ML20214C409
| ML20214C409 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210127 | |
| Download: ML20214C409 (14) | |
Text
UNITED STATES OF AMERICA '
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456
) 50-457 (Braidwood Station, Units 1 and 2 )
AFFIDAVIT OF ROBERT D. SCHULZ -
IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION OF ROREM QA SUBCONTENTION 6.F I, Robert D. Schulz, being duly sworn, aver and state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Comission, Region III, as Senior Construction Resident Inspector at the Braidwood Station, Units 1 and 2. A copy of my professional qualifications is attached hereto as Exhibit 6.F-1.
- 2. As Senior Construction Resident Inspector I am responsible for planning, coordinating, and personally conducting or leading inspections for the construction of Braidwood Station to assure. compliance with designing specifications, the conditions of the construction permit, provisions pf the Atomic Energy Act of 1954, as amended, the Energy Reorganization A'ct of 1974, and the rules and regulations of the Comission.
- 3. The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For $umary Disposition of Rorem QA Subcontention 6.F. This subcontention states as follows:
- 6. Contrary to Criterion V, " Instruction, Procedure and Drawings," of 10 CFR Part 50, Appendix B, Comonwealth Edison Company has 8602210127 PDR ADOCK O86 h b 6 PDR G
failed to ensure that activities affecting ,
quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
F. In June 1984, Phillips Getschow, piping contractor, found piping that violated minimum wall requirements. This defect was not reported to owner in accordance with 10 CFR 21.21. (Inspection Report 84-21/20, Exhibit 20.)
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- 4. In preparing this Affidavit I reviewed the following documents:
- a. " Material Facts As To Which There Is No Genuine Issue _ To Be Heard" with respect to Subcontention 6.F;
- c. "NRC Inspection Report Nos. 50-456/84-21; 50-456/84-20 (first page and pertinent portions of which are attached hereto as Exhibit 6.F-2);
- d. NRC Inspection Report Nos. 50-456/85-07 and 50-457/85-07 (pertinent portions attached as Exhibit 6.F-3).
- 5. This item was identified during a roQtine unannounced documentation review of the material traceab,ility program and is reflected in NRC Inspection Report Nos. 50-456/84-21 and 50-457/84-20 (see Exhibit 6.F-2). The piping contractor failed to notify the Applicant of a potential 10 CFR Part 21 deficiency, in accordance with piping Contractor Procedure QAP-110. " Reporting of Defects and Noncompliance," on Form PG/QA-15-7.
- 6. The noncompliance was a minimum wall violation for two feet of a ten foot piece of received pipe. The two feet had been cut off and scrapped by the licensee prior to the NRC finding; therefore, there was
no safety significance for the Braidwood site. The piping supplier, however, had not been notified. Thus, neither the supplier nor ,
manufacturer could perform an evaluation to determine if other nuclear sites had received any additional footage of this heat of pipe which may have been below minimum wall requirements.
- 7. After the NRC finding, the Applicant's corrective actions included notifying the supplier of the deficiency and reinstructing Phillips Getschow piping personnel with regard to their reporting responsibilities to the licensee. Under current procedure, Phillips Getschow performs a documented review of all NCR's for reportability under 10 CFR Part 21.
- 8. Since only two feet of the ten foot section of pipe received had a minimum wall deficiency and that two feet section had been scrapped this violation does not represent a significant breakdown in the QA/QC Program and the Braidwood site. Applicant's corrective actions involving reinstruction and supplier notification were considered appropriate by the NRC staff. This issue was closed in NRC Inspection Report Nos. 50-456/85007 and 50-457/85007 (see Exhibit 6.F-3 attached). ,
seAdD. .feA~ 4 Robert D. Schulz '
Sworn and subscribed before me
- of February,1986 this /J day On o .kv Notary Public My Connission expires: # ** '
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Professional Qualifications ,
ROBERT D. SCHULZ Organization: U.S. Nuclear Regulatory Consnission, Region III
Title:
Senior Resident Inspector of Construction .
