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UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

In the Matter of )

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456) 50-457

(Braidwood Station,' Units 1 and 2 )

AFFIDAVIT OF JAMES W. MUFFETTIN SUPPORT OF NRC STAFF'S RESPONSE TO

APPLICANT'S MOTION FOR SUMMARY DISPOSITION OFROREM QA SUBCONTENTION 5.C

I, James W. Muffett, being duly sworn, depose and state as follows:

1. I am employed as a Reactor Inspector (Mechanical Engineer) by

the U.S. Nuclear Regulatory Commission (NRC), Region III, 799 Roosevelt

Rd, Glen Ellyn, IL 60137. I have been employed by the NRC in this

capacity since August 1983. A copy of my Statement of Professional

Qualifications is attached hereto as Exhibit 5.C-1 to this affidavit.

2. As a Reactor Inspector, I am primarily responsible for

reviewing the design of and performing inspections of mechanical and -

~

structural components.

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 5.C. This subcontention states as follows:

5. Contrary to Criterion III, " Design Control,"of 10 C.F.R. Part 50, , Appendix B,Comonwealth Edison Company has failed toestablish measures to assure that applicableregulatory requirements and design bases arecorrectly translated into specifications,drawings, procedures, and instructionsincluding provisions to assure thatappropriate quality standards are specified in

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8602210117 860210y46PDR ADOCK OG

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design documents and the deviations from such -

standards are controlled. Applicant has alsof, ailed to requirement that measures areestablished for the identification and controlof design interfaces and for the coordinationamong participating. design organizations, thatthe measures include the establishment ofprocedures among participating designorganizations for the r,eview, approval,release, distribution, and revision ofdocuments involving design interfaces; andthat the design control measures provide forverifying or checking the adequacy of design,-such as by the performance of design reviews,by the use of alternate or simplifiedcalculational methods, or by the performanceof a suitable testing program.

C. Edison employed designs for safety-relatedHVAC duct supports based on Chapter E36.0 ofS&L's Structural Standard Document which didnot limit the slenderness ratio for ceilingmounted duct supports. (Inspection ReportNo. 85-43/39, Exh. 19.)

4. In preparing this Affidavit I reviewed the following materials:

a. Applicant's Statement of " Material Facts As To Which There

Is No Genuine Issue To Be Heard;"

b. Testimony of Kenneth T. Kostal (On Rorem Q. A.e;

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Subcontention 5 C)

c. Inspection Report Nos. 50-456/84043 and 50-457/84039;

d. Applicants Response to Inspection Report Nos. 50-456/84043

and 50-457/84039;

e. Inspection Report Nos. 50-456/85040 ar.d 50-457/85040

5. I identified the violation upon which Rorem Subcontention 5.C

is based. The violation was identified during an inspection conducted by,

me to address concerns raised by an expert witness during the remanded

licensing hearing for the Byron Station. During the inspection I

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discovered that Chapter E36.0 of Sargent & Lundy's Structural Standards ,

Document ("SSD") did not contain a limit on slenderness ratio for ceiling

mounted HVAC duct supports. Upon further inspection, I determined that

all other sections of the SSD contained the necessary guidance on maximum

allowable slenderness ratios.

6. In that the appropriate limitation on slenderness ratio for

-

ceiling mounted HVAC duct supports was not included in the design

specification for these items, the Applicant was in violation of 10 CFR

Part 50, Appendix B, Criterion III. The circumstances surrounding this

violation are discussed more fully in Inspection Report Nos. 50-456/85043

and 50-457/84039, the pertinent portions of which are attached as'

Exhibit 5.C-2 to this Affidavit.

7. In its response to Inspection Report Nos. 50-456/84043 and

50-457/84039, Applicant proposed to take a number of corrective actions.

These actions include (i) reevaluation of existing designs to determine

structural adequacy (ii) revision of Chapter E36.0 to incorporate the

limit on slenderness ratio (iii) review of its Structural Standard Docu-

ment for omission of similar requirements. Exhibit 5.C-4.

( 8. I reviewed and evaluated Applicant's proposed corrective action

plan and am satisfied that the plan contained proposed corrective actions,

|sufficient to remedy the effects of the violation and render the

j possibility of recurrence minimal.

