ML20214C583

Affidavit of JW Muffett Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 13.B.Supporting Documentation Encl

ML20214C583
Person / Time
Site:	Braidwood
Issue date:	02/13/1986
From:	Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
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ML20214C321	List: ML20214C317 ML20214C330 ML20214C334 ML20214C358 ML20214C380 ML20214C409 ML20214C439 ML20214C451 ML20214C468 ML20214C496 ML20214C514 ML20214C526 ML20214C552 ML20214C569 ML20214C580 ML20214C583 ML20214C596 ML20214C606 ML20214C628 ML20214C676
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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 JAMES W. MUFFETT IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF ROREM QA SUBCONTENTION 13.8 I, James W. Muffett, being duly sworn, depose and state as follows:

1. I am employed as a Reactor Inspector (Mechanical Engineer) by the U.S. Nuclear Regulatory Commission (NRC), Region III, 799 Roosevelt Rd, Glen Ellyn, IL 60137. I have been employed by the NRC in this capacity since August 1983. A copy of my Statement of Professional Qualifications is attached hereto as Exhibit 13.B-1 to this affidavit.

2. As a Reactor Inspector, I am responsible for reviewing the desig'n of and performing inspections of mechanical and structural components.

3. The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Summary Disposition of Rorem QA l

Subcontention 13.B. This subcontention states as follows:

13. Contrary to Criterion X VII, " Q uality Assurance 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 l to include at least the following: results of i reviews , ins pections , tests , au dits ,

j monitoring of work performance, and materials l

B602210192 860218 I PDR ADOCK 05000456 Q PDR i

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a nalyses. 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, E x h . 19. )

4. In preparing this Affidavit I reviewed the following materials:

a. Applicant's Statement of " Material Facts As To Which There Is No Genuine Issue To Be Heard;"

, b. Testimony of Kenneth T. Kostal (On Rorem Q.A.

Subcontention 13.B)

c. Inspection Report Nos. 50-456/84043 and 50-457/84039;

d. Applicant's Response to Inspection Report Nos. 50-456/84043 and 50-457/84039;

e. Inspection Report Nos. 50-456/85040 and 50-457/85040

5. I identified the violation upon which Rorem Subcontention 13.B is based. The violation was identified during an inspection conducted to address concerns raised by an expert witness in the remanded licensing hearing for the Byron Station. During this inspection, I was informed by Sargent & Lundy, Applicant's architect-engineer, that calculations demonstrating the acceptability of the " phi" factor methodology had been completed prior to October 5,1981. Phi or "0" factor methodology is a technique used in connection with the design of structural steel pipe supports and restraints.

6. I was unable to verify that Sargent & Lundy's calculations demonstrated the acceptability of the phi factor method for use in connection with the design of structural steel pipe supports and restraints because Sargent & Lundy was not able to retrieve the original

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records. T.he inability of Sargent & Lundy to retrieve the original phi ,

factor calculations was deemed a violation of 10 C.F.R. Part 50, Appendix B, Criterion XVII. The circumstances surrounding this violation are discussed more fully in Inspection Report Nos. 50-456/84043 and

, 50-457/84039, the pertinent portions of which are attached as Exhibit 12.B-2 to this Affidavit.

7. In its response to the Inspection Report (attached as Exhibit 13.B-3 to this Affidavit), Applicant proposed to take a number of corrective actions. These actions included: (i) recreating the original

calculations supporting the acceptability of the phi factor methodology;-

(ii) reviewing all installed pipe supports at the Braidwood facility to ensure compliance with S&L phi factor methodology; and (iii) enhancing S&L's ability to retain and retrieve technical support documentation.

8. I reviewed and evaluated Applicant's proposed corrective action I

plan and am satisfied that the proposed corrective actions, if l

implemented properly, are sufficient to remedy the effects of the violation and render the . possibility of recurrence minimal.

9. I verified the implementation of the corrective actions de:cribed in 1 8 of this Affidavit and on that basis closed this matter

in Inspection Report Nos. 50-456/85040 and 50-457/85040, the pertinent part of which is attached as Exhibit 13.B-4 to this Affidavit.

i 10. The violation that forms the basis of Rorem Subcontention 13.B represents the only instance in which records for the design basis of f

l safety-related items were not retrievable. For this reason, this l violation does not represent a significant breakdown in Applicant's quality f

l l .

h

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, assurance program. Consequently, I agree with Applicant that there is no .

genuine issue to be litigated regarding Rorem Subcontention 13.B.

%C James W. Muffett ,

Sworn and subscribed before me this i M day of February,1986

/, . t ._ h, k.u N. ,

Notary Public My Commission expires}di G N U I

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l Professional Qualifications .

JAMES W. MUFFETT Organization: Region III

Title:

ReactorInspector(Mechanical)

Birth Date: January 5, 1950 Education: B.S. Physics, Purdue University 1972 M.S. Mechanical Engineering University of Idaho 1978 Registration: Professional Engineer, Illinois, Indiana, Minnesota Experience: .

1983 - Present Reactor Inspector - Responsible for inspection of reactor under construction and in operation.

1981 - 1983 Encineering Manager - Managed mechanical design '

anc analysis group with staff of 20 (NuTech).

1980 - 1981 Product Engineer - Responsible for development of advanced design methods. (International Harvester) 1978 - 1980 Senior Engineer - Responsible for development and application of advanced design methods. (Cummins Engine Co., Inc.)

1915 - 1978 Grou) Leader.- Leader of piping analysis group

, whic) performed piping analysis for LOFT reactor at Idaho National Engineering Lab. (EG & G Idaho) 1972 - 1975 Stress Analyst - Performed piping stress analysis, support design and field interface duties at various

nuclear power stations. (Sargent & Lundy)

I l

i

/ g UNITED STATES I i -

P NUCLEAR REGULATORY COMMISSION

{ h REGION lil I 798 ROOSEVELT ROAD -

SLEN ELLYN. ILLINots 80137

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March 15, 1985 Docket No. 50-454 Docket No. 50-455 Docket No. 50-456 Docket No. 50-457 A l Commonwealth Edison Company ATTN: Mr. Cordell Reed l Vice President I Post Office Box 767 l Chicago, IL 60690 Gentlemen:

This refers to the special safety inspee. tion conducted by Messrs. J. W. Muffett, K. D. Ward, R. S. Love, J. A. Jacobson, and J. Schapker, of this office on September 24, 1984 through February 4,1985, of activities at Sargent & Lundy Engineers, Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 j authorized by NRC Operating License NPF-37, and NRC Construction Permits i

CPPR-131, CPPR-132, and CPPR-133. The inspection was conducted to review concerns expressed by an expert witness who appeared on behalf of the Inter-venors during the remanded Atomic Safety Licensing Board hearing for the Byron Station operating license.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures al.d representative records, observations, and interviews with personnel. The report also contains your responses to the questions asked by this office regarding the concerns.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.

A written response is required.

In addition to the noncompliances, a number of design practices were found to be in need of improvement. During the inspection appropriate corrective actions were taken by your architect engineer to effect the needed improve-ments in the design process. The positive attitude exhibited by you and your architect engineer toward the prompt resolution of all issues and the willingness to implement improvements in the design process are encouraging.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room.

l O

I

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Commonwealth Edison Company 2 '

The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980 PL 96-511.

~

Sincerely,

%-~g 1

P J. F. Streeter, Director Byron Project Division  !

Enclosures:

1. Appendix, Notice of Violation

2. Inspection Reports No. 50-454/84-71(DRS);

No. 50-455/84-49(DRS);

No. 50-456/84-43(DRS);

. No. 50-457/84-39(DRS) '

cc w/encis:

D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Station Superintendent DFB/ Document Control Desk (RIDS)

Resident Inspector, RIII'8yron -

. Resident Inspector, RIII

Braidwood Phyllis Dunton, Attorney .

! General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.

Diane Chavez DAARE/ SAFE W. Paton, ELD L. 01shan, NRR LPM M. Wallace, Project Manager B. Shamblin, Construction Superintendent J. F. Gudac, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent H. S. Taylor, Quality Assurance Division, S&L

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I Appendix I

, NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station Units 1 and 2 50-456; 50-457 As a result of the inspection conducted on September 24, 1984 through February 4,1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVII requires that records to furnish evidence of activities affecting quality be identifiable l and retrievable.

The Ceco Corporate Quality Assurance Manual and the Ceco Quality Assurance Procedures Manual commit to the above 10 CFR, Appendix B requirements in Section 17. The Ceco Corporate Quality Assurance Manual states, " Quality Assurance records will be stored in a i

predetermined location as necessary to meet the requirements of applicable standards, codes and regulatory agencies and shall be accessible to Edison." '

Contrary to the above, the Sargent & Lundy Engineers calculations which provided the original justification for the 5 factor design

, methodology and magnitude were not retrievable.

This is a Severity Level IV violation (Supplement II)

(454/84-71-01(DRS); 455/84-49-01(DRS); 456/84-43-01(DRS);

457/84-39-01(DRS)).

