ML20079L989
| ML20079L989 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/22/1983 |
| From: | Arrington T, Joseph Kelly, Museler W LONG ISLAND LIGHTING CO., STONE & WEBSTER ENGINEERING CORP. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8302230536 | |
| Download: ML20079L989 (31) | |
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WTED CORRESPOhDENCR DOCKETED UT!rC T.9 22 fl.1 59 UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)
)
(Shoreham Nuclear Power Station, )
Unit 1) )
SUPPLEMENTAL TESTIMONY OF MESSRS. MUSELER, ARRINGTON, AND KELLY CONCERNING I&E INSPECTION REPORT NO. 50-322/83-02 *
- 1. Would you state your names and your business affiliations and positions?
A. My name is William J. Museler, and I am employed by the Long Island Lighting Company as Manager of Engineering and Construction for Shoreham Nuclear Power Station.
My name is Tracy T. Arrington, and I am employed by the Stone & Webster Engineering Corporation, and I am Superintendent of Field Quality Control at the Shoreham Nuclear Power Station.
My name is Joseph Kelly, and I am employed by the Long Island Lighting Company as Manager of the Field Quality Assurance Division at the Shoreham Nuclear Power Station.
F302230536 830222 (DRADOCK 05000322 PDR f
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Q. Has each of you previously submitted a statement of
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professional qualifications in connection with this contention?
A. Yes.
Q. What is the purpose of this testimony?
A. The purpose of this testimony is to furnish the
, Board and the parties with LILCO's response as of this time to notice of violations contained in I&E Inspection Report No.
50-322/83-02. LILCO's formal response to the NRC is in preparation and will be submitted to I&E as required. This ,
testimony also furnishes the Board and the parties with information concerning housekeeping and final inspection matters referred to in Report No. 50-322/83-02.
Q. Appendix A, Notice of Violation of Inspection Report No. 50-322/83-02, lists four Level IV violations.
Please give LILCO's response to paragraph A of Appendix A and, if appropriate, include in your response the LILCO corractive 1
I or preventive action.
A. The three parts of paragraph A of Appendix A will be addressed separately.
(1) Welds on CRD Piping Supports
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In this specific instance, the NRC inspector noted Reactor Controls, Inc., welds on control rod' drive
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hydraulic line supports which were completed with fit-up gaps.
The welds were performed and inspected to drawings which did not specify a gap requirement. When the weld was inspected, the inspector, as had the welder, believed the gap was allow-able.
Tne cause of this situation appears to be the lack of specificity with respect to the gap requirement.
Beyond that all steps in the process were correct. Preliminary engineering analysis indicates that allowable stress levels may be exceeded due to the existence of the gap, but that stress will not exceed yield strength, and therefore the condition would not constitute a safety hazard. ilore detailed analysis is being performed to determine whether or not rework will be required to ensure allowable stress levels are not exceeded. A reinspection of 100% of all RCI pipe support welds of this type. In addition, the applicable design documents are being modified to ensure no ambiguity exists for work which may be l done in the future.
1 (2) Completed RHR System Hangars (a) Bolt Torcue on Pipe Support Ell-SPA-109 l
The NRC found that two bolts on a pipe support were not able to be loosened by hand when the design document called for " hand tight" conditions. Further, when the
c bolts were removed for correction of this perceived problem, a significant amount of force (unmeasured) was required for re-moval. Since this pipe support had been final inspected by FQC, the NRC concern was that additional items of this type (hand tight bolt requirements) might be present in other areas of the plant. LILCO believes that the bolts in question were properly installed and that the Quality Assurance Program in this case did function effectively. We do not believe there was, in fact, any nonconforming condition in the field for the following reasons:
- 1. The nuts and bolts in question had been installed for some time and the difficulty in removing the nuts can be attributed in part to normal oxidation of the mating surfaces.
- 2. The nut in question was secured by a lock nut, and the process of in-stalling lock nuts sometimes results in slight additional tightening of the principal nut, and therefore the appearance of tightening in excess of the " hand tightness" requirement would not be unusual.
