ML20133B869
| ML20133B869 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/01/1985 |
| From: | Ireland R, Plumlee G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133B837 | List: |
| References | |
| 50-267-85-14, GL-85-04, GL-85-4, NUDOCS 8508060278 | |
| Download: ML20133B869 (8) | |
See also: IR 05000267/1985014
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APPENDIX B
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U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report: 50-267/85-14 License: DPR-34 .
Docket: 50-267
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Licdnsee: Public Service Company of Colorado (PSC) ,
P. O. Box 840
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Denver, Colorado 80201
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Facility Name: Fort St. Vrain Nuclear Generating Station
Inspection At: Fort St. Vrain (FSV) Site, Platteville, Colorado
Inspection Conducted: May 1-31, 1985
Inspectors: M dru M; A j ////g
p G.Senior
L. Plumlet IIIInspector (SRI) / ' Date
Resident
Other Accompanying Personnel: Harold Miller, EG&G Consultant
Approved: [d. M
R. E. Ireland, Chief, Spdcial Projects and
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Engineering Section, Reactor Project Branch 1
Inspection Summary
Inspection Conducted May 1-31, 1985 (Report 50-267/85-14)
Areas Inspected: Routine, unannounced inspection of the control rod
drive event, followup on violations and deviations, generic letter followup,
licensee event report, maintenance, management meetings, operational safety
verification, and periodic and special reports. The inspection involved
92 inspector-hours onsite by one NRC inspector and 108 inspector-hours by one
NRC consultant.
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PDR AEK)CK O!KhDO267
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Results: Within the eight areas inspected, two violations (failure to
follow procedures, paragraphs 2 and 6), and two open items (G-9 procedure
deficiencies, paragraph 3, and operator knowledge, paragraph 8) were
identified.
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DETAILS
1. Persons Contacted
Principal Licensee Employees
- T. Borst, Support Services Manager
D. Brown, I&C Supervisor
- W. Craine, Superintendent of Maintenance
- R. Craun, Site Engineering Manager
M. Deniston, Shift Supervisor
D. Evans, Shift Supervisor
- M. Ferris, QA Operations Manager
- W. Franek, Superintendent Operations
- C. Fuller, Station Manager
- J. Gahm, Manager Nuclear ~ Production
D. Hood, Shift Supervisor
J. Jackson, QA/QC Supervisor
J. McCauley, Results Engineering Supervisor
P. Moore, QA Technical Support Supervisor
- F. Novachek, Technical / Administrative Services Manager
H. O'Hagen, Shift Supervisor
- T. Orlin, Superintendent QA Services
- G. Powers, Scheduling / Stores Supervisor
- T. Prenger, QA Engineering Supervisor
- G. Redmond, MQC Supervisor
G. Reigel, Shift Supervisor
T. Schleiger, Health Physics Supervisor
- L. Singleton, Manager QA
H. Starner, Coordinator Nuclear Site Construction
R. Webb, Maintenance Supervisor
S. Willford, Training Supervisor
The SRI also contacted other plant personnel including administrative,
electrical, maintenance, reactor operators, and technicians.
- Denotes those attending the exit interview.
2. Control Rod Drive (CRD) Event
During this reporting period, the licensee's progress on their CRD refur-
bishment program has been monitored on a periodic basis by both the SRI
and NRC consultant. The NRC inspectors noted the following findings.
. On May 6, 1985, the licensee made a 4-hour nonemergency event
notification concerning the determination that a purified helium
interspace pressurizing line, to refueling penetration Region 4, was
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plugged. Followup to this report indicated that a special test
T-272 had identified several blocked pressurization lines. T-272
was subsequently terminated and T-283 was developed to test and
remove residual material from all refueling interspace pressurizing
lines. T-283 is being performed on each region upon completion of
that region's CRD refurbishment. Upon issuance, the SRI will review
the licensee's LER on this event.
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On May 9, 1985, the NRC inspectors reviewing the procedure to
refurbish CRD 31 determined that:
. Refurbishment of CRD 31 was near completion when its back-EMF
test failed.
. A small squeak was heard in the cable drum area.
Site-nuclear engineering (NED) decided to disassemble the 200 assembly
to locate the problem. It was discovered that the wrong slinger
washer had been installed on the third stage causing the gears to
rub and that the two second stage duplex bearings had been installed
reversed. Task Step 48.1 to install the bearings and Task Step 48.5 to
install the slinger had the required workman and QC signatures.
Violation of the procedure by both the workman and the QC inspector -
was the cause of this problem.
A rework procedure was written to correct the problem and to continue
the assembly of the CRD.
The licensee was informed that this failure to follow procedural
requirements is considered a violation (8514-01) similar to Viola-
tion 8507-02. Upon request by the SRI, this subsequent violation and
corrective action were also discussed in the licensee's response to
Violation 8507-02, dated May 21, 1985 (P-85172). The SRI determined
! that the licensee's corrective action for the previous event, now
being implemented, should prevent further violations.
The NRC inspectors had no further comments in this area.
3. Followup on Violations and Deviations
l The SRI reviewed the licensee's response for the following violations
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and deviations to verify conformance with regulatory requirements and
that corrective measures were completed:
a. (OPEN) Violation (50-267/8414-01): System in Deviation Status
Without Operation's Knowledge. The reactor equipment operator's
(EO) log was not revised as stated in the licensee's response dated
August 3, 1984 (P-84255). The licensee stated that a revised
corrective action would be i.csued explaining why the logs were not
permanently revised. A specific requirement to check the N p
cover
gas is currently being written on the E0 logs and is not a con-
trolled formal requirement.
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b. (OPEN) Violation (50-267/8414-02): Failure to Follow Fire Protec-
tion and Housekeeping Requirements. Corrective action was not - -
adequate to avoid further violations. Closeout is pending review
of response to NRC Inspection Report 85-07, Violation 8507-08.
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(OPEN) Violation (50-267/8414-03): Failure to Follow Startup
Procedures. Both the shift supervisor and senior reactor operator
involved have been admonished for their omission and were warned
that any further failures to follow procedures would result in
disciplinary actions. However, the. memoranda that documented the
above were not placed in the individual's personnel files as stated in
the licensee's response (P-84255). The memoranda were actually
placed in the superintendent of operation's personnel file. The SRI
is awaiting the licensee's resolution of this issue prior to
closecut of this violation. The SRI informed the licensee of the
need for accurate responses and obtained the licensee's agreement
to ensure that future responses are accurate.
d. (CLOSED) Violation (50-267/8414-04): Failure to Install Check
Valves in Accordance With Procedures. Maintenance Procedure MP 11-3,
Issue 11, dated May 1, 1985, and Surveillance SR 5.2.16f-RX, Issue 5,
dated August 8, 1984, incorporated QC hold and witness points to
ensure that work is stopped before check valve installation and that
the installation is independently observed. SR 5.2.16f-RX, Issue 6, -
dated January 17, 1985, subsequently incorporated proof testing upon
completion of installation in accordance with SR-RE-52-X (for verifying
purge-helium-check valve installation) and SR 5.1.2ad-Q (for verifying i
reserve-shutdown-helium-check valve installation). The responsible
QC inspector was admonished. '
e. (CLOSED) Deviation (50-267/8414-05): Deviation from Response to
Previous Violation. A memorandum (NFG-84-0135, dated August 1,
1984) was issued to people in the control work procedure (CWP)
cycle to ensure efforts were made to utilize the correct CWP cover
page. The CWP manual was subsequently revised to include the
correct CWP cover page.