2. 10 CFR 50, Appendix B, Criterion III requires that design control i

measures include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled."

Ceco Quality Procedure Q.P. No. 3-1 requires that "... design

, requirements, including regulatory requirements, codes and standards be utilized in the development of specifications, l drawings, procedures, and instructions."

The AISC Steel Construction Manual (Section 1.8) committed to in the FSAR identifies the slenderness ratio (KL/r) for structural steel members as a controlled design parameter for compression members.

l

g j$.g.t Appendix 2 Contrary to the above, Ceco employed designs for safety-related HVAC duct supports based on Chapter E36.0, " Safety-Related HVAC Duct Supports," of S&L's Structural Standard Document which did not limit the slenderness ratio (KL/r) for ceiling mounted duct supports.

This is a Severity Level V violation (Supplement II)

(454/84-71-02(DRS); 455/84-49-02(DRS); 456/84-43-02(DRS);

457/84-39-02(DRS)).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) cor-rectivo action taken and the results achieved; (2) ccrrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

March 15, 1985 ~

Dated J. F. Streeter, Director Byron Project Division 9

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fl t3. 3-z-These walkdowns were completed in February 1984 for HVAC ducts and supports and in March 1984 for piping and pipe supports. Resolution of the potential ,

interactions identified from these walkdowns was completed in September 1984.

Limited clearance points identified in the final piping system walkdown are also being reviewed to confirm that the conclusions reached from the PI-BB-40 walkdowns are representative and applicable. This review will be complete'd by November 30, 1984.

NRC Review and Conclusion Recardina Concern B.2.jj Project Instruction PI-B8-40 provides an acceptable method for identifying and resolving potential interactions between non-safety related components and safety related components. The licensee's review of the limited clearance points identified in the final piping system walkdown of Byron. Unit 1, has been completed and the results confirmed that the conclusions reached from the PI-BB-40 walkdowns are representative and applicable.

Concern B.2.kk Section 37.2 gives no definitive statement that torsional stresses should be checked.

• Concern B.2.nm Section 37.2.1.g.1.8 ignores axial self weight. What is the magnitude of the load affecting members and connections?'

Concern B.2.nn Section 37.2.1.g.1.C does not require torsion analysis. What is the magnitude of load affecting members and connections?

Concern B.2.oo Section 37.2.1.g.2.B indicates axial self weight may be ignored. What is the magnitude of the load affecting members and connections?

Concern B.2.pp Section 37.2.1.g.2.C includes torsion. What was the logic for including I torsion here?

Concern B.2.co Section 37.2.1.g.3.A assumes all masses are lumped at the shear center.

Concern B.2.rr Section 37.2.1.g.3.8 indicates axial self weight may be ignored.

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l concern B.2.ss 4

Section 37.2.1.g.3.C indicates torsional analysis is not required. .

Concern 8.2.tt .

Section 37.2.1.g.4.A assumes all masses are luaped at shear center.

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l Section 37.2.1.g.4.B indicates that axial self weight may be ignored. i Section 37.2.1.g.4.C indicates that torsional analysis is not required.

Concern 8.2.uu Section 37.2.1.g.5 indicates exact analysis must be performed for loads greater than 20 kips. ,

Concern 8.2.vv Section 37.2.1.g.5. A assumes all masses are lumped at shear center.

. Section 37.2.1.g.5.B indicates axial self weight may be ignored.

! Section 37.2.1.g.5.C indicates torsional analysis not required.

concern B.2.ww Section 37.2.1.g.6.8 indicates axial self weight may be ignored.

Section 37.2.1.g.6.C indicates torsional analysis not required.

Concern B.2.xx Section 37.2.1.g.7. A assumes all masses are lumpea at shear center.

Licensee Response to Concerns B.2.kk and B.2.mm throuch B.2.xx l The items questioned in this concern are instructions to the engineers to -

describe what loads must be applied, and how they must be applied to various types of auxiliary steel for pipe supports.

l When performing a simplified analysis as described in these sections, an inter-action factor, 5, is used to implicitly account for the effects of eccentricities, axial stresses and torsional stresses that result from the seismic self-weight excitation of the component support steel. This interaction factor was derived by comparing the results of detailed analyses for a variety of common support configurations to the results of corresponding simplified anlyses to ensure that l the use of the interaction factor always yields conservative results. Certain strasses such as torsional stresses due to applied piping loads (Sections 37.2 and 37.2.1.e), torsional stresses due to spring cans which have relatively large 42

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l mass as compared to a rod hanger (Section 37.2.1.g.2.c) and all stresses on specific types of supports with loads greater than 20 kips (Section 37.2.1.g.5) cannot be implicitly included in the 5 factor, and thus must be explicitly '

accounted for in the design.

The sections discussed here give the engineer guidarH:e so that he understands when these items are accounted for by the 5 factor and when they are not. The use of this 5 factor permits a simpler and more reasonable structural analysis without compromising the integrity of the support. This simplified analysis does not ignore the axial stresses, torsional stresses, eccentricities, etc.,

rather it implicitly accounts for their effects through the use of a reduction factor.

t NRC Recuest for Additional Information on Concerns B.2.kk and B.2.mm throuch B.2.xx Please provide detailed engineering justification for the magnitude of the e factor.

Additional Licensee Information on Concerns B.2.kk and 8.2.mm through B.2.xx The e factor is an aid to be used by the engineer which permits a simpler and more reasonable structural analysis without compromising the integrity of the support.

• To derive the e factors, a study was performed in March 1982. This study consisted of a series of sample problems which represent a variety of bounding

! auxiliary support steel configurations and bounding loading conditions. The following parameters were considered in determining the bounding conditions:

a. auxiliary steel configuration and support conditions,

b. auxiliary steel size and shape,

c. span length,

d. load location,along the span, ,

e. load direction, and '

f. load magnitude.

The sample problems included actual pipe support drawings and hypothetical pipe supports. The range of the sample problems was judged to be broad enough to serve as a basis for the e factor.

Two separate analyses were performed for each sample problem. The first analysis used the simplified design procedures outlined in the Design Criteria.

The second analysis consisted of detailed manual calculations. In addition, the AUXSTL computer program, which performs a detailed analysis was also used 43

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3 for the second anal'ysis. The e factor is the stress interaction ratic from the simplified analysis divided by the stress interaction ratio from the detailed analysis.

>- The e factor accounts for all significant design items not explicitly included in the individual support design. These items include axial and torsional stresses due to,5mif-weight excitation of the auxiliary support steel and hardware components, the effects of eccentricities between the point of load application and the member shear center, and the effects of permissible

, construction tolerances and misalignments of the auxiliary support steel and I hanger component.

Additional Licensee Information on Concerns 8.2.kk and B.2.am through 8.2.xx On December 1, 1984, calculations were reconstructed to su5stantiate the "s" factors used in the simplified design process as described in the Project Design Criteria - DC-ST-03-BY/8R, Revision 8 Section 37.0.

What follows is a discussion of:

a. What the "s" factor is.

b. How the "s" factor was numerically quantified.

c. The bounding parameters involved in the selection of the "s" factors.

d. Tables 15.1 and 15.2 which summarize the "s" factors used and the sarple calculations performed to substantiate them.

e. Attachment 15.5 which is a reproduction of one of the calculations performed highlighted to show the elements

of design required by the Project Design Criteria.

What the e Factor Is The Project Design Criteria enumerates all the design requirements for auxiliary '

steel supports. In addition to the major ~ contribution of the actual applied pipe load, the effects of the following additive minor tolerances, eccentricities and member self-weight seismic excitation must be considered as specified in the Byron Project. Design Criteria Section and further clarified by reference to Figures 15.1, 15.2, 15.3A and 15.38.

37.1.1. Itam e.

105 lateral structural steel misalignment for simply supported W-shaped beams and double channels, and a 1% lateral structural steel misalignment for W-shaped cantiltver and knee brace brackets.

(See Figure 15.1) .

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h/$8 37.1.1. Item f.

0.5% vertical structural steel misalignment for simply supported

• W-shaped members subject to an axial load. (See Figure 15.1) 37.1.1. Item h.

6" tolerance for the location of the hanger component along the longitudinal axis of the support steel. (See Figure 15.1) 37.1.1. Item 1.

%" location tolerance for the attachment of a lug on W-shaped

! member flanges with respect to the center line of the web.

l (See Figure 15.1) ~

37.1.1. Item o.

2% hanger component displacement from its design position for all i loading cases. (See Figure 15.2) 37.1.1. Item b.

Self-weight OBE and SSE excitation of the auxiliary steel and conponent hardware in the three principal orthogonal directions.

The governing peak seismic excitation values, 2.0 g horizontal and 4.0 g vertical, have been used for all cases. (See Figures 15.3A and 15.38)

Item b. is a design requirement conservatively calculated by using the peak acceleration values (2.0 g horizontal and 4.0 g vertical).

