ML20214C580
| ML20214C580 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210188 | |
| Download: ML20214C580 (16) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEhSING BOARD In the Matter of
)
)
C0f940NWEALTH EDISON COMPANY
)
Docket Nos.
50-456
)
50-457 (Braidwood Station, Units 1 and 2
)
AFFIDAVIT OF RONALD N. GARDNER IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION OF ROREM QA SUBCONTENTION 12.J I, Ronald N. Gardner, being duly sworn, aver and state:
s 1.
I am employed by the U.S. Nuclear Regulatory Comission, e
Region III, 799 Roosevelt Rd., Glen Ellyn, IL 60137 as Project Manager for the Kewaunee, Point Beach, and Prairie Island facilities in Branch 2,
's, DRP. A copy of my professional qualifications is attached hereto as Exhibit 12.J-1.
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s 2.
Prior to becoming Project Manager, I was the NRC inspector a'ssigned to follow the implementation of the Braidwood Construction
.y Assessment Program' (BCAP).. BCAP is a program of inspections and reviews undertaken by the licensee in response to various concerns regarding the overall quality of construction of the Braidwood Station.
3.
The BCAP was comprised of three elements.
The first element, a
the Construction Sample Reinspection (CSR), consists of a review and i
1 reinspection of a sample of the complettd construction work.
The second i
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element, the Reverification of Procedures to Specification Requirements (RPSR), consists of c review of current installation and inspection procedures which govern ongoing and future safety-related construction i
8602210100 86021s PDR ADOCK 05000456 G
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work. The third element of BCAP, the Review of Significant Corrective Action Programs (RSCAP), consists of a review of the implementation, methodologies, and resulting documentation associated with the significant corrective action programs which resulted frcm previously identified deficiencies.
4.
My duties in following the BCAP included:
the performance of inspections and' investigations of BCAP activities to assure that_the program was being conducted in accordance with regulatory requirements and licensee commitments including recomendations for any appropriate enforcement action, action as liaison between NRC staff personnel and senior licensee management in BCAP and escalated enforcement matters, and preparation of evaluation of the BCAP for the NRC SALP report.
5.
The purpose of this Affidavit is to support the NRC Staff's Response to Applicant's Motion for Sumary Disposition of Rorem QA Subcontention 12.J.
This subcontention states:
12.
Contrary to Criterion XVI, " Corrective Action," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, 4
and nonconformances are properly identified and corrected. And in the case of significant conditions adverse to quality, Applicant failed to ensure that the cause of the condition is determined and corrective action taken to preclude repetition.
J.
In two areas, supports / restraints and piping runs, deficiencies were identified by the NRC CAT that were not identified by the BCAP inspectors.
On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in
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areas of supports / restraints and piping runs.
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6.
In preparing this Affidavit, I reviewed the following documents:
a.
Applicant's submitted " Material Facts As to Which There is No Genuine Issue to be Heard" with regard to Subcontention 12.J; b.
" Affidavit of Narinder N. Kaushal (on Rorem QA Subcontention 12.J);"
c.
" Affidavit of Edward Michael Shevlin (on Rorem QA Subcontention 12.J);"
d.
" Affidavit of Neil P. Smith (on Rorem QA Subcontention 12.J);"
e.
BCAP QA Surveillance Report No. BQA5-IV-259; and f.
BCAP QA Document (08678);
g.
NRC Inspection Report Nos. 50-456/85002 and 50-457/85002 (pertinent sections attached hereto as Exhibit 12.J-2) 7.
The need for an improved inspection effort in the areas of pipe supports / restraints and runs was identified during the Construction Appraisal Team (CAT) inspection of the Braidwood facility conducted between December 10-20, 1984 and January 7-18, 1985. An effort was made by the CAT to evaluate the then ongoing BCAP, See CAT Inspection Report Nos. 50-456/84-44 and 50-457/84-40, pertinent portions attached hereto as Exhibit 12.J-3 at A-1.
8.
In addition to the aforementioned CAT inspection, on January 16, 1985, I witnessed the overinspections of a concrete placement and observed the following:
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An embedded plate was observed which had a visible partial a.
identification number which did not match the vendor drawing for that plate.
This embedded plate was not identified as an observation by BCAP inspectors.
b.
Two construction joints were observed which did not appear on design drawings. These construction joints were not identified as observations by BCAP inspectors.
c.
An embedded plate was observed which had no visible identification numbers. The plate was accepted by BCAP inspectors.
d.
Two embedded plates were observed which had visible identification numbers which were identified as not verifiable by BCAP inspectors.
9.
