ML20214C439
| ML20214C439 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Schultz R, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210137 | |
| Download: ML20214C439 (19) | |
Text
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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.G I, Robert D. Schulz, being duly sworn, depose and state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Ccmission, Region III, as Senior Construction Resident Inspector at the Braidwood Station, Unit 1 and 2. A copy of my professional qualifications is attached hereto as Exhibit 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 of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, and the rules and regulation of the l Comission.
- 3. The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Sumary Disposition of Rorem QA Subcontention 6.G. This subcontention states as follows:
- 6. Contrary to Criterion V, " Instructions.
Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Comonwealth Edison 8602210137 860218 hDR ADOCM 05000456 PDR
Company has failed to ensure that activities '
affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these in'structions, 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.)
- 4. In preparing this Affidavit I reviewed the following documents:
- a. " Statement of Material Facts As To Which There Is No Genuine Issue;"
- b. " Testimony of Michael A. Gorski (on Rorem Q.A.
Subcontentions SA and 6.G)."
- 5. I identified the item which fcrms the basis for this subcontention as a result of a construction worker's request that the Senior Construction Resident investigate the installation of small bore piping that may not meet minimum wall requirements.
- 6. My inspection began with a review of 10 C.F.R. 5 50.55(e)
Report, 84-10, dated July 20,.1984. This report identified Heat Number 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.
- 7. My subsequent investigation of Phillips Getschow documentation revealed that eight heats of pipe were ider.tified by Phillips Getschow as being in a rusted condition due to outdoor storage. I determined from discussions with Phillips Getschow personnel that some of the rusted pipe had been sent to a vendor to be cleaned. On the basis of this information I reviewed the Applicant's purchase orders, which authorized
the offsite cleaning of the rusted pipe. Purchase Order Number 730091 ,
placed on May 17, 1981 and Purchase Order 254379 placed or. July 9, 1981 indicated that eight heats of safety-related pipe were sent to H. H. Howard Corporation for chemical cleaning. The vendor performed the service of chemical cleaning the pipe. The eight heats of pipe represented 206,744 feet.
- 8. The vendor, H. H. Howard Corporation, was not an approved bidder as required by Q.P. No. 4.1 of the Connonwealth Edison Quality Assurance Manual. H. H. Howard Corporation did not have an approved quality assurance program. There were no references in the purchase orders to quality assurance program requirements. The NRC documented its finding concerning the 206,744 feet of pipe in NRC Inspection Report Nos. 456/84-17 and 457/84-17, (July 7, 1984 through August 31,1984),the pertinent portion of which is attached hereto as Exhibit 6.G-2.
- 9. Applicant submitted a supplemental 10 C.F.R. 6 50.55(e) Report.
84-10, dated September 18, 1984, to the NRC which listed the eight heats of pipe with potential minimum wall violations due to rust and subsequent chemical c' leanings. The Applicant had originally identified only Heat .
Number KD 6751 as having potential minimum wall violations in 50.55,(e) l Report 84-10, dated July 20, 1984. Mr. James Muffet is reviewing the i
l effect of the chemical cleaning process on the 206,744 feet of pipe.
l This issue is tracked by 10 C.F.R. 9 50.55(e) report 84-10. Although this violation represented a lapse in QA/QC controls, the design significance of the issue will be based on the hardware analysis of the l
l effect of the chemical cleaning process on minimum wall deficiencies.
The Applicant has subsequently 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.
- 10. The Applicant's corrective action measure required a procure-ment review by quality assurance supervisory to preclude unapproved vendors from performing future services on safety-related material and to ensure that appropriate quality provisions are included'in procurement documents. I closed this itam in NRC Inspection Report Nos. 456/84-42 and 457/84-38 based on my review and determination that the corrective actions for future purchase orders and the analysis to be performed as delineated in 10 C.F.R. 5 50.55(e) Report 84-10, dated December 12, 1984, were adequate.
