ML20214C596

Affidavit of Rd Schulz Supporting NRC Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 14.B.1.Supporting Documentation Encl

ML20214C596
Person / Time
Site:	Braidwood
Issue date:	02/13/1986
From:	Schultz R, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214C321	List: ML20214C317 ML20214C330 ML20214C334 ML20214C358 ML20214C380 ML20214C409 ML20214C439 ML20214C451 ML20214C468 ML20214C496 ML20214C514 ML20214C526 ML20214C552 ML20214C569 ML20214C580 ML20214C583 ML20214C596 ML20214C606 ML20214C628 ML20214C676
References
OL, NUDOCS 8602210198
Download: ML20214C596 (9)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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COMMONWEALTH EDIS0N COMPANY

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Docket Nos.

50-456

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50-457 (Braidwood Station, Units 1 and 2

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AFFIDAVIT OF ROBERT D. SCHULZ IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF ROREM QA SUBCONTENTION 14.B.1 I, Robert D. Schulz, being duly sworn, depose and state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission, Region III, as Resident Inspector at the Braidwood Station, Unit 1 and 2.

A copy of my professional qualifications is attached hereto as Exhibit 14.B.1.

2.

As Senior Construction Resident Inspector I am responsible for planning, coordinating, and personally conducting.or leading inspections for the construction of Braidwood Station to assure compliance with design specifications, the conditions of the construction. permit, provisions of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, and the rules and regulations of the Commission.

3.

The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Summary Disposition of Rorem QA Subcontention 14.B.1.

This subcontention states as follows:.

14. Contrary to Criterion XVIII, " Audits," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a 8602210198 86021846y DR ADOCK O

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comprehensive system of planned and periodic audits is carried.out to verify compliance l

with all aspects of the quality atsurance

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program and to detennine the effectiveness of the program.

The Applicant also failed to ensure follow-up action, including reaudit of deficient areas.

B.

A special NRC QA inspection reported May 7, 1984 that:

1.

Mechanical contractor Phillips, Getschow, Co.

has not established and executed a plan for auditing the implementing procedures of the quality assurance program on a period (sic) basis to determine the effectiveness of the program in accordance with the Phillips, Getschow QA Manual.

4.

In preparing this Affidavit I reviewed the following documents:

a.

" Statement of Material Facts As To Which There Is No Genuine Issue" for Sut: contention 14.B, Part One - Phillips Getschow Company b.

" Testimony of Scot T. Forbes (on Rorem Q.A. Subcontentions 14.B.1):"

c.

"NRC Inspection Report Nos. 50-456/83-09 and 50-457/83-09" pertinent parts of the report and notice of violation are attached as Exhibit 14.B.1-2; d.

"NRC Inspection Report Nos. 50-456/85-52 and 50-457-85-50" (pertinent portions attached as Exhibit 14.B.1-3) 5.

I identified the item which forms the basis for this subcontention during a documentation review of Phillips Getschow Company's audit program which is documented in NRC Inspection Report Nos. 50-456/83-09 and 50-457/83-09 (see Exhibit 14.B.1-2).

I found that

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the piping contractor had not established and executed a plan for auditing the implementing procedures of the quality assurance program.

6.

The Aoplicant implemented a corrective action program which included the following actions:

a.

establishment and implementation of a Phillip Getschow audit program that covers all the implementing procedures; b.

performance of a comprehensive review of past auditing activities, taking into account both Applicant and piping contractor audits. Applicant determined that this combination of audits was appropriate to assure acceptable confidence level for Braidwood installations or documentation. The Applicant's review took in account all subsequent retro-fit programs; and c.

Verification of the implementation of the Phillips Getschow Company Audit Plans by Applicant (through its own audits and surveillances) to prevent recurrence of this audit problem in the future.

7.

I reviewed and evaluated the corrective actions described in Paragraph 6.

On the basis of that review, I was satisfied that these measures would remedy the problem identified in Rorem Subcontention 14.B.1.

I verified that Applicant has implemented the corrective actions discussed above. To the best of my knowledge there has been no recurrence of the type of violation which forms the basis of Rorem Subcontention 14.B.1.