9. I verified the implementation of the corrective actionsi

' described in Paragraph 7 and on that basis closed this matter ini; Inspection Report Nos. 50-456/85040 and 50-457/85039, the pertinent part

of which is attached as Exhibit 5.C-3 to this Affidavit.

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10. The violation that forms the basis of Rorem Subcontention 5.C -

represents an isolated incident of failure to incorporate a single design

parameter in a design specification. For this reason, this violation

does

not represent a significant breakdown in Applicant's quality assurance

program. Consequently, I agree with Applicant that there is no genuine

issue to be litigated regarding Rorem Subcontention 5.C..

e=

hy"-

James W. Muffett M '

Sworn and subscribed before methisi15 day of February,1986

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L . .r u _Y.: *

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Notary Public ..

My Commission expires:' *' * ' ' -'

ht|r|| $ C-f- 41 -

Professional Qualifications ,

JAMES W. MUFFETT

Organization: Region III

Title: Reactor Inspector (Mechanical)

Birth Date: January 5, 1950

Education: B.S. Physics, Purdue University 1972M.S. Mechanical Engineering

University of Idaho 1978

Reg'istration: Professional Engineer, Illinois, Indiana, Minnesota

Experience:

1983 - Present Reactor Inspector - Responsible for inspection ofreactor under construction and in operation.

1981 - 1983 Engineering Manager - Managed mechanical design andanalysis group with staff of 20 (NuTech).

1980 - 1981 Product Engineer - Responsible for development ofadvanced design methods. (International Harvester)

1978 - 1980 Senior Engineer - Responsible for development andapplication of advanced design methods. (CumminsEngine Co., Inc.)

1975 - 1978 Group Leader - Leader of piping analysis groupwhich performed piping analysis for LOFT reactor atIdaho National Engineering Lab. (EG & G Idaho)

1972 - 1975 Stress Analyst - Performed piping stress analysis,support design and field interface duties at variousnuclear power stations. (Sargent & Lundy)

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/s~ f4W fc-2UNITED STATESfNUCLEAR REGULATORY COMMISSIONgy a REG 80N lli

.,79e ROOSEVELT ROAD

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GLEN sLLYN. 8LLINots 00137

March 15, 1985

Docket No. 50-454Docket No. 50-455Docket No. 50-456 -

Docket No. 50-457 A

Commonwealth Edison CompanyATTN: Mr. Cordell Reed -

Vice PresidentPost Office Box 767Chicago, IL 60690

Gentlemen:

This refers to the special safety inspection conducted by Messrs. J. W. Muffett,K. D. Ward, R. S. Love, J. A. Jacobson, and J. Schapker, of this office onSeptember 24, 1984 through February 4,1985, of activities at Sargent & LundyEngineers, Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2,authorized by NRC Operating License NPF-37, and NRC Construction PermitsCPPR-131, CPPR-132, and CPPR-133. The inspection was conducted to reviewconcerns expressed by an expert witness who appeared on behalf of the Inter-venors during the remanded Atomic Safety Licensing Board hearing for the ByronStation operating license.

The enclosed copy of our inspection report identifies areas examined duringthe inspection. Within these areas, the inspection consisted of a selectiveexamination of procedures and representative records, observations, andinterviews with personnel. The report also contains your responses to thequestions asked by this office regarding the concerns.,

During this inspection, certain of your activitie~ s appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.A written response is required.

; In addition to the noncompliances, a number of design practices were foundto be in need of improvement. During the inspection appropriate correctiveactions were taken by your architect engineer to effect the needed improve-ments in the design process. The positive attitude exhibited by you and yourarchitect engineer toward the prompt resolution of all issues and thewillingness to implement improvements in the design process are encouraging.

! In accordance with 10 CFR 2.790(.n), a copy of this letter and the enclosures'

will be placed in the NRC Public Document Room.|

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Commonwealth Edison Company 2 *

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The responses directed by this letter (and the accompanying Notice) arenot subject to the clearance procedures of the Office of Management andBudget as required by the Paperwork Reduction Act of 1980, PL 96-511.