Mp.sM Robert D. Schulz j d
Sworn an# day subscribed before me this /J of February,1986 0t <k Notary Public k r' T.IyCe==!:IuE; gg y,z 3,33 ,
My Commission expires:
bbbkf,g-j Professional Qualifications ,
ROBERT D. SCHULZ Organization: U.S. Nuclear Regulatory Commission, 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 inspections at the tite. 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.
- b. (p. 6 - 1
- 59 -
j 1971 to Quality Control Inspector - Morrison Construction *
- 1973 and Engineering, Zion Station, Zion, IL. Mechanical Contractor.
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&hW t,.G -1 U. S. NUCLEAR REGULATORY COMMISSION
' REGION III Report No. 50-456/84-17(DPR); 50-457/84-17(DPR)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 L,1censee: 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: July 7, 1964 tnrough August 31, 1984 Inspectors: L. G. McGregor R. D. Schulz J. F. Schapker Approved By:
f.9 P W. L.k $rChief Forney', /
/ /84 Projects Section 1A Date Inspection Summary
- Inspection on July 7 through Auaust 31, 1984 (Report No. 50-456/84-17(DPR);
50-457/84-17(DPR))
Areas Inspected: Routine, unannounced safety inspection of work activities observed during plant tours, items reported pursuant to 10 CFR 50.55(e),
Inspection and Enforcement Bulletins, licensee action on previous inspection -
findings, structural steel and supports, and instrument piping and tubing.
The inspection consisted of 128 inspector-hours onsite by three NRC inspectors including 13 inspector-hours onsite during off shifts.
! Results: Of the six areas inspected, no items of noncompliance were identified in the area of items reported pursuant to 10 CFR 50.55(e); Inspection and Enforce-ment Bulletins; and licensee action on previous inspection findings; two items of l
noncompliance were identified as a result of plant tours (deficiencies in the control of small bore piping, paragraph 2); and one item of noncompliance was i
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identified (inadequate welding controls and insufficient records, paragraph 4 and
- 5) in the areas of structural steel and supports and instrument piping and tubing.
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- bic. (o. 6- 2.
j Pittsburgh Testing Laboratory (PTL)
F. Forest, Site Manager
- i T. Frazier, Assistant Site Manager
- Denotes those attending exit meeting on August 31, 1984. -
- 2. Plant Tours The inspectors observed work activities in progress, completed work, and .
} plant status during general inspections of the plant. Observation of work l included structural high strength bolting, safety-related pipe welding,
! anchor bolts, structural welds, flange bolt-ups, and cable trays in the
- containments and auxiliary building. Particular note was taken of material
- identification, nonconforming material identification, housekeeping, and equipment preservation. Craft personnel were interviewed, as such personnel were available, in the work areas.
l During one of the tours, a construction worker asked the Senior Construction i
Resident to investigate the installation of some small bore piping, identi-fied as heat number KD6751. Subsequent investigation revealed that Common-
- wealth Edison notified the USNRC, by telephone, on June 21, 1984, of a i 10 CFR 50.55(e) regarding wall thickness inadequacies for 2" S/80 pipe, heat l number KD6751, and on July 20, 1984, submitted written notification in
- accordance with the thirty day reporting requirements. The July 20 letter j stated that the reduced wall thickness, which was primarily caused by pits
- and grooves, was the result of excessive corrosion and quantities of this
- pipe had been installed in various ASME and instrumentation safety related i
systems. The letter included a section entitled " Analysis of Safety Impli-cation and Corrective Action Taken" which are detailed below:
Analysis of Safety Implication "The reduced wall thicknesses could result in certain piping systems I
not meeting the code stress allowables. If left undetected, this condi-
! tion could potentially result in pipe failure and negatively impact on f its associated system safety functions."