- 3. Field inspections conducted since this NRC inspection and subsequent to rework of those two nut-bolt combinations (at three different times several days apart) indicated that the reworked nut / bolt combina-tions have been variously " loose,"
" tight" and " loose" based on the tims of the inspection. We there-fore believe that the condition observed by the NRC Inspector is consistent with a properly " hand tight" installed nut / bolt combina-tion under the various operating conditions that the particular pipe support is expected to experience.
W
-S-It was verified by the NRC that the proper bolting material had been employed. In addition, this condition has been reviewed by Engineering and judged that even if the nut / bolt had been tightened significantly beyond the " hand tight" criteria, the pipe support would still have functioned
- properly. We would emphasize, however, that we believe that the original installation was correct, and the inspections required were carried out and verified the correctness of the installation at the time of the nspection. We have further verified that there are only two pipe supports of this type in the Plant.
(b) Bearing Gap between Lugs and Pipe Clamps The NRC noted that there was not full con-l i
tact between the lugs welded to piping (four lugs) and the pipe clamps supporting that pipe'in the vertical direction on supports E11-PSSH-173 and E11-PSSH-184 as required by the " full bearing" provision of E&DCR F-1748S. The NRC also believed that on one of the supports, only three of the four lugs were in contact with the pipe clamp. This observation later turned l
out to be invalid as subsequent FQC reinspection indicated that, in fact, positive contact was being achieved on the lug j in question. The NRC was also concerned that GE criteria for l
GE supports delineated on E&DCR F-33350C were being used as ac-ceptance criteria for SWEC supports instead of E&DCR F-1748S.
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With respect to the issue of " full bearing" (i.e.,
complete surface contact between the mating surfaces),
Engineering has reviewed the condition and determined that
" positive bearing" (meaning that each lug is, in fact, in some contact with the pipe clamp) is an acceptable condition from a technical standpoint. Further, the two supports inspected by the NRC had an angled surface on the clamp where it contacted the lug. Therefore, " full bearing" is not possible without specific machining operations which were neither required nor necessary.
E&DCR F-1748S, however, did call for " full bearing,"
and the final inspection did not document the presence of "pos-itive bearing" (which existed) as opposed to " full bearing" of all surfaces of the clamp / lug interface. We believe the particular FQC inspector involved found the condition accept-able based on his interpretation of the documentation package to which he was inspecting. That documentation package includ-ed prior approval granted by Engineering for a previously iden-
- 1fied reduced surface contact condition. This prior approval is consistent with the recent Engineering review of the condition and with the overall intent of this particular design detail since the only way to achieve absolute " full bearing" would be to have machined surfaces on both parts. Therefore, the " positive bearing" requirement represents the actual Engineering requirement for this configuration. In order to
verify further that adequate bearing for this type of a configuration was achieved, even on supports not employing the specific clamp / lug design encountered on supports E11-PSSH-173 and Ell-PSSH-184, LILCO is reinspecting all supports of a similar configuration for this attribute.
With respect to application of the SWEC versus the GE E&DCRs for construction and inspection of clamp / lug joints in the vertical configuration, the UNICO Supervisor originally 1
questioned by the NRC Inspector did not fully understand the NRC Inspector's question, leading to an NRC concern that the 1
appropriate E&DCRs had not been applied in the construction and inspection process for SWEC and GE pipe supports of this con-figuration. In fact, we have verified that the SWEC scope pipe supports of this configuration were installed and inspected to the appropriate document (E&DCR F-1748S) and that the GE supports of this cenfiguration were installed and inspected to
, their appropriate document (E&DCR F-33350C.) Evidence of this was obtained through review of inspection records which specif-ically noted these E&DCRs on the inspection records.
(3) Cable Tray Supports (CAB TRAF)
RB100B, RB208A, and RB131 _
This situation involves three observed conditions on cable tray supports. Each will be separately discussed.
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(a) RB100B
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The NRC Inspector noted on the as-built draw-ing that on one tier of a three tier cable tray support, the as-built drawing showed one cable tray whereas in the field two cable trays were, in fact, installed. The configuration of the cable tray support was in accordance with the Design Documents.