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f. (CLOSED) Violation (50-267/8414-12): CWP Process / Inadequate Proce-
dure. Administrative Procedure G-9, " Controlled Work Procedures,"
Issue 6, dated December 5, 1984, and Controlled Work Procedure
Manual (CWPM), Issue 2, dated January 31, 1985, prescribed the
appropriate instructions / procedures for performing / controlling
CWPs, procedure / inspection / test / reports (PITRs), and deviation
reports (DRs). During a review of G-9, the SRI identified the
following problems:
. Step 5.5.1.2 as worded allows the use of a " prefab /nonsafety-
related" PITR for prefab of safety-related items.
. Page 9 of 21, fourth paragraph, has a "(4)" that appears not
to have any meaning.
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. Step 4.1.18 does not require updated control room and shift
supervisor design documents prior to return of the modified
system to service.
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G-9 does not require an independent design verification of DRs
as does the CWPM Step 5.6.11.
The licensee was informed that these procedure deficiencies are
considered an open item (8514-02) pending the necessary procedure
revisions.
g. (CLOSED) Violation (50-267/8415-02): Fire Water Pump House Fans
, Inoperable Without Operator Knowledge. The licensee was unable to
determine the reason for the fans being in the ACM position, but
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power system after the modifications to the 480-volt buses. The L. '
Surveillance SR 5.2.21-SA, "ACM Pneumatically and Electrically
. Operated Valves and Transfer Switch Functional Test," Issue 19,
dated September 28, 1984, used ta test the ACM was revised to
provide independent verification of system return to " normal.",
b. (CLOSED) Deviation (50-267/8415-06): TMI Action Item I.C.2 Commit-
ment. The effectiveness ,cf shift turnover procedures was evaluated
during performance of the Atgust - September 1984, NFSC ;g.
Audit A-84-01 and duringe.he quarterly performance of QA Monitor *
Procedure QAMP P1-1, " Plant Operations Shift Turnover Activities,"
Issue 1, dated December 27, 1984, which was developed in response *o
, Violation 8416-01. A QA commitment tracking system has also been
l established via a computerized report distributed monthly to QA
management. QA General Procedure QAGP-6, "QA Commitment System,"
is being issued to document this tracking system. ,
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i. (CLOSED) Violation (50-267/8416-01): No shift Turnover Proceduce.
Station Manager Administrative Procedure SMAP-8, " Plant Operations
Shift Turnover Procedure," Issue 1, dated October 10, 1984, estab-
lished the instructions to be followed by operations personnel
during shift relief and turnover.
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4. Generic Letter Followup
The SRI reviewed the licensee's response dated May 10, 1985 (P-85165),
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to Generic Letter 85-04, " Operator Licensing Examinations." The
response addressed the information discussed in the generic letter. ,
No violations or deviations were identified. I)[
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5. Licensee-Event report (LER) -
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The SRI reviewed licensee event reporting activities to verify that they 'F. * -
were in accordane.e with Technical Specification, Section 7, including ,3 -
identification details, corrective action, review, and evaluation of , <'
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aspects relative to operations and accuracy of reporting. '
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The following LERS were reviewed for adequacy and/or closeout:
(CLOSED)83-051
(CLOSED)83-052
6. Maintenance (Monthly)
The NRC inspectors reviewed records and observed work in progress to
ascertain that the following maintenance activities were being conducted
as required by approved procedures, Technical Specifications, and appro-
priate codes and standards. The following maintenance activities were
reviewed and observed:
SSR 85506015 HV2251 Inspection / Repair in accordance with
MP 22, " Maintenance and Repair of
Rockwell-Edwards Valves, Pressure Seal Type"
CN 1976 A,B/CWP 85-500 Replace Exiting Bolts with New Inconel Bolts,
"D" Circulator (C-2101)
SSR 85505605 Replace Helium Ducting Bolts in accordance with
MP 21-18, " Helium Circulator Compressor
Assembly Retaining Bolt Replacement"
CN 1886/CWPs85-330 Reorganization, Functional Grouping, Relabeling,
through 85-343 and Demarcation of Instrumentation
Components and Systems on I-01/02
t CN 1907/CWPs 85-74, Replace Existing Flow Meters on Each CRD Purge
CW 85-75, CWP 85-78, Line; Provide Remote Alarm and Continuous
CW 85-145 through through CWP 85-100, and Recording for Each CRD
CW 85-195 Purge Flow
During a review of the control room design review (CROR) modification
CN 1886 on May 28, 1985, the SRI determined a significant breakdown in
housekeeping / cleanliness. Both the vertical and bench boards as well as
the rear of panels I-01/-02 contained significant amounts of metal
shavings / filings on recorders, handswitches, controllers, and terminal
boards. The amounts of shavings / filings indicated a degradation of
housekeeping / cleanliness requirements. The SRI immediately informed the
licensee and an immediate investigation was initiated by the licensee.
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instances of QA deficiencies relied upon by -Intervenors and the
documents related to such deficiencies such instances are
identified in the ' body of our amended contention with citations
to the related documents and relevant portions of such documents
are reproduced and attached as exhibits. This information
regarding our contention has already been fully disclosed to the
NRC Staff and Applicant.
The NRC Staff seeks the production of documents from
Intervenors for inspection and copying. Documents so identified
in~ the answers to the following' interrogatories, except for
those'which are privileged, will be made available for inspection
and copying at counsel's office in Chicago, Illinois, at a
, time to be agreed upon. In the course of preparing for the
litigation of this contention and advising Intervenors ,
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documents are prepared which are privileged and not subject to
discovery pursuant to 10 CFR Section 2.740(b)(1) . Such
documents as trial preparation materials are subject to a
work product privilege and an attorney-client privilege protects
from disclosure the mental impressions and opinions of counsel.
10 CFR Section 2. 740(b)(2) .
Such documents as the handwritten notes prepared by
Intervenors' counsel are privileged and protected from disclosure.
Intervenors obj ect to the production of such documents and ask
the Board to enter an order protecting such materials from
! disclosure.
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These interrogatories are being answered by the under-
signed counsel fo.r Intervenors . No consultants or other
advisors are relied upon for such answers. Intervenors have
not, at this time, identified the witnesses they expect to
call at hearing with regard to the subject matter of these
interrogatories. However, pursuant to 10 CFR Section 2.740(e),
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Intervenors intend to seasonably supplement this response
to identify persons expected to be called as experts.
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INTERROGATORY RESPONSES:
Q-1.- Are there instances other than those cited in subpart
A.-F. of paragraph 1 which support your allegation that
Applicant's QA program violates Criterion I of 10 C.F.R. Part 50,
Appendix B by failing to oversee the performance of their site
contractors?
A-1. No.
