ML20214C735
| ML20214C735 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/17/1986 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| References | |
| CON-#486-1585 OL, NUDOCS 8611210218 | |
| Download: ML20214C735 (17) | |
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November 17, 1986 ut1AIED coH* SPONDENC%
DOCKETED U9iRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI%# NOV 19 A11:05 BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD Yo$l cci,
fi BU UC5 In the Matter of
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o COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456
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50-457 (Braidwood Station, Units 1 and 2)
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NRC STAFF TESTIMON [d'F RONALD N. GARDNER REGARDING BRIDGET LITTLE ROREM, ET AL. SUBCONTENTION 2.C Q1. Please state your name and business address.
A1. My name is Ronald Nelson Gardner.
I am employed by the United States Nuclear Regulatory Commission, Region III, as Section Chief for the Braidwood Project.
My business address is 799 Roosevelt Road, Glen Ellyn, Illinois, 60137.
Q2. Please describe your resnonsibilities as Section Chief.
A2. I am responsible for supervising the implementation of the routine and reactive inspection program for the Braidwood Project during all phases of construction, testing, operations, and decommissioning.
Q3. Have you prepared a statement of your professional qualifications?
A3. Yes.
A statement of my professional qualifications is attached to this testimony as Exhibit 1.
8611210218 861117 PDR ADOCK 05000456 PDR T
Q4. Mr. Gardner, what is the purpose of your testimony?
A4. The purpose of my testimony is to describe the NRC's actions taken to assure that the Construction Sample Reinspection (CSR) element of the Braidwood Construction Assecament Program (BCAP) undertaken by Applicant was conducted in accordance with applicable procedures by competent personnel-and to explain the bases underlying the NRC's. conclusions concer'ning BCAP.
i Q5. Mr. Gardner, what did you understand 40 be the purpose of the CSR element of BCAP?
AS. In regards to the CSR element, BCAP was intended to provide additional assurance that there were no programmatic design significant problems in the construction of Braidwood which had not been identified and addressed.
Did the NRC require ' pplicant to implement BCAP?
Q6.
A A6. It is my understanding that BCAP was a program of reinspections and reviews undertaken by Applicant on it's own initiative to address NRC concerns regarding the overall quality of construction at Braidwood.
I have no knowledge of any actions taken by the NRC to impose DCAP on Applicant.
Q7. What involvement did you have with respect to BCAP?
A7. I was assigned as an onsite inspector to monitor the implementation of the BCAP.
I received this assignment in August 1984.
Q8. Fr'om whom did you receive your assignment?
A8. I received my assignment from Mr. Charles Norelius who was and is the Director of the NRC's Division of Reactor Projects for Region III.
Q9. Why were you selected for this assignment?
AD. I understand that my selection was-; based, in part, on the experience I gained as the project inspector-for the Midland Nuclear Power Facility.
While at Midland, I was involved in a similar reinspection program.
Q10. What, if
- any, instructions did you receive regarding your responsibilities as the BCAP inspector?
A10. I was instructed to overview the BCAP program to ensure that it i
was properly implemented.
My instructions were communicated orally by Mr. Robert Warnick and Mr. William Forney.
Mr. Warnick was the Branch Chief responsible for Braidwood, while Mr. Forney was the Braidwood Section Chief.
Q11. Please describe generallv the methodology you used in monitoring BCAP.
All. From August 20, 1984 to June 1985, I was at the Braidwood site i
monitoring the BCAP program.
During this time period I performed daily inspections which focused on some of the more key aspects of BCAP.
With regard to the CSR element of BCAP, these key aspects included:
(i) qualification of BCAP personnel; (ii) training of BCAP l
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pe'rsonnel; (iii) BCAP Quality Assurance; (iv) Independent Expert Overview Group; (v) adequacy of CSR procedures, checklists, and instructions; (vi) performance of CSR reinspections; and (vii) evaluation of discrepancies identified by CSR inspectors.
Q12. Why did you regard these aspects as impo~ tant?
r A12. Each of the items listed was considered.important because it had the potential to affect in a significant way the results of the CSR reinspections.
For example, lack of precision and clarity in the CSR inspection procedures or checklists c'ould have undermined the quality of CSR reinspections.