-- Sincerely,4

MM->

y . -

J. F. Streeter, DirectorByron Project Division

Enclosures:1. Appendix, Notice

of Violation2. Inspection Reports

No. 50-454/84-71(DRS);No. 50-455/84-49(DRS);No. 50-456/84-43(DRS);No. 50-457/84-39(DRS)

: cc w/encis:D. L. Farrar. Director

of Nuclear LicensingV. I. Schlosser Project ManagerGunner Sorensen, Site Project

SuperintendentR. E. Querio, Station

| Superintendent

DDB/ Document Control Desk (RIDS)| Resident Inspector, RIII Syron ,~

Resident Inspector, RIII *'

BraidwoodPhyllis Dunton, Attorney

,General's Office, Environmental

I Control DivisionD. W. Cassel, Jr. , Esq.Diane Chavez DAARE/ SAFEW. Paton, ELD

t L. 01shan, NRR LPMM. Wallace, Project Manager8. Shamblin, Construction,

! Superintendent! J. F. Gudac, Stationi Superintendent'

C. W. Schroeder, Licensing andCompliance Superintendent

j H. S. Taylor, Quality AssuranceDivision. S&L'

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Appendix '

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NOTICE OF VIOLATION,

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Commonwealth Edison Company Docket Nos. 50-454; 50-455Byron Station, Units 1 and 2 50-456; 50-457

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As a result of the inspection conducted on September 24, 1984 throughFebruary 4,1985, and in accordance with the General Policy and Procedures.

1

for NRC Enforcement Actions, (10 CFR Part 2 Appendix C), the followingviolations were identified:

1. 10 CFR 50, Appendix B, Criterion XVII requires that records tofurnish evidence of activities affecting quality be identifiableand retrievable.

.

i

The Ceco Corporate Quality Assurance Manual and the Ceco QualityAssurance Procedures Manual commit to the above 10 CFR, Appendix Brequirements in Section 17. The Ceco Corporate Quality AssuranceManual states, " Quality Assurance records will be stored in a-

predetermined location as necessary to meet the requirements ofapplicable standards, codes and regulatory agencies and shall be;

accessible to Edison."

Contrary to the above, the Sargent & Lundy Engineers calculationswhich provided the original justification for the 5 factor design,

methodology and magnitude were not retrievable.,

j This is a Severity Level IV violation (Supplement II)(454/84-71-01(DRS); 455/84-49-01(DRS); 456/84-43-01(DRS);;

! 457/84-39-01(DRS)).

2. 10 CFR 50, Appendix 8, Criterion III requires 'that design controlmeasures include provisions to assure that appropriate qualitystandards are specified and included in design documents and thatdeviations from such standards are controlled."

Ceco Quality Procedure Q.P. No. 3-1 requires that "... designrequirements, including regulatory requirements, codes andstandards be utilized in the development of specifications,drawings, procedures, and instructions."

The AISC Steel Construction Manual (Section 1.8) committed to inthe FSAR identifies the slenderness ratio (KL/r) for structuralsteel members as a controlled design parameter for compressionmembers.

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I -*~*ea -- w e w w .,wm.-% w ,.w.w-,,cy_vcw_., py, ., - ,wmpw _

$1 S~ C - 2.

Appendix 2.

Contrary to the above, CECO employed designs.for safety-relatedHVAC duct supports based on Chapter E36.0, " Safety-Related HVACDuct Supports " of S&L's Structural Standard Document which didnot limit the slenderness ratio (KL/r) for ceiling mounted duct

--supports.

This is a Severity Level V violation (Supplement II)(454/84-71-02(DRS); 455/84-49-02(DRS); 456/84-43-02(ORS);457/84-39-02(DR3)).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit tothis office within thirty days of the date of this Notice a written statementor explanation in reply, including for each item of noncompliance: (1) cor-rective action taken and the results achieved; (2) corrective action to betaken to avoid further noncompliance; and (3) the date when full compliancewill be achieved. Consideration may be given to extending your response timefor good cause shown.

March 15, 1985 -

Dated J. F. Streeter, DirectorByron Project Division

.

CM

Furthermore, the AISC Specification for Structural Joints using ASTM A325 orA490 Solts requires that holes be 1/16" in diameter larger than the bolt

.

diamete'. The calculations in question show that for a %" e bolt, a 9/32" sr

hole was provided. This is a 1/32" difference which 13 conservative when.

compared to AISC recommendations.i

NRC Review and Conclusion Regarding Concern C.6.ci

_

It is , theoretically true that slightly different bearing stresses will bedeveloped when the bolt is not centered in the hole. In this case, the loadsand stresses are very small and refining the calculation to account for thiseffect will not change the result.o

Concern C.6.d1

. Based on review of Drawing 6E-0-33938, " Category I Conduit Supports - Typical! Support and Load Tables," support Type CF & MCF (floor to ceiling), and Type

CC & CP maximum load tables, it appears that the KL/r for many of those shownexceeds 200.