Q-2. If the answer to Interrogatory 1 above is yes:
a. Describe each instance in detail, including the '
time period during which it occurred.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-2. Not applicable.
-Q-3 Are you aware of corrective actions which have been
taken to remedy the situation set forth in paragraph 17
A-3 Yes.
Q-4. If the answer to Interrogatory 3 above is yes:
a. Describe such corrective actions with particular-
ity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 1. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 3
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A 4. a. Intervenors are aware generally that Applicant has
undertaken a number of corrective action programs, at least in
part as required by the NRC Staff, to address quality assurance
deficiencies at the Braidwood station. The " top twenty"
corrective action programs at Braidwood are identified and
described by Mr. David H. Smith of Commonwealth Edison in his
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April 8, 1985, letter to NRC Regional Administrator James G.
Keppler. Exhibit 7 to the May 24, 1985, Motion To Admit Amended
Quality Assurance Contention. The status and scheduling of these
corrective action programs is further described in the June 7,
1985, Affidavit of Michael J. Wallace, filed by Applicant in this
proceeding. There, at page 2, Mr. Wallace states the Applicant's
position regarding the relationship between such programs and
Intervenors' contention:
Counsel advised that the admission of such a
contention could necessitate litigation of the
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following corrective action programs: the
heating, ventilation, and air conditioning
("HVAC") configuration program, the HVAC duct
fitting verification program, the HVAC housing
and air risers program, the concrete expansion
anchor ("CEA") inspection program, the safety-
related mechanical equipment reinspection
program, and the electrical document review.
Counsel further advised that such litigation
could not be undertaken and the record in the NRC
licensing proceeding could not be closed on such
a contention until these corrective actions and
programs have been implemented to the point
where reasonably complete actions have been
taken or reasonably final results are available.
In addition, Commonwealth Edison has been required by NRC to
institute the Braidwood Construction Assessment Program (BCAP)
which was described in a June 22, 1984, transmittal letter from
James J. O'Connor, Chairman and President of Commonwealth Edison
Company to Mr. Keppler. Id., Exhibit 8. The BCAP program
elements may either directly or indirectly represent corrective
actions for previously identified quality assurance deficiencies.
BCAP includes a Construction Sample Reinspection (CSR) of
selected safety related hardware, a Reverification of Procedures
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to Specification Requirements (RPSR) element which reviews
installation and inspection procedures, and a Review of
Significant Corrective Action Program (RSCAP) element which
purports to review the effectiveness of existing major corrective
actions.
Finally, for items of noncompliance, identified by the NRC
Staff and acknowledged by Applicant, Intervenors understand that
Applicant generally undertakes some measures characterized as
corrective actions. Intervenors have sought information
regarding such corrective action in discovery requests which are
pending. Interrogatory No. 58, for example, served July 2, 1985,
seeks information regarding the corrective actions taken to
remedy deficiencies referred to in our amended contention. It
was objected to, in part, by Applicant in a July 29, 1985,
pleading. No answer to this interrogatory was provided by
Applicant in its July 30, 1985, First Partial Response; any
answers to the unobjected-to portion of the interrogatory are
expected to be served August 9, 1985.
In Appendix B to the June 1984 BCAP program descriptions a
" Reinspection of Safety-Related Mechanical Equipment" corrective
action program (CAP) is identified which is believed to relate to
this part of the contention. This CAP is described by Applicant
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as the one corrective action "that drives the schedule" Tr. 201-
202, since it is anticipated that it will not be completed until
October 1, 1985. Id.
Among the " top twenty" Corrective Action Programs identified
by Mr. Smith of Edison in his April 8, 1985, letter, supra, is
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the Material Traceability Verification Program (MTV) which is
believed to relate to this part of the contention.
! b. Intervenors at present have not taken a position
on the adequacy of any such corrective action programs. However,
Intervenors are aware of criticisms and weaknesses which have
l been identified with respect to some of these programs. In
addition, the NRC Construction Assessment Program (CAT) expressed
major concerns at Braidwood about "the ability to manage the
large number (over 20) of ongoing major corrective action
programs and ensure that current work is correctly performed."
Inspection Report 84-44/40, p. 1, Exhibit 10 to the May 24, 1985,
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Motion To Admit Amended Contention.
Weaknesses and criticisms of the Braidwood corrective action
programs are discussed in Intervenors' May 24 Motion at pp. 8-11.
These weaknesses included " reinspection discrepancies," improper
" invalidations" of discrepancies when identified, failure of the
BCAP RPSR element to review " current" site procedures, failure of
the BCAP RSCAP element to include actual hardware inspections,
and a concern that the MTV program cannot effectively verify
traceability where either markings or documentation are absent.
Id.
c. All documents relied upon are identified in the
text of the responses given.
Q-5. Explain the meaning of the term " widespread
deficiencies" as used in paragraph 1 on page 19
A-5. " Deficiencies" are instances of noncompliance with
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applicable codes, specifications, procedures or other
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requirements. The term " widespread" is intended to reflect the
significance, pervasiveness a,nd frequency of occurrence.
Q-6. Are the instances described in subparts A.-C. of
paragraph 3 the sole instances upon which you rely as your basis
for the contention that Applicant's QA program is not adequately
documen;ed by written policies, procedures and instructions and
does not effectively control activities affecting quality?
A-6. No.
Q-7. If the answer to Interrogatory 6 above is not
a. Describe in detail each additional instance on
which you rely as a basis for paragraph 3
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-7. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion II.
Other such instances ares
(1) Additional management attention is required to improve
contractor performance in craft and quality control
. inspector training. Paragraph 1, subpart F, page 22.
(2) Phillips, Getschow Quality Procedure regarding uce of a
calibrated instrument to measure pipe bends was not
followed. Paragraph 6, subpart B(3), page 31.
L (3) Purchased piping from a company that did not have an
approved QA program. Paragraph 6, subpart G, page 32.
(4) Adequate traceability records were not maintained
regarding large cap screws which was in part the basis
for imposition of penalties for Quality Assurance
breakdown. Paragraph 8, subpart A, page 34.
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(5) Civil penalty was imposed for' breakdown of QA program
because of a problem with bolting of the steam
generator supports. Paragraph 12, subpart A, page 41.
t- (6) Applicant failed to implement a QA program for the
l erection of mechanical, safety-related equipment..
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Paragraph 12, subpart G, page 43
-(7) A number of mechanical safety-related equipment records
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failed to show compliance with quality assurance
requirements. Paragraph 13, subpart A, page 45.
(8) No follow-up was done to determine the effectiveness of
the quality assurance program regarding installation of
l . most of the critical nuclear steam supply system.
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Paragraph'14, subpart A, page 46.
l b. Documents reflecting the instance described in
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Interrogatory 7a(1)~ above are cited on page 22 of Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Contention ,
and relevant portions are included in the exhibits attached
thereto.(Exh. 10). f
Documents reflecting the instance described in Interrogatory
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7a(2). above are cited on page 31 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
! portions are included in the exhibits attached thereto (Exh. 5).
I Documents reflecting the' instance described in Interrogatory
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7a(3) above are cited on page 32 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
- portions are inel,uded in the exhibits attached thereto (Exh. 21).