Similarly, lack of effective overview by tha IEOG could have lessened confidence in the accuracy of CSR observations and discrepancy evaluations.
For these reasons, I was particularly sensitive to those aspects of the CSR element of BCAP.
Q13. How did you inspect the items listed in All, of your testimony?
A13.
I considered it essential that the BCAP personnel involved in the development of BCAP CSR procedures, checklists, and instructions or performing CSR reinspections had the sufficient educational background and qualifications necessary to perform those functions.
Consequently, during my inspections of BCAP, I
reviewed a number of resumes of BCAP personnel, including those of BCAP taskforce engineers and BCAP CSR inspectors.
In addition, I had frequent contact with numerous BCAP engineers and inspectors I
which provided further opportunities for me to evaluate their competency.
Due to the numerous BCAP implementing procedures, instructions, and other documentation unique to the BCAP, and thus new' to many BCAP personnel, appropriate training to those documents was essential to the success of BCAP. Therefore, during my initial inspections of BCAP I reviewed BCAP personnel training records, observed BCAP training classes, and reviewed BCAP training documentation.
Another key aspect was the Quality 2 Assurance component of BCAP.
BCAP QA was charged with the task of conducting reviews, verifications, audits and surveillances 'of BCAP.
Throughout my tenure as the BCAP inspector I dedicated a significant portion of my daily inspection activities reviewing BCAP QA.
These activities included reviewing BCAP QA personnel training and qualification records, reviewing audits and surveillances conducted by BCAP QA, interviewing BCAP QA personnel, and overviewing BCAP QA reinspections.
Applicant retained the Evaluation Research Corporation (ERC) as the Independent Expert Overview Group (IEOG) for BCAP.
As the IEOG, ERC was responsible for performing an independent overview of BCAP.
Thus, I considered ERC to have a significant role in assuring the adequacy of BCAP.
As with BCAP QA, I dedicated a significant portion of my daily inspection activities in observing and reviewing the performance of the ERC overviews of BCAP.
The CSR element of BCAP was to be implemented in accordance with approved procedures, checklists, and instructions.
Conse-quently, I placed heavy emphasis and devoted much time at the front end of my BCAP inspection reviewing and commenting on these documents.
I held a number of meetings with BCAP personnel during which my comments regar, ding these documents were discussed.
I was assisted in this review by both resident and regional inspection personnel.
The satisfactory performance of CSR reinspections was perhaps the most crucial aspect of the CSR element of BCAP.
Accordingly, after the CSR reinspection effort was begun, I dedicated a significant portion of my daily inspection activities towards the overview of CSR reinspections.
This was accomplished through assuring the adequacy of CSR reinspection checklists and instructions, the assurance that CSR inspectors were qualified, that BCAP QA was performing effective overviews of CSR reinspections, that the IEOG was performing effective overviews of CSP.
reinspections, and through my own overview of CSR inspectors.
Since the focus of the NRC's attention to the results of DCAP was directed towards the identification of previously unidentified design-significant problems in the construction of Braidwood, I considered the evaluation of discrepancies to be a key aspect of the BCAP.
With the initiation of CSR reinspection activities and the subsequent initiation of BCAP observations, I initiated periodic reviews of BCAP observations and their subsequent evaluation.
As the number of observations increased, I requested and received
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regional support in the review of the technical adequacy of those observations.
Regional personnel who performed reviews of BCAP observations included J. Muffett, R. Mendez, and Z. Falevits.
Q14. Were the provisions of 10 CTR Part 50, Appendix B, applicable to BCAP7 A14. Yes.
s Q15. To your knowledge, did Applicant ever take the position that the requirements of 10 C.F.R. Part 50, Appendix B, were not applicable
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to BCAP?
A15. No.
Q16. Did you ever suggest to Applicant that it not present the results of BCAP on the basis of inspection polats?
A16. Yes.
Although I do, not now recall the date of the meeting, I did meet with Applicant on one occasion to discuss my concern that the presentation of CSR reinspection results utilizing only inspection point data without also presenting those results on an item basis would not provide a balanced portrayal of the CSR reinspection results.