Birth Date: June 9, 1948 Education: B.S., Northern Illinois University,1970 Completed BWR Technology Courses and Two-Week PWR Technology Course, Chattanooga, TN Experience:
1984 to Senior Resident Inspector (Construction) -
Braidwood Site. Plans, supervises and conducts Present conducts inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media. (NRC) 1983 to Reactor Inspector - Inspects reactors under 1984 construction and in operation. (NRC) 1982 to Senior Resident Inspector - Nine Mile Point Plant, 1983 Region I, Construction Site. Plans, supervises and conducts inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media. (NRC) 1981 to Resident Inspector - Nine Mile Point Plant, Region I, 1982 Construction Site. Performed 2513 and 2514 inspection programs at the Nine Mile Point Plant. *
, (NRC) 1980 to Reactor Inspector - Inspected reactors under 1981 construction and in operation in Region III. (NRC) 1975 to Q.A. Engineer - Morrison Construction and 1980 Engineering, LaSalle Station, Braidwood Township, IL.
Mechanical Contractor.
1973 to Senior Buyer - Sundstrand Nuclear, Belvidere, IL.
1975 Purchased material for the Fast Flux Test Facility located in Hanford, Washington.
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1971 to Quality Control Inspector - Morrison Construction 1973 and Engineering, Zion Station, Zion, IL. Mechanical '
- Contractor.
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fddt t.r-z U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-456/84-21(DRP); 50-457/84-20(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois -
Inspection Conducted: September 4 through October 5, 1984 Inspectors: L. G. McGregor R.D.ghulz Approved By: . nk hief Il lb {4 Projects Section lA Date Inspection Summary Inspection on September 4 through October 5, 1984 (Report No. 50-456/84-21(DRP);
50-457/84-20(DRP))
Areas Inspected: Routine, unannounced safety inspection of licensee actions on previous inspection findings; licensee actions on 50.55(e) reports; plant tours; material traceability verification program; welder qualification; heating, ventilation and air conditioning systems; reactor coolant piping; l preoperational test procedure reviews; preoperational test performance; radio-graphic incident; cleanliness inspections of piping and safety-related component,;
and design changes to reactor coolant pump lateral supports. The inspection l consisted of 233 inspector-hours onsite by two NRC inspectors including l
28 inspector-hours onsite during offshifts.
Results: Of the twelve areas inspected no items of noncompliance or deviations were identified in eight areas; one item of noncompliance was identified in each of the remaining areas (paragraph 2, failure to properly perform weld inspections and failure to perform visual weld examinations; paragraph 5, failure to report j minimum wall defects; paragraph 12, failure to perform cleanliness inspections;
.and paragraph 13, failure to adequately complete a plant re-design).
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- 5. Material Traceability Verification Program The material traceability verification program was instituted as a result of an NRC finding identified in Inspection Report Number 83-09, which stated that a documented inspection program to verify correct material installation had not been implemented for 2" and under safety-related piping prior to July 1983, and for over 2" safety-related piping prior to November 1982.
As a result of this finding the licensee decided to inspect all the piping installed prior to the above applicable dates in order to determine the acceptability of piping material installations. As of September 24, 1984, 56 percent of the field inspections have been accomplished and 29 percent of the (documentation) office reviews have been done. Completion of the material traceability verification program i, expected by February 28, 1985.
The, program involves the dedication of nine personnel in the office and 24 personnel in the field. Results of the over 2" safety-related piping inspections were not yet available for review but detailed below are the results of the 2" and under safety-related piping inspections as of September 24, 1984:
. Total number of items inspected - 2123
. Total number of items acceptable - 1625
. Total number of items rejectable - 1
. Total number of items requiring further analysis - 497 Of the 497 items requiring further analysis, 463 items do not have any hardware identification markings, but these items are associated with stores requests. The 2123 items represent 16.8% of the small bore piping included in the material traceability verification program.
l While reviewing the material traceability verification program the inspector I reviewed Phillips Getschow Company Nonconformance Reports Number 1615 and Number 1847. Nonconformance Number 1615 stated that 8" S/120, 7/8" wall, SA-106 Gr. B pipe, heat number 93739, received on Receiving Inspection ,
Report number 15253, was found to be under the minimtm wall requirement of .629 inches. Two feet of the ten foot length were found to be .620
! inches by digital ultrasonic measurement.
