ML20214C676
| ML20214C676 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210230 | |
| Download: ML20214C676 (24) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
COMMONWEALTH EDIS0N COMPANY
)
Docket Nos. 50-456
)
50-457 (Braidwood Station, Units I 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 14.B.4 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 Comission (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 to this affidavit as Exhibit 14.B.4-1.
2.
As a Reactor Inspector, I am primarily responsible for reviewing the design 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 Subcontention 14.B.4.
This subcontention states 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 B602210230 860218y6 ADOCK O
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ensure followup action, including reaudit of deficient areas.
8.
A special NRC QA inspection reported May 7, 1984 that:
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 ears.
(Inspection Report 83.09, Exh. 5.
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 Thomas E. Quaka (on Rorem Q.A.
Subcontention 14.B) c.
NRC Inspection Report Nos. 50-456/83-09 and 50-457/83-09 (pertinent portions attached hereto as Exhibit 14.B.4-2);
d.
Applicants Response to Inspection Report Nos. 50-456/83-09; 50-457/83-09 dated August 31, 1984 (pertinent portions attached hereto as Exhibit 14.B.4-3).
e.
Letter from Carl J. Paperiello, Director, Division of Reactor Safety To Cordell Reed, Comonwealth Edison Company withdrawing violation dated February 13, 1986 (attached hereto as Exhibit 14.B.4-4).
5.
The violation upon which Rorem Subcontention 14.B.4 is based was identified by Mr. I. Yin. This violation was identified during a routine inspection documented in Inspection Report 83-09 (Exhibit 14.B.4-2).
Based on information gathered during his inspection, Mr. Yin believed that Applicant's quality assurance audits of certain Phillips Getschow Company activities relating to the installation of
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small bore instrumentation and process piping had not been timely or adequate.
6.
Subsequently I conducted an investigation of the Applicant's response (see Exhibit 14.B.4-3).
My inspection of Applicant's audit records confirmed that contrary to what Mr. Yin had been told the audits of these certain activities had been timely and adequate. This violation has been withdrawn by the NRC and Mr. Cordell Reed of Comonwealth Edison Co. has been notified by letter dated February 13, 1986 from Mr. Carl J.
Paperiello, Director, Division of Reactor Safety (see Exhibit 14.B.4-4).
7.
.Rorem Subcontention 14.B.4 is based on a violation which subsequent information invalidated.
For this reason this item does not represent a significant breakdown in the Applicant's quality assurance program.
>WA James W. Muffect
)Q Sworn and subscribed before me this /P day of February,1986 Iqi.w.v
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e Notary Public My Commission expires:
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Professional Qualifications JAMES W. MUFFETT Organization:
Region III
Title:
Reactor Inspector (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 Engineering Manager - Managed mechanical design and 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. (Cumins Engine Co., Inc.)
1975 - 1978 Grou ) Leader - Leader of piping analysis group whici 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)
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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 Edison 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 Db-S W Inspectors:
R. D. Schulz yg y Date
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D. E. Keating A AC
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D. R. Hunter, Chief YM /N Management Programs Section Date Inspection and Enforcement Conference Summary Inspection on June 20-24, June 27-July 1, August 1-5, Auaust 9. Octo'oer 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))
/Y'N#L Areas Inspected: Special, announced inspection of the piping contractor QA Program for training, large bore and Class I small bore piping design control,
procurement control, document control, receipt inspection, special processes, inspections,< measuring and test equipment, nonconformance and corrective action, audits, and small bore piping design; of the electrical contractor QA Program for staffing and qualifications, contractor auditing, document control, noncon-1 formance control, equipment installation control, licensee auditing; and of the heating, ventilation, and air conditioning (KVAC) contractor QA Program for qualification and training, design control, drawing control, material inspection, installation, nonconformance/ corrective action, and audits. Enforcement conferences were conducted on December 20, 1983, and March 7, 1984, to discuss the inspection findings. The inspection involved a total of 300 inspector-hours onsite by four NRC inspectors and the enforcement conferences involved a total of approximately 64 staff-hours.