Documents reflecting the instance described in Interrogatory
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7a(4) above are cited on page 34 of Intervenors' May 24, 1985,
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' Motion To Admit Amended Quality Assurance Contention and relevant
dortionsare'includedintheexhibitsattachedthereto(Exh. 3).
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Documents reflecting the instance described in Interrogatory
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7a(5) above are cited on page 41 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 3).
Documents reflecting the instance described in Interrogatory
7a(6) above are cited on page 43 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 20).
Dccuments reflecting the instance described in Interrogatory
7a(7) above are cited on page 45 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 3).
Documents reflecting the instance described in Interrogatory
7a(8) above are cited on page 46 of Intervenors' May 24, 1985,
Motion To Admit Ameaded Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 3).
Q-8. Are you aware of corrective actions which Applicant
has taken to correct the deficiencies cited in paragraph 3
A-8. Yes.
Q-9 If the answer to Interrogatory 8 above is yes:
a. Describe such corrective actions with particular-
ity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 3 State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 8.
A-9. a. Please refer to the answer given to
Interrogatory 4a above. In addition, by letter of July 3, 1985,
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Applicant circulated their June 21, 1985, response to the
noncompliances in Inspection Report 85-15/16. They state that no
specific corrective action has been taken with regard to the
unauthorized modification of structural beams because, in their
judgment, other existing corrective action programs were l
adequate to assure that either the problem would not recur; and
that other instances had been, or would be, identified.
b. Please refer to the answer given in Interrogatory
4b above. l
c. Please refer to the answer given in Interrogatory
4c above.
Q-10. Are the instances cited in subparts A. and B. of
paragraph 4 the only instances which form the basis for the
contention that training and indoctrination of those performing
activities affecting quality was inadequate?
A-10. No.
Q-11. If the answer to Interrogatory 10 above is no:
a. Describe in detail the other instances upon which
you rely as the basis for this contention, including the date of
their occurrence.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-11. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion II.
8
O__
~ a
...
Other such instances are:
~(1) .A welder documented as performing welding was not
qualified. Paragraph 9, subpart D, page 36.
(2) Craft personnel improperly repaired welds. Paragraph
11, subpart D, page 40.
b. Documents reflecting the instance described in
Interrogatory 11a(1) above are cited on page 36 of Intervenors'
May 24, 1985, _ Motion To Admit Amended Quality Assurance Contention
and relevant' portions are included in the exhibits attached
thereto (Exh. 21).
Documents reflecting the instance described in Interrogatory
11a(2) above are cited on page 40 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 18).
~Q-12. Are you aware of corrective actions which Applicant.has
taken to remedy the situations in subparts A. and B. of paragraph 4.
~A-12. No.
Q-13 If the answer to Interrogatory 12 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 4. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 12.
A-13 Not applicable.
Q-14. Are the instances alleged in subparts A.-C. of
paragraph 5 of your contention concerning quality assurance the
only instances upon which you rely as the basis for your
contention that there is inadequate program to assure that
9
M
.
applicable regulatory requirements and design basis are correctly
translated into specifications, drawings, procedures, and
instructions?
A-14. No.
Q-15. If your answer to Interrogatory 14 above is no:
a. Describe in detail all other instances upon which
you rely as the basis for subparagraph 5 of your contention.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-15. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion III.
Other such instances includes
(1) Edison and Sargent and Lundy did not provide sufficient
assessments and verifications of Phillips, Gotschow
design capabilities prior to authorizing field routing
of Class 2 and 3 small bore piping and field design of
supports / restraints. Paragraph 3, subpart A(4)(a),
page 26.
(2) Phillips, Getschow small bore pipe routing procedures
lacked specific quantitative field design criteria to
meet specifications. Paragraph 3, subpart A(4)(6),
page 26.
(3) Use of the Field Change Request system compromised the
final design change acceptance review and approval.
Paragraph 3, subpart A(4)(f), page 27.
(4) Phillips, Getschow piping crews failed to adequately '
control the mocifications of beams. Paragraph 3,
subpart B, page 27.
(5) bargent and Lundy did not prescribe clearance criteria
for safety-related HVAC components or safety related
10
L t
_ _ _ _ _ _ - _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
. *
, large bore piping and electrical items in relation to
l other items. Paragraph 6, subpart D, page 32. i
- '
! (6) Craft personnel made field changes to drawings being
made during the installation of ASME Section II piping. '
Paragraph 7, subpart A, page 33
(7) Some piping was installed that did not meet design
requirements. Paragraph 10, subpart B, page 37
,
i (8) Applicant's QA inspectors failed to identify areas
where Phillips, Getschow siesmic category I and other
pipe supports / restraints have not been constructed in
accordance with design requirements. Paragraph 10,
subpart C, page 38.
(9) Records relative to installation of mechanical safety-
related equipment failed to show compliance with design ,
requirements. Paragraph 13, subpart A, page 45. !
b. Documents reflecting the instance described in
l Interrogatory 15a(1) above are cited on page 26 of Intervenors'
l May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached !
thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
[
15a(2) above are cited on page 26 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5). '
Documents reflecting the instance described in Interrogatory
15a(3) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
,
Documents reflecting the instance described in Interrogatory
15a(4) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assursuce Contention and relevant
,
portions are included in the exhibits attached thereto (Exh. 17).
11
l
- .
r-
,
Documents reflecting the instance described in Interrogatory
15a(5) above are cited on page 32 of Intervenors' May 24, 1985,
Hotion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 22).
Documents rerlecting the instance described in Interrogatory
15a(6) above are cited on page 33 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions aru included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
15a(7) above are cited on page 37 or Intervenors' May 24, 1985,
'
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 6).
Documents reflecting the instance described in Interrogatory
15a(8) above are cited on page 38 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10).
Documents reflecting the instance described in Interrogatory
15a(9) above are cited on page 45 or Intervenors' May 24, 1985,
Hotion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 3).
Q-16. Are you aware or any corrective actions being taken
by Applicant to correct the situations described in subparts A.-
C. or paragraph 5 or your contention?
A-16. No.
"
Q-17 If the answer to Interrogatory 16 above is yes:
a. Describe what you understand to be the corrective
actions being taken by Applicant.
b. State your position as to whether such corrective
12
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
actions would or would not be adequate to remedy the situation
described in paragraph 5. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatories 15 and 16.
A-17. Not applicable.
Q-18. Are the instances specified in subparts A.-I. of
paragraph 6 of your quality assurance contention the only
instances on which you rely as the basis for your contention that
there is inadequate prescription of activities affecting quality
by documented procedures, instructions and drawings?
A-18. No.
Q-19 In the answer to Interrogatory 18 above is not
a. Describe in detail the other instances upon which
you rely as the basis for paragraph 6 of your contention.
b. Identify all documents which relate to such
instances by title, author, if any, date or issuance and, if
other than NRC documents, provide a summary of their contents.
A-19 a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quelity Assurance program violates this Appendix B
Criterion V.
Other such instances includes
(1) Detailed drawings regarding small bore pipes were not
losued by Sargent and Lundy or Phillips, Getschow.