10 tFR 21.21 states in part that each individual, corporation, partnership or other entity subject to the regulations in this part shall adopt appro-priate procedures to assure that a director or responsible officer is informed if the construction or operation of a facility, or activity, or a basic component supplied for such facility or activity contains a defect.
Piping Contractor Procedure, QAP-110, Reporting of Defects and Noncompliance, Revision 1, requires that a noncompliance or a basic component or activity supplied to the owner of i licensed facility shall be reported to the owner on Exhibit 1, Form PG/QA-15-7, by the Manager - Quality Assurance under the requirements of 10 CFR 21. The procedure further stated that the scope of the procedure included notifying the owner of a suspected deviation or noncompliance and then the owner had the responsibility for evaluation and corrective action.
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The minimum wall defect was not reported to the owner in accordance with Procedure QAP-110. This is in violation of 10 CFR 50, Appendix B, Criterion V (456/84-21-03; 457/84-20-03). The significance of this issue is that the supplier was not notified of the defect and therefore the supplier did not have the information to notify other nuclear facilities which may have received the pipe. Af ter the NRC inspector identified this issue the licensee notified the supplier.
Nonconformance number 1847 stated that a piece of 31/2" carbon steel pipe was stamped with two heat numbers, 67343 and 38453. The pipe was classified as ASME Boiler and Pressure Vessel Code,Section III, Subsection NC, Class 2.
The piping contractor determined that heat number 67343 was the correct number, but there was no documented evidence justifying heat number 67343.
The NRC inspector determined, by measuring the wall thickness and length of the pipe, that heat number 67343 was the correct number. Heat number 38453 was for schedule 40 pipe and heat number 67343 was for schedule 80 pipe and the pipe was schedule 80. The schedule 80 pipe also matched the length of the pipe for heat identified on the receipt inspection report. The inspector considers this issue closed, but advised the piping contractor to document all justifications for accepting material in the material traceability verification program.
Numerous ASME nameplates were found to be missing from piping subassemblies and as a result a 10 CFR 50.55(e) report, assigned number 84-12, was verbally reported to the NRC on July 24, 1984. A thirty day written report, dated August 24, 1984, stated:
" Description of Deficiency ASME NPT symbol nameplates were removed from piping subassemblies without proper controls and documentation. Nondestructive examinations required by ASME Section III of the nameplate removal areas were not subsequently performed.
Analysis of Safety Implications .
The piping systems involved are ASME Secti~on III and are Safety Cate-gory I. Lack of required nondestructive surface examinations and wall thickness measurements could potentially result in allowing conditions to exist that do not meet the design requirements. This could poten-tially allow piping defects to exist which may impact on the safety function of the systems involved.
Corrective Action Taken Commonwealth Edison Company NCR No. 639 and Phillips Getschow Company NCR No. 1783 have been generated to document this item and track its resolution. Phillips Getschow Company will initiate a program to determine the total number of nameplates removed, identify the spools, locate nameplate removal areas, and perform the required examinations.
A followup report concerning this issue will be submitted by October 15, 1984."
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4-i U. S. NUCLEAR REGULATORY COMMISSION t REGION III Report No. 50-456/85007(DRP); 50-457/35007(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site Braidwood, Illinois g
, Inspection Conducted: February 13 through March 22, 1985 Inspectors: R. D. Schulz W. J. Kropp I
R. N. Gardner l Approved By: y f N* J Projects Section IA Date Inspection Summary:
Inspection on February 13 throuah March 22, 1985 (Report No. 50-456/85007 (DRP): 50-457/85007(DRP))
Areas Inspected: Routine, unannounced safety inspection of activities observed during plant tours, licensee action on previously identified items, corrective action programs, Quality First Program, mechanical equipment, environmental qualification of containment spray pumps and motors, electrical conduits and cable, electrical penetrations, electrical panels, piping, and instrumentation. The inspection consisted of 299 inspector-hours onsite by three NRC inspectors including 28 inspector-hours onsite during off shifts.
l Results: Of the eleven areas inspected, no items of noncompliance or 1
deviations were identified in nine areas, two items of noncompliance were identified in the remaining areas: failure to set the containment spray pumps in accordance with drawing requirements (paragraph 6), failure to have a documented instruction or procedure for producing Inservice Inspection
! drawings (paragraph 11).