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|Licensee Response to Concern C.6.d

!

The allowable load tables shown on Sargent & Lundy design drawing 6E-0-33938,: " Category I Conduit Supports - Typical Support and Load Tables," are designed| based on AISC Specifications as stated in FSAR Section 3.10.3.2.2 (page 3.10-6)! and not on any undocumented information contained in the Unistrut Catalog.

There is no effective length factor "K" to consider since the member typesj indicated CC, CP, CF, and MCF are tension members, as demonstrated by the

connection details provided on the design drawings.;

! According to AISC Commentary Section 1.6, the last paragraph, "The slenderness| limitations recommended for tension members are not essential to the structural

integrity of such members; they merely afford a degree of stiffness such that;

: undesirable lateral movement (' slapping' or vibration) will be avoided. Thesei limitations are not mandatory." -

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| The attached sketch shows hanger H056 on drawing 6/20-E-1-3052 which is the' cable tray hanger that was alleged to have a KL/r ratio exceeding allowable! limits.

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| The vertical member has a calculated KL/r value of 192. The internal diagonalhas a calculated KL/r value of 208.

Although the internal diagonal has a KL/r value slightly higher than 200, it| 1s a secondary member in the sense that it does not carry gravity loads (i.e.,

| cable or tray weight) and is not required for stability of the hanger. Thisdiagonal only resists lateral loads due to a seismic event. The Ibads are ofshort duration and are reversible. Therefore, the local buckling 'due to thisshort term transient will not effect the overall behavior or structuralintegrity of the support.

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The allowable axial stresses for this hanger were calculated using Equation 1.5-2from the AISC Specifications, which states: -

F, , 12*2E2

23(KL/r)

Iha actual KL/r ratios for the hanger were used in this equation, and the.

allowable stresses were reduced accordingly.

In addition, this hanger is top supported and is a tension type system.Therefore, this hanger will not locally buckle. However, if local bucklingshould occur in this type of system, the diagonal would be restored to itsoriginal configuration due to the vertical gravity load and the reversiblelongitudinal loads.

NRC Review and Conclusion Recarding Cnneern C.6.d

The members mentioned in this concern all have the potential to be placedin compression by a seismic event. The diagonal braces and "out-of plane"braces will only be loaded during a seismic event. The AISC Manual to whichthe licensee committed in the FSAR states that "The slenderness ratio, KL/r,of compression members shall not exceed 200." Thirty-eight hangers havingmembers which will experience compressive load and which have KL/r in excessof 200 have been identified at Byron and 41 at Braidwood. All of these hangerson Byron 1 and some on Byron 2 were repaired prior to fuel loading and the

j majority of the repairs were inspected by the Staff. The following Byron 1'

repaired hangers were inspected and found to be acceptable:

HVAC Supports

| Hanaer Drawing

322 M-1311-5' 1108 1313-5

1110 1313-52214 1326-42233 1326-4 *

2237 1326-4218 1310-6607 1312-2791 1312-7

3899 1323-103901 1323-10

323 1311-5

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Cable Tray Hancers

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Hanaer Drawing

443 E-0-3033H069 1-3052H103 1-3052 .

H063 1-3052--

H056 1-3052H090 1-3052H118 1-305270H1 0-3031H004 1-3053H8 1-3251H9 1-3254H10 1-3251HS 1-3251H6 1-3251

During a February 5,1985 meeting between the licensee, Sargent & LundyEngineers, NRR, and Region III, all parties agreed that the KL/r limitationin the AISC Manual does not affect the stability or strength of the ceilingmounted members which experience compressive loads only during a seismic event.However, failure to reflect the KL/r ratio limit of the AISC Manual in thedocuments governing design in this area is a violation of 10 CFR Part 50,Appendix B, Criterion III, which requires the appropriate quality standardsand code provisions to be specified in design standards (454/84-71-02(DRS);455/84-49-02(DRS); 456/84-43-02(ORS); 457/84-39-02(DRS)).

