ML20214C628

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Affidavit of Rd Schulz Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.3.Supporting Documentation Encl
ML20214C628
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/13/1986
From: Schulz R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
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ML20214C321 List:
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OL, NUDOCS 8602210208
Download: ML20214C628 (12)
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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Station, Units 1 and 2 )

AFFIDAVIT OF ROBERT D. SCHULZ IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF ROREM QA SUBCONTENTION 14.B.3 I, Robert D. Schulz, being duly sworn, depose and state as follows:

1. I am employed by the U.S. Nuclear Regulatory Comission, Region III, as Resident Inspector at the Braidwood Station, Unit 1 and 2. A copy of my professional qualifications is attached hereto as Exhibit 14.B.3.
2. As Senior Construction Resident Inspector I am responsible for planning, coordinating, and personally conducting or leading inspections for the construction of Braidwood Station to assure compliance with design specifications, the conditions of the construction permit, provisions of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, and the rules and regulation of the Comission.
3. The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Summary Disposition of Rorem QA Subcontention 14.B.3. This subcontention states as follows:
14. Contrary to Criterion XVIII, " Audits," of 10 C.F.R. Part 50, Appndix B, Comonwealth Edison Company has failed to ensure that a m22;ogg g6foh6 G

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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: '

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 procedure 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

4. In preparing this Affidavit I reviewed the following documents:
a. " Statement of Material Facts As Tc Which There Is No Genuine Issue" Subcontention 14.B. Part 3 - Pullman Sheet Metal.
b. " Testimony of Conrad L. Holt (on Rorem Q.A. Subcontention 14.B.3)."
c. "NRC Inspection Report Nos. 50-456/83-09 and 50-457/83-09" (pertinent portions of the notice of violation and of the report attached hereto as Exhibit 15.B.3-2.
d. " Notice of Inspection Report Nos. 50-456/85-52 and 457/85-50" (pertinent portions attached hereto as Exhibit 14.B.3-3) .
5. I 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. I found that

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Pullman had not met the annual schedule for audit activities as required ,

by its Quality Assurance Manual, Section 18 because the following four implementing procedures wer,e not audited in 1983:

B 3.1.F Design. Control B 5.1.F, HVAC Repair Adjustment

- B 9.3.F. Expansion Anchor Installation 8 10.2.F, Visual Weld Inspection This finding is documented in NRC Inspection Report Nos. 456/83-09 and 457/83-09 (see Exhibit 14.B.3-2).

6. Corrective actions by the Applicant and Pullman consisted of 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. Pullman performed two audits in August and December of 1983. Pullman took corrective action to assure that audits woul'dbe 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. I have reviewed these corrective actions and am satisfied that they are' adequate to prevent recurrences of the tyne described in Rorem Subcontention 14.B.3.
7. Although Pullman failed to audit its implementation procedures relating to design control, HVAC repair ad'justment, expansion anchor installation, and visual weld inspection, the Staff has little concern that these auditing deficiencies have had an adverse impact on construction quality. An evaluation by Applicant indicated that each of these implementing procedures had been adequately audited by sources t

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other than Pullman. (See Inspection Report Nos. 50-456/85-52 and ,

50-457/85-50 (attached as Exh. 14.B.3-3 to this Affidavit).

8. I reviewed this evaluation and found it to be through and I agree that Pullman's failure to audit implementing procedures for the activities noted above did not affect adversely past construction activities. M . It was on this basis that I closed this matter in Inspection Report Nos. 50-456/85-52 and 50-457/85-50.
9. The failure of Pullman to audit four implementing procedures does not represent a significant breakdown in the QA/QC system at Braidwood Station.

RobertD.Schulz/

Swornangsubscribedbeforeme this /J day of February, 1986 An ea. Na Notary Public :f7 '

My Commission expires: I3 6

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2 Professional Oualifications .

ROBERT D. SCHULZ Organization: U.S. Nuclear Regulatory Commission, Region III

Title:

Senior Resident Inspector of Construction Birth Date: June 9, 1948 e

Education: B.S., Northern Illinois University, 1970 Completed BWR Technology Courses and Two-Week PWR j Technology Course, Chattanooga, TN Experience:

1984 to Senior Resident Inspector (Construction) - .

Present Braidwood Site. Plans, supervises and conducts i

inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media. (NRC) 1983 to Reactor Inspector - Inspects reactors under 1984 construction and in cperation. (NRC) 1982 to Senior Resident Inspector - Nine Mile Point Plant, Region I, Construction Site. Plans, supervises 1983 and conducts inspections at the site. Represents the i

NRC to the licensee, state and local officials, and i the news media. (NRC) i 1981 to Resident Inspector - Nine Mile Point Plant, Region I, i

1982 Construction Site. Performed 2513 and 2514 inspection programs at the Nine Mile Point plant. *

(NRC) 1980 to Reactor Inspector - Inspected reactors under i.