Results: Six items of noncompliance were identified (failure to establish control for revisions to drawings - Section I, Paragraph 6.a; failure to follow procedures - Section I, Paragraphs 6.b, 7, 8.c and 9.b,Section II, Paragraph 3.c; failure to take adequate corrective action - Section I, Paragraph 11; inadequate control of small bore piping design - Section I, Paragraph 13; failure to execute a comprehensive audit plan - Section I, Paragraph 12,Section II, Paragraph 5.b, and Section III, Paragraph 9.a; and failure to provide design control which complies with the requirements - Section III, Paragraphs 7 and 8.a.).
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h))lP/N'b NOTICE OF VIOLATION Connonwealth Edison, Company Docket No. 50-456 Braidwood Units 1 and 2 Docket No. 50-457 EA 84-35 As a result of the inspection conducted on June 20-21, June 27-July 1, August 1-5, August 9. October 4-7, October 24, 1983, January 11-13, f
January 2b, and February 9,1984, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9,1982), the following violations j
were identified:
1.
10 CFR 50, Appendix B, Criterion XVI, as implemented by CECO QA Manual, QR No.16.0, requires, in part, that measures be established to assure that conditions adverse to quality such as nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above:
1/2" S/80, SA-312 Type 304, ASME Boiler and Pressure Vessel Code, a.
Section III, Class 1. NB pipe heat number 745107 was discovered in Section III installations without material test reports or records of receiving and receipt inspections by either Commonwealth Edison Company or PGCo as identified by PGCo on September 17, 1982, on Nonconformance Report No. 789. The disposition of the Nonconformance Report resulted in accepting the pipe, after only obtaining material test reports, without examining the pipe, initiating and maintaining receipt inspection records, or determining the total quantity of the pipe in storage and installed.
I b.
The HVAC contractor had not established a corrective action program to assure that conditions adverse to quality such as deficiencies and deviations were analyzed for significance and subs'equently that the causes of any significant conditions were determined and corrective action taken to preclude repetition. Through August 4, 1983, 2,513 Correction Notices had been written by the HVAC contractor for deficiencies and deviations, including numerous welding deficiencies and deviations, but the contractor's Quality Assurance Program did
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not require that Correction Notices be analyzed for significance, Corrective action was not adequate concerning Nanconformance Report c.
No. BR-08, dated June 15, 1981, since the nonconforming welds completed by unknown welders were " accepted-as-is" after only a visual examination. The acceptance of a weld by visual examination pursuant i
to AWS D1.1 is based on the fact that a qualified welder performed the welding in accordance with the qualified process.
This is a Severity Level IV violation (Supplement II).
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/Y.ES Z-Notice of Violation 4
Y 7 1954 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 prior to welding on those components where fit-up tolerances cannot >e 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 D1.1-1977, 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 DI.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by the amount of the separation or the contractor demonstrates that the required effective throat has been obtained.
Quality Control was not reouired to examine the base metal prior c.
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 D1.1-1977, 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 Compa / 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.
l b.
L. K. Comstock Company /L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule i
l 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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Y Pullman Construction Industries, Inc., did not meet their yearly c.
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 d.
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.
This is a Severity Level IV violation (Supplement II).
5.
10 CFR 50, Appendix B, Criterion VI, requires that measures be established 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.
Ceco QA Manual, QR No. 6.0, Paragraph 6.1, requires that a document 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 Boiler 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
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l 12.
Audits The licensee's audit program of the piping contractor and the piping contractor's audit program was reviewed to ascertain compliance with ANSI N45.2.12, ANSI N45.2.23, and implementing procedures.
The following piping contractor audits were reviewed:
- Process Control, Small Bore Piping, 4/12/83 - 4/20/83
- Welding Controls, 3/29/83 - 3/31/83
- Documentation Control, 5/10 5/18/83
- Process Control, Large Bore Piping, 2/22/83 - 3/11/83 The following licensee audits of the piping contractor were reviewed:
- QA-20, 82 Instrumentation Design and Installation, 2" and Under Pipe Design and Installation, June 1982.
- QA-20, 82 PGCo Q.A. Manual Sections 10, 11, 12, 14, 15, 16, 17 and Applicable Procedures, October 1982.
- QA-20, 82 Pipe Supports / Whip Restraints, April 1982.
