectable even upon visual inspection? i A: Oh, yes. (Pucket t Tr. 338.) 4 I ') .. s _. . The significant issues involving the' adequacy of'the Comstock corrective action regarding the document deficiencies 'and the acceptability of the previously unspecified weld metal
- I cannot be resolved on summary disposition. The acceptability of the . workmanship is in further doubt 'where production and -schedule pressure and harassment claims undermine confidence in Comstock visual inspections. Summary disposition should be denied, i
i t Y 4 + i 1 t i i 4 9 I .I 5 r Sutcontention 9(C)
- 9. Contrary to Criterion IX, " Control of Special P r oc e s se s ," of 10 C.F.P. Part 50, Appendix P, Common-wealth Edison Company has failed to ensure that measures be established to assure that special processes, includ-ing welding are controlled and accomplished in accordance with applicable codes, standards, specifica-tions, criteria and other special reouirements.
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 Peport 84-13, Exhibit 2 4.) Facts In Dispute Edison and its electrical contractor L.K. Comstock (LKC) failed to assure that special processes such as welding were effectively controlled where they failed to provide for and ef fectively implement procedures to assure for the proper control of weld rod for cable pan welds. The quality of such safety-related welds is indeterminate where LKC failed to complete the 100% weld rod documentation review to which it had committed and the quality of welds performed with the wrong weld rod cannot be assumed. One facet of the widespread Comstock quality doctment reliability problem is the indeterminate character of we]d rod withdrawal authorization forms which are required to document the use of specified weld rods for particular sa fety-related welding applications. Comstock employed Worley O. Puckett in the spring of 1984 as the Level TII weld inspector with the essignment of l identifying and resolving quality problems including document l l traceability problems for weld filler material. The results of l 1 Mr. Puckett's investigation of Comstock weld rod withdrawal' forms is documented in memoranda dated April '15 and 17,1984. In the 'latter document Mr. Puckett identifies a " generic" traceability problem for weld filler material records stretching back tio.1982. He recommended "a more thorough review be performed on all the rod slips so as to have an in-house identification of any major problems we may have." Mr. Pucket t was subsequently terminated by Comstock in retaliation for his expression of safety and ouality concerns. See, e .g . , OC Inspector Harassment and Intimidation Contention and incorporated reference documents. Mr. Puckett's generic weld rod document concern is the subject of -Comstock nonconformance report No. 3275 and as revised, No. 3275 Rev. 1, dated 11/7/85 to which his April memos are attached. (Exhibit - A hereto.) The original disposition of the Comstock NCR committed to a review of "all filler metal withdrawal forms for discrepancies in heat number and rod type." A recurring problem reflected in the weld rod withdrawal forms was the listing of heat numbers for E7018 electrodes and the issuance of E6013 electrodes. Ultimately, the-disposition of the NCR was changed, Rev. 1, to eliminate- the 100% review of withdrawal forms for discre-pancies. In place of such a review, the. problem was simply " engineered away" by the Comstock OA welding engineer, who stated that "the components welded utilizing either of these electrodes meets or -exceeds the strength requirements specified by AWS Dl.1-7 5."- (Exhibit A. hereto, Apr il 15, 1984 memo attached.)- This disposition is wholly inadequate to address and resolve the 2 _-.A discrepancies in' Comstock quality documents or to establish the quality of what remains indeterminate welding. It should be obvious that this.NCR disposition does nothing to resolve what was indisputably-characterized by Mr. Puckett and those Comstock managers who originated the NCR as a " generic" problem. No effort whatever is expended in att'empting to determine the root cause of the document discrepancy problems. One is simply lef t to wonder why the wrong heat numbers or rod type specifications were listed on the quality documents. Further, a genuine issue as to the workmanship quality and I weld acceptability exists where the specified weld filler material was not, in fact, employed. Even Applicant's affiant, M r. Kurtz, acknowledges that "when using an E70 electrode on i galvanized material, additional surface preparation is required." Given such preparation, he asserts, "[I]f a properly qualified welder .follows a suitable welding procedure, a sound weld should result with either electrode ser ies." (Kurtz Affidavit, p. 3. ) i That's a lot of "if's", and's", and "but's." Comstock's former Level III inspector, Worley O. Puckett explains the workmanship and quality concern: 0: And do you agree that when you use the E7018 4 filler material in such an application, on . galvanized cable pan base metal, a~ welder would ~1ikely get rejectable porocity and cracking? A: I would say that he could get porosity and cracking. He wouldn' t necessarily get that. .Your : P,7018 is a low-hydrogen rod, and if it becomes ; impregnated _ with the galvanize ~ that burns off i your sheet metal it .very well..could show visible j porosity or there could very well be cracks that 3 I I were sur face or sub-surface.- This is, I think, the specification come from Sargent & Lundy telling Comstock to use 6013 rods. 4 (Puckett Deposition Tr. 335.)- THE WITNESS: Yes. Well, I was a nuclear component welder in the Navy for 14 years. I worked on numerous power plants. I welded all l components. I was well qualified,_and I think my-aualifications reflect as much. I would say that it would be more appropriate to use the E6013 rod if for no other reason because it was stipulated by Comstock procedures and by Sargent &:Lundy procedures. I do know that.there are engineering. reasons behind using the E6013 over E7018. I don't know all their reasonings. I do know in my past experience in welding galvanized with E7018 i rod that you sometimes do receive porosity, that you can receive surface and sub-surface cracking. There is a possibility that you will receive some good welds out of this. (Puckett Tr. 337.) You are more likely to receive ~ a defective weld. However, if you do get a weld that does not reflect porosity or surface cracking visual to the eye where you can see it, you have a prettier weld. It's easier to inspect and easier to accept. With the E6013 rod you have a very rough surface. The surface'is hard to clean because of the slag. With the E7018, the surface is much more easy to clean and you get a better looking weld. 0: Alright. But that better looking weld with the E7 material may nonetheless be rejectable due to sub-surface porosity. or cracking? A: There is a good possibility of that, yes. 0: Might some of that rejectable condition, the porosity and sub-surface cracking. remain undetectable even upon visual inspection? A: Oh, yes. (Pucket t Tr. 3 38.) I 4 4 - _ . _ - _ . _ _ _ . - - . _ _ . . - - - _ - - _ _ _ _ - _ _ -__ _--.s._ _ _ . - - - - _ . _ . - - _ _ . - _ - - - - _ - - _ _ _ _ _ - - - - _ - _ - _ _ _ _ _ . _ _ _ - - - - - - _ - _ _ _ - A The significant issues involving the adequacy.of the Comstock corrective action regarding the document deficiencies and the acceptability of the previously unspecified weld metal cannot be resolved on summary-. disposition. .The acceptability of. the workmanship is in further doubt.where production and schedule pressure and harassment claims undermine confidence in Comstock visual inspections. . Summary disposition should be denied. t 4 4 4 T e b i l . j ., i i 1 5 _ = _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ - - _ _ _ _ = _ - _ _ _ _ - - - - _ - _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ ___:-_--___---______--__-____ g . SUBPART 9(C): EXilTBIT A L. K. COMSTOCK & COMPANY. INC. nratdwood 4.11.1 cAsect NONCONFORMANCE REPORT
- L. K. COMSTOCK & COMPANY, INC. Sht. L of R
- NONCONFORMANCE REPORT NO. 32 7 f~ REY. 1 OATE HH/85 ;
INSPECTION CRITERIA: I DWG. II/A REV. tt/A SPEC. L-2790 3 PROCEDURE: h.3.10 REV. D Int. OTHER N/A ITEM (S) DESCRIPTION Weld Rod Withdrawal Forn 57's LOCATION N/A DESCRIPTION OF NONCONFORMANCE: NCR 3275 is being revised as follows: Form 57's, Weld Rod Withdrawal forms, had errors in documentaticn. Forms snoved heat numbers for E7018 electrodes and issuance of E6013, as shown on sheet 2 of original NCR 3275. In addition, there are clerical errors on the transfer of the heat numbers as noted below:
- 1) On sheet 2 of NCR 3275, original, a heat number is shown as h21 Phk61. This heat nu=ber is actually hil Ph161.
~ ~ ~ ~ (Cont on Sht. 2) ORIGINATOR / Y 4~ DATE /481//( [ ] Engineering ' / HOLO TAG N0'S N/A [>d QC DEEMED REPORTABl.E PER 10CFR21 (l.KC 3.1.3) POTENTIAL 10CFR50.55(e) YES [ ] NO (( YES [ ] NO [y QC MANAGER / DESIGNEE REVIEW AA-t DATE/{4v6 SYSTEM (S) ra/A* (if applicable) DISPOSITION: [ ] USE-AS-IS [ ] REWORX [ ] REPAIR [ ] SCRAP }<3 OTHER CORRECTIVE ACTION / JUSTIFICATION: , 4= 1L3STip.tc ATicM A44C5 Catse OGdTic M ATTDt Mt.D TO ) [ N G M L- (,ftA W. D) c:G HCR. C: ATE.C> W.ZI. 84 Al 4sch SEE AN ED N , hh t4o. SS-o2.-og -o4 ANO hcAwoum. Is 0" TShe. Twt as h(OMVG.464.Tice. N FM MAIA& t.sgTHM*'1 McTE. T%AT FogMS 16 N MW SS Z c 4S-od. $ ACTION TO PRECLUDE REPETITION: M WegQ' I 6E.E Ac nce To eem a Race.Tirew ( ATrN un.o To es.v.O c5 R G.C . CMTuo W.w.m . DISPOSITIONED BY/TITL b d O R ; /Anst.%=1Evad) ATE INS 85 (continued on hack) { P R E PA R E O APPRO V E D R E vtSEO TITLE O RIG. O AT E REVISloN FCHM # [ MRW RVS RVS c t PROCEDURE 05/31/79 QAS4 10/03/05 14 { L K. COMSTOCK & COMPA~Y. INC. oraidwood 4 11 1 GA ,ECT 50.55E [ } YES C><3 NO j CLIENT CONCURRENCE WITH DISPOSITION: (COMMENTS) A kCb A6 ass nuim ThE /.4uscreu t wico 1 AA>b A:nno in ChEVhn EecuR210eE._. WlA LU . N E Lulvlbs AECWPROJECTSUPT. DATE CECO QA SUPV. [ bi j ' DATE ' CECO FIEt,VE1dG. '0 ATE CORRECTIVE ACTION COMPLETE 0/ ACTION TAKEN TO PRECLUDE REPETITION: DISPOSITION COMPLETED TITLE DATE Q.C. VERIFICATION OF CORRECTIVE ACTION [ ] REJECT QC INITIAL /0 ATE REASON FOR REJECTION: [ ] ACCEPT REMARKS / ACTION TAKEN: , I II& %= DATE NONCONFORMANCE CLOSED ' QC INSPECTOR _ DM REVIEWED QC MGR/ DESIGNEE 4Q DATE N, COPIES: LKC ENGINEERING DEPT. Q.C. RECORDS FILE 'g$ {h CECO QUALITY ASSURANCE REASON FOR VOID (IF APPLICABLE) I ti [ l = e l L. K. COMSTOCK O COMPANY. INC. BRAIDWOOD 4.11.1 M SECT ~ 1 I NONCONFORMANCE REPORT CONTINUATION SHEET ' E7E NCR MO. i REV._ 1 _ Sht._ 2 _of 2 I t I NOTE: Pascrintion of Nonconrorrance: (cont.) STATE SECTION CONTI
- 2) ,
On Sheet 3 of orh innt NCR 1275: a) A heat number is shown as h0259001. This heat nt.ciber is actually h02S9011. ) , b) - The dates listed shov S/25/82 and 7/22/83. The 7/22/83 5
- 3) date should be 7/22/82 as referenced on sheet 2 of NCR .
On Sheet b of original NCR 3275: a) A heat number is listed as holS9011. This heat number - is actually h02S9011. b) A heat number in listed no 3S202061. This heat number ; is actually 3_S202061. I l 3 17 (~ U N /.f f l i pi si a , i i l 4$,I w ts ; ! !I L is 9 l s ? KEFARED A*9 AO v t D #EvtMO { fifLE ORIO.OATE REVISION JOS IFD FORM $ PR EEOURE F m 06/18/84 = 14A ' 4 3h:n : Attached - Nonconformance - 3275 September 12, 1984 I In violation of Procedure 4.3.10 Filter Metal Withdraw Forms. The forms did not specify the specific component the rod was used on and only listed fee t. general building locations, such as Auxiliary Building, elevation' 463 Nine' filler metal withdrawal authorization forms documented tha assign-ment of E7018 weld rod for cable pan welding, even though Sargent and I. undy drawing 20E-0-3251, Revision AC and L. K. Comstock Procedure 4. 3. 3, dated January 29, 1982, required the use of E60 Series weld rod for crble pan welds. Detailed below are the nine forms documenting the release of E7018 weld rod, by heat number, for cable pan welding: f Date of Requisition _ Designated Area Heat No. Class 5/25/82 Auxiliary Bldg., 383' 411P4161 5/25/82 *E6013 Auxiliary Bldg. 411P4161 *E6013 l 5/26/82 Auxiliary Dldg. 411P4161 *E6013 j 6/9/82 Auxiliary Bldg., 383' 411P4161 6/10/82 *E6013 Containment #1, 426' 411P4161 j 6/11/82 E7018 Auxiliary D1dg.,426' 421P4461 E7018
- 6/22/82 Auxiliary Dldg.,426' 402S9011 E7018 7/13/82 Auxiliary Bldg. ,463' 402S9011 *E6013 7/28/82 Auxiliary Bldg.,439' 402S9011 E7018 g-
- Heat numbers 411P4161 and 402S90ll were actually E7018 weld. rod as the inspector reviewed the material certifications. The rod issue attendants apparently thought these heatn of rod were E6013. Note that the same heats, 411P4161 and 402S9011, were handed out as both E6013 and E7018 weld r'd.