8.

The corrective actions taken by Applicant to address this violation are sufficient to prevent recurrence and to assure that

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construction quality has not been affected adversely as a result of the violation.. Consequently, the Staff's concerns closed this issue in NRC Inspection Report Nos. 456/85-52 and 457/85-50 (see Exhibit 14.B.1-3).

Nad b s a Robert D. Schulz Sworn and subscribed before me this /J Eday of February, 1986 aAd AL Notary Public f(

Ily0:es*:d::L;.'ze:1p:.;0,;;O My Comission expires:

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Professional Oualifications ROBERT D. SCHULZ Organization:

U.S. Nuclear Regulatory Connission, Region III

Title:

Senior Resident Inspector of Construction Birth Date:

June 9, 1948 Education:

B.S., Northern Illinois University; 1.970 Completed BWR Technology Courses and Two-Week PWR Technology Course, Chattanooga, TN Experience:

1984 to Senior Resident Inspector (Construction) -

Present Braidwood Site.

Plans, supervises and conducts inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media.

(NRC) 1983 to Reactor Inspector - Inspects reactors under 1984 construction and in operation.

(NRC) 1982 to Senior Resident Inspector - Nine Mile Point Plant, 1982 Region I, Construction Site.

Plans, supervises and conducts inspections at the site.

Represents the NRC to the licensee, state and local officials, and the news media.

(NRC) 1981 to Resident Inspector.- Nine Mile Point Plant, Region I, 1982 Construction Site.

Performed 2513 and 2514 inspection programs at the Nine Mile Point Plant.

(NRC) 1980 to Reactor Inspector - Inspected reactors under 1981 construction and in operation in Region III.

(NRC) 1975 to Q. A. Engineer - Morrison Construction and 1980 Engineering, LaSalle Station, Braidwood Township, IL.

I Mechanical Contractor.

l 1973 to Senior Buyer - Sundstrand Nuclear, Belvidere, IL.

1975 Purchased material for the Fast Flux Test Facility located in Hanford, Washington.

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1971 to Quality Control Inspector - Morrison Construction 1973 and Engineering, Zion Station, Zion, IL. Mechanical Contractor.

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U. S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/83-09(DE); 50-457/83-09(DE)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Braidwood - Units 1 and 2 Inspection At: Braidwood Site - Braidwood, IL Enforcement Conferences At: Region III Office, Glen Ellyn, IL l

Inspection Conducted:

June 20-24, June 27-July 1, August 1-5, August 9, October 4-7, October 24, 1983, Jam'sry 11-13, January 26, and February 9, 1984 Enforcement Conferences Conducted: December 20, 1983 Harch 7, 1984 h M -- E R. D. Schulz %

gM/84 4

Inspectors:

Date 4%

. T. Yin d,Y Date

'l T. E. Vandel J-J/-

~

Date h.

D. E. Keating b

Date Approved By:

D. R. Hunter, Chief N"L4 /

Management Programs Section Date Inspection and Enforcement Conference Summary Inspection on June 20-24, June 27-July 1, August 1-5, August 9, October 4-7 October 24, 1983, and January 11-13. January 26, and February 9, 1984; and Enforcement Conferences on December 20, 1983, and March 7, 1984 (Report No. 50-456/83-09(DE); 50-457/83-09(DE))

O

l fy. A N - i-Notice of Violation 4

WAY 7 1984 Contrary to the above:

Instructions were not appropriate to the circumstances in that a.

welding procedures specifying the essential variables were not prescribed on drawings or welding sequences (travelers) for cd.

specific HVAC installation, and Quality Control inspections during the welding process were not of adequate scope and frequency to l

assure the use of correct welding variables.

1 b.

Quality Control was not-required to examine the HVAC components for fit-up yrior to welding on those components where fit-up tolerances cannot a determined after welding, such as all-around fillet welds and full penetration welds.

Consequently there was a lack of records documenting the confonnance with the requirements of AWS D1.1-1977 Section 3, and the Ceco QA Manual.