On January 23, 1985, during the overinspection of electrical conduit hangers, I observed:
a.
A conduit supported by the conduit hanger was not the conduit identified on the pertinent S&L drawing.
This was not identified by the BCAP inspector; b.
Two attributes on the reinspection checklist were documented as "N/A" by the BCAP inspector.
These attributes were applicable and should have been reinspected; c.
One attribute was documented as accepted by the BCAP inspector which was not applicable to the hanger. This attribute should have been documented as "N/A";
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d.
One attribute on the reinspection checklist was documented as "N/A" by the BCAP inspector. This attribute was applicable and should have been reinspected; e.
Two attributes on the reinspection checklist were documented as acceptable by the BCAP inspector which were not applicable to the subject hanger. These attributes should have been documented as "N/A"; and f.
Required back-plates for one of the subject hangers were not installed.. This was not identified by the BCAP inspector.
10.
The aforementioned overinspections of the electrical conduit hangers and concrete placement created a concern on my part that BCAP reinspections were not adequately identifying construction deficiencies.
This concern was reinforced by the CAT finding regarding BCAP reinspection deficiencies ir. 'ie area of mechanical pipe supports.
- 11. As a result of the CAT inspections and a meeting I had with the applicant's BCAP Director to discuss the need for 3sgnificant actions to strengthen the BCAP reinspection effort, Applicant initiated the following corrective actions:
a.
The Applicant performed a partial repeat reinspection of 160 previously ~einspected mechanical pipe support; r
b.
BCAP instructions were revised; and c.
Additional training was provided to BCAP inspectors.
- 12. These corrective actions adequately address the CAT findings in my view. Subsequent inspections of BCAP inspector performance in these areas provide further assurance that the BCAP inspection effort has been
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i satisfactory. This item will be closed in the final BCAP inspection report expected to be issued in February 1986. Hence, with regard to Subcontention 12.J, BCAP inspections efforts were in fact 1
improved in the areas of pipe supports / restraints and pipe runs.
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Ronald N. Gardner Sworn and subscribed before me this I W day of February, 1986 w - k.*-
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Notary Public
?ACasida2Egirss!!ar.27,lS33 My Comission expires:
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Professional Qualifications RONALD N. GARDNER ORGANIZATION:
U.S. Nuclear Regulatory Commission, Region III TITLE:
Project Inspector, Division of Reactor Projects BIRTH DATE:
June 19, 1945 EDUCATION:
1968 - 1970, Thomas Nelson Community College 1970 - 1972, Virginia Polytechnic Institute, B.S.
in Electrical Engineering 1975, Department of the Navy, Ship Superintendent School (Nuclear)
EXPERIENCE:
July 1, 1985 to Project Inspector - NRC - Maintaining status of Present operational and regulatory performance of operating reactors.
August 1984 to Project Manager - NRC - Manages and coordinates July 1, 1985 inspections / investigations of BCAP activities to assure that the program is being conducted in accordance with regulatory requirements and licensee commitmer.ts.
October 1982 to Project Manager - NRC - Coordinate licensing August 1984 activities and perform inspections on reactors under construction (Office of Special Cases).
October 1980 to Electrical Inspector - NRC - Perform electrical October 1982 inspe,tions on reactors under construction.
1977 to 1980 Electrical Engineer - Daniel Construction Company -
Responsible for systems completion and cable terminations on nuclear plants under construction.
1975 to 1977 Electrical Engineer - Norfolk Naval Shipyard -
Responsible for timely overhaul of Nuclear Submarines.
1972 to 1975 Electrical Test Engineer - Newport News Shipyard -
Responsible for testing of electrical systems on Nuclear Surface Ships.
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U.S. NUCLEAR REGULATORY COMISSION REGION III Reports No. 50-456/85-02(DRP);50-457/85-02(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Connonwealth 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: January 2 through February 1, 1985 Inspectors:
R. N. Gardner R. B. Landsman k)db, L" 4/A2/#[
Approved By:
W. Forney, af Projects Section IA Dat(
Inspection Summary Inspection on January 2 through February 1. 1985 (Reports No. 50-456/85-02(DRP);
50-457/85-02(DRP))Special, announced safety inspection of the Braidwood Con-Areas Inspected:
structionAssessmentProgram(BCAP)inregardstolicenseeactiononpreviously identified items, Construction Sample Reinspection (CSR) Reinspection Checklists, CSR Documentation Review Checklists, S&L evaluation of BCAP discrepancies CSR reinspecticn activities, and Review of Procedures to Specification Requirements (RPSR) activities. The inspection consisted of 165 inspector-hours onsite by two NRC inspectors.