In addition, further inpstigation/research has revealed that this was a generic violation during the same time period as per attached memorandum - Control No. 84-08-15-14, 84-08-15-14A, 84-09-12-07. 4 P 4 5 5 1 wr t L. K. COE TOC A 9 CO*1PANY. INC. er.m.,w : i t i ! -- NONCCNFORMANCE REPORT { ' SYSTEM _ N/A l She 1 of 5 { l q g NONCONFORMANCE REPORT NO. 3275 l DATE Sentember 12, 1984 ' INSPECTION CRITERIA: OWG.N/A 1 REV.N/A SPEC. L-2 790 PROCEDURE: 4.3.10 Pov D Int. OTHER N/A l ITEM (S) DESCRIPTION Weld Rod Withdrawal LOCATION OA Records Vault Form 1857 l DESCRIPTION OF NONCONFORMANCE: See Attached Sheets 2 Thru S l l NUMBER OF HOLD TAGS APPLIED 'J OC INSPECTOR /# DATE 9- d df 10 CFR 21 PROCEDURE 3.1.3 YES NO h - REPORTABLE ITEM CONCURRENCE DY Q.C. MANAGER i t~ z d } _. h RECOMMENDED DISPOSITION. h USE. ASIS EXPLAIN JsSTIFICATION: REWORK REJECT OTHER #:M!.t' ATTA( MEC) I"XS4beatot 4 MEUEX. D. I COMSTOCK PROJ. MGR/ DESIGNEE d d@ _ DATE b.rt..e 4 D. s >.% . to .zc.. s A ACTION TO PRECLUDE REPETITION: ( se. Arruuao e-- w r.x 1 9s ER. ATTAc wa.1:2 (oPLEs. oF 'tTAnom l ( $Esotoc 4 Arrut.Nc%>4(.A. Suas COMSTOCK PROJECT MANAGER (OR DESIGNEE)b. - 3d.E I _ DATE to FT..en o.a... - 1zm t j CLIENT CONCURRENCE WITH OISPOSITION: (COMMENTS) I \ Ob tow.utt's wim M. Asca nisposmou Auo ocnras -ra Meu.uoE. REPEntnW. l % J. L. SLAL ECO PROJECT SUPT. DATE h% oMDwbi ~L/u OiMhex ..Isist. ~ i i o i ltcla. CECOQyUPV. ' DATE ' ECO FIELD ENG. 'd5 ATE ! .a 1.Ac l i -PREPARED APPROVED REVISED l TITLE \ ORIG. DATE REV.DATE FORM NOR. ROM AJT IFD PROCEDURE 5/18/79 14 03/01/84 DATE CORRECTIVE ACTION COMPLETED i l b,_J C.3 - RESPONSIBLE COMSTOCK FIELD REPRESENTATIVE 10*3\* M CATE Dve W. h6dTE. O. C. VERIFICATION OF CORRECTIVE ACTION h REJECT QC INITIAL /DATE REASON FOR REJECTION: _ ACCEPT REMARKS / ACTION TAKEN: DATE NONCONFORMANCE CLOSED OC INSPECTOR REVIEWED OC MGR/ DESIGNEE DATE COPIES: COMSTOCK PROJECT MANAGER ~~ COMSTOCK ENGINEERING DEPT. O. C. RECORDS FILE o%v 4$ w
- t I n.
RECElVED h, lJ$~. . eh N0'/ 011984 , i 'l eri9m cum rm c9,m ;j n%n*ntsi$ II i; 'ARED APPROVED REVISED TITLE ORIG. DATE R E.V. DATE FORM NBR OM AJT IFD PROCCDURE E 5/18/79 03/01/84 14 ( .j i;i.1- . + ~~ Comstock Engineering, Inc. , Memorandum To: M DeWald Office: Braidwood
- rom: T. D. Vogt ubsect Weld Piller Metal Withdrawal Date: Septembe r 12, 1984
'entrol No: 84-09-12-07 In response drawal program,to the FIRC statements regarding the Comstock filler metal with-ing actions have re ferenco been NRC Docket tio. 50-456 and No. 50-457, the follow-taken. A review iden tified.of the identified items was conducted and the following has been 1. The heat nu:r.bers identified are acceptable heat numbers trace-able to valid certification papers. 2. The components welded utilizing either of these electrodes meets or exceeds the strength requirements specified by AWS Dl.1-75. 3. 'Ihe wolders making the welds were qualified to use either filler metal. 4. An obvious procedure violation did occur. 5. A nonconformance report should be initiated. Based on the above co nts nonconformance report riCR 3275 has been issuco to identify the procedure violations which did occur and allow time for a proper review and evaluation of the identified nonconformance condition. h(I , N Correction Action Completed: . t i. Procedure 4.3.10 Rev D dated 8-12-84 titled l " Storage," Issue and Control of Wolding Material has been revised and 1 approved, which requires a filler tnetal issue tab to be issued for each g type and size of electrode and for each day's welding activity . gg Ib Corrective Action to be Taken: Training on the Procedure Requirements will it be given to all affected Personnel detailing the control of heat numbers and i documentaticn practices for the filler snetal issue tabs. 3 D 7 W T. D. Vogd I QA Welding Engineer l j TDV/pb cc: QC File M QC Mgr. file i -- s . 4e$ 1 ' ~~ Comstock Engineering, Inc. Memorandum 3
- a. Saklak Office: Braidwood om W. Pucke tt bject: R d Slips Date: April 15, 1984 {
l :ntro2, No: 84-08-15-14 l In regards and to the 7/22/83, Weld Rcdconcern main withdrawal involvesForms dated three between heat numbers 5/25/8f g l 411P4161 and 40259001 for E-7018 and 2D209808 for E-6013. N.R.C's concern was that the Weld Rod withdrawal Forms referenced i a type of Rod i.e. , E-6013 but the heat numNr listed for the material is docu: rented as being E-7018. I preformed extensive research on these Rod Slips with the follo sing results.
- 1. We three heat numbers afore mentioned are good heat numbers traceable to valid certification papers.
- 2. The coc:ponents on which they were used, the filler l
strength reets or exceeds the strength requirements.
- 3. We welders naking the welds were qualified to use '
either filler, i 4 ." We have an obvious procedure violation which could be aleviated in t)e future by a thorough Indoctornation of the craft tool room weld rod issue clerk. 5. A non conformance report should be initiated listing the heat numbers and types involved and a outline of R the procedural violation. $ j l DM Respectfully, 4b (. , t if ,s i 't h y e k . In .- - '[f I W. O. Puckett g I NOP/pb f 4 D cc: QC File ' h QC Mgr. ) g ~ d NED 2 %ug*h!ll l * - _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ B g ,... ,, , - .- M,* * - E. A. " 1 Comstock Engineering, Inc. Memorandum R. Saklak Office: Braidwood W. Puckett From: et. Rod Slios Date. Auaust 17, 1984 YAW Centrol No: 8.l-08-15-14 4 g a/TI i During the period of tice that I was doing Research on Neld Pod Slips for the months of May, June and July of 1982 it occured to me that the problems we were having during the afore mentioned period cculd possibly be generic through other periods, so I perforred a spot check on the Rod Slips Issued in December 1982, Septerber 1983, January 1984, June and July 1984 and during this period the problem did persist, however not as prevelant in the year 1984. In addition during the period prior to May 1982 Heat Numbers for E-6013 electrode were not entered on the weld filler material withdrawal form. I also took a sampling of heat numbers off of these previously issued Rod Slips to see if they could be ( traced to doeurentation the Heat lot numbers in the Pasearch of 'Nelve separate heat numbers I was successful in all but three heats 40lS7441 and 401S9011 for E-7018 and 35202061 for E-6013. It would be my suggestion at the very earliest convenient tice g that a more thourough review be performed on all the Pod Slips so as to have an in-house identification of any major problems we may have. o I < Respectfully, 1 I i , 1 u.n -C DM ' W. O. Pucke tt .o b 4 D WOP /pb cc: OC File lI. g hC Mgr. / 'tg i ll'F . RECEIVED 2 (+ i .M u m ~ WOC COMSloc' otpr. @ l I 1 1 ! \ t_ ~ .x. COMSTOCK & COMPANY. 'NC QA SECT l I NCR #3275 0!SPOSITION USE AS IS p<3 i i} JUSTIFICATION: The problems identified stem from documentation errors. As stated in referenced memorandum the heat numbers identified are traceable to valid certification papers, the filler metal tensile strength of either type of f electrode meets or exceeds the requirements of AWS 01.1-75 and the welders ' making the welds were qualified to use either electrode. In addition, any , unaccpetable welds would have been identified because 100% visual inspection of welding has always been required. Per ECN #23028 the use of E7018 ; electrode for welding of cable pan is acceptable. ACTION TO PRECLUDE REPETITION: i i Th2 applicable procedure (4.3.10) has been revised subsequent to the nonconfornance to improve control of filler metal and personnel involved in n issuance and control of filler metal have received training. ] v j C' O_x.J.a D. Bradfute 1 i c,.m.e4 Asst. Project Engineer 3 I a W WWM FW DOU &$ , TH L FCL.\=O \Q e% ~ ~ 1. m .6 a x, ,,< m e - e, m,s e4 , & :- g i D M YO w i-c~~ % IM kk @lQ M QTAL toe .--as %,. m _ g == =~ me go- s m _ , - . "" #" a ezase a-o m u r< w e w e n m. s awe ve - me c , ,, $ ece.omim , i k 'A- Du.a. 1 t85 t> zc..g4 WJE.V15,o M k op 3. l := M. .p IO, 4 Subcontention 9(D) ~ 9.- Contrary to Criterion IX, " Control of Special Processes," of 10 C.F.R. Part 50, Appendix B, Common-wealth Edison Company has failed to ensure that measures-be' established to assure that special : processes, includ - ing welding are . controlled and accomplished in accordance with applicable codes, standards, specifica-tions, criteria and other special requirements. D. Quality structural steel was not approved for use by the Architect-Engineer, Sargentl& Lundy, but.was released for use in installation.by the structuralLsteel'contrac-tor and documented as being used for cover plate welds.- Furthermore, the welder documented as; per forming the welding was'not qualified. In addition, RPSl Division loop B, reactor coolant flow, - completed socket weld joints, have no piping records-identifying the welder or weld filler metal utilized. (Inspection Report 84-17, Exh. 21. ) Facts In Dispute Edison and its contractors Gust K. Newberg Construction Company ("Newberg") and Phillips-Getschow failed to assure that special processes such as welding are controlled where Newberg-specified an incorrect welding procedure which was falsely documented as actually used for cover plate welds; and where Phillips-Getschow procedure failed to assure that welder and weld filler material identification were documented in an instrumentation . piping weld package. .The r'oot cause'of these deficiencies has not been effectively ident'ified. .This subcontention raises further concerns.regarding-the ef fectiveness- of quali ty assurance to control special. processes as well as guestions.regarding the. reliability.and integrity of quality documentation practices by site contractors. The subcontention raises two. distinct discrepancies identified by an 1 -a q . HNRC inspector: .one involving the structural contractor Gust'K. J Newberg specifying an incorrect weld procedure which was falsely
- documented by a Newberg welder in the quality records in place of the procedure actually employed; and second, quality documentation omission by the mechanical contractor Phillips-Getschow Company. The root cause of these deficiencies have-not been_ identified, and, therefore, the effectiveness of. corrective action is indeterminate.
With respect to the Newberg welding procedure issue, the glaring guestion remaining is: Why did the welder list-the incorrect procedure - falsely - when he actually employed the correct procedure? Clearly there was an error by Newberg 'in specifying the incorrect procedure. However, more troubling is the welder's false documentation of that incorrect procedure on-the quality records for that work. Edison's affiant Mr. Peynolds recites what is, of course, hearsay in his version of the inter-view with the of fending welder. (Feynolds Affidavit, p. 8.) We-are not even assured that this is first-hand hearsay, since Feynolds never establishes his competence to present such testi-mony. In any event, no evidence is presented explaining' why "the welder copied this incorrect WPS ~onto the section of the report where the WPS actually used was to be iden t i f ied." Id. Making an intentional false entry on a quality document is a very serious matter; and, yet, no consideration is given. this subject in Edison's papers. The second weld documentation deficiency incident -identified in subcontention 9(D) involves a failure to specify weld filler. 2- e metal and welder identification on a Phillips-Getschow record for an RPS Division Loop B reactor coolant flow, completed socket weld jcint. (Carlson Affidavit, p. 3.) Apparently, until the occurrence of this documentation discrepancy, Phillips-Getschow quality control personnel had been responsible for completing the quality records. The change in procedure was implemented to place this responsibility on the craf t supervision. If the defects in the former practice is identified to be the cause of this deficiency, one is left to wonder how many other similar deficiencies resul ted from that practice. The need for evalua tion of the cause of these weld and weld document deficiencies and the weighingof their significance and implications require that summary disposition be denied. t 3 4 - 1 h metal ~and' welder ide'ntification on a Phillips-Getscho'w -record for i an RPS Division Loop B reactor coolant flow, completed socket l weld. joint. (Carlson Affidavit, p.- 3.) Apparently, until the i. occurrence of this documentation' discrepancy, Phillips-Getschow; quality control personnel had been responsible for completing _ the i quality records. The change in procedure was implemented to place this responsibility on the craf t supe rv i sion.- If the defects in the former practice is identified to be the cause of . q this deficiency, one is lef t to wonder- how many other similar i deficiencies resulted from that practice. The need for evaluation of the cause of these weld and weld i document deficiencies and the weighingof their . significance and i implications require that summary disposition be denied. i i i 1 N 4 i 1 I 4 s. 3 i _ _ _ _ . _ _ . _ _ _ _ _ . - -' _ _ . _ _ _ _ _ _ . _ _ _ _ . _ _ ' _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ . _ _ . _ __._l.____ _ _ _ _ . _ . - - ._ . _ _ . . _ . _ .___..____..m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - . _ _ . _ _ _ _ . _ _ . _ . y - - , ,=i[Y" Subcontention 10(F)
- 10. Contrary to Criterion;X, " Inspection," of 10 C. F. R. -
~ Part 50, Appendix E, Commonwealth Edison Company has failed to ensure that ai program for . inspection of activities affecting quality was established and exe - cuted by or-for the organization performing the activ-ity to verify conformance-with the documented instruc-tions, 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' mounting of the junction box. Anchors were accepted. even though they were 3" from the required location specified by S&L drawing 20E-1-3571. Facts In Dispute Edison and its electrical contractor L.lG Comstock' failed - to assure that inspections for activities affecting quality ~were-adequately executed where electrical junction box anchors were documented as acceptable even though they were three inches f rom' the specified location. Corrective action is not demonstrably effective where the cause of this gross inspection error is not iden ti fied . An L.K. Comstock quality control inspector-inspected and accepted the anchors for-electrical junction box even though.they were three inches off the specified location. In addition, in the same inspection the CC inspector failed to verify and document the installation torques for the function box cap screws.1 (Gieseker, Affidavit, pp. 2-4.) . The corrective acticn for'this wholly unexplained gross inspection . error is simply to inspect the six remaining junction boxes-previously. inspected by-1 i
- ,6 this inspector.- Having found'no other similar deficiencies,.