The as-built drawing utilized by the NRC Inspector was a new support drawing developed in the as-built program as a result of a walkdown. During the walkdown, the designer failed to observe the second cable tray in that location. Again, the cable tray supports and cable trays themselves were properly installed in accordance with appropriate design documents. The as-built support drawing will be revised to reflect the second tray. In summary, no further preventive or corrective action is being initiated because the constructed condition is in ac-cordance with the design, the occurrence has no implications with respect to the adequacy of the plant, and we have no basis to believe that this is other than an isolated human error.
The as-built support drawing, which reflected the error in this regard, was not a document used for analyses in connection with raceway location.
The purpose of this as-built support drawing is to reflect the final support configurt. tion and location, and it do so accurately; its purpose is not to control raceway lo-cations. Cable tray locations are controlled by the raceway support schedule.
We have confirmed that this schedule correctly reflects the as-built raceway configuration.
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(b) RB208A At the outset, it must be noted that the 1
specific cable tray support involved here was correctly installed in conformance with the applicable design documents.
- However, the ac-built drawing depicted a concrete beam on the i
! wrong side of the support for the view (west) noted on the drawing. It should also be noted that a diagonal brace, such e
- as the one in question, could be installed either way (going down left to right or going up left to right) and would perform exactly the same function since the seismic loading is applied in both directions horizontally to the tray support. This was i-t a drafting error. The corrective action included a revision of the as-built drawing and a field check of 12 additional cable tray supperts having an east / west aspect and their associated as-built drawings. This field check disclosed no similar errors in drafting the as-built drawings. One minor discrepan-cy of a section view was observed and will be corrected on the as-built drawing. In addition to this, a formal training pro-( gram for all FQC inspectors responsible for inspections in the elecrical as-built program has been conducted. LILCO believes no further action is required.
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(c) RB131 The NRC Inspector noted in this case that a diagonal brace termination was locates one foot above the ter-mination point indicated on the as-built drawing and indicated on the original design drawing for this support. The brace was originally installed in the correct location. However, as a result of the CAE TRAP reanalysis program, the FQC inspection identified the need to install modified hardware at the lower termination point of the brace.
The correct hardware was installed, but to do so required movement of the termination point to the existing location. Since the FQC inspector reinspected this support (same inspector) for only the modified hardware called for on the previous inspection report and having already verified that the brace was in the correct loca-tion, he did not reinspect for correct location. Investigation also revealed that the brace was installed in the only possible configuration given the new hardware installation requirements.
We have confirmed by our Engineering review that ad-justment of the diageaal brace termination location is accept-
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able from an Engineering standpoint. The corrective and pre-ventive action in this instance included an engineering verifi-cation that the as-built condition was acceptable and the revi-sion of the as-built drawing. Also we verified through 5 interviews that personnel performing work in the field are $
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aware of and are implementing their responsibility to obtain prior approval for deviations from specified conditions. ~
Q. Please give LILCO's response to paragraph B of Appendix A and, if appropriate, include in your response the LILCO corrective or preventive action.
A. The NRC's concern was that verification cf hangar cold set, specifically the pulling of the shear pin, was not being adequately verified. We reviewed this matcer and have concluded that existing site programs adequately ensure that hangar cold set verification occurs at the appropriate time.
For example, there is a requirement, which preexisted the NRC inspection, to check pins pulled prior to fuel load. In addition, the Construction Site Inspection Program has required the inspection of the attribute to be noted on the construction inspection program forms for all supports of this type in the secondary containment. We have reviewed the two specific spring cans referenced in the NRC report and found them to be in the condition called for by the site programs. Thus, the observed condition was not different from the required condition, but rather was appropriate and controlled. Also, 12 additional spring cans were checked and found to be in the l correct configuration. (Six of these had already had the cold l
l set verified, and the other six were in process with the shear pins still installed as required.) While LILCO considers the I
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existing programs adequate, we agree with the NRC that a more rigorous accounting system for the cold setting of pipe ~
supports prior to fuel load will be beneficial in providing ad-ditional assurance that the final configuration is correct.
Accordingly, LILCO established, effective February 2, 1983, a program composed of the following elements:
a.
An additional CIP form (Construction Inspection Program) will be generated for each spring can in the Plant (safe-ty related and non-safety related) highlighting the cold setting require-ment.
b.