Results: No items of noncompliance or deviations were identified.
I
-n
6 s2.7-2,p 2ep3 inspector reviewed the QC inspection procedure for cable terminations and was unable to ascertain where the purported flex fitting inspection was delineated in the procedure.
The inspector discussed the adequacy of the S&L discrepancy review and evaluation with the licensee. This is an unresolved item (50-456/85-02-02;50-457/85-02-02).-
6.
CSR Reinspection Activities a.
On January 16, 1985, the inspector witnessed the overinspection of a concrete placement. The overinspection was being performed by an The concrete Evaluation Research Corporation (ERC) inspector.
placement had previously been reinspected by the BCAP taskforce.
The reinspection package was numbered CSR-I-S-01-120. During the overinspection, the following was observed:
l An embedded plate was observed which had a visible partial (1) identification number which did not match the vendor drawing for that plate. This embedded plate was not identified as an observation by BCAP inspectors.
i Two construction joints were observed which did not appear on (2)
These construction joints were not identified design drawings.
as observations by BCAP inspectors.
(3) An embedded plate was observed which had no visible identification nuders. The plate was accepted by BCAP inspectors.
Two embedded plates were observed which had visible (4) identification numers which were identified as not verifiable by BCAP inspectors.
The above reinspection deficiencies were subsequently documented in ERC observation 010.
On January 23, 1985, the inspector, accompanied by an ERC inspector, b.
performed an overinspection of electrical con:luit hanger CC-125.
The The hanger was previously reinspected by the BCAP taskforce.
reinspection package was numbered CSR-I-E-COH-20.. During the overinspection, the following was observed:
(1) A conduit supported by the conduit hanger was not the conduit identified on the pertinent S&L drawing. This was not identified by the SCAP inspector.
Two attributes on the reinspection checklist were documented as (2)
These attributes were applicable N/A by the BCAP inspector.
and should have been reinspected.
1 6
G. l 2. 7 - 2, p S cj 3 (3) One attribute was documented as accepted by the BCAP inspector which was not applicable to the hanger. This attribute should have been documented as N/A.
The above reinspection deficiencies were subsequently documented in ERC observation 011.
c.
On January 23, 1985, the inspector, accompanied by an ERC inspector, performed an overinspection of electrical conduit hanger CC-512.
The The hanger was previously reinspected by the BCAP taskforce.
reinspection package was numbered CSR-1-E-COH-12.
During the overinspection, the following was observed:
(1) One attribute on the reinspection checklist was documented as N/A by the BCAP inspector. This attribute was applicable and should have been reinspected.
(2) Two attributas on the reinspection checklist were documented as acceptable by the BCAP inspector which were not applicable to the subject hanger. These attributes should have been documented as N/A.
(3) Required back-plates for the subject hanger were not installed.
This was not identified by the BCAP inspector.
The above reinspection deficiencies were subsequently documented in ERC observation 011.
The aforementioned overinspections of electrical conduit hangers and the overinspection of the concrete placement created a concern that BCAP reinspections were not adequately identifying construction deficiencies.
This concern was reinforced.by the Construction Appraisal Team (CI.T).
findings regarding BCAP reinspection deficiencies in the area of mechanical pipe supports.
On January 23, 1985, the inspector met with the BCAP Director to discuss the need.for significant actions to address the issue of BCAP reinspection deficiencies. Subsequent to that discussion the licensee issued BCAP memorandum #546 implementing a midpoint look into the CSR reinspection program.
Reinspections were suspended until written authorization was provided to allow resumption. As a result of the identified reinspection deficiencies, the licensee has initiated a program which involves the partial repeat reinspection of 160 previously l
reinspected mechanical pipe supports, the assessment of the need to repeat reinspections in other BCAP populations, the assessment of additional training requirements, and the assessment of the need to I
revise reinspection checklists and instructions. Pending a review of the licensee's actions to resolve BCAP reinspection deficiencies, this is an unresolveditem(50-456/85-02-03;50-457/85-02-03).
i
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ExH6 T 12..J-3 UNITED STATES NUCLEAR REGULATORY C0f04ISSION 0FFICE OF INSPECTION AND ENFORCEMENT DIVISION 0F INSPECTION PROGRAMS REACTOR CONSTRUCTION PROGRAMS BRANCH Report No.:
50-456/50-457/84-44, 84-40 Docket No.:
50-456, 50-457 Applicant:
Commonwealth Edison Company Facility Mame:
Braidwood Inspection At:
Braidwood,' Illinois Inspection Conducted:
December 10-20, 1984 and January 7-18, 1985 Inspectors:
/
P. Keshishian, Sr. Reactor Construction Engineer Utte Signed To Leader w 1_.e.
M'W 4//flW sG. 8. Geefgiev, Sr. Reinctor ConWtruction Engineer Dite Tigned fo*ve=Y Ab -
W/f KIR. Hooks, Reactor Construction Engineer Date FIgned cQf/f//f f
~W.