Edison embraces ' the desired conclusion that this, is merely an , i isolated case. (Gieseker Af fidavit, p. 4.) In absence of.any , evidence explaining the cause of such a gross inspection error, there is simply no basis for assuming its isolated character or limiting corrective action to that same inspector's work. Thousands of electrical junction boxes are installed and j inspected by Comstock. (Gieseker Dep. Tr. 206.) -What confidence exists that others, yet unidentified, reflect similar gross inspection discrepancies? Such an issue cannot be simply ^ resolved on summary disposition. 1 i a i i I l 1 2 I' i ' l Subcontention 12(E)
- 12. Contrary to Criterion XVI, " 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, m alf unc t ions , 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.
E. Although BCAP had identified that Le"el I OC inspectors had inspected and accepted construction activities, this nonconforming condition was not documented as a BCAP observation. (Inspection Peport 85-06, Exh. 11. ) Facts In Dispute Edison and its Braidwood Construction Assessment Program (BCAP) have failed to assure that conditions adverse to cuality are promptly identified and corrected where the improper practice of employing unqualified Level I Quality Control (OC) inspectors for the performance and acceptance of visual weld inspections was not documented as a BCAP observation until af ter the NPC identified the problem. Edison's Braidwood Construction Assessment Program (BCAP) . has been presented to the NPC and the public as a comprehensive assessment of the quality of construction of the Braidwood facility. BCAP's sorry performance in steadfastly refusing to acknowledge the serious programmatic OA deficiencies represented by the practice of utilizing Level I OC inspectors to per form the visual inspection of welds casts serious doubt on the integrity and reliability of the BCAP effort. Only after the NPC BCAP 1 ,, i .- .t inspector Fon Gardner had identified his dissatisfaction wish S BCAP's failure to document the Level I concern as an' observation , - af ter having previously committed to do so~ - did the BCAP ,- j director, Dr. Kaushal, finally adopt the prudent course of initiating an observation to~ placate the NPC. (Orlov Deposition, Tr. 156-60 7 Far from demonstrating a' conservative, cautious approach to a significant ouestion implicating quality and safety of construction, BCAP's treatment of the Level I OC in s,pec to r, at , issue evidences. a false and overly technical defense of a flawed inspection practice. , 'h , Even the observation itself, once issued anter the NR,C inspector pressed tNe, issue, fails to take any position on the question at all an'd simply fgames the observation as a series of questions concerning the Level I practice. + The timing and content of this observation clearly' reflect BCAP management < 1 positions since initiated at the direction of Dr. Kaushal and written by-Deputy BCAP Director George Orlov. (Orlov Deposition Fxhibit No. 3, Exhibit A attached; Orlov Deposition Tr. 160.) Of course, Edison continua <1 to assert the propriety of use of Level I OC inspectors. In its May.6, 1985 responte to'the items of noncompliance identified by Mr. Gardner (Orlov T ) A f fidav'i t, Orlov Exhibit B), Edison disputes the item of noncom-1 pliance about the use of Level I.OC inspectd>rs while noting that revised procedures limiting weld inspections to Level II or III inspectors " lead to an enhaaced inspection prog ram."g.- Edison claims "further confirmation of-~ the cuality of the installed . i hardware, including welds by the electrical contractqr, is i l 2 l / provided by BCAP and other reinspection /overinspection programs already in progress at Br a id wood. " Id. Edison, of course, dis-puted the item of noncompliance regarding the lack of a BCAP. ' observation on the Level I issue, relying on its action taken af ter Mr. Gardner pressed the matter. As for the " formal" processing of this BCAP observation, it might as well have not been written. Although he has no knowledge of a unique evaluation by Sargent & Lundy of the BCAP Level I observation (Orlov Tr. 164), Mr. Orlov believes that S&L determined that this issue was to be treated like other document review observations and " determined that it is impossible to review for design significance." (Orlov Tr. 163.) The BCAP processing of this serious matter, thus, even af ter the issue was forced by the NRC, simply led to a dead end. Contention subpart 12(E) must be considered together with subpart 3(C) which raises the substance of the improper use of Level I OC inspectors. The failure by the BCAP program to identify and correct the. Level I problem in a timely and effective manner evidences serious weaknesses in that program and undermines its results. 3 ^ , ' lYi $1 I ITEg 1 E, 'E I f8 .p s) C. '( * ]$Y2 ' O ). < flt hal ' s BGP 03SNATION MrctvrD $ Page 1 of 3
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l During ths developanent of CSR checklists and instructions for the review of electrical documentation, it was observed that it was general practice (prior to 6/30/84) within L.K. Comstock to use Lovel I inspectors to perform and doctant the performance of inspections. These inspections by Level I inspectors were performed in conjunction with a review and concurrence cignattire by a Level II inspector on the inspection record.
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Ex wple: L.K. Cor:ustock Procedure 4.0.3 Rev. P specifies Level I or Level II I certificc innpoctors to perforn the visual inspection of welds (ref. Paragraph 3.21) an.t reequires a Lovel II inupector to review the inspection record.
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b iR concern: Do C(.mtock Pr eceduras 4.1.3. 4.13.1, and 4.8.3, in allowing Level I k# -
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- ,u bj ec t to revlow of the in2pection results by a Lovel II inspector, n.tequately address the regulatory requirements established by the Braidwood e'- ([ ,
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'r Subcontention 12(J) ;
- 12. Contrarysto Critorion.XVI, " Corrective Action," of :10f
- C.F.R. Part-50, Appendix.D,: Commonwealth Edison .CompanyL has failed to ensure-that measures were-established to assureLthat conditions ~ adverse'to quality,Leuch 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 11s determined and corrective. action taken'to preclude repetition.
'l J. In two areas,-supports / restraints and piping' runs,.
deficiencies.were identified by the NBC' CAT that.were not identified by the:BCAP inspectors.- On the basis of' the limited sample overinspected, it appears that BCAP inspection effort needs-to be improved =in areas' of "
supports / restraints and piping runs.
Facts In Dispute Edison and its Braidwood Construction Assessment Program.
(BCAP) have failed to assure that conditions adverse'to quality are identified and corrected in a timely mar.ner where the-ef fectiveness of Construction Sampling Peinspections~ are indeterminate because of such factors .as sloppiness and going 'too.
fast due to cost and schedule pressute,' the relaxation of inspection acceptance criteria, and the improper ' invalidation of adverse inspection results.
The Construction Sampling Reinspections (CSR) are at the' core of the Braidwood Construction Assessment Program .(BCAP).
effort to assess and establish the quality.of' construction at B ra id wood. Serious guestions exist'as to the effectiveness of the CSR inspection effort. Such questions include questions as 7
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-w y to the adequacy ~and effectiveness-of the reinspections themselves-as raised by NPC CAT inspectors and others;1cuestions also exist as to'the-relaxation of inspection acceptance criteria and the improper invalidation of adverse inspection results.
Intervenors' review and evaluation of the BCAP CSR inspection evidence is only now underway. BCAP CSR documents have only;been available for a short period of time. In sum, the evaluation of the ef fectiveness .of the construction sampling reinspection-element of BCAP must take into account a range of criticisms and a fully developed record.
Additional questions have been raised about the effectiveness of the CSP reinspections themselves. In inspection report 85-02 of February 13, 1985, NFC inspectors identified "a concern that BCAP reinspections were not adeguately identifying construction deficiencies," a concern which was " reinforced" by the CAT findings which were cited in this contention subport.
The NRC inspector continues by noting that the BCAP Director met with him "to discuss the need for significant actions to address the issue of BCAP reinspection deficiencies." At page 7 of his summary disposition af fidavit, Dr. Kaushal, the BCAP. Director, acknowledges inspection errors identified by the IEOG in-the areas of concrete placements and electrical hangers. -As a result of the "mid-point look" initiated in January, 1985, BCAP identified changes "to enhance the quality of reinspection checklists and instructions and also the inspectors' understanding of these checklists and instructions. Action plans were also identified for reverification of previously 2
- t. ___1____________________
.i completed inspections in the area of piping'and electrical hangers / supports. ' Inspections in the areas of concrete placement ~in the electrical and piping hangers / supports were placed on hold pending completion of-the identified actions."
i BCAP Progress Report,' February 26, 1985, Exhibit A hereto. The NPC BCAP' inspector,.Pon Gardner,-. attributed these deficiencies "to going too fast" (Gardner Deposition Tr. 158). "It.was slop-piness as much as ~a nyth i ng." (Gardner Tr. 159.) Dr. Kaushal acknowledges that the type of inspector errors identified in the CAT report "are not uncommon especially in the early parts of a 1 p r og r a m ." (Kaushal Affidavit, p. 10.) As Edison's-affiant Mr.
Smith acknowledges, "[I]n the beginning this project was esti-mated for completion by December 1984 which is when the BCAP Task i
Force inspections were getting started in a meaningful way. The BCAP Task Force inspectors were aware of this schedule." (Smith Affidavit, p. 2 2. ) Concerns about cost and schedule pressure from management and the sacrifice of quality for quantity in inspection work have been voiced by many Braidwood site quality control inspectors. (See, OC' Inspector liarassment and Intimida-tion Contention and incorporated referenced documents.) The independence of the BCAP inspectors from cost and schedule considerations, as required by 10 CPR Part 50, Appendix B, is.in auestion.- Dr. Kaushal places the issue of the effectiveness of i
BCAP inspections in an appropriate perspective when he states:
"My basis for the confidence in the adecuacy of the BCAP Task Force inspections stems from the manner in which the totality of the BCAP was i m pl em en ted." (Kaushal Affidavit, p. 10.)' This r
3
issue, indeed, must be judged in the contex t -of an evaluation -of .
'the full BCAP.
'Even from' the limited opportunity for review of BCAP files several troubling questions arise.
First, BCAP guality' assurance
- raises the question about the. appropriateness of relaxing inspection acceptance criteria through utilizing non-current.
3 revisions of procedures. The final resolution of March- 25,.1985, by Mr. Orlov appears to endorse.just such a result. There he approves " relaxation of design-requirements when an attribute is already deemed design significant." AIR No. 009, attached as Exhibit B.
Other issues are raised by the internal invalidation of BCAP.
CSR inspection observations. How widespread this practice ~was is unknown, as are also the ef fects of such .a practice on inspector morale and inspector willingness to ' test disputed inspection decisions. For example, an instance came to light in discovery, more or less at random, where a BCAP inspector " declined acknowledgement of the observation's invalidity." He was summarily reversed by a committee of BCAP management "for- the reasons stated in Part 3 of the- observation form." No further explanation. BCAP Memo #3368 with attachment 2?bkxhibit C. hereto.
How many such instances have occurred and what their effects are ;
.1 on the CSR program remain to be established. H l
l Finally, as should come as no surprise to the parties or the q Board, the BCAP program has been developed and implemented in anticipation'of this licensing proceeding. It should not be understood as simply a neutral, objective engineering evaluation 4
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~o f the safety of the Braidwood facility. Its final product, the.
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~ BCAP Peport, as well .as presumably other significant aspects of
' the program's implementation are 'the product not sinoply of engineering decisions but also of Edison management decisions' and
! of decisions by Applicant's counsel. A September 18, 1985 BCAP memo to management and counsel from Dr. Kaushal noticing a meeting for counsel's offices to " discuss and resolve questions
- regarding overall approach to the BCAP report," exemplifies this l reality. BCAP Memo #3409, Exhibit D.
Edison itself makes clear that the overall results of BCAP will be relied upon in this proceeding address the questions by the NFC and Intervenors regarding past quality assurance failures:
CECO presently intends to rely upon the fact that, the BCAP was pe,r formed, and that the BCAP was performed subject to quality assurance oversight in responding to Contention Item 1.B. These facts will be used as evidence of Ceco management's involvement in and support of the CECO OA program and as evidence of management's commitment to-ensure-that all safety-related activities performed by contractors' personnel are in accordance with regulations, codes, standards, and license requirements.
l l Applicant's Second Partial Pesponse to Intervenors' Second Set of Interrogatories and Pequests To Produce, November 22, 1985,
! Specific Interrogatory #7, Pesolution of Contention subpart 12 (J) will. depend upon a full evaluation of the BCAP program.