Items, e., f., h., i., and g. are installation tolerances. That is, they do not change the applied piping load, but are effects on stress in auxiliary steel due to variation. in support installation. Their main effect is to introduce torsional stresses in the auxiliary support steel.

Prior to 1980, detailed design was manually performed to account for the major f applied loads and the minor tolerances listed above. This was a time consuming and laborious process. Therefore, a need arose to conservatively remove some of'the tedious elements of the hand calculation effort without neglecting their effect on the member design. Thus, the "S" factor was developed. Minor toler-ances and load effects which result in relatively low member stress were lumped together and were accounted for in the design by the use of the 5 factor. ,

This "9" factor is an allowable stress reduction factor introduced into the design process to account oA for minor load effects. Stresses due to major load effects such as the actual applied load are directly calculated and are not included in the 5 factor. This 5 factor is only intended for certain support configurations and member types as shown in Table 15.1. -

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All tolerances, items v. , f. , h. , i. , and g. are accounted for by this factor and in . item b. the effect of auxiliary steel self-weight acceleration and component hardware acceleration in the longitudinal direction of the member

• is included in the "s" factor.

This longitudinal effect was chosen since its contribution is very minor when compared to all other loadings since it amounts to a small percentage of loads compared to the member allowable load.

For detailed analysis as shown in the idealized support on Figure 15.3A, the l loads other than piping applied load (PA) act as follows: i

a. Auxiliary Steel member weight (WS) excited seismically in 3 directions, applied at the center of beam and midspan.

b. Hanger hardware (WH) - excited seismically in 3 directions, applied at the hardware pin point, e rom the centerline H

of the beam.

For simplified analysis as shown in the idealized support on Figure 15.38, all the loads are applied at the shear center of the beam. (Note: seismic excitation in the longitudinal direction.)

It is important to note that even for these minor load effects this " simplified" approach which uses a reduction factor yields conservative assigns compared to the detailed hand calculation procedure.

How The e Factor was Numerically Quantified The 5 factor is defined as the ratio of the design interaction ratio obtainad by the simplified calculation to the design interaction ratio obtained by a detailed calculation. In the form of an equation:

, , 1s, ,

Simplified Interaction Ratio

.I D Detailed In'eraction t Ratio The design interaction ratio, 1, is the ratio of the actual member stre.u, divided by the allowable member stress. Before the advent of the computer-ization of the design parameters, the simplified and detailed analyses were performed manually. The " Auxiliary Steel" program was developed in 1980 to aid in the preliminary selection of mechanical component support steel members.

This program considers all the design requirements of the detailed analysis as specified in the Byron' Project Design Criteria. To expedite the reverification of the 5 factors, the " Auxiliary Steel" program was used both for the simplified approach and the detailed approach.

Thus, for calculations performed on December 1, 1984, the e factor can be quantified by the ratio:

i .

46 l .

h 68. Design interaction obtained with the " Auxiliary Steel" program using the simplified Design Criteria and all

• applicable loads.

Design interaction obtained with the " Auxiliary Steel" program with each and every detailed requirement and all applicable loads.

The simplified and detailed calculation requirements are pictorially represented in Figures 15.3A and 15.38. Both figures show the actual support configuration and the idealized design condition locating the loads and the direction of loads to be considered.

To obtain the design interaction necessary to compute the "s" factors, certain parameters were co.nsidered in determining the bounding conditions used to select the piping support configurations. What follows is an identification of how those parameters were used in the selection process. A more detailed description will be discussed further with the introduction of Tebles 15.1 and 15.2 which summarize the results of the calculations performed on December 1, 1984.

Bounding Parameters in the Selection of the 9 Factors The bounding parameters are:

a. Auxiliary steel configuration and support conditions Support conditions can be said to bound a selection process if they are more critical, that is, produce greater stress levels than other support conditions. When the simplified design process was used manually, a frame was conservatively

, considered as being composed of simply supported and canti-l 1evered members without considering the continuity of the members. Thus, simply supported members and cantilevered ,

members are bounding support conditions over frame assem-blies since the redundancy of a frame allows redistribution of stresses over its multiple members. A simply supported or cantilevered member has no other members to sha're its stresses. Frame assemblies are bounded by other conditions since it'can be said that a frame is an extension of a simply supported C.cndition and two cantilevered conditions.

Therefore, the "s" factor of 0.75 is conservative when compared to the factors for simply supported and cantilevered members.

b. Auxiliary steel size and shape

1. The auxiliary steel sizes and shapes must be represent-ative of actual field requirements. The selection process involved choosing the most commonly used sizes and shapes.

47

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2. A size and shape selection can be said to bound a

, selection process if the more critically stressed size and shape is chosen. For example, once it has '

been determined what "5" factor is required for a ]

wide fisnge shape, a determination of a factor for i an angle shape is not required. Warping normal '

torsional stress added to the bending stresses is l

-- the primary reason for the factor used and this effect occurs in wide-flange shapes, but not in angle shapes. The consideration of the same tolerances produce torsional shear stresses in angle shapes that are not added to the bending stresses.

In addition, the wide variety of members selected are bounding torsional strength comparisons. Since the effect of the design requirements that the e factor ,

replac'es is primarily one of torsion, by comparing the strong axis strength to the torsional strength, one can determine bounding conditions on members.

Thus, a W8x31 strong axis strength to torsional

trength has a ratio of about 19. A W4x13 strong axis strength to torsional strength has a ratio of approximately 12. Therefore, the W8x31 is bounding over the W4x13.

c. Span length Representative lengths were selected. Auxiliary steel members span between in place main-steel or embedded i- plates. Based on this, spans ranging from 5'0" to l 8'0" encompass lengths for simply-supported cases and, therefore, were selected. However, since the detailed interaction values are fully stressed, the length variation has very little effect on the e factor.

d. Load location along the span l Various locations along the spans of simply-supported l members were selected. For cantilevers, the load was placed at the end of the member where its placement would have the most critical effect. For simply-supported cases, the position of the load was placed close to the center of the center where its location would have the most conservative effect.

e. Load direction The most critical applied piping load is a load creating torsion on a member. The 8 factor does not account for this effect and, thus, separate hand calculations must be performed to account for this effect.

48 1

1_._ - . __ _ _ .

[ h / $ 25~ 2-An applied vertical piping load on a member produces no torsion and, thus, a load from any tolerance creating torsion, changes a torsional stress from 0% to some finite number which theoretically is an infinite per-centage increase; whereas, a load from any tolerance causing torsion on a member already designed for an applied piping load that produces torsion, will have 1

a substantially lower percentage increase than one with a vertically applied loading producing no torsion. All 5 factor calculations were performed with the most i conservative direction of the applied piping load - the direction vertical to the member. In an actual calculation

where the actual applied piping load is at an angle to the member, the components of this loading are considered in a manually performed detailed analysis.

f. Load magnitude .

Various magnitudes of 1sedings were selected to assure

In = 1.0 or as close as possible. This has the same effect al ensuring that various loading magnitudes were considered.

Tables 15.1 and 15.2 summarizes the calculations performed, and a detailed discussion on the results obtained follows.

Table 15.1 is a summary of the commonly used member sizes with the corres-ponding appropriate configurations. Representative configurations are shown in Figure 15.3c.

Table 15.2 is a recreation of a table available in Calculation Book 13.3.15

! completed December 1, 1984, with the problem "I.D." numbers renumbered for the convenience of grouping the auxiliary steel configuration. Therefore, a one-to-one correspondence between the "I.D." number in Table 15.2 and the summary table provided in Calculation Book 13.3.15 is not appropriate.

However, when reviewing Calculation Book 13.3.15, all problem "I.D." numbers were identified correspondingly with the calculation page numbering sequential to what is listed in the summary table provided in Calculation Book 13.3.15.

l For simply supported cases from t'able 15.1, the most commonly used shapes with appropriate load ranges and spans are shown.

A total of 15 sample problems were selected and summarized in Table 15.2 and a review of Table 15.2 when compared to Table 15.1 will show a member size correspondence; loading ranging from 503 pounds to 7,723 pounds compared to 500 to 4,000 pounds; span ranging from 5'0" to 8'0" compared to spans ranging from 5'0" to 9'0".

i In addition to the member sizes being representative, they offer a' wide cross section of various structural shapes ranging from torsionally weaker to torsionally stronger, e.g. , double channel C3x4.1 to TS3x3x1/4.

I 49 i

. . - . . _ - , . . _ . - _ - . , . , _ _ - , , . - , - - . - . . , - . . _ , - . - . . , . . _ _ , ~ . . - . . - - -

_ . _ _ _ __ , ,yv, , ,,

G I M PL Y -

]

' [  :

' UPP'ORTEP

- y <'

.35 l g.

~-

CARTILEVER ,

,4,9 'l hT l',

ll O ,

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BRACKET ,

,M Ok .40 W .

i t

O -

t

\

E

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FRAME W/ 75 l HARC7 WARE i M. ,

l O  :

I w- w _.

