ML20205C612
| ML20205C612 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/31/1986 |
| From: | Kaushal N, Kostal K, Shevlin E, Smith N, Thorsell T, Woziak J COMMONWEALTH EDISON CO., DANIEL INTERNATIONAL CORP. (SUBS. OF FLUOR CORP.), SARGENT & LUNDY, INC. |
| To: | |
| Shared Package | |
| ML20205C591 | List: |
| References | |
| OL, NUDOCS 8608120405 | |
| Download: ML20205C612 (200) | |
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P MME%Mq UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~86 AUG 11 A10:40 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF Su. in:
n the Matter of 00CKET'% & zi Wicf.
BRAtCH COMMONWEALTH EDISON COMPANY ) Docket Nes. 50-456
) 50-457
,(Braidwood Station Units 1 and 2) )
REBUTTAL TESTIMONY OF
[NARINDER N. KAUSHAL)
[KENNETH T. KOSTAL]
[ THOMAS B. THORSELL]
[ EDWARD M. SHEVLIN]
[ JOHN R. WOZNIAK]
[NEIL P. SMITH]
(BCAP CSR) 8608120405 PDR 860307 T ADOCK 05000456 PDR August 1986
.a
(
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matcer of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
REBUTTAL TESTIMONY OF NARINDER N. KAUSHAL (ON ROREM Q. A. SUBCONTENTION 2)
(Harassment and Intimidation) a August, 1986 t
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REBUITAL TESTIMOST OF NARINDER N. KAUSHAL Q.1. Please state your full name for the record.
A.1. Narinder Nath Kaushal Q.2. By whom are you employed and in what capacity?
A.2. I am currently employed by Commonwealth Edison as Project Field Engineering Manager for Braidwood Nuclear Power Station.
Q.3. What was your job immediately prior to your current job?
A.3. Prior to my current position, I was the Director of the Braidwood Construction Assessment Program (BCAF) throughout the period when the BCAP was being implemented.
Q.4. What were your responsibilities as BCAP Director?
A.4. I was responsible for managing and directing the activities of the BCAP Task Force in accordance with the BCAP Program Document submitted to the NRC in June 1984.
Q.5. Please summarize your educational background and professional experience. l l
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A.5. I received my doctorate in Nuclear Physics from Rensselaer Polytechnic Institute, Troy, N.Y. in 1967. Subsequently, I was Research Associate in the Nuclear Engineering Department at Rensselaer Polytechnic Institute from 1967 to 1974. In 1974, I joined Commonwealth Edison and was assigned to the Clinch River Breeder Project on which I held a series of engineering management positions. Starting as a cognizant engineer for several instrumentation and control systems, I served successively as Chief of the Instrumentation Control and Electrical Branch, Chief of the Systems Branch, Chief of the Reactor and Plant Systems Branch, and finally Deputy Assistant Director for Engineering.
During these assignments, I was responsible for managing and directing engineering activities of reactor manufacturers and the architect engineer.
Q.6. What is the purpose of this testimony?
A.6. The purpose of this testimony is to describe the BCAP Construction Sample Reinspection (CSR) and its reinspection results for the electrical construction categories. Other witnesses will discuss specific aspects of the CSR in more detail. In particular, Dr. Frankel discusses the statistical aspeces of the CSR, Mr. Shevlin and Mr. Wozniak discuss the reinspections which were performed, Mr. Kostal and Mr. Thorsell address the engineering evaluations of CSR observations, and Mr. Smith describes the quality assurance overview of the CSR.
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Q.7. What was the BCAP CSR7 A.7. The Braidwood Construction Assessment Program or BCAP was a program of reinspections and reviews covering safety related construction activities at the Braidwood Nuclear Power Station.
One of the objectives of the BCAP was to assure that no unidentified or unaddressed programmatic design significant censtruction problems exist at Braidwood.
The BCAP was comprised of three principle program elements. These were (1) the construction sample reinspection or CSR (2) the reverification of procedurcs to specification requirements or RPSR and (3) the review of significant corrective action programs or RSCAP. The element relevant to the purpose of this testimony is the first one, namely, the construction sample reinspection. The CSR consisted of a visual reinspection of a sample of on-site safety related construction work which as of June 30, 1984 had been completed and QC accepted. The reinspections were carried out from October 1984 thru July 1985. The CSR also included review of the quality documentation associated with the items i
reinspected, but this testimony is only concerned with the CSR reinspection results.
Q.8. What was the purpose of the CSR7 l
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A.8. The purpose of the CSR was to accomplish one of the objectives of the BCAP as I stated in response to Q.7, that is, to assure that no unidentified or unaddressed programmatic design significant construction problems exist at Braidwood.
Q.9. Was the CSR designed to determine whether the alleged harassment and intimidation of L.K. Comstock QC inspectors adversely affected their inspe- .ons?
A.9. The CSR was not specifically designed to answer questions regarding the possible effect of alleged harassment and intimidation of L.K. Comstock QC Inspectors, although the results shed some light on that subject, as shown in Mr. Del George's and Dr. Frankel's testimonies.
Q.10. Why was the goal of the CSR to determine whether unidentified or unaddressed programmatic design significant construction problems exist?
A.10. The objective in conducting the CSR was to assure that the l
construction of the Braidwood Nuclear Station meets the applicable j desigr. requirements. In building Braidwood, Commonwealth Edison relies not only on its formal Quality Assurance program l established pursuant to the requirements of 10CFR 50 Appendix B, but also on the conservatism and quality of every aspect of the design, construction and testing at Braidwood. Based on its 4-
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l confidenes in this overall quality program Commonwealth Edison ,
-l believed that the quality of construction at Braidwood was acceptable. Our objective through the CSR was to confirm that the overall quality program was functioning as expected.
It is not abnormal that construction errors occur in the construction of a nuclear plant. However, such errors are normally expected to be discovered and corrected by the checks and balances inherent in an overall quality program. Conservative design and construction practices reduce the likelihood that any construction errors that do occur will be design significant.
In this context, the term " design significant" relates to the kind of construction deficiency which if uncorrected might prevent the affected portion of the construction from fulfilling its intended safety function. It should be noted that even a design significant construction defect does not necessarily pose a safety problem. There are numerous other factors such as margins of safety inherent in code requirements, redundancies in design, pre-operational testing etc., which provide significant additional assurance of safety.
If there were a problem of some sort in the overall quality program applicable to a part of the construction, we expected that this would result in recurring design significant discrepancies.
We wanted to assure ourselves that no such problems existed. Thus through the CSR, we were looking for design significant
discrepancies which were " programmatic," that is, occurred repetitively and went unidentified or unaddressed through the existing system of checks and balances. With a view to further enhancing the confidence that no design significant discrepancies exist in the uninspected portion of the plant, we also were i looking for discrepancies chich while not design significant, were repetitive in nature and might be indicative of a design significant problem in the unreinspected portion of the population.
Q.11. Why was the CSR designed as a sample program, rather than a 100%
reinspection?
A.11. A 100% reinspection of all safety related work at Braidwood completed prior to June 30, 1984 would have been prohibitively time consuming and unnecessary to achieve the objective of the 1
CSR, which was to identify design significant discrepancies that i
might occur repetitively and were unidentified and unaddressed under the normal Quality Control / Quality Assurance program. A reasonable sampling program can be expected to be effective in confirming the existence or non-existence of such recurring construction discrepancies. In establishing our sampling program we continually consulted with and were advised by Dr. Frankel.
The sampling program was set up to assure with at least a 95%
confidence level that at least 95% of the construction work in
'l each construction category is free of design significant discrepancies. Features were provided in the program to reinspect additional items of construction (expand the reinspection sample) in case a design significant defect was identified in the initial reinspection sample. Inasmuch as no design significant discrepancy was identified in the course of the CSR, this feature of the program was not exercised.
Q.12. How does the size of the CSR effort compare with other reinspection programs with which you are familiar?
A.12. The size of the CSR effort is equal to or larger than any other general quality verification program that I am familiar with. I make here, a distinction between a general program of quality verification as opposed to reinspection programs resulting from known or suspected deficiencies in specific aspects of construction work which may have resulted in a complete reinspection of the entire affected population. All in all, the CSR involved more than 90 man-years of direct engineering and reinspection effort in addition to engineering evaluation of identified discrepancies by the architect engineer and the support services provided by the various construction contractors on site.
Q.13. Why was a cut-off date of June 30, 1984 chosen?
A.13. The date of June 30, 1984 was somewhat arbitrary. The overall CSR effort was started in June of 1984. In order for us to select a
, l sample of the completed construction work for the purposes of I reinspection we had to pre-identify all completed construction l
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s work in each construction category under consideration. Inasmuch l
as construction work was still in progress at Braidwood, we had to establish a cut-off date in order to determine the total population of the completed construction work from which we could draw the reinspection sample. June 30, 1984 was the latest cut-off date that we could adopt without delaying implementation of the CSR effort.
Q.14. Why did the CSR involve QC accepted work?
A.14. Generally, only construction work that had been QC inspected and accepted was considered appropriate for reinspection under the CSR element because the work that had not been QC inspected and accepted could not be considered completed construction work.
Furthermore, as I stated in response to question 10, we were attempting to identify those construction discrepancies which went undetected and unaddressed through the normal quality control and quality assurance program. For this reason, the CSR generally included only the work that had been QC inspected and accepted.
Q.15. Why did the CSR involve visual reinspections?
A.15. Visual reinspections cover a vast majority of the normal QC inspections performed in the course of construction completion.
This is true in particular for L.K. Comstock's scope of work. For example, QC inspections performed on AWS DI.1 welding are all 8-
visue.1 inspections. Inasmuch as.the overall objective was to ,
assure the absence of programmatic design significant discrepancies in completed construction, the visual reinspections were. considered to be adequate to identify such conditions if such conditions had existed.
Q.16. Please describe the organization which carried out the CSR.
A.16. The BCAP Task Force was specifically organized for the purpose of implementing the Braidwood Construction Assessment Program. The personnel comprising the BCAP Task Force were drawn from several organizations. Most of the engineering staff was drawn from the
! Stone & Webster Engineering Corporation and all of the inspection staff was drawn from the Daniel Construction Corporation. The individuals selected to work on the Task Force were highly qualified and experienced. The average experience level of the engineering staff was approximately 22 years while the average a
experience level of the inspection staff was 11 years. None of the individuals who worked on the BCAP Task Force had any prior involvement with the work that was to be reinspected or reviewed under the BCAP. The Task Force worked under my direction. I was assisted in my responsibilities by two assistant directors, one of i
I whom was responsible among other things for managing the inspection force while the other one was responsible for manasing 1
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s among other things the engineering and technical efforts related to the CSR. In my capacity as the director of the BCAP Task Force I reported to the Braidwood Project Manager.
Q.17. How, if at all, did 10 CFR Part 50 Appendix B apply to the activities of the BCAP Task Force?
A.17. The CSR effort was not required to assure the quality of the safety related components, systems and structures. It was an effort in addition to the first line inspections that are normally required to. determine the acceptability of completed construction. Thus, the provisions of 10 CFR 50 Appendix B are not necessarily applicable to the CSR effort. However, in fulfillment of a comnitment to the NRC, the activities of the BCAP Task Force were conducted in accordance with the Commonwealth Edison Company Quality Assurance Program which meets the requirements of 10 CFR Part 50 Appendix B.
Q.18. What oversight, if any, was given to BCAP Task Force activities?
A.18. BCAP Task Force activities were directly overviewed by the BCAP QA group established within Edison's Quality Assurance Department.
The activities of the BCAP Tcsk Force as well as the activities of the BCAP QA group were overviewed by the independent expert overview group (IEOG) which was assembled by the Evaluation Research Corporation and consisted entirely of individuals from 1
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outside of the Commonwealth Edison Company. The activities of the BCAP Task Force, the BCAP QA group, and those of the independent expert overview group were all overviewed by a full-time resident NRC inspector.
Q.19. Please describe the method of approach used in performing the CSR.
A.19. As I stated in response to Question 7, the CSR consisted of visual reinspections of a sample of on-site contractors' safety-related construction work completed and QC accepted through June 30, 1984. The CSR reinspections were designed to indicate with a high degree of confidence whether there were any previously unidentified or unaddressed programmatic design significant problems in the construction of the plant.
For purpose of taking a sample to be reinspected, the entire population of the completed safety related work was divided into construction categories which were defined as groups of hardware items constructed using similar processes or containing similar types of components. A total of 30 construction categories were included in the CSR. Out of these thirty, six pertained to the electrical work and are relevant to the purpose of this testimony.
For each construction category, the population of all safety related items that were completed a d QC accepted as of June 30, 1984 was identified. The CSR sample was selected from each of i
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these populations. Checklists and instructions for conducting the CSR reinspections and reviews were developed for each construction category. For each item selected for reinspection, verification packages containing applicable checklists and other~ information were assembled to facilitate performance and recording of the results of visual reinspections and documentation reviews.
Inspection personnel used these verification packages and checklists and instructions to perform reinspections and documentation reviews and to document the results. If the inspectors observed a condition in the field that apparently differed from the design requirements, an observation report was written. These observations were reviewed by the BCAP engineering staff to determine if they represented a valid discrepancy. Each discrepancy was then evaluated by the architect engineer to determine if it was design significant. Upon completion of the reinspections and reviews, the results from each construction category were reviewed to determine whether there were any previously unidentified programmatic design significant problems in that construction category.
Q.20. What were the CSR construction categories within the scope of L.K.
Comstock's work?
A.20. These categories were: conduit, conduit hangers, cables, cable pans, cable pan hangers, and electrical equipment installation.
These are described in more detail below: l l
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Conduit Class IE rigid and flexible conduits and conduit system wireways Conduit hangers Category I hangers supporting conduits or conduit system wireways Cables Power, control, and instrumentation cables Cable pans Cable pans, cable racks, and cable pan system wireways that are Class 1E Cable pan hangers Cable pan hangers, supports, and nonsegregated phase bus duct hangers that support cable pans or bus ducts in safety-related areas Electrical equipment Installation of electrical equipment installation such as switchgear, motor control centers, control panels, batteries, junction boxes, and ion chambers Q.21. What was the basis for dividing up the electrical work into these six categories, rather than some other grouping?
A.21. The division of the electrical work into these six construction categories follows the natural division of work and inspection activities in this area of construction.
Q.22. Please explain how the CSR samples were chosen.
A.22. The overall method of selecting samples was based on engineering judgment, including, but not limited to, appropriate use of statistical concepts. The sample size was established to provide a high degree of confidence in conclusions regarding the quality of construction in each construction category.
4 The total sample for each category consisted of three parts as 1
shown in Attachment 2C (Kaushal-1). The first, or "randem,"
i portion of the sample was chosen in such a manner that each item )
e in the population had an equal chance of inclusion in the sample.
The number of items for the random portion of the CSR samples was sufficient to support a conclusion with 95% confidence that a 1 1
l minimum of 95% of the population is free of design-significant I defects, assuming that no such defects were found in the sampled items. The size of the random portion of the sample for each population is shown n Attachment 2C (Kaushal-2).
For second portion of the sample, engineering judgment was used both to determine sample size and to select items. This portion emphasized areas of plant construction which (1) had previously exhibited discrepancies or (2) are part of safe-shutdown and emergency core cooling systems. The documents reviewed for determining previously identified discrepancies included Byron and Braidwood reports required by 10 CFR 50.55(e), NRC Inspection Reports for Byron and Braidwood, and Braidwood trend reports associated with CECO and contractor audit findings and' nonconformance reports (NCRs). However, for each of the
- electrical construction categories it was determined that none of these previously identified discrepancies could be limited to a subset of the population. Therefore, for approximately 1/2 of engineering judgement portion, items were chosen from the
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population using random methods; i.e., such that each item in the population had an equal chance of inclusion.
1 The second half of the engineering judgment sample emphasized the 4
systems, structures, components, and equipment that comprise, support, or enclose the following systems: auxiliary feedwater; chemical and volume control; component cooling; emergency core cooling; emergency diesel generator; essential service water; and ventilation systems associated with the control room, diesel generator rooms, and essential switchgear rooms.
Both the random and engineering judgment portions of the sample included more-highly-stressed items. However, as a result of public comments and with the concurrence of the NRC staff and IEOG, efforts were made to ensure that the total sample contained a significant number of additional more-highly-stressed items in the construction categories in which stress is a significant design factor. Among the construction categories pertaining to Comstock work this applied only to cable pan hangers.
Thus for cable pan hangers, items for the second half of the 1
engineering judgment sample were selected, to the extent practical, from a list provided by the architect-engineer of items containing more-highly-stressed elements. Ten additional items were selected as third part of the CSR sample from the list of i
more-highly-stressed items so that there was a total of 68 such items.
1 Attachment 2C (Kaushal-2) provides a tabulation of population size and composition of the CSR sample for each electrical-construction category. Note that a portion of the " engineering judgment" sample was in fact selected using statistically random methods.
i Under the provisions of the CSR, if any design-significant discrepancies had been found in the initial CSR sample, the cample size would have been increased. This proved to be unnecessary since no design-significant discrepancies were identified.
Q.23. Why were the reliability and confidence levels for the " random" t portion of the CSR sample chosen to be 95% and 95%7 A.23. As I stated earlier in response to Questions 8 and 10, the purpose of the CSR was to assure that no unidentified or unaddressed I
programmatic design significant construction problems exist at
. Braidwood. If any such construction problems were to exist I i
would expect them to produce recurring construction discrepancies.
which would surface at least once and perhaps several times through a sample of this size. 'Therefore, if one concludes with j at least a 95% confidence level that at least 95% of the I
population is free of design significant defects, this represents a very high confidence level that there are na programmatic design l
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significant problems in the construction of the plant in a given construction category.
In any sampling approach, a judgment has to be made 'on the optimum size of the sample. A larger sample entails corresponding increase in the size of the effort. Increase in the size of the effort might then entail a corresponding delay in completion of the program. A delay in completion of the program would negate the benefit of timely feedback so corrective actions, if any, may be expeditiously implemented.
Thus, in establishing the size of a program such as the CSR, judgment has to be made whether the increase in the size of the effort is justified by the corresponding small increment in the confidence level. Inasmuch as the CSR did not constitute the first line inspections which are required to determine the acceptability of the completed construction work, but rather the CSR was intended to be a verification program to confirm the quality of the product from the overall quality program in place, a confidence level of 95% at 95% reliability was considered to be adequate for the random portion of the sample.
Q.24. Why was an " engineering judgment" sample included in the CSR sample?
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. I A.24. The engineering judgment portion of the sample was in addition to the random portion of the sample which, as stated in response to Q.22, alone provided a confidence level of 95% at 95% reliability.
The overall purpose of including the " engineering judgment" portion of the sample was to enhance still further our confidance in the conclusions drawn from the results from the CSR reinspections. Part of the enhancement in confidence results from the fact that the inclusion of the engineering judgment portion increases the size of the overall sample reinspected.
Further enhancement of the confidence results from the fact that this portion of the sample was deliberately selected from items which we believed would be more likely to have design significant discrepancies, if any existed.
Q.25. Please describe the development of the CSR reinspection check-lists and instructions.
A.25. In performing the CSR, the construction categories were subdivided into attributes which were reinspected or reviewed to verify conformance with design and regulatory requirenents. For example, cable pans was one construction category and we lding (of the cable pans) was one attribute reinspected in the CSR.
For each construction category, relevant design information was reviewed to determine such attributes. The attributes selected were those that (1) are required by applicable codes and standards, (2) potentially have an effect on the item's ability to perform its safety-related design function, and (3) are currently observable. These attributes were included in the reinspection and documentation review checklists. Detailed instructions were prepared for the verification of each attribute, including definitive accept / reject criteria. Verification checklists and checklist instructions were used by the inspectors and documentation reviewers to perform and to record the results of reinspections and documentation reviews. There were separate checklists and instructions for hardware reinspection and documentation review.
Q.26. Please describe the preparation of the verification packages.
A.26. Verification packages containing applicable checklists and other information were assembled for each sample item to facilitate the performance and recording of the results of visual reinspections and documentation reviews. Each verification package had a unique identifying number and an index listing the contents of the package.
Q.27. Please explain how the CSR reinspections were performed.
A.27. Qualified inspection personnel used verification packages and checklist instructions to perform reinspections and documentation reviews and to document the results. The inspectors verified that the sample item conformed with the current design documentation for each attribute on the checklist. Any attribute inspection a'g 19
a check to determine the acceptability or rejectability of an item was termed an " inspection point." Thus, the inspection of each '
1 sample item included multiple inspection points.
If the condition of an installed item apparently differed from design requirements, an observation was recorded by the inspector and processed in accordance with an approved procedure. The observation described the item and condition in sufficient detail, attaching sketches or other pertinent information, to enable processing in accordance with the procedure. (Reinspections of the 10 additional more-highly- stressed items in the cable pan hanger category were generally limited to the more-highly-stressed portions of the items.) Mr. Shevlin's and Mr. Wozniak's testimonies describe the inspection activities in the electrical construction categories in more detail.
Q.28. What is your opinion as to the adequacy of the CSR inspections of electrical construction categories?
A.28. In my opinion, the CSR inspections of electrical construction categories were adequate.
Q.29. What is the basis for that opinion?
A.29. My opinion in this respect is based on the manner in which the i BCAP activities were organized and conducted. The BCAP Task Force inspectors were highly experienced. They were specifically I
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. i trained in the BCAP procedures and certified under the Commonwealth Edison Company Quality Assurance Program. The inspectors were provided written checklists and instructions prepared by the BCAP Task Force engineering staff and reviewed and
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concurred in by the BCAP Quality Assurance group. The inspection activities of the inspectors were overviewed by the BCAP Quality Assurance group through day-to-day surveillance activities and through approximately a 10% over-inspection in the field by a separate group of inspectors working for the BCAP Quality
, Assurance group. Furthermore, the inspection activities of the BCAP inspectors, as well as the BCAP QA group inspectors, were over-inspected on a sample basis by inspectors working for the IEOG. With all these checks and overchecks, I am very confident that the final product of the CSR inspections was adequate.
i Q.30. Are you aware of any NRC Staff items of noncompliance or concerns relating to the adequacy of the CSR electrical inspections?
Q.30. I am not aware of any NRC Staff item of non-compliance relating to the adequacy of the CSR electrical inspections.
1 In early phases of the program, the NRC resident inspector reviewed checklists and instruction for reinspections and made comments which were subsequently resolved to his satisfaction. In i l
January 1985, NRC resident inspector, based on his own I overinspections and overinspections by ERC inspectors (working on 1
6 behalf of IEOG) in the area of electrical conduit hangers, indicated a concern that CSR reinspections were not adequately identifying construction deficiencies. These concerns were documented by the NRC inspector as an unresolved item in Inspection Report 85-02 and by ERC in its observation number 11 and are discussed in Mr. Wozniak's testimony. In response to ERC observation number 11, the reinspections on conduit hangers were temporarily suspended. We then thoroughly reviewed in a training session with the inspectors, the checklist and instructions applicable to this category, to assure that there were no areas of misunderstanding. The instructions were revised as necessary.
All conduit hangers reinspections completed prior to the temporary suspension, were repeated and corrections made as necessary. A second feedback cum training session was held with the inspectors to disseminate the results of the repeat reinspections before the reinspections were resumed. These corrective actions were reviewed by the NRC Staff and were found to be satisfactory in Inspection Report 86-03.
l Q.31. Please describe the process by which CSR reinspection observations were reviewed for validity.
A.31. All CSR reinspection observations reported by the BCAP Task Force )
inspectors were reviewed by the BCAP Task Force engineering l i
staff. Each observation was evaluated to determine if it represented a valid construction discrepancy not previously 1
identified. An observation was considered invalid if it pertained to a construction discrepancy previously identified and addressed by CECO or its contractors on an existing nonconformance report (NCR) or other controlled system. Conditions that were in accordance with design documents at the time of the original inspection were also considered as not valid. If the evaluation showed that the observation was not a valid construction discrepancy, the reason for this determination was documented and l the observation was considered closed.
Observations that did not pertain to the items included in the CSR sample or identified conditions that did not relate to design-significant attributes as identified in the CSR checklists were considered outside the CSR scope. In addition, because the objective of the CSR was to look for previously unidentified design-significant construction problems, observations which pertained to conditions addressed prior to the CSR through existing procedures or other documented plans for future construction completion activities were also considered outside the CSR scope.
It was our policy that any time ~an observation was determined to be invalid it was routed back to the inspector who originally conducted the inspection, for his acknowledgment, concurrence, or comments. This assured a feedback to the inspector for his use in future inspection activities and also provided an opportunity to
the inspector to record his views should the inspector believe that the invalidation was inappropriate. All observations that were considered invalid were also reviewed and concurred in by the BCAP QA group independent of the BCAP Task Force.
Q.32. Were there any cases in which a BCAP Task Force inspector refused to concur in the invalidation of a reinspection observation relating to any electrical construction category?
A.32. Yes, there were a few instances where the BCAP Task Force inspector refused to concur in the invalidation of an observation in the electrical construction categories. Only one pertained to reinspection of a hardware condition. All others pertained to documentation.
I The one reinspection related observation pertained to the location of a fuse mounting in an electrical switchgear cubicle. The mounting was shown on the drawing pictorially but without specific dimensions. The inspector recorded the location of the fuse mounting in the field, which did not seem to him to agree with the l
drawing, as an observation. Investigation by BCAP Task Force engineers indicated that the fuse mounting was intended to be !
l generally identified on the drawing but the exact location was to be determined during field installation. The BCAP Task Force engineers believed that the condition in the field was not in
, conflict with the drawing. The inspector disagreed. The BCAP procedures provided for a review of such instances by a committee l
including the cognizant BCAP" assistant director. In virtually all cases this committee also included the BCAP lead inspector for that discipline. This committee made a written recommendation for the final disposition of the observation in question to the director, that is myself, for a final decision. I determined that this observation was invalid.
Q.33. Are you aware of any NRC Staff concerns relating to the invalidation of any CSR reinspection observation relating to the electrical construction categories?
A.33. In January 1985, as documented in Inspection Report 85-02, the NRC inspector raised a concern with respect to the architect engi-neer's recommendations for invalidating certain observations.
This concern was resolved by instituting a 100% overview of all invalidations by BCAP QA. The NRC Staff found this resolution to be satisfactory, as documented in Inspection Report 86-03.
Q.34. Please describe the process by which valid reinspection observations were reviewed for design significance.
A.34. Reinspection observations that were considered valid were called discrepancies. Each such reinspection discrepancy was forwarded to the architect engineer for a review to determine whether the discrepancy was design significant. The actual evaluation for design significance was carried out by the architect engineer and i
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the results of that assessment were returned to the BCAP Task l l
Force. The BCAP Task Force Engineering Staff made a general review and concurred with the overall approach taken and the methodology used by the architect engineer in its assessments of the discrepancy for design significance. Additional details on how these evaluations for design significance were performed by the architect engineer can be found in Mr. Thorsell's and Mr. Kostal's testimonies.
Q.35. According to Mr. Thorsell's testimony, no design significance ,
evaluations were performed as part of the CSR for reinspection observations relating to objective attributes of cable pan hangers. Why not?
A.35. As I stated in response to Question 10 the CSR reinspections were designed to indicate whether there are any previously unidentified or unaddressed programmatic design significant problems in the construction of the plant. Thus observation which pertained to conditions addressed independent of the CSR through existing procedures or other documented plans for construction completion activities were considered outside the CSR scope.
Problems with respect to objective attributes of cable pan hangers (i.e., configuration) had been previously identified independent of the CSR. Commonwealth Edison NCRs (numbers 708,709) had been written to document this concern. There was also the knowledge i
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l that a similar problem had been identified at Byron which was resolved by a walkdown, and that a similar walkdown of cable pan j hangers was planned to be implemented at Braidwood.
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l However, at the time the BCAP Task Force was ready to initiate the
! reinspection work on cable pan hangers, the detailed procedure for
! implementation of the corrective action to resolve the NCRs had l not been completed. In the absence of this objective evidence, the BCAP Task Force as a conservative approach, included the caole pan hanger objective attributes in the inspection checklist and conducted the corresponding inspections.
During the period that the CSR effort was proceeding, the i
procedure showing implementation of the corrective action on NCRs l
708 and 709 was completed. The contents of this procedure showed that the planned walkdown inspections for configuration of cable pan hangers would adequately cover the objective attributes and, as such, the objective attribute for cable pan hanger could appropriately be considered out-of-scope of the CSR. Thus an evaluation of these observations for design signific'ance was not required for purposes of the CSR.
l Q.36. How were the results of the CSR engineering evaluations classified?
A.36. Based on the results of the engineering evaluation by the i
Architect Engineer, reinspection discrepancies were categorized as follows:
Discrepancies which impaired the item's ability to perform its safety-related design function were classified as " design- )
significant". Any discrepancy for which it was shown by engineering evaluation that code-required design margins were maintained, and code design criteria and equipment functional requirements were met, was not considered to be design significant.
Discrepancies which reduced the item's capacity by 10% or more but did not impair the item's ability to perform its safety-related design function were termed " notable". Discrepancies of this type include undersized plate washers, incorrect junction box mounting details, and incorrect member location.
Discrepancies which reduced the item's capacity by less than 10%
and did not impair its ability to perform its safety-related design function were categorized as " insignificant". Examples of insignificant discrepancies include cosmetic defects, minor weld defects, the presence of additional parts such as spacer plates or washers, and a missing segregation code label on a conduit.
I Q.37. What were the CSR results for the electrical construction categories?
A.37. The bottom line result of the CSR for the electrical construction
~ categories is that there were no design significant discre-pancies. The detailed CSR resuls are tabulated in Attachment 2C (Kaushal-3).
4
! I Q.38 Why was the term " notable" used to describe certain non-design i significant discrepancies?
A.38. While none of the discrepancies was found to be design significant, further evaluation of the discrepancies was performed 4
to fulfill commitment to identify "significant conditions adverse to quality". The goal was to identify through the exercise of sound engineering judgment any areas of construction where additional efforts would further increase confidence that no unidentified design significant discrepancies exist in the uninspected portion of the plant. For this purpose, the discrepancies were divided into two groups, namely insignificant and notable. Those discrepancies which affected an item's i capacity to perform its intended safety related function by less than 10% were termed insignificant. Those discrepancies which affected the item's capacity to perform its intended safety related function by more than 10% were termed notable. The nature and frequency of the notable dispancies in each construction category were then reviewed to identify those areas of construction where additional efforts following the conclusion of the BCAP would further increase confidence that no design
!. significant discrepancies existed in unreinspected work.
l l
I Q.39. Did the CSR identify any attributes in the electrical area for which follow-up action was recommended?
1
a l
A.39. Out of the six construction categories in the electrical area there were two specific attributes in two different construction categories for which follow-up action.was recommended. The first pertained to the attachment of conduit to the conduit hangers. In a few instances, the conduit was found not to be properly attached to the appropriate hanger. The second attribute pertained to the beam stiffeners at the point of electrical junction box support' installation. In a few cases the stiffeners were missing. While these discrepancies were discovered in the course of reinspecting electrical equipment installation, this portion of the work was and is really in the scope of Gust K. Newberg.
The BCAP Task Force concluded that while the specific discrepancies identified by the CSR were not design significant and while the likelihood of finding a design significant discrepancy was small, nevertheless follow up actions to assure that all conduits are properly attached to the appropriate hanger and beam stiffeners for electrical junction box supports are present, would enhance confidence that no design significant discrepancies exist in the uninspected portion of these construction categories.
Since the completion of the CSR effort, walkdowns to identify any discrepant conditions with respect to conduit attachments and field work to correct discrepant conditions have essentially been 1
completed. The walkdowns and filed work to identify and correct the discrepant conditions with respect to beam stiffereness are in progress.
The occurence of these two types of discrepancies does not neces-sarily indicate that the related L.K. Comstock QC inspections were inadequate. With respect to conduit attachments, it is possible that some of the conduit attachments were disturbed in the course of construction work subsequent to the original QC inspections.
With respect to junction box support beam stiffeners, the L.K.