All hangars will be reinspected for this specific attribute prior to fuel load (a directive which existed prior to inspection 83-02) and the CIP form will be filled out and forwarded to the Resident Engineering Office for inclu-sion in the permanent Plant files.
c.
In addition to individual inspection forms for each spring can, an overall reverification sheet by System will be established for all spring cans in 1
every System.
- d. i The Master -anch list has had this ver- i ification included as a line item for each system.
LILCO believes this additional precaution is acceptable to the NRC and that no further action is required in connection g with this matter. a g
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Q. Please give LILCO's response to paragraph C of h Appendix A and, if appropriate, include in your response the 5 il LILCO corrective or preventive action. it
A. Paragraph C cf Appendix A notes that the inspectors observed the following conditions:
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- 1. Construction did not notify QC prior to working on safety related platform number 21 in the secondary containment, and on main steam line restraint number 30 within primary containment.
- 2. The cover sheets for safety related E&DCRs F39112 and F39190 did not specify that drawing number 1.61-207 was affected by these E&DCRs.
- 3. No discrepancy had been noted in elementary diagram 1.61-207F al-though testing conducted per CG 000.007-5 on the Yellow Line Master
- Drawing 1.61-207E indicated that E&DCRs F39112 and F39190 had been incorporated into Reactor Core Isolation Cooling System circuitry.
Each of the observed cond?.tions will be addressed sepa-rately.
(1) A portion of the quality assurance program requires construction to advise FQC of work being performed after FQC has inspected previous work. This is true in the case of both inprocess and final inspection. Under this proce-dural control, construction advises FQC by submittal of an appropriate notification form. This is a redundant procedural control over and above the direct receipt by FQC of any document which directs work to be performed at the plant which must ultimately be inspected by FQC.
In the specific instances raised in this portion of the violation, the work involved was structural steel activ-ity. In one case, platform 21 in the secondary containment was being modified, and, in the second case, additional structural steel in the form of a monorail was being attached to a main steam restraint (MSR-30). LILCO agrees that in these irstances a notification form should have been submitted to FQC but was not. In each case, however, notification was achieved through the delivery to FQC of the doct:ments to which the work was being performed. These documents would have triggered addi-tional inspection by FQC. In addition, the final inspection remained for the installations in both activities in question.
Although the notice of violation indicates that this procedure is used whenever work activity affects final QC-accepted items, that it not the case. The procedure applies, as we have stat-ed, following completion of either in-process and final QC in-spections.
In these cases, the notification forms were not submitted by construction as the construction force was not aware that FQC in-process inspection had been performed on these items. In the structural steel area, in-process inspec-tion is an ongoing activity and no formal notification of com-pleted inspections is required to be submitted by FQC to Cons *ruction. In the particular case of the attachment of a monorail to the main steam restraint, the structural steel
monorail attachment to the restraint was not part of the restraint and came under a separate, new inspection which would asure that both the monorail was properly installed, and the restraint continued to be acceptable after installation of the monorail. The monorail installation was a new and separate component requiring full FQC inspection after completion of the work.
To facilitate identification of work which requires notification to FQC, FQC has initiated a procedure which requires the tagging of all items which have received FQC inspections as well as formal notification to the construction organization. This will allow for more positive determination by construction of the need for a notification form when work is conducted.
(2) We have evaluated the situation involving E&DCRs F-39112 and F-39190 and have determined that the appropriate document control program requirements were applied and func-tioned properly. These E&DCRs did list the correct affected drawing numbers on them. The referenced drawings were multiple sheet drawings, and the E&DCR properly noted only the SWEC number of the first sheet. Accordingly, no corrective or pre-ventive action is required.
(3) The NRC's concern was the apparent failure of the responsible test engineer to note, as a discrepancy, the fact
there were outstanding EEDCRs not posted on the drawing being used for the test. In fact, the E&DCRs were correctly posted on the first sheet of a multi-sheet drawing (Revision E) being used by the test engineer. Thus, there was no discrepancy to note. The inspector identified on site a later revision (Revision F) which was issued after the test and which did not have the E&DCRs incorporated. In fact, the E&DCRs were issued after Revision F and were correctly posted on'the first sheet i
. of the Revision F drawing, as they had been on the Revision E drawing of record for the test. In fact, Revision G was issued on December.4, 1982, in Boston, and was in transit to the site at the time of the inspection. This revision does incorporate the E&DCRs in question. Therefore, no corrective or preventive actions are required.