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- 2. Plant Tours The inspectors observed work activities in progress, completed work, and plant status during general inspections of the plant. Obse rva tion of work included high strength bolting, safety-related pipe welding, reactor coolant pipe welding, HVAC welding, anchor bolts, structural welds, mechanical equipment installations, piping spool transfers, instrumentation racks, instrumentation piping, and cable trays in the containments and auxiliary. building. Particular note was taken of material identification, nonconforming material identification, and housekeeping. Craft personnel were interviewed in the work areas.
No violations or deviations were identified.
- 3. Licensee Action on Previously Identified Items
- a. Noncompliances '
(Closed) 456/84-21-03; 457/84-2' -03: A piping minimum wall violation was not reported to die licensee in accordance with procedure requirements and 10 CFR Part 21. The piping supplier has been notified of the nonconforming condition and the non-conforming section of the pipe has been removed and scrapped.
Phillips, Getschow personnel have been re-instructed in their reporting requirement responsibilities.
(- (Closed) 457/84-29-02: Two cables were not routed in accordance with the cable pull cards. The routings have been corrected and craft personnel were retrained in cable pulling activities. In addition, twenty-four additional cables, that had been inspected and accepted by the quality control inspector who accepted the two misrouted cables, were inspected by another qualified cable inspector. All of the twenty-four cables were routed correctly,
- b. Open Items
! (Open) 456/84-17-04; 457/84-17-04: Flange bolt-up documentation deficiencies and rusted flange bolts. Commonwealth Edison presented this item to the NRC for closure, based on a mechanical joint retro-fit program written by the piping contractor. The procedure for implementing the program was reviewed by the NRC and the procedure was found to be ambiguous with regard to the visual inspections that were to be performed. The procedure is presently being revised and will address the specific visual examination requirements. This item will not be closed until the procedure is revised and the retro-fit program is satisfactorily implemented.
No violations or deviations were identified.
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SUBCONTENTI')N 6.G ,
Rorem QA Subcontention 6.G, as admitted in this proceeding, states as follows:
- 6. Contrary to Criterion V, " Instructions, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
G. Applicant placed purchase orders with an unapproved bidder, H. H. Howard Corporation of Chicago, that did not have an approved QA program. Purchase orders were for cleaning of 206,744 feet of safety-related piping.
(Inspection Report 84-17, Exhibit 21.)
In its Motion for Sumary Disposition of Rorem QA Contention, Subcontention 6.G Applicant acknowledges that having the pipe cleaned by a non-safety-related vendor was an error and constituted a noncompliance with the requirements of Criterion V., " Instructions, Procedures and Drawings," of Appendix B to 10 C.F.R. Part 50. Applicant's Motion 6.G at 4. Applicant concedes that its QA Manual, in Q.P. No. 4-1, requires that vendors of safety-related services be listed on in an approved bidders list and that purchase orders for such services must be reviewed and accepted by Applicant's Quality Assurance Department to assure that the necessary technical and quality requirements are included in the procurement documents, and that the procurement is made from the plant location for which the vendor's Quality Assurance Program is approved. Id. While Applicant admits that the purchase of the chemical cleaning services from H. H. Howard constituted a noncompliance with the QA Manual requirement, Applicant contends that this noncompliance was an
isolated incident and that it has taken effective corrective action to ,
prevent recurrence and thus there is no genuine issue of material fact to be heard with respect to this subcontention. Applicant's Motion 6.G at 4-6. The NRC Staff agrees.
The item which forms the basis of this subcontention was identified
.by Mr. Robert D. Schulz, the Senior Construction Resident Inspector at the Braidwood Station, as a result of a construction worker's request that he investigate the Phillips Getchow Company's installation of small bore piping that may not meet minimum wall requirements. Affidavit of Robert D. Schulz in Support of NRC Staff's Response to Applicant's Motion for Sumary Disposition of Rorem QA Subcontention 6.G at 15 (hereinafter Schulz Affidavit 6.G).