Paragraph 3, subpart A(4)(a), page 26.
(2) Phillips, Getschow did not follow procedure
requirements for small bore piping calculations.
Paragraph 3, subpart A(4)(c), page 27
(3) NRC CAT found design change control problems, including
design change documents written against superceded
13
,
4
_ . _ . . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
'
.
l
revisions or the approved design drawings. Paragraph
5, subpart A, page 29
(4) Field changes were made to drawings by craft personnel
during installation or ASME Boiler and Pressure Vessel
Code. Paragraph 7, subpart A, page 33
(5) A procedure for setting major nuclear steam supply
system components was not developed. Paragraph 10,
subpart A, page 37.
b. Documents reflecting the instance described in
1
Interrogatory 19a(1) above are cited on page 26 or Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Contention
and relevant portions are included in the exhibits attached
thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
19a(2) above are cited on page 27 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
..
Documents reflecting the instance described in Interrogatory
19a(3) above are cited on page 29 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10).
Documents reflecting the instance described in Interrogatory
19a(4) above are cited on page 33 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
19a(5) above are cited on page 37 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention .and relevant
portions are included in the exhibits attached thereto (Exh. 3).
14
'~
_ _ _ _ _ _ _ _ _
r ,
. *
Q-20. Is the instance set forth in subpart A. of paragraph
7 of your contention the sole instance of inadequate document
control which provides the basis for your contention that
- Applicant has failed to establish a program of adequate document
i control?
A-20. No.
! Q-21. If the answer to Interrogatory 20 above is no:
l
l a. Describe your detail the other instances you
allege form the basis of paragraph 7 of your contention,
including the date of occurrence of each instance.
'
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
l
A-21. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
i serve as the basis for that contention, other instances of
l
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
l
!
Applicant's Quality Assurance program violates this Appendix B
Criterion VI.
Other such instances include:
l
(1) Sargent and Lundy calculations which provided the
original justification for the factor design
methodology and magnitude were not retrievable.
Paragraph 13, subpart B, page 45.
, b. Documents reflecting the instance described in
Interrogatory 21a(1) above are cited on page 45 of Intervenors'
l
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
thereto (Exh.19).
Q-22. Are you aware of any corrective actions taken by
Applicant to provide adequate document control?
l
15 ,
,
._ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . . _ .
.
A-22. Yes.
Q-23 If the answer to Interrogatory 22 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 7. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 22.
A-23 a. Please refer to the answer given to Interrogatory
4a above.
b. Please refer to the answer given in Interrogatory
4b above.
c. Please refer to the answer given in Interrogatory
4c above.
Q-24. Are the instances specified in subparts A.-F. of
paragraph 8 of your contention the sole basis for your contention
that Applicant's program for material and parts control is
inadequate?
A-24. No.
Q-25. If the answer to Interrogatory 24 above is not
'
a. Describe each instance in detail, including the
time period during which it occurred.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-25. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
16
i
.
.
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion VIII.
.
Other such instances include:
(1) Additional support plates were not identified during QC
inspections. Paragraph 6, subpart D, page 32.
(2) Piping contractor found piping that violated minimum
requirements. Paragraph 6, subpart F, page 32.
(3) Material installed for the pipe whip restraint plate
was not of proper specifications. Paragraph 6, subpart
I, page 33
(4) Quality structural steel was not approved for use by
the Architect-Engineer but was released for use in
installation by the structural steel contractor and
documented as being used for cover plate welds.
Paragraph 9, subpart D, page 36.
(5) Seventy to seventy-two steam generator support bolts
were received in January 1979 and identified as
nonconforming. There is no record as to dispostion of
these bolts. Paragraph 11, subpart A, page 39
(6) Rejected safety-related pipe was installed. Paragraph
11, subpart C, page 40.
b. Documents reflecting the instance described in
Interrogatory 25a(1) above are cited on page 32 of Intervenors' May
24, 1985, Motion To Admit Amended Quality Assurance Contention
and relevant portions are included in the exhibits attached
thereto (Exh.14).
Documents reflecting the instance described in Interrogatory
25a(2) above are cited on page 32 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 20).
Documents reflecting the instance described in Interrogatory
25a(3) above are cited on page 33 of Intervenors' May 24, 1985,
17
___ - _-__ - _-_____ _ _ ___ _ 2 -
. _ _ _ _ _ _ _ _ _ - _ _ _
'
.
Motion To Admit Amended Quality Assurance Contentien and relevant
portions are included in the exhibits attached thereto (Exh. 22).
Documents reflecting the instance described in Interrogatory
25a(4) above are cited on page 36 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 21).
Documents reflecting the instance described in Interrogatory
, 25a(5) above are cited on page 39 of Intervenors' May 24, 1985,
l
l Motion To Admit Amended Quality Assurance Contention and relevant
l
portions are included in the exhibits attached thereto (Exh. 3).
Documents reflecting the instance described in Interrogatory
25a(6) above are cited on page 40 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 21).
Q-26. Are you aware of any corrective actions which have
been taken by Applicant to improve materials and parts control at
the Braidwood site?
A-26. Yes.
Q-27. If the answer to Interrogatory 26 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 8. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 26.
A-28. a. Please refer to the answer given to Interrogatory
4a above.
b. Please refer to the answer given in Interrogatory
18
.
_ _ _ . _ _ _ _ _ _ _ _
.
l
4b above.
l c. Please refer to the answer given in Interrogatory
4c above.
Q-28. Are the instances set forth in subparts A.-E. of
paragraph 9 of your contention the sole basis for your contention
that Applicant's program does not provide adequate control of
special process and adequate ensurance that these special
processes are accomplished in accordance with applicable codes
and standards?
A-28. No.
Q-29 If the answer to Interrogatory 28 above is not
a. Describe in detail each other instance of
inadequate control or oversight of special processes which forms
l the basis for your contention in paragraph 9.
b. Identify all documents which relate to such
i
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
l A-29. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this intorrogatory,
serve as the basis for that contention, other instances of
l
Quality Assurance deficiencies identified elsewhere in our
,
amended contention provide further support for our claim that
l
Applicant's Quality Assurance program violates this Appendix B
Criterion IX.
Other such instancen includes
(1) Qun11ty control inspection activities need to be
improved in the welding nren. Paragraph 1, subpart D,
pnge 21.
(2) Instructionn were not approprinto to the circumntances
in that welding procedures npecifying the essentini
variablen were not prencribed on drawings or welding
sequences for each specific flVAC inntnlintion und
Qualtiy Control innpoetionn during the wolding procenn
were not of adequate scope und frequency to nasure the
19
,
. 1
,
'
use of correct welding variables. Paragraph 3, subnart ,
A(1), page 25.
(3) Quality control inspectors were not given appropriate
instructions regarding fillet weld gaps. Paragraph 3,',
subpart A(2), page 25.
(4) The piping contractor, Phillips, Getschow, did not have
a procedure or documented instruction stipulating a
systematic method for producing an accurate In-service
Inspection drawing, including determining the number -
und location of all field welds and shop welds.
Paragraph 6, subpart C, pages 31-32.
(5) Weld sizes in structural pipe support /rentrainto were
not identitled to be proper weld configurations.