The licensee agreed to submit a change of the FSAR to NRR which will indicatethe licensee's exception to the AISC KL/r limitation. The licensee will notpursue modifying the hangers on Byron 2 and Braidwood 1 and 2 having KL/rratios greater than 200.

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Concern C.6.e

Based on review of Drawing 6E-0-3393E, the load table for steel conduit seems.to disagree with the table in the Unistrut Catalog, Page 113.

Licensee Response to Concern C.6.e

See Response B.2.aa.

NRC Review and Conclusion Regardino Concern C.6.e

See NRC Review and Conclusion Regarding Concern 8.2.aa.*

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Concern C.7

An NRC letter dated September 30, 1983, to Commonwealth Edison Company con-cerning Integrated Design Inspection 50-454/83-32 has a calculation whichis difficult to follow on Pages 4-11 in the last two paragraphs.

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8/vif f.c- 3

NOV 221985,

Docket No. 50-456Docket No. 50-457

Commonwealth Edison CompanyATTN: Mr. Cordell Reed

Vice PresidentPost Office Box 767Chicago, IL 60690

Gentlemen:

This refers to the routine safety inspection conducted by Messrs. J. Jacobsonand J. Muffett of this office on August 19, 22, September 17-19, andOctober 3-4, 16-18, 24, 1985, of activities at Braidwood Station, Units 1i

and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133'

and to the discussion of our findings with Mr. C. Schroeder and others at thei conclusion of the inspection.;

The enclosed copy of our inspection report identifies areas examined during,

. the inspection. Within these areas, the inspection consisted of a selectivej examination of procedures and representative records, obssrvations, and

interviews with personnel,i.

No violations of NRC requirements were identified during the course of thisinspection.

; In accordance with 10 CFR 2.790 of the Commission's regulations, a copy ofthis letter and the enclosures will be placed in the NRC's Public DocumentRoom.

:'

We will gladly discuss any questions you have concerning.this inspection..

Sincerely,

j ce;,:.1t;;:dbh'JIJ.;hrt::n~

J. J. Harrison, ChiefEngineering Branch

Enclosure: Inspection ReportNo. 50-456/85040(DRS);No. 50-457/85039(DRS),

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See Attached Distribution;

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[K [ C- 3

Commonwealth Edison Company 2NOV 2 21985

.

Distribution.

cc w/ enclosure:D. L. Farrar, Director

of Nuclear LicensingM. Wallace', Project ManagerD. Shamblin, Construction

SuperintendentJ. F. Gudac, Plant ManagerC. W. Schroeder, Licensing and

Compliance SuperintendentDCS/RSS (RIDS)Licensing Fee Management Branch

'| Resident Inspector, RIII ''

BraidwoodResident Inspector, RIII ByronPh/111s Dunton, Attorney

General's Office, EnvironmentalControl Division

D. W. Cassel, Jr. , Esq.J. W. McCaffrey, Chief, Public

Utilities DivisionH. S. Taylor, Quality Assurance

DivisionE. Chan, ELDJ. Stevens, NRRThe Honorable Herbert Grossman, ASLBThe Honorable A. Dixon Callihan, ASLBThe Honorable Richard F. Cole, ASLB

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U.S. NUCLEAR REGULATORY COPWISSION, .

REGION III

^

Reports No. 50-456/85040(DRS);50-457/85039(DRS)

i Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133

Licensee: ' Commonwealth Edison Companyi Post Office Box 767

Chicago, IL 60690;

'Facility Name: Braidwood Station, Units 1 and 2

Inspection At: Braidwood Site, Braidwood, IL e

Inspection Conducted: August 19, 22, September 17-19, and October 3-4,16-18, 24, 1985

W: WInspectors M . Jacobson it s a//4-

J Date

d%E '

ola./s,,a. nuffettDate'

& *0|::-Approved By: D. H. Danielson, Chief l'/&1//f~

. Materials and Processes Section Date:i

Inspection Summary,

*

Inspection on August 19. 22. September 17-19, and October 3-4. 16-18, 24. 1985(Reports No. 50-456/85040(DRS): 50-457/85039tDRS)?

j Areas Inspected: Announced safety inspection of icensee actions concerningprevious inspection findings and one 50.55(e) ites. The inspection involved atotal of 122 inspector-hours by two NRC inspectors.Resu1*s: No violations or deviations were found.