Mr. Schulz began his inspection with a review of 10 C.F.R. 50.55(e)
Report No. 84-10 (July 20, 1984). This report identified Heat Num-ber KD 6751 as having minimum wall dimensions which did not meet material manufacturer ASME Code requirements. This heat number included a received quantity of 47,850 feet of pipe. Schulz Affidavit 6.G at 16.
Subsequent investigation by Mr. Schulz of Phillips Getschow documentation revealed that eight heats of pipe were identified by Phillips Getschow as being in a rusted condition due to outdoor storage. Schulz Affidavit 6.G at 1 7. He determined from discussions with Phillips Getschow personnel that some of the rusted pipe had been sent to a vendor to be cleaned.
M . On the basis of this information he reviewed the Applicant's purchase orders, which authorized the offsite cleaning of the rusted pipe. M. Purchase Order Number 730091 placed on May 17, 1981 and Purchase Order 254379 placed on July 9, 1981 indicated that eight heats
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l of safety-related pipe were sent to H. H. Howard Corporation for chemical ,
cleaning. I d_. The vendor performed the service of chemical cleaning the pipe. The eight heats of pipe represented 206,744 feet. M.
In the course of his inspection Mr. Schulz verified that the vendor, H. H. Howard Corporation, was not an approved bidder as required by Q.P.
No. 4.1 of the Commonwealth Edison Quality Assurance Manual. Schulz Affidavit 6.G at 1 8. H. H. Howard Corporation did not have an approved quality assurance program. Id. There were no references in the purchase orders to quality assurance program requirements. I_d . This procedural i
violation pennitted H. H. Howard to receive the corroded pipe.
Mr. Schulz documented his finding concerning the improper receipt of 206,744 feet of pipe by an unapproved vendor in NRC Inspection Report Nos. 456/84-17 and 457/84-17, (July 7, 1984 through August 31,1984).
M,seealsoEx.6.G-2.
After the NRC Inspection Report was issued Applicant submitted a supplement 10 C.F.R. 50.55(e) Report No. 84-10 on September 18, 1984, to the NRC which listed the eight heats of pipe sent for chemical cleanings
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by the same unapproved vendor. .
Schulz Affidavit 6.G at 19. The l~ Applicant had originally identified only Heat Number KD 6751 as having [
! potential minimum wall violations in 10 C.F.R i 50.55(e) Report 84-10, dated July 20, 1984. Id.
Mr. Schulz verified that the Applicant's corrective action measure required a procurement review by quality assurance supervisory personnel to preclude unapproved vendors from performing future services with ,.
J respect to any safety-related material and to ensure that appropriate quality provisions are included in procurement documents. Schulz l
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Affidavit 6.G at 1 10. Mr. Schulz reviewed the corrective actions taken by Applicant to correct this violation and, after concluding that they were satisfactory, Mr. Schulz closed this item in NRC Inspection Report Nos. 456/84-42 457/84-38, See Ex. 6.G-3. This resolves the procedural
. noncompliance which forms the basis of Subcontention 6.G.
The NRC Staff contends that although the procedural noncompliance represented a lapse in QA/QC controls, the design significance of the underlying deficiency will be based on the hardware analysis of the effect of the chemical cleaning process on minimum wall deficiencies.
Schulz Affidavit 6.G at 19. As to the hardware implications of possible minimum wall deficiencies, NRC Region III Inspector James Muffet is reviewing the effect of the chemical cleaning process on the 206,744 feet of pipe as part of Rorem QA Subcontention 11c. I_d . This issue is tracked by 10 C.F.R. 5 50.55(e) report 84-10. The Applicant instituted a comprehensive program involving an analysis of the effects on the pipe by the chemical cleaning process and this item will be addressed in Contention Item 11.C. I d..
None of the information available to the Staff indicates a failure of the Applicant's corrective action to prevent recurrence of this isolated procedural ncncompliance. Intervenor has not presented any information to the contrary during discovery. Therefore, there are no genuine issues of material fact to be heard regarding this subcontention as a matter of law. The Staff concludes, based on the discussion above, that Applicant's Motion for Sumary Disposition of Subcontention 6.G should be granted.
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