Summary disposition is inappropriate to resolve such an issue and it should be denied.
5
SUBPART 12(J)
EXHIBIT A
> February 26, 1985 BCAP Memo #622 To: T. J. Maiman W. J. Shewski ,
I M. J. Wallace E. E. Fitzpatrick 4
From: N. N. Kaushal subject: Braidwood Construction Assessment-Program J
Progress Report Attached is the Braidwood Construction Assessment Program Progress Report for January 1 through January 31, 1985.
hN. N.M.Kuuld Kaushal BCAP Director j NNK:Irw
] xc: R. N. Gardner, NRC R. L. Byers 1 G. M. Orlov l
H. L. Vener
- N. P. Smith, QA -
J. Hansel, ERC BCAP File QG 69.60.3 QG 69.70.2 /
E0004393 1
0892J ,
BRAIDWOOD STATION BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM
' REPORT PERIOD JANUARY 1 -' JANUARY 31, l985 ,
I. SUMHARY/ STATUS ThisistheseventhmonthlyproghessreportfortheBraidwood Construction Assessment Program (BCAP), covering the period from January i 1 through January 31, 1985.
In the CSR area, the pace of inspections and related evaluations has increased. Advances were made in visuali inspections and document review package preparation and inspection. Visual reinspections for one population, Conduit, were completed and related observations submitted to S&L for evaluation. The RPSR effort was involved with unincorporated Field Change Requests (FCR's) and checklist development for personnel qualification / certification, construction and field coating work requirements. Progress continues on all' active programs in the RSCAP element.
As of January 31, the number of personnel assigned to the BCAP effort has risen to 123. Satisfactory office and clerical support continues to be available to the BCAP work force.
II. SCHEDULE ANALYSIS CSR Activities are generally on schedule. RPSR and RSCAP activities are, i
respectively, six and one week behind schedule for achieving project j interim milestones; however, the scheduled completion of the draft final
- BCAP report is not expected to be impacted.
III. PERSONNEL AND EOUIPMENT STATUS BCAP manpower totaled 123 as of January 31. Five additional inspectors were certified during January. Inspection personnel activities included training, accessibility walkdowns, reinspections, document reviews and supplemental observation detailing (e.g., weld mapping, configuration).
Conversion of observation and verification package tracking from Mapper to the IBM system was initiated. The program and data entry for verification packages has been completed. Initial verification package tracking reports are expected to be generated by the IBM system during the first week in February. The program and data entry for observation 4
tracking is also expected to be completed during the first week in February.
d l
E0004394 0892J j
- . s
. s
_i IV. BCAP ELEMENT STATUS A. CSR STATUS Preparation of inspection packages and performance of inspections continued.-
Forty-nine of 70' checklists and instructions have been prepared. of these, 14 are being used for current inspections of plant hardware and documentation.
Inspection packages are being generated at a rate of about 250 per week. Documentation reviews have begun in Concrete Placements, Conduit, and Small Bore Pipe Configuration.
4 Additionally, during this period, activitied concentrated on 1) defining the three categories of engineering judgment portion of the samples (related to safe shutdown, previously identified deficiencies, and high stress), 2) completing assembly of-inspection packages for populations, 3) developing documentation review have checklists for the group of populations for which inspections begun,
- 4) developing the remaining checklists and instructions and 5) processing observations.
On January 23, based partly on concerns expressed by the NRC resident inspector and partly on BCAP internal assessment, the inspections under the CSR element were temporarily suspended and a
" midpoint look" was initiated,to factor-in the knowledge and ideas resulting from experience-to-date. As a result of this " midpoint look", specific actions were identified to enhance the quality of reinspection checklists and instructions and also the inspectors' understanding of these checklists and instructions. Action plans were also identified for reverification of previously completed inspections in the area of piping and electrical hangers / supports.
Inspections in the areas of concrete placement and electrical and piping hangers / supports were placed on hold pending' completion of-the identified actions. Inspections in other areas were resumed on January 25, 1985.
B. RPSR STATUS During January, the RPSR group Was primarily involved in identifying unincorporated Field Change Requests (FCRs) that affect specifications applicable to the RPSR effort and finalizing checklists that contain construction and personnel qualification / certification requirements. Three unincorporated FCRs were identified. Requirements from these FCRs have been added to checklists. A preliminary review of a sampling of sheets from the 29 checklists involved was conducted. Results of that review have been incorporated in 18 of the checklists. The remaining checklists will be updated in February.
1 1
i E0004395 0892J
.-(
.3 .
- Final review of the checklist for field coating' work began on January 24. Comparison of contractor procedural requirements to that checklist is scheduled,to start on February 4. .The next checklist to-be. reviewed will be for inspection and testing services. Comparison of contractor procedures to this checklist is
, scheduled to be completed in late February.
C. RScAP STATUS In January, the RSCAP Group completed preparation of Commitment Lists, procedure Review Check Lists, Implementation Review Checklists and Documentation Review Checklists for each of the Corrective Action Programs under-RSCAP Review. Field Review of Contractor Implementation and Documentation Reviews were also conducted this month. Several observations have be initiated as a result. BCAP-QA conducted several surveillances of the RSCAP element with no findings.
V. PROBLEMS /DISCREPENCY FINDINGS
- 2 A. Implementation Problems No specific implementation problems were experienced during this period.
B. Discrepancy Findings A total of 1486 observation reports have been written as of January 4
31, 1985. of these, the review for validity has been completed for 1017. Of these, 865 have been determined to be valid discrepancies. Those forwarded to S&L for design significance determination currently number 617.
j As of the end of this report period, S&L has not identified any discrepancy as design significant.
l VI. RECOMMENDATIONS l No specific recommendations are offered at this time.
^
l.
f 4
N.M. Kodd4 N. N. Kaushal i
BCAP Director E0004396 i l I 0892J
m h1 a, y vJ.
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SUBPART 12(J)
EXHIBIT B April 2 1985 BRD #15.459 TO: N. N. Kaushal BCAP Director
SUBJECT:
(AIR #009 BCAP Q.A. accepts your explanations and clarifications of the issues brought forth in AIR H009 and it is _ closed.
/
N. P. Smith General Supervisor Q.A. Braidwood Station NPS/WJM/n1w (0350B) cc: E. E. Fitzpatrick Q. A. File - 71.7 71.12 (H009) k$J$0T$% p i APR - 01985 ' ffd _ 1J B.C. A.P. I100111'J1
March 25, 1983 BCAP Memo 8968 TO: N. P. Smith FROM: G. M. Orlov i
SUBJECT:
AIR-009, Clarification of Additional Information
REFERENCES:
a) QA Memo BRD 815,262 dated March 19, 1985 b) DCAP Memo 8800 Dated March 5, 1985 The following additional information is provided in response to the Reference (a) memo.
- 1. Definitions of terms used in Reference (b):
A. Generic Design Requirements - Requirements regarding construction that apply to more than one item. Examples of such requirements may be those in NRC codes, Architect / Engineer specifications, general drawings not specific to any one item and specific parts of codes or standards that apply to a class of items. B. Item-specific Design Requirements - Those requirements invoked regarding the construction of one particular ites. These include a specific design drawing for a component and all referenced codes, standards, specifications, general drawings, etc. invoked by that drawing. C. Item-Specific. Acceptance Criteria - These are the reinspection or i documentation review checklist acceptance criteria in a package for a specific sample item. They are developed from design requirements, but may be less stringent when it has been determined that the design will allow a relaxation in the construction tolerances. D. Specification Requirements - Those requirements defined in an Architect / Engineer document labeled a " Specification". E. Specification - An Architect / Engineer document labeled as a
" Specification"
- 2. Meaning of the following quote in terms of writing observations:
"If the design requirements have become more stringent subsequent to an item's installation, provisions within BCAP allow for the invalidation of observations that result from application of the more stringent requirements (BCAP prog. Doc. at II-2 and BCAP-06, para. 4.3.3c).
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Neil Smith March 25. 1985
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SCAP does not plan to write observations in the instance where l design-requirements have become more stringent subsequent to an item's installation since this is not within BCAP scope.- CBCo at-Braidwood is expected have other QA programs that are designed to ensure that any more stringent requirements are recognized and that previously completed work is reviewed to determine the possible need for rework. SCAP does not include such provision within its scope, rather ensuring that at least a " snapshot in time" view of the- - construction design-significant quality is taken. This approach recognizes that less stringent requirements indicate the lack of design-significance of those previous requirements. Therefore, where less stringent requirements are known to BCAP,'such t changes are acknowledged by invalidating observations written regarding a failure to meet the old requirements. i 3. Second sentence of Section 3-A, regarding the development of j acceptance criteria, in most cases, from latest design requirements: t Acceptance criteria are, for checklist preparation, developed based I first on consideration of the latest design requirements, however (as explained in the third and fourth sentences of Section 3.A.) , alternate criteria may be used if less stringent, but still i 1 design-significant criteria, can be developed. The words "in most cases" were intended to convey that the final acceptance criteria as used in the checklist may not end up identical to those in the latest drawings and specification requirements.
- 4. Third sentence of Section 3.A regarding relaxation of design-requirements when an attribute is already deemed design-significant:
4
' In the case where an attribute is design-significant, its design-requirements are then examined to determine acceptance criteria for BCAP use as explained in item 3 Above. The subject sentence in Reference (b) is correct as written in that BCAP inspection criteria may be less stringent thart original inspection criteria, as discussed in (1 c. above) yet BCAP results will properly
} indicate design-significant deviations should they exist.
/ tM p.M.Orlov Assistant BCAP Director I
cc: SCAP File QG.69.60.3 QG.69.60.2.6 QG.69.80.2 / N. Kaunhal L. Weiss P. Iau 3,g 1100111'J3 r--.--, . ,.- y -,m, , - ~~,-,-,--,.,.._-,_m -
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~ esngvw*me~-- , y GXn G9,9 0. 9-March 19, 1985 BRD #15,262 TO: N. N. Kaushal G. M. Orlov FROM: N. P. Smith
SUBJECT:
Clarification of Additional Information Regarding AIR-09
REFERENCE:
- 1. AIR-09 dated February 1, 1985
- 2. BCAP Response dated February 21, 1985
- 3. BRD #14,982 dated February 21, 1985
- 4. BCAP Memo #800 dated March 5. 1985 In our review of the additional information that BCAP has provided (dated 3-5-85), we feel that additional information is needed.
We would like you to define several terms used in BCAP Memo #800 (dated 3-5-85). The terms used which we feel need to be defined are as follows: A. Generic Design Requirements B. Item - Specific Design Requirements C. Item - Specific Acceptance Critoria D. Specification Requirements E. Specification What is meant by, "If the design requirements have become more stringent .... but meet the original requirements (BCAP Prag. Doc. at II-2 and BCAP-06, para. 4.3.3c).", in terms of writing observations (i.e. generic or specific observations). i (0320B) m lh
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p @ (,9.9 0. A March 19, 1985 BRD #15.262 TO: N. N. Kaushal G. M. Orlov FROM: N. P. Smith
SUBJECT:
Clarification of Additional Information Regarding AI
REFERENCE:
- 1. AIR-09 dated February 1, 1985
- 2. BCAP Response dated February 21, 1985
- 3. BRD #14,982 dated February 21, 1985
- 4. BCAP Memo H000 dated March 5, 1985 In our review of the additional information that BCAP has provided (dated 3-5-85), we feel that additional information is needed.
We would like you to define several terms used in BCAP Memo #000 (dated 3-5-85). The terms used which we fool need to be defined are as follows: A. Generic Design Requirements B. Item - Specific Design Requirements C. Item - Specific Acceptanca Criteria D. Specification Requirements E. Specification What is meant by, "If the design requirements have become more stringent ..., but meet the original requirements (BCAP Prag. Doc. at II-2 and BCAP-06, para. 4.3.3c).", in terms of writing observations (i.e. generic or specific observations). u-0 (0320B) ' ML 2 i RECD 110011124 ~ w
- 8. C. A. P.
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BRD #15.262 Page 2 Also in BCAP Memo H800 cection 3.A second sentence it states "in most cases", why not in a11 pases? And in the third sentence of section 3.A. how can the cr5teria be relaxed from design-requirements from a design - significance standpoint when the attribute has already been deemed design - significant. Please provide the above information by March 22 1985. N. P., Smith General Supervisor Quality Assurance NPS/ PAL /nlw (0320B) cc: E. E. Fitzpatrick P. A. Lau O. A. File - 71.7 71.12
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March 11, 1985 BRD #15,155 TO: N. N. Kaushal-G. N. Orlov FROM: N. P. Smith
SUBJECT:
Clarification of. Additional Information Regarding AIR-09
REFERENCE:
- 1. AIR-009 dated February 1, 1985
- 2. BCAP Response dated February 21, 1985
- 3. BRD #14,982 dated February 21, 1985
- 4. BCAP Memo #800 dated March 5, 1985 In our review of the additional information that BCAP has provided (dated 3-5-85), we feel that additional clarification is needed. Therefore, we are presenting a few examples, as we interpret the additional information, for your review and approval.
Example 01: A particular population has had several revisions to the field installation (contractor specifications and/or drawings) tolerances which were more restrictive for each revision. Issue Date Length Tolerance A. Original issue (3-2-78) z 4" B. Rev. A (3'-14-79) t 3" C. Rev. B (6-9-82) t 2" D. Rev. C (10-6-83) 1 1" E. Rev. D (11-7-84) 1 1/2" ) In this example a generic observation would be written for all population items not meeting the Rev. D (11-7-84) tolerances, that is those population items constructed to the original issue up to and including Rev. C (10-6-83) would be covered by the generic observation.