Comstock QC inspectors did not have responsibility for verifying the presence of the stiffeners. These stiffeners were to be installed and QC accepted by Gust K. Newberg. (The probable cause of these discrepancies was a failure by L.K. Comstock engineering to notify Gust K. Newberg that such stiffeners were required.)
Q.40. Were there any other CSR findings which were recurring in nature, but for which follow up action was not recommended?
A.40. Yes. There were a few types of discrepancies which occurred repetitively but for which no follow up action was specifically recommended. These were the types of discrepancies which by their nature were considered not likely to result in a design significant discrepancy. For example, the Task Force found that some of the segregation code labels on safety related conduits and cable trays were missing or damaged. These conduit and cable tray i
1 labels could well have been damaged or removed during construction l 1
activity subsequent to original QC inspection and acceptance.
While it is desirable and a regulatory expectation that such labels be in place, the Task Force believed that the presence or absence of the segregation code label does not have the potential for resulting in a design significant discrepancy.
Another discrepancy which occured repetitively involved the compression nuts on the flexible conduit connector fittings, which were found to be hand-tight rather than wrench-tight. Analysis by the architect-engineer showed that the lack of wrench-tightening of the compression nut is not design significant. Hence, no specific follow up action was recommended by the BCAP Task Force.
Based on a review of the pertinent construction procedure, the BCAP Task Force also concluded that the probable cause of this type of discrepancy was a deficiency in this procedure, which has since been corrected.
In a few cases two out of four specified hanger-to-cable pan hold down welds were found to be missing. Only a small fraction of the hanger-to-cable pan attachments in the plant require four hold down welds; in most cases only two hold down welds are specified.
This suggests that the craft and the QC inspectors installed and accepted two welds (where four were called for) out of habit.
Based on the architect engineer's evaluation it was concluded that
there was sufficient margin in the design that even if two out. of the four specified welds are always missing, the cable pan to hanger attachment will perform satisfactorily.
While there were a number of notable discrepancies related to welds being undersized, such discrepancies are considered unlikely to be design significant, based on architect engineer's evaluation of the margins in the design. Hence, no specific followup correc-tive action was recommended with respect to undersize welds.
Q.41. What conclusion do you draw from the results of the CSR reinspections with respect to the adequacy of the electrical contractors' work at Braidwood?
A.41. In.as much as the CSR did not identify any design significant discrepancies in the sample of electrical work reinspected, I conclude that the quality of the electrical contractors' work at Braidwood is adequate.
Q.42. Since the cut off date for the CSR was June 30, 1984, what inference, if any, can be drawn from the results of the CSR with respect to the adequacy of the electrical contractor's work after June 30, 1984?
A.42. Inasmuch as the quality of the construction work is a product of the overall system in place, I would conclude that the overall quality program was effective in assuring that the quality of the
electrical contractors' work at Braidwood completed prior to June 30, 1984 is adequate. Assuming that the quality program that was in effect prior to June 30, 1984 and resulted in construction of adequate quality has continued without significant adverse changes since June 30, 1984, I would conclude ~that the quality of the electrical contractor's construction work has continued to be adequate since June 30, 1984.
Q.43. Do you have an opinion whether the alleged harassment and intimidation of Comstock QC inspectors got better or worse after June 30, 19847 A.43. No. I am not familiar with the claims of harassment and intimidation which have been made in this proceeding.
Q.44. Was CSR data collected and provided to Mr. Del George and Dr. Frankel for the purpose of evaluating Comstock QC inspector performance over time?
A 44. Yes. Attachment 2C (Kaushal-4) is a computer printout of the data provided to Mr. Del George and Dr. Frankel.
Q.45. How was that data assembled?
A.45. For each electrical item . inspected under the CSR, the L.K.
Comstock inspectors who performed the original QC inspections were identified. For each of these inspections, the date on which the item was QC accepted, the number of inspection points comprised in l-
1 the inspection and the number of discrepant inspection points observed through CSR inspections were all compiled into a data base.
Q.46. Was the data provided to Mr. Del George and Dr. Frankel accurate?
l A.46. Yes. While the detailed work to compile the data for this purpose was done by others, under the direction of Mr. George Orlov, who was the Assistant Director for CSR under me, I personally
- spot-checked the data to assure myself that it is accurate.
1
?
I Q.47. Does this conclude your testimony?
A.47. Yes.
9 l
a 4
l l
BCAP CSR ELECTRICAL REINSPECTION SAMPLE Safe Shutdown '
j Systems j
/
ENGIEERING/JUDGEENT
/
/ Additional
- Random p
i i
NORE HI6ftY STRESSED RANDON SAMPLE I
Total Population
( Not to Scale )
\ (
. 2 '
o ATTACHMENT 2C (KAUSHAL-2) l SAMPLES Number or Eno ineerino J3rd_que_n_t Construction Population (Safe Shutdown M.H.S.
_ Category items Random __ _.[Randomi & ECCS) Only TOTAL Conduits 2,828 61 30 31 0 122 Conduit Hangers 10,676 72 30 31 0 133 Cables 2,722 60 30 30 0 120 Cable Pans 893 60 15 15 0 90 Cable Pan Hange r 3,769 60 30 30 10 130 E lect rica l Equipment Installation _ .1. 83L1 30 3_Q 26 J 131 TOTAL .22.731 211 161 163 ,_1.Q 13J
_ .. ._ _ _ _ _ _ . _ . _ _ . _ . . . _ . . . _. _ . _ _ _ _ . . . ~ _._ __ < _ _. . . -_.- - ---
ge s o
J i
ATTACHMENT 2C ( KAUSHAL-3 )
t I
CSR Reinspection Results For Electrical Construction Categories 1
i i Total Notable Design Construction Population Total Inspection insignificant D i sc repanc ies Significant j
Ca tego ry Size Reinspected Points pisc_repanc ies (1) Discrepancies 1
Conduits 2,828 122 5.800 136 10 (0.17) O 1
Conduit Hangers 10,676 133 32,700 193 96 (0.29) 0 -
i Cables 2,722 120 20,100 318 0 (0.00) O Cable Pans 893 90 30,400 262 25 (0.08) O Cable Pan Ha nge r 3,769 130 129,000 1100 469 (0.36) O Electrical Equipment I nsta l la t ion 1.841 13A JLOQQ 471 495 (0.85) Q i TOTAL 22.731 211 276.09_Q 2.480 1.095 (0.40) Q l
I i
e
- . _ - _ _ _ - - _ - . _ -_ e- -
Attachment 2C (Kaushal-4) it
j 26-Jul-86. CSR DATA BASE: LKC INSPECTOR 2N1TIALS PAGE 1 INITIALS INSPECTOR AD DAVIS. AN HONY AG GONZALES, ALBERT BAR ROBBINS. BF2D A.
BEB BROWN, BRUCE E.
CJP PIPIS, CHARLES J.
CMG GERRISH, CHARLES M.
CNT TYLER, CHUCK CT TURNER, CHRISTINA DB BARKER, DAVE DC COSS, DON DGC CRISPINO, DONALD G.
DJA ASMUSSEN, DANIEL J.
DJF FREY, DONALD J.
DJS SOBERSKI, DAVID J.
DKW WARD, DENNIS K.
DLP PETERSUN, DEAN L.
DN NORMAN, DODY DP PARKS, DAVID DRH HOLLEY, DANNY R.
DS SCHIRMED, DONALD DT THOMAS, DAVID ERB BRODDE, E. R.
FJR ROLAN, FRANCISCO J.
GF FREIMARK, GLENN GGN NEMETH, GEORGE G.
GY YOUNG, G.
HWS STOUT, HERSCHEL W.
IFD DEWALD, IRVING F.
JAM MINER, JOHN A.
JBH HANNAH, J. B.
JLL LOBUE, JANET L.
JMH HALL, JAMES M.
JPH HII, JOSEPH PAUL JTR ROMAN, JOHN T.
JVW WALTERS, JOHN V.
JWN NOLKER, J. WILLIAM KK KDEHLING, HURT KK2 KRUG, KEN KLB BUSHUE, KEVIN L.
KMC CONNER, KEVIN M.
KW WILLIAMS, HERMIT LAP PERRYMAN, LAWRENCE A.
LKB BOSSONG, LARRY K.
LMB BOHM, L.M.
LOW WALKER, LORI O.
LP PHILLIPS, LARRY MAK KLACHKE, MARK MDL LECHNER, MICHAEL D.
MEW WALKER, MICHAEL E.
MH HELLMER, MATTHEW MK KAST, M.
MLB BLAKE, MIKE MM MUSTERED, MIKE MPW WYNTER, MICHAEL P.
D 252
26-Jul-86 CSR DATA BASE: LKC INSPECTOR INITIALS PAGE 2 INITIALS INSPECTOR MSS SPROULL, MYRA S.
NK KIMBLE, NORMAN NPC CONNER. NORMAN P.
RAG GALLICK, RICHARD A.
RAP PATEY, ROBERT A.
RAS S'i1 ELDS, ROBERT A.
RLF RISBY, RODNEY L.
RLM MARTIN, RIC.,ARD L.
RLW WICKS, ROBERT L.
RM5 SAKLAK, RICHARD M.
RY YANKETIS. RICK SAS SCOTT, STEVEN A.
SBD DOOLEY, SHAWN B.
SL LOBUE, STEVEN THS STEWART, TIMOTHY H.
TLB BOWMAN. THERMAN L.
TLG GORMAN, TERRY L.
TMD DUNBAR, THOMAS TML LESH, THOMAS M.
TS SIEBARTH, TERRY TWZ ZYCH, THOMAS W.
WCB BISSETT, WILLIAM C.
WJB BAXTER. WILLIAM J.
WJH HUTSON, WILLIAM J.
WW WILCO /, WILLIAM e
R000253
_ ~ _ _ _
, 26-Jul-85 CSR REINSPECTION RESULTS FOR LHC PAGE 1 a
- ITEM R INSP DATE ATT IP DP WI WD 1 CEL-OO2 R FJR 16-Jun-82 P 302 O O O 2 CBL-OO2 R NK 16-Sep-82 T 40 0 0 0 3 CBL-OO2 R NK 12-Jul-82 T 40 1 O O 4'CEL-OO3 R MSS 22 reb-84 T 26 0 0 0 5 CBL-OO3 R TS 03-Feb-84 P 84 0 0 0
? 6 CBL-OO3 R MSS 16-Feb-84 T 26 O O O 7 CBL-OO4 R GF 15-Aug-83 P 93 1 O O 8 CBL-OO4 R DS 12-Sep-83 T 45 O O O 9 CBL-OO4 R DS 18-Aug-83 7 45 0 0 0 10 CBL-OO5 R FJR 10-Mar-82 P 232 O O O 11 CBL-OO5 R NK 21-Feb-84 T 30 0 0 0 12 CBL-OO5 R NK 24-Feb-84 T 30 0 0 0 I
13 CBL-OO6 R TS 19-Mar-84 P 111 O O O 14 CBL-OO6 R MSS 07-Jun-84 T 100 0 0 0 15 CBL-OO6 R NK 06-Apr-84 T 100 2 O O 16 CBL-OO7 R GF 25-May-83 P 36 O O O 17 CBL-OO7 R JMH 07-Jun-83 T 11 O O O 18 CBL-OO7 R DS 29-Jul-83 T 11 O O O.
19 CBL-OO8 R NK 17-Feb-84 T 35 0 0 0 20 CBL-OO8 R NK 08-Mar-84 T 35 0 0 0 21 CBL-OOB R MDL 06-Jan-84 P 120 1 O O 22 CBL-OO9 R DS 14-Jul-82 T 16 O O O 23 CBL-OO9 R FJR 14-Jul-8E P 62 2 O O 24 CEL-OO9 R DS 21-Jul-82 T 16 0 0 0 25 CBL-010 R DS 15-Oct-83 T 25 0 0 0 26 CEL-010 R JLL 09-May-83 P 267 2 O O
- 27 CBL-010 R DS 24-Feb-83 T 25 0 0 0 28 CBL-011 R KMC 11-Apr-84 T 40 0 0 0 29 CBL-011 R TS 06-Feb-84 P 98 3 0 0 30 CBL-011 R NK 05-Mar-84 T 40 0 0 0 31 CBL-012 R NK 30-Jun-83 T 10 0 0 0 32 CBL-012 R FJR 24-Feb-83 P 89 0 0 0 33 CBL-012 R DS 13-Jul-83 T 10 0 0 0 34 CEL-013 R NK 15-Dec-82 T 10 0 0 0 35 CBL-013 R FJR 27-Oct-82 P 115 3 0 0
, 36 CBL-013 R NK 05-May-83 T 10 0 0 0 37 CBL-014 R FJR 04-Mar-83 P 60 0 0 0 38 CBL-014 R KMC 08-May-84 T 10 0 0 0
. 39 CBL-014 R KMC 08-May-84 T 10 0 0 0 40 CBL-015 R DS 08-Mar-82 T 20 0 0 0 41 CBL-015 R FJR 24-Feb-82 P 134 1 O O 42 CEL-015 R NK 11-May-84 T 20 0 0 0 43 CBL-016 R DS 08-Mar-82 T 55 O O O 44 CBL-016 R JMH 15-Feb-82 P 206 0 0 0 55 45 CBL-016 R NK 26-Apr-83 T 0 0 0 46 CBL-017 R NK 11-Oct-83 T 30 6 0 0 47 CBL-017 R NK 03-Apr-84 T 30 0 0 0 48 CBL-017 R JMH 30-Mar-83 P 62 4 O O 49 CBL-018 R DS 07-Apr-83 T 60 0 0 0 50 CBL-018 R NK 01-Dec-83 T 60 3 0 0 51 CEL-018 R FJR 11-Mar-83 P 83 0 0 0 52 CBL-019 R DS 26-Feb-82 T 40 0 0 0 53 CBL-019 R FJR 12-Feb-82 F 193 0 0 0 54 CBL-019 R DS 19-Mar-82 T 40 0 0 0 55 CBL-020 R DS 11-Apr-83 T 35 0 0 0 2000254
Eo-Jul-86 CSR REINSPECTION RESUL S FOR LKC CAGE 2 t
. # ITEM R INS: DATE ATT IA . DF WI WD
, 36 CBL-020 R KMC 09-Apr-84 T 2: O O O 1 5 7 CB -020 R NK O2-M+r-83 P 77 O O O 58 CBL-021 R aMH 11-Apr~si P 184 42 0 0 50 CBu-021 R h 21-Jul-63 T 40 0 C 0
, 60 CFL-021 b MDL 30-Jun-63 T 40 0 C 0 61 CBL-022 R NK 28-Jan-62 P ES 1 O O 62 CBL-022 R DS 06-Jan-82 T 2C 5 O O 63 CBL-022 R DS 16-Jun-82 T 20 0 0 0 64 CBL-023 R DS 27-Jun-53 T 13 0 0 0 65 CBL-023 F JMH 21-Apr-83 P 82 O O O 66 CBL-023 R DS 15-Jul-83 T 13 0 0 0 67 CBL-024 R FJR 11 sul-82 P 51 2 O O l 68 CBL-024 R NK 20-Sep-83 T 25 0 0 0 i 69 CBL-024 R NK 30-Jul-82 T 25 0 0 0 I 70 CBL-025 R NK 15-Jul-83 T 10 0 0 0 4
71 CBL-025 R NK 15-Apr-83 T 10 0 0 0 72 CEL-025 R MDL 07-Apr-83 P 123 O O O 73 CBL-026 R FJR 12-Jul-82 P 264 0 0 0 74 CBL-026 R KMC 10-May-84 T 45 0 0 0 75 CBL-026 R DS 05-Aug-82 T 45 0 0 0 76 CBL-027 R JMH 13-Nov-81 P 121 O O O 4
77 CEL-027 R DS O2-Dec-81 T 10 0 0 0 78 CBL-027 R DS 19-Nov-51 T 10 0 0 0
- 79 CBL-OES R DS 14-Mar-82 T 35 O O O 80 CBL-028 R MSS 17-Feb-82 .P 330 0 0 0 81 CBL-026 R D5 19-Mar-82 T 35 0 0 0 82 CBL-029 R MLL 03-Nov-83 T 10 0 0 0 l 83 CBL-029 R KMC 10-hey-84 T 10 0 0 0 84 CBL-029 R JMH 17-Mar-83 P 93 1 O O 85 CEL-030 R MDL 19-Oct-83 T 20 0 0 0 86 CBL-030 R JMH 14-Jul-82 P 231 2 O O
! 87 CBL-030 R DS 27-Aug-82 T 20 0 0 0 88 CBL-031 R NK 19-Apr-84 T 23 0 0 0 89 CBL-031 R JMH 30-Dec-82 P 54 2 O O 90 CBL-031 R NK 05-Mar-83 T 23 0 0 0 91 CBL-032 R MDL 20-Feb-64 P 25 0 0 0 92 CBL-032 R MSS 24-Feb-84 T 10 0 0 0 92 CBL-032 R MSS 19-Apr-84 T 10 0 0 0
, 94 CBL-033 R DS O2-Dec-83 T 25 0 0 0
)
95 CBL-033 R MDL 07-Nov-83 P 204 0 0 0 96 CBL-033 R DS 12-Apr-83 T 25 O O O 97 CBL-034 R NK 14-Feb-83 T 1 O O O 98 CBL-034 R FJR 22-Jan-82 P 175 4 0 0 99 CBL-034 R DS 14-Nov-83 T 1 O O O 100 CBL-035 R DS 11-Aug-83 T 10 0 0 0
! 101 CBL-035 R NK 01-Feb-84 T 10 0 0 0 102 CBL-035 R FJR 04-Aug-83 P 27 O O O i 103 CBL-036 R NK 06-Oct-82 T 35 0 0 0 104 CBL-036 R JLL 21-Sep-82 P 130 0 0 0 105 CBL-036 R NK 27-Sep-83 T 35 0 0 0 106 CBL-037 R NK 14-Jul-83 T 20 0 0 0 107 CBL-037 R DS 14-Jul-83 T 20 0 0 0 108 CBL-037 R FJR 21-Jun-33 P 141 1 O O l 109 CBL-038 R DS 22-Jun-83 T 132 O O O 110 CBL-038 R JMH 18-May-83 P 60 0 0 0 AR600:55
\ 26-Jul-86 CSR REINSPECTION RESULTS FOR LvC PAGE 3 I
\ l i
- ITEM R INSP DATE ATT IP DP WI WD 111 CEL-038 R MSS 25-Jar-84 T 132 O O O 112 CBL-039 R TS 06-Jcn-84 P 45 0 0 0 113 CF.-03c R NK 12-Jan~54 T i2 3 O C 114 CBL-039 R DS 17.~. a n-84 ?
13 3 0 0 115 CEL-040 R b_B 12-Nov-83 F 38 1 O O I 116 CBL-040 9 DC 22-Dec-83 T 6 O C O
, 117 CEL-040 R DS O2-Feb-64 T 6 1 O O f
118 CBL-041 9 NK 18-J u l-83 T 15 0 0 0 119 CSL-041 R MDL 31-May-83 P 49 0 0 0 120 Cbt-041 R JMH 07-Jun-83 T 15 0 0 0 121 CBL-042 R JTR 11-Feb-83 P 149 0 0 0 122 CBL-042 R KMC 21-Mar-84 T 10 0 0 0 123 CBL-042 R DS 24-Feb-84 T 10 0 0 0 124 CBL-043 R KMC 08-May-84 T 35 0 0 0
- 125 CBL-043 R JMH 20-Apr-83 P 96 0 0 0 126 CBL-043 R JMH 13-Dec-82 T 35 0 0 0 127 CBL-044 R NK 23-Mar-83 T 15 0 0 0 l; 128 CBL-044 R NK 11-Apr-83 T 15 0 0 0
'29 CBL-044 R MSS O2-Mar-83 P 35 0 0 O i
130 CBL-045 R GF 18-Dec-83 P 144 0 0 0 131 CBL-045 R NK 19-Jan-84 T 25 0 0 0 132 CBL-045 R NK 27-Dec-83 T 25 O O O j 133 CBL-046 R DS 1 1- A p r-83 7 30 9 O O 134 CBL-046 R M55 02-Mar-83 P 48 0 0 0 135 CBL-046 R NK 26-Mar-83 T 30 0 0 0 j 136 CBL-047 R DS 05-Feb-32 T 10 0 0 0 137 CBL-047 R NK 26-Feo-82 T 10 0 0 0 138 CBL-047 R FJR 26-Jan-82 P 96 0 0 0 j 139 CBL-048 R NK 09-Jan-84 P 49 0 0 0 140 CBL-048 R NK 18-Jan-84 T 20 0 0 0 141 CBL-048 R NK 19-Jan-84 T 20 0 0 0 j 142 CBL-049 R FJR 03-May-84 P 47 0 0 0 1 143 CBL-049 R NK 22-May-84 T 22 O O O 1 144 CBL-049 R NK 22-May-84 T 22 2 O O 1
145 CBL-050 R NK 19-Aug-82 T 11 O O O I 146 CBL-050 R DS 23-Nov-83 T 11 3 O O 147 CBL-050 R JMH 13-Oct-81 P 51 4 0 0 148 CBL-051 R JTR 12-Aug-82 P 117 3 0 0 l 149 CBL-051 R DS 27-Aug-82 T 10 0 0 0 1
150 CBL-051 R DS 28-Dec-82 T 10 0 0 0 151 CBL-052 R NK 22-Feb-82 T 20 0 0 0 152 CBL-052 R JMH 12-Feb-82 P 247 0 0 0 1
153 CBL-052 R ERB O2-Mar-82 T 20 0 0 0 154 CBL-053 R GF 27-Jan-84 P 108 1 O O 155 CBL-053 R NK O2-Feb-84 T 10 0 0 0 156 CBL-053 R NK 17-Feb-84 T 10 0 0 0 157 CBL-054 R KMC 08-May-84 T SO O O O
! 158 CBL-054 R MDL 02-May-83 P 154 0 0 0 159 CBL-054 R DS 21-Mar-83 T 50 0 0 0 160 CBL-055 R NK O2-Aug-82 T 10 1 O O 161 CBL-055 R NK O2-Aug-82 T 10 0 0 0 162 CBL-055 R JTR 13-Jul-82 P 106 O O O
- 163 CBL-056 R MDL 29-Jun-83 'T 30 0 0 0 164 CBL-056 R JMH 12-Apr-83 P 158 11 O O 165 CBL-056 R NK 07-May-83 T 30 0 0 0 MMM
., 26-Jul-86 CSR REINSPECTION RE2VLTS FOR LKC FAGE 4
\
- ITEM R INSP 5 DATE ATT IP DP WI WD 166 CBL-057 R FJR 16-Jul-82 P 139 167 CBL-057 0 0 0 R NK 17-Sep-82 T 20 0 0 0 168 CBL-057 R NK 18-Aug-82 T 20 0 164 CBL-058 ; 0 0 NK C3-Nov-82 T 15 O O O 170 CBL-OSS R Me 08-Oct-82 P 233 171 CBL-058 16 0 0 R DS 22-Oct-82 T 15 O O O 172 CBL-050 R RMS 15-Mar-83 .: 233 2 O O 173 CBL-C.39 R FJR 21-Apr-83 T 25 O O 174 CBL-059 R O
KMC 08-May-84 T 25 0 0 0 175 CBL-060 R Nk 05-Jul-83 T 56 0 176 CBL-060 0 0 R DS 30-Apr-84 T 56 O O O 177 CBL-060 R JMH 21-Jun-82 P 134 1 O 178 CBL-061 O R NK 03-Dec-82 T 50 0 0 0
- 179 CEL-061 R JLL 27-Oct-82 P 197 O O O 180 CBL-061 R DS 03-Jan-83 T 50 0 181 CBL-101 0 0 E MSS 26-Jan-84 T 6 O O O 182 CBL-101 E MSS 24-Oct-81 T 6 O 183 CBL-101 O O E MSS 24-Apr-81 P 36 0 0 0 184 CEL-102 E JTR 10-Sep-82 P 112 185 CBL-102 1 O O E DS 11-Jan-83 T 18 1 O O 186 CEL-102 E NK 09-Nov-83 T 18 187 CBL-103 E 1 O O NK 08-Sep-82 T 13 0 0 188 CBL-103 0 E JMH 13-Aug-82 P 68 1 O O 189 CEL-103 E NK 08-Sep-82 T 13 l 190 CBL-104 1 O O E FJR 08-Mar-83 P 83 O i
191 CBL- 104 E O O NK 11-Mar-83 T 18 0 0 0 192 CBL-104 E NK 24-Jan-83 7 18 193 CBL-105 E 1 O O KMC 08-May-84 T 40 0 0 0 194 CBL-105 E NK 03-Dec-83 T 40 195 CBL-105 E 0 0 0 JLL 22-Nov-82 P 105 7 0 0 196 CBL-106 E NK 25-Jan-83 T 18 197 CBL-106 E DS 1 O O 14-Sep-83 T 18 0 198 CBL-106 E JTR 0 0 24-Nov-82 P 98 1 O 199 CBL-107 E JMH 23-Jun-82 P 85 O
200 CBL-107 E 0 0 0 NK 28-Jun-82 T 18 3 0 0 201 CBL-107 E NK E8-Jun-82 T 18 202 CBL-108 E 0 0 0 NK 06-Apr-83 T 203 CBL-108 E MSS 13 0 0 0 25-Apr-84 T 13 0 204 CBL-108 E MSS 0 0 30-Mar-83 P 91 O O O 205 CBL-109 E NK 21-Dec-81 T 16 O 206 CBL-109 E JMH O O 03-Dec-81 P 120 0 0 0 207 CBL-109 E NK 08-Dec-81 T 16 208 CBL-110 E 0 0 0 DS 21-Feb-83 T 17 2 O O 209 CBL-110 E MSS 17-Feb-83 P 85 3 210 CBL-110 E 0 0 1
DS 17-Feb-84 T 17 O O O 211 CBL-111 E DS 31-Dec-82 T 18 212 CBL-111 E 0 0 0 DS 23-Dec-82 T 18 3 .O O 213 CBL-111 E FJR 05-Aug-82 P 114 0 214 CBL-112 E FJR 0 0
! 12-May-83 P 125 1 O O 215 CBL-112 E NH 17-Jun-83 T 16 216 CBL-112 E i O O DS 22-Dec-82 T 16 O O O 217 CBL-113 E FJR 15-Mar-83 P 144 218 CBL-113 E MSS 3 0 0 25-Apr-84 T 25 0 219 CBL-113 E 0 0 NK 20-Jun-84 T 25 1 O O 220 CBL-114 E DS 27-Sep-83 T 13 0 0 0 AR000257
- -^ ..