Q. Please give LILCO's response to paragraph D of Appendix A and, if appropriate, include in your response the LILCO corrective or preventive action.
i A. Paragraph D of Appendix A notes that the inspectors observed the following conditions:
- 1. A tubular support weld varied from its design drawing detail because it failed to wrap around the entire fit-up joint, as required; i
- 2. A welding technique used in the re-work was not qualified for the
, angular orientation encountered in the field; and 4
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- 3. High-strength bolting installations did not conform to applicable AISC Code requirements in that several -
bolted joints had their washers missing, and ASTM A490 bolts in these installations had been retorqued.
Conditions 1 and 2 are essentially the same and will be treated together, and condition 3 will be treated separately.
(1)
Conditions 1 and 2 are the same condition result-ing directly from the physical configuration of the joint.
This situation involved a tubular support attached to a flat surface at a sharp angle, resulting in a small area that was unweldable due to lack of accessibility. A four-sided weld was called for using a technique suitable for either three-sided or four-sided welding. The weld was performed to the extent pos-sible considering the inaccessibility of the small angle por-tion of the installation. The inspector accepted the weld be-cause he did not observe the small amount ( es/ 1/2") of weld material missing.
This has been confirmed in an interview with the inspector.
The weld technique which had been used in the field was qualified for the orientrxion except that it could not be used in the area where the setup angle was less than 30 degrees.
The weld could not be performed in full compliance with the drawing because of the accessibility considerations. 1 Actual installation resulted in an angle of less than 30 de-
- grees.
As we now know from the evaluation, a full, four-sided i
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circumferential weld is not required for this support member.
Had engineering known that field adjustment would result in
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less than 30 degrees, a three-sided weld would have been called for using the same weld technique, which is in fact the final installation achieved. This was an isolated instance of an
- inspector failing to observe a small amount of missing weld.
1 only two other welds of this type exist, and, in the remaining two crises, the angle was greater than 30 degrees, making the I joint fully accessible.
The installation matched exactly the
- engineering requirements.
The co:rective and preventive action required for these two conditions was to confirm by engineering review that the l
small amount of weld material missing was acceptable. No re-work was required.
All documentation will be conformed to the actual inst,allation. Additional corrective and preventive actions included review of the other two similar installations which were found to be correct. This matter has been thor-oughly discussed and reviewed with the inspector and the welder. As a result of this interview with the inspector, it was apparent that the inspector was aware of the requirement for a full circumferential weld and conducted his inspection to that requirement, but simply missed it. The welder, who had i performed a number of welds of this tupe, thought he had satis-factorily completed this weld. Further, when asked, the welder i
stated that he was familiar with and complied with the t
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r requirement to obtain Engineering approval for deviations from design drawings. Accordingly, we believe this to be an iso-f lated instance.
(2) The third condition in paragraph D of Appendix A involved specific high strength bolting installations where
( washers were not used as required by the applicable code and where bolts were retorqued. We have reviewed all work done by the start-up support personnel and have confirmed that this was the only instance where they were required to use high strength bolting material on hangars. This high strength bolting l
material is used in only a few locations throughout the plant.
For example, we reviewed 250 pipe supports for this condition and found only three instances where A490 bolts were called for and used, and in these three instances the bolting configura-tion was confirmed to be correct. We have reviewed the site programs for this type of bolting material and performed addi-tional field inspections and ascertained that this was an iso-lated instance limited to these three particular turbocharger supports. It should be noted, however, that an engineering review of these conditions (both the absence of washers and the I
l retorquing) was performed and the adequacy of the support
! confirmed notwithstanding the discrepant conditions noted by the NRC.
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l The corrective and preventive action for these conditions is to install new bolts and washers in the 1 1
turbocharger support. By additional training, start-up support ,
1 personnel and OQA inspectors will be informed of this specific l 1
requirement relating to A490 high strength bolts.