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BRD #15.155 Page 2 Example 02: A particular population has had'oeveral revisions to the field installation (contractor; specifications and/or drawings) tolerances which were less restrictive for each revision. Issue Date Length Tolerance A. Original issue (3-2-78) t 1/2" B. Rev. A (3-14-79) i 1" 4 C. Rev. B (6-9-82) 1 2" D. Rev. C (10-6-83) 1 3" E. Rev. D (11-7-84) 14" In this example no generic observations would be written. Example 03: A particular population has had a requirement deleted from the contractor specification or a design drawing: Issue Date Requirement A. Original issue (3-2-78) floor to be Painted purple B. Rev. A (3-14-79) floor to be painted any color C. Rev. B (12-13-84)* floor does not have to be painted In this example no observations of any kind would be written on painting associated with floors. Example 94: A particular population included a population item where the design was changed since the installation of the item but the item had not been reworked. 1 A. Original construction (dated 5-3-82) dimension. 3" x 3" x 14" tube steel. ; B. Redesign as per revised drawing (dated 12-4-84) dimension. 3" x 3" x 18" tube steel. l l
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D BRD.#15,155 Page 3 In this example an observation would be written. then during evaluation it'was found to be constructed as per original design, the observation would be evaluated as an invalid observation. Example 05: A particular population included a population item where the i design was changed after installation of the item and then was reworked after 6-30-84. A. Original construction (dated 5-3-82) dimension,-3" x 3" x 14" tube steel. B. Redesign as per tevised drawing (dated 7-4-84) dimension, , 3 x 3" x 18" tube steel. C. Item reworked on 8-3-84 to meet new redesign. In this example the population item would be deleted and replaced as an invalid sample item. Also, we would like to clarify the fol' lowing terms: A. Generic Design Requirements are those documents which provide a contractor with general guidance in terms of general construction activities which may include the following documents:
- 1. Contractor Specifications
- 2. Design Drawings
- 3. Codes
! 4. Standards
- 5. Contractor Procedures
- 6. Other generic (type) documents B. Item - Specific Design Requirements are those documents which provide a contractor with specific guidance in terma of construction of a specific population item which may include the following documents:
i- 1. Detailed Design Drawings 1
- 2. A specific paragraph or sub-paragraph of a specific code (0298B) H001112
BRD #15,155 Page 4
- 3. A specific paragraph or sub-paragraph of a specific standard
- 4. A specific requirement from a contractor procedure Please provide your concurrence to the above examples by approving this document below by March 15. 1905.
'l N. P. Smith '
General Supervisor Quality Assurance Reviewed by: G. M. Orlov Assistant Director BCAP i Approved by:
.N. N. Kaushal DCAP Director NPS/ PAL /nlw (0296B)
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cc: E. E. Fitzpatrick P. A. Lau Q. A. File - 71.12 71.7 Il0011129
s . 4 . March 5~,c1985 BCAP Memo 0800 TO: N. P.-Smith $ FROM: 'G. M. Orlov
SUBJECT:
. Additional Information Regarding AIR-009 PEFERENCE: BRD #14,982 dated February 25, 1985 i
The attached provides:information you requested in the reference regarding the basis for the CSR. element using , design requirements applicable after. June 30, 1984,.to review construction work completed as of that date. Your consideration of the closure of AIR-009 based on this additional information will be apprec,iated. I G M. Orlov Assistant DCAP Director i 4 GMO/LSW/sjs Attachment
.cc: N. N. Kaushal ,
, BCAP File QG 69.60.3 QG.69.60.2.6 yQG 69.80.2 i i i > E 1 110011130 i
- _ . __ _ ._.. __ __ . ~ . _ _ _ _ _ _ ~ __. ___, -__
o . Attachment ; l BCAP-CSR Element Application of Latest Design Requirements to Previously-Completed Work ~ The BCAP Program Document provides, in the CSR element, a framework for the verification of construction work completed and Q.C. accepted prior to 6/30/84. The CSR verification consists of inspections and documentation reviews performed using the _ latest approved design requirements. The appropriateness of using " latest" approved design requirements to perform inspections or doctanentation reviews for items completed prior to 6/30/84 is discussed in this doctament. The presentation that follows describes: (1) the construction work subject to review; (2) how design requirements are applied in developing inspection criteria; (3) which design documents, applicable at what time, are used in each stage of this criteria development; and (4) how the application of the
" latest" design requirements to "previously completed" work is appropriate in the context of the BCAP. The consistency of the logic presented with both the BCAP Program Doctament and CSR implementing procedttres is demonstrated by detailed references where appropriate.
- 1. Construction Subject to Review Those safety-related " items" which were completed, Q.C. inspected and accepted prior to 6/30/84 are subject to the inspections and doctamentation reviews in the CSR element'(BCAP Prog. Doc. at 11-1 and BCAP-20 para. 4.3).
- 2. Design Requirement Applicability The verification of design-significant attributes is performed against the latest approved design drawings and specification rkquirements. (SCAP Prog. Doc. at 11-2). The following discusses the acceptability of using the latest design requirements which, in some cases, may not have been applicable to the item at the time of its construction. The various uses of design requirements in the several stages of verification criteria 110011131 (1012J)
i selection are also discussed. The following discussion also explains why generic design requirements may be used for determining checklist attributes for reinspection or documentation review, while other item-specific design requirements may be used in preparing item-specific acceptance criteria. A. Checklist Attributes (Use of Generic Design Requirements) t Attributes for reinspection or for documentat on review are identified-byreviewingthelatestdesigndrawings, specifications,andother documents which are ap'plicable at the time of the population checklist / instruction preparation (BCAP-22, para. 4.1.1 and 2). Considering the BCAP work schedule, the applicability date for these design doctaments will be 6/30/84 or later. Those attributes considered design significant are identified from these doctseents (BCAP-22, para 4.1.3). For the purposes of BCAP CSR verifications, the use of design requirements in existence on or after 6/30/84 is acceptable. . Generic i design requirements for any given item within the scope of CSR may have been eliminated, relaxed, or made more stringent subsequent to , that item's installation date. If a requiremenk has been eliminated, theoriginalrequirementbyitselfcouldnothahebeendesign significant. Anyrelaxationinthedesignrequkrementsisacceptable ! inthatthenewrequirementwillautomaticallykilowacceptanceofthe existing installation. Hence, compliance in these cases need not be ' verified by BCAP. If the design requirements have become more stringent subsequent to an item's installation, provisions within BCAP allow for the invalidation of observations that result from , application of the more stringent requirement, but meet the original requirements (BCAP Prog. Doc. at II-2 and BCAP-06, para. 4.3.3c). Hence, the BCAP results are not affected by the use of any design requirements effective on or after 6/30/84. ! 110011132 (1012J)
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t 4 B. Package Preparation (Use of Item-Specific Design Requirements) , The latest design drawings applicable to the item, as available at the time of package preparation, are required to be included in the package by BCAP procedure (BCAP-23, para 4.2.2g). However, any i drawings applicable on or after 6/30/84 would be satisfactory for BCAP purposes. i Since the item was final O.C. accepted prior to 6/30/84, the current revision of the drawing should reflect the existing installation of the item. If the item design has changed since the item's i installation and the item has not been reworked, an observation is ' generated and subsequently invalidated based on the item's 4 acceptability at the time of installation (BCAP Prog. Doc. at II-2 and
- BCAP-06 para. 4.3.3c). If the item design had changed and the item had been reworked after 6/30/84, then the item would be considered to j
have been erroneously included in the population and no longer subject i to CSR review. i j 3. Methods of Verification and Acceptance criteria i 4
+
A. Reinspection Foreachdesign-significantattributethatisAccessibleand recreatable, a method of verification is developed and incorporated ( into the checklist instruction. Acceptance criteria are, in most cases, developed from the latest design drawings and specification requirements. However, inspection criteria may be relaxed from design requirements where the original inspection criteria are overly restrictive from a design-significance standpoint [BCAp-22 para 4.4.1, 4.4.2 (a,b)]. These alternate inspection criteria are reviewed by the i Architect / Engineer (BCAP-22, para. 4.6.5 and letter N.N. Kaushal to D. Fischer 9/10/84). i, 110011133 ! (1012J)
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y ,, y 8 n , x B. Documentation Review ' p Each design-significant attribute which is required to\be do tanented to support the hardware installation is identifie4 by latest
- specification, code, standard, or regulatory requirements at the time of instruction preparation. The detailed methods of verification are
! based on contractors' procedures in effect at the time of installation, if these procedures s% sept or exceed the specification, 5
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code, standard, or regulatory requirements. If these procedures dd< '1 not meet or exceed t'his requirement, a generic observation is , generate'l by the CSR Engineering Section for the particular attributes t which are potentially inadequately addressed by the contractors'
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procedures. ' q 4.\ Conclusion g , x e ( The application of the latest design requirements to the verification of 1 previously completed work, as currently performed in the BCAP CSR ' verification, is appropriate and correct. This conclusion is supported by
,the equivalence in the results of CSR when the latest design, the design applicable at the time of construction, or the design as of 6/30/84, is applied to an item. The 6/30/84 date merely determines the scope of previously comple'ted work included within the CSR review.
m k Refererced procedures: BCAP-06 Revision 7 n ! BCAP-20 Revistor 2 ( " I BCAP-22 Revision 1 i BCAP-23 Revision 1 ' J 110011134 I i 4 (1012J)
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y . . 's (, : February 25. 1985 BRD #14.982 TO: N. N. Kaushal FROM: N. P. Smith RE: AIR-009 In reference to your response to the above AIR. We understand your response to Item 1. however, provide to Quality Assurance the source document used to determine the accept / reject criteria for qualifications of Electrical Inspectors if Comstock Procedure 4.8.3 was not used. Since Item 2 in the " Description of Action Requested" of AIR-009 was not responded to. we will rephrase the question so that you can more fully understand the issue and provide the basis for the question. The BCAP program document discusses construction Sample Reinspection in terms of items which were consttIcted and inspected prior to June 30. 1984. Therefore, the use of design documents commitments. dated after June 30, 1984 seems to be outside the program The rephrasing of the question (Item 2) is as follows: We would like you to justify the basis for your CSR engineers not using the specifications, drawings, and other design documents which were in effect as of June 30, 1984. Please respond to.this request by 4:00 P.M. on February 28. 1985. N. P. Smith General Supervisor Q.A. Braidwood Station NPS/ PAL /mjv (0270B) cc: E. E. Fitzpatrick k@hhh P. A. Lau ! o
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u . r IMSPONSE TO DCAP Q.A. AIR #-009 verification in accordance with Para. 4.1.2 and 4.1.3 o Refer and to the memo written as required by Para 4.3.2 f instruction. However, in the development of instructions on.the detailed methods of verification Procedure 4.8.3of certain attributes identified.in CSR-R-G-ELE, Comstock was utilized. utilized in developing the methods of verification. Revision F and earlier revisions utilized because it was not Revision G was not in effect at the time of checklist prep 3 ration, the preparer which began on January 2, 1985.in November 1984 and was completed and signed NOTE: Paragraph 4.1.2 of BCAP-22, Rev. 1 is the applicable paragraph. Neither para. 4.1.1 of BCAP-22 nor para. 4.1.2.G of BCAP 23 Rev. 1, which both identify the requirement for the selection of design drawings for attribute selection and package contents, respectively, are applicable to the use of contractor procedures in the development of checklists and instructions. 4 ggy 0987J 110011137 g ql- -_
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4 f RESPONSE TO BCAP Q.A. AIR 8-009 1 i Comstock procedure 4.8.3 was Do.1 used as a source of attributes requiring verification in accordance with Para. 4.1.2 and 4.1.3 of Procedure BCAP-22, Rev. 1 in the development of CSR-R-G-ELE checklist and instruction. ! Refer to the memo written as required by Para 4.3.2 for this checklist and instruction. . However, in the development of instructions on the detailed methods of. verification of certain attributes identified in CSR-R-G-ELE, Comstock 1 Procedure 4.8.3 was utilized. Revision F and earlier revisions were
; utilized in developing the methods of verification. Revision G was not 1
utilized because it was not in effect at the time of checklist preparation, which began in November 1984 and was completed and signed by '
- the preparer on January 2, 1985. -
, NOTE: Paragraph 4.1.2ofBCAP-22,Rev.1istbeapplicable i paragraph. Neither para. 4.1.1 of BCAP-22 nor para. 4.1.2.0 of BCAP 23 Rev. 1, which both identify the requirement for the selection of design drawings for attribute selection and package' contents, respectively, are applicable to the use of contractor procedures in the development of checklists and instructions. l l 4 i i 4%Y 0987J 110011139 '
G February'15, 1985
.BCAP Memo 8686
( i 'I TO: N. P. Smith, Q.A. FROM: G. M. Orlov An extension is requested for the response due dates for l' AIR 8 and 9. A response will be provided by 2-22-85.