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Corrective Action Taken
" Commonwealth Edison Company NCR No. 633 has been initiated to address this problem. Investigations conducted to date have indicated that this problem is limited to heat number KD6751 pipe. That portion of this heat number which remains in storage has been placed on hold. No release of this material will be authorized until measurements confirm that the pipe meets the minimum wall thickness requirements.
l In order to determine the adequacy of pipe from this heat number which
- has already been installed, a program is being developed to measure,
! in detail, wall thicknesses of the most severely pitted or grooved l pipe currently in storage. Measurement results will be sent to Sargent I, and Lundy for evaluation and subsequent piping system assessments. The I
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h . 6. di - E extent of field inspections and rework will be determined based on the results of the Sargent and Lur.dy investigation.
When this lot of pipe was initially received, it was stored outdoors for an extended period of time which resulted in excessive corrosion.
This condition was observed in the field and the pipe was subsequently chemically cleaned and stored indoors. A review has been conducted of the bulk storage of safety related two inch and under carbon steel pipe by the Commonwealth Edison Company. The results of this review indicate that present storage practices prevent excessive corrosion of pipe due to outdoor exposure.
A follow-up report will be submitted following the initial investigation
. by Sargent and Lundy which is expected by October 1, 1984."
The Senior Construction Resident Inspector performed a detailed investig-ation and discovered that numerous heats of ASME Section III pipe were stored outdoors for extended periods of time and were subject to corrosion.
Commonwealth Edison had received the following heats of safety-related SA-106GR-B pipe in 1977:
Heat No. Size / Schedule Quantity KD6830 2" S/80 5,709 feet KD6751 2" S/80 55,000 feet 273088 2" S/160 1,509 feet HD7760, JD1571 1 1/2" S/80 54,390 feet HD7760 1 1/2" S/160 2,006 feet KD7115 1" S/80 59,145 feet KD7115 1" S/160 3,014 feet JD1570 3/4" S/80 45,086 feet KD6830 1/2" S/80 38,341 feet H07643 3/8" S/80 73,150 feet TOTAL 337,350 feet i In an inspection report on April 9, 1979, the quality control department of the piping contractor rejected the pipe, detailed above, due to rust, scale, and failure to cap the ends of the pipe. The pipe being uncapped allowed water and snow to settle on the inside of the pipe. On April 23, 1979, the piping contractor's Quality Assurance Manager wrote this memo to the piping contractor Quality Control Supervisor:
"It is my recommendation that all the two inch and under pipe on the east side of the railroad tracks outside of the Phillips, Getschow i
building be pickled to remove the extensive rust and scale buildup that l occured during storage."
The Quality Control Supervisor replied on April 22, 1979, in memo form, stating:
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ESC 4.G-2.
"Since CECO has ordered and purchased this pipe, your recommendation has been forwarded through P.G.Co. Engineering Department to Ceco for their disposition and resolution." '
No action was taken by Commonwealth Edison or Phillips Getschow Company, the piping contractor, until May 5, 1981 when Phillips Getschow Company initiated Nonconformance Report Number 569. The nonconformance stated that the pipe listed below was unacceptable due to rust:
Size Sch Spec & Grade Quantity Heat #
2" 80 SA-106 Gr8 47,850 FT KD 6751 i
2" 80 SA-106 GrB 888 FT KD 6830 2" 160 SA-106 GrB 1,550 FT 273088 1 1/2" 80 SA-106 GrB 36,483 FT HD 7760 1 1/2" 160 SA-106 GrB 1,702 FT HD 7760 1 1/2" 80 SA-106 Gr8 7,943 FT JD 1571 1" 80 SA-106 Gr8 45,402 FT KD 7115 3/4" 80 SA-106 GrB 41,860 FT JD 1570 1/2" 80 SA-106.GrB 31,472 FT KD 6830 3/8" 80 SA-106 Gr8 77,064 FT HD 7643 TOTAL - 292,164 FT On May 17, 1981 and July 9,1981, Commonwealth Edison, on Purchase Order Numbers 730091 and 254379 respectively, sent the following SA-106 GrB, safety-related pipe to the H. H. Howard Corporation in Chicago, Illinois to be cleaned:
Heat No. Size / Schedule Quantity KD 6751 2" S/80 45,878 feet 273088 2" S/160 876 feet JD 1571, HD 7760 1 1/2" S/80 45,423 feet HD 7760 1 1/2" S/160 1,554 feet KD 7115 1" S/80 44,758 feet JD 1570 3/4" S/80 35,514 feet KD 6830 1/2" S/80 27,940 feet HD 7643 3/8" S/80 3,329 feet KD 7115 1" S/80 1,472 feet TOTAL - 206,744 feet The purchase orders stated the method to be used in cleaning the pipe which included:
. Soak in bath of caustic soda at 160 degrees F until mill coating is removed.