1 Q. On page 7, paragraph 6, of Inspection Report No. !
l 50-322/83-02, the inspection team noted a concern regarding l I
housekeeping. What is LILCO's response concerning housekeeping?
A. With regard to the overall cleanliness of the Plant, it is pertinent to note that the NRC Inspector's per-spective was one of a plant within one month of fuel load, whereas shoreham, at that point, was actually four to five months from fuel load. This perspective, LILCO believes, had an effect on the NRC assessment. LILCO believes that the general condition of the Plant during the inspection was com-l patible with the stage of construction at the time. For exam-ple, at the time of the inspection, LILCO had been striving to complete both construction in the elevation 8 area of the reac-tor building and to r:itiate a general clean-up of this area by the end of January in order to effect access control and turn over the area to Plant Staff. The NRC believed that a clean-up should have been made independent of the turnover of this area j to Plant Staff. In any event, LILCO took the immediate action l
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requested by the NRC inspectors and notes that many of these actions would have occurred under the normal construction and start-up program by late January or early February.
LILCO believes that the specific cleanliness observations made by the NRC inspectors were not conditions ad-verse to quality.1/ LILCO's existing housekeeping program is designed to ensure that conditions adverse to quality do not occur or if they occur, are detected and remedied. In LILCO's view it was more efficient to postpone a final and extensive general clean-up until the remaining construction activity was closer to completion. LILCO had planned such a clean-up pro-gram to address all of the general concerns expressed by the NRC inspectors. The NRC inspectors disagree with this approach and therefore LILCO has undertaken the following measures:
(a) A general clean-up of the major buildings in the Plant will be conducted on at least a weekly basis.
Additional craft personnel will be assigned full-time to housekeeping duties until Plant readiness is accept-able to NRC inspectors. Fifty addi-tional laborers have already been dedi-cated full-time to this process.
(b) Specific eating areas were established in the Plant even within zone 5 areas which normally permit eat-ing and smoking.
1/ For example, the NRC conducted an internal inspection of an RCIC barometric condenser at elevation 8 and this inspection revealed no degradation attributable to lack of cleanliness.
(c) Specific verbal instructions have been and will continue to be pro- .
vided to Plant personnel and to all manual construction personnel regarding housekeeping policies.
(d) Inspections have been and will be conducted of all areas by LILCO man-agement personnel and-these inspections will be documented.
(e) Field quality assurance will <
monitor these additional activities as part of their normal surveillance pro-gram.
(f) LILCO has initiated weekly Monday morning walking tours of the re-actor building, control building, and screenwell with the following personnel generally in attendance:
- 1. Manager of Construction and Engineering;
- 2. General Superintendent of Construction;
- 3. Safety Supervisor (head of Plant clean-up program);
- 4. NRC Resident Inspector; and
- 5. Field Quality Assurance Manager.
Three of these inapections have already been conducted and improvement has been noted in all areas of the Plant. The i NRC Inspector concurs in this assess-ment, although both the NRC and LILCO agree that additional improvement can still be achieved.
LILCO has now committed to increasing the housekeeping effont until the Plant obtains the cleanliness level sought by the NRC inspectors. LILCO does not believe that the NRC's
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dissatisfaction with housekeeping at Shoreham reflects poorly on LILCO management attitude. Rather, it reprecents a differ-ence of opinion between professionals, in an area in which judgment plays a substantial role. Prior LILCO management in-volvement in housekeeping during the construction phase of the project is illustrated by the following points:
(a) LILCO has maintained a compre-hensive housekeeping program throughout the project documented by formal con-struction site instructions.
(b) At various appropriate times in the construction process, general roll-backs and clean-ups of various buildings have been initiated in order to keep unused censtruction material and debris from accumulating.
(c) LILCO field quality assurance has maintained an ongoing audit program of the site housekeeping program.
(d) LILCO's manager of construc-tion and engineering personally reviews every FQA audit report.
(e) Various areas of the plant which have equipment turned over to start-up or plant staff have been sepa-rately caged for cleanliness control.
(f) The LILCO start-up manager and the LILCO plant manager have communi-cated directly with the UNICO construc-tion manager on numerous occasions re-questing special clean-up activities or increased attention in some areas.