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. M. Orlov i GMO/sjs d
cc: BCAP File QG 69.60.3 , QG 69.60.2.6 , QG-69780--ib O . , q a i 110011110
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, /p6 49 pd V Q 6. 4 9 M./. G d,,9 g 96 u February 8, 1985 BRD #14,819 TO: ,
N. Kaushal BCAP Director
SUBJECT:
AIRS-008/Ob9) , The subject AIRS were issued and hand delivered on Friday, February 1, 1985. Responses were requested by February 5 and 6, 1985 respectively and are currently overdue. Please advise when they will,be returned. N. P. Smith General Supervisor Q.A. NPS/WMS/nlw (0254B) cc: M. J. Wallace E. E. Fitzpatrick O. A. File - 71.12 (008/009) 71.7 (Chrono file)
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BLOCK ORG. PERSON WHAT/WHEN/WHERE/HOW (AS APPLICABLE) (1)-(12) BCAP Q.A. Originator (see-QASI-17.) (13) Responsible Engineer Describe the action taken or planned to resolve action Organization requested by Q.A. (14) Insert date the action completed or planned to be completed. (15) Supvr. After review of (8) through (14), indicate approval of response by signing and inserting date. (16)-(18) BCAP Q.A. Q.A. Person (see QASI-17.) cen. Supvr. s i 4 110011143 t
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- SUBPART 12(J)
EXHIBIT C September 12, 1985 BCAP Memo 83368 To: N.N. Kaushal From: G.M. Orlov/T.J. Ryan/D.J.!Patel/ J.P Stevens
Subject:
Invalidation of Observation The observacion. CSR-I-E-EIN-078-902, was evaluated as invalid by the electrical CSR engineers for the reasons as stated in Part 3 of the observation form. A copy of the observation and ,the applicable drawing references are attached. The Level II inspector who wrote the observation has declined acknowledgment of the observation's invalidity. Therefore, as required by BCAP-06, Section 4.4.5, a comunittee consisting of Mr. G.M. Orlov, Mr. T.J. Ryan, Mr. D.J. Patel, and Mr. J.P. Stevens discussed the disposition of the observation and recommended that you or your designee sign the observation acknowledging the invalidity. G.M. Orlov Assistant Director Appd. & M d"# - " 6 h ~w d e A W k , Technical Assistant cd,(Al Cd bh Vd N .(N Kwdd G4 N' ti((([fd' D.J. Pate1 CSR - Lead Electrical Engineer J; . Stevense GdRElectr(4 cc: BCAP File QG 69.20.19 QG 69.30.1 QG 69.60.3 g69.81.5 (2012J)
!!0011G05
, , ~ , - - -
BCAP OBSERVATION RECORD IO.A.I
- 1. Observation No. CSR _I -E -EIN - OJ - 907 PART 1 OBSERVATION IDENTIFICATION & DESCRIPTION
- 2. DESCRIPTION OF ITEM (Equipment, Material Component, Procedure) 3. Package No.
1761857A 3 JuMC.TtON TSoy: cm .r-E- E I M - O'78,
- 4. SYSTEM (If known): N/A , 5. CheckIist/ Item No.
- 6. UNIT 1 WW UNIT 2 h l COMMON O N b I E 6-o.e s
- 7. ELEMENT 8. OBSERVED DURING:
CSR h hRPSR RSCAP h h Doctanentation W Reinspection Review
- 9. DESCRIPTION OF OBSERVATION:
THE CONMECT\DM DETAll ; 'CNE.% 2DE'-O-33G3Oo3. rev.'O.
'OE'TA1L. D SPECIFtES AM *ECW cos NECTtOM TO AM EMBEODEC PLAT E. AT THE FLODR [EL.4M) . OCa. *2OE-O-339'5R rev.T; DETAt t FOR 'TTPE.
- E C 5'$ SHOWS THE A'TTACRMENT ELEVATtON A5 *CE) LING" ONLY , l His OE. TAIL 15 NOT INTER tRANGE ASLE AMD i-S N EREFORE LAM ACC EPTABLE .
6-r3 f Signature Date PART 2 OBSERVATION CLARITY, COMPLETENESS, AND ACCURACY REVIEV
- 11. COMMENTS /CLARIPICATION:
jC//j) 'TL44' 4 /V EC ' j
- 12. SUITABLE FOR FURTHER PROCESSING: R IEVED BY:
YES' ) M /-//-J l
. . dignature Date uO I I ll0011606 l
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BCAP OBSERVATION RECORD Page 2 of 3
- 15. OBSERVATION NO. O S - 1 b ENO ON PART 3 EVALUATION & Dt,Tr.xMINATION OP VALIDITY
- 16. EVALUATION 1*l. DETERMINATION OF VALIDITY:
N INVALID l l SCOPE
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- 20. ARCHITECI/ ENGINEER EVALUATION
- 18. EVALUATION & DETERMINATION REQUIRED: l l YES l l No Ne Signature 6-2 0if
- 19. A BY: Date
- 21. REVIEVED BY: 22. APPROVED BY:
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e SUBPART 12(J) EXHIBIT D September 18, 1985 BCAP Memo #3409 TO: Tom Maiman Mike Wallace Lou Del George Gene Fitzpatrick Mike Miller Phil Steptoe Ken Kostal George Orlov Bob Byers FROM: Ninu Kaushal
SUBJECT:
Overall Approach to the BCAP Report You are requested to participate in a meeting, on Thursday, September 26, 1985, starting at 11:00 A.M., at IL&B offices. The purpose of the meeting is to discuss and resolve questions-regarding overall approach to the BCAP Report. A copy of the latest draft of the report will be provided to you by Friday, September 20, 1985. V h, N. N. Kaushal BCAP Director NNK/jan cc: BCAP File QG 69.60.3 v0G 69.81.5 QG 69.60.2.4, 2.5, 2.6 110011604
7_ s 'h ' ' l Subcontention 13(B) l
~
- 13. Contrary'to Criter' ion XVII, " Quality Assurance; Reco rd s ," of 10 C.F.R. Part~50, AppendixLB, common- ,
- wealth Edison Company has failed to ensure that suffi-L cient records were maintained to. furnish evidence of' activities affecting quality. The records are1to include at least the following
- results of reviews, inspections,. tests, audits, monitoring of work perfor-mance, and materials analyses. Applicant has failed to make such records identifiable and retrievable.
B. S&rgent & Lundy Engineers ~ calculations .which provided I the original justification for the factor design l-methodology and magnitude were not retrievable. (Inspection Report 84-43/39, Exh. 19.) i Facts In Dispute l Sargent & Lundy employed a simplified calculational derating factor - a phi (4) factor - in sizing pipe hangers. S&L was i L unabletojustifytheuseofthehfactor in certain. bounding cases due to irretrievable, incomplete and inadeguate calculations. While these bounding cases were ultimately l specified through criteria revision and detailed individual calculations were performed to justify hangers outside:the bounding cases, S&L failed to adequately address the root cause of these deficiencies. This matter was identified not in the course of a " routine review" of S&L's design documentation by NRC as Mr. Kostal of S&L would have us believe (Kostal Affidavit, p. 3), butLin' response to allegations raised in the Byron; licensing proceeding by i
-engineer Charles Stokes. (Kostal-Deposition Tr. 119.) The item.
1 of noncompliance is identified and the circumstances of identification are described.in Inspection Report 84-43/J9 for
~
l t-
.e Eb-Braidwood, - and the companion report for the Byron facility of March 14, 1985. According to the NRC, "S&L maintained that calculations demonstrating the acceptability of the phi factor methodology had been completed prior to October 5,1981; however, S&L was unable to retrieve these calculations. Other calculations justifying the use of the phi factor methodology completed as part of a March,-1982, internal S&L study were retrieved. These calculations were not approved for use until April, 1984. The NRC review determined that those-calculations were incomplete and inadequate "to demonstrate the acceptability of the phi factor methodology as it was being used." (16.) Further ef forts to provide calculational justification for the phi factor methodology were judged by the NRC " incomplete to demonstrate the consorvatism of the phi factor methodology in all potential configurations." Detailed, exact, individual calculations were required to justify configurations falling outside the bounding cases. Id. The NRC was critical of Sargent
& Lundy's efforts to just.ify the phi factor methodology:
Several statements in t.he licensee's responses appear to be incorrect and required considerable discussion for the licensee to explain the intent of the statements. Satisfactory explanations were given for all but one of the statements. The one incorrect statement had no technical significance, and related to coreponent support hardware weight. Id. In response to the NRC findings, Sargent & Lundy's corrective action included revisions to its Structural Standard Document (SSD) which acknowledged explicitly the bounding cases l applicable to its phi factor methodology, which cases had not 2 1 1 j
A been previously explicit. (Kostal Tr. 135-38.) For example, in the revised SSD the following bounding case is identified: '"the ffactor is only applicable for spans greater than or equal to 5'-0". ' Shorter spans require a detailed analysis." (Kostal Deposition Exhibit No. 6, Exhibit A hereto.) Evidence on the root cause of~these deficiencies and
~
therefore the effectiveness of S&L's corrective action is, indeed, sketchy. M r. Kostal relies on the knowledge of a Mr. Tom Longlais, who directed a search for the missing calculation book. (Kostal Tr. 14 5.) . The original book was never found; nor was it determined when the document was last retrievable. It may have be'en missing for as long as five years, to the best of Mr. Kostal's knowledge. (Kostal Tr. 145.) In addition to the issue of lack of retrievability, this incident also raises questions concerning the completeness and adequacy of S&L's calculational methodology. Edison presents no explanation for the failure to identify bounding cases in the S&L standards which provided for use of the phi factor methodology. The materiality of.such an omission is established by its inclusion in the revised SSD. (Exhibit A hereto.) S&L's design control as well as design document corttrol practices are called into question by the circumstances reflected in contention item 13(B). The.signifi-cance of such discrepancies and their implications for. 0A at Braidwood should be evaluated in the context of a full record in this proceeding. Summary disposition is inappropriate and should be denied. 3
[> SUBPART 13(B): EXHIBIT A ( $TRUCTURAL norrr1cnTim or SARGENT &LUNDY ru:v1SION To SsD ( STANDARD se.o esa.- !
~ ^ - NORDS-32 dr DOCUMENT ;
3 F I L 0: th, The following paragraph will be added to Sections 37.6.3.G.S . L. and 37.6.3.G.6: .h
" Simplified analysis and the use of the p factor is I f'i;. l applicable for structural tube sections and for wide flange sections with a nominal depth less than or equal '%,,
to 18 inches, a weight less than or equal to 60 pounds f s 3 per foot and a ratio of major axis to minor axis section 1j modulii less than or equal to 10. A detailed analysis is . i required for al1 other sections not included above." 't o The following paragraph will be added to Section 37.6.3.G.7: ,,, 3 h h " Simplified analysis and the use of the p f actor is applicable
~ nI'(
for all angle sections and for wide flange sections with a f;\ nominal depth less th an or equal to 18 inches, a weight less ,t i than or equal to 60 pounds per foot and a ratio of major , h axis to minor axis section modulii less than or equal to 10. ( A detailed analysis is required for all other sections not included above." y]
'[ ,
V h g, The description at the beginninq of S<'e t i on 37.6. 3.G. 5 will be i revised to read: 1 9 y " Cantilevered wide flange and structural tube section a b ra cke ts (knee braces):" h, The description at the beqinninq of Section 37.6.3.G.6 will be b revised to read: F L " Wide flange and structural tube section trapezc type frame 4 assemblies:"
't y, The description at the beginning of Section 37.6. 3.G. 7 will be revised to read:
1 1 A " Wide flange or single angle sections without mechanical component hardware , e.g., seismic restraint. or clamped l pipes (see Figures 37.6.3-1A and 37.6. 3-1D) :" i y 1 (
)
h - b Y i Page 2 of 2
.. u . .
(p. no. 6 [
" STRUCTURAL NOTIFICATION OF 1
STANDARD SARGENT MUNDY REVISION To 550
.. . .. .. h.>
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DOCUMENT tR ltr!EATION NUMBEP NonDS- 32 DATE December 26, 1984 3 UlU
,e I
t'CTURAL DEPARTMENT STANDARDS SECTION NUMBER SDS-E37, " Mechanical Component i,2xiliary Support Steel Framing" I( f. p j ; FEVISED AS f 0Lt.0WS. PLEASE TAKE THE FOLLOWING ACTION: b INSERT THIS NOTIFICATION INTO YOUR COPY OF THE STANDARDS COOK IMMEDIATELY
.I I r.{
F FRECEDING THE DOCUMENT BEING REVISED. l *{1 i I DO NOT REM 3VE THE PREVIOUS ISSUE Of THE DOCUMENT FROM THE STANDARDS BOOK t- [ UNLES5 SPECif! CALL Y IN5!RUCTED TO DO S0 IN THE DESCRIPTION OF THE REVISION BELOW. :fm b W l' p h,5(RIPT10N OF REVISION: i t, The following sentence will be added to the first paragraph of Section 37.6.3: , tr j "This simplified analysis procedure is only applicable if g 3 the applied piping load from each load case is less than , 20 kips." i 1 2 The f ollowing paragraph will be added to Sections 37.6.3.G.1, f, 37.6.3.G.2 and 37.6.3.G.3: I t
"The O factor is only applicable for spans greater than or equal to S'-0". Shorter spans require a detailed analysis."
x th, The f ollowing paragraph will be added to Sections 37.6.3.G.1, 37.6.3.G.2, 37.6.3.G.3 and 37.6.3.G.4: ql " Simplified analysis and the use of the p factor is applicable E for all double channe ls , all single and double angles and i all structural tube sections. Simplified analysis is also applicable for wide flange sections with a nominal depth less 3 than or equal to 18 inches, a weight less than or equal to 60 pounds per foot and a ratio of major axis to minor axis
.- section modulii less than or equal to 10. A detailed analysis is required for all other sections not included above." .
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Subcontention-14(B) 7,
- 14. Contrary to Criterion xvIII, " Aud i t s ," of 10-CFR'Part-50, Appendix B, Commonwealth Edison Conpany 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 ef fectiveness. of the prograin. The , Applicant also fa'iled to ensure follow-up' action, 4 including .re-audit- of deficient areas. B. A specibl NFC QA inspection reported May 7, 1984 that:
- Mechanical contractor Phillips, Getschow, Co. has -
not established and executed a plan far auditing the implementing procedures of the q;ality assurance program on a periodic basis to determine the. effec - E tiveness of the program in accordance with the Phillips, Getschow OA Manual. Electrical contractor L.K. . Com stock /L.F. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule of-planned and periodic audits established as required by OA Program Manual Section 4.14.1, nor did they
~
i verify compliance with all aspects of the Oua2ity
- Assurance Program.