}
o l
, 26-Jul-8@ CSR REINSPECTION RESULTS FOR LKC PAGE 5 t # ITEM R INSP DATE ATT IP DP WI WD l 221 CBL-114 E DS 07-Apr-83 T 13 0 0 0 222 CBL-114 E MSS 09-Mar-83 P 121 1 O O I 223 CBL-115 E DS OS-Nov-83 T 25 1 O O l 224 CBL-115 E JMH 03-Nov-82 P 110 1 O O 225 CBL-115 E NK 01-Nov-82 T 25 0 0 0 226 CBL-116 E MSS 12-Jan-83 P 81 1 O O 227 CBL-116 E DS 15-Jun-83 T 13 0 0 0 228 CBL-116 E DS 21-Jan-83 T 13 2 O O 229 CBL-117 E MSS 12-Jan-83 P 84 O O O 230 CBL-117 E NK 14-Feb-83 T 35 0 0 0 231 CBL-117 E DS 21-Jan-83 T 35 2 O O 232 CBL-118 E KMC 10-May-84 T 10 0 0 0 233 CBL-118 E DS 07-Jul-83 T 10 2 O O 234 CBL-118 E MDL 02-May-83 P 88 0 0 0 235 CBL-119 E MDL 12-May-83 P 78 0 0 0 236 CBL-119 E DS 17-May-83 T 60 16 0 0 237 CBL-119 E NK 05-Aug-83 T 60 0 0 0 238 CBL-120 E DS 09-Mar-83 T 13 0 0 0 239 CBL-120 E JTR 03-Mar-83 P 70 0 0 0 240 CBL-120 E NH 26-Sep-83 T 13 0 0 0 241 CBL-121 E NK 01-Dec-81 T 18 O O O 242 CBL-121 E JMH 01-Oct-81 P 117 0 0 0 243 CBL- 121 E NK 04-Dec-81 T 18 0 0 0 244 CBL-122 E NK 08-Mar-84 T 17 1 O O 245 CBL-122 E NK 17-Aug-82 T 17 0 0 0 246 CBL-122 E MDL 07-Mar-84 P 108 1 O O 247 CEL-123 E NK 29-Nov-83 T 13 0 0 0 248 CBL-123 E MSS 15-Mar-83 P 72 O O O 249 CBL-123 E DS 30-Jun-83 T 13 0 0 0 250 CBL-124 E NK 13-Jul-82 T 45 0 0 0 251 CBL-124 E JMH 30-Jun-82 P 146 0 0 0 252 CBL-124 E NK 08-Jul-82 T 45 0 0 0 253 CBL-125 E NK 22-Feb-82 T 45 0 0 0 254 CBL-125 E JLL 02-Feb-82 P 137 1 O O 255 CBL-125 E NK 12-Feb-82 T 45 0 0 0 256 CBL-126 E NK 14-Apr-83 T 60 0 0 0 i 257 CBL-126 E DS 21-Nov-83 T 60 0 0 O i 258 CBL-126 E KLB 11-Apr-83 P 85 2 O O l 259 CBL-127 E NK 08-Dec-83 T 40 0 0 0 260 CBL-127 E MSS 16-Feb-82 P 299 4 0 0 261 CBL-127 E NK 18-Mar-82 T 40 0 0 0 262 CBL-128 E DS 16-Jun-84 T 13 0 0 0 263 CBL-128 E JMH 17-Jan-83 P 69 0 0 0 264 CBL-128 E KMC 08-May-84 T 13 0 0 0 265 CBL-129 E NK 10-Oct-83 T 18 1 O O 266 CBL-129 E JMH 21-Jan-83 P 47 4 0 0 267 CBL-129 E NK 27-Jan-83 T 18 O 0 0 268 CBL-130 E NM 10-Oct-83 T 18 3 0 0 269 CBL-130 E NK 27-Jan-83 T 18 O O O 270 CBL-130 E JTR 21-Jan-83 P 45 4 0 0 271 CBL-131 R NK 01-Feb-83 T 41 O O O 272 CBL-131 R JLL 26-Jan-83 P 195 0 0 0 273 CBL-131 R DS 31-May-83 T 41 O O O 274 CBL-132 R KMC 08-May-84 T 10 2 O O 275 CBL-132 R FJR 07-Oct-82 P 96 1 o O 8000258
', 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 6
- ITEM R INSP DATE ATT IF DP WI WD 276 CBL-132 R DS 14-Sep-83 -
10 0 0 0 277 CBL-133 R NK 24-Jan-84 T 10 0 0 0 278 CBL-133 R GF 23-Jan-84 F 44 0 0 0 279 CBL-133 R 05 23-Feb-84 T 10 3 0 0 280 CBL-134 R JMH 03-Dec-82 T 35 0 0 0 281 CBL-134 R NK 12-Nov-83 T 35 7 0 0 262 CBL-134 R FJR 22-Nov-82 P 65 2 O O 283 CBL-135 R MS8 07-Apr-83 P 387 0 0 0 284 CBL-135 R NK 11-May-83 T 45 0 0 .O 285 CBL-135 R DS 14-Jun-83 T 45 0 0 0 286 CBL-136 R DS 30-Aug-83 7 10 0 0 0 287 CBL-136 R DS 30-Aug-83 T 10 0 0 0 288 CBL-136 R THS 13-Jul-83 P 209 0 0 0 289 CBL-137 R MSS 13-Jan-83 P 158 0 0 0 290 CBL-137 R NK 14-Jun-83 T 10 1 O O 291 CBL-137 R NK 09-Dec-83 T 10 0 0 0 292 CBL-138 R DS 11-Mar-82 T 20 1 O O 293 CBL-138 R JLL 03-Feb-82 P 107 1 O O
, 294 CBL-138 R DS 10-May-83 T 20 0 0 0 l
295 CBL-139 R DS 25-Jun-82 T 25 0 0 0 296 CBL-139 R NK O2-Jul-82 T 25 0 0 0 297 CBL-139 R NK 16-Jun-82 P 215 4 0 0 298 CE'L-140 R DS 14-Mar-83 T 66 0 0 0 299 CBL-140 P JTR 04-Mar-83 P 130 1 O O 300 CBL-140 R KMC 08-May-84 T 66 0 0 0 301 CBL-141 R DS 04-Jan-84 T 10 0 0 0 302 CBL-141 R NK 10-Feb-84 T 10 0 0 0 303 CBL-141 R GF 16-Dec-83 P 116 0 0 0 304 CBL- 142 R DS 29-Nov-83 T 5 0 0- O 305 CBL- 142 R DS 20-Dec-83 T 5 0 0 0 306 CBL-142 R KLB 12-Nov-83 P 31 O O O 307 CEL-143 R NK 18-Apr-84 T 10 0 0 0 308 CSL-143 R GF 20-Jan-84 P 61 1 O O 309 CBL-143 R MSS 08-Feb-84 T 10 0 0 0 310 CBL-144 R GF 30-Jan-84 P 139 0 0 0 311 CBL-144 R MSS 08-Feb-84 T 30 0 0 O l 312 CBL-144 R MSS 09-Feb-84 T 30 0 0 0 313 CBL-145 R FJR 22-Apr-83 P 108 7 0 0 1
314 CBL-145 R NK 25-Apr-83 T 25 0 0 0 l 315 CBL-145 R NK 21-Apr-83 T 25 0 0 0 316 CBL-146 R NK 31-Aug-82 T 20 4 O O 317 CBL-146 R JTR 27-Aug-82 P 232 2 O O 318 CBL-146 R NK O2-Sep-82 T 20 0 0 0 319 CBL-147 R MSS 28-Mar-84 T 22 O O O 320 CBL-147 R DS 25-Apr-83 T 22 O O O 321 CBL-147 R MSS 28-Mar-84 P 40 2 O O 322 CBL-148 R MDL 13-Dec-83 P 51 O O O 323 CBL-148 R NK 19-Dec-83 T 15 0 0 0 324 CBL-148 A NK 19-Dec-83 T 15 O O O 325 CBL-149 R NK 05-Nov-82 T 15 O O O 326 CBL-149 R NK 27-Oct-82 T 15 O O O 327 CBL-149 R JMH 08-Oct-82 P 179 16 O O 328 CBL-150 R NK 01-Dec-82 T 40 0 0 0 329 CBL-150 R JMH 29-Oct-82 P 110 0 0 0 j 330 CBL-150 R NK 17-Sep-82 T 40 0 0 0 1
$WhI
26-Jul-85 CSR REINSFECTION RESULTS FOR LKC 5 AGE '
- ITEM R INSP DATE ATT IP DP WI WD 231 CBL- 151 R ES 26-Mer-83 T 20 0 0 0 332 CBL-151 R MSS O2-Mar-83 P 46 0 0 0 333 CBL-151 R D3 Oe-Apr-83 T 20 0 0 0 334 CBL-452 R NK 22-Jun-82 T 10 0 0 0 235 CBL-153 R JMH 09-Jun-82 P 150 'S O O 336 CBL-153 R DS 17-Jun-82 T 10 0 0 0 337 CBL- 04 R DS 23-Mar-83 T 11 O O O 338 CBL-154 R DS 24-Mar-83 T 11 O O O 339 CBL-154 R MSS 11-Mar-83 P 59 1 0 0 340 CBL-155 R MDL 14-Jun-83 P 126 2 O O 341 CBL-155 R NK 30-Jul-82 T 10 0 0 0 342 CBL-155 R NK O2-Aug-82 T 10 0 0 0 343 CBL-156 R DS 23-Apr-83 T 10 0 0 0 344 CBL-156 R FJR 17-Jun-82 P 27 O O O 345 CBL-156 R NK 28-Jun-82 T 10 0 0 0 346 CBL-157 R NK 26-Aug-82 T 60 1 O O >
347 CBL-157 R DS 31-Aug-83 T 60 0 0 0 348 CBL- 157 R MSS 04-Apr-83 P 73 0 0 0 349 CBL-ISS R JTR 09-Aug-82 P 56 O O O 350 CBL-158 R DS 18-Aug-82 T 13 1 O O
".51 CBL- 158 R NK 2e-Aug-83 T 13 0- 0 0 352 CBL-159 R JLL 22-Sep-82 P 224 i O O 353 CBL-159 R NK 30-Sep-82 T 35 0 0 0 -
354 CBL-159 R NK 01-Oct-82 T 35 0 0 0 355 CBL-160 R DS 27-Dec-83 'T 18 1 O O 356 CBL- 160 R DS 12-Sep-83 T 18 0 0 0 357 CBL-160 R FJR 05-Mar-83 P 79 0 0 0 358 CBL- 161 R TS 10-Aug-83 P 61 O O O 359 CBL-161 R DS 15-Aug-87 T 11 O O O 360 CBL-161 R NK 23-Aug-83 T 11 O O O 361 CBP-OO1 R DJS O2-May-83 C 386 3 0 0 451 CBP-OO1 R DRH 19-Aug-83 W 93 0 6 0 362 CBP-OO2 R KLB 21-Jan-83 C 24 0 0 0 452 CBP-OO2 R LHB 04-Apr-84 W 33 0 2 0 363 CBP-OO3 R DJS O2-Sep-83 C 585 5 0 0 453 CBP-OO3 R RLM 11-Sep-81 W 213 0 14 0 364 CEP-OO4 R DJF 18-Aug-83 C 221 4 0 0 454 CBP-OC4 R DJS 10-Oct-83 W 93 0 6 0 455 CBA-OO4 R DB 28-Nov-83 W 93 0 6 0 365 CBP-OO5 R DJF 18-Jan-84 C 255 4 O O 456 CBP-OO5 R CNT 09-Dec-83 W 123 0 8 0 366 CBP-OO6 R HLB 26-Jun-82 C 177 21 O O 457 CBP-OO6 R KH2 19-Jul-82 W 33 0 2 0 367 CBP-OO7 R DJF 18-Jan-84 C 114 3 O O 368 CBP-OO8 R DJF 31-Jan-84 C 402 9 0 0 458 CBP-OO8 R SL 24-Apr-81 W 183 0 12 0 369 CBP-OO9 R DJS 07-Jul-83 C 98 3 0 0 459 CBP-OO9 R SL 02-Jun-81 W 93 0 6 0 370 CBP-010 R DJS 1 1-J u l-83 C 322 3 0 0 460 CBP-010 R SL 02-Jun-81 W 153 0 10 0 461 CBP-010 R IFD 02-Jul-81 W 153 0 10 0 371 CBP-011 R DJS 07-Jul-83 C 21 O O O 462 CBP-011 R SL 02-Jun-81 W 33 0 2 0 372 CBP-012 R DJS 06-Nov-81 C 283 5 0 0 373 CBP-013 R NLB 21-Jan-83 C 286 i O O AR000260
~
j .
. 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 8
- ITEM R INSP DATE ATT' IP DP WI WD 463 CBP-013 R TML 02-Nov-83 W 63 0 4 0 374 CBP-014 R DJS 09-Nov-81 C 25e O O O
- 464 CBF-014 R IFD 04-Jun-81 W 63 2 4 1 -
375 CBP-015 R KLB 07-Jul-82 C 166 0 0 0 l
465 CBF-015 R DLP 31-Mar-84 W 93 0 6 0 l 376 CBP-016 R KLB 26-Jun-82 C 167 0 0 0 466 CBP-01e R RLM 14-Sep-83 W 33 0 2 O i
377 CBP-O'17 R TS 07-May-84 C 108 C 0 0 467 CBP-017 R CT 25-Nov-83 W 153 0 10 0 378 CBP-018 R DJS 12-Mar-82 C 86 2 O O .
468 CBP-018 R MK 09-Feb-81 W 63 0 4 0 379 CBP-019 R DJS 31-Aug-83 C 275 5 0 0 4
469 CBP-019 R RLM 07-Dec-81 W 123 0 8 0 1 380 CBP-020 R TS 06-Dec-83 C 23 0 0 :O
) 470 CBP-020 R DB 19-Nov-83 W 63 0 4 0
! 381 CBP-021 R KLB 21-Jan-83 C 169 0 0 0 382 CBP-022 R FJR 18-May-81 C 331 O O O 383 CBP-023 R DJS 11-Mar-82 C 21 O O O
! 384 CBP-024 R DJF 16-Apr-84 C 53 0 0 0
- 471 CBP-024 R FJR 22-Oct-81 W 33 3 2 1 i
385 CBP-025 R DJS 18-Nov-81 C 84 4 0 0 472 CBP-025 R IFD 02-Jul-81 W 33 0 2 0 j 473 CDP-025 R RLM 12-Nov-81 W 33 0 2 O l 386 CBP-026 R DJF 18-Jan-84 C 107 0 0 0 j 474 CBP-026 R BEB 15-Jul-82 W 123 3 8 2 1
387 CBP-027 R DJF 30-Nov-83 C 24 0 0 0
! 388 CDP-028 R DJF 26-Mar-84 C 532 10 0 0 i 475 CBP-028 R SL 26-Mar-81 W 273 0 18 O j
389 CBP-029 R KLB 25-Oct-82 C 26 2 O O 390 CBP-030 R DJS 31-Aug-83 C 126 0 0 0
, 476 CBP-030 R BEB 09-Mar-84 W 63 0 4 0 j 391 CBP-031 R DJF 08-Dec-83 C 415 4 0 0 477 CBP-031 R FJR 01-Sep-82 W 213 0 14 0 392 CDP-032 R DJS 09-Nov-81 C 238 0 0 0 393 CBP-033 R DJF 16-Feb-84 C 405 2 O O
! 478 CDP-033 R WJH 12-Feb-84 W 123 0 8 0 479 CDP-033 R BEB 14-Apr-83 W 123 0 8 0 i 394 CBP-034 R BEB 08-Sep-82 C 562 4 0 0 i' 480 CDP-034 R IFD 12-Jan-81 W 213 5 14 4 395 CDP-035 R TS 12-Dec-83 C 165 3 0 0 396 CDP-036 R DJS 11-Mar-82 C 161 O O O 1
397 CBP-037 R KLB 08-Sep-42 C 80 6 0 0 398 CDP-038 R DJS 06-Sep-83 C 344 8 0 0 j 481 CDP-038 R RLM 01-Feb-82 W 123 0 8 0 399 CDP-039 R TS 17-Nov-83 C 243 2 O O 482 CDP-039 R KKE 28-Jun-82 W 93 9 6 6 l 400 CBF-040 R DJS 07-Jul-83 C 56 0 .O O '.
j 483 CDP-040 R TLB 23-May-84 W 33 0 2 0
- 401 CSP-041 R TS O2-Nov-83 C 197 4 0 0 1 484 CDP-041 R RLM 29-Jan-82 W 93 3 6 3
! 402 CDP-042 R DJS 12-Jul-83 C 32 O O O 1
485 CDP-042 R IFD 02-Jul-81 W 33 0 2 0
! 403 CDP-043 R DJS 17-Nov-81 C 428 2 O O I 486 CDP-043 R IFD 12-Jan-81 W 93 0 6 0 404 CDP-044 R DJF 09-Feb-84 C 67 4 0 0 MON I
~
26-Jul-86 CSR REINSPECTION RESULTS FOR LHC PAGE 9
- ITEM R INSP DATE ATT IP DP WI WD 487 CBP-044 R DT 20-Jan-82 W 33 0 2 0 488 CEP-044 R FJR 17-Dec-81 W 33 0 2 0 40S CDP-045 R DJF 12-Jan-84 C 320 0 0 0 489 CBP-045 R CNT 30-Nov-83 W 243 0 16 0 406 CDP-046 R TLG 30-Apr-84 C 20 0 0 0 407 CBP-047 R DJF 28-Dec-83 C 164 0 0 0 408 CEP-048 R DJF 10-Feb-84 C 303 7 O O 490 CBP-048 R IFC 11-Jun-81 W 138 0 9 0 491 CBP-048 R BEB 15-Jul-82 W 138 0 9 0 492 CBP-048 R SL 26-May-81 W 138 0 9 0 409 CBP-049 R DJS 22-Jun-82 C 61 O O O 493 CBP-049 R RLM 01-Feb-82 W 33 0 2 0 410 CBP-OSO R BEB 10-Mar-82 C 836 0 0 0 494 CBP-050 R BEB 08-Jul-82 W 243 0 16 0 411 CDP-051 R DJS 11-Mar-82 C 327 2 O O 495 CBP-051 R IFD 02-Dec-80 W 213 0 14 0 412 CBP-052 R DJF 16-Apr-84 C 166 0 0 0 496 CBP-052 R DLP 17-Mar-84 W 63 1 4 1 497 CBP-052 R FJR 17-Dec-81 W 63 1 4 1 413 CBP-053 R DJS 08-Jul-83 C 99 0 0 0 498 CBP-053 R TLB 23-May-84 W 33 1 2 1 414 CBP-054 R DJS 11-Mar-82 C 28 O O O 499 CBP-054 R IFD 03-Dec-80 W 63 0 4 0 415 CDP-055 R MK 17-Nov-81 C 21 O O O 500 CEP-055 R RAP 30-Aug-84 44 33 0 2 0 416 CBP-056 R DJF 29-Aug-83 C 122 O O O 501 CBF-056 R MH 29-Nov-83 W 33 0 2 0 417 CBP-057 R DJF 10-Feb-84 C 264 0 0 0 502 CDP-057 R IFD 17-Apr-81 W 153 0 10 0 418 CBP-058 P DJS 05-Oct-81 C 180 0 0 0 503 CBP-058 R IFD 26-Mar-81 W 123 0 8 0 419 CBP-059 R KLB O2-Jul-82 C 288 0 0 0 420 CBP-060 R DJS 28-Sep-81 C 144 0 0 0 421 CBP- 101 E DJF 13-Dec-83 C 176 2 O O 504 CBP-101 E SL 04-Jun-81 W 93 0 6 0 422 CDP-102 E DJS 22-Jun-82 C 154 0 0 0 423 CBP-103 E DJF 06-Mar-84 C 258 2 O O SOS CBP-103 E DRH 26-Oct-82 W 153 0 10 0 506 CBP-103 E HK2 15-Dec-82 W 153 0 10 0 507 CDP-103 E MH 23-Apr-81 W 153 0 10 0 424 CBP-104 E DJS 12-Jul-82 C 882 5 O O 508 CBP-104 E HK2 12-Jul-82 W 243 0 16 0 425 CBP-105 E TS 09-Jun-84 C 552 2 O O 509 CDP-105 E SL 03-Jun-82 W 198 7 13 7 426 CBP-106 E MEW 04-Jun-84 C 274 5 0 0 510 CBP-106 E MAK 26-Oct-82 W 213 1 14 1 511 CDP-106 E CMG 20-Apr-84 W 213 1 14 1 427 CBP-107 E TS 14-Nov-83 C 196 3 0 0 512 CBo-107 E MK 04-Dec-80 W 183 0 12 0 428 CEs-108 E FJR 30-Jun-81 C 938 4 0 0 513 CL -108 E BEB 06-Dec-82 W 213 4 14 4 514 CBP-108 E RLM 10-Oct-81 W 213 4 14 4 429 CDP-109 E DJS O2-Sep-83 C 459 1 O O 430 CDP-110 E DJS O2-Sep-83 C 345 2 O O 515 CBP-110 E RLM 01-Jul-82 W 123 0 8 O AR0002E43
. 26-Jul-8e CSR REINSPECTION RESULTS FOR LKC PAGE to
- ITEM R INSP DATE AT~ IP DP W1 WD 431 CBP-111 E DJF 10-Feb-84 C 105 0 0 0 51e CBD-111 E SL 26-May-61 W 93 0 6 0 517 CEP-111 E IFD 30-Aor-81 W 93 0 6 0 432 CEP-112 E DJS 09-Nov-81 C 176 O O O 433 CEP-113 E DJS 22-Jun-82 C 539 1 O O 434 CEP-114 E TS 09-Ncv-83 C 435 15 0 0 518 CEP-114 E FJR 09-Aug-82 W 63 0 4 0 435 CBP-1'15 E KLE 26-Jun-82 C 1033 8 0 0 519 CBP-115 E FJR 22-Jul-82 W 303 6 20 6 436 CEP-116 R DJS 09-Nov-81 C 241 O O O 520 CSP-116 R IFD 02-Jul-81 W 33 0 2 0 437 CBP-117 R TS 06-Sep-83 C 22 O O O 438 CPP-118 R MK 17-Nov-81 C 22 2 O O 521 CBF-118 R RAP 11-Sep-84 W 63 2 4 2 439 CBP-119 R DJF 29-Nov-83 C 106 4 0 0 522 CPP-119 R IFD 08-May-81 W 63 0 4 0 440 CBP-120 R DJS 05-Oct-81 C 92 4 0 0 523 CEP-120 R SL 13-Jul-82 W 63 0 4 0 441 CEP- 121 9 TS 07-May-84 C 95 0 0 0 524 CEP-121 R DRH 13-Dec-83 W 33 0 2 0 442 CBP-122 R MK 06-Oct-81 C 13e 2 O O 525 CEP- 122 R IFD 17- A p r -81 W 153 4 10 4 526 CEP- 122 R SL 13-Jul-82 W 153 4 10 4 443 CEP-123 P DJF 05-Jun-84 C 334 1 O O 527 CBP-123 R TMC 22-Nov-83 W 33 0 2 0 528 CEP-123 R DN 28-Nov-83 W 33 0 2 0 529 CEF-123 R LHE 01-May-84 W 33 0 2 0 530 C5P-123 P RLF 30-Apr-84 W 33 0 2 0 444 CEP-124 R DJS 09-Nov-81 C 52 O O O 445 CEP-125 R KLB 08-Jul-82 C 78 0 0 0 531 CEP- 125 R SAS 21-De c-83 W 63 0 4 0 446 CBP-126 R KLB 20-Oct-82 C 164 0 0 0 532 CBP-126 R SL 26-Mar-81 W 123 0 8 0 533 CBP-126 R RLM 24-Jun-82 W 123 0 8 0 447 CDP-127 R KLB 17-Aug-82 C 373 9 0 0 448 CPP-128 R DJS 11-Jul-83 C 50 4 0 0 449 CBP-129 R DJF 10-Feb-84 C 200 O O O I 450 CDP- 130 R FJR 12-May-81 C 69 2 O O 534 CDP-130 R IFD 09-Feb-81 W 93 1 6 1 535 CND-OO1 R HW O2-Feb-83 C 18 4 0 0 536 CND-OO2 R HLB 19-Aug-82 C 59 1 O O 537 CND-OO3 R DJS 24-Aug-83 C 18 4 0 0 538 CND-OO4 R SBD 19-Mar-84 C 23 0 0 0 539 CND-OO5 R CBD 10-Nov-83 C 34 0 0 0 540 CND-OO6 R HLB 19-Nov-82 C 84 4 0 0 541 CND-OO7 R HW 22-Oct-83 C 32 O O O 542 CND-OO8 R HW 24-Oct-83 C 35 2 O O 543 CND-OO9 R HW 09-May-84 C 47 0 0 0 544 CND-010 R HW 01-Dec-82 C 47 0 0 0 545 CND-011 R HW 24-Mar-83 C 31 3 0 0 546 CND-012 R KW 08-Jul-33 C 38 2 O O 547 CND-013 R SBD 06-Sep-83 C 25 2 O O 549 CND-014 R HW 26-Apr-83 C 15 1 O O 549 CND-015 R SBD 26-May-83 C 65 2 O O 550 CND-016 R DJG 22-Oct-83 C 27 2 O O AR6002G3
. 26-Jul-86 CSR RE2NSPECTION RESULTS FOR LKC PAGE 1;
- ITEM R INSP DATE ATT IP DP WI WD 551 CND-017 R SBD 10-Jun-84 C 75 O O O 552 CND-018 R BAR 08-Jun-83 C 33 1 O O 553 CND-019 R MK 15-Jun-51 C 23 1 O O 554 CND-020 R KW 18-Nov-83 C 68 O O O 555 CND-021 R SBD 20-Feb-84 C 18 2 O O 556 CND-022 R DJS 25-Feb-82 C 227 0 0 0 557 CND-323 R SBD 07-Nov-83 C 86 0 0 0 558 CND-024 R KLB 22-Dec-82 C 86 2 O O 559 CND-025 R DJS 24-Jan-83 C 18 2 O O 560 CND-026 R DJS 05-Jan-84 C 21 0 0 0 561 CND-027 R BEB 05-Mar-82 C 60 0 0 0 562 CND-028 R BEB 05-Mar-82 C 43 0 0 0 563 CND-029 R SBD 17-Nov-83 C 40 2 O O 564 CND-030 R KLB 06-Nov-81 C 32 1 O O 565 CND-031 R SBD 26-May-83 C 92 4 0 0 56e CND-032 R KW 08-Jul-83 C 38 2 O O 567 CND-033 R KW 21-Fe b-84 C 37 1 O O 568 CND-034 R SBD 19-Jun-84 C 33 0 0 0 569 CND-035 R KW 22-Oct-83 C 31 O O O 570 CND-036 R SBD 28-Feb-84 C 44 0 0 0 571 CND-037 R DJS 26-Apr-83 0 29 1 O O 572 CND-038 R BAR 16-Jan-84 C 23 0 0 0 573 CND-039 R KW 26-Apr-83 C 54 0 0 0 574 CND-040 R KLB 28-Dec-82 C 43 3 O O 575 CND-041 R SBD 29-Dec-83 'C 59 3 0 0 576 CND-042 R KW 03-Oct-83 C 18 3 0 0 577 CND-043 R SBD 25-Oct-83 C 67 0 0 0 578 CND-044 R MDL 14-May-84 C 37 0 0 0 579 CND-045 R KW 31-Oct-83 C 18 2 O O 580 CND-046 R KW 11-Oct-83 C 37 0 0 0 581 CND-047 R KW 25-Apr-84 C 18 2 O O 582 CND-049 R SBD 02-Dec-83 C 66 1 O O 583 CND-050 R SBD 07-Dec-83 C 46 0 0 0 584 CND-051 R DJS 28-Jul-83 C 57 0 0 0 585 CND-052 R KW 16-Nov-83 C 24 0 0 0 586 CND-053 R SBD 19-Dec-83 C 29 0 0 0 587 CND-054 R WCB 12-Jun-84 C 26 O O O 588 CND-055 R BAR 16-Jul-83 C 52 O O O 589 CND-056 R KLB O2-Oct-82 C 71 O O O 590 CND-057 R KLB 16-Nov-81 C 48 2 O O 591 CND-058 R DJS 25-Apr-83 C 24 3 0 0 592 CND-059 R CJP 29-May-84 C 15 2 O O 593 CND-060 R KW 13-Sep-83 C 34 1 O O 594 CND-061 R KW 11-Apr-84 C 64 1 O O 595 CND-062 E KLB 10-Aug-82 C 49 2 O O 596 CND-063 E SBD 02-Dec-83 C 28 1 O O 597 CND-064 E KW 15-Feb-84 C 32 4 0 0 598 CND-065 E KLB 13-Oct-82 C 43 0 0 0 599 CND-066 E SBD 24-Aug-83 C 26 0 0 0 600 CND-067 E KW 21-Oct-83 C 72 3 0 0 601 CND-068 E KLB 18-Nov-81 C 35 2 O O 602 CND-069 E KLB 27-Aug-82 C 53 2 O O 603 CND-070 E DJs 16-Aug-83 C 89 2 O O 604 CND-071 E KLB 07-Mar-83 C 42 2 O O 605 CND-072 E DJS 19-Apr-83 C 44 0 0 0 AROOOENg4
^
- I 20-Jul-86 CSR REINSPECTION RESULTS FOR LNC
. PAGE 12
- ITEM R INSP DATE ATT IP DP WI WD
' 606 CND-073 E KLB 05-Nov-82 C 79 5 0 0 607 CND-074 E SBD 20-Jan-84 C 60 2 O O 608 CND-075 E KW 07-Jun-84 C 33 1 O O 609 CND-076 E DJS 17-Jan-84 C 26 O O O 610 ChD-077 E KLB O2-Sep-82 C 65 1 O O 611 CND-078 E DJS 16-Mar-82 C 42 O O O 612 CND-079 E KLB 03-Mar-83 C 22 1 O O 613 CND-080 E KLB 27-Sep-82 C 84 3 0 0 614 CND-081 E KLB O2-Sep-82 C 105 1 O O 615 CND-082 E KW 15-Jun-84 C 72 1 O O 616 CND-083 E DJS 01-Dec-83 C 43 2 O O
, 617 CND-084 E KLB 07-Oct-82 C 31 1 O O 618 CND-085 E KW 14-Nov-83 C 33 1 O O l 619 CND-086 E KW 23-Feb-84 C 32 4 0 0 l 620 CND-087 E KW 16-Dec-82 C 32 1 O O 621 CND-088 E KLB 21-Jan-83 C 70 2 O O
! 622 CND-088 E DJS 20-May-83 C 59 0 0 0 623 CND-089 E KW 25-Jul-83 C 44 1 O O
- 624 CND-OSO E SBD 07-Mar-84 C 40 0 0 0 625 CND-092 E DJS 25-Feb-82 C 198 O O O 626 CND-093 E KW 14-Jun-84 C 54 2 O O j 627 CND-094 R KW 10-Feb-84 C 40 0 0 0 628 CND-095 R KW 01-Aug-83 C 25 3 O O 629 CND-096 R DJS 17-Dec-83 C 17 2 O O 630 CND-097 R KW 08-Sep-83 C 53 1 O O l 631 CND-098 R WCB 15-Jun-64 C 33 4 0 0 l 632 CND-099 R KLB 03-Dec-81 C 52 O O O 633 CND-100 R DJS 23-Aug-83 C 29 0 0 0 634 CND-101 R KW 08-May-84 C 37 3 0 0 635 CND-102 R MK 15-Jun-81 C 52 O O O l
636 CND-103 R DJS 16-Mar-82 C 42 O O O l 637 CND- 104 R KW 20-Sep-83 C 33 0 0 0 4
638 CND-105 R SBD 15-Dec-83 C 69 0 0 0 5
639 CND-106 R KLB 03-Dec-81 C 52 O O O 640 CND-107 R KW O2-Dec-83 C 61 O O O 641 CND-108 R KLB 30-Oct-81 C 57 0 0 0 642 CND-109 R SBD 12-Nov-83 C 28 0 0 0 4 643 CND-110 R SBD 02-Nov-83 C 58 3 0 0 t
644 CND-111 R KW 11-Oct-83 C 18 0 0 0 i
645 CND-112 R KW 14-Feb-84 C 65 0 0 0 646 CND-113 R KLB 20-Aug-82 C 44 2 O O 1 647 CND-114 R KW 08-Dec-83 C 18 2 O O i 648 CND-115 R DJS 25-Feb-82 C 87 1 O O
- 649 CND-116 R SBD 29-Oct-83 C 53 0 0 0
- 650 CND-117 R KW 13-Sep-83 C 51 1 O O 651 CND-118 R KW 22-Nov-83 C 18 0 0 0
- 652 CND-119 R KW 08-Apr-83 C 63 1 O O 653 CND-120 R SBD 07-Nov-83 C 27 0 0 0 654 CND-121 R SBD 06-Mar-84 C 76 2 O O j 655 CND-122 E KLB 14-Nov-82 C 18 1 O O ;
j 656 CND-123 R KLB 06-Apr-83 C 43 1 O O 657 COH-OO1 R CNT 02-Mar-84 C 19 0 0 0 715 COH-OO1 R CNT 23-Feb-84 W 183 0 12 0 4
658 COH-OO2 R JLL 23-May-84 C 10 0 0 0
- 716 COH-003 R FJR 07-Sep-82 W 273 0 18 0 AR000265
, , _ - . . _ . . _ . . . _ _ . ~ . _ _ _ _ __
26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 13
~
- ITEM R INSP DATE ATT IP DP WI WD 717 COH-OO4 R MK 06-Feb-81 W 123 4 8 2 259 COH-OOS R JPH 07-Jan-82 C 10 1 O O 718 CCH-OO6 P RLM 08-Jan-82 W 63 0 4 0 719 COH-COe R RLM 22-Oct-81 W 303 2 20 1 660 COH-OO9 R RLM 18-May-83 C 14 0 0 0 720 COH-OO9 R RLM 19-May-83 W 63 0 4 0 661 COH-011 R CNT 29-Oct-82 C 17 O O O 721 COH-011 R IFD 18-Jul-81 W 63 0 4 0 722 COH-011 R WW 18-Jul-81 W 63 0 4 0 723 COH-012 R JVW 03-Apr-84 W 273 3 18 3 724 COH-015 R WW 30-Jun-81 W E73 1 18 1 725 COH-017 R MK 18-Sep-82 W 363 0 24 0 726 COH-018 R WJH 15-Feb-84 W 48 0 3 0 727 COH-020 R RAS 16-Feb-84 W 273 0 18 0 728 COH-021 R LKB 10-Feb-84 W 153 0 10 0 729 COH-021 R GGN 08-Feb-84 W 153 0 10 0 730 COH-024 R AG O2-Oct-82 W 183 2 12 2 662 COH-026 R JPH 15-Jun-83 C 10 1 O O 731 COH-026 R IFD 09 eb-81 W 63 4 4 4 732 COh-027 R WJE 30-Mar-84 W 303 2 20 2 733 COH-028 R RAG 03-Mav-84 W 63 0 4 0 734 COH-029 R RLM 26-Oct-81 W 123 0 8 0 735 COH-030 R kK 13-Nov-82 W 363 2 24 2 663 COH-031 R RLM 04-Nev-82 C 10 3 O O 736 COH-032 R SL 11-Jan-52 W 183 5 12 5 737 COH-033 R FJR 25-Sep-82 W 123 0 8 0 664 COH-034 R MM 23-Nov-84 C 31 O O O 738 COH-034 R RAG 23-Jun-84 W 348 2 23 2 739 COH-034 R RLW EO-Mar-84 W 348 2 23 2 740 COH-036 R NPC 20-Jan-84 W 63 0 4 0 665 COH-037 R JPH 29-Jul-82 C 5 0 0 0 741 COH-038 R MPW 17-Feb-84 W 303 0 20 0 742 COH-039 R LOW 18-Feb-82 W 123 0 8 0 666 COH-041 R JPH 20-Oct-81 C 30 2 O O 743 COH-041 R IFD 05-Mar-81 W 243 0 16 0 744 COH-041 R DT 30-Jul-81 W 243 0 16 0 667 COH-042 R CNT 13-Oct-82 C 19 0 0 0 745 COH-042 R DRH 14-Oct-82 W 273 0 18 0 746 COH-042 R KK 26-Nov-82 W 273 0 18 0 747 COH-043 R MAK 20-Oct-83 W 48 0 3 0 748 COH-043 R TMD 27-Sep-83 W 48 0 3 0 668 COH-044 R CNT 30-Dec-82 C 12 O O O 749 COH-044 R KK2 03-Nov-82 W 123 2 8 2 750 COH-044 R DRH 11-Oct-82 W 123 2 8 2 751 COH-045 R DGC 30-Aug-83 W 123 0 8 0 l 669 COH-046 R DP 12-Feb-83 C 6 O O O ;
752 COH-046 R LKB 04-Apr-84 W 63 0 4 0 753 COH-046 R DP 13-Dec-82 W 63 0 4 0 754 COH-047 R GGN 13-Apr-84 W 123 0 8 0 670 COH-048 R JLL 29-Feb-84 C 15 0 0 0 755 COH-048 R GGN 24-Jan-84 W 123 0 8 0 756 COH-049 R GGN 23-Feb-84 W 33 2 2 2 671 COH-050 R JPH 16-Oct-81 C 23 1 O O 757 COH-050 R SL 15-Jul-81 W 153 1 10 1 672 COH-052 R RLM 15-Sep-82 C 11 O O O
Ei-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 14
- ITEM R INSP DATE ATT IP DP WI WD 758 COH-052 R MK 18-Jul-81 W 93 2 6 2 673 CO,-053 R CNT 16-Mar-83 C 10 0 0 0
- 759 COH-053 ? mad 1C -J an-83 W 63 0 4 0 674 COH-054 R JAP 08-Feb-84 C 14 O O O 760 COH-054 R TMD 03-Feb-84 W 123 O 3 0 761 COH-055 R SL 10-Feb-81 W 633 16 42 12 675 CCH-OSE R JPH C4-Jan-82 C 30 2 O O 762 COH-059 F RLM 09-Oct-81 W 273 0 18 0 763 COH-059 R HWS 31-May-84 W 273 0 18 0 764 COH-060 R RLM 26-Oct-81 W 93 5 6 5 1 765 COH-062 R AG 21-Oct-82 W 93 4 6 4 766 COH-C63 R BEB 25-Sep-82 W 63 0 4 0 676 COH-064 R MH 23-Mar-84 C 20 0 0 0 767 COH-064 R MAK 13-Mar-84 W 123 0 8 0 768 COH-064 R JBH 06-Jul-79 W 123 0 8 0 677 COH-065 R KLB 15-Mar-82 C 32 O O O 769 COH-065 R KKE 10-Dec-81 W 363 5 24 5 770 COH-066 R BES 09-Oct-82 W 63 10 4 6 678 COH-067 9 ORH 22-Jun-84 C 21 2 O O 771 CCH-067 R DPH 22-Jun-84 W 123 1 8 1 679 COH-068 R CNT 16-Mar-23 C 22 O O O 772 COH-06B R MAK 10-Jan-83 W 93 0 v 0 773 COH-069 R MK 23-Apr-81 W 453 6 30 6 774 COH-070 R BEB 25-Aug-82 W 153 0 10 0 680 COH-071 R MM 18-Jun-24 C 5 0 0 0 681 COH-072 R LP 09-Feb-82 C 55 1 O O 775 COH-072 R SL 08-Aug-81 W 393 3 26 3 682 COH-073 R KLB 03-Nov-83 C 21 O O O 776 COH-073 R MAF OE-Nov-83 W 153 0 10 0 683 COH-074 R CNT 22-Dec-82 C 16 0 0 0 777 COH-074 R KK2 23-Dec-82 W 123 0 8 0 684 COH-075 R CNT 29-Mar-83 C 11 O O O 778 COH-075 R SL 10-Sep-82 W 33 0 2 0 685 COH-076 R MH 24-Aug-83 C 5 0 0 0 686 COH-077 R CNT 18-Jul-83 C 28 4 0 0 779 COH-077 R DT 26-Aug-81 W 333 4 22 4 j 780 COH-077 R TML 13-Se p-83 W 333 4 22 2 !