ropp, Reactor Inspection (Region III)
Dite Signed ff^
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anfV)fff.1~
T. K. McLellan, Reactor Construction Engineer Date' Signed 2//S N y Nemoto, Reactor onstruction Engineer Date Signed xf4 McW a
' 5. R.'5tein,~ Reactor Construction Engineer Date Signed Consultants:
R. M. Compton, D. C. Ford, J. 8. McCormack.
O. P. Mallon, W. S. Marini, E. Y. Martindale, A.
iller, R. E. Serb and W. J. Sparko, Jr.
Approved By:
/
Rotfert F. Heishman, Chief Dhte' Signed Reactor Construction Programs Branch l
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APPENDIX A EXECUTIVE SUMARY An announced NRC Construction Appraisal Teas (CAT) inspection was conducted at Commonwealth Edison company's (Ceco) Braidwood Station during the perioc December 10-20, 1984 and January 7-18, 1985.
Overall Conclusions Hardware, Project Management and doctmentation for construction activities were generally in accordance with requirements and licensee commiitments.
the NRC CAT did identify a n' umber of construction program weaknesses thatHowever, require increased management attention.
These are:
1.
The effectiveness of first level quality control (QC) inspection activi-J ties needs to be improved, particularly in the pipe support / restraint anc welding areas.
2.
A large nimber of final inspection activities are being includ&d in a final walkdown, when greater difficulty wfl1 be encountered in identifying deficiencies because of interferences, accessibility and the pressure of schedule.
3.
The identification and resolution of cabis tray anc conduit electri-cal separation deficiencies is inadequate.
)
4.
An excessive number of incidents of damage to installed equipment has been caused by current construction activities.
The foregoing identified weaknesses require additional management attention to assure that completed installations meet design requirements.
An effort was made by the NRC CAT to evaluate the ongoing Braidwood Construc-wa tion Assessment Program (BCAP).
The schedule for the BCAP inspection program l
L was such that only limited hardware samples were available for NRC CAT over-inspection.
It was possible to overinspect a very small sample of hardware in the areas of supports / restraints, piping runs, WAC supports and ducts for welding, HVAC ducts for configuration and conduit runs.
In four of the six areas that were overinspected, there was general agreement between BCAP and NRC CAT findings; in W.N..,
supports / restraints and piping runs, deficien-cies were identified by the NRC CAT that were not identified by the BCAP inspectors.
On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in the areas of supports / restraints and piping runs.
AREAS INSPECTED AND RESULTS Electrical and Instrimentation Construction The electrical and instrumentation samples inspected generally met the applicable design and construction requirements.
)
However, construction and inspection deficiencies were identified in several areas including several items which will require additional MRC review and analysis.
l a-5L.
$h R.S 3 (3) For restraint ICS0450025, angle iron beam stiffeners have been l
removed by Field Change Orders (FCO's), but the latest support drering revision ("D", issued 10/44) did not reflect renoval of stiffeners and showed a one inch thick cover plate on the wrong side of beam.
This installed and QC accepted support does not o
conform to the latest design documents.
(4) For IAB16018R, Advar.ced Engineering Change Notice (AECN) 15114 was issued in March 1984 to change the attachment location on a beam weld that had been incorrectly installed and accepted 5-3/8 inches beyond allowed tolerances in February 1984.
No NCR was written to doc uent the out of tolerance condition as required by site procedures.
See Section VII for a further discussion' of design change control activities.
Three QC accepted supports / restraints had been disassembled without the required authority or documentation to assure that necessary reinspection were performed.
Numerous instances of loose or missing fasteners were also observed.
These examples indicata a need for greater attention to the problem of altering counleted and accepted hardware.
Of the six supports / restraints that had undergone a previous inspection by the BCAP program, two were found to be installed as designed by both the NRC CAT and 8 CAP and one had deficiencies that were identified by both the NRC CAT and BCAP. Three of the supports / restraints were found to be installed with discrepant conditions not identified by the BCAP inspection.
On ISX06028R, BCAP did not note that the attachment to existing steel was approximately three inches out of tolarance.
In addition, the BCAP inspection did not note that an undersize pipe clamp and load bolt had been installed on this support.