The meeting was held in response to Applicant's decision to adopt an inspection point methodology in presenting CSR reinspection results.
Q17. Did Applicant ever make a commitment to the NRC not to present the results of BCAP on an " inspection point" basis?
l A17. No, not to my knowledge.
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Q18. Mr. Gardner, did the Applicant breach any commitment to the NRC by assigning Sargent & Lundy, Applicant's Architect-Engineer, the task of evaluating discrepancies found by BCAP CSR inspectors?
A18. Not to my knowledge.
Q19. Are you, or were you ever, concerned that Sargent a Lundy was assigned the task of evaluating discrepancies found by BCAP CSR inspectors?
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A19. No. sal is responsible for developing 'the design drawings and specifications to which Braidwood is constructed.
Thus, it would have the greatest expertise in evaluating the significance of discrepancies in Braidwood's construction.
Also, since S&L did not perform construction activities, there would be no reason why it would be adversely influenced by identifled construction defects.
Q20. Mr. Gardner, are you familiar with the " midpoint look" as that term has been used in this proceeding?
A20. Yes.
Q21. What role, if any, did you have in the decision to suspend temporarily the CSR reinspections?
A21. As stated in NRC Inspection Report Nos. 50-456/85002; 50-457/85002, I met with Mr. Kaushal, the BCAP Director, on January 23, 1985, to discuss the need for significant actions to address the issue of BCAP reinspection discrepancies.
By that time, discrepancies in BCAP CSR reinspections had been identified by the NRC Construction
Appraisal Team (CAT) in the area of mechanical pipe supports and by ERC in the areas of electrical conduit hangers and concrete placements.
The CAT inspection had identified deficiencies on three of six pipe supports / restraints previously reinspected by BCAP CSR inspectors.
These deficiencies had not been identified by the BCAP CSR inspectors.
The ERC overinspectioris identified deficiencies on two conduit hanger installations which had not been identified during the BCAP CSR reinspections.
In addition, ERC overinspections identified four deficiencien associated with a concrete placement.
t These deficiencies were also not identified during the BCAP CSR reinspections.
Due to the number of instances in which BCAP reinspections failed to identify construction deficiencies, I suggested Applicant suspend CSR reinspections until adequate measures were adopted to ensure that similar discrepancies did not recur.
Q22. Were the actions taken by Applicant adequate to resolve to the NRC's satisfaction the discrepancies identified by the CAT and ERC?
A22.
Yes.
As identified in NRC Inspection Report Nos.
50-456/86003; 50-457/86003, a number of actions were taken to address the identified BCAP reinspection discrepancies and to assure that future BCAP reinspections were performed in an acceptable manner.
These actions included the partial repeat reinspection of previously reinspected mechanical pipe supports, the review of electrical conduit support packages, the implementation of additional I
training for BCAP incpectors, the revision and clarification of BCAP checklists and instructions, and the initiation of the BCAP QA overview of BCAP reinspections.
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In my opinion, the suspension of CSR reinspections, in itself, had the greatest effect on improving subsequent CSR reinspections.
This. is because I believe the root cause of previous reinspection deficiencies was due to the fast pace at which the BCAP inspectors were working.
As a result of the suspension, Applicant reduced the pace of CSR reinspection activities,and increased the quality of subsequent CSR reinspections.
The effectiveness of Applicant's actions were proven effective during subsequent
- NRC, QA, and IEOG overviews of BCAP reinspection activities.
Q23. Mr. Gardner, did you identify any violations with respect to the CSR portion of BCAP?
A23. Yes.
I identified three violations, each of which is documented in an inspection report.
Q24. Please describe each violation you identified.
A24.
The first violation is documented in NRC Inspection Report Nos. 50-456/84025; 50-457/84024 and concerns instances in which Applicant failed to comply with the BCAP training requirements for l
QA personnel who perform formal reviews of BCAP procedures.
In the course of my inspection, I determined that two DCAP QA individuals, who had reviewed two BCAP procedures, had not completed the required site orientation. While I had no concern with the adequacy of the reviews which these individuals had performed, I was concerned that the QA organization responsible for ensuring l
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BCAP taskforce compliance with BCAP procedures had failed to note their own noncompliance.