781 COH-101 E RLM 03-Dec-81 W 33 0 2 0 782 COH-102 E RLM 123 {
23-Oct-81 W 1 8 1 '
687 COH-103 E RLM 08-Apr-83 C 21 O O O i 783 COH-103 E DRH 21-Sep-82 W 123 0 8 0 784 COM-104 E DT 28-Sep-81 W 93 0 6 0 688 COH-105 E CNT 04-Nov-81 C 90 0 0 0 785 COH-105 E DT 18-Sep-81 W 543 5 36 4 I
689 COH-106 E RLM 16-Sep-82 C 35 0 0 0 786 COH-106 E RLM 17-Feb-82 W 243 2 16 2 787 COH-107 E RLM 03-Dec-81 W 273 2 -18 2 690 COH-108 E RLM 19-Oct-82 C 11 O O O 788 COH-108 E IFD 27-Jun-81 W 63 0 4 0 691 COH-109 E BEB 12-Mar-83 C 21 O O O 789 COH-110 E RLM 05-Oct-81 W 183 5 12 5 790 COH-111 E RLM 05-Oct-81 W 273 0 18 0 692 COH-112 E LP 17-May-83 C 73 1 O O 791 COH-112 E LOW 11-Feb-82 W 603 14 40 11 693 COH-113 E JPH 20-Aug-82 C 20 0 0 0 AR000267
{
26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 13 o
- ITEM R INSP DATE ATT IP DP WI WD 792 COH-113 E DP 19-Aug-82 W 93 0 6 0 793 COH-114 E SL 22-Nov-62 W 153 0 10 0 794 COH-115 E RLM 26-Oct-81 W 243 0 16 0 694 COH-116 E MK 03-Dec-81 C 21 O O O 795 COH-116 E DT 12-Nov-80 W 153 0 10 0 695 COH-117 E CNT 18-Jul-83 C 38 2 O O 796 COH-117 E IPD 23-Deb-81 W 423 3 28 3 696 COH-il8 E SL 12-Apr-82 C 32 O O O 797 COH-118 E IFD 20-Mar-81 W 363 7 24 7 798 COH-119 E KK 14-Oct-82 W 483 0 32 0 697 COH-120 E BEB 13-Jan-82 C 145 1 O O 799 COH-120 E IFD 16-Dec-80 W 603 3 40 3 800 COH-122 E FJR 30-Dec-82 W 183 2 12 2 801 COH-122 E FJR 29-Sep-82 W 183 2 12 2 802 COH-123 E FJR 29-Sep-82 W 393 2 26 1 698 COH-124 E JPH 10-Feb-83 C 13 0 0 0 803 COH-124 E FJR OS-Oct-82 W 33 0 2 0 804 COH-125 E RLM 05-Oct-81 W 153 0 10 0 805 COH-127 E RLM 26-Oct-81 W 303 2 20 2 699 COH-129 E MAK 16-Mar-84 C 17 O O O 806 COH-129 E JBH 05-Jul-79 W 123 0 8 0 807 COH-129 E MAK 16-Mar-84 W 123 0 8 0 808 COH-129 E RV 05-Jul-79 W 123 0 8 0 809 COH-129 E DP 24-Mar-83 W 123 0 8 0 810 COH-130 E RLM 05-Oct-81 W 423 0 28 0 811 COH-131 E DT 12-Aug-81 W 333 0 22 0 812 COH-132 E MAK 29-Jul-83 W 153 0 10 0 813 COH-133 E TML 28-Nov-83 W 423 2 28 2 814 COH-133 E MH 13-Feb-84 W 423 2 28 2 815 COH-134 E FJR 18-Sep-82 W 3e3 0 24 0 816 COH-135 E FJR 13-Sep-82 W 303 0 20 0 700 COH-136 E CNT 03-Mar-83 C 28 1 O O 817 COH-136 E MAK 28-Feb-83 W 423 2 28 2 818 COH-137 E KK2 03-Nov-82 W 393 1 26 1 701 COH-138 E MH 22-Mar-84 C 32 2 O O 819 COH-138 E MH 22-Mar-84 W 303 0 20 0 702 COH-139 E LP 27-Jan-82 C 45 5 0 0 820 COH-139 E IFD 12-May-81 W 543 0 36 0 821 COH-139 E JAM 14-Mar-84 W 543 0 36 0 703 COH-140 E SL 12-Apr-82 C 47 0 0 0 822 COH-140 E IFD 20-Mar-81 W 573 0 38 0 823 COH-140 E DGC 20-Sep-83 W 573 0 38 0 824 COH-141 E BEB 11-Sep-82 W 123 0 8 0
- 825 COH-142 E KK2 03-Nov-82 W 423 0 28 0 704 COH-143 E JLL 07-Feb-84 C 24 0 0 0 826 COH-143 E MAK O2-May-83 W 273 2 18 1 705 COH-144 E THS 10-Jan-84 C 31 3 0 0 827 COH-144 E DN 01-Nov-83 W 393 1 26 1 828 COH-145 E WJH 11-Apr-84 W 123 0 8 0 l 829 COH-146 E TML 08-Dec-83 W 453 4 30 4 706 COH-147 E KLB 27-Sep-83 C 29 0 0 0 830 COH-147 E KK2 18-Jan-83 W 363 1 24 1 831 COH-148 E KK2 01-Nov-82 W 213 2 14 2 832 COH-149 E FJR 07-Jun-84 W 393 0 26 0 833 COH-149 E RLM 21-Jan-82 W 393 0 26 O M 000TrTs8
~
, 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 16
- ITEM R INSP DATE ATT IP DP WI WD 707 COH-150 E JLL 12-Mar-84 C 12 O O O 834 COH-150 E TMD 06-Mar-84 W 123 0 8 0 708 COH- 151 E AG O2-Jun-83 C 24 0 0 0 835 COH-151 E MAK 29-Apr-83 W 318 0 2 '. O
- 836 COH-152 E TML 08-Dec-83 W 453 4 30 4 709 COH-153 E MH 13-Seo-83 C 24 0 0 0 837 COH-153 E MH 13-Seo-83 W 303 1 20 1 710 COH-154 E LP 15-Jan-82 C 33 2 O O 838 COH-154 E RLM 19-Oct-81 W 333 1 22 1 711 COH-155 E DRH 28-Feb-84 C 33 3 0 0 839 COH- 155 E DRH 28-Feb-84 W 273 0 18 0 840 COH-156 E IFD 11-May-81 W 393 0 26 0 841 COH-157 E MAK 29-Jun-83 W E73 4 18 4 712 COH-158 E CNT 25-Jan-84 C 34 2 O O 842 COH-158 E MAK 27-May-83 W 393 0 26 0 713 COH-159 E CNT 13-Oct-82 C 16 O O O 843 COH-159 E KK2 18-Oct-82 W 123 0 8 0 844 COH-160 E RLM 21-Oct-81 W 273 2 18 2 714 COH-161 E THS 24-Jan-84 C 31 O O O 845 COH-161 E RLM 22-Oct-81 W 273 0 18 0 846 COH-161 E RAS 05-Jan-84 W 273 0 18 0 847 CPH-OO1 R MK 12-Jan-81 W 963 1 64 1 848 CPH-OO2 R BEB 14-Oct-82 W 108 0 7 0 849 CPH-OO3 R RY 22-May-79 W 633 9 42 9 850 CPH-OO4 R IFD 15-Jan-81 W 603 0 40 0 851 CPH-OOS F TLB 21-Dec-83 W 93 0 6 0 852 CPH-OOS R CNT 12-Jan-84 W 93 0 6 0 853 CPH-OO6 R GY 13-Jun-78 W 543 4 36 4 854 CPH-OO7 R GY 16-May-78 W 1683 10 112 9 855 CPH-OO8 R RLM 19-Feb-82 W 303 2 20 2 856 CPH-OO9 R WCB 27-Jan-84 W 1833 42 122 28 857 CPH-010 R DRH 18-Feb-83 W 483 0 32 0 858 CPH-011 R JBH 31-Jul-79 W 363 2 24 2 859 CPH-012 R DN 26-Oct-83 W 513 4 34 4 860 CPH-012 R MAK 14-Sep-83 W 513 4 34 4 861 CPH-013 R IFD 11-Feb-81 W 543 10 36 6 862 CPH-015 R IFD 24-Jun-81 W 393 4 26 3 863 CPH-016 R GY 21-Feb-78 W 1563 18 104 15 864 CPH-017 R BEB 03-Sep-82 W 468 0 31 0 865 CPH-019 R RY 30-Jun-80 W 513 2 34 2 866 CPH-020 R RY 12-Jun-79 W 1323 10 88 10 867 CPH-OEO R DRH 16-Apr-83 W 1323 10 88 10 868 CPH-021 R RLM 01-Dec-81 W 213 0 14 0 869 CPH-022 R SL 28-Jul-81 W 1533 10 102 9 870 CPH-023 R RLM 18-Feb-82 W 633 2 42 2 871 CPH-025 R GY 31-May-78 W 1233 21 82 16 872 CPH-026 R DT 02-Jul-81 W 813 3 54 3 873 CPH-026 R SL 20-Jun-81 W 813 3 54 3 874 CPH-OE7 R BEB 26-Oct-82 W 303 1 20 1 875 CPH-028 R IFD 22-Dec-80 W 693 8 46 4 876 CPH-029 R RY O2-Jul-79 W 183 1 12 1 877 CPH-030 R DRH 18-Feb-83 W 693 9 46 6 878 CPH-031 R GY 07-Apr-78 W 123 1 8 1 879 CPH-032 R TLB 21-Dec-83 W 123 4 8 4 880 CPH-033 R GY 22-Nov-78 W 903 16 60 15 AR000269
Es-Jul-86 CSR REINSPECTIOM RESULTS FOR LKC PAGE e
- ITEM R INSP DATE ATT IP
- DP WI WD 881 CPH-034 R RLM 18-Feb-82 W 393 0 26 0 882 CPH-034 R BEB 13-Aug-82 W 393 0 26 0 852 CPH-035 R TLE 10-Jar-84 W 1023 13 68 12 l 864 CPH-03e R JBH 31-Jul-73 W 2283 7 152 7 885 CPH-036 R IFD 27-Jan-81 W 2283 7 152 7 886 CPH-037 R MAK 01-Dec-82 W 1113 25 74 15 887 CPH-037 R DRh 26-Dec-E2 W 1113 25 74 15 888 CPH-038 R BEB 20-Dec-82 W 108 0 7 0 889 CPH-039 R IFD 30-Jan-81 W 1143 23 76 19 890 CPH-039 R DT 09-Jul-80 W 1143 23 76 19 891 CPH-040 R RLM 05-Jan-82 W 1113 20 74 13 892 CPH-041 R RY 08-May-79 W 1218 20 81 17 893 CPH-042 R GY 21-Feb-78 W 2613 59 174 50
- 894 CPH-043 R GY 18-Jan-79 W 648 8 43 7
- i. 895 CPH-043 R RY 22-May-79 W 648 8 43 7 896 CPH-044 R RY 08-May-79 W 873 7 58 7 897 CPH-045 R RLM 27-Ncv-81 W 1053 16 70 16 898 CPH-046 R RLM 01-Dec-81 W 153 0 10 0 899 CPH-047 R RLM 10-Dec-81 W 423 4 28 4 900 CPH-048 R MAK 12-Jul-83 W 1233 9 82 7 901 CPH-049 R DT 21-Sep-81 W 183 0 12 0 902 CPH-050 R RY 08-May-79 W 903 13 60 13 903 CPH-051 R TML 17-Aug-83 W 693 9 46 6 904 CPH-051 R NPC 13-Apr-84 W 693 9 46 6 905 CPH-052 R DT 10-Jul-81 W 483 5 32 2 906 CPH-053 R IFD 20-Jan-81 W 843 1 56 1 907 CPH-053 R IFD 22-Dec-80 W 843 1 56 1 908 CPH-054 R SL 15-Jul-81 W ~813 19 54 9 909 CPH-055 R SL 10-Mar-81 W 483 4 32 4 910 CPH-055 R RY 06-Aug-80 W 483 4 32 4 i 911 CPH-056 R BEB 30-Sep-82 W 273 0 18 0 912 CPH-057 R IFD 20-Dec-80 W 603 6 40 6 913 CPH-058 R KK2 22-Nov-82 W 1203 8 80 7 914 CPH-059 R GY 22-Nov-78 W 63 3 4 2 915 CPH-060 R GY 27-Mar-78 W 123 0 8 O l 916 CPH-101 E IFD 03-Apr-81 W 1263 19 84 16 917 CPH-102 E IFD 20-Jan-81 W 1143 14 76 13 )
918 CPH-103 E IFD 22-Dec-80 W 543 'O 36 0 919 CPH-104 E IFD 15-May-81 W 1923 37 128 24
, 920 CPH-104 E RLM 08-Feb-82 W 1923 37 128 24 1 921 CPH-105 E SL 25-Apr-81 W 873 20 58 15 l 922 CPH-108 E SL 30-Jun-81 W 1023 3 68 3 923 CPH-110 E RY 22-May-79 W 1173 2 78 2 924 CPH-110 E GY 18-Jan-79 W 1173 2 78 2 925 CPH-111 E SL 27-Apr-81 W 1248 7 83 6 926 CPH-112 E IFD 17-Dec-80 W 843 9 56 9
! 927 CPH-113 E GY 09-Oct-78 W 1293 22 46 18
, 928 CPH-114 E RY 01-Aug-79 W 903 19 60 13 929 CPH-115 E SL 17-Feb-82 W 663 12 44 11 930 CPH-116 E SL 18-Feb-81 W 1143 5 76 5 931 CPH-116 E RY 28-Jun-79 W 1143 5 76 5 932 CPH-117 E GY 09-Oct-78 W 903 3 60 3 3 933 CPH-118 E GY 22-Nov-78 W 1563 6 104 5 934 CPH-119 E RLM 07-Oct-81 W 873 18 58 9 935 CPH- 119 E DT 02-Jul-81 W 873 18 58 9
, - , _ , - . , . . _. , ,m , , . - w., ---.e~. -- , - . - - , ,
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, 26-Jul-86 CSR REINSPECTION RESULTS FOR ._K C PAGE 18
- ITEM R INSP DATE ATT IP DP WI WD 936 CFH-120 E RAG 19-Jun-84 W 723 ?
48 7 937 CPH-121 E MK 05-Feb-81 W 393 0 26 0 938 CPH-122 E SL 05-Mar-81 W 1533 27 102 14 939 CFH-122 E RY 06-Aug-80 W li33 27 102 14 940 CPH-123 E MK 08-Dec-80 W 2433 28 162 25 941 CPH-125 E DT 17-Aug-81 W 1143 30 76 17 942 CFH-126 E GY 18-Jan-79 W 693 5 46 4 943 CPH-126 E RY 22-May-79 W 693 5 46 4 944 CPH-127 E RY 22-May-79 W 813 6 54 6 945 CPH-127 E GY 18-Jan-79 W 813 6 54 6 946 CPH-128 E RLM 16-Jul-81 W 1083 14 72 12 947 CPH-129 E RY 08-May-79 W 1443 8 96 8 948 CPH-129 E MK 09-May-81 W 1443 8 96 8 949 CPH-130 E RY 07-Aug-80 W 1743 27 116 16 l 950 CPH-130 E DT 22-Feb-82 W 1743 27 116 16 951 CPH-130 E RLM 14-Oct-81 W 1743 27 116 16 952 CPH-131 E DT 05-Jan-82 W 1413 13 94 13 953 CPH-132 E GY 21-Feb-78 W 1323 32 88 16 954 CPH-132 E SL 01-Apr-81 W 1323 32 88 16 955 cpm-133 E DT 11-Jan-82 W 2043 25 136 18 956 CPH-135 E DT 25-Feb-82 W 453 14 30 14 957 CPH-136 E GY 18-Jan-79 W 873 20 58 18 958 CPH-137 E DT 29-Jul-80 W 1143 34 76 22 959 CPH-137 E JBH 31-Jul-79 W 1143 34 76 22 960 CPH-138 E GY 17-Apr-78 W 1203 19 80 18 961 CPH-139 E MK 04-May-81 W 1293 19 86 9 962 CPH-139 E IFD 17-Apr-81 W 1293 19 86 9 963 CPH-140 E GY 18-Jan-79 W 1293 6 86 6 964 CPH-140 E RY 22-May-79 W 1293 6 86 6 4 965 CPH-141 E SL 02-May-81 W 3033 63 202 47 966 CPH-141 E IFD 26-Mar-81 W 3033 63 202 47 967 CPH-142 E SL 20-Mar-81 W 678 2 45 2 968 CPH-144 E RLM 01-Feb-82 W 1443 2 96 2 969 CPH-146 E RY 14-Jun-79 W 1203 10 80 8 970 CPH-147 E IFD 24-Apr-81 W 1323 10 88 10 971 CPH-149 E DT 18-Feb-82 W 993 1 66 1 972 CPH-150 E SL 09-Feb-81 W 1083 37 72 16
- 973 CPH-150 E DT 16-Jun-80 W 1083 37 72 16
)
974 CPH-150 E MK 11-Mar-81 W 1083 37 72 16 i 975 CPH-151 E RY 13-Jun-79 W 1323 34 88 28 976 CPH-153 E SL 05-Aug-81 W 933 18 62 14 977 CPH-154 E RLM 13-Nov-81 W 2043 26 136 25 978 CPH-154 E SL 18-Sep-82 W 2043 26 136 25
. 979 CPH-155 E SL 20-Mar-81 W 678 3 45 3 980 CPH-156 E BEB 27-Aug-82 W 1263 4 84 4 981 CPH-156 E TLB 10-Jan-84 W 1263 4 84 4 982 CPH-157 E RY 27-Aug-80 W 1398 9 93 9 983 CPH-158 E IFD 15-Jan-81 W 843 6 56 5 984 CPH-158 E RY 08-Aug-79 W 843 6 56 5 985 CPH-159 E RLM 19-Oct-81 W 1353 18 90 13 986 CPH-160 E AD 09-May-81 W 798 11 53 7 987 CPH-161 E RLM 11-May-83 W 1893 45 126 44
. 988 CPH-162 E MK 29-Jan-81 W 1338 36 89 23 989 CPH-164 E RLM 05-Oct-81 W 543 2 36 2 990 CPH-165 E BEB 13-Aug-82 W 543 0 36 O AR000271L
l
)
. 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC FAGE 19 l
- ITEM R INSP DATE ATT IP DP WI WD 991 CPH-165 E RLM 18-Dec-82 W 543 0 36 0 992 CPH-166 E IFD 20-May-81 W 1863 16 124 15 993 CFM- 166 E RY 06-Aug-80 W 1863 ic 124 15 094 CPH-166 E SL 10-Feo-81 W 1863 16 124 15 99'S CPH-le7 E Ri 22-May-79 W 783 3 52 3 996 CPH-167 E IFD 15-Apr-81 W 783 3 52 3 997 CPH-1e8 E SL 18-Sep-82 W 963 32 64 32 998 CPH-168 E RLM 13-Nov-81 W 963 32 64 32 .
999 CPH-169 E SL 11-Mar-81 W 1443 16 96 7 1000 CPH-170 E IFD 19-Jun-81 W 2073 26 138 26 1001 CPH-171 E RLM 01-Feb-82 W 2493 2 166 2 1002 CPH-171 E IFD 06-Jan-80 W 2493 2 166 2 1003 CPH-172 E SL 11-May-81 W 963 14 64 8 1005 EIN-OO1 R TWZ 25-Apr-84 C 11 O O O 1006 EIN-OO2 R KLB 06-Jun-83 C 102 4 O O 1141 EIN-OO2 R MK 18-Sep-82 W 873 0 58 0 1007 EIN-OO3 R FJR 27-Oct-83 C 113 5 0 0 1142 EIN-OO3 R DGC 19-Jul-83 W 423 0 28 0 1008 EIN-OO4 R TWZ O2-May-84 C 33 O O O 1143 EIN-OO4 R TWZ 03-May-84 W 127 0 8 O 100o EIN-OO5 R TWZ 23-Apr-84 C 9 4 0 0 l 1010 EIN-OO6 R MLB 07-May-84 C 49 13 0 0 1011 EIN-OO7 R TWZ 17-Feb-84 C 9 O O O 1012 EIN-OO8 R BAR 25-Aug-83 .C 41 3 0 0 1144 EIN-OO8 R DP 25-Aug-83 W 71 0 5 0 1145 EIN-OO8 R DGC 31-Aug-83 W 71 0 5 0 1013 EIN-010 R KLB 16-Dec-81 C 35 2 O O 1014 EIN-011 R KLB 13-Dec-82 C 68 1 O O 1146 EIN-011 R MLB 12-Dec-83 W 453 5 30 4 1147 EIN-011 R FJR 12-Dec-83 W 453 5 30 4 1015 EIN-012 R MLB 10-Mar-84 C 10 0 0 0 1016 EIN-013 R MLB 10-Mar-84 C 9 0 0 0 1017 EIN-014 R DJS 03-Feb-82 C 13 0 0 0 1018 EIN-015 R MLB 14-Mar-84 C 5 1 O O 1019 EIN-016 R BAR 12-Jan-84 C 13 1 O O 1020 EIN-017 R FJR 09-Jun-84 C 81 7 O O 1148 EIN-017 R FJR 09-Jun-84 W 723 3 48 3 1021 EIN-018 R TWZ 10-Mar-84 C 9 0 0 0 1022 EIN-019 R DJS 05-Feb-82 C 45 5 O O 1149 EIN-019 R RLM 29-Jan-82 W 397 2 26 2 1023 EIN-020 R MLB 13-Mar-84 C 33 4 0 0 1150 EIN-020 R FJR 26-Oct-83 W 183 0 12 0 1024 EIN-022 R JVW 08-Jun-84 C 13 0 0 0 1025 EIN-023 R TWZ 10-Jan-84 C 16 1 O O 1151 EIN-023 R JVW 09-Jun-84 W 303 4 20 4 1152 EIN-023 R KK 20-Aug-82 W 303 4 20 4 1153 EIN-023 R DRH 22-Feb-84 W 303 4 20 4 1154 EIN-023 R MAK 12-Apr-83 W 303 4 20 4 1026 EIN-024 R TWZ 06-Jun-84 C 9 O O O 1027 EIN-025 R MLB 18-Jun-84 C 39 4 0 0 1155 EIN-025 R SL 01-Feb-83 W 123 0 8 0 1028 EIN-026 R TWZ 21-Mar-84 C 19 2 O O 1029 EIN-027 R TWZ 05-May-84 C 61 O O O 115e EIN-027 R TWZ 05-May-84 W 603 0 40 0 1030 EIN-028 R MLB 07-Jun-84 C 9 4 O O AR000272
,. 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 20
- ITEM R INSP DATE ATT IP DP WI WD 1031 EIN-029 R KLB 29-Sep-81 C 54 0 0 0 1157 EIN-029 R WW 20-Jul-81 W 303 13 20 11 1032 EIN-030 R MLB 25-Fet-84 C 13 0 0 0 1033 EIN-031 R TWZ OJ-Jun-84 C 63 3 O O 1158 EIN-031 R MAK 25-Jan-83 W 123 0 8 0 1034 EIN-032 R FJR 01-Dec-83 C 5 2 O O 1035 EIN-033 R JVW 03-Mar-84 C 9 0 0 0 1036 EIN-034 R KLB 22-Sep-82 C 51 1 O O
, 1159 EIN-034 R DP 07-Feb-83 W 243 0 16 0 1037 EIN-035 R MLB 06-Mar-84 C 23 0 0 0 1160 EIN-035 FJR {
R 10-Nov-83 W 63 0 4 0 1161 EIN-035 R MLB 06-Mar-84 W 63 0 4 0 1038 EIN-036 R MLB 13-Mar-84 C 71 8 0 0 1162 EIN-036 R WJH 16-Apr-84 W 423 13 28 12 l 1163 EIN-036 R FJR 22-Nov-83 W 423 13 28 12 l 1039 EIN-037 R NK 16-May-83 C 11 1 O O 1040 EIN-038 R MLB 10-Mar-84 C 30 6 O O 1041 EIN-039 R MLB 13-Mar-84 C 33 0 0 0 1164 EIN-039 R FJR 26-Oct-83 W 183 3 12 3 1042 EIN-040 R JLL 24-Jan-84 C 51 O O O 1043 EIN-041 R FJR 13-Jun-84 C 30 0 0 0 1165 EIN-041 R FJR 13-Jun-84 W 123 0 8 O 1044 EIN-042 R DJS 22-Sep-83 C 74 5 O O 1166 EIN-042 R DJS 22-Sep-83 W 783 0 SE O 1045 EIN-043 R DJS 09-Nov-82 C 9 1 O O 1046 EIN-044 R FJR 13-Sep-83 C 56 O O O 1167 EIN-044 R FJR 12-Apr-84 W 453 0 30 0 ,
1047 EIN-045 R FJR 12-Apr-84 C 9 0 0 0 1048 EIN-046 R MLB 27-Apr-84 C 6 0 0 0 1168 EIN-046 R SL 29-Sep-82 W 63 O 4 0 1049 EIN-047 R TWZ 16-Jun-84 C 33 2 O O 1169 EIN-047 R KK2 05-Mar-82 W 63 0 4 0 1050 EIN-048 R BAR 07-Nov-83 C 5 0 0 0 1051 EIN-049 R KLB 22-Sep-82 C 58 0 0 0 1170 EIN-049 R DP 17-May-83 W 423 8 28 6 1052 EIN-050 R BAR 01-Nov-83 C 5 0 0 0 1053 EIN-051 R MLB 26-Mar-84 C 9 O O O 1054 EIN-052 R BAR 04-Oct-83 C 19 0 0 0 1171 EIN-OS2 R FJR 04-Oct-83 W 63 2 4 2 1055 EIN-053 R TWZ 13-Jun-84 C 33 0 0 0 1172 EIN-053 R MAK 10-Feb-83 W 63 0 4 0 1056 EIN-054 R BAR 06-Sep-83 C 31 2 O O 1173 EIN-054 R CNT 06-Sep-83 W 183 0 12 0 1057 EIN-055 R DJS 10-Feb-82 C 61 3 O O 1174 EIN-055 R LOW 09-Feb-82 W 423 5 28 5 1058 EIN-056 R DJS 10-Feb-82 C 62 2 O O 1175 EIN-056 R LOW 09-Feb-82 W 573 21 38 19 1059 EIN-057 R BAR 06-Jan-84 C 5 O O O 1176 EIN-057 R IFD 13-Jan-81 W 633 0 42 0 1177 EIN-057 R JVW 14-Apr-84 W 633 0 42 0 1178 EIN-057 R RY 10-Nov-80 W 633 0 42 O l 1060 EIN-058 R DJS 14-Jan-84 C 5 0 0 0 l 1179 EIN-058 R MLB 24-Feb-84 W 303 2 20 2 1061 EIN-059 R MLB 16-Jun-84 C 37 1 O O 1180 EIN-059 R RLM 29-Jan-82 W 63 -6 4 4 L
AR000273
26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 21
- ITEM R INSP DATE ATT IP DP WI WD 1062 EIN-060 R KLB 27-May-83 C 35 0 0 0 1181 EIN-060 R DP 06-Apr-83 W 63 0 4 0 1063 EIN-061 R MLB 25-Feb-84 C 9 O O C 1182 EIN-061 R MLB 25-Feb-84 W 63 0 4 0 1064 EIN-062 R FJR OB-Nov-83 C 33 3 0 0 1183 EIN-062 R FJR 08-Nov-83 W 123 0 8 0 1065 EIN-063 R MLB 26-Jan-84 C 96 27 0 0 1184 EIN-063 R MLB 26-Jan-84 W 363 0 24 0 1004 EIN-064 R MSS 04-May-81 A 24 2 O O 1066 EIN-064 R MK 13-Jul-81 C 31 O O O 1185 EIN-064 R WW 13-Jul-81 W 63 4 4 4 1067 EIN-065 R JVW 05-Jun-84 C 5 0 0 0 1068 EIN-066 R TWZ 12-Feb-84 C 42 2 O O 1186 EIN-066 R TWZ 16-Feb-84 W 423 0 28 0 1187 EIN-066 R FJR 26-Apr-84 W 423 0 28 0 1069 EIN-067 R JVW O2-Apr-84 C 66 0 0 0 1070 EIN-068 R DJS 15-Oct-8; C 49 2 O O 1071 EIN-069 R KLB 29-Sep-81 C 35 O O O 1188 EIN-069 R DT 30-Sep-81 W 423 0 28 0 1072 EIN-070 R BAR 01-Nov-83 C 71 2 O O 1073 EIN-071 R FJR 13-Sep-83 C 97 11 O O t 1189 EIN-071 R FJR 03-Nov-83 W 603 0 40 0 1074 EIN-072 R DJS 10-Feb-82 C 26 1 O O 1075 EIN-073 R DJS 03-Feb-82 C 26 5 0 0 1076 EIN-074 R DJS 14-Oct-81 C 29 0 0 0 1077 EIN-075 R TWZ 12-Apr-84 C 63 1 O O 1190 EIN-075 R FJR 27-Apr-84 W 423 0 28 0 1078 EIN-076 R KLB 09-Sep-82 C 5 1 O O 1191 EIN-076 R JWN 09-Mar-84 W ---
0 0 0 1079 EIN-077 R MLB 24-Feb-84 C 157 O O O 1192 EIN-077 R SL 27-Jul-82 W 1278 0 85 0 1080 EIN-078 R BAR 04-Aug-83 C 87 7 0 0 1193 EIN-078 R DJA 03-Jul-84 W 363 4 24 4 1081 EIN-079 R MLB 05-Jun-84 C 5 1 O O 1082 EIN-080 R MLB 20-Mar-84 C 5266 1 O O 1194 EIN-080 R LAP 28-Feb-84 W 513 25 34 20 1195 EIN-OBO R LKB 08-Mar-84 W 513 25 34 20 1083 EIN-081 R BAR 10-Feb-84 C 13 0 0 0 1196 EIN-081 R IFD 23-Dec-80 W 513 0 34 0 1197 EIN-081 R TWZ 12-Mar-84 W 513 0 34 0 1084 EIN-101 E BAR 12-Jan-84 C C* O O O 1198 EIN-101 E FJR 10-Jan-84 W 153 2 10 2 1085 EIN-102 E KLB 23-Feb-82 C 123 0 0 0 1199 EIN-102 E RLM 08-Oct-81 W 693 32 46 32 1200 EIN-102 E DP 03-Feb-83 W 693 32 46 32 1086 EIN-103 E JLL 24-Jan-84 C 51 O O O 1087 EIN-104 E BAR 10-Jan-84 C 16 1 O O 1201 EIN-104 E MAK 12-Apr-83 W 123 9 8 8 1202 EIN-104 E KK2 19-Aug-82 W 123 9 8 8 1088 EIN-105 E KLB 09-Jul-82 C 1464 44 0 0 1089 EIN-106 E MLB 24-Feb-84 C 36 O O O 1203 EIN-106 E MLB 12-Jan-84 W 483 0 32 0 1204 EIN-106 E KK2 19-Aug-82 W 483 0 32 0 1205 EIN-106 E LHB 09-Mar-84 W 483 0 32 0 1206 EIN-106 E MAK 11-Apr-83 W 483 0 32 O AR000274 l
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,, 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 22
- ITEM R INSP DATE ATT IP DP WI WD 1090 EIN-107 E DJS 20-Feb-84 C 28 0 0 0 '
1207 EIN-107 E FJR 27-Jan-83 W 363 8 24 8 1091 EIN-108 E DJS 20-Feb-84 C 28 0 0 0 l 1208 EIN-108 E FJR 27-Jan-83 W 273 3 18 3 1092 EIN-110 E MLB 03-Mar-84 C 4 0 0 0 '
1209 EIN-110 E RY 05-Sep-80 W 183 0 12 0 1093 EIN-111 E MLB 06-Mar-84 C 710 49 0 0 1210 EIN-11'1 E RY 14-Aug-80 W 3003 4 200 4 1094 EIN-112 E MLB 22-May-84 C 2540 107 0 0 1211 EIN-112 E RY 30-Sep-80 W 2853 0 190 0 1095 EIN-113 E BAR 10-Jan-84 C 40 1 O O 1212 EIN-113 E KK2 19-Aug-82 W 273 7 18 7 1213 EIN-113 E JVW 09-Jun-84 W 273 7 18 7 1096 EIN-114 E MLB 20-Mar-84 C 40 1 O O 1214 EIN-114 E BEB 06-Jun-84 W 273 32 18 18 1097 EIN-115 E MLB 20-Mar-84 C 4 1 O O 1215 EIN-115 E MAK 24-May-83 W 243 0 16 0 1216 EIN-115 E TWZ 18-Jan-84 W 243 0 16 0 1098 EIN-116 E MLB 16-Jan-84 C 366 14 0 0 1217 EIN-116 E IFD 18-Jul-81 W 813 8 54 8 1099 EIN-117 E FJR 01-Dec-83 C 4 0 0 0 1218 EIN-117 E DP 03-Feb-83 W 363 8 24 8 1100 EIN-119 E FJR 15-Dec-83 C 48 0 0 0 1219 EIN-119 E SL 08-Sep-82 W 858 20 57 20 1220 EIN-119 E RLM 15-Jan-82 'W 858 20 57 20 1101 EIN-120 E MLB 15-Dec-83 C 4 0 0 0 1221 EIN-120 E LMB 13-Sep-79 W 453 4 30 4 1102 EIN-121 E FJR 21-May-84 C 4 0 0 0 1222 EIN-121 E MAK 27-Oct-82 W ---
0 0 0 1223 EIN-121 E RY 10-Nov-80 W ---
0 0 0 1224 EIN-121 E LMB 13-Sep-79 W ---
0 0 0 1103 EIN-122 E TWZ 24-Jan-84 C 59 4 0 0 1225 EIN-122 E TWZ 23-Jan-84 W 303 1 20 1 1104 EIN-123 E MLB 24-Feb-84 C 94 0 0 0 1226 EIN-123 E DRH O2-Feb-84 W 678 0 45 0 1227 EIN-123 E SL 27-Jul-82 W 678 0 45 0 1105 EIN-124 E TWZ 16-Jan-84 C 24 O O O 1228 EIN-124 E TWZ 16-Jan-84 W 303 0 20 0 1229 EIN-124 E LAP 21-Mar-84 W 303 0 20 0 1106 EIN-125 E MLB 16-Jan-84 C 28 1 O O 1230 EIN-125 E MLB 12-Jan-84 W 363 0 24 0 1231 EIN-125 E LKB 08-Mar-84 W 363 0 24 0 1107 EIN-126 E MLB 20-Mar-84 C 38 6 O O 1232 EIN-126 E LAP 10-Jan-84 W 513 26 34 17 .