Additionally, instructions to the quality control inspectors regarding fillet weld gaps after welding were not appropriate to the circumstances in that the HVAC contractor Visual Weld Inspection Procedure, B10.2.F. stated that a 3/16" gap i

was acceptable whereas AWS D1.1-1977, Section 3.3, states that a 3/16" gap is allowed only if the leg of the fillet weld is increased by the l

amount of the separation or the contractor demonstrates that the required effective throat has been obtained.

Quality Control was not required to examine the base metal prior c.

to welding to assure that surfaces and edges were free of dis-continuities.

conformance with the requirements of AWS D1.1-1977, Cons i

the CECO QA Manual.

Section 3, and 1

This is a Severity Level IV ~ iolation (Supplement II).

v 4.

10 CFR 50, Appendix B, Criterion XVIII, as implemented by the CECO QA Manual, QR No. 18.0, requires,.in part, that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program and to determine the effective-ness of the program.

Contrary to the above:

Phillips, Getschow Company has not established and executed a plan a.

for auditing the implementing procedures of the quality assurance l

program on a periodic basis to determine the effectiveness of the program in accordance with the PG QA Manual Section 16.

b.

L. K. Comstock Company /L. K. Comstock Engineering Company auditing activities neither conformed with the comprehensive annual schedule of planned and periodic audits established as required by QA Program l

Manual Section 4.14.1, nor did they verify compliance with all aspects of the Quality Assurance Program.

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ff. N.6,1 A Notice of Violation 5

Iw'Y 7 I904 Pullman Construction Industries, Inc., did not meet their yearly c.

schedule for audit activities required by their QA Manual, Section 18, in that the following implementing procedures were not audited:

- B 3.1.F. Design Control i

- B 5.1.F. HVAC Repair Adjustment

- B 9.3.F. Expansion Anchor Installation

- B 10.2.F. Visual Weld Inspection d.

The licensee's audits of the installation of small bore instrumen-tation and process piping were inadequate in that contractor hanger design calculation problems were not identified for more than two years.

This is a Severity Level IV violation (Supplement II).

5.

10 CFR 50, Appendix B, Criterion VI, requires that measures be established to control the issuance of documents and these measures assure that changes to those documents are reviewed for adequacy and approved for release by

• authorized personnel and are distributed to and used at the location where the prescribed activity is perforined.

CECO QA Manual, QR No. 6.0, Paragraph 6.1, requires that a document control system be used, including changes, and the documents and changes be reviewed and approved for release by authorized personnel.

QP No. 6-2, Paragraph 4.3.1, requires that field changes to drawings be submitted with a Field Change Request.

Contrary to the above, adequate measures had not been established to control field changes to drawings being made during the installation of ASME Boiler and Pressure Vessel Code,Section III, Class 2 and 3, 2" and under piping.

Craft personnel.had been making field changes to the drawings by rerouting lines, assigning weld numbers, and adding material which resulted in a lack of necessary control of approving, updating, and releasing drawings.

j This is a Severity Level IV violation (Supplement II).

6.

10 CFR 50, Appendix B, Criterion II, requires, in part, that a quality assurance program be established which complies with the requirements of Appendix B-and that the program be documented by written policies, procedures, or instructions and carried out in accordance with these instructions.

The quality assurance program shall provide control over activities affecting quality and shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Criterion III requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions and

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Shkth)h lY.8d-3 U. S. NUCLEAR REGULATORY COMISSION REGION III Report No. 50-456/85052(DRP); 50-457/85050(DRP)

Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee:

Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Braidwo'od. Station, Units 1 and 2 Inspection At:

Braidwood Site, Braidwood, IL Inspection Conducted:

October 21 through November 30, 1985 Inspector:

R. D. Schulz W. J. Krepp k

Approved By:

W. S. Little, Director

/2 /6ds

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Braidwood Project Date Inspection Summary Inspection on October 21 through November 30, 1985 (Report No.

50-456/85052(DRP); 50-457/85050(DRP))

Areas Inspected:

Routine safety inspection of licensee action on previously identified items, licensee action on 10 CFR 50.55(e) reports, plant tours, structural steel, and trending.