The BCAP inspector did note on a material listing that the clamp was marked N3H rather than the 3HN marking indicated in the drawing Bill of Materials.
It is doubtful if a review of this discrepancy in marking of the catalogue number would have revealud that a wrong size clamp had been installed.
On 1C5040025, beam stiffeners shown on the latest design drawing were not installed and a cover plate not shown on the drawing was installed. The BCAP inspector did note, in the remarks column of the inspection report, that he was unable to identify if the stiffener was installed.
This may have been identified as a problem during the BCAP engineering review of the inspection report. On ICS030295, the BCAP inspection did not note that the
\\ attachment location along the supplementary steel wa tolerance by 2 1/2 inches and that four clip angles were smaller in size than specified on the drawing.
L-Another condition noted during the hardware inspection was a large number of supports / restraints in contact or close proximity to pipe or other structures.
Of special concern were several instances of snubbers binding against other structures (see Table III-3).
See Section 1I1.8.1 of the report for a further discussion of clearance violations.
III -
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SUBCONTENTION 13.B Subcontention 13.B, as admitted in this proceeding, states:
- 13. Contrary to criterion XVII, " Quality Assuranco Records," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that sufficient records were maintained to furnish evidence of activities affecting quality.
The records are to include at least the following:
results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.
Applicant has failed to make such records identifiable and retrievable.
.B.
Sargent & Lundy Engineers calculations which provided the original justification for the factor design methodology and magnitude were not retrievable. (Inspection Report 84-43/39, Exh. 19.)
The Staff agrees that this contention should be summarily dismissed.
As explained below, the incident described in Subcontention 13.B represents an isolated occurrence and is not indicative of a programmatic breakdown in Applicant's quality assurance program.
The incident giving rise to Subcontention 13.B was identified by Region III NRC Inspector J.W. Muffett during an inspection conducted to investigate the concerns rai' sed by an expert witness in the remanded
~
licensing hearings for the Byron Station facility.
See Affidavit of James W. Muffett In Support of NRC Staff's Response To Applicant's Motion For Summary Disposition of Rorem QA Subcontention 13.B at 15 (hereinafter "MuffettAffidavit").
During that inspection, NRC Inspector Muffett was informed by Sargent & Lundy (S&L), Applicant's architect-engineer, that calculations demonstrating the acceptability of the " phi factor method" used by S&L in connection with the design of structural steel pipe supports and restraints had been completed prior to October 5, 1981. See
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Muffett Affidavit at 15; Inspection Report Nos. 50-456/84043 and 50-457/84039 (attached as Ex. 13.B-2 to Muffett Affidavit). However, NRC Inspector Muffett was not able to ve.rify S&L's claim because S&L was unable to retrieve the original record of these calculations. Muffett Affidavit at 17; Ex. 13.B-2.
S&L's inability to retrieve the original phi factor calculations was deemed a violation of 10 C.F.R. Part 50, Appendix B, Criterion XVII. Muffett Affidavit at 16.
In its response to Inspection Report Nos. 50-456/84043 and 50-457/84039, Applicant undertook a number of. corrective actions to address this violation.
First, Applicant recreated the calculations supporting the phi factor methodology. Muffett Affidavit at 17. Next, Applicant evaluated the pipe supports installed at the Braidwood facility to make certain that they complied with the phi factor method. M.
Finally, S&L enhanced its ability to retain and retrieve technical support documents. M.
NRC Inspector Muffett reviewed and evaluated Applicant's proposed corrective action program and was satisfied that. those remedial measures l
were " sufficient to remedy the effects of the violation and render the possibility of recurrerice minimal." Muffett Affidavit at 18.
It was on the basis of Applicant's satisfactory implementation of the corrective I
actions described above that NRC Inspector Muffett closed this violation in Inspection Report Nos. 50-456/85040 and 50-457/85040 (attached as Ex. 13.B-4 to Muffett Affidavit).
NRC Inspector Muffett notes that the " violation that forms the basis of Rorem Subcontention 13.8 represents the only instance in which records for the design basis of safety-related items were not retrievable."
O
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Muffett Affidavit at 110.
This single occurrence does not establish a significant failure on the Applicant's part "to ensure that sufficient records [are] maintained to furnish evidence of activities affecting quality" as required by 10 C.F.R. Part 50, Appendix B, Criterion XVIII.
The violation identified in Subcontention 13.B has been remedied and there is no evidence of a recurrence.
Consequently, there is no genuine issue es to any material fact to be litigated regarding this subcontention and Applicant is entitled to a favorable decision on this subcontention as a matter of law. Accordingly, the Motion for Summary Disposition should be granted.
..