1233 EIN-126 E TWZ 03-Aug-84 W 513 26 34 17 1234 EIN-126 E MK 24-May-83 W 513 26 34 17 1108 EIN-127 E MLB 20-Mar-84 C 30 7 O O 1235 EIN-127 E LAP 05-Mar-84 W 393 33 26 13 1236 EIN-127 E DKW 03-Apr-84 W 393 33 26 13 1237 EIN-128 E LAP 28-Feb-84 W 123 13 8 8 1109 EIN-129 E MLB 24-Feb-84 C 14 2 O O
- 1238 EIN-129 E MAK 12-Apr-83 W 198 0 13 0 1239 EIN-129 E JVW 16-May-84 W 198 0 13 0 1110 EIN-130 E TWZ 10-Jan-84 C 6 1 O O 1240 EIN-130 E RLM 21-Oct-81 W 168 0 11 O AR000275
. 26-Jul-86 CSR REINSPECTION RESULTS FOR LKC PAGE 23
- ITEM R INSP DATE ATT IP DP WI WD 1241 EIN-130 E KK2 24-Aug-82 W 168 0 11 0 1111 EIN-131 E DJS 18-Feb-82 C 289 15 0 0 1242 EIN-131 E RLM 16-Feb-82 W 258 0 17 0 '
1243 EIN-131 E FJR 26-Jul-82 W 258 0 17 O l 1112 EIN-132 E MLB 24-Feb-84 C 4 2 O O !
1244 EIN-132 E MLB 12-Jan-84 W 183 0 12 O l 1113 EIN-133 E MLB 24-Feb-84 C 16 2 O O 1245 EIN-133 E KK2 20-Aug-82 W 303 0 20 0 1246 EIN-133 E JVW 09-Jun-84 W 303 0 20 0 1 1114 EIN-134 E JVW 10-Jan-84 C 2545 6 0 0 1247 EIN-134 E JVW 09-Jun-84 W 153 1 10 1 1248 EIN-134 E KK2 19-Aug-82 W 153 1 10 1 1249 EIN-134 E MAK 11-Apr-83 W 153 1 10 1 1115 EIN-135 E BAR 10-Jan-84 C 4 2 O O 1250 EIN-135 E MAK 08-Apr-83 W 183 0 12 0 1251 EIN-135 E KKE 21-Aug-82 W 183 0 12 0 1252 EIN-135 E JVW 05-Jun-84 W 183 0 12 0 1116 EIN-136 E MLB 16-Jan-84 C 4 1 O O 1253 EIN-136 E JVW 16-May-84 W 228 2 15 2 1117 EIN-137 E MLB 24-Feb-84 C 4 O O O 1254 EIN-137 E KK2 13-Jan-82 W 243 9 16 9 1118 EIN-138 E MLB 20-Mar-84 C 76 4 0 0 1255 EIN-138 E TWZ 03-Aug-84 W 63 15 4 11 ,
1256 EIN-138 E MAK 24-May-83 W 63 15 4 11 1119 EIN-139 E MLB 24-Feb-84 .C 4 O O O 1257 EIN-139 E MLB 16-Jan-84 W 93 0 6 0 1258 EIN-139 E MAK 24-May-83 W 93 0 6 0 1120 EIN-140 E MLB 24-Feb-84 C 4 0 0 0 1259 EIN-140 E MAK 24-May-83 W 93 0 6 0 1260 EIN-140 E MLB 16-Jan-84 W 93 0 6 0 1121 EIN-141 E MLB 20-Mar-84 C 4 0 0 0 1261 EIN-141 E MAK 24-May-83 W 93 0 6 0 1262 EIN-141 E MLB 17-Jan-84 W 93 0 6 0 1122 EIN-142 E MLB 20-Mar-84 C 4 O O O 1263 EIN-142 E MLB {
17-Jan-84 W 93 0 6 0 i 1264 EIN-142 E NPC 14-Feb-84 W 93 0 6 0 l 1123 EIN-143 E MLB 20-Mar-84 C 4 0 0 0 1265 EIN-143 E MAK 23-May-83 W 153 0 10 0 1266 EIN-143 E MLB 19-Jan-84 W 153 0 10 0 1124 EIN-144 E MLB 12-Mar-84 C 40 4 0 0 1267 EIN-144 E LAP 09-Jan-84 W 183 17 12 12 1268 EIN-144 E MLB 22-Oct-84 W 183 17 12 12 1125 EIN-145 E MLB 24-Feb-84 C 40 1 O O 1269 EIN-145 E MAK 24-Feb-83 W 1083 15 72 12 1270 EIN-145 E JVW O2-Mar-84 W 1083 15 72 12 1126 EIN-146 E KLB 29-Sep-81 C 97 18 0 0 I 1271 EIN-146 E WW 20-Jul-81 W 723 4 ~48 6 1127 EIN-147 E KLB 29-Sep-81 C 73 3 0 0 I
1272 EIN-147 E WW 20-Jul-81 W 543 10 36 10 1128 EIN-148 E FJR 15-Sep-83 C 74 4 O O
'1273 EIN-148 E SL 26-Aug-82 W 663 0 44 0 1129 EIN-149 E MK 13-Jul-81 C 61 1 O O 1130 EIN-150 E DJS 27-Jan-82 C 9 1 O O 1131 EIN-151 E JLL 24-Jan-84 C 51 O O O 1132 EIN-152 E KLB 16-Jun-82 C 54 6 O O AR000276
26-Jul-86 CSR REINSPECTION RESULTS FOR LMC PAGE 24
- ITEM R INSF DATE ATT IP DP WI WD 1133 EIN-153 E MLB 04-May-84 C 64 O O O 1134 EIN-154 E FJR 20-Jun-84 C 74 7 O O 1135 EIN-155 E DJS 08-Mar-82 C 10 1 O O 1136 EIN-156 E MLB 21-Nov-82 C 9 0 0 0 1274 EIN-156 E MLB 21-Nov-83 W 93 0 6 0 1137 EIN-157 E JLL 24-Jan-84 C 51 O O O 1138 EIN-158 E MLB 30-Mar-84 C 39 10 0 0 1139 EIN-159 E DJS 03-Feb-82 C 9 5 0 0 1140 EIN-160 E FJR 16-Feb-84 C 9 0 0 0 I
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(
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N UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
REBUTTAL TESTIMONY OF KENNETH T. KOSTAL (ON ROREM Q.A. SUBCONTENTION 2)
(Harassment and Intimidation)
August, 1986 i
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s REBUTTAL TESTIMONY OF KENNETH KOSTAL ON THE BCAP CSR SAMPLES AND ENGINEERING EVALUATIONS FOR ELECTRICAL WORK Q.l. Please state your full name for the record.
A.l. Kenneth Thomas Kostal.
Q.2. By whom are you employed and in what capacity?
A.2. I am employed by Sargent & Lundy (S&L) in the capacity of Project Director for the Braidwood Project.
Q.3. What are your responsibilities for the design of the Braidwood Project?
A.3. As Project Director for the Braidwood Project, I am responsible for implementation and technical integrity of S&L's design efforts. I regularly report to the I
client regarding S&L's performance on the Braidwood Project and on the status of engineering. I work with Commonwealth Edison (CECO) and the Project Team to establish significant design parameters and direct appropriate application of S&L engineering.
h s .
Q.4. Please state your educational background and profes-sional experience.
A.4. I graduated from the University of Illinois in 1965 with a BA in Architectural Engineering and in 1967 with a MS in Architectural Engineering. I have 20 years of experience in the field of civil engineering which includes civil / structural / architectural engi-neering and design work for fossil and nuclear power plants. My assignments have included 14 units with a total capacity in excess of 10,000 megawatts. I have also been involved in numerous studies. In addition, as a structural engineer, I have performed numerous calculations and assessments relating to welded steel construction which includes the design of welded con-nections. Prior to joining Sargent & Lundy in 1967, I was engaged by the University of Illinois as an instructor in structural design and as an engineer responsible for structural design and construction drawings for light office buildings.
I I am a registered professional engineer in 31 states l and I also have a separate structural engineering license in the State of Illinois and am licensed in Alberta, Canada. Presently I am a member of the following organizations:
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e y
American Concrete Institute American Institute of Steel Construction American Nuclear Society American Society of Civil Engineers ;
Structural Engineers Association of Illinois Western Society of Engineers Q.5. What is the purpose of your testimony?
A.S. The purpose of my testimony is to discuss the engi-neering evaluations performed by Sargent & Lundy with respect to the various weld discrepancies identified in the electrical construction categories during the Construction Sample Reinspection (CSR). I also am prepared to respond to questions with respect to the methods of structural analysis used to evaluate the objective attribute discrepancies discussed in Mr. Thorsell's testimony.
In this testimony I also review the basis on which the more highly stressed portions of the CSR samples were selected in the electrical construction categories.
In addition, based on the results of the reinspection and engineering evaluations, I offer an opinion regarding the quality of the reinspected L. K.
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. 1 Comstock work. I discuss the conservatisms in the design of Braidwood which are relevant in asserting the adequacy of L. K. Comstock's work and the perfor-mance of the Comstock Q.C. inspectors.
Q.6. What is the basis for your knowledge concerning the CSR sample selection and engineering evaluations referred to in your previous answer?
A.6. Since the initiation of the CECO BCAP Program in 1984 I have been intimately involved in the program. This involvement began with the forming of Sargent &
Lundy's project team dedicated to the BCAP Program.
The project team also included a liaison group who provided a direct communication link between CECO BCAP personnel and S&L project team members. As Project Director I was assigned to head up this entire effort on S&L's part. Of particular importance was the effort and inv21vement on S&L's part associated with the Construction Sample Reinspection portion of the BCAP Program. I initially provided input into the CSR Program. This included the sampling selection and the inspection attributes associated with each category.
I was involved in daily communication with the project team during the CSR reinspections and our engineering
- e. valuations. These evaluations were conducted in
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l accordance with S&L standards which were reviewed and approved by me. In addition, I conducted weekly meetings at the Braidwood Station with the S&L project-team to review the progress of our efforts in support of the BCAP Program. Also reviewed at these meetings were the evaluations performed by S&L in support of the CSR effort.
1 I reviewed engineering evaluations performed by S&L for electrical construction categories throughout the duration of the CSR and more recently in preparing i
this testimony.
In addition to the daily involvement in the program I have made numerous status presentations to the NRC on a monthly basis, reviewing the various engineering evaluations performed by S&L.
Q.7. Are you familar with Dr. Kaushal's testimony, and in particular the table showing CSR Reinspection Results attached to Dr. Kaushal's testimony, Attachment 2C (Kaushal-3)?
A.7. Yes.
Q.8. Does Dr. Kaushal's testimony and in particular .
Attachment 2C (Kaushal-3) accurately reflect the
< results of the engineering evaluations performed by S&L for purposes of the CSR in the electrical construction categories?
A.8. Yes.
Q.9. Dr. Kaushal states in his testimony that the BCAP CSR element included six construction categories within the scope of L. K. Comstock's work. Do you agree with this categorization?
A.9. Yes. The six construction categories within the scope of L. K. Comstock's work include: conduit, conduit hangers, cables, cable pans, cable pan hangers and electrical equipment installation. Each category is a group of hardware items constructed using similar processes or containing similar types of components.
These six construction categories encompass all safety-related work performed by L. K. Comstock.
Q.10. Is stress a significant design factor with respect to any electrical construction category?
s A.10. Yes, for one electrical construction category, cable pan hangers. All cable pan hangers are uniquely designed such that the stress in each component is maintained within code allowables. Cable pan hangers consist of frame supports, composed of individual structural members, as compared to conduit hangers which are generally simple cantilever members. Due to the configuration of the cable pan hanger supports and the various loads applied to these supports, cable pan hanger designs are performed on an individual hanger basis. These hangers are designed to accommodate cable pans assumed to be fully loaded. Member stresses are evaluated for individual hangers during the design to assure they are within code allowables.
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Q.11. Why isn't stress a significant design factor for the remaining electrical construction categories?
A.11. Stress is a consideration in establishing maximum i conduit spans; however, design stress levels in con-duit is generally low throughout the entire conduit population due to the typical spans found in the plant. The design standards are established based on the heaviest cables which could fit into each conduit and the physical properties of the smallest diameter conduit. These standards establish maximum allowable
s conduit spans which meet code allowable stresses. In reality,. spans are less than allowed due to plant conditions and arrangements. Also in most instances maximum size cables are not installed in each conduit. i l
These factors result in conduits stressed to much I lower levels than allowed. !
For conduit hangers, stress is a consideration but it is not a significant design factor. Individual conduit hangers have been designed by selection from standard conduit hanger load tables. The conduit hanger load tables have been established generically based on stress calculations assuming bounding condi-tions. For practical economical reasons the design of conduit supports is a simplified conservative method.
For cable construction category, stress is not a design factor. Cables are supported throughout their length by cable tray and conduit systems. Therefore, cable stress is not a criteria for design.
Stress is not a significant design' factor in the cable pan construction category, however, it is considered.
Allowable cable pan spans have been determined by stress calculations based on maximum pan loading and seismic accelerations. Cable pans are supported by T l hangers at intervals less than the maximum allowable l
standard spans due to plant conditions and arrange- '
ments. Since the actual cable pan spans are less than
]
the established allowable spans, unique cable pan l
- calculations are not performed. The design margins, which are inherent in this standard design approach, result in actual cable pans installed which are not highly stressed.
For electrical equipment installation, stress is a j consideration but it is not a significant design factor. Electrical equipment mounting details have been designed conservatively based on loads derived from peak seismic accelerations. Many of the equip-ment mounting details are standardized, as was the case with conduit supports. Individual equipment mounting details, designed by selection from standard tables, do not have actual stress calculations com-pletec which represent its actual design loaded condition.
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.l Q.12. Explain how more highly stressed items were added to )
the CSR sample for cable pan hangers. I i
A.12. For construction categories for which stress is a significant design factor, efforts were made to ensure 1
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. 1 that the total sample contained a population of more highly stressed items. A list of highly stressed hangers was prepared by S&L and issued to BCAP for their use in randomly selecting highly stressed-items. Additional items were randomly selected from -
this list by the BCAP Task Force for reinspection.
For cable pan hangers, the BCAP Task Force selected ten additional items in order to assure a minimum of 60 samples were inspected. This resulted in a total of 68 cable pan hangers which were more highly stressed.
Q.13. For each electrical construction category, how many reinspections of cubjective attributes were performed as part of the CSR?
A.13. A summary of reinspections and evaluations for subjective attributes is included in Attachment 2C (Kostal-1). No welding was performed in the conduit and cable construction categories; as such, no subjec-l tive attributes were reinspected. There were a total i of more than 10,000 welds which were ir.pected to 17 different subjective attributes.
Q.14. For each construction category, how many subjective discrepancies were submitted to Sargent & Lundy for engineering evaluation?
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i A.14. The total number of subjective discrepancies submitted to Sargen.t & Lundy for evaluation are shown below, j l
expressed in terms of inspection points found to be discrepant (" discrepancy points"). The figures in i
parenthesis show the percentage of discrepancy points when compared to the entire population of inspection points for each construction category.
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i Conduit Hangers 171 (0.6%)
l Cable Pans 77 (0.82%)
Cable Pan Hangers -1569 (1.22%)
j Electrical Equipment Installation 404 (1.07%)
i Q.15. How were the discrepancies associated with the subjec-tive attributes evaluated?
T i A.15. All discrepancies found during reinspection were sub-I jected to an engineering evaluation by Sargent & Lundy
{
to determine the extent to which-the discrepancy affected an item's ability to perform its safety-related design function. Evaluations were performed 3
by comparing the discrepancies with design parameters, tolerances, and design margins using either documented 1
engineering judgment or calculations. The majority of the discrepancies required simple comparative evalua-tions which established-that each discrepancy had a 1
1 5
, .,. .- .-.,,r_. . - - ,_ . . . . . . . . . . _ - - . . . , . . . . . . . . _ , , , , - .-m_- -- ,_ . . - , , . , , - . . . . .
I negligible effect on the items capacity.to carry. load and no effect on its safety-related design function.
Other discrepancies required unique calculations to evaluate capacity reductions in order to determine whether the item would be able to perform its safety-related design function.
Discrepancies were evaluated by first determining whether they had an effect on the capacity of the weld. Next, if there was an effect, its magnitude was established by subtracting the defective portion when determining the overall remaining capacity of the weld.
4 When a weld had multiple discrepancies, a single eval-I
! uation was performed to determine their effect. In
! ths case of weld defects, for example, there were I cases where more than one defect was present on a weld or in a welded connection, but only one evaluation was performed which assessed the combined effect of the
- individual defects.
i l
} Where necessary, adjacent welds were evaluated to i determine if the design loads could be accommodated in
! a welded assembly. Where this engineering evaluation was done, the adjacent welds were reinspected to verify weld quality.
l
Weld discrepancies were evaluated by considering those portions of weld with defects to be totally ineffec-tive and then calculating the weld capacity of the remaining weld. In the case of weld size or length discrapancies, the actual weld size or length was used to determine weld capacity. Disregarding defective portions of welds is a conservative approach because even the discrepant portion of the weld exhibits significant load-carrying capacity, i
} Q.16. How did S&L derive the inspection point and discre-pancy point numbers which appear in your testimony, Mr. Thorsell's testimony, and Dr. Kaushal's testimony?
A.16. The process of deriving the discrepancy point and inspection point data is not merely arthimetical; to some extent it is judgmental. In 1085 Sargent & Lundy engineers and designers reviewed each CSR checklist to determine the number of inspection points associated
- with each attribute. Once the number of inspection i
points for each attribute was established, each completed CSR inspection package was reviewed by Sargent & Lundy personnel familiar with the hardware I
design and CSR to determine the total number of inspection points for each hardware iten.. The number ;
1 of discrepancy points was then determined by reviewing l
[
h ..
each CSR observation report. The results appear in my testimony and Mr. Thorsell's testimony and in Attachment 2C (Kaushal-3).
In 1986, S&L was again asked to derive inspection point and discrepancy point data, in two new formats
--on a per item basis and on a weld-by-weld basis.
This required S&L to review and summarize data previously created and selectively repeat the process described in the preceding paragraph. The results of this 1986 effort are reflected in Attachment 2C (Kaushal-4). There is a net difference of three discrepancy points between the total number of discrepancy points derived in 1985 and in 1986.
Q.17. How do these methods of engineering evaluation compare with those used in the Byron QCIRP?
A.17. The methods used for engineering evaluation of discre-pancies for CSR are essentially the same as those employed in the Byron QCIRP. The only differences to my knowledge are the following two distinctions. S&L performed engineering evaluations only on a sample of weld discrepancies found in the electrical work for the Byron QCIRP where as for Braidwood CSR weld discrepancies, S&L evaluated each weld discrepancy.
- In addition, for CSR weld discrepancies involving a 4
crack, S&L evaluated whether the crack could propagate and, if not, credit was taken for the uncracked length of the weld segment. This weld propagation assessment was not conducted for the Byron QCIRP weld discrepan-i cies, where the entire weld segment was to be non-existent, whenever a crack was assumed found.
1 Q.18. What was the purpose of categorizing the reinspection discrepancies as insignificant, notable, and design significant?
, 1 A.18. Discrepancies are installed conditions which deviate from the design shown on design drawings. The sever-ity of a discrepancy can range from an insignificant cosmetic flaw such as a weld splatter, which has no impact on the capacity of an item to perform its function, to a more significant flaw which could result in a component whose stress level exceeds code allowables. Therefore, the number of discrepancies alone does not convey the actual quality of the work.
To more accurately convey the quality of the work, discrepancies have been categorized by level of a
severity.
i 1
l Q.19. What did Sargent & Lundy's engineering evaluations of the discrepancies for subjective attributes in each of the six construction categories show?
A.19. Sargent & Lundy engineering evaluations of subjective attributes showed that there were no design signifi-cant subjective attribute discrepancies in any elec-trical construction category. In fact, over 98%
l (98.7%) of the total number of CSR subjective attribute inspection points showed no discrepancies at all. Approximately two-thirds of the discrepancies evaluated were determined to be insignificant. The i remaining one-third resulted in notable discrepancies.
I 1
j Although weld joint capacities were reduced in these cases, the discrepancies did not impair the capability of the items, which remained within code allowables.
Q.20. What does the term " design significance" mean?
A.20. " Design significance" relates to the ability of the structural components to perform their intended func-tion, which is to carry all design loads within code established allowable stress. Code established allow-able stress is incorporated into the design criteria for all equipment supplied to Braidwood and in parti-
! cular structural steel beams. These code established
! i
i allowable stresses have been developed to provide required margins of safety against failure. Anything which affects the ability of a structural component to i perform a function within the code allowable stresses has design significance. S&L engineering evaluations, performed on L. K. Comstock identified discrepancies, established that the stress in all components did not exceed the code allowable stress and consequently are not design significant.
Q.21. What does the term " design margin" mean?
A.21. The concept of margin is one that is inherent in the engineering discipline. Engineers design a structure such that it is sufficiently strong to withstand the expected forces and stresses with spare or extra strength to account for uncertainties and contingen-cies. This extra strength is called margin.
" Design margin" is the difference between code allow-able stress and actual stress. Engineers maintain the presence of design margins by ensuring that actual stress is less than code-allowable stress. For example, connections are designed in_ groups rather than individually.
l The most highly stressed connection is designed to be i
within code-allowable stresses; therefore, all other I connections within the group, which are not as highly stressed, have even greater design margins. Thus, the actual stresses for most connections in the example will be less than those allowed by the applicable code.
There is a second margin in the structural design of connections. This is the margin that code writers put into the design process in the form of the difference between code-allowable stresses and the failure of a component. Code writers typically attempt to obtain a margin of approximately two when they write a code.
! This means that a structure designed to a code could carry approximately twice the design load and not fail. These code required margins were not reduced by any discrepancy identified in the CSR.
a Q.22. Please discuss the " notable" discrepancies identified in each construction category.
A.22. Notable subject.ive discrepancies were identified in
- the construction categories of cable pans, cable pan hangers, conduit hangers and electrical equipment installation. There were no notable subjective discrepancies associated with cable or conduit
construction categories. The following is a review of the types of notable discrepancies found in each of these categories:
Conduit Hangers For the conduit hanger population 28,300 reinspection points were reviewed; out of this population 71 nota-4 4 ble discrepancies were identified. This represents less than 0.3% of the entire population. These nota-ble discrepancies were related to weld size and weld length. In all cases the actual stresses were within code allowables. The minimum design margin remaining after this evaluation was more than 30 percent above code allowables. The average design margin remaining for all welds with discrepancies was 900 percent above code allowables.
Cable Pans For the cable pan population 9400 reinspection points were reviewed; out of this population 22 notable dis-crepancies were id':ntified. This represents approxi-mately 0.2% of the entire population. The notable discrepancies were related to cable pan hold down welds. Six out of 605 cable pan hold down welds
inspected by BCAP were missing. In all cases where a missing weld was observed an adjacent weld was present 1
to carry the design load. Remainder of the notable I weld discrepancies were found to be underlength welds.
There were no design significant discrepancies. The minimum design margin remaining after this evaluation was more than 30 percent above code allowables. The average design margin remaining for all welds with discrepancies was 300 percent above code allowables.
Cable Pan Hangers For the cable pan hanger population, 129,000 reinspec-tion points were reviewed; out of this population 469 notable discrepancies were identified. This repre-sents less than O.4% of the entire population. These notable discrepancies were mainly related to weld size, missing portions of welds and weld length. In all cases the actual stresses were within code allow-ables. The minimum design margin remaining after evaluation was more than 5 percent above code allow-ables. The average design margin remaining for all welds with discrepancies was 800 percent above code allowables.
,w
1 Electrical Equipment Installation j l
l l
For the electrical equipment installation population, 37,700 reinspection points were identified; out of this population 220 notable discrepancies were identi-l i fied. This represents less than 0.6% of the entire l l
population. These notable discrepancies were related I
to weld size, location, concavity, and length. In all cases the actual stresses were within code allowables.
The minimum design margin remaining after evaluation was more than 10 percent above code allowables. The average design margin remaining for all welds with discrepancies was 500 percent above code allowables.
Q.23. What conclusion about the quality of the reinspected L. K. Comstook work can you draw from the evaluation of subjective attribute discrepancies identified in the CSR?
A.23. It is my professional judgment that the quality of the L. K. Comstock work on the Braidwood Station is ade-quate. My judgment is based on two significant elements. First none of the discrepancies identified 1
with respect to L. K. Comstock work had design signi- l l
ficance. Second, the existence of conservative load-ings and assumptions used in the design of Braidwood
O
?
Station and the margins inherent in that design provides the capacity to accommodate the type of discrepancies identified in the CSR Program. These types o'f discrepancies are those that I would have expected to find.
Q.24. In assessing the quality of L. K. Comstock's work, 3 what significance, if any, do you attach to the rate of subjective and objective discrepancies identified in the CSR Program?
A.24. In my judgement the results of the electrical portions s of the CSR Program indicated that the rate of discrepancies is extremely low. Over 98% (98.7%) of all inspection points were found to be correct. Less than 2% were found discrepant. When evaluating these discrepancies the vast majority of them (89%) were determined to be insignificant; meaning, they had no effect or minimal effect on the capacity of the component to perform its function. If I werh to examine the data on a weld or individual item basis, the conclusions would still be the'same, that is the vast majority of discrepancies associated with i l
individual items or welds are insignificant. Ninety- ^ -
l 1
nine point six percent (99.6%) of all electrical inspection points were found to be either correct or
-c
having insignificant discrepancies which have little l l
or no effect on the capacity of the component to perform its function.
The remaining notable discrepancies were evaluated and none were found to be design significant. Sinco an extremely low percentage of discrepancies were found to be notably discrepant (approximately .4%) the results suggest to me that the inspectors were finding
, the important discrepancies which could effect the capacity of the component and that these discrepancies were corrected during the construction process.