- QA-20, 83 Large Bore Pipe Installation, Personnel Qualifi-cations, Weld Rod Control, Storage Control, PGCo Q. A. Manual Sections 12, 13, 14, May 1983.
The audits performed were in accordance with a pre-determined schedule included pre-established questionnaires for depth and continuity, and contained objective evidence and evaluation statements concerning the audits.
Pre and post audit conferences were held. The certifications for the PGCo lead auditor were examined and found to be in compliance with ANSI N45.2.23.
Responsibilities for corrective action were assigned to specific individuals and findings were followed up for correction of the concerns.
Af ter review of the PGCo audit schedule and discussions with the PGCo lead auditor, the inspector learned that PGCo had 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.
PGCo was required by Section 16 of its QA Manual to audit the entire QA manual annually, but no requirement existed to audit the implementing procedures such as the Quality Assurance Procedures, Quality Control Procedures, or Construction Procedures in a specified time period.
These procedures were being audited on a random basis, without regard to complete coverage in any period of time. For example, a review of audits in the welding area revealed the following audits not performed:
- QCP-B7, Ferrite Control of Stainless Steel Field Welds
- QCP-B20, General Repair Procedure
- P QCP-2, Reforming of Pipe Ends and Welds
- P QCP-13, Preparation of Welds for In-Service Inspection 23
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Failure to establish and execute a comprehensive audit plan is an' example of a violation of 10 CFR 50, Appendix B, Criterion XVIII (456/83-09-08(A); 457/83-09-08(A)).
13.
Small Bore Pipina Design The inspector reviewed site design control measures for safety related process and instrumentation small bore piping (2" and under). Process systems installation started in July 1981.
Instrumentation systems installation started in March 1981.
a.
Review of Procedures and Specifications ~
To assess the overall program adequacy, the inspector reviewed the following documentations:
Phillips, Getchow Co. (PG) Quality Control Procedure (QCP)
B21, " Installation and/or Field Routing of Two Inch and Under Process Piping Systems - ASME Classes 1, 2, and 3",
Rev. 4, dated December 3, 1982, including " Supplement For Contract," dated July 22, 1983.
PG Construction Procedure (CP) 22, "2" and Under and 25"-4" Process and Instrument Line Supports in Category I Buildings,"
Rev. 7, dated April 16, 1983.
PG QCP B23, " Installation and Inspection of Component Supports,"
Rev. 4, dated May 11, 1983, including " Supplement For Contract,"
dated May 11, 1983.
4 PG CP 40, " Verification, Preparation and Transmittal of 'As Constructed' Drawings," Rev. O, dated May 31, 1983.
t Pertinent portions of S&L Specification.F/L-2739, " Piping System Installation (Section III and Non-Section III) Byron Station - Under 1 and 2, Braidwood Station Units 1 and 2,"
Amendment 4, dated July 22, 1982.
Findings:
(i) Per PG Procedure CP 22, PG was authorized to constract l
Category I (safety related) 2" and under process and instru-mentation piping with a maximum operating temperature of 150'F, as directed by S&L design guides. Design tasks of: (1) pipe support location and type and routing analysis, (2) documenta-tion of design on routing and structural drawings, (3) hanger detail drawings / material documentation, and (4) design review /
documentation of design acceptability were performed. In view of the many program and computation deficiencies and errors identified during the inspection, it became apparent that neither the licensee nor the AE had performed sufficient assess-ments 'and verifications to determine the adequacy of PG design capabilities, program provisions, or effective procedure imple-mentation.
24
Common
- dth Edison One Fa'e Nanv. mt Pta:9 CNeigo lia.no4
'" Accress Repty to Post Off ce Boa 767 CNeago lu.nois 60690 N1y 6, 1984 Mr. James G. Keppler Regional Administrator - Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
d4tation Units 1 and 2
Response
pection Report Nos.
50-45
-09 d 50-457/83-09 NRC Dos Nos. 50-456 and 50-457 Reference (a):
J. G. Keppler letter to J. J. O'Connor dated May 7, 1984
Dear Mr. Keppler:
This letter is provided in response to the inspection conducted by Messrs. T. E. Vandel, R. D. Schulz, I. T. Yin, D. E. Keating, C. C.