I felt it important that BCAP QA be aware that I would be closely monitoring their activities.
Corrective actions taken by Applicant included the completion of site orientation by all BCAP QA personnel and the revision of the pertinent training requirement.
I reviewed QA personnel training records and reviewed the revised training requirements.
Based on these reviews,
I determined that the ; corrective actions were acceptable.
The second violation is documented in Inspection Report Nos. 50-45G/85006; 50-457/85006.
This violation concerned Applicant's failure to initiate a BCAP observation documenting the use of Level I L. K. Comstock QC inspectors for the purpose of inspecting and accepting welds.
This violation was subsequently withdrawn based on my determination that Applicant had initiated an observation.
The third violation is also documented in Inspection Report Nos. 50-456/85006; 50-457/85006.
This violation concerned the invalidation by BCAP of 37 BCAP observations even though the documented basis for the invalidation of the observations did not support the invalidations.
My concern with this issue dealt with the lack of adequate basis for invalidating BCAP observations.
Corrective actions taken by Applicant resulted in the establishment by BCAP QA of mandatory hold points during the processing of invalid observations to allow BCAP QA the opportunity to substantiate justification for invalidation.
BCAP QA also conducted J
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reviews of previously invalidated observations to ensure that sufficient justification for the invalidations was evident.
I reviewed the BCAP QA records which documented the results of the BCAP QA review of invalidated BCAP observations.
The records indicate that BCAP OA identified comments requiring resolution for a number of the reviewed invalidated observations.
Based on my review of the BCAP QA records and my review of invglidated BCAP observations, I determined that the corrective actions were : adequate.
Q25. Did the NRC reach a conclusion regarding the effectiveness of the BCAP program?
A25. Yes.
In Inspection Fecort Nos. 50-456/86003; 50-457/86003, the NRC concluded that the BCAP program was satisfactorily designed and implemented and'that the results of the BCAP provide additional confidence in the acceptability of the past, ongoing, and future construction activities at Braidwood, Q26. What was the basis for that determination?
A26. That determination was based upon the Region III inspections and the results of my inspections of the key aspects of BCAP identified in All, of my testimony.
The results of my inspections of each of the key aspects disclosed the following:
1.
BCAP task force personnel, who were primarily CECO, Stone and Webster, and Daniel Construction Company personnel, were qualified for their assigned tasks and had a good balance of education and experience in the nuclear industry; l
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early problems identified in the area of BCAP personnel training were dealt with in an expeditious manner resulting in a well defined and well executed training program; 3.
BCAP QA organization responded promptly and effectively to an early NRC finding.
Subsequent reviews of BCAP QA revealed that organization to be staffed.witli qualified individuals who performed in a highly satisfactory nianner; 4.
IEOG audits, reviews, and overinsp'ections were timely and effective, and thus provided a valuable overview of all aspects of the BCAP program; 5.
during the initial stages of the BCAP program, BCAP procedures, check 14ts, and instructions were subjected to cxtensive scrutiny which resulted in a number of revisions to those documents.
Ilowever, I found the procedures, checklists, and instructions which were utilized during the implementation of the BCAP prbgram to be comprehensive, well-organized and adequate to address all areas of the BCAP program; l
6.
a major focus of the NR C's inspection effort was directed towards the performance of CSR reinspections.
I observed I
BCAP CSR reinspections, BCAP QA overinspections, and IEOG overinspections.
In addition, I reviewed the results of the NRC Construction Appraisal Team (CAT) inspection of I
components previously reinspected by BCAP CSR inspectors.
In response to CAT and IEOG findings, Applicant suspended i
DCAP reinspections and initiated adequate corrective actions.
These corrective actions proved effective during subsequent
NRC and IEOG overviews of BCAP reinspection activities and contributed to an overall satisfactory assessment of BCAP CSR l
reinspections; and 7.
as stated in Inspection Report Nos. 50-456/86003; 50-457/86003, the evaluations of the discrepancies identified during the BCAP Project were technically accurate _ and were performed in
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accordance with applicable BCAP procedures.
The records of the observations and their evaluations were maintained in a manner such that the complete docudientation associated with a discrepancy was readily retrievable.