Paragraph 10, subpart E, page 39.
(6) Comstock weld inspectors allowed craf t personnel to
repair / work weld defects identified during final QC ,
inspections. Paragraph 11, subpart D, page 40.
(7) Through August 4, 1983, numerous welding deriotency and
deviation notelces were written by the ilVAC contractor
but the the contractor's Quality Assurance Psegrne did
not require that Correction flotices be analyzed for
nignificance. Paragraph 12, subpart B(2), page 42.
(8) Corrective action was not adequate concerning
lionconformance Report flo. BR-08, dated June 15, 1981,
since the nonconforming welds completed by unknown
welders were " accepted-us-in" after only a visual
examination. The acceptance of the weld by visual
examination pursuant to AWS D1.1 is bneed on the fact
that n qun11ried welder performed the weldin6 in
accordance with the qualified procons. Paragraph 12,
subpart D(3), pages 42-43 s .
(9) flo documentation supporting ntatement that corredrive
action concerning defective wolds was "N/A" and,' hver.
on numeroun wold doriciencien af ter reworY, the
'
corrective action for thin ilCH wnn inerrno'i te.
Paragrnph 12, nubpart D, page 43 '
,
(10) I:dinon QA identirled innpection defici,neien but ralled
to take corrective action with respoet' to llapoleon
Steel Contractorn' punt weiding 1.lopoetten activities
to nasure that defecto do not exist in muitt-pann
weldn. Paragraph 12, nubpart I, ptge 44
b. Documenta rurlocting the inntnnce doncribed in
Interrogntory 29a(1) above are cited on page 21 of Intervenorn'
20
"
, _ __ _ _2 _ .
_
.
.. . .
o
l
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
j thereto (Exh.10).
Documents reflecting the instance described in Interrogatory
29a(2) above are cited on page 25 of Intervenors' May 24, 1985,
,
Motion To Admit Amended Quality Assurance Contention and relevant
'
portions are included in the exhibits attached thereto (Exh. 5).
f,. ,-
1
Documents reflecting the instance described in Interrogatory
29a(3) above are cited on page 25 or Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
f portions are included in the exhibits attached thereto (Exh. 5).
,
4
Documents reflecting the instance described in Interrogatory
) ,
29a(4) above are atted on pages 31-32 of Intervenors' May 24,
4'
1985, Motion To Admit Amended Quality Assurance Contention and
relevant portions are included in the exhibits attached thereto
(Exh. 14).
Documents reflecting the instance described in Interrogatory
29a(5) above are cited on page 39 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant I
e
portions are included in the exhibits attached thereto (Exh. 10). ,
1
Documents reflecting the instance described in Interrogatory
29a(6) above are cited on page 40 of Intervenors' May 24, 1985,
',
Motion To Admit Amended Quality Assurance Contention and relevant
?
portions are included in the exhibits attached thereto (Exh. 18).
,
Documents reflecting the instance described in Interrogatory
f, [' 29a(7) above are cited on page 42 of Intervenors' May 24, 1985,
\, Motion To Admit Amended Qusitty Assurance Contentio.1 nnd relevant
I' 21
6
. .
- __
-
, .
f
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
29a(8) above are cited on 'pages 42 43 of Intervenors' May 24,
1985, Motion To Admit Amended Quality Assurance Contention and
, relevant portions are included in the exhibits attached thereto
s
(Exh. 5).
Documents reflecting the instance described in Interrogatory
1
29a(9) 'above are cited on page 43 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10). j
Documents reflecting the instance described in Interrogatory
29a(10) above are cited on page 44 of Intervenors' May 24, 1985,
,
/ .\
' Motion To Admit Amended Quality Assurance Contention and relevant
portions 4 'are included in the exhibits attached thereto (Exh. 25).
,
'Q- 3 0. Are you aware of any corrective actions taken by
Applicant to improve control of special processes and to ensure
compliance with applicable codes and standards? l
A-30. Yes.
Q-31. If your answer-to Interrogatory 30 above is yes:
a. Describe such corrective ac,tions with
particularity.
b. State your position as' to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 9.' State with' particularity.four basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 30, 4
A-31,. _ a. Please refer to the answer given to Interrogatory
)
4a above( ,g' -
b. Please refer to the answer given in Interrogatory
'
, 1
L 1
22
.9
L
b q.
___ - ____________________-_____ _ _____ _ _ _
?
4b above.
c. Please refer to the answer given in Interrogatory
4c above.
Q-32. Are the instances set forth in subparts A.-F. of
paragraph 10 of your contention the sole basis for your
contention that Applicant's inspection program is inadequate?
A-32. No.
l
Q-33 If your answer to Interrogatory 32 above is no:
a. Describe in detail each other instance of an
inadequate inspection on which you rely for your contention.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-33, a. While the instances cited in that part of amended !
, Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended ~ contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion' X.
Other.such instances include:
(1) An NRC CAT inspection found examples of inadequate
hardware inspection and raised concerns as to
dependence on Final Walkdown inspections late in the
program. Paragraph 1, subpart C, pages 20-21.
hs
"- (2) An NRC CAT found that first level quality control
inspection activities need to be improved, especially
in pipe support / restraints and welding areas.
Paragraph 1, subpart D(1), page 21.
(3) ' Edison has failed to assure that activities affecting
,, quality are appropriately verified for quality by
inspection. Paragraph 3, page 24-25.
1/
.
23
e
__ _ - _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ -
'
.
(4) Quality Control inspections during the welding process
were not of adequate scope and frequency to assure the
process of correct welding variables. Paragraph 3,
l subpart A(1), page 25.
!
(5) Quality control inspectors were given inappropriate
instructions as to Visual Weld Inspection Procedure.
Paragraph 3, subpart A, page 25.
(6) Quality control was not required to examine the base
metal prior to welding to assure that surfaces and
edges were free of discontinuities. Paragraph 3,
subpart A, page 26.
(7) Phillips, Getschow small bore pipe routing procedures
lacked inspection criteria. Paragraph 3, subpart
A(4)(b), page 26.
(8) Applicant had not established an inspection program for
structural beams that were modified during piping
installations. Paragraph 3, subpart B, page 27
,
!
(9) Applicant's electrical contractor utilized Level I
Quality Control inspectors for inspection and
acceptance of electrical welds. Paragraph 3, subpart
l C, page 27.
(10) Approved procedures for installation inspection of
mechanical safety-related equipment did not exist until
July 16, 1980, although numerous pieces of this
equipment were finally or partially installed prior to
this date. Paragraph 6, subpart A, page 30.
f
(11) There was no documented record or log specifying that a
I calibrated instrument was used to measure numerous pipe
bends for ovality requiring inspection measurements to
, the thousands of an inch. Paragraph 6, subpart B(3),
page 31.
(12) Required random visual checks of interface dimensions
7
of piping components were not being done. Paragraph 6,
subpart B(2), page 31.
(13) The piping contractor did not have a procedure for
producing an accurate In-Service Inspection drawing.
Paragraph 6, subpart C, page 31.