In determining the quality of the electrical work these percentages were less important than other considerations. They may be useful, however, in i
1 evaluating the quality of the individual inspector's ,
performance. The important consideration, from my N
\
d perspective, in determining the adequacy of construc-tion, relates to the impact of discrepancies on reducing the capacity of the component. As previously stated the types of discrepancies found which could effect the capacity of the component were small. The design margin remaining after accounting for notable discrepancies were always sufficient to assure i
,el ec r ct i dl components would perform their intended e i i
i function and remain within code allowables. These results indicate to me that the work performed in the
. electrical area is adequate.
i Q.25. Please describe in more detail the conservatisms in i
the design of Braidwood which are relevant in assessing the adequacy of L. K. Comstock's work.
A.25. Various conservatisms exist in the design process a which provide considerable design margin. For purpose
! of discussion, these conservatisms may be summarized 1
i into three broad categories: conservatisms attributed to code requirements, seismic design conservatisms and conservatisms attributed to practical design /construc-tion implementation.
Conservatism is applied by the design margin that. code i
l writers put into the design process in the form of l allowable stresses. The code writers typically
.! attempt to obtain a margin of approximately two when
[
- they write the code. This means that a structure j designed to code could carry approximately twice the j design load and not fail. It should be noted that in
{ our design and evaluation of discrepancies we do not i
encroach on code margins.
l i .
- - - - , , , ,-, .,,n----.- . . , ~ , . - - - - , - , , . - - , - , - - . , - - - . - , - , , . . . . , - - - . . , , , ,,n ,n ,.-
i The welding code also provides margin indirectly by requiring minimum size and lengths for welds. An i
example of this would be the case of welding a 1/2 inch thick gusset plate connection. Based on design calculations, a 1/8 inch fillet weld may be all that l is required. However, the code requires that welds be
! a minimum size based on the thickness of_the base metal being welded.
i Therefore, even though only a 1/8 inch weld is j required by design, a 3/16 inch weld has been i
specified as required by the code for 1/2 inch thick i material.
i.
l In the second category, seismic _ design conservatisms have been established in order to account for seismic forces in a practical manner. Cable pan hangers are conservatively designed by performing seismic analysis for each individual hanger. This individual analysis
- isolates the hanger from the adjacent supports. The actual cable pan support system consists of cable trays supported by a series of hangers. This permits load redistribution to adjacent hangers. A refined computer analysis can be performed for the cable pan i .
i support system consisting of the trays and the series of hangers. The analysis results in significantly I
j !
, ._ -_- __ _ ._. -._ _ _ _ _ , . - _ . , . . _ _. ,. _ . , . . _ , . _ , _ , _ . _ _ . . ~ . . - _ -
l lower stresses and provides for additional design margin.
As part of the evaluations performed for the Byron licensing hearings, three cable pan support assemblies were analyzed using these more refined techniques.
The result of that analysis showed that even with the inclusion of the most discrepant weld and the corres-ponding impact on the support assemblies, none of the connections or members exceeded the code allowables, even when loaded to twice the design load. The time and costs involved in the preparation and application of a more refined computer analysis make this approach less practical.
In addition to the conservatism of enveloped seismic analysis as compared to systems dynamic analysis, the conduit, conduit hangers, cable pan and electrical equipment mountings have all been designed based on peak seismic accelerations. A more refined analysis in which the seismic acceleration is selected based on the actual component frequency results in a lower seismic design force.
Implementation of any of these refined techniques of seismic analysis in the design phase are less practi ,
I l
I cal based on cost economics. Since a simplified conservative method was used in the original design, all subsequent design changes can be evaluated with minimal consideration. If refined analysis had been used at the outset of design, subsequent design changes would have required comprehensive evaluation.
Many conservatisms can be attributed to the third category, practical design / construction implementa-tion. The design margins which exist in the practical design / construction process generally relate to the
, standardization of components and their connections.
This standardization results in more efficient design and more economical construction. For example, in the area of conduit hanger supports, a series of standards have been developed which are utilized by designers to pick the various component hardware. These standards are based on typical member sizes, in which a member size can carry a range of design load. The purpose of standardizing the design is to limit the number of components thereby allowing for ease in construction of the conduit hanger assembly. In the process of l l
standardizing the designs, the maximum allowable load !
l is determined for each standard component. When a designer chooses a component he compares the actual design load with the maximum standard load, and in all i
! t
s cases the standard hanger will have margins remaining. This process provides for a more economical design as well as for a more economical construction of the components. It also provides for additional design margins to accommodate construc-tion discrepancies which may occur.
Cable trays are routed and sized prior to detailed cable routing. The cable trays and their supports are then designed to accommodate the weight of the maximum number of cables that can fit into the cable trays.
Most of the cable trays and cable tray supports at Braidwood are not loaded as heavily as has been assumed in design and thus most have additional margin.
Similarly, most of the conduits and conduit supports have been designed to accommodate the maximum number of cables that will fit into a conduit. Since most of the conduits are not filled with the maximum number of ,
cables, most of the conduits and conduit supports are not loaded as heavily as has been assumed in design and thus most have additional margin.
The materials used for cable trays, cable tray supports and conduit supports have been specified by the engineer to meet minimum-strength requirements.
l In order to consistently meet these minimum require- !
' l ments, manufacturers typically set for themselves )
higher strength requirements to avoid having to scrap substandard material. The actual test results indicate that Braidwood electrical hanger materials have an average strength equal to 20% more than the minimum strength assumed in the design.
All of the conservatisms discussed in my testimony are applicable to the component design and therefore relate to all the subjective evaluations and in a similar fashion to the objective evaluations addressed in Mr. Thorsell's testimony.
The conservatisms as related in the preceding testi-mony overlap and are often times cumulative. These conservatisms provide a basis for my judgment regarding the adequacy of the work performed by L. K.
Comstock. -
Q.26. In discussing the results of the Byron QCIRP in its October 16, 1984 supplemental initial decision, the Byron Licensing Board observed:
?
- 4 "The absence of any design-significant discrep-ancies leads to the conclusion that despite the existence of discrepancies, the original inspectors had sufficient competence not to overlook design significant construction defects.
This conclusion, however, has limited value as a demonstration of inspector competence. The greater the sum of the design margins, the less it challenges the inspector's competence to discover design-significant defects."
LBP-84-41, 20 NRC 1203, 1212-13. Would you agree or disagree with this statement if applied to the results of the BCAP CSR for electrical construction categories?
A.26. I agree with the Byron Licensing Board's statement.
In fact, a broader statement can be made regarding the elements required to assure that a component item can carry its intended design loads. These elements include the plant design, the quality of construction and the quality control inspection.
The engineering process includes various elements of conservatisms in the development of an individual component design. These conservatisms first include the code which has been established in most cases to maintain a design margin of two. This means that a component can accommodate twice its design load prior to failure. In addition, the engineer standardizes f
?
various component designs for maximum loading condi-tions and maximum installation tolerances which could occur. The implementation of this standardization results in very conservatively designed individual components which assures additional margins of safety.
The second element is the quality of construction.
The crafts, through their experience and training, are
, familiar with the construction of these various components. This generally results in components being installed to an adequate standard to assure the components' ability to perform their intended func-tion.
The third element is the quality control inspection performed in the field. This quality control inspec-tion provides an additional level of review to assure that the components are constructed adequately. All three of these elements act together to assure that a component item can carry its intended design loads in a safe manner. The larger the design margins ,
1 l
initially provided by the engineer; the better a component can accommodate deficiencies arising out of the construction installation process. In a like manner, the better the construction quality and the more conservative the design, the less challenge there F
is for quality control inspection. In the electrical construction categories at Braidwood, these three elements have acted together to assure that no design significant discrepancies have been found.
1 Q.27. Have the conservatisms in design of the electrical construction categories changed since the CSR cut-off date of June 30, 1984?
A.27. No , prior to June 1984 and subsequent to that time the engineering design methods have remained constant; therefore, the conservatisms discussed in this testi-mony are applicable to LKC prior to and subsequent to June 30, 1984.
Q.28. Does this complete your testimony?
A.28. Yes.
f
- 32.-
i
_ . . , ~ . - . - . . . _ .. -_
l ATTACHMENT 2C (KOSTAL-1)
SUMMARY
OF SUBJECTIVE DISCREPANCIES i ELECTRICAL CONSTRUCTION CATEGORIES i
PERCENT l ELECTRICAL PERCENT PERCENT DESIGN CONSTRUCTION REINSPECTION PERCENT INSIGNIFICANT NOTABLE SIGNIFICANT CATEGORY POINTS DISCREPANCIES DISCREPANCIES DISCREPANCIES DISCREPANCIES Conduits 0 0 0 0 0 Conduit Hangers 28,300 0.60 0.35 0.25 0 Cables 0 0 0 0 0 Cable Pans 9,400 0.82 0.59 0.23 0 Cable Pan Hanger 129,000 1.22 0.86 0.36 0 Electrical Equip-ment Installation 37,700 1.07 0.49 0.58 0 TOTAL 204,400 1.09 0.71 0.30 0
'.=**. -
s
>W
i
.'t~
UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
REBUTTAL TESTIMONY OF THOMAS B. THORSELL (ON ROREM Q. A. SUBCONTENTION 2)
(Harassment and Intimidation)
August, 1986
.)
REBUTTAL TESTIMONY OF THOMAS B. THORSELL ON THE BCAP CSR ENGINEERING EVALUATIONS OF ELECTRICAL WORK Q.1. Please state your full name for the record.
A.l. Thomas B. Thorsell.
Q.2. By whom are you employed and in what capacity?
A.2. I am employed by Sargent & Lundy (S&L) as a Senior Electrical Project Engineer. My business address is 55 East Monroe Street, Chicago, Illinois 60603. I have been employed by S&L since June 1973. I am currently assigned to Commonwealth Edison Company's '
Braidwood Project.
Q.3. What are your responsibilities for the Braidwood Project?
A.3. As Senior Electrical Project Engineer for Braidwood, I am responsible for directing electrical engineers and designers in the development of conceptual design, design of individual system components and preparation of procurement specifications. I evaluate the proposals of manufacturers, make purchase recommendations, and monitor the activities of manufacturers to ensure that manufacturers' drawings and finished components are received on schedule. I
. . - . - . - . - -..- ._ . -.- - - . - . . . - . .. -..~._. . . - - - - - _ - .
1 j work with the client, Commonwealth Edison Company, and I
with manufacturer and contractor representatives to assure that the electrical design, engineering, and construction of Braidwood incorporate the latest
]
i techniques. I also coordinate the work of the S&L i
2 electrical engineering department with that of other S&L departments and review specifications and drawings-l i
to ensure that all electrical work'is correctly-done.
i j I am responsible for directing the evaluation of Braidwood Construction Assessment Program (BCAP) electrical discrepancies and for S&L's review and ;
i recommendation on BCAP nonconformance reports covering E ~
j electrical items.
4 I
I j Q.4. Please state your educational background and i
i professional experience.
I J A.4. I have a Bachelor of Electrical Engineering and Master ,
1 j of Science in Electrical Engineering from the ,
University of Minnesota. I am a registered
- professional engineer in the State of Illinois. ;
i I-In addition to the work described in A.3. above, I have experience at S&L in the electrical design,
- engineering and analysis of steam-electric' generating stations. This experience includes design and I
4 L
l
economic evaluation of auxiliary power systems, review of electrical designs to assure compliance with various IEEE standards, and performance of a variety of studies covering grounding system design, power system reliability, power system expansion and distribution system protection. I have developed computer programs for calculating power system reliability and for economic evaluation of power pool contracts between utility and industrial generation.
Q.S. What is the purpose of your testimony?
A.S. My testimony addresses the engineering evaluations performed by S&L with respect to the objective attribute discrepancies identified during reinspec-tions of objective attributes of L. K. Comstock work as part of the Construction Sample Reinspection (CSR). The engineering evaluations of subjective attribute discrepancies are addressed in the testimony of Mr. K. T. Kostal. In addition, I discuss in general terms the margins available in the electrical construction categories at Braidwood and the extencive testing which confirms the adequacy and operability of I
electrical equipment and connections prior to operation of the plant.
Q.6. What is the basis for your knowledge concerning the CSR engineering evaluations referred to in your previous answer?
A.6. I am familiar with the objective attribute discre-pancies identified in the CSR in the electrical construction categories. I reviewed them when they were submitted by the BCAP to S&L for evaluation. I discussed them with other S&L engineers as the evaluations were being performed. The electrical engineering evaluations of these objective attribute discrepancies were either prepared or reviewed by myself or were prepared and reviewed by people working under my direction. The structural engineering evaluations of objective attribute discrepancies were prepared by engineers working under Mr. Kostal's direction. I am familiar with the results of those evaluations, although Mr. Kostal is more qualified than I to answer questions regarding the methods of structural analysis used.
Q.7. Are you familiar with Dr. Kaushal's testimony?
A.7. Yes.
Q.8. Does Dr. Kaushal's testimony, and in particular Attachment 2C (Kaushal-3) accurately reflect the
i
\
results of the engineering evaluations of discrepancies in the electrical construciton categories performed by S&L for purposes of the CSR?
A.8. Yes.
- Q.9. Dr. Kaushal states in his testimony that the BCAP CSR element included six construction categories within
~
the scope of L. K. Comstock's work: conduit, conduit hangers, cables, cable pant, cable pan hangers, and 1 electrical equipment installation. Do you agree with this categorization of L. K. Comstock's work?
A.9. Yes, the six construction categories are consistent with the various types of work performed by L. K.
Comstock. The electrical construction drawings issued by S&L can generally be divided into these categories with a different type of drawing for each category.
L. K. Comstock's work procedures also reflect these categories with minor exceptions. There is a procedure for electrical equipment installation.
Conduit and conduit hangers are combined into a single procedure. Cable pans and cable pan hangers are combined into a single procedure. ' Separate procedures address cable pulling and cable termination.
Q.lO. How was inspection of these construction categories classified for purposes the CSR?
A.10. For each construction category, inspection points were established based on the attributes of the associated hardware and work involved. Inspection points were divided into two classifications: Subjective and objective. Visual weld inspections were classified subjective and all other inspections were classified objective. Visual weld inspection differs from the other inspections in that it relies more on the judgment and interpretation of the inspector than on measurement. Thus, visual weld inspection has a higher degree of subjectivity. My testimony concerns engineering evaluations of objective attribute discrepancies; that is, discrepancies other than those associated with visual weld inspection.
Q.11. Was all of the electrical work included in the CSR?
A.11. The CSR was limited to safety-related work which had been completed and quality control accepted prior to June 30, 1984. All safety-related work items from this period were not included in the CSR. Some work items were excluded due to inaccessibility. For example, it was not practical to destroy items such as cable terminations in order to perform the inspec-tion. Other work items were excluded because they i could not be recreated. For example, it was not
l possible to recreate items such as pulling tension on a pulled cable. Cable pulling tension is an inprocess inspection.
Q.12. For each electrical construction category, how many reinspections of objective attributen were performed as part of the CSR?
A.12. The following summarizes the number of CSR objective attribute reinspection inspection points:
Conduit 5800 Conduit Hangers 4400 Cables 20100 i
Cable Pans 21000 l
Cable Pan Hangers O Electrical Equipment Installation 20300 No evaluations of cable pan. hanger objective attributes were performed as part of CSR because of a separate "walkdown" program that provided 100%
i reinspection and repair as necessary of the objective attributes of cable pan hangers.
Q.13. For each construction category in the CSR, how many objective discrepancies were submitted to Sargent &
Lundy for engineering evaluation?
A.13. The following summarizes the number of objective attribute discrepancies submitted to S&L for engineering evaluation:
Conduit 146 (2.5%)
Conduit Hangers 118 (2.7%)
Cable 318 (1.6%)
Cable Pans 210 (1.0%)
Cable Pan Hangers N/A Electrical Equipment Installation 562 (2.8%)
Q.14. How were the discrepancies associated with the objective attributes evaluated?
- A.14. Evaluations were performed by comparing the discrepancies with design parameters, tolerances, and design margins using either documented engineering judgment or calculations. The evaluations were based on design information current at the time the evalua-tion was made. The majority of the discrepancies required only simple evaluations which established that each discrepancy had a negligible effect on the item's capacity and did not impair its ability to perform its safety-related design function. Other discrepancies required more detailed evaluations to l determine whether the item would be able to perform its safety-related design function. For CSR purposes, reinspection discrepancies were categorized as design significant, notable or insignificant.
Q.15. How do the methods of engineering evaluation compare I with those used in the Byron QCIRP?
~
l A.15. The methods used for engineering evaluation of BCAP discrepancies were the same as those used in the Byron QCIRP. l Q.16. What was the purpose of categorizing the reinspection discrepancies?
A.16. A discrepancy is an installed condition that deviates from the design shown on design documents. The severity of a discrepancy could range from a minor cosmetic blemish that has no impact whatsoever on function to a serious flaw or omission that could prevent a component from performing its safety-related function. The number of discrepancies alone does not accurately convey the quality of the work. To more accurately convey the quality of the work, discre-pancies were categorized by level of severity.
Q.17. How were the categories " design significant,"
" notable" and " insignificant" defined?
A.17. Design significant discrepancies are those discrepancies which impaired the item's ability to perform its safety-related design function. Any discrepancy for which it was shown by engineering evaluation that code-required design margins were maintained, and code design criteria and equipment functional requirements were met, was not considered to be design significant.
u________________
Notable discrepancies are those discrepancies which reduced the item's capacity by 10% or more but did not impair the item's ability to perform its safety-related design function. Discrepancies of this type include undersized plate washers, incorrect junction box mounting details, and incorrect member location.
Insignificant discrepancies are those discrepancies which reduced the item's capacity by less than 10% and did not impair its ability to perform its safety-related design function. Examples of insignificant discrepancies include cosmetic defects, the presence of additional parts such as spacer plates or washers, and a missing segregation code label on a conduit.
Q.18. What did S&L's engineering evaluations of the discrepancies for objective attributes in each of the six electrical construction categories show?
i A.18. The results of S&L engineering evaluations of the discrepancies for objective attributes of each of the six electrical construction categories are suntmarized below and in Attachment 2C (Thorsell-1):
2 f
Design Insignificant Notable Significant Conduit 136 10 0 Conduit Hanger 93 25 0 Cables 318 0 0 Cable Pans 207 3 0 Cable Pan Hangers N/A N/A N/A Electrical Equipment 287 275 0 There were no design significant objective attribute discrepancies in the sample reinspected. Approxi-mately 98% of the total number of CSR objective attribute inspection points showed no discrepancies at all. Only 0,4% of the inspection points resulted in notable discrepancies. In each of the construction categories, notable discrepancies amounted to approximately 1% or less of the inspection points.
Although capacities were reduced, these discrepancies did not impair the capability of the items to perform their intended safety function.
I Q.19. Please discuss the notable discrepancies identified in each construction category.
A.19. The ten notable conduit discrepancies involved improper conduit attachments to supports, loose ,
l conduit couplings / fittings and the length of flexible i conduit. The generic design approach of standard span length and peak seismic acceleration values for conduit system design provided sufficient design margin to accommodate the discrepancies in conduit attachment to supports. Sufficient margin also existed to accommodate the loose couplings / fittings.
t 1 Although, in some cases, the flexible conduit length exceeded the design length shown'on installation
- drawings, it was always within allowable design parameters for flexible conduit length.
The 25 notable conduit hanger discrepancies irc.olved minor variations in hanger configuration, attachment details and concrete expansion anchor installation.
The design approach and components used are based on standardized details and member sizes. This standardized design approach provided sufficient ,
design margin to accommodate these discrepancies.
There were no notable cable discrepancies.
l The three notable cable pan discrepancies involved l j
i slightly less than full thread engagement on three i There are eight bolts on each I splice plate bolts.
splice plate and the resulting installation was well within design allowable stress requirements.
i
As discussed previously, cable pan hanger objective attribute discrepancy evaluations were not included as part of the CSR.
The 275 notable electrical equipment discrepancies consisted primarily of minor variations in junction box mounting details,+ junction box barrier installa-tion details and concrete expansion anchor installa-tion. The notable discrepancies also included missing junction box support stiffeners and under-torqued bus l
connections in the medium voltage switchgear. The variations in junction box details and concrete expansion anchors were accommodated by the inherent design margins associated with each. Sufficient
- design margin also existed to accommodate the missing stiffeners and undertorqued bus connections.
It should be noted that the classification of many discrepancies as notable was the result of conserva-tive calculation of capacity reductions. While this 4
approach simplified som9 calculations and further insured that design significant conditions would not go undetected, it resulted in an inflated number of j notable discrepancies.
. - _ _ - - - . .. . . .- .- . .-. ~ - .
4 I i
i l' Although none of'the notable discrepancies was design i
i i significant, further evaluation of these discrepancies was performed to fulfill the BCAP commitment to identify possible "significant conditions adverse to quality." The goal was to identify through sound
]
I engineering judgement any areas of construction where additional efforts would further increase confidence that no unidentified design-significant discrepancies 1
- exist in the unreinspected portion of the plant. This evaluation resulted in establishing walkdowns to verify conduit attachment to hangers and presence of structural steel stiffeners for electrical equipment ,
[ supports.
i
}
Q.20. You have indicated that for each CSR identified
- discrepancy which resulted in reduced capacity, i adequate design margins existed to accommodate.the l capacity reduction. How is it possible that such i
- design margins always existed?
1 A.20. In designing a power plant, the architect / engineer has to come up with designs and procedures that can be handled by a large group of people with a low degree
, of error. This is accomplished by simplifying the
! design process through the use of standardized I
components. The architect / engineer also anticipates
-~. . - ., .. .. .- . - . - . . . - . . . . -.
7.
~
I l
\
l i -
l that construction of the resulting design will not be j perfect. These two factors combine-to produce sufficient margin to accommodate the types of l
L discrepancies that normally occur and were identified in,the CSR. j l
l For exampig, consider the design of conduit supports.
- These are basically structural' members that hold up i
- conduits with cables inside that perform electrical functions. In the design of conduit systems, various
} standardized designs for hangers are established. It
- is not practical or economical to individually design hangers for each. conduit. Thus, a family of standard I hangers is designed and the necessary procedures are i
developed to allow the designer-to select the proper hanger from the family. What could be an' infinite U numbe'r of hanger designs is compressed into about a i
dozen standard hanger designs. In doing so, we have to assume that the largest conduit is attached to the i hanger, that the conduit contains the heaviest cables '
i
! that w'ill fit into the conduit, that the conduit is i
l attached at the end of the hinger,'and that the hanger location results in the maximum span between hangers.
l Thus, the design of standard conduit hangers and their i
l location is based on a composite of design rules based f on maximum conduit size, maximum cable weight, maximum i
1 l
j
hanger length and maximum span between hangers. The resulting hanger is able to accommodate all of these conditions within code allowables. In practice, the conduits are seldom the largest that can be accommodated by the hangers. The cables in the conduit are seldom the maximum size cable that can be installed in the conduit, resulting in less weight on the hanger. The conduit hanger is selcom maximum length. The span between hangers is seldom the maximum for the actual conduit size. Rather than having a continuum of conduit hanger designs there are discrete steps.
In addition to the margin resulting from these discrete steps, there is margin in the design of each component member. Component member design margin is established to accommodate, among other things, the inevitable differences between the design initially shown on S&L drawings and the actual component member installation. This margin can be demonstrated by the span of a conduit between hangers. The maximum allowable span of a conduit is based on the physical properties of smallest diameter conduit and peak seismic accelerators. This span is ten feet. For Braidwood, Sargent & Lundy limits the designed span of a conduit to eight feet. This span takes into account l
l l
i 1
a specified six-inch tolerance on the location of conduit hangers and also includes margin for hangers 1
installed out of tolerance. Similar margins are l
included on the strength of members, member sizes, and welding details. Thus, when a particular discrepancy is evaluated based on the actual loads, there is l considerable margin in design. So what appears to be overdesign is a natural result of the engineering l
process. The underlying reasons for design margins are the discrete steps that result from standardiza-tion of components and the recognition that construction work is not perfect. These factors both streamline the design process and make construction more economical.
Q.21. What conclusion about the quality of reinspected work can you draw from the evaluation of objective attribute discrepancies identified in the CSR?
A.21. The quality of the reinspected work is adequate. This is based on the fact that there were no design significant discrepancies and approximately 98% of the objective attribute inspection points showed no l 1
discrepancies at all. The nature of the objective attribute discrepancies identified in the CSR and ,
1
! _17
their frequency of occurrence was similar to those l identified in the Byron QCIRP.
Q.22. What conclusion about the quality of inaccessible and unrecreatable work can you draw from the BCAP CSR results?
A.22. The inaccessible work was performed by the same electrical contractor who performed the reinspected work for which no design significant discrepancies were identified. This work was also inspected by the same electrical contractor responsible for the inspection of the reinspected work. This work is generally of a similar nature to the reinspected work and the design margins which exist for inaccessible work are similar to those for reinspected work. The combination of these facts allows one to infer that the attributes of electrical construction which were not reinspected are of the same quality as the reinspected work.
As in the case of inaccessible work, nonrecreatable work was also performed by the same electrical contractor who performed the reinspected work for which no design significant discrepancies were
1 identified. This work was inspected by the same electrical contractor responsible for the inspection of the reinspected work. The design margins for nonrecreatable work are similar to those for reinspected work. The combination of these facts allows one to infer that the nonrecreatable attributes of electrical construction are of the same quality as the reinspected work. .
Q.23. Are the design margins applicable to electrical work performed and QC accepted by L. K. Comstock after June 30, 1984 (the CSR cut-off date) different from those applicable to the electrical work reinspected as part of the CSR?
A.23. The design margins are the same.
Q.24. Does this complete your testimony?
A.24. Yes.
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ATTACHMENT 2C (THORSELL-1)
SUMMARY
OF OBJECTIVE DISCREPANCIES ELECTRICAL CONSTRUCTION CATEGORIES PERCENT ELECTRICAL PERCENT PERCENT DESIGN CONSTRUCTION REINSPECTION PERCENT INSIGNIFICANT NOTABLE SIGNIFICANT CATEGORY POINTS DISCREPANCIES DISCREPANCIES DISCREPANCIES DISCREPANCIES
, Conduits 5,800 2.52 2.35 0.17 0 Conduit Hangers 4,400 2.68 2.11 0.57 0 Cables 20,100 1.58 1.58 0 0 Cable Pans 21,000 1.00 0.99 0.01 0 Cab?.a Pan Hanger 0 0 0 0 0 Electrical Equip-ment Installation 20,300 2.77 1.41 1.36 0 TOTAL 71,600 1.89 1.45 0.44 0 4.
]
l t
4
t UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket'Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
REBUTTAL TESTIMONY OF EDWARD M. SHEVLIN
('ON ROREM Q. A. SUBCONTENTION 2)
(Harassment and Intimidation) ,
l August, 1986
i .
REBUTTAL TESTIMONY OF EDWARD MICHAEL SHEVLIN Q.l. Please state your full name for the record.
A.l. Edward Michael Shevlin h
Q.2. By whom are you employed and in what capacity?
A.2. I am employed by Daniel International Corp.,
Greenville, South Carolina. My position title is quality Supervisor III. I am currently assigned as a consultant to Commonwealth Edison at Braidwood Station. This assignment included Quality Engineering work for Commonwealth Edison and the Project Piping and Mechanical Contractor.
Q.3. What was your previous assignment for Daniel?
A.3. I was assigned in a consultant capacity as Lead ;
Mechanical / Welding Inspector and Project Level III j i Inspector for the Braidwood Construction Assessment I
] Program at Braidwood Station.
)
l Q.4. What were your responsibilities in that position?
A.4. My responsibilities were to supervise all mechanical /.
welding quality inspection activities by the'BCAP Task Force. These responsibilities included selection, training, evaluation and testing, and certification of mechanical / welding inspectors. The BCAP Task Force i
d
-- ., . . . _ . _ . ~ _ , , - . _ . _ ., _ _ - . . . _ . . _ , , _ . _ . _ . , _ . - ..__,...._.-,,,.1
l inspection activities included reinspection of samples 1 of all mechanical / welding populations, and audit of associated documentation. This included welding in i the civil and electrical areas. I also assisted in the development and review of procedures, checklists and instructions.
Q.5. Please summarize your education and professional experience.
A.5. I am a high school graduate. I am currently pursuing a degree in Mechanical Engineering. My technical education includes a fifty-two (52) week academic and on-the-job Mechanical / Welding Inspector Training Program, a six month academic and on-the-job Liquid Penetrant Examiner Training Program, and an off duty preparatory course for the American Welding Society Certification Examinations. I have spent 20 years in l Army Aviation. My rank at retirement was Master l Sargent, and I was an Aircraft Maintenance Chief. I have completed four Aircraft repair and inspection courses which related directly to construction Mechanical / Welding Inspection. I have completed a six week training program in Gas-Tungsten Arc and Shielding Metal Arc Welding, the two primary welding processes used in nuclear power construction. I have
also completed leadership, supervision and methods of instruction courses. 3 I have twenty-eight (28) years experience in Mechanical and Welding inspection, maintenance, repair and training, progressing to third line supervision.
Eight (8) of these years involved mechanical and welding inspection, supervision and training in nuclear power plant construction. My assignment prior to Braidwood was Senior Mechanical / Welding Quality Supervisor on a 1250 MW Nuclear Unit, responsible for all mechanical and welding inspection and associated activities for the entire project. I am a member of the Daniel Corporate Committee for development of inspector training and certification testing mate-rials. I am certified as American Welding Society Certified Welding Inspector (CWI). The CWI is an inter- nationally recognized technical certification.
My Daniel Corporate inspection certifications include the following:
Mechanical - Level III Hangers, Instrumentation, Equipment Installation, Piping, Maintenance Welding - Level III Piping Welding, Structural Welding, Material Control, Welder Qualification.
l l
Nondestructive Examination - Level III Visual Testing !
for ASME Section III, Subsection NF; Level II Liquid Penetrant Examiner.
I was also certified Level III in the Mechanical and Welding areas by Commonwealth Edison.
Q.6. Mr. Shevlin, what is the purpose of this testimony?
A.6. The purpose of this testimony is to describe the qualifications of the BCAP CSR welding inspectors and the t .nner in which weld inspections in the electrical construction categories were performed.
Q.8. How were the inspectors in your group selected?
A.8. I personally knew the capabilities and work habits of twelve of the sixteen inspectors prior to their selec-tion for the BCAP team. Another two were recommended by the Daniel Quality Assurance Technical Support l
Director, who was my immediate supervisor, and the remaining two were recommended by other Daniel super-visors qualified in my field. I personally trained five of the sixteen BCAP inspectors from entry level to fully certified inspectors on a previous assignment.
The selection process was unusually rigorous. In addition to ensuring that candidates had the required technical credentials, I satisfied myself as to each
candidate's work habits and work ethics, depend-ability, consistency and ability to function normally under the pressure of a multi-tiered overinspection program. As previously stated, either I or another supervisor whose judgement I accepted had such knowledge of each inspector selected. All selected individuals were known to be willing to discuss 1 problems they encountered or errors they made in group training sessions for the benefit of the other inspectors. All were known to have a habit of-l !
stopping their own work when confronted with a i
problem, and assuring themselves of the correct
! solution prior to proceeding with the inspection.
t Due to the diversity of the BCAP inspection effort, each candidate was required to be competent in more than one area. Ten of the inspectors were fully certified in both mechanical and welding inspection.
The remainder were certified in more than one sub-discipline, and had sufficient experience to assist certified inspectors in areas outside their own disciplines.
In evaluating credentials, a very conservative approach was taken to assure strict compliance with ANSI Standard N45.2.6-1978, the standard for inspector
certification. Also considered was USNRC Regulatory Guide 1.58, Rev. 1 which supplements the ANSI standard. The credentials of each. selected candidate hn were approved by myself, my supervisor, BCAP manage-ment and Commonwealth Edison Quality Assurance.
As sn additional measure, Commonwealth Edison performed an audit of Daniel Training and certifi-cation practices at a Daniel constructed nuclear station which was nearing ccmpletion.
i The Quality experience of the selected inspectors ranged from slightly over three years to_over twenty years. The group's average experience was approxi-mately nine years.