1981 construction and in operation in Region III.

l (NRC) 1975 to Q.A. Engineer - Morrison Construction and

1980 Engineering, LaSalle Station, Braidwood Township, IL.

p Mechanical Contractor.

1973 to Senior Buyer - Sundstrand Nuclear, Belvidere, IL.

1975 Purchased material for the Fast Flux Test Facility located in Hanford, Washington.

1971 to Quality Control Inspector - Morrison Construction l

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1973 and Engineering, Zion Station, Zion, IL. Mechanical Contractor.

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i h Y if $"B< H U. S. NUCLEAR REGULATORY COMMISSION REGION III '

Reports No. 50-456/83-09(DE); 50-457/83-09(DE)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133

' Licensee: Commonwealth 2dison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood - Units 1 and 2 Inspection At: Braidwood Site - Braidwood, IL ,

Enforcement Conferences At: Region III Office, Glen Ellyn, IL Inspection Conducted: June 20-24, June 27-July 1, August 1-5, August 9, October 4-7, October 24, 1983, January 11-13, January 26, and February 9, 1984 Enforcement Conferences Conducted: December 20, 1983 March 7, 1984 Inspectors:

W$_ :N2Q R. D. Schulz NE6 !8d Date Y $M 'M

. . T. Yin 3)4'Y Date JY s T. E. Vandel J J/-h '

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.f. w D. E. Keating M Date Approved By: D. R. Nunter, Chief Yta /N Management Programs Section Date Inspection and Enforcement Conference Summary '

Inspection on June 20-24, June 27-July 1 Aungst 1-5, August 9. October 4-7 October 24, 1983, and January 11-13. January 26, and February 9,1984; and ,

Enforcement Conferences on December 20, 1983, and March 7, 1984 (Report No. 50-456/83-09(DE); 50-457/83-09(DE))

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Notice of Violation 4 I AY 7 1984,

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Contrary to the above: '

a. Instructions were not appropriate to the circumstances in that welding procedures specifying the essential variables were not prescribed on drawings or welding sequences (travelers) for each specific HVAC installation, and Quality Control inspections during the welding process were not of adequate scope and frequency to assure the use of correct welding variables.

b.

Quality Control was not required to examine the HVAC components for fit-up arior to welding on those components where fjt-up tolerances cannot de determined after welding, such as all-around fillet welds and full penetration welds. Consequently there was a lack of records documenting the conformance with the requirements of AWS DI.1-1977, Section 3, and the-Ceco QA Manual. Additionally, instructions to the quality control inspectors regarding fillet weld gaps after welding were not appropriate to the circumstances in that the HVAC contractor Visual Weld Inspection Procedure, B10.2.F. stated that a 3/16" gap was acceptable whereas AWS D1.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by thi amount of the separation or the contractor demonstrates that the required effective throat has been obtained.

c. Quality Control was not required to examine the base metal prior to welding to assure that surfaces and edges were free of dis-continuities. Consequently, there was a lack of records documenting conformance with the requirements of AWS DI.1-1977, Section 3, and the CECO QA Manual.

This is a Severity Level IV violation (Supplement II).

4.

10 CFR 50, Appendix B, Criterion XVIII, as implemented by the CECO QA Manual, QR No. 18.0, requires,.in part, that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effective-ness of the program.

Contrary to the above:

a. Phillips, Getschow Company has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program in accordance with the PG QA Manual, Section 16.
b. L. K. Comstock Company /L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule of 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.

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c. Pullman Construction Industries, Inc., did not meet their yearly schedule fu audit activities required by their QA Manual, Section 18, in tnat 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 j

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The. licensee's audits of the installation of small bore instrumen-tation and process piping were inadequate in that contractor hanger design calculation problems were not identified for more than two

years.

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This is a Severity Level IV violation (Supplement II).

5. 10 CFR 50, Appendix B Criterion VI, requires that measures be established l

to control the issuance of documents and these measures assure that changes to those documents are reviewed for adequacy and approved for release by -

authorized personnel and are distributed to and used at the location where the prescribed activity is performed.

I CECO QA Manual, QR No. 6.0, Paragraph 6.1, requires that a document i control system be used, including changes, and the documents and changes be reviewed and approved for release by authorized personnel. QP No. 6-2,

{ ' Paragraph 4.3.1, requires that field changes to drawings be submitted with

a Field Change Request.

! Contrary to the above, adequate measures had not been-established to control field changes to drawings being made during the installation of ASME Boil'er and Pressure Vessel Code,Section III, Class 2 and 3, 2" and under piping. Craft personnel.had been making field changes to the drawings by rerouting lines, assigning weld numbers, and adding material which resulted in a lack of necessary control of approving, updating, and releasing drawings.

This is a Severity Level IV violation (Supplement II).