.. l FGME W/o / D --'

N '

HARDWARE g

Concern B.2.kk, m thru xx I

$3s

, TABLE 15._ ,

()

in Summary of $ Factor used for Design of Auxiliary Steel for Mechanical Component Supports- .g

' ~

Commonly Used on Byron /Draidwood Project p Factor anfigurations La R 9 Sections Shapes . Spans Used s

(Included in. Factor Wide Flange W4x13, W6x25, W8x31 Derivation Prior to :1982 ,

See Attach. A & B) simply -

(Included in 500 5'-0" .

supported Double Channel C3x4.1, C4x5.4, C5x6.7, C6x8.2 Factor Derivation to .

to .7a.

Prior to 1982, 4000,, 8 -0_ -

See Attach. A& B)

Tube Section TS3x3xl/4, TS4x4xl/4 .

Wide Flange " " " " #

W4x13' W5x16, W8x3.1 Derivation Prior to 1982, See Attach. A & B) ,

Double Channel C12x20.7 500 l'-6"

. to to .65

!antilever 2000 3'-0" Angle L 3x3x3/8, L 4x4x1/4

• Tube Section TS4x4xl/4 Tccket Wide Flange W4x13, W8x31 (Included in Factor Deriva- 250 3'-0" 40 ,

[ Knee Brace) ,

tion Prior to 1982, See to to or Attachments A & D) 2000 5'-0" .65 (Included in p Factor Deriva- 250 4'-0" rdwarn- Wide Flange W4x13, U8x31 to to .75 17/ tion Prior to 1982, see Attachment B) 2000 6'-0"

'rame W/O Ulde Flange W4x13 Ilardware,

• 500 l'-6" to to .90 Angle L tv4xl/4 .

Concern B.2.kk, m thru xx

M L W D M .~h

SUMMARY

OF i*ACKUP CAIC  ! IONS FOR $ FACTOR +

A g

Y N

I CONFIGUR- SPAN LOAD CALC. DESIGN COMPARISON OF j ATION PROBLEM I.D. NO. MEMBER (' ") (lbs) $ FACTOR $ FACTOR FACTOR REMARK!

i Simply Supported 1 (2) C6x8.2 8'-0" 2694 0.80 0.75 .

Acceptable

, 2 W4x13 6 '-0 " 3229 0.76 0.75 Acceptable i

3 W6x25 8'-0" 7723 0.77 0.75 Acceptable 4 (2) C3x4.1 6'-0" 1100 0.82' O.75 Acceptable 5 (2) C6x8.2 6'-0" 3600 0.78 ,

0.75 Acceptable 6 TS 4x4x1/4 6'-0" 5130 0.97 0.75 hcceptable 7 TS 4x4xl/4 6'-0" 4900 1.00 0.75 Acceptable 8 TS 3x3xl/4 6'-0" 1475 1 00 0.75 Acceptable

." 9 (2) C3x4.1 5'-8" 587 1.00 0.75 Acceptable 10 (2) C5x6.7 7'-9" 2200 0.87 0.75 Acceptable 11 (2) C4x5.4 B'-0" 1143 1.03 0.75 Acceptable 12 W4x13 5'-8" 503 1.10' O.75 Neceptable l I Concern B.2.kk, m thru xx

TABLE '

o 2-Y\

o

SUMMARY

OF BACKUP CALCULATIONd FOR $ FACTOR D

. . . P CONFIGUR" SPAN LOAD CALC. DESIGN COMPARISON OFj ATION PROBLEM I.D. NO. HEMBER (' ") (lbs)  % FACTOR $ FACTOR FACTOR REMARKS Simply Supported 13 W8x31. 7'-0" .4750 0.80 0.75 Acceptable 14 W18x50 9'-0" 2500 1.63 0.75 Acceptable 15 W4x13 5'-0" 1300 0.76 0.75 Acceptable Ocntilever 16 W5x16 3'-0" 160. 0.74 0.65 Acceptable .

17 W8x31 2'-0" ,

'12059 0.66 0.65 Acceptable 18 (2) C12x20.7 2'-0" 12016 0.66 0.65 Acceptable 19 L 3x3x3/8 l'-6" 513 0.72 0.65 Acceptable 20 W4x13 2'-0" 1954 0.77 0.65 Acceptable 21 L 3x3x3/8 l'-6" 600 0.83 0.65 Acceptable 22 t 4x4xl/4 2'-0" 475 0.77 0.65 ,

Acceptable 23 TS 4x4xl/4 3'-0" 2000 0.74 0.65 Acceptable 24 W4x13 2'-3-7/16' 2550 0.67 0.65 Acceptablo Concern B.2.kk, m thru xx .

opp ----

y

SUMMARY

OF BACKUP CALCt IONS FOR $ FACTOR - $

CONFIGUR- SPAN LOAD CALC. DESIGN COMPARISON OF W ATION PROBLEM I.D. NO. MEMBER (' ") (lbs) $ FACTOR $ FACTOR FACTOR REMARKS Cantilever 25 ' '5x16 3'-6" 497 0.67 0.65 Acceptable Bracke,t 26 W8x31 4'-0" 12645 'O.52 0.40 Acceptable 27 W4x13 5'-0" 3000 0.71 0.65 Acceptable 28

• W4x13 3'-6" 497 1.06 0.65 Acceptable 29 W4x13 3'-9-3/4" 266 1.01 0.65* Acceptable 30 W4x13 4'-3" 222 2.80 0.65 Acceptable Frame 31 W4x13 l'-3" 10500 d.97 0. 0 . Acceptable l

32 L 4x4xl/4 2'-0" 603 0.88 0.90 Acceptable Concern B.2.hk, m thru xx

h/3-8 L All types of mechanical component hardware were considered on the design process and the most conservative combinations were sclected. For example, in problem I.D. No. 2 for the member W4x13 with a 5 calculation = 0.76, a variable spring hanger was used. This would have the effect of creating the most torsional stress in the member that the 5 factor must account for.

The cosuponly used cantilever configurations are summarized in Table 15.1. When one compares the table to Table 15.2, it will show a member size correspondence; loads ranging from 500 to 2,000 lbs. compared to loads ranging from 475 lbs.

to 12,059 lbs.; spans ranging from l'6" to 3'0" compared to spans ranging from l'6" to 3'6".

For commonly used bracket configurations summarized in TaNie 15.1 when compared to Table 15.2 again shows a correspondence to size, loading, and spans.

For commonly used frames without hardware summarized in Table 15.1 when compared to Table 15.2 again show a correspondence to size, loading and spans.

NRC Review and Conclusion Recarding Concerns B.2.kk and B.2.mm throuch B.2.xx Chapter 7 of the Structural Design Criteria which governs the use of the "0" factor methodology was issueu for use on October 5, 1981. S&L maintained that calculations demonstrating the acceptability of the "9" factor methodology had been completed prior to OctoL r 5, 1981; however, S&L was unable to retrieve l those calculations. Other calculations justifying the use of the "0" factor l methodology, completed as part of a March 1982 internal S&L study, were retrieved.

These calculations were not approved for use until April 1984. The NRC review determined that those calculations were incomplete and inadequate to demonstrate the acceptability of the "5" factor methodology as it was being used. In response l

to the NRC review of this concern, S&L developed another technical justification for the "0" factor methodo1My, which was completed December 4, 1984.

The NRC review determined that the results of this December 4, 1984, effort were incomplete to demonstrate the conservatism of the "B" factor methodology in all potential configurations. However, the "8" factor methodology would

~

produce acceptable designs when used in conjunction with other documents wh'ich control this design activity, such as specifications, design standards and i

project instructions. To provide additional assistance of the acceptability I of the "0" factor methodology, a number of supports which were not strictly bounded by the December 4, 1984, justification were determined to be acceptable i

by detailed, exact, individual calculations.

Several statements in the licensee's responses appeared to be incorrect and I required conaiderable discussion for the licensee to explain the intent of the statements. Satisfactory explanations were given for all but one of the state-ments. The one incorrect statement had no technical significance and related to component support hardware weights.

The inability of S&L to retrieve the original calculations is a violation of 10 CFR Part 50, Appendix B, Criterion XVII (454/8;-71-01(DRS); 455/84-49-01(DRS);

456/84-43-01(DRS); 457/84-39-01(DRS)).

l l 50

Commonwo..dt Edison fdd/ 38-3 O , One First National Plaza. Cheago. Ilknois O~ Address Reply to: Post Office Box 767 Chicago. Illmois 60690 April 15, 1985 -

Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 IE Inspection r 50-454/84-71; 50-455/84-49; 56/84-4 50-457/84-39 Reference (a):- March 15, 1985 letter from J. F. Streeter to Cordell Reed.

Dear Mr. Keppler:

Reference (a) provided the results of inspections by Messrs.

Muffett, Ward, Love, Jacobson, and Schapker at Sargent & Lundy Engineers and Byron and Braidwood Stations from Septerter 24, 1984 to February 4, 1985.