Of the sixteen inspectors, all were certified by Daniel to ANSI Level II in their respective disci-plines. During their tenure in BCAP, two were certi- l l
fied to ANSI level III by Daniel and accepted as ANSI Level III by CECO. Four were AWS CWI. (CWI is I explained in A.5 above). Five inspectors were actually Lead Quality Inspectors and one was a Quality I Supervisor. These titles indicate that these indi-viduals were not only qualified inspectors, but on prior assignments had demonstrated capability to
! -s-
supervise inspection activities. One of the inspec-tors, in addition to holding the CWI, was also certified Level III in two areas by the American Society for Nondestructive Testing. Attaining certification by AWS or ANSI is a very difficult and time consuming undertaking.
In Inspection Report 85-25, the NRC stated "During this inspection period the inspector reviewed the education and experience data for 18 BCAP Task Force Inspectors. In each case the documented data exceeded the requirements delineated in ANSI N45.2.6.
1 Q.9. How were they trained?
A.9. Training was conducted in four general areas:
- 1. Site Familiarization: All inspectors were involved in " accessibility walkdowns". This activity required that the BCAP sample item be located, determined to be accessible, and examined for paint, rust, or other obstructions which would impede the actual inspection process. This proved to be an excellent vehicle to thoroughly familiarize the inspectors with the plant layout. It also made the inspectors familiar with the various drawings issued by the designer and the contractors.
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u
- 2. BCAP Plan: All inspectors read and received training on the BCAP Plan and the CSR (Construc- S' tion Sample Reinspection) Plan. These plans outlinee. the purpose and general approach of BCAP. This effort also included reading and training on the applicable BCAP Procedures.
As a result of this training, each inspector was aware of the intent of the program and the general approach to be taken by CSR. The BCAP organization was explained, to assure that all personnel knew with whom they would interface for each population. (A population was defined to i include all like items subject to BCAP inspection). .
- 3. Skills Refresher: During the lead time prior to site certification, a large amount of time was spent reviewing basic skills, including use of special tools, measurement techniques, shop mathematics, blueprint reading and visual recognition of weld defects. This was done to assure that all requisite skills were refreshed in the minds of those who may not have recently )
performed some inspection tasks (e.g., an inspector may have spent recent months working on l
l l
1 hangers, and would therefore benefit from refreshment of piping inspection skills).
I
- 4. Specific BCAP inspection requirements: Prior to beginning inspection of a population, a training session for that specific population was conducted. Each inspection attribute was explained in detail. Included was the method of inspection, application of measuring devices, acceptance criteria, method of documentation, and l specific requirements for reporting observations.
f Prior to site certification, each inspector was required to pass both a written and a practical examination in each major discipline of certifi-cation. These examinations were at a higher than normal difficulty level.
In addition to the four general areas outlined above, at least once weekly an informal " lessons learned" session was held to discuss any problems encountered or errors made. The inspectors discussed problems or errors with the group and how they should be avoided by others.
l 1
During the BCAP, ten of the inspectors participated in an off-duty study program in preparation for the AWS CWI examinations. One other prepared for the CWI examination by self study. This study program was not required for CECO, Daniel or BCAP purposes; the fact that so many of the BCAP Task Force Inspectors invested their personal time to take this course shows their dedication and professionalism.
Q.10. What instructions were they given in performing inspections of electrical construction categories?
A.10. As stated above, prior to beginning inspection of any population the specific instructions and acceptance criteria were discussed in detail. Where necessary, j on the job training (hands on practice) was conducted.
During all of these sessions, the responsible BCAP Task Force engineer for the construction discipline involved was either present or immediately available to answer questions and discuss any unique reporting requirements.
In many instances, reference material such as-tables, 1
charts, standard dimensions or sketches depicting an l l
applied technique were provided for inclusion in the inspectors' notebooks. )
i
This specific population training resulted in a clear and uniform understanding of the requirements before the work began.
Instruction in performing BCAP inspections of electrical welding was provided prior to beginning work, consistent with the methods outlined above.
Q.11 Please describe what was involved in performing a typical BCAP Weld Inspection on an Electrical Installation.
A.11. Four populations in the electrical area were subject to weld inspections. These were conduit hangers, l cable pans, cable pan hangers and equipment.
Typically, the installed welds were fillets or flare bevels. The number of welds per sample item varied from two or three on a small conduit support to 80 or more on a large cable pan hanger. The governing code was AWS Dl.1-1975 the American Welding Society Code for Structural Welding.
Each weld was visually examined and evaluated against a seventeen attribute checklist, which satisfied the requirements of AWS Dl.1 and the design specifica-tion. The checklist instructions provided inspection criteria for weld size, configuration, location,
reinforcement and discontinuities. Each inspector was required to have the checklist and instructions in his possession during each inspection. A copy of the checklist and instructions is attached as Attachment 2C (Shevlin-1).
Q.12 Were your inspectors aware that the processing of their observations as described in the BCAP Report sometimes led to the invalidation of such observations?
A.12. Yes. Project procedure BCAP-06 outlined the process-ing, including invalidation, tf observations in detail. This procedure was part of the inspectors' required reading. Also, I presented training to all of my inspectors on BCAP-06. During the training sessions the invalidation process was specifically addressed.
Q.13. Were the inspectors given the opportunity to question 3
or challenge the invalidation of such observations?
A.13. Yes. BCAP-06 made the concurrence of either the inspector or his supervisor a prerequisite to closing an observation reord by invalidation. The only exceptions to this requirement were as follows:
A. If the invalidation was based on further evalua-tion of the item by a Level III inspector, the Level II concurrence was not required. It was required that the Level II be made aware of the invalidation. It was common in this case to have the Level III take the inspector to the item and show him how the overriding decision was made.
B. If the invalidation was not based on a Level III inspector's decision, and if the inspector )
refused his concurrence, BCAP-06 had a provision which led to the BCAP Director making the final l
decision on validity. It should be noted that this provision was not needed for any observation l initiated by my group. When the engineer made a disposition of " INVALID", he provided the !
inspector with sufficient objective evidence to i
support the disposition. Additionally, I l
- personally observed this process on a regular basis to assure that the provided evidence was sufficient.
At the beginning of the BCAP, I made the engineering group aware that I intended to interpret the inspector concurrence provision in BCAP-06 to mean that proof was required to support our agreement with invalida-tions. In the training sessions mentioned in A.12 above, this was also made clear to the inspectors.
1
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l I
1 The engineering group was fully supportive on the i
" PROOF REQUIRED" policy. Invalidation of observations was never a point of contention between engineering l and my group. l l
Q.14. Are you aware of any NRC Staff inspection finding i relating to the inspections of electrical work ;
performed by your group?
A.14. To the best of my knowledge, the NRC had no findings.
The NRC inspector entered an Open Item in inspection report 85-19. He questioned a BCAP inspector's deletion of a report of a crack on his checklist. The NRC follow up inspection of the item showed the BCAP inspector to have properly deleted the entry, in that a crack did not exist on the item. (NRC I.R. 85-40).
Q.15. How would you characterize the degree of NRC Staff oversight of your group's work? ,
A.15. The degree of oversight on the part of NRC was very high. Especially at the. onset of inspections in each l l
l population, Mr. Gardner, the NRC inspector assigned to l monitor BCAP, followed our activities very closely, i
He stayed aware of our daily work plans in order to '
select activities and inspectors for direct oversight.
Mr. Gardner regularly visited our work area to ask if there were any problems of which he should be aware.
i l
i He was knowledgeable in our staffing, certification progress and personnel qualifications. All inspectors were aware of the NRC presence and encouraged to discuss any problems with the inspector.
Mr. Gardner also both reviewed and participated in the Independent Expert Overview Group (IEOG) Overviews of our inspectors' work.
I would characterize the NRC Staff oversight of the BCAP Inspectors' work as very thorough, highly visible, and as having a positive effect on the i
conduct of the program.
Q.16. What is your own opinion concerning the overall adequacy of your group's inspections in the electrical construction categories?
A.16. The inspections performed by my group were complete and accurate. The sustained competent performance of this group of inspectors over the life of the BCAP was highly satisfactory.
Q.17. What is the basis for this opinion?
A.17. This opinion is based on a number of factors. First, and probably most significant is the high level of skill and motivation to perform well on the part of the BCAP Task Force inspectors. ,
l 1
i l
l The checklists and instructions used by the inspectors were skillfully prepared. In addition to the accep-1 tance criteria, specific instructions were provided in how to perform the inspection for all but the most elementary steps.
The inspectors received excellent support from the responsible engineers.
Training was continuous throughout the life of the project. The extensive overview by the NRC Staff, the IEOG, BCAP Quality Assurance and, internally, the BCAP Task Force produced very few findings of error on the inspectors' part. (The Task Force overinspected 20 percent of the first 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of each inspector's work). While we cannot say that mistakes are accept-able, we must recognize that even the best worker cannot be consistently perfect. We make every effort to minimize error. When the occasional mistake is identified, it is corrected and the person responsible is made aware of the mistake. Based on my personal observation of the work, both in process and after the fact, and that of the engineers and overinspection groups, I am quite confident in stating that the BCAP weld inspections were performed completely and competently.
Q.18. Does this conclude your testimony?
A.18. Yes.
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, 11 Attribute for Inspection l
Instruction / Source Document i
Prior to the start of inspection assure that welds are clean of any of paint, spatter o_r any foreign material which would impede an adequate visual inspection.
Reference:
BCAP 04 When it is necessary to measure weld dimensions during the course of an inspection, such dimensions should be determined as accurately as is practically j achievable using standard weld inspection tools.
For weld size, any dimensions should be measured to i the nearest 1/32 inch. For weld length, any dimensions should be measured to the nearest 1/16 I inch.
t 1.0 Pitup and Assembly 1.1 FILLETS A. For Shapes or Plates less than 3" thick Verify the following two attributes:
- 1. The maximum gap between two members joined by a fillet weld is 3/16" or less.
- 2. If the'fitup gap is 1/16" or greater, verify the leg size has been increased by the amount of separation.
1 1
! , Instruction Prepared Date Instruction Approved Date
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Attribute for Inspection Instruction / Source Document B. For Shapes or Plates 3" thick and greater.
Verify the following'two httributes:
- 1. The maximum gap of 5/16" is acceptable provided a sealing weld or backing strap is provided. In these cases the backing strap or sealing weld may prevent fitup gap measurements. Document this instance per the paragraph under the heading Fitup Gap inaccessibility.
- 2. If the fitup gap is 1/16" or greater verify the leg has been increased by the amount of separation.
1.2 Partial Penetration Groove Pitup Gap Verify the gap does not exceed 3/16".
Fitup cap inaccessability Note: For any welds in which the governing detail requires welding in such a manner that the initial fitup is unverifiable, place an "X" in the box labeled "Fitup Unverifiable" in the ;
remarks colummn. This note applicable to 1.1 l and 1.2. 1 l
1.3 Butt Welds Verify misalignment does not exceed 1/8" or 10% of the thickness of the thinner member (whichever is less).
Instruction Prepared Date Instruction Approved Date By
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l Attribute for Inspection Instruction / Source Document
- 2. Location Verify that the weld configuration and location are as specified per the detailed drawing.
- 3. Veld Size Verify the weld size meets the requirements of the applicable drawings. Determination of fillet weld size acceptability is subject to the following clarifications:
A. Unequal leg size fillet welds are acceptable, provided the smaller leg meets or exceeds the minimum specified size.
B. Fillet welds may be undersized to a maximum of 1/16" provided that the undersized portion (s) do not exceed 10% the length of the weld, f
t
- 4. Lenoth Verify the length of weld conforms to the minimum requirements of the referenced drawings. length acceptability is subject to the following clarifications.
A. Where the pitch between stitch welds is specified, it shall be construed as the maximum allowable pitch. Therefore, if the pitch between the two adjacent velds is less than specified,then the welds meet the specified
, requirements.
B. Where. deposited weld length exceeds drawing requirements, the ends of the weld in excess need not be. evaluated except for cracks, per attribute 6, and undercut, per attribute 11. In the case of intermittent stitch welds, the maximum allemble clear distance between welds shall be maintained; however, the center-to-center distance.may be greater than specified.
l Instruction Prepared Date Instruction Approved Date By
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l Instruction / Source Document
- 4. (con't) C. Continuous welds where intermittent welds are specified are acceptable.
D. For structural framed beam connections, the end return 90* to the major weld shall not exceed the required length by more than 1/4". I'
- 5. Unspecified The unspecified weld or unspecified portions of , welds
~
Welds may oe left in place provided no cracks, per attribute 6, or undercut, per attribute 11, exists on the unspecified weld; (except as noted in 4 D above).
- 6. Cracks Verify the welds have no visible cracks.
- 7. Fusion Verify the welds have no visible lack of fusion.
Note to Inspector A rounded pocket (apparent lack of fusion) at the root of a fillet weld at the start or stop of the weld is acceptable provided its length, width and depth are less than 3/32".
Instruction Prepared Date Instruction Approved Date By
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- 8. Craters A. Verify that no under-filled groove weld craters exist.
B. Under-filled fillet weld craters shall be accepted, provided the crater length is 3/8" or less in length, and is within the minimum theoretical throat for the specified size.
Where paragraphs 1.1.A.2 and 1.1.B.2 require an increase in leg size due to fit-up gap being greater than 1/16", increase the weld size by the fit-up separation.
- 9. Concavity If the profile is concave verify that the minimum theoretical throat for the specif.ied size is
/ attained.
Where paragraphs 1.1.A.2 and 1.1.B.2 require an increase in leg size due to fit-up gap being greater than 1/16", increase the weld size by the fit-up separation.
- 10. Reinforcement Reinforcement shall have gradual transition to the plane of the base metal surface.
- 11. Undercut verify that any undercut present does not exceed the following criteria.
A. Undercut less than or equal to 1/32" (in depth) is acceptable with no length restriction.
B. Undercut " pockets" < 1/16" depth and < 3/16" length are acceptable, provided the spacing -
between " pockets" is at least 3".
C. For material less than 1/8" in thickness, any undercut present shall not exceed 10% of the material thickness in depth.
Instruction Prepared Date Instruction Approved Date By
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Attribute for Inspection Instruction / Source Document i
- 11. (con't) D. For fillet welds along the free edge of plates and/or shapes, undercut along the edge of the t plate or shape (edge melt) is acceptable provided I the designated weld size is achieved and verifiable, and the edge melt does not exceed a 2 to 1 slope. Refer to attachment Figure A.
- 12. Porosity Verify that the sum of diameters of piping porosity in welds does not exceed 3/8" in any linear inch of weld and does not exceed 3/4" in any 12" length of weld.
- 13. Arc strikes
" Arc strikes on carbon steel base material are acceptable provided:
- 1. There are no cracks.
- 2. There is no nodules or foreign material at the 3
base of the arc strike, (i.e. copper).
l 3. The depth of the arc strike does not exceed: .
I a. 10% of the material thickness for material less than 1/8" in thickness,
- b. 1/32" for material thickness 1/8" and greater and less than or equal to 5/8".
- c. 1/16" for material thickness greater than 5/8".
Instruction Prepared Date Instruction Approved Date
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AttLibute for Inspection Instruction / Source Document 13.(Con't) If the arc strike appears visually to fall within the above tolerances yet the depth of the arc strike cannot be measured with standard inspection tools then the weld is acceptable.
4
- 14. Overlap Verify that welds are free of overlap where fusion can not be verified.
- 15. Peening and Verify the surface layer of the weld has not been Caulkinq peened or deformed in a manner so as to hide defects.
?
\
- 16. Plate Cut Verify that any plate delaminations do not exceed 1" Edges in length. Inspect 2" either side of weld.
- 17. Nicks & Verify that the depth of any nicks or gouges 2" either Gouges side of the weld does not exceed the following:
- 1. 10% of the material thickness for material less than 1/8" in thickness.
- 2. 1/32" for material thickness 1/8" up to 3/8".
- 3. 1/16" for material thickness greater than 3/8", but less than or equal to 2 inches.
- 4. 1/8" for material thickness greater than 2 inches.
Note to Inspector Record all welder identification star.ps located near i the weld in the space provided under " remarks". If none are visible, place an "x" in the box .
l Instruction Prepared Date Instruction Approved Date
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMTSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDioON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) )
l REBUTTAL TESTIMONY OF JOHN R. WOZNIAK (ON ROREM Q. A. SUBCONTENTION 2)
(Harassment and Intimidation) i August, 1986 i
1
9 REBUTTAL TESTIMONY OF JOHN WOZNIAK BCAP CSR INSPECTIONS OF ELECTRICAL WORK ,
Q.1. Please state your name for the record.
A.1. John R. Wozniak Q.2. By whom are you employed and in what capacity?
A.2. I am employed by Daniel International Corp., as a Certified Lead j Electrical Inspector, acting in the capacity of a consultant to Commonwealth Edison's Electrical Project Construction Department.
Q.3. What was your previous assignment?
A.3. I was assigned in a consultant capacity as an Electrical Inspector for CECO's Braidwood Construction Assessment Program at Braidwood Station.
Q.4. Please summarize your education and professional experience.
A.4. I am a High School Graduate. I have 3 years manufacturing experience, having progressed to Shift Supervisor. I have 8 1/2 years power plant (Fossil Fuel & Nuclear) construction experience, 7 1/2 years experience in Quality Control, in various disciplines; Civil / Structural, Welding, Electrical, Non-Destructive Examination (Liquid Penetrant, Radiography). 5 1/2 of these years has been in in nuclear power plant construction. My assignment prior to i
Braidwood was Lead Electrical Inspector on an 1150 MW Nuclear Unit, responsible for the electrical raceway supports inspections and associated activities for the project. This included on-the-job training and certification of the inspectors assigned to me.
. My Daniel Inspection Certifications include the following:
1 Electrical - Level II, Raceway, Terminations, Cable pulling, l
Equipment Installation, Instrumentation. l Q.5. Mr. Wozniak, what is the purpose of this rebuttal testimony?
Q.5. The purpose of this rebuttal testimony is to describe the qualifications of the BCAP CSR Electrical inspectors and the manner in which CSR electrical inspections were performed.
Q.6. How many BCAP Task Force inspectors were in your group?
A.6. There were (7) Certified Electrical Inspectors, and one (1) Lead Inspector.
Q.7. Do you have an opinion concerning their competence?
A.7. Yes, I had an opportunity to observe their performance during the CSR, and in addition, I have reviewed their qualification files in connection with this testimony. I believe all of them were very competent. For example, of the seven CSR Electrical inspectors, all of whom were employed by Daniel, 3 had held previous Lead inspector / supervisor positions with Daniel on previous assignments. In my opinion, the higher than normal competence level was exhibited throughout the CSR.
Q.8. Please describe the training you received in connection with the BCAP.
<a
. . . . - _ . . ~ . . . . -. . _ . _ . - _ _ __
~
l l
A.8. The BCAP Task Force inspectors in my group received the same .l l
general training described in Mr. Shevlin's testimony, answer 9.
) (e.g. site familiarization, BCAP plan, skills' refresher, specific
} CSR inspection requirements).
l Q.9. For each of the six CSR construction categories involving electrical work, what attributes did your group reinspect?
A.9. We inspected the attributes as delineated on the reinspection 4
l checklists. Copies of these checklists are attached as Attachment f 2C (Wozniak-1)
Q.10. What inspection criteria did you use?
4 A.10. These were set forth in instructions which accompanied each
- checklist. Refer to Attachment 2C (Wozniak-2), an example of
] - .
these, which is our instructions related to the conduit i population. Note the clear, concise, descriptive manner in which the instructions are presented. This was generally true for all the instructions we used.
Q.11. How did you document your inspection findings?
A.11. We used the reinspections checklists attached to this testimony, l
[ which included per-attribute sign-offs, with signature requirements
! per page. In addition, an observation record was initiated to
- . document apparent deviations from design, specification, or
- installation requirements, per procedure BCAP-06.
k l l l 1
Q.12. How did you perform your inspactions of electrical work?
A.12. Extreme care was used in performing the CSR inspections. I was critical of the electrical installations, and would not hesitate to stop inspections when confronted with a problem or unique installation, to obtain the correct solution prior to resuming the inspection.
Q.13. Do you have an opinion as to the degree of care exercised by other BCAP Task Force inspectors in your group?
A.13. I feel that the fellow inspectors possessed the same philosophy as I, conscious of the visibility of our work under the multi-tiered overinspection program.
Q.14. What is the basis for this opinion?
A.14. I was the first BCAP Task Force electrical inspector certified, therefore, I gave on the job training to fellow inspectors prior to their certification.
Additionally, we normally worked in two-man teams, for ease of inspection, and safety's sake. The teams would rotate, therefore we all worked with each other numerous times. This also provided informal " checks & balances" in inspecting items, to assure accuracy of inspections.
1
)
Q.15. Dr. Kaushal testifies that CSR inspections were overviewed by BCAP QA, by ERC, and by the NRC Staff. Were you conscious of these ,
overviews when you were performing CSR inspections? l l
4-
A.15. Yes. This was explained to the BCAP Task Force inspectors during classroom training on CSR plan and procedures. BCAP QA was present during training given to us by CSR Engineering in the use of checklists and instructions. When the Task Force completed inspection packages, and CSR Engineering completed processing them, BCAP QA would randomly select packages for their inspection overview. On numerous occasions, we were accompanied by the ERC overviewer while performing our inspections. The Task Force Inspectors, having become familiar with the plant layout from performing the accessibility walkdowns, aided the ERC overviewer in his knowledge of plant layout. On several occasions, the NRC inspector accompanied us on our inspections. His presence enhanced our feeling of BCAP's importance.
Q.16. Mr. Wozniak, are you familiar with any concerns identified by the NRC Staff with respect to CSR reinspections of any electrical construction category?
A.16. Yes. In NRC Inspection Report 85-02 dated February 13, 1985, the NRC Staff (along with the ERC) identified an unresolved item with respect to reinspections of conduit hangers. This item was resolved by the NRC Staff in Inspection Report 86-03, dated June 9, 1986.
Q.17. Can you briefly summarize the nature of the pr'oblems with conduit hanger reinspections identified in Inspection Report 85-02?
A.17. In general, they related to the interpretation of the reinspection checklist and instructions for the conduit hanger population,
\
l rather than the care and accuracy with which we performed our reinspections. For example, in reinspection package CSR-I-E-C0H-20 there were two conduits attached to a hanger. The instructions at that time required the BCAP Task Force inspector to verify that they were the right type of conduits and that they were properly attached, but did_not explicitly require the BCAP Task Force inspector to verify that the conduits attached were the ones identified in the design drawings. We were required to verify this information as part of the CSR reinspections of the conduit construction category. Therefore it was not obvious to the BCAP Task Force inspectors that we should also have been verifying conduit identity as part of our inspections of conduit hangers.
Another example of a mistake identified in Inspection Report 85-02 occurred in package CSR-I-E-COH-12. The inspector inspected the bolting which connected the conduit strap plate to the conduit hanger. He properly accepted the bolting but he wrote down his finding on Line 3G of his checklist. For this particular type of hanger, he should have marked that line of the checklist "N/A" and marked down his results on Line 7 of the checklist. See Attachment 2C (Wozniak-1), pages 4 and 6.
1 The only error identified in Inspection Report 85-02 which I believe was an inspector "miss", as opposed to an interpretation problem, was the failure to identify the absence of required back plates for the conduit hanger in package CSR-I-E-COH-12. A back I
1 plate is a small block of steel, about ona inch thick in this case, .
l which is welded onto the hanger. The conduit strap is placed over the conduit and bolted into holes in the back plate when the i
conduit is installed.
't Q.18. What if anything was done in response to this NRC Staff and ERC i concern?
A.18. We suspended CSR conduit hanger inspections on January 23, 1985.
$ ~ Appropriate revisions were made to clarify the instructions for the i
conduit hanger population, and the BCAP Task Force inspectors in my
- group received additional training to make sure we understood the instructions and the concerns raised by the NRC Staff and ERC. We reinspected all conduit support hangers inspected prior to January
- 24, 1985 for the attributes called into question. CSR inspections of conduit supports resumed on February 8, 1985.
Q.19. Do you agree or disagree with the finding in Inspection Report 86-03 that the corrective actions taken in response to this concern were effective?
A.19. I agree that the corrective actions were effective.
Q.20. Are you aware that some of the observations made by your group were later invalidated?
A.20. Yes. The governing procedure (BCAP-06), which'we all read and received training on, had provisions for determining observations invalid, by CSR Engineering, by reviewing the observations against A/E Drawings and Notes, Engineering change notices, Field Change Requests, previously issued nonconformance reports, etc.
i 1
i
, i i
, .- - . . .- . ~ . . - _ _-. - ..
Q.21. Were you aware of it at the time?
A.21. Yes. Sheet 2 of the observation record contained the evaluation I
and determination of validity by CSR Engineering. If determined ;
invalid, the form, (Sht. 2) had an " Acknowledged By" signature requirement of the originating inspector. -This gave~the inspector I !
a chance to review the determination of invalidity.
4 The procedure, BCAP-06, which all inspectors read and received
, training on, had provisions for observations that were deemed invalid, where the Task Force inspectors and CSR Engineers were not in agreement. A review would be performed by a group designated by the Assistant BCAP Director, that would recommend a resolution to the BCAP Director, who made the final validity determination. The t
l procedure also had provisions to allow the inspector to request a l
i reconsideration of the determination of invalidity, e.g., if he obtained additional information which might affect the validity determination.
j 4
Q.22. Did you ever challenge the invalidation of any observations which
, you personally had made? ,
A.22. Yes. When I didn't understand why the observation was being
- invalidated I would discuss it with the CSR engineers, i
i j Q.23. Were there any " invalidated" reinspection observations for which
- you ultimately did not' concur in the invalidation?
J i
1 i
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1
A.23. No. I concurred in each invalidation of my reinspection observations. (I did not concur in the invalidation of one of my document review observations.)
l Q.24. Were there any " invalidated" reinspection observations for which any member of your group did not concur in the invalidation?
A.24. Yes, there was one. It involved pictorial arrangement of an electrical component in some electrical switchgear. The design drawing did not specify the location of the component, although the component was pictorially shown on the left-hand side of a cubical of the switchgear. The note on the drawing indicated that the i
component was to be field-installed. The inspection showed that the component was installed on the right-hand side. This observation was ultimately determined to be invalid. I have reviewed the observation and in my judgment, the invalidation of this observation was reasonable.
Q.25 Do you have an opinion as to the adequacy of the reinspections performed by your group in the electrical construction categories?
A.25. They were thorough and complete, throughout the duration of the CSR.
l l
Q.26. What is the basis for your opinion?
A.26. Several reasons. The desire to perform well on the part of the BCAP Task Force. The continued exposure to training through out the program. The assistance from the CSR Engineers was excellent.
The extensive overviews by the Lead Inspector, BCAP QA, IEOG, NRC 9
Staff. All the:c Iced to my opinion that the inspections were performed competently.
Q.27. Does this conclude your testimony?
A.27. Yes.
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Nt!NWtL.51UN UtMLDI l1l DOCUMENTATION . VIEW QECKLISI l__l CSR-I-E.CPH Pace 1 of 5 Rev. 1 POPULATION CATEGORY I - CABLE PAN HANGERS Equipment / Tag / Mark Equipment Description Observation NCR No. Prepared Date Remarks Number Record No. By Attribute VERIFICATION Accepted Rejected Initial Date Initial Date
- l. Aux. Steel Location.
Tvoe and Size
- 2. Connection: Aux. Steel to Primary Structure: - m 2a. Gusset Plate. l Filler Plate 2b. Clip Angle, Channel 2c. Welds 2d. Bolts Torque Wrench No.
Torque Wrench Calibration Due Date 2e. Stiffeners 2f. Gap Between Aux. Steel and Structural Steel
- 3. Hanger Configuration ba. Member Arrangement Checklist Prepared Date Checklist Approved Date gcy, Signature of Date Signature of Gate g
By By Inspector Lead Inspecter
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Attachment 2C (Wozniak-2) -
Paga 1 of 8 Rev. 4
(, Checklist Instruction
( -
l Population l Conduit Identification No.
i CSR-I-E-CND Attribute for Inspection Instruction / Source Doctment i
- 1. Conduit Size verify that conduit size agrees with conduit tabulation drawing. Verify that the conduit material used is rigid steel, zinc coated unless otherwise specified on Electrical Installation drawing. Verify that all couplings are wrench tight (i.e. couplings are not loose).
- 2. Segregation verify that the segregation code marked on the conduit Code agrees with conduit tabulation drawing. Segregation l - "
codes shall agree with the color coding indicated below and shall, as a minintaa, consist of the unit number 1 or 2 and the type character P, C, or K, (e.g. IP or IC).
DIVISION COLOR CODES Safety Related Black Letters on PIE,CIE,K1E Division 11 (21) Green Background Safety Related Black Letters on P2E,C2E,K2E Division 12 (22) Brown Backaround Reactor Protection Ch.1 Black Letters on KIR, CIR 4eutron Monitorine Ch.1 Red M keround KIN. C1N
, Reactor Protection Ch.2 Black Letters on K2R. C2R Neutron Monitorine Ch.2 Orance Background K2N, C2N Reactor Protection Ch.3 Black Letters on K3R C3R Neutron Monitorine Ch.3 Blue Backaround K3N. C3N Reactor Protection Ch.4 Black Letters on K4R. C4R
. Neutron Monitorine Ch.4 Yellow Backaround K4N. C4N Instruction Prepared Date Instruction Approved Date By (DE) (CSR SUPV.)
/ e W d l'v(dh 4, trAf '/2 /f f 0198J
.b, f a11AIg l[2.hf BCAP DIRECTOR
/
page 2 of 8 Rev. 4
( Checklist Instruction Population Conduit Identification No.
CSR'-I-E-CND Attribute for Inspection Instruction / source Document
- 3. Segregation Verify that segregation code labels are marked on the Code Labels conduit near terminations, and both sides of floors and walls.
- 4. Conduit origin Verify that conduit origin and destination s
agree
& Destination with Electrical Installation drawing (EI drawing)
Note: In some cases the sealtite conduit might have been disconnected from the terminal equipment to complete cable pulling and termination. Also,in j "
some cases the terminal equipment is not
- installed. These are not considered reasons for rejection of the, subject attribute.
- 5. Conduit a. Verify that conduit is attached to all supports I Attachment shown on support schedule, to supports b. Verify that conduit is attached to support at locations shown on support schedule such that the distance to the structure is within tolerances specified in Attachment A.
- c. Verify that conduit clamps are snug against the conduit and cap screws are finger tight.
- d. Verify that the cap screws or welding studs for conduit clamps are 1/4" diameter for conduits up to 1 1/2" size and 3/8" diameter for conduits 2" to 6" size.
Note: If secondary tolerance is used, check box on the checklist.
l Instruction Prepared Date Instruction Approved Date By (DE) (CSR SUPV.)
D' '
d/k.gg ,/-/g
/
0198J
Page 3 of 8 i
Rev. 4 I-Checklist Instruction Population Conduit Identification No.
CSR-I-E-CND Attribute for Inspection Instruction / Source Document
- 6. Separation Verify that a minimum of 1" space separation is (Safety) maintained between conduits and between conduits and tray of each sf the following safety-related segregations: lE, 2E, IR(N), 2R(N), 3R(N), and ,
4R(N), A minimum of 1" separation must also be
{
maintained between conduits and between conduits and trays of each of the above named safety-related segregations and non-safety related raceways.
Non-safety related raceways include all conduits or
) trays with IB or 2B segregation as well as unlabeled conduits (e.g. conduits used for lighting, communicatins, fire detection, etc.). The minimum 1" space separation is to be measured metal to metal
, between conduits, not to include fittings or pull sleeves. Wireways used as pull points are to be considered as trays in above.
- 7. Conduit Bending Verify that the bending radius is not less than the Radius Sargent & Lundy's standard large conduit bends shown on Attachment C., unless otherwise indicated (e.g.
min. radius bend or specific radius) on the EI drawing. Where conduits are shown to have " minimum radius bend" on the EI drawing, the radius shall not be less than the " manufacturer's standard elbows" shown on Attachment C. *
- 8. Total Conduit Verify that total conduit bends between pull points do Bends Between not exceed 270* unless otherwise indicated on EI Pullpoints drawing.