. Submerge pipe in 10 percent sulphuric acid at 160 - 180 degrees F to remove all scale and oxidation.
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. Clear water rinse.
. Submerge into wyandate #6 metal cleaner at 160 degrees F. -
. Air dry and inspect to make sure all scale and oxidation is removed. <
. Cover the ends of each bundle'with visqueen covering.
Examination of the purchase orders revealed:
- a. The vendor was not an approved bidder as required by the Conronwealth Edison Quality Assurance Manual which states in part in Q. P. No. 4-1, Request for Bid, Proposal Evaluation and Recomendation: " Quality
. Assurance shall verify that necessary technical and quality requirements are included, the proposed bidders are acceptable by verifying they are on the Approved Bidders List and the procurement is being made from the plant location for which the Quality Assurance Program is approved."
Approval of a vendor documents that the vendor has an approved quality assurance program and is capable of supplying products or services in accordance with standards required for the nuclear industry.
- b. The purchase orders were not reviewed and accepted by the Quality Assurance Department, which is required to be done by the Comonwealth Edison, Quality Assurance Manual in Q. P. No. 4-1. Quality Assurance could not, therefore, assure that the necessary technical and quality requirements were included in the purchase orders. There were no references in the purchase orders to Quality Assurance program require-ments such as 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes. 10 CFR 50, Appendix B, states in part in Criterion IV:
"To the extent necessary, procurement documents shall require contractors or subcontractors to provide a Quality Assurance program consistent with the pertinent provisions of this appendix."
Items a and b above are in' violation of 10 CFR 50, Appendix B, Criterion V, Failure'to Follow Procedures. (456/84-17-01; 457/84-17-01)
Sumart. jng the chronolo'gy of events:
. Phillips Getschow Co. rejected on April 9, 1979, 337,350 feet of pipe due to rust.
. No action was taken until May 5,1981, when Phillips Getschow Co.
identified on Nonconformance Report No. 569 a total of 292.164 feet of unacceptable pipe due to rust, and dispositioned the 292,164 feet to be cleaned.
. Purchase Order Number 730091, placed on May 17, 1981, and Purchase Order Number 254379, placed on July 9, 1981, provided for the cleaning of only 206,744 feet of pipe.
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L y (.. qi - S The investigation by the Senior Construction Resident revealed, as evidenced
, by the above dates, that Phillips Getschow Co. and Comonwealth Edison Company did not correct the rusted pipe condition in a timely manner. Further-more, the licensee did not prevent the rusted pipe from being withdrawn from storage areas and installed in safety-related systems. Not only was heat number KD 6751, 2" S/80, installed,in safety-related systems as stated in the 10 CFR 50.55(e) report, but numerous other heats of pipe, identified as being in a rusted condition, were withdrawn and installed. For example, 200 feet of heat number KD 680,1/?" S/80 pipe was withdrawn for installation on February 16, 1981 for the essential service water system and another 200 feet was withdrawn on March 3,1981 for the same safety-related system.
The pipe identified on April 9, 1979 was not placed on hold to prevent with-drawal and installation.
Since 337,350 feet was identified as being in a rusted condition and only 206,744 feet was cleaned, it is apparent that a significant amount of pipe has been installed, some of which is installed in safety-related systems.