Joint tours of various areas have been conducted by the LILCO start-up manager and the UNICO construction manager.
In summary, we believe that LILCO management has been directly and appropriately involved in the housekeeping activities at Shoreham. LILCO believes that the actions it has now taken in response to the NRC Inspector's request have resulted in cleanliness improvements and that no further action will be required by the NRC in this matter. It should also be 4
noted that during the RAT assessment, the NRC inspected several areas of the Plant which have reached the state of completion approaching operational status. Specifically, the upper elevations of the primary containment and the radwaste building fall into this category, and the NRC concurred that cleanliness levels in this area, while not perfect, were appropriate for an area where construction was essentially completed. This confirms, in our judgment, that LILCO's previously established programs and philosophy were achieving the desired goal.
1 Q. On page 1, paragraph 2 of report no. 50-322/8302 NRC inspectors noted certain FQC inspection rejection rates that had been identified as complete by LILCO and also listed additional measures LILCO would take to ensure quality and ef-fectiveness of construction and FQC inspections. The cover letter to the r ort indicates that LILCO should give particular attention in its response to those actions taken or planned to ensure the effectiveness of the final inspection program. What is LILCO's response to this?
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A. This matter can be best understood by placing those rates in perspective. The following points are relevant in this respect:
(1) The overall quality assurance pro-gram provides an extremely detailed review and inspection of the final product and associated documenta-tion. Therefore, many " findings" are not unusual given this extreme level of detail; most are minor in nature and inconsequential from a technical standpoint.
(2) Many of the reasons for rejection included in the cited FQC parcent-ages have no bearing at all on even the extremely detailed level of attribute verification. For exam-ple, inspection packages are re-turned if any FQC inspector tempo-rarily cannot obtain access to an area or component to perform his inspection.
(3) A review of FQC inspection findings for the period November through December, 1982 reveals a relatively low percentage of findings actually requiring any hardware modifica-tions in the field.
l In any event, in order to evaluate the final inspection i findings in more detail and to ascertain whether or not any corrective action is required, and also to respond to any specific NRC concerns in this area, LILCO has initiated the actions listed in the Report on page 1, including the follow-ing:
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-A detailed review has been conducted of all FQC inspection findings from November 1, 1982 through late January, -
1983. This detailed review has thus far confirmed, as noted ab,ove, that the largest percentage of those findings resulting in N & D's, 95 percent do'not require modifications to hard-ware in the field. Based on the total number of components i
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inspected, only approximately two percent involve any component rework as delineated on N & D's. Lower level inspection find-
- ings as reflected on DCO's result in a larger number of find-ings which, through requiring correction in accordance with our I
I program, do not constitute significant deficiencies. As an ex-ample, small bore pipe support DCO's for the last three-week period resulted in an average rework rate of 9 percent.
i (2) Individual construction personnel accountability has been established for the major inspection areas, such as large bore and small bore hangers, in order to evaluate whether or not recurrent inspection rejects are attributable to l specific construction personnel. This program will provide the same type of information to construction management that the welder " report card" program did during the welding effort on the project.
(3) In order to establish direct accountability for cable tray supports, an additional construction inspection pro-gram has been initiated. This program, though it will slow the
final inspection and signoff process in the CAB TRAF area, is designed to decrease the number of cable tray supports returned I
to construction after final inspection. It is worth noting, as ,
I described in previous testimony, that the cable tray support '
building program (CAB TRAP) is a program unique in the indus-l try. The CAB TRAP program acknowledges that FQC will generally inspect each cable tray support at least twice and therefore FQC inspections are generily categorized as preliminary and final as indicated in the cabtrap reports. All FQC inspec-tions, however, including the initial inspection, are included in the reject statistics. This is an important reason for the apparent magnitude of the rejection rates. Also, as noted, this program is unique at Shoreham. Where general configura-tion conformance has been an acceptable criteria for this type of support in the past, the detailed dimensional and hardware i
requirements imposed at Shoreham have resulted in a number of minior deviations from these self-imposed, detailed criteria.