During these inspections, certain activities were found to be not in compliance with NRC requirements. Attachment A to this letter contains Commonwealth Edison Company's response to the Notice of Violation which was appended to reference (a).

Please direct any questions regarding this ma,tter to this office.

Very ly yours,

_ _; . - _ -x -

D. L. Farrar Director of Nuclear Licensing im cc: Byron Resident Inspector Braidwood Resident Insoector Attachment

'APR16 885 997JN . _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_ _ _ _ _ - _ - - - - -

6.68-3 4

ATTACFDENT A ' -

• RESPONSE TO NOTICE OF VIOLATION l

. VIOLATION 1 10 CFR 50, Appendix B, Criterion XVII requires that records to furnish evidence of activities affecting quality be identifiable and retrievable.

The Ceco Corporate Quality Assurance Manual and the CECO Quality Assurance Procedures Manual comit to the above 10 CFR, Appendix B require-i sents in Section 17. The CECO Corporate Quality Assurance Manual states,

" Quality Assurance records will be stored in a predetermined location as necessary to meet the requirement 5 of applicable standards, codes and regulatory agencies and shall be accessible to Edimn."

Contrary to the above, the Sargent & Lundy Engineers calculations which provided the original justification for the g factor desim methodology and maritude were not retrievable. ,

j CORRCCTIVE ACTION TAKEN Ato RESLLTS ACHIEVED Additional calculations, in addition to the 1982 supplementary calculations, were performed to justify the g factor methodology. As a result of the additional calculations, revised g factor parameters were developed.

i Support desips where the g factor was used were identified and reviewed. In those cases where the support desip using the g factor methodology was not bounded by the revised g factor parameters, detailed individual calculations were performed which showed that the support desi ps were within code allowable stresses.

CORRECTIVE ACTIONS TO AVOID FLRTFER NOPC06PLIANCE Structural Design Standard for Mechanical Component Support Steel Framing (SDS-E37) is the document used by Sargent & Lundy (S4L) to govern their desip of mechanical component supports. S&L issued a notification of revision (NORDS32) to SDS-E37 on December 26, 1984. NORDS-32 incorporates revisedboundingparametersforgfactormethodologytobeusedinconjunction with the simplified analysis procedure in Section 37.6.3 of SDS-E37. NORDS-32 was distributed to each engineer in S&L's Structural Engineering Division.

ICRDb32 was discussed in Structural Department and Structural Engineering Division meetings which are held for dissemination of information such as this. In addition, the technical support documentation for SDS-E37 will be microfilmed to ensure retrievability.

l

h,)$.$-7

~

1 l

- l l

The other Structural Engineering Desi p Standards are being reviewed to assure that adequate technical support documentation is available, that the documentation meets QA requirements, that it has been microfilmed and will therefore be retrievable.

DATE #EN RLL COWLIAPCE WILL EE ACHIEVED NORDS-32 was issued on Decent)er 26, 1984. The review of Byron and Braidwood to assure that support designs using the g factor methodology either met the revised g factor bounds or have detailed individual calculations in place was completed on February 13, 1985. The technical support documentation

' for SDS-E37 will be microfilmed by June 30, 1985. The technical support documentation for the other Structural Engineering Desip Standards will be reviewed, microfilmed and made fully retrievable by June 30, 1985.

l 6

e f

9973N

jk /3.8 - 3 VIOLATION 2 10 CFR 50, Appendix B, Criterion III requires that design control measures include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

CECO Quality Procedure QP No. 3-1 requires that "... design require-ments, including regulatory requirec.ents, codes and standards be utilized in the development of specifications, drawings, procedures, and instructions."

The AISC Steel Construction Manual (Section 1.8) committed to in the FSAR controlled designthe identifies slenderness parameter ratio (KL/r)menbers.

for conpression for structural steel members as a Contrary to the above, CECO employed designs for safety-related HVAC Ay S&L's Structural Standard Document which did not limit the slendern (KL/r) for ceiling mounted duct supports.

CORRECTIVE ACTION TAKEN APO RESLLTS ACHIEVED A notification of revision (NORDS28 dated October 31, 1984) was issued to Supports.

SDS-E36, the Structural Steel Standard for Safety-Related Duct supports.

NORDS-28 limits the slenderness ratio for ceiling mounted duct Safety-related duct support designs were reviewed and it was determined that the slenderness ratios met the limits stated in NORDS-28.

^

CORRECTIVE ACTION TAKEN TO AVOID FURTER NONCOWLIANCE NORDS-28 was r'istributed to each engineer in S&L's Structural Engineering Division and was discussed at Structural Department and Structural Enginecrjno Division Meetings. The other Structural Design Standards that govern the design of safety-related supports for other components such as cable trays, conduits, and piping have been reviewed and it was determined that these documents contained appropriate limits for slenderness ratios.

DATE MEN FlLL COWLIANCE WILL BE ACHIEVED The corrective action has baen completed. NORDS-28 was issued on October 31, 1984. The review of Byron and Braidwood safety-related HVAC duct support designs to assure that slenderness ratios met the limits stated in NORDS-28 was completed on January 31, 1985. The review of the other Structural Desip Standards for safety-related supports to verify they contained 1984.

appropriate slenderness ratio limits was completed by October 31,

__ 9973N_ _ _ _ .

i f.L^$ N ~Y E Commonw::lth Edison One First National Ptare. Chicago. Ithnois . /Y, "' 3 o '

- Address Reply to: Post Office Box 767 Chcago. Illmois 30690 April 22, 1985

,,,s......_. ,- - - .... , ... . .

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• O

. . . ** 9. . , .S

, 81. t , *', W.tgf y ;q f;j.g,,g p:3 . <g: ...$ g s .- .

,. w;. . ,? ; . - .

..,y.:; t.u .: ' .

., . . t Mr. James G. Keppler .

Regional Administrator i U.S. Nuclear Regulatory Comission l Region.III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Generating Station Units 1 and 2 Braidwood Generating Station Units 1 and 2 Design Concerns I&E Inspection Report Nos. 50-454/84-71, 50-455/84-49, 50-456/84-43 and 50-457/84-39 References (a): October 22, 1984 letter from L. O. DelGeorge .

to.J. G. Keppler.

(b): Decerter 11, 1984 letter from T. R. Tramm to J. G. Keppler.

(c): March 15, 1985 letter from J. F. Streeter to Cordell Reed.

Dear Mr. Keppler:

This letter provides for the record corrected pages for two letters which were previously supplied by Commonwealth Edison to the PRC. This information relates to the tEC's investigation of design concerns expressed by an Intervenor's expert witness which was documented in reference (a).

These revisions are submitted to fulfill commitments made during the NRC investigation. They contain no new information.

On Thursday, January 31, 1985, Mr. T. G. Longlais of Sargent &

Lundy, met with Mr. J. Muffett of PEC Region III to discuss the support merter that was reported to have a slenderness ratio (Kl/r) over 300. Mr.

Langlais stated that based upon further review of hanger ntster S-2214 on drawing M-1326-4, the revised Kl/r value is 291. This revision was due to the selection of an original K value of 2.0, which ignored the presence of a brace. The brace provides lateral support and a 1.2 value for K is more appropriate. Page 15 of reference (a) has been appropriately revised. It is enclosed and is labeled " Table 1".

APR2: 1985

b. /1. $-3 4

J. G. Keppler I

April 22, 1985 Also enclosed are revised pages 15 and 16 of the attachment to reference (b). Typographical errors have been corrected. -

Please direct further Questions regarding these matters to this Very truly yours, R l, [ b w--- -

T. R. Tramm Nuclear Licensing Administrator 1m i

Attachment i

i e

t .

9997N l

9

j I N i .

i D ,

TABLE 1

' g ,y -

BYRON - UNIT 1 HVAC MEMBER SLENDERNESS RATIO SURVEY l .

TENSION SYSTEM (CEILING MOUNTED) l Drawing Member K1 i

Serial Floor Number llanger Type F f F f

Number Elev. M- Number 1 2 3 4 (ksi) (ksi) F

! Al 364'-0 '1311-5 S-322 X 237 1.33 4.27 0.31 A2

. X 237 1.33 4.27 0.31 l

A3 401-0 1313-3 S-12101

^ '

X 212 1.12 5.33 0.21 A4 X 212 1.12 5.33 0.21 AS 401-0 1313-3 S-1211 X 219 0.20 4.97 0.04 A6 '" ~

X 219 , 0.20 4.97 0.04

A7 401-0 1313-5 S-1104 X 285 0.47 2.96 0.16 .

A8 X 285 0.47 2.96 0.16

• A9 401-0 1313-5 S-1108 X 219 1.75 4.98 0.35 A10 '

X 219 1.75 4.98 0.35 i

. All 401-0 1313-5 S-ll10 X 245 0.29 3.98 0.07 A12 X 245 0.29 3.98 0.07 .