Williams, and D. R. HJnter on June 20-24, June 27-July 1, August 1-5, August 9, October 4-7, and October 24, 1983, and January 11-13, January 26, and February 9,1984 of activities at our Braidwood Station.
Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements.-
The Cormenwealth Edison Company response to the totice of Violation is provided as Attachment A to this letter. Our response to unresolved Items 456/83-09-04 (A), 457/83-09-04 (A), 456/83-09-04 (B),
and 457/83-09-04 (B), and the description of our program to verify the quality of installed piping components is included as Attachment 8 to this letter. An extension of the response period was requested from W.
S. Little and R. F. Warnick of Re~gion III on separate occasions, and extension was granted to July 6, 1984 We appreciate the extension of time given to us to respond to this matter.
Reference (a) revealed a number of deficiencies concerning the programs and procedures which had been established at Braidwood Station for the verification of correct material for ASE piping components, control of HVAC welding activities, and design control of field routed small bore piping and associated hanger installation activities. Our responses to the items of non-compliance describe the changes and irtprovements which we have made to those procedures as a result of our intensive and comprehensive reviews of your findings and those of other inspections. The information provided in this submittal also serves to respond to the additional questions raised in the Reference (a) letter transmitting the Notice of Violation.
yn.12
k /W-J J. G. Keppler July 6, 1984 Comonwealth Edison believed that the programs and procedures, at the time of their approval, were adequate to assure the quality of the completed construction work. We acknowledge, however, that they contained deficiencies with respect to meeting all regulatory requirements, particularly with regard to the need for providing detailed documentation of activities. We also recognize the need in several cases to more rigorously follow and more effectively monitor approved procedures and activities.
Recently, an Atomic Safety and Licensing Appeal Board found that the critical questions regarding the assurance of quality of construction of complex nulcear power plants are whether identified constru' tion deficiencies have been corrected, and whether there is a functioning quality assurance program so that there is reasonable assurance as to the overall integrity of the facility. Comonwealth Edison Company believes that the responses contained in the Attachments to this letter do substantiate that construction deficiencies have been and are being identified and corrected, and that there is aggressive implementation of Quality Assurance at our Braidwood Station.
We have established a nutter of corrective action programs to confirm the quality of specific areas of past construction work through a series of special inspections and documentation reviews. The programs have been designed to demonstrate that past construction work is of acceptable quality, and that deficiencies are identified and appropriately dispositioned. These quality confirmation programs include: the Reinspection of Safety Related Mechanical Equipment; a Quality Control Inspector Reinspection; the Piping Heat Number Material Traceability verification Program; the Quality Control Structural Steel Review; an Electrical Installation Document Review; a Review of Safety-Related Pipe Supports; the HVAC Welding Reinspection; the HVAC Configuration Review; the HVAC Ouct Stiffener and Fitting Detail Review; an Instrumentation Installation Verification; and a NSSS Component Support Verification Review.
Finally, we have made extensive management and organizational changes within the Comonwealth Edison management team and the contractor management organizations, and within the Comonwealth Edison and contractor Quality Assurance /QiJality Control organizations which effect overview activities, to provide assurance that procedural requirements will be met, and to ensure aggressive and effective management involvement in our Quality Assurance Program. A description of these changes is included as Attachment C to this letter.
The cortination of these efforts provide the basis for Commonwealth Edison Company's confidence in the performance of the site contractors, and our confidence that our Braidwood Station will be cargleted in accordance with regulatory requirements.
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h/Y$Y-3 J. G. Keppler July 6, 1984 To the best of my knowledge and belief, the statements contained herein and in the Attachments to this letter are true and correct.
In scrne respects, these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees, contractors and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Very truly yours, f
4 Louis 0. DelGeorge /
Assistant Vice President Attachments cc: P#C Resident Inspector Braidwood 8931N
/Y$ V'- 3 COMMONEALTH EDISON COWANY RESPONSE TO INSPECTION REPORT 50-456/83-09 and 50-457/83-09 ITEM OF NONCO WLIANCE:
4.
10 CFR 50, Appendix B, Criterion XVIII, as implemented b/ the Coninonwealth Edison Company Quality Assurance 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 effectiveness of the program.
Contrary to the above:
a.