(14) Cables 2AF307 and 2AF154 were not routed by Comstock
per pull cards, and the QC inspector accepted the cable
pulls documenting that the cables were pulled in
accordance with the pull cards. Paragraph 6, subpart
E, page 32.
(15) Visual weld inspections were not performed on safety-
24
,
4
.
I
related full penetration welds completed under the
jurisdiction of Structural Specifications F/L-2735 and
F/L-2722. Paragraph 9, subpart A, page 35.
(16) Napolean Steel Contractors, Inc. QA program did not
require fit-up inspections for safety-related
structural steel members joined by welds and therefore,
QC personnel did not inspect and insure acceptable gaps
for weld joints. Paragraph 9, subpart E, page 36.
(17) Nonconforming welds completed by unknown welders were
" accepted-as-is" af ter only a visual examination.
Paragraph 12, subpart B(3), page 42.
(18) Phillips, Getschow identified numerous pieces of
equipment that had been installed without QC
verification of internal cleanliness. Paragraph 12,
subpart G, page 44.
(19) BCAP inspection effort needs to be improved in areas of
supports / restraints and piping runs. Paragraph 12,
subpart J, page 44.
b. Documents reflecting the instance described in
Interrogatory 33a(1) above are cited on page 21 of Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
thereto (Exh.10).
Documents reflecting the instance described in Interrogatory
33a(2) above are cited on page 21 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10).
Documents reflecting the instance described in Interrogatory
33a(3) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(4) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
25
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portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(5) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(6) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(7) above are cited on page 27 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(8) above are cited on page 27 of Intervenors' May 24, 1985,
1
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Motion To Admit Amended Quality Assurance Contention and relevant
'
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(9) above are cited on page 28 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 11).
L Documents reflectin6 the instance described in Interrogatory
33a(10) above are cited on page 30 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 3).
Documents reflecting the instance described in Interrogatory
33a(11) above are cited on page 31 of Intervenors' May 24, 1985,
26
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Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(12) above are cited on page 31 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(13) above are cited on pages 31-32 of Intervenors' May 24,
1985, Motion To Admit Amended Quality Assurance Contention and
relevant portions are included in the exhibits attached thereto
(Exh. 14).
Documents reflecting the instance described in Interrogatory
33a(14) above are cited on page 32 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 13).
Documents reflecting the instance described in Interrogatory
33a(15) above are cited on page 35 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 20).
Documents reflecting the instance described in Interrogatory
33a(16) above are cited on page 36 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 25).
Documents reflecting the instance described in Interrogatory
33a(17) above are cited on pages 42 43 of Intervenors' May 24,
1985, Motion To Admit Amended Quality Assurance Contention and
relevant portions are included in the exhibits attached thereto
27
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(Exh. 5).
Documents reflecting the instance described in Interrogatory
33a(18) above are cited on page 44 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 20).
Documents reflecting the instance described in Interrogatory
33a(19) above are cited on page 44 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10).
Q-34. Are you aware of any corrective actions proposed by
Applicant to improve its inspection program?
A-34. Yes.
Q-35. If the answer to Interrogatory 34 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 10. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 34.
A-35. a. Please refer to the answer given to Interrogatory
4a above. In addition, by letter of July 3, 1985, Applicant
circulated its June 21, 1985, response to the noncompliances in
inspection reports 85-15/16. They stated that this was an
isolated case and assert that no further corrective action is
required.
b. Please refer to the answer given in Interrogatory
4b above.
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c. Please refer to the answer given in Interrogatory
4c above.
Q-36. Are the instances set forth in subparts A.-D. of
paragraph 11 of your contention the sole basis for your
contention that the Applicant's program for the maintenance of
records is adequate?
A-36. No.
Q-37. If your answer to Interrogatory 36 above is no:
a. Describe in detail the other instances of
inadequate maintenance of records which form the basis for
paragraph 11 of your contention.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, i f
other than NRC documents, provide a summary of their contents.
A-37 a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion XV.
Other such instances include:
(1) Some General Electric "VULKENE" wire has been installed
without appropriate qualification to IEEE 383-1974.
Paragraph 8, subpart B, page 34.
(2) Piping material has been installed that did not meet
design requirements. Paragraph 10, subpart B, page 37
(3) Pipe installations were discoverd in Section III
installations without material test reports or records
of test reports or records of receiving and receipt
inspections. Paragraph 12, subpart B, page 42.
(4) Supports were found that were not procured and examined
in accordance with ASME Section III, section NF.
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Paragraph 12, subpart C, page 43
b. Documents reflecting the instance described in
Interrogatory 37a(1) above are cited on page 34 of Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
thereto (Exh.10).
Documents reflecting the instance described in Interrogatory
37a(2) above are cited on page 38 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 6).
Documents reflecting the instance described in Interrogatory
37a(3) above are cited on page 43 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
37a(4) above are cited on page 43 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 17).
Q-38. Are you aware of any corrective actions taken by
Applicant to improve the maintenance of QA records?
A-38. Yes.
Q-39 If the answer to Interrogatory 38 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 11. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
30
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Interrogatory 38.
A-39 a. Please refer to the answer given to Interrogatory
4a above.
b. Please refer to the answer given in Interrogatory
4b above.
c. Please refer to the answer given in Interrogatory
4c above.
Q-40. Are the instances set forth in subparts A.-J. of
paragraph 12 of your contention the sole basis for your conten-
tion that Applicant has provided an inadequate program for the
identification and correction of conditions adverse to quality.
A-40. No.
Q-41. If the answer to Interrogatory 40 above is yes:
a. Describe in detail such other instances the date of
occurrence of each such instance.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-41. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion XVI.
Other such instances include:
(1) Edison failed to take timely and effective corrective
action after identifying related significant problems
that occurred at its Byron station. Paragraph 1,
subpart A, page 19
(2) NRC CAT expressed concern over ability to manage the
31
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large number of ongoing major corrective action
programs. Paragraph 1, subpart C, page 21.
(3) NRC CAT inspection concluded that additional management
attention is required to improve contractor performance
in the ares of contractor deficiency trending, and
craft and quality control inspector training.
Paragraph 1, subpart F, page 22.
(4) No corrective action documents were written to identify
and track nonconforming conditions (loose crimps at the 1
determination blocks). Paragraph 11, subpart B, page 40.
b. Documents reflecting the instance described in
Interrogatory 41a(1) above are cited on page 19 of Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
thereto (Exh. 3).
Documents reflecting the instance described in Interrogatory
41a(2) above are cited on page 21 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10).
Documents reflecting the instance described in Interrogatory
41a(3) above are cited on page 22 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 10).
Documents reflecting the instance described in Interrogatory
41a(4) above are cited on page 40 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 26).
Q-42. Are you aware of any corrective actions which have
been taken by Applicant to improve the identification and correc-
tion of conditions adverse to quality?
A-42. Yes.
32
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Q-43 If the answer to Interrogatory 42 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 12. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 42.
A-43 a. Please refer to the answer given to Interrogatory
4a above. In addition, by letter of July 3, 1985, Applicant
circulated its June 21, 1985, response to the noncompliances in
inspection report 85-15/16. They stated that they believe this
was an isolated case and that to avoid further noncompliance they
will hold a training sesson for QA site personnel.