A13 463-5 1326-4 S-2214 X 291 0.36 1.76 0.20 A14 X 291 0.36 1.76 0.20 NOTE: Fa is based on 1.6 x AISC equation 1.5-2

• All of these hangers are located in the Auxiliary Buidling.

O

h . /5. 8 .E t .

e. Load Direction Themostcriticalappliedpipingloadisaloadcrea(ting .

torsion on a member. The # factor does'not account for this effec.t and thuh, separate' hand calculations must be performed I

to account for this effee.*.. -

An applied vertical piping load on a member produces no tor-sion and thus, a load from any tolerance creating torsion -

changes a torsional stress from 0% to some finite number which theoretically is an infinite percentage increases whereas,

~

a load from any tolerance causing torsion on a member already designed for an applied piping load that produces torsion will have a substantially lower percentage increase than I

one with a vertically applied loading producing no torsion.

All (factor calculations were performod with the most conser-vative direction of the applied pining load - the direction vertical to the member. In an actual calculation where the actual applied piping load is at an angle to the member, 4

the components of this loading are considered in a manually performed detailed analysis.

~

I t

1 .

l f. Load magnitude l '

Various magnitudes of loadings were selected to assure I R D

15.

h /3. 5- 3

,. s

= 1.0 or as close as possible. This has the same effect R

as ensuring that various loading magnitudes were considered.

Tables 15.1 and 15.2 se:amarizes the calculations,gIerformed, ,

andadetaileddiscussionontheresultsobtainedhollows.

s ,

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e 0

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• 16.

h l3. 8- f NOV 221985 .

Docket No. 50-456 j Docket No. 50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the routine safety inspection conducted by Messrs. J. Jacobson and J. Muffett of this office on August 19, 22, September 17-19, and October 3-4, 16-18, 24, 1985, of activities at Braidwood Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. C. Schroeder and others at the conclusion of the inspection.

The enclosed copy of our 1ispection report identifies areas examined during the inspection. Within tiese areas, the inspection consisted of a selective

examination of procedures and representative records, observations, and interviews with personnel.

No violations of NRC requirements were identified during the course of this inspection.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

-~

c. L *.c.1 C';.:d by'J. J. b r M 9 J. J. Harrison, Chief Engineering Branch j

Enclosure:

Inspection Report No. 50-456/85040(DRS);

No. 50-457/d5039(DRS)

! See Attached Distribution I

i

% .-- - .7_ . . , . _ _ . _ _ _ _ _ _ , . . _ . , . . , _ , . . _ . , . - , _ . _ _ _ _ _ , __,_..,,,.,_,_.___.,,.,_.,_._,_,_....,,._____,-_.______,,_-,__.-,_..m_

( hy /3 d-y Commonwealth Edison Company 2 bH3V 2 21985 ,

Distribution -

cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent J. F. Gudac, Plant Manager C. W. Schroeder, Licensing and -

Compliance Superintendent DCS/RSB(RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Enviroi, ental Control Division D. W. Cassel, Jr. , Esq.

J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB e

e l

h./TB-f

U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/85040(DRS);50-457/85039(DRS)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: 'Cosmonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: _Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: August 19, 22, September 17-19, and October 3-4, 16-18, 24, 1985 W=Jr ~

Inspectors M . Jacobson itsa/r g Date bW5 it /2.2./8,3 J. Muffett

Date (n _

Approved By: D. H. Danielson, Chief ///21/W

~

Materials and Processes Section Date Inspection Summari' Inspection on August 19, 22. September 17-19. and October 3-4, 16-18, 24, 1985 (Reports No. 50-456/85040(DRS): 50-457/85039(ORS)J Areas Inspected: Announced safety inspection of licensee actions concerning previous inspection findings and one 50.55(e) item. The inspection involved a total of 122 inspector-hours by two NRC inspectors.

Results: No violations or deviations were found.

! . /3.8 - Y I

DETAILS l r

1. Persons Contacted -

t Commonwealth Edison (CECO) ,

M. Wallace, Project Manager

• C Schroeder, Project Licensing and Compliance Superintendent i

• D. Shamblin, Project Construction Superintendent i P. Barnes, Project Licensing l W. Vahle, Project Field Engineering Manager l

J. Dierbeck, Project Field Engineer

• E. Fitzpatrick, Assistant Manager of Quality Assurance The inspectors also contacted and interviewed other Itcensee and contractor employees.

• Denotes those attending the final exit interview at the Braidwood l Station ori October 24, 1985.

2. Licensee Action on Previous Inspection Findings

a. (Closed) Open Item (456/84-36-04): Improperly qualified welding procedure for L. K. Comstock (electrical contractor) welding of i galvanized material. To preclude the possibility of any

, questionable work arising fror a failure to remove the galvanize coating before welding, the licensee instructed L. K. Comstock to l qualify a procedure for welding with the galvanized coating in place.

l The NRC inspector reviewed the Procedure Qualification Test Records l No. LKCE-PQR-084, 085, 086, and 087. These tests were conducted in i the flat, horizontal, vertical and overhead positions with the galvanize coating in place. Performance of these qualification tests are considered a technically acceptable method of closing this item.

b. (Closed) Open Item (456/84021-04; 457/84020-04): Questionable certification of a L. K. Comstock (electrical contractor) welder.

A review of the qualification tests performed by Welder No. 11 was i

conducted with results as follows:

Welder No.11 originally qualified for carbon steel welding on July 28, 1978.

( Welder No.11 left the jobsite and returned on April 16, 1981.

At this time he was retested and again qualified for carbon steel welding.

i Welder No. 11 was tested for stainless steel welding on May 18, i and May 20, 1981, failing both tests.

i i

Welder No. 11 was given additional training and retested successfully for stainless steel on May 21, 1981.

1 i 2 l

l_ -- -- - - - - -

hy'I1.IS-1 I

Welder No. 11 again left the jobsite and returned on May 23, 1983. He was ratested on this date and failed to requalify.

• Based on the above review, Welder No.11 was properly qualified during the periods in which he performed safety related welding for 1

L. K. Comstock

c. (Closed) Violation (456/84021-01; 457/84020-01): Safety-related i structural steel fillet welds were visually examined for acceptance in the painted condition. A 100% review of the Napolean (structural contractor) Visual Weld Reports was conducted by Pittsburg Testing Laboratory (PTL). Visual Weld Report Nos. 709, 711, 713, 716, and 717 encompassing 122 welds were identified as being performed through paint. These inspections were perfomed by a single inspector during l a nine day period in 1980. These inspections were performed through

) paint at the direction of CECO Site Quality Assurance and are deemed to be an isolated' occurrence. All paint was removed and the welds j were reinspected to correct this deficiency. To prevent recurrence,

! PTL was directed to perform first line weld inspection only in the unpainted condition. The NRC inspector reviewed PTL Nonconformance l Report No.191, Revision 1 documenting the resolution of this item i

and found it acceptable.

d. (Closed) Violation (456/83009-10(c); 457/83009-10(c)): Pullman i Sheet Metal (PSM) Procedure B10.2.F. " Visual Weld Inspection", did i

not require a documented inspection of base metal surfaces and edges prior to welding. Section 3 of the AWS D1.1-77 Code, entitled

" Workmanship," states in part that surfaces and edges to be welded shall be smooth, uniform, and free from discontinuities which would adversely affect weld quality.

PSM procedures require inspection of shop fabricated items at the time of shipping and inspection of materials for field fabricated items at the time of receipt at the Braidwood site. Jobsite fabricated items are saw cut, which virtually eliminates the likelihood of irregular edges. In addition, the PSM welding procedures require inspection of the welding surface by the welder before welding is commenced.

To further demonstrate weld quality, the licensee performed a weld sample test program. The sample program consisted of tensile tests on 82 welded joint samples removed from the HVAC as-welded construction at the Braidwood Station. The results of this test program demonstrated that test failure loads were larger than the design allowable loads by at least 50%.

Based on a review of the above information and an inspection of in excess of 300 HVAC welds performed by the NRC inspector, it was .

- concluded that the lack of a documented inspection of base metal surfaces and edges prior to welding had no design significant effect on weld quality.