Phillips, Getschow Company has not established and executed a plan for auditing the iglementing procedures of the quality assurance program on a periodic basis to determine the effectiveness of the program in accordance with the PG Quality Assurance Manual, Section 16.
b.
L. K. Comstock Company /L. K. Comstock Engineering Comany auditing activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by Quality Assurance Program Manual Section 4.14.1 nordidtheyverifycompliancewithallaspectsoftheQualkty Assurance Program.
c.
Pullman Construction Industries, Inc., did not meet their yearly schedule for audit activities required by their Quality Assurance 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 d.
The licensee'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.
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Response to Item Ad
RESPONSE
Comonwealth Edison Company does not agree with the mC Finding that problems with the Phillips, Getschow Conpany support selection program were not identified and that correction of identified non-conformances were not performed in a timely manner. The history presented below represents the Site Quality Assurance Department activity in this area. The history demonstrates that an audit had been conducted and that work was stopped on safety related instrumentation piping support selection in October, 1981. The history also indicates tht times when various instrumentation line and small bore process pipe activities had been started. (For example, safety related small bore process piping support selection started in January, 1983). The history demonstrates that Site Quality Assurance was actively involved in this area.
INSTRU>ENTATION Upon approval of Phillips, Getschow Company Procedure PGCP-22, Rev.
1, safety related instrumentation line support selection started in July, 1981. After enough work had been completed so that a representative sample could be taken, this area was checked by Commonwealth Edison Company Quality Assurance in an audit of October, 1981. This audit identified deficiencies that are summarized as,follows:
1.
Incorrect calculations 2.
Improper calculation reviews 3.
Three dimensional restraints not used per ECN 2194 4.
Adjacent line weights not used in line weight calculations 5.
Revision levels of applicable isometric drawings not listed on calculation sheets 6.
System component weights obtained from an uncontrolled source (uncalibrated scale) 7.
Quality Control not monitoring instrument group activities 8.
Documented training not given to Procedures PCCP-21 and 22 9.
Interface document not clearly written 10.
Organization chart in error
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Response to Item ed (cont'd)
A The details of these items, including Quality Assurance follow-up work, corrective actions, and item close-outs, are described in the audit close-out surveillance reports. This audit resulted in a stop work action being placed on Phillips, Getschow Company until February, 1982. All items were resolved and closed by March, 1982.
l As an additional follow-up to the October,1981 audit, an audit was t
. performed in July, 1982. The concerns of the Octooer,1981 audit were re-checked as evidenced by approved checklist ouestions 1, 2, 3, 4, 5, 10, 11, 12, 14, 15, 16, and 17. All Question areas were found acceptably implemented. At that time, based on the audit history, Commonwealth Edison Company Quality Assurance believed that instrument support selection was being performed in an acceptable manner, and that Phillips, Getschow Company was implementing their i
procedures in this area.
SMLLL BORE Small bore process pipe support selection started in January,1983 upon approval of Revision 2 of PCCP-22 which then added support selection for small bore process pipe. Again, after work had been completed so that a representative sample could be taken, small bore pipe support selection was checked and instrumentation line support selection was re-checked in July, 1983 during audit QA-20-83-33. It was identified that Phillips, Getschow Company Procedure PG7-22 dio not give the step-by-step method for performing support selection i
calculations; that the procedure did not reference the current applicable ECN (4566); and that information on the calculation 4
sheets was unclear or incomplete. This resulted in PCCP-22 being revised to more specifically define the methodology of performing ~
support selection calculations. Revision 8 of this procedure was given interim approval by Comonwealth Edison Site 02ality Assurance i
on Novent>er 10, 1983, and was accepted by Sargent and Lundy on December 2, 1983.
Thouti the above deficiencies were identified, for the calculations reviewed in Quality Assurance Audit 20-83-33, no cases were identified where calculations were being incorrectly performed or undersized pipe supports were being selected. The first process l
pipe support package was issued to the field for installation in August, 1983, 4
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Response to Item Ad (cont'd)
Also, audit QA-20-83-33 identified that small bore pipe and instrumentation line support selection training files were incomlete. Corrective actions were defined and iglemented to correct this item as well.