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DETAILS

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1. Persons Contacted

Commonwealth Edison (Ceco)

M. Wall' ace, Project Manager*C. Schroeder, Project Licensing and Compliance Superintendent*D. Shamblin, Project Construction Superintendent,

P. Barnes, Project LicensingW. Vahle, Project Field Engineering ManagerJ. Dierbeck, Project Field Engineer

*E. Fitzpatrick, Assistant Manager of Quality Assurance

| The inspectors also contacted and interviewed other licensee and. contractor employees.

* Denotes those attending the final exit interview at the BraidwoodStation on October 24, 1985.

;

2. Licensee Action on Previous Inspection Findings,

a. (Closed) Open Item (456/84-36-04): Improperly qualified weldingprocedure for L. K. Comstock (electrical contractor) welding ofgalvanized material. To preclude the possibility of anyquestionable work arising from a failure to remove the galvanizecoating before welding, the licensee instructed L. K. Comstock toqualify a procedure for welding with the galvanized coating in place.The NRC inspector reviewed the Procedure Qualification Test RecordsNo. LKCE-PQR-084, 085, 086, and 087. These tests were conducted inthe flat, horizontal, vertical and overhead positions with thegalvanize coating in place. Performance of these qualification testsare considered a technically acceptable method of closing this item.

b. (Closed) Open Item (456/840'21-04; 457/8'4020-04): Questionablecertification of a L. K. Comstock (electrical contractor) welder.

| A review of the qualification tests performed by Welder No.11 wasconducted with results as follows:i

Welder No.11 originally qualified for carbon steel welding onJuly 28, 1978.

| Welder No.11 left the jobsite and returned on April 16, 1981.At this time he was retested and again qualified for carbonsteel welding.

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Welder No. 11 was tested for stainless steel welding on May 18,,

| and May 20, 1981, failing both tests.

Welder No. 11 was given additional training and retested| successfully for stainless steel on May 21, 1981.i

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; Welder No. 11 again left the jobsite and returned on May 23, '

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1983. He was retested on this date and failed to requalify. .

Based on the above review, Welder No.11 was properly qualifiedduring the periods in which he performed safety related welding forL. K. Comstock

(Closed) Violation (456/84021-01; 457/84020-01): Safety-relatedc.! structural steel fillet welds were visually examined for acceptance1 in the painted condition. A 1005 review of the Napolean (structuralj contractor) Visual Weld Reports was conducted by Pittsburg Testing! Laboratory (PTL). Visual Weld Report Nos. 709, 711, 713, 716, andi 717 encompassing 122 welds were identified as being performed through: paint. These inspections were performed by a single inspector during;

a nine day period in~1980. These inspections were performed through!paint at the direction of Ceco Site Quality Assurance and are deemed !

; to be an isolated occurrence. All paint was removed and the weldswere reinspected to correct this deficiency. To prevent recurrence,

. PTL was directed to perform first line weld inspection only in the{ unpainted condition. The NRC inspector reviewed PTL Nonconformancej Report No. 191, Revision 1 documenting the resolution of this item ,

and found it acceptable.:

! d. (Closed) Violation (456/83009-10(c); 457/83009-10(c)): PullmanSheet Metal (PSM) Procedure B10.2.F, " Visual Weld Inspection", did

j not require a documented inspection of base metal surfaces and edgesprior to welding. Section 3 of the AWS D1.1-77 Code, entitled4

| " Workmanship," states in part that surfaces and edges to be welded. shall be smooth, uniform, and free from discontinuities which would| adversely affect weld quality.

i PSM procedures require inspection of shop fabricated items at the: time of shipping and inspection of materials for field fabricatedi items at the time of receipt at the Braidwood site. Jobsite{ fabricated items are saw cut, which virtually eliminates the.i likelihood of irregular edges. In addition, the PSM weldingj procedures require jnspection of the welding surface by the welderi before welding is commenced.

| To further demonstrate weld quality, the licensee performed a weldsample test program. The sample program consisted of tensile testson 82 welded joint samples removed from the HVAC as-weldedconstruction at the Braidwood Station. The results of this test

; program demonstrated that test failure loads were larger than thedesign allowable loads by at least 505.