The inspection involved a total of 186 inspector-hours onsite by two NRC inspectors, including 38 inspector-hours onsite during off-shifts.

Results:

No violations or deviations were identified.

I M W 2"i, G51205 hDR ADOCK 05000456 PDR

[ N / M /.3 system not qualified in accordance with ANSI N101.2.

The coating contractor issued Nonconformance Reports 23, 24, 25, and 26 to document and disposition the areas in the Unit 1 and Unit 2 containments, where repairs were do'ne with a process not qualified to ANSI N101.2.

The nonconformances were dispositioned "use-as-is" and were approved by Sargent & Lundy (S&L).

The justifications for the disposition were documented by S&L on Design Information Transmittals (DITs) BR-SSD-0032-0 and BR-SSD-0005-1 and were found to be acceptable.

These DITs documented that the square footage of the areas repaired was limited (less than 200).

This area is identified by S&L on a coatings exception list which is being prepared for identifying unqualified coatings in the containments.

The inspector also verified that the coating contractor. Midway, has a qualified coating repair procedure (C.P. 3A, Revision 4) approved by S&L.

(Closed) 456/83-09-08A; 457/83-09-08A:

Phillips Getschow Company had not established and executed a plan for auditing the implementing procedures of the quality assurance program.

Phillips Getschow Company revised their audit schedule on August ~21, 1983, to include auditing all the implementing procedures annually.

The inspector verified that audits are being performed in accordance with the audit schedule.

A comprehensive review was accomplished by the licensee and piping contractor with regard to past auditing activities.

Each implementing procedure approved for use at the site was analyzed against both the piping contractor's and licensee's audits.

Based on this combination of audits, which were conducted to determine compliance with the Phillips Getschow Quality Assurance Manual and inherent overlap into the implementing procedures the review concluded that no questionable areas remained.

The evaluation also took into account the nature of the task and retrofit programs which have been implemented.

The inspector examined this comprehensive review and found it to be satisfactory for resolving the question of past auditing activities in relation to programmatic and regulatory compliance.

l (Closed) 456/83-09-08C; 457/83-1)9-08C:

Pullman Construction l

Industries, Inc. audit program did not cover all the implementing i

procedures.

Pullman has implemented an audit schedule that provides for auditing the entire population of implementing procedures.

The implementing procedures not previously covered and identified in 1983 included:

B3.1.F, Design Control B5.1.F, HVAC Repair Adjustment B9.3.F, Expansion Anchor Installation B10.2.F, Visual Weld Inspection 1

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Evaluations by the licensee and Pullman concluded that either the procedures were adequately implemented or corrective actions have been identified to assure compliance with the procedures.

The evaluations are summarized below:

Procedure B3.1.'F has been adequately audited at the site based on:

Sargent and Lundy review and approval of all duct brochure details, all field and shop procedures, and all design documents.

i Surveillances and audits performed by Pullman and the licensee.

Procedure B5.1.F has been adequately audited at the site based on:

Licensee reviews which resulted in reinspection activities delineated in Nonconformance Reports 349, 353, 407, 460, 540, 558, 632, and 606.

Licensee reviews which resulted in the corrective actions required by 10 CFR 50.55(e) reports 82-01, 83-01, 83-08, and 84-08.

Procedure 89.3.F has been adequately audited at the site based on the Pullman expansion anchor installation retro inspection performed in accordance with licensee Nonconformance Reports 658 and 659.

Procedure B10.2.F has been adequately audited at the site based on:

Pittsburgh Testing Laboratory 10% overview of Pullman weld inspections.

Surveillance and audits performed by Puliman and the licensee.

The inspector found the evaluations thorough and supporting the adeq'scy of past construction activities.

4 b.

Unresolved Items (Closed) 456/84-08-06; 457/84-08-06:

Three ASTM A-490 structural steel bolting connections were found in Containment 2 to have low torque values for some of the bolts in the connection.

An engineering review was performed by Sargent & Lundy for all connections in both containments.

The review concluded that only friction type connections, and not bearing type connections, required tightening to the original 4

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