6. 10 CFR 50, Appendix B, Criterion II, requires, in part, that a quality assurance program be established which complies with the requirements of Appendix B and that the program be documented by written policies, procedures, or instructions and carried out in accordance with these instructions. The quality assurance program shall provide control over activities affecting quality and shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Criterion III requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions and w

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. U. S. NUCLEAR REGULATORY COMMISSION R,EGION III Report No. 50-456/85052(DRP); 50-457/85050(DRP)

Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Commonwealth 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: October 21 through November 30, 1985 Inspector: R. D. Schulz W. J. Kropp

$L f Approved By: W. S. Little, Director Braidwood Project

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. Date Inspection Summary Inspection on October 21 through November 30, 1985 (Report No.

50-456/85052(DRP); 50-457/85050(URP)) -

Areas Inspected: Routine safety inspection of licensee action on previously

. identified items, licenses action on 10 CFR 50.55(e) reports, plant tours, structural steel, and trending. The inspection involved a total of 186 -

inspector-hours onsite by two NRC inspectors, including 38 inspector-hours onsite during off-shifts.

Results: No violations or deviations were identified.

l f-8512260256 DR 851205 ADOCK 05000456 PDR

- M /M.J. J system not qualified in accordance with ANSI N101.2. The coating contractor issued Nonconformance Reports 23, 24, 25, and 26 to ,

document and disposition the areas in the Unit 1 and Unit 2 con.tainments, where repairs were done with a process not qualified to ANSI N101.2. The nonconformances were dispositioned "use-as-is" and were approved by Sargent & Lundy (S&L). The justifications for the disposition were documented by S&L on Design Information Transmittals (DITs) BR-SSD-0002-0 and BR-SSD-0005-1 and were found to be acceptable. These DITs documented that the square footage of the areas repaired was lim'ited (less than 200). This area is identified by S&L on a coatings exception list which is being prepared for identifying unqualified coatings in the containments. The inspector also verified that the coating contractor, Midway, has a qualified coating repair procedure (C.P. 3A, Revision 4) approved by S&L.

(Closed) 456/83-09-08A; 457/83-09-08A: Phillips Getschow Company had not established and executed a plan for auditing the implementing procedures of the quality assurance program. Phillips Getschow Company revised their audit schedule on August 21, 1983, to include auditing all the implementing procedures annually. The inspector verified that audits are being performed in accordance with the audit schedule. A comprehensive review was accomplished by the licensee and piping contractor with regard to past auditing activities. Each implementing procedure approved for use at the site was analyzed against both the piping contractor's and licensee's audits. Based on

. this con.bination of audits, which were conducted to determine compliance with the Phillips Getschow Quality Assurance Manual and inherent overlap into the implementing procedures the review concluded that no questionable areas remained. The evaluation also took into account the nature of the task and retrofit programs which have been implemented.

The inspector examined this comprehensive review and found it to be satisfactory for resolving the question of past auditing activities in relation to programmatic and regulatory compliance.

(Clrsed) 456/83-09-08C; 457/83-09-08C: Pullman Construction Anoustries, Inc. audit program did not cover all the implementing -

procedures. Pullman has implemented an audit schedule that provides for auditing the entire population of implementing procedures. The implementing procedures not previously covered and identified in

1983 included
  • B3.1.F, Design Control
  • B5.1.F, HVAC Repair Adjustment
  • B9.3.F, Expansion Anchor Installation ]

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  • B10.2.F, Visual Weld Inspection l

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.. Mbd Evaluations by the licensee and Pullman concluded that either the procedures were adequately implemented or corrective actions have been identified to assure compliance with the procedures. The '

evaluations are summarized below:

  • Procedure B3.1.F has been adequately audited at the site based on:
  • Sargent and Lundy review and approval of all duct brochure details, all field and shop procedures, and all design documents.
  • Surveillances and audits performed by Pullman and the licensee.
  • Procedure B5.1.F has been adequately audited at the site based on:
  • Licensee reviews which resulted in reinspection activities delineated in Nonconformance Reports 349, 353, 407, 460, 540, 558, 632, and 606.

Licensee reviews which resulted in the corrective actions required by 10 CFR 50.55(e) reports 82-01, 83-01, 83-08, and 84-08.

  • Procedure 89.3.F has been adequately audited at i.he site based on the Pullman expansion anchor installation retro inspection performed in accordance with licensee Nonconformance Reports 658 and 659.
  • Procedure B10.2.F has been adequately audited at the site based on:
  • Pittsburgh Testing Laboratory 10% overview of Pullman weld inspections.
  • Surveillance and audits performed by Pullman and the licensee.

The inspector found the evaluations thorough and supporting the adequacy of past construction activities.

b. Unresolved Items (Closed) 456/84-08-06; 457/84-08-06: Three ASTM A-490 structural steel bolting connections were found in Containment 2 to have low torque values for some of the bolts in the connection. An engineering review was performed by Sargent & Lundy for all connections in both containments. The review concluded that only friction type connections, and not bearing type connections, required tightening to the original 6

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