HVAC contractor Pullman Construction Industries, Inc. did not meet their yearly schedule for^ audit i activities required by their OA Manual, Section-18, in that the following implementing procedure were not audited: B 3.1.F, Design Control 4 - B 5.1.F, HVAC-Repair Adjustment B 9.3.F, Expansion Anchor Installation B 10.2.F, Visual Weld Inspection Edison's audits of the installation of small bore instrumentation and process-piping weresinadeguate in that contractor hanger design : calculation prob-lems were not identified for more than two' years.. Pacts In Dispute i J Edison and its site mechanical, electrical and HVAC contractors have - failed to assure the adequacy of their1guality 1 __-___ 2 _- - __ _.____--
. a_. , . . . .- . . . .. . . . . . - . . . . - _ _
. assurance programs through a comprehensive and ef fective system' s
' of audits which have' identified. :significant quality assurance-deficiencies in a timely' manner.
f- Overview T Under this subcontention, the critical questions to be t a determined are: 1) whether past audits-conducted by Edison and its site contractors were comprehensive, planned,. periodic and - 1 effective; 2) whether the root causes of the original failures , have been determined so that preventive measures may be taken to avoid similar failures in the future; 3) whether present audits are effective a..d are being adequa tely conducted; and most impor-tantly: 4) whether the failure by Edison and its contractors to j- meet the requirements of Criterion XVIII may have led to insuf-ficient confidence that all deficiencies at .Braidwood will be . . identified and corrected. f Edison seeks to summarily dispose of Contention 14(B) by showing that there are no genuine issues as to any of the j " material facts" relevant to Contention 14(B). }
^ . Edison's " Material" Facts i .- -In an attempt to show there are no genuine issues of fact 5 Edison essentially makes the following arguments:
- 1. The four examples in Contention 14(B) represent one i violation of Criterion XVIII of CFR Part 50, App. B
! (Edison,. Statement of Ma te r-ia l - Fac ts , p. ' 2, 11). J
- 2. NRC based the item of noncompliance on Pegulatory. Guide i- .].444-1980 (Edison, Statement: of Material Facts, p. 2, j ~ 13).
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.3. Edison did notishare the NRC 4 interpretation 1 and passed
-its (Edison's) interpretation on to its contractors, which resulted in the root. cause for 'the first . example of noncompliance- (Edison,'-Statement of ~
Material Facts,
- p. 3, 14)..
- 4. Edison " deemed it appropriate".to. subsequently adopt the.
NFC qtaff's interpretation, directed its contractors toi take corrective actions which were then determined to be_ ef fective, which led to the close-out of the-item of noncompl iance (Edison, Statement of Material Facts, p.. 3, 15).
.5. No similar items of noncomp.liance have been-issued.
against Edison since the noncompliance in the summer of 1983 (Edison, Statement of Material. Facts,.p. 3, 16).
- 6. The noncompliance with a single, common root cause which has been resolved does not represent a trend of recurrin'g violations (Edison, Statement'ofLMaterial Fact, p. 4, 17.)
- 7. The noncompliance listed' in subcontention 14(B)(4) is not a violation because the .NPC staf f inspector was simply mistaken regarding the dates on which audits were begun. (Edison, Statement of Material. Facts, p. 4, 18).
Summary Edison's attempt to achieve summary disposition must fail for three reasons. First, Edison's eleventh-hour attempt .to re-write history and make it now appear that the -violations of Criterion XVIII were merely the result of differing interpreta-tions by the NRC and Edison is' inconsistent with the evidence. Edison's argument that its allegedly differing interpretation was communicated to its contractors is not supported by any competent evidence. The. evidence shows numerous other genuine. issues of material fact that require rejection of Edison's motion for summary disposition. Second, Edison does not provide competent evidence to sustain its own allegations of " material- facts." Por tions of Edison's supporting af fidavits are - flawed in that' 3
f they.do net conform to the standards of .10 'CFR 2.749(b), - Rule . 56(e) of.the Federal Rules of Civil Procedure, or the Federal-Rules of Evidence. A number of Edison's affiants lack personal knowledge and do not exhibit competence to testify. Additional-ly, certain of the affidavits are replete with inadmissible hearsay and impermissibly~ express opinions on -the ultimate facts. Third, important discovery is still ongoing with respect- to this contention. For example, despite Edison's claim of contrary interpretations, many guestions remain regarding the root causes of the audit deficiencies identified.- This issue is not yet' ripe for summary disposition. In sum, Edison's motion is inconsistent with the evidence revealed to da te, its " material facts"' and supporting af fidavits are not competent or reliable, and there is still much discovery to be had and questions to be answered before any of this subcon-tention is ripe for decision. Inconsistencies Between Edison's Assertions of Material Fact And The Evidence To Date. The NRC Staff did not base the item of noncompliance on an interpretation of Regulatory Guide 1.444-1980 (Schulz Deposition Tr. 333-34.) Moreover, at the time the NRC Staf f identified the item of i noncompliance Edison made no mention of differing interpreta-tions of Regulatory Guide 1.444-1980 to the NRC (Schulz Tr. 333-34; see also Edison's response to the Notice of Violation, dated July 6, 1984, pp. 27-31, Exhibit A hereto.) Nor is there any competent evidence to indicate that Edison's interpretation 4
. . . .. - .. _ - ~ . . .
was passed on tor the 'three Braidwood site contractors. (Ouaka-Deposition Tr. 29). l In addition, Fdison has done no studies .to determine the i root causes of inoncompliances listed in Inspection Report.83-09.-
.(Edison Response to Intervenors' Quality Assurance Interroga-tor ies.) The record.does indicate that the major factors contri-buting to ' the noncompliances were inadequate contractor: programs and inadeguate licensee quality assurance overview to ensure l
i contractor activities met all requirements. (Letter'to10'Connor i (Ed ison) from Keppler (NPC Region III) transmitting inspection
] report 83-09, dated May 7, 1984, Exhibit B.)
1 Edison's subsequent audits were not by themselves sufficient to cure the earlier auditing deficiencies. The NRC inspector responsible for closing out the item of noncompliance based ~ his close-out not on1'y on licensee audits and contractor audits, but 4 also on all the ongoing retrofit programs. (Schulz Dep. Tr. 3 41.) The specific audit deficiencies cited in the contention were-identified in the summer of 1983. Since then, there have been l numerous deficiencies and noncompliances issued that are examples i of recurring audit-failures. One example is Edison's failure to-take appropriate corrective action with regard to Audit OA-20 '
- 22. An assessment of OC inspector qualifications was not
! performed to address the potential- impact on work performed prior to the audit finding (Inspection Report 84-07). Prior to the identification of the NRC Staff's' item of noncompliance, the audits per formed by Edison and Phillips-Getschow Co. were not ef fective in that they did not identify
-5 i
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Level--IV violations (Schulz Dep..Tr. .338-40; Yin-Deposition 1Tr. 126). The NRCEinspector responsible for the item of noncompliance 14(B)(4) reviewed the prior Audit No. 20-83-33 in order to iden-tify similar findings by the site OA organization and based on that evaluation still concluded that the audits were inadeguate
- . (Yin Dep. Tr. 131).
The noncompliance example listed in Rorem Subcontention 14 ( B) (<4 ) is a violation of Criterion XVIII in that it evidenced inadequate auditing (Yin Dep. Tr. 126-27; Muffet Deposition, Tr. 331). Whether or not the inspector's understanding of the time sequence of the audits performed was incorrect as Edison claims, the audits were nonetheless inadequate because they failed to
- identify deficiencies (Yin Dep. Tr. 128).
, We now turn to those specific portions of Edison's affida-vits and resulting " material f a c t s" with respect to Intervonors' contention subpart 14(B) which are unreliable due to failure to
. meet the requirements of 10 CFR S 2.74 9 ( b) and Fule 56(e). . Quaka Affidavit (On Intervenors' Subpart 14(B)) Numerous portions of Mr. Quaka's affidavit are unreliable based on: (1) lack of competency; (2) lack of personal knowledge; (3) inadmissible hearsay; (4) inadmissible opinion; (5) testifying to conclusions and ultimate facts; and/or (6) failure to append documents to the affidavit. For example:
- 1. Answer 5 (entirety)
In his af fidavit Mr. Quaka makes no showing that he is competent to testify to events which occurred in 1983, prior to his employment at the Braidwood site. Answer 5 is also clearly 2 6-
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not; based on Mr. Quaka's personal knowledge: and is therefore: s h'earsay.
- 2. . Answers 6'and 7 (entirety)
A q ~ Mr. Quaka's beli,efs are inadm'issible. opinion and are. hearsay because he has no personal knowledge:astto-the underlying; facts surrounding events whibh transpired. prior to his empiqyment 6 at thE Braidwood site.
; -3. Answer 9 (entirety) , 4 Mr. Quaka's . opinion as to an ultimate fact is inadmis-sible in its entirety. ,
(
- 4. Answers 10 and 11 (entirety)
As Mr. Quaka clearly lacks personal knowledge as . to , events prior to his employment at Braidwood, his answer is hearsay. This is especially so when, as here, tir. Quaka appears to speak for the NRC. Moreover, Mr. Quaka testifies to ultimate facts, and in Answer 10, his response refers to a " comprehensive review" to support his conblusion. Such review was neitaer ap' pended . to Mr. Quaka's testimony nor produced in its entirety for Intervenors. J ' Forbes Affidavit (On Intervenors' Subpart 14(B))' _
\\ i Numerous por tions of Mr. 'Forbes' affidavit are unreliable ~ =
based on: (1) lack of competency; (2) lack of personal knowledge; (3) inadmissible hearsay; '(4) inadmissible opinion;. 'and/or (5) 4 nonresponsiveness. For example: i
- 1. Answer 2 (entirety) st .
Mr. -Forbes does not affirmatively state his competence? ( H
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g _ to testify about the subject matter of his affidavit.
- 2. Answer 5-(entirety)
Mr._ Forbes of fers an inadmissible opinion as to his
" understanding" and bases his answer on conversations with unknown NBC inspector (s), which constitute hearsay.
- 3. Answer 8 (entirety)
Mr. Forbes answer has little, if anything, to-do with the question posed and is therefore nonresponsive.
- 4. Answer 10 (last sentence) -
The last sentence in Mr. Forbes' answer reports on information to be provided in a presently non-existent document once it has been developed. This answer is speculative, conclusory and not based on personal knowledge.
- 5. , Answer 12 (entirety)
Mr. Forbes' response is based on documents which were not appended to his affidavit. Additionally, some portions of his answer rely on NRC Staff documents or reviews and are therefore hearsay. Quaka Affidavit (On Intervenors' Subpart 14.B.2)) Numerous portions of Mr. Quaka's affidavits are unreliable because: (1) there is no demonstration of competency; (2) it is ; replete with inadmissible hearsay; (3) it fails to demonstrate i personal knowledge; and/or (4) the response is speculative. For-example: ,
- 1. Answer 5 (entirety)
Mr. Ouaka has not .af firmatively demonstrated his I competence to effectively answer and lacks personal knowledge in ' 8 l
)
. i that he was not yet on the site when the activity:in question ,
occurred. Mr. Quaka's' testimony is hearsay.
- 2. Answer 6 (entirety) .
Mr. Quaka lacks the personal knowledge to respond because he was not yet on site.
- 3. Answer 7 (portions)
Mr. Quaka lacks ~ the personal knowledge with respect to the first sentence in the second paragraph. Mr. Quaka does not have personal-- knowledge respecting the first three sentences of the answer because he was not on . site before March 1984. The last portion of the next sentence is unreliable and speculative because it refers to a document not-yet developed.
- 4. Answer 11 (portions)
Mr. Quaka bases his opinion on documents which have not been appended to his affidavit. Additionally, the last~ two sentences of the first paragraph are hearsay, in that Mr. Quaka cites a conclusion contained in a report. The report itself is i i the best evidence of what it concludes.
- 5. Answer 12 (portions)
Mr. Quaka's response is clearly inadmissible hearsay beginning after the second line and ending before the second to the last sentence. Additionally, the inspection report.referreo to is the best evidence of its conclusion. Holt Affidavit'(On Intervenors' Subpart 14(B)(3)) Numerous por tions of Mr. Holt's af fidavit are unreliable-I , .9 E e f. L x
V - L . based'on: (1) lack -of competency;1(2) lack of personal knowledge; (3)- inadmissible hearsay; (4) absence of supporting documentation, and (5) speculation. For example:
- 1. Answer 2 (entirety) ,
Mr. IIolt does not af firmatively demonstrate his competence to testify on.the matters contained in his affidavit.
- 2. Answers 5 and 6.(entirety)
M r . I!ol t lacks the personal knowledge to speak to events
.which occurred prior to his arrival-at the Braidwood site on October 16, 1984. Ilis answer is therefore hearsay'
- 3. Answer 10 (portion).
See analysis for An'swers 5 and 6 as to the first sentence in Answer 10.
- 4. Answer 13 (portions)
Mr. Hol t refers to documents in support of his state-ments which are not' appended to his deposition. Additionally, d' the last sentence in his answer is . inadmissible hearsay because it characterizes a document.