3

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e. (Closed) Violation (456/84043-01;457/84039-01): During an inspection related to allegations concerning Byron /Braidwood design activities, it was determined that Sargent and Lundy did not have retrievable design basis records for the "p" factor methodology employed in the ,

design of auxiliary steel for pipe supports. This was a violation of '

! 10 CFR 50, Appendix B, Criterion XVII. (SeeNRCInspectionReport

No. 50-454/84-71 fordetails). In response to this violation the i ,

design basis for the "p" factor methodology was recreated. All

supperts designed using the "0" factor methodology were reviewed for compliance with the new "p" factor parameters or specific detailed design calculations were performed to verify the acceptability of the supports. In addition, the Structural Design Standard for Mechanical Component Support Steel Framing (SDS-E37) was revised. Also, a review of other technical support documentation was performed to

assure that the design bases were retrievable. An inspection was l performed concerning these actions and all were found acceptable.

f. (Closed) Violation (456/84043-02;457/84039-02): During an inspection related to allegations concerning Byron /Braidwood design activities, it was determined that the AISC (American Institute of Steel Construction) limit for slenderness ratio (KL/R) had not been incorporated into the Structural Design Standard, Chapter E 36.0,

" Safety-Related HVAC Duct Supports," for ceiling mounted duct j supports. This was a violation of 10 CFR 50, Appendix B,

! Criterion III. (SeeNRCInspectionReportNo. 50-454/84-71 for details.) In response, SDS, E 36.0 was revised to incorporate the limit on sle.nderness ratio (KL/R) and existing designs were reviewed j for compliarce with the limit on slendarness ratio. An inspection of the revisions to SDE, E 36.0 and the review of existing designs was performed and found acceptable. l l g. (Closed) Violation (456/83009-02(B); 457/83009)-02(B)): NRC l Inspection Report No. 50-456/83-09; 50-457/83-09 found that the

! licensee was not in compliance with the Quality Assurance Manual,

! Revision 77, Q.P. No. 7-1 which is a violation of 10 CFR 50. Appendix

! B, Criterion V. This violation concerned the lack of receipt inspection of wall thickness and diameter of piping. As a corrective action, the inspection requirement was incorporated into QCP-B4, <

Revision 4, which was approved for use on January 23, 1984.

Subsequent to the violation, the licensee inspected piping received prior to July 28, 1983, for wall thickness violations. To provide

an addition assurance that piping currently in storage had received i the dimensional inspection, the NRC inspectors performed independent

dimensional inspections of piping in storage using a Digital Thickness Measurement device. The results of this independent inspection are as follows

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4

. 6 it.e-y 1

No. Min.

Size Heat No. Type Lengths Measurements Acceptance 2" Sch 80 U71443 SA-106 3 .221, .221, .222, .191 l

.224, .228, .228

.226, .220, .223 j .220, .218, .221,

.232, .228 11" Sch.80 187312 SA-106 3 .235, .226, .222, .175

.224, .209, .206,

.210, .218, .206

.199, .200, .186,

.184, .187 1

11" Sch 80 204272 SA-106 4 .224, .230, .206, .175

.206. 208, .198,

.200, .206 207,

.218 .

3/4" Sch 80 169031 SA-106 3 .156, .156, .155, .135

.151, .148, .152,

.167, .160, .159 2" Sch 160 74001 SA-106 3 .350, .350, .348, .300

) .335, .335, .337,

.349, .348, .348 5

6 /4.5-9 No. Min.

4 Size Heat No. Type Lengths Measurements Acceptance 1" Sch 80 204891 SA-106 3 .195, .190, .186, .157

.209, .212, .209, i

l .208, .210, .214 2" Sch 80 18497 SA-106 1 .244, .250, .242, .191

.229, .240, .236 li" Sch 80 B16497 SA-312TP304 3 .206, .201, .201, .175

.203, .201, .200,

.209, .202, .200

~

. 2" Sch 80 462774 SA-312TP304 3 .212, .212, .210, .191 i

.210. 211, .212, l .210 212, .213 l

l i 3/4" Sch 80 470382 SA-312TP304 1 .115, .124 .99 1

'11" Sch 80 462800 SA-312TP304 3 .147, .147, .146, .127

.152, .148, .149, l

.142, .144, .146 l

li" Sch 160 463001 SA-312TP304 3 .271, .268, .271, .246

.274, .273, .273,

.270, .268, .264 6

L

h /5.8-Y i

No. Min.

Size Heat No. Type Lengths Measurements Acceptance 2" Sch 80 24257 SA-312TP304 3 .211, .211, .211, .191

.210 210, .210,

.220,.220, .220 4

2" S/160 462843 SA-312TP304 3 .324, .325, .324, .300

' ~

.332, .331, .331,

! .335, .340, .336 The NRC inspector reviewed QCP-84, Revision 4 and found it acceptable, in addition, all measurements of wall thickness perfomed by the '

licensee and the NRC inspectors were acceptable.

i

h. (Closed).0penItem(456/85019-03;457/85020-03): During an inspection of'BCAP documentation and engineering analysis the inspector discovered a BCAP observation fom which stated that a crack had been discovered in a cable tray support weld. Subiaquent I

to the initial observation, the original BCAP inspector changed the observation to a " shrinkage line." A decision was made that the NRC 4

would inspect this weld in a subsequent inspection. (See NRC

! Inspection Report No. 50-456/85019; 50-457/85020 fordetails).

During this inspection the weld was inspected by the NRC inspectors.

, The weld contained no cracks and was acceptable.

I 1. (Closed)OpenItem(456/84034-02;457/84032-02): This item concerns .

a Pullman Sheet Metal inspection procedure pemitting transverse i

cracks to remain in the weld. Inspection Procedure PSM-WP-307, Addendum A, was prepared by Pullman Sheet Metal (PSM) and subsequently was accepted by S&L on March 3, 1981. This inspection procedure was used by PSM to reinspect a random sample of 200 ducts.

These inspections were used to disposition Ceco NCR L-246 which i

concerned inspection of silicon bronze welds, with respect to overlap and weld profile. Production inspections were not perfomed using

this procedure. Current PSM weld inspection procedures do not pemit

cracks of any orientation.

AWS D1.1 " Structural Welding Code," allows the use of alternate acceptance criteria, provided they are based on engineering evaluation. The acceptance of PSM-WP-307, Addendum A, was based on tensile testing of welds containing transverse cracks, as j documented in a letter from PSM dated February 10, 1981. To l

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7

h/58-Y supplement the data provided in 1981, S&L reviewed the results of 80 tensile tests perfonned in 1983. This review has shown that this .

specific type of transverse cracks in silicon bronze welds, used for the HVAC applications in question, has no significant effect on the abil!ty of the welds to perfonn their design function. The NRC inspector reviewed the basis for acceptance of this inspection procedure and its limited application and found it acceptable.

3. Licensee Action on 50.55(c' Items (Closed)50.55(e) Item (456/83004-EE;457/83004-EE)

This item concerns the use of jam nuts in sliding structural connections. The inspector reviewed a sample of the design analyses of the sliding connections for the Byron and Braidwood containment buildings. In addition, selected examples of sliding connections utilizing jam nuts were inspected. Both the design analyses and the installations inspected were acceptable. -

4. Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1),

on October 24, 1985, and summarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector. The licensee did not identify any such documents or processes as proprietary.

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SU8 CONTENTIONS 14.B.1, 14.B.2, 14.B.3 AND 14.B.4

• l Rorem QA Subcontentions 14.B.1, 14.B.2, 14.B.3 and 14.B.4 as admitted in this proceeding, state as follows:

14. Contrary to Criterion XVIII, " Audits," of 10 C.F.R. Part 50, Appendix B, Comonwealth Edison Company has failed to ensure that a comprehensive system of planned and periodic audits is carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The Applicant also failed to ensure follow-up action, including reaudit of deficient areas.

B. A special NRC QA inspection reported May 7, 1984 that:

1. Mechanical contractor Phillips, Getschow, Co. has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a period [ sic] basis to determine the effectiveness of the program in accordance with the Phillips, Getschow QA Manual.

2. Electrical contractor L. K. Comstock Co./L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule o.f planned and periodic audits established as required by QA Program Manual Section 4.14.1, nor did they verify compliance with all aspects of the Quality Assurance Program.

3. HVAC contractor Pullman Construction Industries, Inc. did not meet their yearly schedule for audit activities required by their QA Manual, Section 18, in that the following implementing procedures were not audited:

B 3.1.F, Design Control B 5.1.F. HVAC Repair Adjustment B 9.3.F, Expansion Anchor Installation B 10.2.F. Visual Weld Inspection

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4. Edison's audits of the installation of -

small bore instrumentation and process piping were inadequate in that contractor '

hanger design calculation problems were not identified for more than two years.

(Inspector Report 83-09, Exh. 5)

In its Motion for Sumary Disposition, Applicant concedes that the ,

three examples of noncompliance listed in Subcontention 14.B, parts one, two and three represent a violation of Criterion XVIII of 10 C.F.R. Part 50, Appendix B. Applicant argues that the three examples of the I

same items of noncompliance properly constitutes only one violation of Criterion XVIII and that the noncompliance occurred because of a different interpretation of Regulatory Guide 1.144-1980, the regulatory guide which provides guidance on how to achieve compliance with Criterion XVIII. Further, Applicant argues that the contractors involved have undertaken effective corrective actions, as independently verified by both Comonwealth Edison and the NRC Staff, to resolve the noncompliance and to prevent recurrence of similar noncompliance. Finally, Applicant argues that this isolated instance does not represent an adverse trend in the conduct of comprehensive audits by Coumonwealth Edison or its site contractors at Braidwood and thus, there is no generic issue of material

• fact to be heard with respect to Subcontention 14.B. parts one, two and three and accordingly summary disposition should be granted. With regard to Subcontention 14.B, part four, Applicant argues this item is not a bona fide item of noncompliance but rather simply a mistake by the NRC inspector as to the dates on which Comonwealth Edison audit activities actually began. The Staff agrees with the Applicant's arguments and supports the Motion for Sumary Disposition.

t

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The following discussions are provided for each part. -

Subcontention 14.B Part 1 (Phillips Getschow Company)

Mr. Schulz identified the item which forms the basis for Subcon-tention 14.B.1 during a documentation review of Phillips Getschow Company's audit program. Affidavit of Robert D. Schulz in Support of NRC Staff's Response to Applicant's Motion for Sumary Disposition of Rorem QA Subcontention 14.B.I. at 15 (hereinafter Schulz Affidavit 14.B.1).