Failure to control the rusted pipe is in violation of 10 CFR 50, Appendix B.
Criterion XV and failure to correct the deficient condition is in violation of 10 CFR 50, Appendix B, Criterion XVI. (456/84-17-02; 457/84-17-02)
Phillips Getschow Company Nonconfomance Reports Numbers 1294, 1524, 1525, and 1611 written on December 7, 1983, May 17, 1984, May 17, 1984, and June 13, 1984 respectively, identified 2" S/80 pipe, Heat No. KD 6751, with ribbon groove indications that caused the pipe to be rejectable for minimum wall violations. Recent Comonwealth Edison analysis by their System Material Analysis Department stated that the pipe, (Heat KD 6751), experienced metal loss and pitting due to one or more of the following conditions:
. ribbon groove indications,
. outdoor storage, and
. overpickling(cleaningvendor).
All of the pipe rejected on April 9, 1979 was stored outdoors and 206,744 feet of numerous heats were pickled. The Senior Construction Resident met with Comonwealth Edison representatives on August 20, 1984 and requested the licensee, to address, the following question:
. What evidence exists to assure that the heats, other than KD 6751, identified on April 9,1979, do not have minimum wall deficiencies" (Heat number KD 6751 was identified in the 10 CFR 50.55(e) report as having minimum wall violations.) A factor the licensee is taking into account is that apparently only heat number KD 6751 had ribbon groove indications which may have contributed to the minimum wall deficiency.
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N. i, .(s- L This question will remain an open item (456/84-17-03; 457/84-17-03). The .
licensee needs to determine if the rusted condition is significant in rela-tion to pitting and minimum wall violations for all the heats identified on April 9, 1979, and that the worst case wall thickness degradation can be
~or has been identified and analyzed for acceptability. At the close of the inspection the licensee believed that heat number KD 6751 contained pipe that failed to meet minimum wall thickness.
A positive factor is that although ASME and ASTM minimum wall is 12 1/27 below nominal, many of the piping systems are overdesigned to allow wall reduction significantly below the 12 1/2% figure. This overdesign is being analy.ed by the licensee and will be a factor in determining deficiency significance.
During other plant tours, the NRC inspectors noticed that the flange bolt-ups of the piping contractor were heavily rusted around the thread areas of the bolts. In addition, some of the essential service water flange bolt-ups were noted to have missing bolts and inadequate thread engagement. The Senior Construction Resident Inspector discussed these issues with the piping contractor's Quality Control supervisor and construction manager. The inspector learned that the piping contractor was aware of past bolting docu-mentation deficiencies and a retro-fit program was in the process of being submitted to Connonwealth Edison that would address documentation deficiencies and would reconnend a visual retro-fit program to identify the type of findings existing in the essential service water system. Pending licensee evaluation and resolution with regard to flange bolting acceptability, this issue will remain open (456/84-17-04; 457/84-17-04). The present system of control by the piping contractor is adequate to assure correct bolt-ups.
- 3. Items Reported Pursuant to 10 CFR 50.55(e)
The inspector examined the licensee's corrective actions relative to the deficiencies listed below:
(Closed) 456/83-06; 457/83-06: E1cen Metal Products supplied spring hangers with a carbon content in excess of the applicable ASME B&PV Code,Section III, Subsection NF limit. Replacement spring har.gers were supplied for those
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hangers which did not meet the ASME Code. An evaluation and analysis of the 2 balance of the variable spring hangers concluded that the hangers would meet the Load Capacity Data Sheet Specification and therefore are acceptable for i
use.
(0 pen)456/82-10;457/82-10: On November 19, 1982, a deficiency was reported
! regarding missing inspection records for structural bolted and welded connec-tions. An updated report on May 7, 1984 stated in part:
"The deficiency is limited to G. K. Newberg's installation of blockwall columns and miscellaneous structural steel in the Auxiliary Building.