- 5. Answer 14 (entirety)
~
Because Mr. 11olt's answer is prefaced with theLwords "I believe", his response is both speculative and conclusory. 4 t Hunsader' Affidavit (On Intervenors' Subpart 14.B.4)) Numerous portions of Mr. Quaka's af fidavit are unreliable based on: (1) lack of competency; (2) Jack of personal 1 knowledge;
,(3) inadmissible hearsay; (4) inadmissible opinion; (5)
? ) di' testifying to conclusions and ultimate facts; and/or (6) failure to append documents to_the affidavit. For example: 10
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_ _ __ _ . N - M____________________ _ _ _ _ _ __ _ ____ __.__1__._ _ _ _ u _ _ _________ _ _
. a
- 1. Answer 2 (entirety)
Mr. Hunsader has. made no affirmative demonstration thati he is competent to testify to the f acts contained in his' affidavit.
- 2. Answer 5 (portions);
Everything beyond the first sentence-is unreliable'and-inadmissible hearsay.
- 3. Answer 6 (portions)
The entire answer beyond the first sentence is unreliable beca'use it is speculative and conclusory.
- 4. Answer 7 (portion)
The second to the last sentence is unreliable because it is hearsay and lacks personal knowledge.
- 5. Answer 8 (portion)
The second sentence is unresponsive to the question and is conclusory respecting an ultimate-fact.
- 6. Answer 10 (portion)
)
The fourth sentence is inadmissible hearsayf and l conclusory as to an ultimate fact.
- 7. Answer 11 (portion).
The second sentence is hearsay and speculation (; the H NRC inspector's belief. It also purports to reach an ultimate 'I 1 fact.
^ 8',
. Answer 14 (portions)
The second and third sentences of the Lfourth paragraph-are speculative and conclusory. This answer also purports to reach an ultimate fact. 11 2 h - .
- 9. Answer 15 (entirety)
Answer 15 in its entirety should bc disregarded because the question to which it responds is flawed in form. The question assumes a fact not established ("notwithstanding the fact that the NFC Inspector misteok the dates when .... ")
- 10. Answer 16 (portions)
The last sentence in the first paragraph and the last two sentences in the second paragraph are nonresponsive to the question, conclusory and speculative. In addition, the last two sentences are replete with inadmissible hearsay. 12
SUBPART 14 (B) EXilIBIT A COMMONEALTH EDISON CO WANY RESPONSE TO INSPECTION REPORT 50-456/83-09 and 50-457/83-09 ITEM OF NONCOWLIANCE:
- 4. 10 CFR 50, Appendix B, Criterion XVIII, as implemented by the-Commonwealth Edison Company Quality Assurance Manual, QR No.'18.0, requires, in part, that a comprehensive system of planned and periodic audits be. carried out to verify compliance with all aspects-of the quality assurance program and to determine the effectiveness of the program.
Contrary to the above:
- a. Phillips, Getschow Company has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program in accordance with the PG Quality Assurance Manual, Section 16.
- b. L. K. Comstock Company /L. K. Comstock Engineering Company auditing-activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by Quality Assurance Program Manual Section 4.14.1 nor did they verify compliance with all aspects of the Quality Assurance Program.
- c. Pullman Construction Industries, Inc., did not meet their yearly schedule for audit activities required by their Quality Assurance Manual, Section 18, in that the_following implementing procedures were not audited:
B 3.1.F, Design Control-
- B 5.1.F, HVAC Repair Adjustment
- B 9.3.F, Expansion Anchor Installation B 10.2.F, Visual Weld Inspection
- d. The licensee's audits of the installation of small bore instrumentation and process piping were inadequate.in that contractor hanger design calculation problems were not identified for more than two years.
t
' Response to Item 4a
RESPONSE
Commonwealth Edison Company acknowledges that 'Phillips, Getschow , Company did not audit each of its implementing procedures. Rather,. j the Phillips, Getschow' Company Quality Assurance Program required all Quality Assurance Manual sections to be audited-over the year period. This requirement. met and fulfilled ASME Code . requirements. . The audit schedule for'the 1983/1984 period, dated 14urh 17, 1983 l provided for all Quality Assurance Manual sections' to be audited. -A special schedule was established to audit process control procedures. CORRECTIVE ACTION TAKEN AND RESULTS' ACHIEVED Phillips, Getschow Company revised their ' audit schedule un August i 21, 1983 to include auditing of all procedures annually. : Procedures not used in the annual period will be designated not applicable at the time of the audit. CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE Commonwealth Edison Company verifles implementation of the Phillips, Getschow Company Audit Plans through our audits and surveillances. DATE OF FULL C0FPLIANCE The revised Audit Plen has been implemented. Commonwealth Edison Company verification of the schedule has been completed. (Reference Commonwealth Edison Company comprehensive onsite/offsite audit of October 1983). l l a. 2
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Response to Item 4b 1 RESPONSE-l Commonwealth Edison Company acknowledges that L. K. Comstock did not fully implement their 1983 audit schedule. However, adequate ., Commonwealth Edison Quality Assurance audits were performed to cover all. applicable L. K. Comstock activities. During the inspection. visit, the NRC acknowledged that Commanwealth Edison Quality Assurance provided adequate quality audit coverage and that Site Quality Assurance was previously aware of the L. K. Comstock-shortfall. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A review of L. K. Comstock's audit coverage (corporate and site) for 1982 and 1983, indicates that a total of six (6). Quality Assurance manual subsections and six (6) field work p'rocedures had not been audited as follows. A review of the six (6) Quality Assurance manual subsections not audited by L. K. Comstock showed: One (1) section covered the L. K. Comstock Policy Statement One (1) section covered the overall program description . One (1) section defined the program applicability One (1) section covered L. K. Comstock's reporting of 10 CFR Part 21 items One (1) section covered the corporate review of the site i' Quality Assurance program One (1) section covered the corporate Organization Chart-L. K. Comstock corporate Quality Assurance has since completed audits of the above sections, i For the six (6) work procedures: 4-Two (2) were new procedures.as of late 1983 and therefore were not yet scheduled for audit One (1) covered silver plating of bus bars (an infrequently '
~
performed operation which is subjected to a 100% Quality Control witness) ~
~
Response to Ab (cont'd)
- One (1) covered site organization position delineation. This section is normally audited by corporate auditors during their audits One (1) covered Production's use of a Revision WorkLRequest (RWR). (However, the related Quality Control inspection of-RWRs had been audited. Subsequently, the work-instruction was audited during the week of ' January 9,1984 by L. K. Comstock.')
One'(1) covered Equipment / Junction Box. Installation. (However, the related Quality Control inspection of' equipment erection had been audited. Subsequently, the work instruction was audited 'during the week of January 9,1984 by L. K. Comstock.) Therefore, the active applicable work procedures and quality control inspection procedures have been audited by L. K. Comstock as of the week of January 9,1984. A concern raised by the -inspector in the area of supporting evidence-for L. K. Comstock audits prompted Site Quality Assurance to review copies of the objective evidence for the L. K. Comstock corporate offsite audits. Commonwealth Edison Company Quality Assurance with L. K. Comstock site Quality Assurance performed this review. (This information was not available onsite during'the NRC inspection.) This review disclosed that there was sufficient cbjective evidence-recorded to support the conclusions stated in the audit reports. Copies of this objective evidence are available at the. site for. review. CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE ' As a result of the Commonwealth Edison Company-Quality Assurance concerns, L. K. Comstock has placed two (2) fulltime, qualified auditors on site (one activated in October, 1983 and one in November, 1983). Counseling has been given to these auditors by Commonwealth Edison Company Quality Assurance'to include more descriptive evaluations of audit results in their audit reports. Additionally, Procedures (4.14.3 and 4.14.1).have bee,n revised to more clearly define the L. K. Comstock onsite auditing activities and qualification processes for site auditors. L. K. Comstock site Quality Assurance has submitted an. audit plan for 1984 which indicates that the Quality Assurance Program and their' active safety related activities will be adequately covered.
O
. Response to Item 4b (cont'd)
DATE OF FULL COFPLIAtCE All applicable site procedures were audited by the week of January 9, 1984. Procedures 4.14.3 and 4.14.1 were revised to reflect onsite auditing activities and qualification processes. Interim approval was granted on 2/29/84 and 11/2/83 respectively. I i 1 l
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UNITED ST ATCS , t 6p a P e % ,% NUCLEAR nEGULATOnY COMMisSIO
$- nEcecn tis '" D f.u r j 799 noostvtLT noAo
%i 3 cten c.ttvn. stumois soi n SUBPAI(T 14 (B) h,t'.**o '
/ EXIIIBIT B MAY 7 1984 Docket Nos. 50-456 50-457 Construction Pennit Nos. CPPR-132 CPPR 133 EA 84-35 Comor. wealth Edison Company ATTN: Mr. James J. O'Connor President and Chief Executive Officer Post Office Box 767 Chicago, IL 60690 Gentlemen: ,
This refers to the special quality assurance program inspection conducted by Messrs. T. E. Vandel, R. D. Schulz,1. T. Yin, D. E. Keating, C. C. Williams, and D. R. Hunter of this office on June 20-24, June 27-July 1. August 1-5, August 9, October 4-7, and October 24, 1983, and January 11-13, January 26, a ar.d February 9,1984, at Braidwood Station, Units 1 and 2, and to the discussions of our findings during the conduct of the inspection. This also refers to enforcement conferences which were conducted concerning the findings of this inspection in the Region Ill office on December 20, 1983, between Mr. C. Reed and other members of your staff and Mr. A. B. Davis and other members of the Region III staff, and on March 7, 1984, between you and me and members of our staffs. The purpuse of this inspection was to assess the effectiveness of the quality assurance programs of the p'i' ping contractor, the electrical contractor, and theheating, ventilation,andairconditioning(HVAC) contractor. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective
- examination of p(rocedures and representative records, observations, and interviews with personnel. '
The inspection revealed a number of deficiencies concerning the verification of correct material for ASME piping components, control of HVAC welding activities, and design control of field run small bore piping and associated hanger installation activities. These deficiencies existed even though Ceco had recently conducted comprehensive reviews of the performance of all site contractors in response to a proposed civil penalty issued on February 2, 1983, involving one of these contractors. We are concerned that experience gained at otter CECO facilities and the lessons learned from the mechanical equipment place-mer.t violations at Braidwood were not adequately applied to the Braidwood facility. k. CERTIFIED Mall li_DUR*l RECEIPT REQUESTED
Comonwealth Edison Ccmpany 2 MAY 713E4 ( The major factors contributing tu the deficiencies were inadequate contractor programs and workmanship, inadequate licensee reviews of the contractor pro-- grams, and inadequate licensee quality assurance overview to' ensure contractor activities net all requirements. The violatiens indicate the need for more aggressive CECO management involvement in and support of the CECO QA Program to ensure that all safety-related activities perfonned by contractor personnel are in accordance with the regulations, codes,s standards, and license require-ments. The stop work orders and construction deticiency reports which were issued as a result of our inspection findings in the areas of small bore piping hangers, HVAC welding activities, and piping material control should have been initiated by CECO without the involvement of the NRC. We-are encouraged by the personnel and organizational changes-you described during the March 7, 1984, enf orcement conf erence which indicate that you recognize the need for increased minagement involvement in the quality assurance program and have taken some positive actions in that regard. The 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; s theref ore, inspection re:.ords verifying correct material installation prior 4 to that date do not exist. A documented inspection program had not been terplemented 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 enfor cement confercnce you described a verification program you are developing which will include a 100% inspection of all installed piping and associated records. We understand that the results of that program and the completion of any necessary corrective actions that might result will ensure that all installed piping material meets design requirements. Since we will need to evaluate th'e results of your verification efforts in order to fully assess the significance of the programmatic deficiencies, enforcement action is not being taten on this violation at this time. Following our review of your ef forts we will cetermine the appropriate enforcement action. Until that time, this matter is being classified as Unresolved items 4 U /83-09-04(A); 457/83-09-04(A) and 456/83-09-04(B); 457/83-09-04(B). Ibe iter., of noncompliance identified during the inspection are specified in the enclosed Appendix, and have been categorized as a Severity Level IV in accordance with the NRC Enforcement' Policy of 10 CFR Part 2, Appendix C, published-in the Federal Register 47 FR 9987 (March 9, 1982). A written response is required. A response is also requested for Unresolved items 456/83-09-04(A); 457/83-09-04(A) and 456/83-09-04(B); 457/03-09-04(B). Ycur response should include a description of your program to verify the quality of installed piping components, your efforts to improve the aggressiveness and ef f ectiveness nf LECo management involvement in and support of the CLCo QA Program, and the basis for your confidence in the performance of j all site contractors. Your response should add ess why the contractnr programs in the piping and HVAC areas were inadequate, why Ceco reviews of the deficient programs toiled to identify the deficiencies, and why the CECO QA overview was
r-g Comcnwealth Edison Company 3 MAY 7 1984 inadequate to ensure the contractor activities met all requirements. Also, your response should describe your efforts to assure that all construction workers and their supervisors understand their role in building quality into the facility. In accordance with 10 CFR 2.790(a) a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days ~ of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear f rom you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room. The response directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Of fice of Management and Budget as required by the Paperwork Reduction .;ct of 1980, PL 96-511. We will gladly discuss any questions you have concerning this inspection. Sincerely, Mb James G. Keppl Regional Administrator
Enclosures:
- 1. Appendix, Notice of Violation
- 2. Inst.ection Reports No. 50-456/83-09(DE);
ho. 50-457/E3-ia(DE) cc w/encls: D. L. Farrar, Director of Nuclear Licensin<; M. Wallace, Projec t M mager P. Cesaro, Project Superinter. dent J. F. Gudac, Station Superintender.t ctg / Document Control Desk (RIUS) Resident inspector, kill Phyllis Dunton, Attor. icy 7, General's Office, Environmental g Control Division Jane Whicher, Esq.
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