(4) Field reviews of components previously accepted by FQC will be conducted on a regular basis for a two-month period l
by LILCO field quality assurance (FQA). This program program 1
will be evaluated by the quality assurar.ce and construction and engineering departments. To date, the program has identified only three minor deviations cut of 180 specific attributes checked. These field reviews are actual hardware checks and not merely documentation checks. The three minor deviations
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will be evaluated by LILCO quality assurance, construction and engineering and SWEC engineering, and will be dispositioned in -
accordance with existing Project Procedures. On the basis of this limited data, we believe the final inspection program is functioning adequately. However, this program will be contin-ued at least through the end of March and longer if the results indicate additional inspections are required.
(5) FQC working hours were reviewed to ensure that excessive overtime was not involved in the inspection effort and an additional ten FQC inspectors were added to the job site on February 1.
It should be noted that LILCO and SWEC had al-ready identified the need for additional inspectors prior to the RAT inspection and 15 additional FQC inspectors had been added to the job site on January 1, 1983. As a result of our review, we have verified that the average overtime level for inspectors is consistent with industry practice for this stage of construction. .
In summary, an examination of the significance of the rejection rates and the results of the reinspections to date confirm that the construction, construction inspection and final FQC inspection programs at Shoreham are and have been ef-fective in producing quality hardware in the field and the l
appropriate documentation associated with that hardware. LILCO E
does not believe that the number of findings is excessive, h even :
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including those that have no significance with respect to the hardware.
i The fact that there are a large number of findings is a reflection of the magnitude of the inspection program itself and of the detailed attribute reviews required by the j LILCO-SWEC program. We believe that the fact that these items are identified and corrected where necessary is a positive in-dication that the program works and that the discrepancies are identified and properly dispositioned.
The absolute number of findings is also, we believe, not excessive. If the number of individual attribute devia-tions is compared to the total number of attributes requiring inspection, the percentages of findings during the final in-spection process is in the one to two percent range. In addition, the number of findings covered in the November, 1982 through January, 1983 time period when inspection activitiy was at a very high level, is not excessive on a per inspector basis. Nonetheless, LILCO agrees with the NRC inspectors that the additional measures undertaken by LILCO in response to the concerns of the NRC inspectors will provide added assurance of the quality of the installations and bolster the effectiveness of the construction and FQC inspection programs.
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. LILCo, Esbruary 15, 1983
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CERTIFICATE OF SERVICE -
-E^
In the Matter of k.13 hnM LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322 (OL)
I hereby certify that copies of Supplemental Testimony
- Of Messrs. Museler, Arrington, And Kelly Concerning I&E Inspection Report No. 50-322/83-02 were served this date upon the following by first-class mail, postage prepaid.
Lawrence Brenner, Esq. Secretary of the Commission Administrative Judge U.S. Nuclear Regulatory -
Atomic Safety and Licensing Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Dr. Peter A. Morris Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. James H. Carpenter l Administrative Judge Daniel F. Brown, Esq.
i Atomic' Safety and Licensing Attorney Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel i
Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555
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A.
Bernard M. Bordenick, Esq.
David A. Repka, Esq. David J. Gilmartin, Esq.
U.S. Nuclear Regulatory Attn: Patricia A. Dempsey, Esq.
County Attorney
- l Commission Washington, D.C. 20555 Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11787 Herbert H. Brown, Esq. Stephen B. Latham, Esq.
Lawrence Coe Lanpher, Esq. Twomey, Latham & Shea Karla J. Letsche, Esq.
Kirkpatrick, Lockhart, Hill, 33 West Second Street P. O. Box.398 Christopher & Phillips Riverhead, New York 11901 8th Floor 1900 M Street, N.W.
Washington, D.C. 20036 Ralph Shapiro, Esq.
Cammer and Shapiro, P.C.
Mr. Marc W. Goldsmith 9 East 40th Street New York, New York 10016 Energy Research Group 4001 Totten Pond Road Howard L. Blau, Esq.
Waltham, Massachusetts 02154 217 Newbridge Road Hicksville, New York 11801 MHB Technical Associates 1723 Hamilton Avenue Matthew J. Kelly, Esq.
Suite K San Jose, California State of New York 95125 Department of Public Service Mr. Jay Dunkleberger Three Empire State Plaza Albany, New York 12223 New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 l
i l
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: February 15, 1982 5
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