!. A continued review of the records for bolted and welded inspection i
reports is being performed during the progress of the inspection program.
l This continual review of records has identified a revised total of 1,282 weld connections of 2,028 total and 484 bolted connections of 825 total
! with missing inspection reports.
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Euf 6 6 -3 i U. S. NUCLEAR REGULATORY COMMISSION REGION III -
Report No. 50-456/84-21(DRP); 50-457/84-20(DRP) i 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: Br,aidwood 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 .,0zyhulz Approved By: . L. k Projects Section 1A hief lIflk (9 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; preoperational test procedure reviews; preoperational test performance; radio-graphic incident; cleanliness inspections of piping and safety-related components; and design changes to reactor coolant pump lateral supports. The inspection consisted of 233 inspector-hours onsite by two NRC inspectors including 28 inspector-hours onsite during offshifts.
Results: Of the twelve areas inspected no items of no'ncoepliance 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 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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i 2. Licensee Action on Previously Identified Items i
l a. Violations
- 3 (Closed) 456/84-17-01; 457/84-17-01: Small bore piping was chemically '
cleaned by a vendor not on the approved bidders list. Subsequently, j a 10 CFR Part 50.55(e) report, 84-10, was reported to the NRC. The ,
l effect that the chemically cleaning process had on the pipe will be r analyzed and tracked by the Part 50.55(e) report. Additional procure- '
- ment reviews will be performed by quality assurance supervisors to l preclude unapproved vendors from performing services on safety-related I i material and to ensure adequate quality provisions are included in j future procurement documents.
(Open)'456/84-17-02; 457/84-17-02: Failure to correct a nonconfore- !
j ing condition concerning 337,350 feet of pipe. The quality control I j department of the piping contractor rejected the pipe due to the rust I and scale conditions of the pipe but failed to place the pipe on hold
) to prevent installation. The licensee presented this item to the :
j Senior Construction Resident for closure, based on the formulation of '
j a program to analyze the pipe for minimal wall deficiencies and the r j submittal of the potential minimal wall, 10 CFR 50.55(e) Report 84-10.
j This ites will not be closed until the program is completed and the ;
{ adequacy of corrective action can be assessed by the NRC.
J (Closed) 456/84-07-02(a); 457/84-07-02(a): Prospective electrical i r '
Quality Control inspector training consisted of a Familiarization
- I Los which identified specific codes and procedures to be read. Dis-j .
.cussion.with .L.~ K. Coastock's QA department revealed that there was no formal system for identifying required ret. ding fr a specific 1 i inspection activity. Corrective action by L. K. Comstock included the implementation of Procedure 4.2.3, Revision C, " Qualification j ;
! Classification and Training of QC Personnel". This procedure identi-fios a formal system for identifying and performing the required l '
reading for each area of inspector certification (i.e. welding, )
! receipt inspection, cable tray, etc.). The procedure became effective l on August 14, 1984. Six L. K. Coastock inspector files were reviewed j which d' ocumented that the required reading was completed by each j inspector in accordance with Procedure 4.2.3.
I i j b. Unresolved Ites (Closed) 456/83-10-04; 457/83-10-04: The licensee did not require I the verification / recording of piping (instrument) heat numbers. This !
I ites was identified in Inspection Reports No. 456/83-09; 457/83 09, j
! and will be tracked by identification Nos. 456/83 09-04a, 457/83 l
! 04a and 456/43-09-04b, 457/83-09-04b. Inforcement action is pending :
! on this issue as a result of NRC identified concerns documented in !
l Inspection Reports No. 456/83-09; 457/83-09. I l
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SUBCONTENTION 6.I ,
Rorem QA Subcontention 6.I, as a@nitted in this proceeding, states as follows:
- 6. Contrary to Criterion V, " Instructions, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Comonwealth Edisdn 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.
I. Material installed for the pipe whip restraint plate was not of proper specifications.
(InspectionReport84-09, Exhibit 22.)