Q27. Does this complete your testimony?
A27. Yes.
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3 Professional Qualifications s
RmAID N. GARINEP.
U.S. Nuclear Regulator' Conmission, Region II m GANIZATim:
/
TI'ILE:
mief, Braidwood Section Division of Reactor Projects BIIGH IKIE:
June 19, 1945 1968
,1970, 'Ihanas Ne[ sori Connunity College EDUCATIm:
1970 - 1972, Virginia Polytechnic Institute, E.S. In Electrical Engineering 1975, Department of the Navy, ~ Ship Superintendent School (Nuclear)
EXPERIDE:
February 1986 to Section mief - NRC - Supervises the implanentation Present of the routine and reactive inspection program for Braidwood.
July 1, 1985 to Project Inspector - NRC - Maintaining status of February 1986 operational and regulatory perfonnance of operating reactors.
August 1984 to Project Manager - NRC - Manages and coordinates July 1, 1985 inspections / investigations of BCAP activities to assure that the program is being conducted in accordance with regulatory requirements and licensee ccumitment s.
October 1982 to Project Manager - NRC - Coordinate licensing August 1984 activitles and perfonn inspections on reactors under construction (Office of Special Cases).
October 1980 to Electrical Engineer - NRC - Perfonn electrical
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October 1982 inspections on reactors under construction.
1977 to 1980 Electrical Engineer - Daniel Construction Cocpany -
Responsible for systens conpletion and cable tenni-nations on nuclear plants under construction.
. l 1975 to 1977 Electrical Thgineer - Norfolk Naval Shipyard -
Esponsible for timely overhaul of Nuclear Subnarines.
1972 to 1975 Electrical Test Engineer - Newport News Shipya14 -
Responsible for testing of electrical systens on Nuclear Furface Ships.
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UNITED STATES OF AMERICA
'y NUCLEAR REGULATORY COMMISSION g g 19 A11:05
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BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD
- - ~. E 4 0FF n t' 00CKEIN O ', N~
In the hkatter of
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4 COMMONWEALTil EDISON COMPANY
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= Docket Nos. 50-456 50-457
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(Braidwood Station, Units 1 and 2
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CERTIFICATE OF SERVICE I heraby certify that copies of "NBC STAFF TESTIM NY OF RONALD N.
GARDNER REGARDING BRIDGET LITTLE ROREM~,'.2T AL. SUBCONTEN-g' IION b.C" in the above-captioned proceeding'have Seen served on thd following by deposit'in the United States mail, first class; or as indicated by an (*) through deposit in the Nuclear Regulatory Commission's internal mail system this 17th day of November,1986:
Ilerbert Grossman, Esq., Chairman
- Commonwealth Edison Company ATTN:
Cordell Reed Adminintrative. Judge Atomic Safety and Licensing Foard Assistant Vice President U.S. Nuclear Regulatory Commission P.O. Box 767 Washington, DC 20555 e
Chicago, IL 60690 Dr. AZ Dixon Callihan Region III U.S. Nuclear Regulatory Commission Adminictrative Judge Office of Inspection & Enforcement 102 Oak Lane 799 Roosevelt Road
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Oak Ridge, TN 37830 Glen Ellyn, IL 60137 Dr. Richard F. Cole Joseph Gallo, Esq.
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i Isham, Lincoln a Beale Administrative Judge Suite 1100 Atomic Safety and Licensing Board 1150 Connecticut Avenue, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC. 20036 f
Michael I. Miller, Esq.
Elena Z. Kezelis, Esq.
Isham, Lincoln & Beale Three First National Plaza Suite 5200
-Chicago, IL 60602
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O O Douglasis 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 Panel
- Illinois Emergency Services U.S. Nuclear Regulatory Commission and Dicaster Agency Washington, DC 20555 110 East Adams
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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 Es'ex, IL 60935 Associate General Counsel s
FEMA 500 C Street, S.W., Suite 480 George L. Edgar, Esq.
Newman & Holtzinger, P.C.
Washington, DC 20472 1615 L Street, N.W.
Suite 1000 Washington, DC 20036 EIaine I. Chan Counsel for NRC Staff 9
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