Subsequent to the NFC inspection, Site Quality Assurance continued to audit this area. Site Quality Assurance audit QA-20-83-49 dated 10/20/83 specifically audited support selection activities and design document control related to support selection work. Three (3) findings were identified which are summarized as follows:
1).
Arithmetic errors were found in support selection calculations.
2)
Drawings used to locate component supports were not verified "as constructed" drawings.
3)
Drawings used as input for calculations were not the most current revision.
Each of these iterns has had corrective actions defined and completed, and verified by Site Quality Assurance as having been ir@lemented. This audit was recently closed on 3/16/84.
In Decerter, 1983, Quality Assurance audit 20-83-62 checked the implementation of Phillips, Getschow Procedure PGCP-22, Rev. O, which had been revised to more clearly delineate and refine the technical support selection requirements provided by S & L in ECN 5776. Fifty-five (55) supports were reviewed in detail and no errors were identified indicating that the methodology used at that time was adequate to perform the support selection in an acceptable manncr. As part of a recent audit of Phillips, Getschow Company, QA-20-84-518 dated 5/4/84, support selection was again checked and in this area, one (1) observation was identified for which corrective action has been defined.
As of June,1984, the activities discussed above are being acceptably performed. Site Quality Assurance will continue to monitor this activity to assure proper compliance.
Commonwealth Edison Company overview of contractors continues to be imprwed as described in Attachment C.
hbk 8SY-4/
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FEB 131986 i
4 Docket No. 50-456 Docket No. 50-457 Comonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This is in response to your letters dated July 6 July 23, and August 31, 1984, and March 11. March 27, and April 25, 1985, in response to our Inspection Report Nos. 50-456/83-09 and 50-457/83-09. We have completed our evaluation of your answers to the violations and other matters to which you responded and find that collectively your responses are acceptable. Regarding violation Items 1.c, 3.a. 3.b, 3.c, 4.d, and 6.a. your responses indicate that you do not believe them to be violations. With the exception of Item 4.d we continue to 1
believe those items are violations. We offer the following bases for cur conclusions:
Item 1.c e
We do not agree that the " accept as is" disposition of NCR BR-08 was adequate.
It is our position that any weld for which the welder is unknown is unacceptable and must be replaced. Your corrective action comitment to remove and replace any weld for which the welder identification cannot be established will acceptably resolve this issue.
1 Item 3.a l
The many welding procedure variables coupled with the lack of documentation and the limited verification activities by QC personnel led us to conclude that your welding controls were inadequate. We believe those inadequate controls may have contributed to the numerous deficient conditions identified i
by you in 1982-1983 which led to your 100% reinspection effort in this area.
i We believe your corrective actions since our inspection have resulted in your present welding ccntrols being acceptable. Your HVAC Veld Testing Program will provide us with adequate confidence regarding the quality of work completed under the previous welding controls.
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ff./Y8.b'f Comonwealth Edison Company 2
FEB 131986 Item 3.b Since not all welds could be properly inspected for fit-up after welding, it is clear that your controls should have required examinations for fit-up prior to welding to comply with AWS 01.1-1977. Additionally, ycur procedure (B10.2.F) was deficient in that it failed to specifically require a check for increased fillet size when a 1/16" to 3/16" fillet weld gap existed. These welding control deficiencies led us to conclude that your controls for these matters were inadequate. However, your corrective actions since our inspection have resulted in your present controls being acceptable. Your resolution of the NCR concerning lack of fit-up inspection, the results of your 100%
reinspection program, and your HVAC Weld Testing Program will provide us with adequate confidence regarding the quality of work completed under the previous fit-up controls. This item was closed in Inspection Report Nos. 50-456/85050 and 50-457/85048.
Item 3.c The lack of a program requirement for the examination of base metals for surface and edge discontinuities did not comply with AWS D1.1-1977. Your revision of procedure B10.2.F corrects that program deficiency. Uter reviewing the specific applications of the prior procedure, we believe
- that it is unnecessary for you to review past work for evidence of discontinuities. This item was closed in Inspection Report Nos. 50-456/85040 and 50-457/85039.