Instruction Prepared Date Instruction Approved Date By (DE) (CSR SUPV.)
t Y~f m,_, (){ll0rV '/2l%i 0198J y 1
l Psga 4 of 8 Rev. 4
(, Checklist Instruction Population Conduit Identification No.
CSR-I-E-CND Attribute for Inspection j t
Instruction / Source Document i
- 9. Conduit a. Verify that power and control conduit terminations I Terminations. are not attached to category I trays.
to Cat I Tray b. Verify that' instrument conduits terminate at cable tray with a section of liquid-tight flex conduit with an allowance for 12" mo,vement between conduit and tray unless otherwise noted on EI drawings.
- 10. Conduit verify that when conduit terminates at motor terminal Termination to housing or free standing panels, flexible conduit is Equipment )
l provided with length at least 12 times the diameter but not exceeding 6' unless otherwise specified on EI drawing. No minimum length is required when both ends are rigidly supported from the same surface.
i
- 12. Wireways Verify all subattributes listed in the cable pan reinspection checklist and instructions.
I Instruction Prepared Date Instruction Approved Date By (DE) (CSR SUPV. )
( 'Nfffs-h; il'/85 Q4%g,y a:/yg 0198J
/ -
P g) _E_ cf ,_g_
1 R ".v . 4 Identification No: CSR-I-E-CND .
ATTActBIENT A I* 1. The extension of the hanger member beyond the last conduit on vertical or horizontal support must be 1/8" min. beyond the edge of the clamp or connection element.
- 2. The attachment location of conduit on unistrut type supports CC, W, WH, CP, & PC may be relocated minus 6" (closer to' supporting structure) or plus 2" (farther from supporting structure) provided that the maximum
\
dimension does not exceed that shown on Attachment B.
42 ~6 ye,upmg _ ,,,,,,,,,
4 / STRUCTURE - -
g NISTRUT U
.a
-' g DE5dN -6 ~-A 2 CDN.DUlT s .' LOCATIONt 2 ' + 't ; s ,
l CONDUIT NMEM SIMEN$Emb O N D R A W if %
- 3. Elevation for conduits except those attached to vertical cantilever supports must remain within 16".
- 4. Secondary Erection Tolerances (Applicable only to Unit I conduits North of Coltaan Row 18. Not applicable to "N" or,"R" category conduits).
~ suppear/N6
- a. The attachment location of conduit on Kreuerugs vertical or horizontal cantilever ' ' ' ' ' ''
I supports may be moved from the design D.* "* ',,-d location upto d" towards or 2" away 3 - - 44tdCATEA #05/72' from the supporting structure. When 1 0# coNAu/r the relocation is more than 6" the conditions of item 4c have to be met. ag '
- b. Elevation for conduits on supports other than listed in 4a must remain 5 - -
- '## #0######
within 12'-0" of the design location. I or coNou/r i
When the relocation is more than 6" the conditions of item 4c have to be y gppg, ,,,y,,,, ,,, go,,u,,
STRAP CONNGCT/ON
- c. Relocation of conduit supports, conduit attachments and auxiliary tube steel shall be limited such that the metal to metal separation distance between the conduit and all other conduits, boxes and trays meet the greatest of the applicable following criteria:
(contd)
! Prepared by(Dhi MT 1 /'
Approved by (CSR Supv) 'S LO b/(X l
1 0198J
l p:g) 6 cf L
, Rev. 4 Identification No:CSR-I-R-CND
{.
Attachment A (contd)
- 1. Minimum 6" separation between conduits in the same division.
ii. Minimum 12" separation between "K" type conduits and "C" type conduits.
iii. Minimum 20" separation between "K" type conduits and "P" , type conduits iv. Minimum 3'-0" separation between conduits in different divisions.
- v. Minimum 6'-0" separation between "P" type or "C" type conduits and "KN" category or "KR" category conduits.
vi.
When more than one conduit is attached to the same support and the existing conduit separation of that support violates secondary erection tolerance criteria, the existing separation may be maintained when relocating that support.
I i
Prepared by (DE) T-2 7*7._ ,
' ' I/fJ O! Civ/
Approved by (CSR Supv) ' ' ' N >~
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1 l
~
0198J
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< 9:g2 7 of 8
. Rev. 4 Identification No:CSR-I-E-CND l 1
l ArtacunENT a
, .r= EENT PolNT OF CONOUlT ,
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- OR P 100t. A c-%
CONDUli 7YPE CP CElyNG CANTILEVER - CONDUlT PARALLEL
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Prepared by (DE) M I [d- P -)
Approved by (CSR Supv) 6N!teWl/1/6
(
0198J
Page 8 of 8 Rev. 4 Identification No:CSR-I-E-CND ATTACittBNT C Normal Sargent & Lundy Manufacturers Conduit Large Radius Standard Size Conduit Bends Conduit Elbows Radius Radius 3/4" 12" 4-1/2" t
1" 12" 5-3/4" i 1-1/4" 18" 7-1/4"
(
1-1/2" 18" 8-1/4" 2" 24" 9-1/2" 2-1/2" 24" 10-1/2" 3" 36" 13" 3-1/2" 36" 15" 4" 36" 16" 5" 48" 24" 6" 48" 30" RIGID STEEL CONDUITS BENDS & ELBOWS Prepared by (DE) '"7 @ 7 '/#/C
.- 1 Approved by (CSR Supv. ) '?tik/ 'it..'<C
/
i 0198J -
,i fE3
/
D) UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of -)
) '
I COMMONWEALTH EDISON COMPANY i
) Docket Nos. 50-456
) 50-457 (Braidwood Station Units 1 and 2) ) '
REBUTTAL TESTIMONY OF NEIL P. SMITH (ON ROREM Q.A'. SUBCONTENTION 2)
(Harassment and Intimidation) i
< i l
1 i
f f
l August, 1986 i
- - - - e. . - , . -
. - - - - - . . - . . --- , ,-, ,, -,-_,e.---~~.-,3 -, r,._-,--... , , , , - . . - . - - - + - - -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD q
In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 Braidwood Station Units 1 and 2 >
REBUTTAL TESTIMONY OF NEIL P. SMITH ON BCAP CSR RESULTS FOR ELECTRICAL CONSTRUCTION CATEGORIES Q.l. Mr. Smith, by whom are_you employed and in what capacity?
A.l. I am employed by Commonwealth Edison and was the BCAP Site General Supervisor, Quality Assurance. The BCAP has now been completed, i and I am currently assigned to Commonwealth Edison's Station Nuclear Engineering Department as Reliability and Design Group Supervisor.
4 Q.2. What were your responsibilities with respect to the BCAP?
A.2. I managed the BCAP Quality Assurance group (BCAP QA) on a day to day basis.
Q.3. How long were you the BCAP Site General Supervisor, Quality Assurance?
l
}
I i
A.3. I was the Site General Supervisor, Quality Assurance since April
\_,1 16, 1984. This was prior to the BCAP program document being fully developed thus allowing for my comments to be incorporated into the final document that was submitted to and approved by the NRC Staff.
Q.4. Please summarize your education and professional experience.
A.4. I have a BSEE from the University of Illinois and a MBA from the University of Chicago. From January, 1968 through June, 1976 I was associated with Commonwealth Edison's Division Engineering Departments. In June, 1976, I was transferred to Quality Assurance as a Lead Electrical Inspector. In this capacity I was certified as an SNT TC-1A Level II Radiographic Interpreter, Magnetic Particle Test Observer and Liquid Penetrant Test Observer as well as being trained in other areas such as welding, codes and standards. I was also certified as a Lead Auditor. In November,
, 1977, I was transferred to the Station Nuclear Engineering Department (SNED) where I was assigned to the Dresden I engineering group, then later I was given special assignments. My final assignment in SNED was that of the Zion Project Engineer.
In April, 1984, I was again transferred to Quality Assurance as Site General Supervisor, Quality Assurance. I have been re-certified as an Auditor and a Level II QA Inspector.
In addition to the above employment experience I am a Registered Professional Engineer and a member of the IEEE and the associated Power Society and Industrial Applications Groups. Also, I have been a member of a number of industry owners groups.
O 2-
For additional details concerning my professional experience, O Attachment 2C (Smith-1) is a copy of my resume.
Q.5. Mr. Smith, what is the purpose of this rebuttal testimony?
A.S. The purpose of this rebuttal testimony is to explain why BCAP QA concluded that the BCAP Task Force inspectors who inspected electrical construction categories performed their work. carefully and competently, and to explain why BCAP QA also concluded that the results of the CSR reinspections for the electrical construction categories are reliable.
Q.6. Mr. Smith, please describe generally the BCAP Q.A. organization and its activities.
A.6. The BCAP QA group was formed within the Braidwood Site Quality Assurance Department to overview BCAP for conformance to quality assurance requirements. The organization of BCAP QA is shown in Attachment 2C l (Smith-2). There were four groups established within i
i BCAP QA, one for each of the three BCAP elements (CSR, 1
RPSR, and RSCAP) and a separate overinspection group.
BCAP Quality Assurance was staffed with personnel from CECO and consultant organizations. These personnel had no prior responsibility for construction activities at Braidwood. At its peak, BCAP Quality Assurance included ,
I 17 professional personnel. These personnel had a total of nine bachelor's degrees, seven master's or advanced O
degrees, and two professional engineer's licenses. In
%/ addition, four of these personnel had nuclear power plant operations experience. The BCAP Quality Assurance engineers had an average of 21.9 years of experience.
The BCAP Quality Assurance inspectors had an average of 11.6 years of experience. Over the course of the program, the BCAP Quality Assurance professional staff expended more than 20 man-years in carrying out its duties. Attachments 2C (Smith-3) and 2C (Smith-4) reflect the document reviews, and the schedule audits and surveillances carried out by BCAP QA with respect to BCAP Task Force activities. Attachment 2C (Smith-5) shows that BCAP QA actually carried out many more surveillances than scheduled. In short the BCAP QA overview of BCAP Task Force activities was extensive.
Q.7. Mr. Smith, what of anything did BCAP QA do to ensure the quality of CSR inspections of electrical work?
A.7. First, BCAP QA overviewed the qualifications and training of the BCAP Task Force Inspectors to assure their competence.
4 I
Second, BCAP QA reviewed all the BCAP inspection checklists and instructions in detail to assure they met the program commitments and adequately addressed the subject.
Finally, BCAP QA performed overinspections of the reinspections performed by the BCAP Task Force personnel. The BCAP QA i
4
inspectors were qualified and certified in the same manner as the
.\- Task Force inspectors. The results of the overinspections were within the acceptance criteria which we established.
Q.8. Please describe BCAP QA's overview of BCAP Task Force inspectors' qualifications and training.
A.8. BCAP QA reviewed the training of BCAP Task Force inspectors in a three step approach. The first step was the review of each BCAP Task Force inspector's individual qualification / certification package. The second step was BCAP QA's scheduled and unscheduled surveillances of the training and the maintenance of training of the BCAP Task Force inspectors. Finally we performed comprehensive audits in which we explored in depth the training given to the BCAP Task Force inspectors.
In addition, the BCAP QA required the BCAP Task Force Level III inspector for each discipline to overinspect a 20% sample of the first 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of each Task Force Level II inspector's work to assure that the Level II inspector was performing satisfactorily.
Q.9. What was BCAP QA's conclusion with respect to the qualifications and training of the BCAP Task Force inspectors?
A.9. We found that the BCAP Task Force inspectors were highly experienced in their respective discipline (sy. In addition, all l 1
qualification and certification requirements were satisfactorily completed indicating that each inspector had the proper understanding and~ knowledge of the BCAP program.
b)
- s. -
_= _
Q.10. Please describe BCAP QA overview of BCAP Task Force inspection
()
checklists and instructions.
A.10. Before reinspections could begin, the BCAP Task Force had to develop checklists and instructions to guide the BCAP Task Force inspectors. All checklists and instructions were reviewed and concurred with by BCAP Quality Assurance. (This concurrence is not shown on the face of the checklists and instructions attached to Mr. Shevlin's and Mr. Wozniak's testimony, but is documented in the BCAP QA files.) Moreover, BCAP Quality Assurance confirmed by surveillance that the checklists and instructions for each population had been appropriately reviewed by Sargent and Lundy, concurred with by BCAP Quality Assurance, and approved for use by the BCAP Task Force Director.
BCAP Quality Assurance performed a surveillance of the reinspection and documentation review verification packages assembled by the BCAP Task Force before each population was released for reinspection. The surveillance included examining a minimum of 10% of the packages for each reinspection sample category. Such examination assured that the appropriate index, references, checklists, instructions, drawings, and documents were included.
The results of reviews were documented. Additionally, quality assurance guidance was provided to BCAP Task Force continuously during the development and evaluation of checklists, and instructions.
,~
Q.11. Please describe the BCAP QA overinspection program for the f- electrical construction categories.
A.11. The BCAP Quality Assurance Overinspection/0verview Group performed a minimum of 10% overinspections of the BCAP Task Force inspections in each construction category sample. Individual inspection verification packages were randomly selected by computer for each construction category. The sample selected was kept confidential until the BCAP Task Force completed its inspections in the particular construction category being overviewed. Upon BCAP Task Force completion of reinspections, one inspection package for each BCAP Task Force inspector performing a construction category inspection not covered by the random sample l
was overinspected. This process resulted in each BCAP Task Force inspector being overinspected at least once for each construction category that he or she inspected.
The overinspection effort verified the competence of the individual BCAP Task Force inspectors and validated the quality.of the entire BCAP Task Force reinspection effort as described later in this testimony.
Q.12. Describe the qualifications and training of the BCAP QA overinspectors who performed these overinspections.
A.12. The BCAP overinspectors completed required training prior to the time they were certified as inspectors for BCAP QA. This training was detailed in applicable procedures and included general j l
orientation and indoctrination, site specific procedure l 1
r- .
I and on-the-job training under actual field conditions. After the
~
- (',_,T
/ BCAP inspectors were certified, their training was maintained
- current by being updated to applicable procedures as they were I
revised and issued for use.
The qualification / certification of BCAP QA overinspectors was accomplished by the completion of site qualification requirements relative to the applicable area or areas of certification for individual inspectors. These requirements included applicable training, requisite related experience, general and practical (field) testing, and satisfactory eye examinations. It should be noted that after completion of initial certification, the BCAP QA overinspectors were retested to upgrade them to a new revision of the site qualification / certification procedure. This was accomplished prior to their performance of actual overinspections in the field. The decision to delay overinspections until after the satisfactory completion of retesting, as described in the revised site procedure, was made to assure consistency and continuity for the overall overinspection activity. The overinspectors satisfactorily passed the retesting as described in the revised qualification / certification procedure, including overinspectors who were not employed at the time when the earlier revision of the site qualification / certification procedure was in-effect.
O
7 BCAP QA inspectors were selected that were highly qualified by (3
(l virtue of their previous experience in related inspection areas.
The average experience of BCAP QA overinspectors was 12.33 years.
This experience integrated with site specific training and testing provided a high degree of confidence in the qualifications of the BCAP QA inspectors.
]
What was the acceptance criteria for the BCAP QA overinspection
~
Q.13.
effort?
A.13. Agreement percentag s of 95% for objective attributes and 90% for i
subjective attributes were established by BCAP management as
, acceptable. These acceptance criteria were intended to apply to the summation of all the BCAP Task Force inspectors work in each construction category. They were not intended to apply to an
- individual inspector's work.
The basis for these acceptance criteria was the Lyron QC Inspector Reinspection Program which was addressed and accepted by the Licensing Board in the Byron Supplemental Initial Decision, LBP-84-41, 20 NRC 1203 (1984).
l Q.14. How were BCAP Task Force inspectors' findings compared with the BCAP QA overinspectors' findings?
A.14. The Task Force inspection results were compared with the overinspection results on a checklist attribute level not an individual inspection point basis. That is, an attribute such as
" cable pan type and size" (as shown on checklist CBP-CSR-I-E, 4
O d
which is Attachment 2C (Wozniak-1), page 8) which requires
.) verification of a number of subattributes, would be considered to be in disagreement. if even' a single sub-attribute were missed.
The sub-attributes for cable pan type and size are as follows:
4
- a. Verify that cable pans are solid bottom type except those identified with detail numbers 709, 710, and 711 series in cable pan piece parts drawing.
Verify that cable' pans identified with detail numbers 709, 710, and 711 series are ladder type.
- b. Verify that the width and depth of straight cable pan section agrees with the cable pan detail number shown on the piece parts and covers drawing, using the following table. Do not include the depth of side rail, if any, in measuring cable pan depth.
4th Digit of Pan 5th Digit of Pan Detail Number Width Number Depth A 6" 4 4" B 1-0" 6 4" C 1-6" 8 4" D 2-0" 12 4" E 2-6" F 3-0" Example: Cable Pan Detail Number - 705E4 E - Means 2'-6" wide 4 - Means -4" Deep
- c. Verify that the width and depth of straight wireway section agrees with the electrical installation drawing.
- d. Verify that fittings have the same width and depth as the straight cable pan sections they are connected to, and are of the correct type (e.g. tees, ells, etc.) as per piece parts and covers drawings.
A single miss on a single item would have caused the entire attribute to be considered in disagreement. Comparisons of BCAP Quality Assurance results were then made against the BCAP Task Force results and the number of. agreement / disagreements recorded.
b
- ~ >
1
, ? ,
F ~-
Acceptable checklist attribute. combinations were:
O s/
BCAP BCAP Quality Assurance
! Task Force Overinspection/0verview Group Accept Accept .s Reject Reject
- Reject Accept Unacceptable checklist attribute combination:
Accept Reject
- Task-Force is in the conservative direction.
.Q.15. What were the results of the BCAP QA overinspections for the electrical construction categories?
A.15. The results of the BCAP QA cverinspection for the electrical construction categories are as follows:
Packages.
Construction Category Overinspected % Objective (%)' Subjective (%)
Acceptance Criteria 95 90 Conduit 12 97 N/A Category 1 conduit hangers 12 98 95 j Cables 15 97 N/A Cable pans 10 99 98 Category 1 cable pan hangers 11 97 95 Electrical equipment installation 4 100 98 Q.16. What is your opinion of the qua11sy of these inspector's work?
A.16. I believe these inspectors performed quite well.
4 1
i l
.l u
-)
Q.17. Why?
r e-( )s A.17. As the preceding Table shows, the Task Force inspectors missed relatively few items.' None of the items missed was found to be design significant. Also, my belief is based on my superv'sion i of and discussions with the BCAP QA overinspectors who overinspected the Task Force work.
M Q.18. What basis is there for believing that the BCAP QA overinspectors' results arc an appropriate yardstick with which'to measure the BCAP Task Force inspectors' performance?
A.18. In addition to the above described experience, training and certification programs, an overinspection validity review was conducted. This review was undertaken in order to ensure the overall effectiveness of the overinspection program.
As part of the overinspection validity review a performance evaluation program was conducted in accordance with guidance provided by an industrial psychologist. The Performance Evaluation Program (PEP) was initiated to' determine the extent to which an overinspector would agree or disagree with the initial inspection results of the original inspector.
Within the PEP, inspection packages which contained !
l inspection rejects which had been altered to inspection l accepts were provided to the BCAP QA overinspectors as part !
I of their normal work. During the preparation of the PEP j l
package, the original observation was removed, all references to the observation were eliminated and the applicable D
G
attribute (s) on the checklist was altered from reject to
.( accept. Copies of the altered inspection packages were then produced and put into the overinspection file' drawer from which they were assigned to overinspectors. As far as the BCAP QA overinspectors were concerned, they were receiving a regular BCAP Task Force inspection package. Once the overinspection had been completed, the overinspector prepared the paperwork documenting the overinspection results.
Overall, 13 PEP packages containing 25 altered attributes were overinspected. Of these 25 altered attributes, the overinspectors accurately identified the correct state of 24 of the altered attributes. Additionally, beyond th scope of the performance evaluation program, the overinspectors identified 10 originally accepted attributes that the overinspectors then rejected. These results suggest that the overinspectors did not demonstrate a bias to accept the findings of the original BCAP Task Force inspectors. In fact, the overinspectors were extremely effective in being able to identify and reject any attribute that should have been rejected by the BCAP Task Force.
Q.19. Mr. Smith, to the best of your knowledge, wer'e there any NRC i
inspection violations with respect to the quality of BCAP Task Force inspections in the electrical construction categories? -
O i
A.19. To the best of my knowledge, there were no NRC inspection rh O violations relating to the adequacy of the BCAP Task Force inspections in the electrical construction categories. I am aware of the open item with respect to conduit hanger inspections identified in NRC Inspection Report 85-02, and I agree with the NRC Staff finding in NRC Inspection Report 86-03 that effective corrective action was taken.
Q.20. Please summarize your conclusion with respect to the adequacy of BCAP Task Force inspections of electrical construction categories.
A.20. I believe the BCAP Task Force inspectors did a very professional job in inspecting electrical construction categories. My belief is based on my supervision of and discussions with the BCAP QA overinspectors who overinspected the Task Force work and on the analytical results previously described.
Q.21. Describe the review BCAP QA performed with respect to BCAP Task Force invalidation of observations. 1 A.21. In response to the concern expressed by the NRC Staff early 1
in the BCAP invalidation process, BCAP-QA placed a hold point j such that all CSR observations the BCAP Task Force thought i
should be 'nvalidated, first had to be reviewed and concurred with by BCAP-QA prior to the observation becoming invalid.
The BCAP-QA review first assured the reason for invalidation was acceptable per procedural requirements. If the 1
l l
invalidation reason was acceptable then BCAP-QA performed an
('T
\J-independent verification of the facts which supported ~the invalidation of a specific observation.-
If the review resulted in BCAP-QA not concurring with the BCAP Task Force, a Document Review Sheet was generated detailing BCAP-QA's specific comments. If the Task Force believed the observation in question should still be invalidated, they would provide a written response to the Document Review Sheet. BCAP-QA would review the response, verify any necessary facts and make a determination based on all the facts presented. If additional comments were required, the Document Review Sheet cycle would be redone.
If BCAP-QA agreed with the facts presented either originally or after a comment cycle, a letter would be sent to the Task Force accepting the invalidation reasons, thus allowing the Task Force to invalidate a specific observations. If BCAP-QA did not agree, the observation was processed as valid.
Q.22. What is your opinion concerning the reliability of the CSR results for the electrical construction categories?
A.22. Based on my knowledge of the controlled process used in obtaining the results, my supervision of and discussions with the BCAP-QA overinspectors who overinspected the Task Force inspections, and the analytical results of the overin-specting, I believe the CSR results for electrical construc-tion to be representative of plant conditions and as a result O>
j i
)
reliable. The controlled process used to obtain the results U has been previously discussed in this testimony. However, to briefly summarize, the process included, 1) a detailed procedure development and review process, 2) use'of experienced personnel for both inspectors and overin-spectors, 3) detailed training and certification. programs,
- 4) PEP review and finally (5) the invalidation hold point
- process.
t Q.23. Does this complete your testimony?
A.23. Yes.
I 1
1 i
i 4
- O
Attachment 2C (Smith-1)
RESUME lI PERSONAL:
Name: Neil P. Smith Social Security No.: 361-38-8104 Employe No.: 769-190 Birth Date: June 2,4, 1945 Address: 9859 S. Bell' Chicago, IL 60643 Phone: (312) 233-3327 EDUCATION:
Lane Technical Hiah School, Chicago, IL College Preparatory Program, Graduated June 1963 University of Illinois, Urbana, IL Graduated January 1968 with BSEE University of Chicaco Graduate May 1977 with MBA
( _
1 MILITARY SERVICE:,
I None EMPLOYMENT EXPERIENCE:
January 1968 - August 1968 i Commonwealth Job
Title:
Edison - General Office Industrial Relations Dept.
Engineer. Primary Duties: Observe the activities and functions.of departments within Commonwealth Edison.
August 1968 - January 1970 Commonwealth Edison ComDany - Division Engineering, Chicago North Division. Job
Title:
Engineer. Primary Duties: Field Engineering relating to the design of distribution facilities
- January 1970 - March 1974 Commonwealth Edison Company - Distribution Engineering, General Office. Job
Title:
General Engineer. Primary Duties: Worked
(
on special studies concerning the distribution system addition, Planning Section, planning for large distribution capacity
{} additions.
l (0051R)
- ./
RESUME Page 2 March 1974 - September 1974 Commonwealth Edison Comoany - Division Engineering, Northern Division. Job
Title:
General Engineer. Primary Duties:
Supervised the field design work for new business distribution facilities.
September 1974 - June 1976 Commonwealth Edison Company - Area Engineering Northwest Area.
Job
Title:
Area Engineer. Primary Duties: Supervisor of Area Engineering Department.
June 1976 - November 1977 i
Commonwealth Edison Company - Quality Assurance, General Office. Job
Title:
Senior Engineer. Primary Duties: Lead Electrical Inspector, Braidwood Station.
November 1977 - April 1984 Commonwealth Edison Company - Station Nuclear Engineering
' Department, General Office. Job
Title:
Supervising Design
(
Engineer. Primary Duties: Various assignments which include but not limit,'ed to the following:
- 1. Responsible for the Dresden 1 Reactor Protection System and Post Accident Monitoring System Upgrade.
- 2. Managed the Systematic Evaluation Program (SEP) for Dresden 1 and 2. Represented Commonwealth Edison at the SEP Owner's Group and was Group Chairman during 1981.
- 3. Managed the Operating plants (D, QC, and Z) environmental
~ qualification (EQ) program for electrical equipment.
Represented CECO at the EQ le member of the steering group. gal group meetings and was a 4.
Managed Ceco's efforts for installing the Emergency Off-Site Facilities for the operating plants and LaSalle.
- 5. Coordinated some of CECO long term TMI activities such as i
SPDS for operating plants and LaSalle, response to Reg.
Guide 1.97 and-NUREG 0737.
- 6. Member of INPO's NUTAC's for SPDS, Reg. Guide 1.97, and Emergency Response Facilities.
(
- 7. Zion Project Engineer - Responsible for all major and safety-related engineering projects for the Zion Nuclear Power Plant.
(0051R) l L__ _
__ --__ _ _ - - _ .- -- ~ ~~-- --- --- -
1 I
RESUME Page 3
- 8. CECO Technical Advisory Committee representative to the EPRI
'~
Seismic Hazards program and limited stand-in to the Executive committee for the program.
April - Present Commonwealth Edison Comnany - Quality Assurance, General Office. Job
Title:
General Supervisor Q.A. Primary Duties:
. Review of BCAP program results and interfacing with NRC and IE
- OG.
OTHER EMPLOYMENT EXPERIENCE:
1981 - Present CE representative to the Seismic Qualification Utility Group.
4 Chairman of the group since formation.
1983 - Present
[ CE representative to EPRI Advisory Committee on seismic equipment qualification. Chairman of the group since formation.
(
December 1984'. Present CE representative to EPRI Seismic Center working group.
1 Certification Professional Develooment (ANSI N45.2.6 ANSI N45.2.23) 8 Hour Auditor Training, Quality Auditor, 8-24-84 Assurance, May 1984 Level II Q.A.
' Inspector 8 Hour Codes and Standards Seminar 10-21-85 Quality Assurance, Sept. 1984 PROFESSIONAL CERTIFICATION: .
, Professional Engineer State of Illinois Cert #62-30650 Professional Societies l l
IEEE (member) ,
Power Society I Industrial Applications Group
()
(0051R)
- - . - - - - -- - ---- - - - - - - - - - - - - - - -l
g RESUME Page 4 O~
i COMMONWEALTH EDISON COMPANY COURSES:
- a. Review of Engineering Practices and Calculations i
- b. Fundamentals of Digital Computers !
- c. Introduction to Conversational Programming
- d. Engineering Economics
- e. Law of the Layman
- f. Commonwealth Edison in Perspective ,
- g. Basic Supervision Program l
- h. Instructor Training Course l
- i. Westinghouse Surge Protection of Power Systems )
- j. Utiliterains
- k. Management Coaching l
- 1. Zion Systems Course i l
1
'fhb b
Name
,/>/bh-l Date i
N i
l e
e k
O (0051R)
Attachment 2C (Smith-2) r~
Exhibit 11-3 Il-9
)
1 BCAP Site Quality Assurance Organization l Assistant Manager Quality Assurance Site General Supervisor Quality Assurance i
l l I I Lead Element Lead Element Lead Element Overinspection/
CSR Engineer RPSR Engineer RSCAP Engineer Overview Group i
Supervisor Quality Engineers / Quality Engineers / Quality Engineers / Inspectors Specialists Specialista Specialists O
L L
L l- j l
f svaN-11 11-85 KPS
i di r=== & & & & - *
- m 4 % % MD Exhibit C-1 BCAP Ouality Assurance Document Reviews 1984 1985 Type Sept Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept Oct Policy plans 3 1 3 3 1 1 0 0 0 0 0 0 0 0 Procedures / 26 22 10 7 8 10 6 8 4 2 5 1 4 0 instructions Checklists / 5 19 22 15 34 49 17 33 12 6 0 0 instructions 0 0 Inspector 2 37 6 0 9 8 3 4 2 0 0 0 0 0 certification packages invalid - - - - - - -
362 1059 1475 879 732 758 139 observations Flecord - - - - - - - - - -
packages 1449 Monthly totals 36 79 41 25 52 68 26 407 1077 1482 881 737 762 1588 Cumulative 36 115 156 181 233 301 327 734 1811 3293 4174 4911 >
totals 5673 7261 ,
g e
8 s
M a
?
c> L C378N-811-65 KPS a~
e e .
4 F F F F F - C * *
- M M M =%h '"'"1 Exhibit C-2 BCAP Ouality Assurance Scheduled Completed Audits and Surveillances 1984 1985 SEP OCT NOV DEC JAN FEB MAR APR MAY JUNE Week endng 14l21l28 05l12l19l26 02l09l16l23l30 01l14l21l28 04l11l18l25 01l08l15l22 01l08l15l22l29 05l12l19l26 03l10l17l24l31 07l14l21l28 ActivitytSubject Aree CSR Procedures Population estabash A S S S S A S S A S S S A S S S S j Sarmle selection A S S S S S A S S A S S S A S S S S Chechtst/ktstructions prop A S S S S A S S ___
A S S S A S S S S Verification package prop S SA S S S A S S A S S S S A S S S S Reinspect / doc review S SA S S S A S S A S A RPSR Procedures Regts Hentification A S S S S S A 3 S S S A A Check 8st prep A S S S S S A S S S S A S S S S A S S Contractor proc review A S S S S A S S S A S S S S A S S RSCAP Procedures Review rnethode ll lAlSlSlSl lSl lSl lAl lSl ll lSl lSl lSl lSlAl lSl lSl lSl lSl lSl lAl lSl lSl l Administrative Procedures Program kusoctrination A S S S S A S S S A S S S A 5 S Organtration A S S S S A S A A Records management A S S S S A S S S A S S S A S Contractor /eng interface A S S S S A S S A S S S A g A S A A A Observation processing A S S S S S S S S ft Reports A .
S S S S A S A A h Reinspection training A S S S S A S S A S S S S A h a
S&L Procedures BCAP related ll l l l l l ll l l l ll l l l l l lAl l l lSl l l lAl l l lSl l l l l lAl l l lSl o,.ct - .c.du,..
o BCAP related ll lll l lll l l lll l lll lAl l l lSl l l lSl ll lAl l l lSl l l lSl l l l g N
e,s . . ..as .r., Notes. A8 A . sched,uled audits.a_nd
. S . se,ve .. survemances were completed as scheduled s ;;-
T t
I Exhibit A-5 Surveillances Conducted ,
September 7,1984, Through November 1,1985
/ .
Cumulettwo 200 number of surve418ences pertermed ISO
~
I Actual survelliantee 100 survolgences SG
- End of schedule 8
I I I I I I a.mm si m m amm amm wmm amm umm 6378-2311-46 MPS O O h' -
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