Q 44. Are there any instances other than those set forth in
subparts A. and B of paragraph 13 of your contention which form
the basis for your contention that maintenance of sufficient
records concerning activities affecting quality is inadequate?
A 44. -Yes.
Q 45. If the answer to Interrogatory 44 above is yes:
a. Describe in detail each such instance and the
date of occurrence of each incident.
b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-45. a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that l
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b
a
Applicant's Quality Assurance program violates this Appendix B
Criterion XVII.
Other such instances include:
(1) There was a lack of records documenting conformance
with the requirements of AWS D1.1-1977, Section 3, and
'
the Edison QA Manual. Paragraph 3, subpart A(3), page
26.
(2) A newly designed reactor coolant pump lateral support
anchorage was installed in Units 1 and 2 without
records to establish the material heat number, charpy
impact tests, lamination tests, welder identification,
weld procedure, weld filler material, in-process.
Inspections and other quality related records.
Paragraph 9, subpart B, page 36.
(3) 1/2" S/80, SA-312, Type 304, ASME Boiler and Pressure
Vessel Code, Section III, Class 1, NB pipe heat number
745107 were discovered in Section III installations
without material tests reports or records. Paragraph
12, subpart B, page 42.
(4) Audit did not verify that proper quality records were
being generated and maintained. Paragraph 14, subpart
A, page 46.
b. Documents reflecting the instance described in
Interrogatory 45a(1) above are cited on page 27 of Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
thereto (Exh. 5).
Documents reflecting the instance described in Interrogatory
45a(2) above are cited on page 36 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 20).
Documents reflecting the instance described in Interrogatory
45a(3) above are cited on page 42 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached- thereto (Exh. 5).
34
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Documents reflecting the instance described in Interrogatory
45a(4) above are cited on page 46 of Intervenors' May 24, 1985,
Motion To Admit Amended Quality Assurance Contention and relevant
portions are included in the exhibits attached thereto (Exh. 3).
Q-46. Are you aware of any corrective actions taken by
Applicant to improve the maintenance of records relating to
activities affecting quality?
A 46. Yes.
Q 47. If the answer to Interrogatory 46 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 13 State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 46.
A 47. a. Please refer to the answer given to Interrogatory
4a above.
b. Please refer to the answer given in Interrogatory
4b above.
c. Please refer to the answer given in Interrogatory
4c above.
Q-48. Are the instances set forth in subparts A. and B. of
paragraph 14 the sole basis for your contention that Applicant
failed to institute a systematic program of audits of quality
related activities?
A-48. No.
Q 49 If your answer to Interrogatory 48 above is yes:
!
a. Please describe in detail each instance.
35
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b. Identify all documents which relate to such
instances by title, author, if any, date of issuance and, if
other than NRC documents, provide a summary of their contents.
A-49 a. While the instances cited in that part of amended
Quality Assurance Contention, identified in this interrogatory,
serve as'the basis for that contention, other instances of
Quality Assurance deficiencies identified elsewhere in our
amended contention provide further support for our claim that
Applicant's Quality Assurance program violates this Appendix B
Criterion XVIII.
Other such instances include:
(1) Edison did not take appropriate corrective action with
regard to Audit QA-20-80-22. Paragraph 13, subpart A,
page 44.
b. Documents reflecting the instance described in
Interrogatory 49a(1) above are cited on page 44 of Intervenors'
May 24, 1985, Motion To Admit Amended Quality Assurance Conten-
tion and relevant portions are included in the exhibits attached
thereto (Exh.18). <
Q-50. Are you aware of any corrective actions taken by
Applicant to improve its program of audits of quality related
activities?
A-50. Yes.
Q-51. If your answer to Interrogatory 50 above is yes:
a. Describe such corrective actions with
particularity.
b. State your position as to whether such corrective
actions would or would not be adequate to remedy the situation
described in paragraph 14. State with particularity your basis
for your position.
c. Identify all documents relied upon in answering
Interrogatory 50.
36
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A-51. a. Please refer to the answer given to Interrogatory
4a above.
. b. Please refer to the answer given in Interrogatory
4b above.
c. Please refer to the answer given in Interrogatory
4c above.
DATbD: August 1, 1985
i
Robert GOild / \
One of the Attorneys for Intervenors
Bridget Little Rorem, et al.
Douglass W. Cassel, Jr.
Robert Guild
Timothy W. Wright, III
109 North Dearborn
Suite 1300
Chicago, Illinois 60602
(312) 641-5570
37
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CERTIFICATE OF SERVICE
D $h[
I hereby certify that I have served copies of '65
Agg _5 g;I 38
[Intervenors '] Response to NRC Staff Interrogatories To, .,.. _
'L'
Intervenor Bridget Little Rorem, Et Al. Concerning Its GO${Gy[I(gj-ki;.:
ea fP V!D
Quality Assurance Contention and Motion For Protective
Order on each party listed on the attached service list
by having said copies placed in envelopes, properly addressed
. and postaged (first class), and deposited in the U.S. mail
afterLclose of business on August 1,1985; except that
the NRC Staff counsel was served via Federal Express, also
on this 1st day of August, 1985.
'
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BRAIDWOOD SERVICE LIST
50-456/50-457 OL
Lawrence Brenner, Esq. Elaine Chan, Esq.
Chairman and Administrative Judge NRC Staff Counsel
Atomic Safety and Licensing Board U.S. Nuclear Regulatory
U.S. Nuclear Regulatory Commission Commission
Washington D.C. 20555 7335 Old Georgetown Road
Bethesda, MD 20014
Dr. A. Dixon Callihan
Administrative Judge Joseph Gallo, Esq.
102 Oak Lane Isham, Lincoln & Beale
Oak Ridge, TN 37830 Suite 840
1120 Connecticut Avenue N.W.
Dr. Richard F. Cole Washington D.C. 20036
Administrative Judge
Atomic Safety and Licensing Board Docketing & Service Section
U.S. Nuclear Regulatory Commission Office of the Secretary
Washington D.C. 20555 U.S. Nuclear Regulatory
Commission
Rebecca J. Lauer, Esq. Washington D.C. 20555
Isham, Lincoln & Beale
Three First National Plaza Atomic Safety and Licensing
Chicago , IL 60602 Board Panel
U.S. Nuclear Regulatory
Ms. Bridget Little Rorem Commission
117 North Linden Street Washington D.C. 20555
Essex, IL 60935
Atomic Safety and Licensing
C. Allen Bock, Esq. Appeal Board Panel
P.O. Box 342 U.S. Nuclear Regulatory
Urbana, IL 61801 Commission
Washington D.C. 20555
Thomas J. Gordon, Esq.
Waller, Evans & Gordon Michael I. Miller, Esq.
2503 South Neil Isham, Lincoln & Beale
Champaign, IL 61820 Three First National Plaza
Chicago, IL 60602
Lorraine Creek
Route 1, Box 182
Manteno, IL 60950
Region III
U.S. Nuclear Regulatory Commission
Office of Inspection & Enforcement
799 Roosevelt Road
Glen Ellyn, IL 60137
m