In its Motion for Sumary Disposition, Applicant acknowledges incorrect material usage in a pipe whip restraint. Applicant's Motion 6.I at 2. Applicant contends that prior to the identification of the item by NRC in an inspection conducted from May 1, 1984 to June 4, 1984, the item of noncompliance which forms the basis for Subcontention 6.I was identified by the Phillips Getschow in the course of a 100f, of all pipe whip restraint documentation data packs review and w&s described in a log maintained to record the results of that review .
for later documentation in an NCR'. Applicant's 6.! Motion' at 3, 6.
Applicant asserts that the contractor, Phillips Getschow, had a procedure governing the use of material in pipe whip restraints and that the contractor identified discrepancies in the implementation of that program and promptly and adequately remedied them. Applicant's Motion at 3, 7.
Applicant contends that the facts demonstrate that an effective quality assurance program to assure that work is prescribed by documented procedures existed and that nonconforming conditions were identified and properly dispositioned. Applicant's Motion 6.! at 6-8. Applicant
contends that it is entitled to sunnary disposition on this item of ,
intervenors's quality assurance contention as a matter of law.
Applicant's Motion 6.I' at 8. The Staff agrees.
The incorrect material usage for reactor coolant whip restraint plate 1 WR-RC1-6, the subject of this subcontention, was identified by Region III NRC Inspection R. D. Schulz during a documentation review of pipe whip restraints and is documented in NRC Inspection Report Nos. 456/84-09 and 457/84-09. Ex. 6.!-2. Affidavit of Robert D. Schulz In Support of NRC Staff's Response to Applicant's Motion for Sunnary Disposition of Rorem QA Subcontention 6.I at 15 [ hereinafter Schulz Affidavit 6.I].
At the time of Mr. Schulz's documentation review, the piping contractor, Phillips Getschow, was in the precess of corpleting a review of all whip restraint material. Schulz Affidavit 6.I at 16. The Phillips Getschow review was initiated as a result of an audit conducted by Applicant in January 1984, which had identified another whip restraint material deficiency. M. At the time of the NRC inspection in May 1984,
.the piping contractor had not yet documented the results of its review in a nonconformance report or corrected the deficiency relating to pipe whip restraint plate IWR-RCI-6. Consequently, a notice of violation for reactor coolant whip restraint plate IWR-RCI-6 was issued by the NRC Staff. M.;seealso,Ex.6.I-2.
Mr. Schulz verified that the Applicant initiated corrective actions in response to the notice of violation. Schulz Affidavit 6.I at 1 7.
l These corrective actions included documentation of the installed material i
for all safety-related whip restraints through contractor inspection.
M. Nonconforming conditions were properly documented in nonconformance ,
reports. M. The design engineer determined whether nonconforming whip restraint material should be removed and replaced with the proper material or accepted as installed. M.
Mr. Schulz verified that the Applicant had implemented additional corrective actions to preclude further noncompliances which included (f) documented approval by the contractor's engineering organization prior to allowing material substitutions and (ii) quality control verification of correct material installation. Schulz Affidavit 6.I at 1 8.
After verifying that reactor coolant whip restraint plate 1WR-RCI-6 was replaced per Field Change Order No. IRC-7592 with the correct material, and that an audit was performed by the piping contractor which identified and properly dispositioned six other material deficiencies, Mr. Schulz closed this item in Inspection Report Nos. 456/85-15 and 457/85-16. Since all whip restraint material was audited by the piping contractor and nonconforming conditions were identified and properly
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dispositioned, Mr. Schulz detennined that Applicant's whip restraint material usage does not pose any safety problem. This item of nonconformance does not represent a significant breakdown of the QA/QC Programs of Connonwealth Edison or Phillips Getschow. Schulz Affidavit 6.I at 1 9. 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, and Applicant is entitled to a favorable decision on this subcontention as a matter of law. The
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Staff concludes based on the discussion above, that Applicant's Motion ,
for Sununary Disposition of Subcontention 6.I should be granted.
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