Mr. Schulz found that the piping contractor had not established and executed a plan for auditing the implementing procedures of the quality assurance program. M.

After identifying the noncompliance of the Phillips Getschow Co.

audit program, Mr. Schulz verified that a corrective action program was implemented. Schulz Affidavit 14.B.1 at 17. The program included estab-lishing and implementing an audit program that covered all the imple-menting procedures and performing a comprehensive review of past auditing activities, taking into account both the Applicant and piping contractor l

l audits. Schulz Affidavit 14.B.1 at H6. The Applicant determined that 1

this combination of audits was appropriate to assure an acceptable confidence. level fer Braidwood installations or documentation. .I_d. The Applicant's review took in account all subsequent retrofit programs. M.

The NRC agreed with the Applicant's review and evaluations and verified that the current audit program covered all implementing procedures.

Schulz Affidavit 14.B.1 at H7. Commonwealth Edison quality assurance personnel verify implementation of the Phillips Getschow Company Audit Plans through its own audits and surveillances which serve to prevent l

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recurrence of this audit problem in the future. Schulz Affidavit 14.B.1 *

.at H6.

Based on ver,1fication and review of the adequacy of Applicant's corrective actions discussed above, Mr. Schulz closed this item. Schulz Affidavit 14.B.1 at TH 7 and 8. See also Exhibit 14.B.1-3.

Subcontention 14.B, Part 2 (L.K. Comstock Company)

This item of noncompliance was identified in June 1983 by Region III flRC Inspector T. E. Vandel in Inspection Report Nos. 50-456/83-09 and 50-457/83-09, which was issued May 7, 1984. Region III Inspector P. Pelke performed the followup inspections for this item of noncompliance. Affidavit of Paul R. Pelke In Support of NRC Response to Applicant's Motion for Summary Disposition of Rorem Subcontention 14.B.2 1 2 (hereinafter Pelke Affidavit 14.B.2).

In its Motion for Summary Disposition 14.B and its July 6, 1984 response to the NRC inspection report, Applicant acknowledged that L. K.

Comstock did not fully implement its 1983 audit schedule. In its response which sets forth the corrective actions Applicant proposed to address the identified item of noncompliance, Applicant stated that the active applicable work procedures and quality control inspection proce-dures had been audited by L. K. Comsteck as of the week of January 9, 1984. Id. Further, the Applicant placed two full-time, qualified auditors onsite. Id. L. K. Comstock procedures were revised and L. K. Comstock site Quality Assurance submitted an audit plan for 1984 which indicated that the Quality Assurance Program and their active safety-related activities would be adequately covered. Id.

'w ~ - - - - , -

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Mr. Pelke tracked the corrective action by reviewing a CECO QA -

Surveillance No. 4852 which was specifically conducted to verify L. K.

Conistock's corrective actions taken in response to the violation. Pelke Affidavit at 19. This review revealed that the Applicant took credit for 17 CECO QA audits of L. K. Comstock from June 1982 through December 1983, to compensate for the lack of L. K. Comstock auditing. M. Mr. Pelke stated that CECO's QA auditing program has been reviewed by the NRC and was found to be acceptable in previous inspections. Ed.

To verify that the L. K. Comstock QA program was adequately audited on an annual basis, Mr. Pelke reviewed audit schedules versus completed audits for 1984 and 1985. Pelke Affidavit at 11 10 and 11. He verified that L. K. Comstock conducted 33 internal audits in 1984 and 37 internal audits were scheduled to be conducted in 1985 at the time of his inspection, Mr. Pelke specifically reviewed nineteen L. K. Comstock internal audits conducted in 1985 and eight L. K. Comstock Corporate audits conducted in 1984 and 1985 to verify compliance with the controlling procedures. M. - i He identified one open item regarding the L. K. Comstock internal auditing program, L. K. Comstock Procedure 4.14.1, " Internal Audit Program," which allowed limited activity procedures to be placed on a 24 month audit schedule. Pelke Affidavit at 112. Mr. Pelke notes that Regulatory Guide 1.44 states that applicable elements of the QA Program should be audited at least annually or at least once within the life of the activity, whichever is shorter. Ld. To the best of his knowledge and understanding the Applicant resolved this issue, however, Mr. Pelke had not yet verified the Applicant's resolution.

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Based on the reviews and observations discussed above, Mr. Pelke -

closed this item. Based on Mr. Pelke's review, the Staff agrees that the Applicant took effective corrective actions to resolve this item and that this example of a violation was isolated in time and did not represent a significant breakdown in the QA/QC program.

Subcontention 14.8, Part 3 (Pullman Construction Industries, Inc.)

Region III NRC Inspector Schulz identified the item which forms the basis for this subcontention during an audit, a documentation review of Pullman Construction Industries, Inc., Applicant's HVAC contractor.

Affidavit of Robert D. Schulz in Support of NRC Staff Response to Applicant's Motion for Sumary Disposition of Rorem QA Subcontention 14.B.3 at 15 (hereafter Schulz Affidavit 14.B.3). In the course of his inspection, Mr. Schulz found that Pullma'n had not met the annual schedule for audit activities as required by its Quality Assurance Manual, Section 18, because four implementing procedures were not audited in 1983. Id. These implementing procedures were identified by Mr. Schulz as B 3.1.F, Design Control; B 5.1.F, HVAC Repair Adjustment; B 9.3.F, Expansio'i Anchor Installation and B 10.2.F Visual Weld Inspection. M.

Mr. Schulz verified the corrective actions taken by the Applicant and Pullman. Schulz Affidavit 14.B.3 at 16. The corrective action involved implementation of an audit program which included all sections of Pullman's Quality Assurance Program and assessment of compliance with Pullman's implementing site procedures. Id. Mr. Schulz determined that Pullman performed two audits in August and December of 1983. M. He observed that Pullman also took corrective action to assure that audits l

m

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would be properly conducted in the future by implementing an audit schedule matrix listing Appendix B criterion,-Quality Assurance manual sections, and procedures to be covered for future audits. Id.

Based on the adequacy of Applicant's and Pullman's corrective actions for current and future audits Mr. Schulz closed this item.

Schulz Affidavit 14.B.3 at 17.

Subcontention 14.B. Part 4 (Applicant's Audits)

Region III NRC Inspector Yin identified as a violation that Appli-cant's quality assurance audits of certain Phillips Getschow activities relating to the installation of small bore instrumentation and process piping had not been timely or adequate. Affidavit of James W. Muffett In Support Of NRC Staff's Response To Applicant's Motion For Summary Disposition Of Rorem QA Subcontention 14.B.4 at 15 (hereinafter Muffett Affidavit 14.B.4). Applicant provided the affidavit of Steven C.

Hunsader, Applicant's Site Quality Assurarice Supervisor at the Braidwood Nuclear Station, which details the program of audits Applicant's site

. quality assurance organization performed to examine Phillips Getschow's safety-related small bore instrumentation and process piping support selection work. Mr. Hunsader's affidavit asserts that Applicant's audits examined in detail Phillips Getschow's small bore support selection work

[

activity, identified support selection calculation errors and broader Phillips Getschow support selection program deficiencies and verified that corrective actions were implemented for the identifie; deficiencies through timely audit follow-up. Handsader's Affidavit at pp. 4-9.

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Region III NRC Inspector Muffett conducted an inspection of ,

Applicant's audit records which confirmed Applicant's claim that the audits of Phillips Getschow's safety-related small bore instrumentation and process piping support selection work had been timely and adequate.

Muffett's affidavit at 16. Consequently, this violation has been with-drawn by the NRC (see Exhibit 15.B.4-4). Id.

Staff Conclusion on Subcontention 14.B.1, 14.B.2, 14.B.3 and 14.B.4 Intervenor has not presented any information during discovery which might indicate that corrective actions taken by Applicant or its contractors were not adequate or effective or that these noncompliances were more than isolated incidents. Therefore, there are no genuine issues of material fact to be heard regarding these subcontentions, and Applicant is entitled to a favorable decision on these subcontentions as a matter of law. The Staff concludes, based on the discussion above, that Applicant's Motions for Summary Disposition of subcontentions 14.B.1, 14.B.2, 14.B.3 and 14.B.4 should be granted.

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