ML20205T548

Lists Issues That NRC Must Be Able to Address in Hearing or Inquiry Re ASLB Decision to Withhold Authorization for OL & Suggestions Re Region III Insp & Independent Verification Effort to Address Issues

ML20205T548
Person / Time
Site:	Byron, 05000000
Issue date:	02/13/1984
From:	Hayes D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20205S388	List: IR 05000454/1983038 ML20205S384 ML20205S395 ML20205S410 ML20205S434 ML20205S462 ML20205S613 ML20205T369 ML20205T392 ML20205T405 ML20205T451 ML20205T469 ML20205T526 ML20205T531 ML20205T537 ML20205T542 ML20205T548 ML20205T563
References
FOIA-88-344 NUDOCS 8811140282
Download: ML20205T548 (4)

Text

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February 13, 1984 MEMORANDUM FOR: R. L. Spessard. Director, Division of Engineering THRU: R. C. Knop, Chief. Projects Branch 1 FROM: / D. W. Hayes, Chief, Projects Section IB

SUBJECT:

BYRON STATION ,

i This memo has two parts. The first part is a list of those issues which I feel the NRC must be in a position to address in any subsequent hearing or inquiry relative to the ASLB decision to withhold authorization for an J

operating license for Byron Station. The second part is a list of suggestions relative to Region !!!'s inspection and independent verification efforts 1

to address these issues.

Part 1

1. What did the reinspection program demonstrate?  !

I As suggested by the Byron resident inspectors infomation may be

! available to allow a subjective characterization of the selected inspector's ability to discern between acceptable and rejectable l items and his/her tenacity in perfoming inspections. This may .

be difficult to defend, since very likely information would be incorrplete and difficult to resurrect. Even if it was available I'm not sure how gemaine it would be to other inspectors whose .

work was not reinspected.  !

In my opinion, the reinspection program tells us little about the  !

t capability and effectiveness of the selected inspectors and thus i

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those not selected and we should not try to make an argument from ,

this standpoint.

1 The reinspection program does give us a wealth of data on the quality l of the work itself and this is where we need to concentrate our efforts  ;

to demonstrate with reasonable assurance that no unacct:ptable defects 1 exist in the plant (i.e. that although there were failures in the '

contractors QA programs, no widespread hardware or construction problems exist).

. What inferences can reasonably be drawn based on conclusions reached '

t on work reinspected to iteas inspected which are inherently non-I recreatable or inaccessiblet  !

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R. L. Spessard February 13, 1984

3. What can be said about the noncompliance history of Hatfield at Byron station and its irnpact on plant. safety? (Need to provide

, assurances that deficiencies in the Hatfield QA program have been identified and corrected.) ,

, 4. Was the applicant's evaluation / analysis of identified discrepancies adequate and appropriate? i

5. How do current problems at Braidwood reflect on the applicant's willingness and ability to implement an effective QA program?

6. Was the applicant's actions relative to the 10! findings and the  :

NRC's followup adequate?

7. What was the results of the applicants / contractor efforts relative  !

to the HVAC problems? Were the applicants / contractor efforts l reasonable and adequate?

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8. What can bei said about the ASLB's concern relative to Hunter's QA program shortcomings? What assurances eHrt that deficiencies in  :

their QA program have been identified and corrected?

I do not claim that the above list is corplate and very likely it is not.

Part 2 Suggestions 1 through 7 concern the Ceco reinspection program at Byron and should receive first priority with completion required by March 16, 1984.*

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Suggestions 8 through 13 concern other issues we will need to address in i i the reopened hearing and should be completed no later than May 1,1984. '

j As Mr. Keppler indicated, we may face a congressional inquiry into Byron [

j and should that happen we may need inspection and verification results earlier. ,

i 1. Verify that the applicent has performed a rigorous evaluation of the ,,,,

1< discrepancies identified under the reinspection program; that i methodologies and &ssumptions were appropriatei that worse cases '

] have been identified and applied to items / areas / locations with least j design margin, r

2. The last Hatfield visual we d inspector to have his work reinspected (

l~ was Mr. h te i.ane. He failed the first 90 days but passed the ,

second 90 days with about 90.1%. Examine a sample of his welds that '

l were rejected by the I.evel !! inspector but accepted by the Level !!!. i

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3. Review reinspecticn results of the four additional PTL and one i i additional Hunter visual weld inspector selected since October 28, 1983.  !

Conduct independent examination, as considered appropriate, based on i j reinspection resul:s. I

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); *!t is assumed without listing it as a suggestion, that Ceco's report of I the reinspection program results will be reviewed for completeness and  !

! accuracy.  !

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R. L. Spessard February 13, 1984 4 Review and determine accuracy and acceptability of applicant's response to items 3, 8 and 10 of our February 3,1984 lettur.

Verify by independent reviews as necessary. In regard to item 10 determine if a pattern exists (i.e. were a few welders or QC inspectors involved in a majority of the discrepancies?) and if sn how this may apply to other work by these individuals not re-inspected.

l 5. Verify that ASME code weld Aa6 deficiencies have been properly l resolved including the small bore pipe socket undersize welds due to over-grinding, (both those reinspected and those accessible but not reinspected).

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6. Review inspection acceptance criteria and all interpretations issued during the reinspection program and determine if they were  ;

reasonable and proper relative to how and to the extent they were l applied.

I 7. Review actions taken by Ceco QA and as a minimum Hatfield and Hunter QA, relative to the reinspection program. Was QA involvement acequate or minimal? Were audit and surveillance finding corrected?

8. Review applicant's action (if any) to review and evaluate Hatfield's noncompliance history against impact on plant safety. What kind of problems with Hatfield did Ceco's QA program identify? Independently evaluate significance of Region !!!'s findings relative to Hatfield were these problems all attributable to Hatfield or were some due.to poor design?

I 9. Thoroughly review and evaluate applicants activities relative to Reliable Sheetmetal Company. Verify adequacy of HVAC materials and material traceability, OC inspections and design analysis. Also l review resalts of PTL 100% overinspection of HVAC safety related l

i installations. '"

10. Review and evaluate the probices associated with Systems Control Corporation supplisd equipment and verify that these problems have l been corrected. Included our (or NRR's) evaluation of the seismic l reanalysis of the control boards and panels perforwed by Westinghouse.

, 11. Review and evaluate applicants actions relative to the Hunter Corpor-ation "tabling" nonconforming conditions and relying on someone's awareness of the problems or identifying all problems during system walkdowns. Conduct independent incpections as considered appropriate based on results of review and evaluation of licensee's actions.

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, l R. L. Spessard February 13, 1984

12. Complete followup inspections of pipe support systems installed by Hunter.

13. Review and evaluate some of the Byron unit concept inspection results.

Conduct independent inspections as considered appropriate based on numbers, severity and types of problems identified under the "unit concept" inspections.

This list does not include the many routine inspection program items, followup resolution of previously identified problems, followup to SER items, test procedures and test result reviews, etc. needed before Region

!!! can make a finding that construction and preoperational testing of Byron station have been completed in substantial agreement with documented .

commitments and regulatory requirements. Present deadline for completing this work is July 1984.

p D. W. Hayes Chief ,

Projects Section IB j 1 cc

J. G. Keppler <

l A. B. Davis r i W. S. Little ,

O. H. Danielson C. C. Williams -

t D. R. Hunter

K. D. Ward t

! R. S. Love  !

l i J. M. Hinds /K. Connaughton .

R. Lerch

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