Item 4.d We agree that the conduct of your audits relative to the comencement of support selection activities was not untimely and indicative of an inadequate audit program in that area. Therefore, we retract this item as an example of the violation and will correct our records accordingly. Your followup audits since our inspection and your comitment to continue to monitor this activity 4
assure that similar support selection problems do not recur.
Item 6.a It continues to be our view that the Phillips-Getschow Company small bore piping and piping suspension system site activities involving field routing j
of piping, calculation of restraint loads, and selection of restraint types based on calculated loads have the ability to affect the quality of the final design. Therefore, we believe the violation to be proper as written.
4 We find the program revisions you instituted in response to our findings to be adequate to correct past deficiencies and to prevent the recurrence of future problems in this area.
4 i
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h N54'- Y Comonwealth Edison Company 3
FEB 131386 We will examine your corrective actions during future inspections.
Sincerely, Original signed by C. J. Paperiello Carl J. Paperiello, Director Division of Reactor Safety cc:
D. L. Farrar, D'irector of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent E. E. Fitzpatrick, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent cc w/1trs dtd 07/06/84, 07/23/84, 08/31/84, 03/11/85, 03/27/85, and 04/25/85:
DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel,'Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Moore, ELD G. Berry, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB
IV. CONCLUSION For the reasons set forth above, the Staff concludes that Applicant's Motion for Summary Disposition of portions of Intervenor Rorem, g al.'s QA contention should be granted in its entirety.
Re ifctfully submitted, N
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@ Counsel {for NRC Staff Elaine
. Chan I
gory n
B erry Okbs1&(
gl for41RC Staff Co
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p anice E Moon e Counsel r NRC Staff Dated at Bethesda, Maryland this 18th day of February, 1986
COLMETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'86 FEB 19 41 :59 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD gFFICE C m,
- 3..
In the Matter of
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hNNC
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456
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50-457 (Braidwood Station, Units 1 and 2
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE IN SUPPORT OF APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION OF PORTIONS OF ROREM'S AMENDED QUALITY ASSURANCE CONTENTION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, thia 18th day of February, 1986:
Herbert Grossman, Esq., Chairman
- Commonwealth Edison Company Administrative Judge ATTN: Cordell Reed Atomic Safety and Licensing Board Assistant Vice President U.S. Nuclear Regulatory Commission P.O. Box 767 Washington, DC 20555 Chicago, IL 60690 Dr. A. Dixon Callihan Region III Administrative Judge U.S. Nuclear Regulatory Commission 102 Oak Lane Office of Inspection a Enforcement Oak Ridge, TN 37830 799 Roosevelt Road Glen Ellyn, IL 60137 Dr. Richard F. Cole Joseph Gallo, Esq.
Administrative Judge Isham, Lincoln a Beale Atomic Safety and Licensing Board Suite 840 U.S. Nuclear Regulatory Commission 1120 Connecticut Avenue, N.W.
Washington, DC 20555 Washington, DC 20036 Michael I. Miller, Esq.
Elena Z. Kezelis, Esq.
Isham, Lincoln a Beale Three First National Plaza Suite 5200 Chicago, IL 60602
\\ i Douglass W. Cassel, Jr., Esq.
Atomic Safety and Licensing Board Timothy Wright, Esq.
Panel
- Robert Guild, Esq.
U.S. Nuclear Regulatory Commission 109 North Dearborn Street Washington, DC 20555 Suite 1300 Chicago, IL 60602 Atomic Safety and Licensing Appeal Erie Jones, Director Board Panol*
Illinois Emergcncy Services U.S. Nuclear Regulatory Commission and Disaster Agency Washington, DC 20555 110 East Adams Springfield, IL 62705 Docketing and Service Section*
Office of the Secretary Lorraine Creek U.S. Nuclear Regulatory Commission Route 1, Box 182 Washington, DC 20555 Manteno, IL 60950 Ms. Bridget Little Rorem H. Joseph Flynn, Esq.
117 North Linden Street Associate General Counsel Essex, IL 60935 FEMA 500 C Street, S.W., Suite 480 George L. Edgar, Esq.
Washington, DC 20472 Newman a Holtzinger, P.C.
1615 L Street, N.W.
Suite 1000 Washington, DC 20036 t
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Gregory 4 (n Bprry Counsel fa NRC Staff
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