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i Based on a review of the above information and an inspection of in| excess of 300 HVAC welds performed by the NRC inspector, it was . ,

| concluded that the lack of a documented inspection of base metal-

surfaces and edges prior to welding had no design significant effect,

|on weld quality.

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e. (Closed) Violation (456/84043-01;457/84039-01): During an inspection- related to allegations concerning Byron /Braidwood design activities,'

it was detemined that Sargent and Lundy did not have retrievabledesign basis records for the "p" factor dethodology employed in thedesign of auxiliary steel for pipe supports. This was a violation of10 CFR 50, Appendix B, Criterion XVII. (See NRC Inspection ReportNo. 50-454/84-71 fordetails). In response to this violation thedesign basis for the "p" factor methodology was recreated. All

,

supports designed using the "9" factor methodology were reviewed for',

compliance with the new "p" factor parameters or specific detailedhsign calculations were perfomed to verify the acceptability of thesupports. In addition, the Structural Design Standard for MechanicalComponent Support Steel Framing (SDS-E37) was revised. Also, areview of other technical support documentation was performed toassure that the design bases were retrievable. An inspection wasperfomed concerning these actions and all were found acceptable.

f. (Closed) Violation (456/84043-02;457/84039-02): During an*

inspection related to allegations concerning Byron /Braidwood designactivities, it was detemined that the AISC (American Institute ofSteel Construction) limit for slenderness ratio (KL/R) had not beenincorporated into the Structural Design Standard, Chapter E 36.0," Safety-Related HVAC Duct Supports " for ceiling mounted ductsupports. This was a violation of 10 CFR 50, Appendix 8Criterion III. (See NRC Inspection Report No. 50-454/84-71 for i

details.) In response SDS, E 36.0 was revised to incorporate thelimit on slenderness ratio (KL/R) and existing designs were reviewedfor compliance with the limit on slenderness ratio. An inspection ,

of the revisions to SDE. E 36.0 and the review of existing designswas perfomed and found acceptable.

g. (Closed) Violation (456/83009-02(8); 457/83009)-02(B)): NRCInspection Report No. 50-456/83-09; 50-457/83-09 found that thelicerisee was not in compliance with the Quality Assurance Manual, '

Revision 77 Q.P. No. 7-1 which is a violation of 10 CFR 50,. AppendixB Criterion V. This violation concerned the lack of receipt

* inspection of wall thickne',s and diameter of piping. As a correctivej action, the inspection requirement was incorporated into QCP-84,j Revision 4, which was approved for use on January 23, 1984.!

j Subsequent to the violation, the licensee inspected piping received| prior to July 28, 1983, for wall thickness violations. To providei an addition assurance that piping currently in storage had received

the dimensional inspection, the NRC inspectors perfonned independentdimensional inspections of piping in storage using a Digital!

Thickness Measurement device. The results of this independenti

| inspection are as follows:i

.

1

i

| 4

!- _ _ _ - . _ _ _ _ _ __ _

h S C- 3.

.

No. Min.i Size Heat No. Type Lengths Measurements Acceptance

2" Sch 80 U71443 SA-106 3 .221, .221, .222, .191

.224, .228, .228,

,

.226, .220, .223,,

'

.220, .218, .221,

.232, .228.

11" Sch 80 187312 SA-106 3 .235, .226 222, .175

.224, .209, .206,

.210, .218, .206,

.199, .200, .186,.

* .184, .187

li" Sch 80 204272 SA-106 4 .224, .230, .206 .175

; .206 208, .198,

.200, .206, .207,

.218.

.

.

3/4" Sch 80 169031 SA-106 3 .156, .156, .155, .135

.151, .148, .152,

.167, .160 159

2" Sch 160 74001 SA-106 3 .350, .350, .348, .300

.335, .335, .337,

.349, .348, .348

5

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - , _ , _ _ _ _ _ _ . _ _ _ . _ _ . . __ _ . - _ _ _ _ _ _ _ . _ _

[f .5 C - 3

'

No. Min.

Size Heat No. Type Lengths Measurements Acceptance

1" Sch 80 204891 SA-106 3 .195, .190, .186, .157

.209, .212, .209,

.208, .210, .214

-

2" Sch 80 18497 SA-106 1 .244, .250, .242, .191

.229, .240, .236

11" Sch 80 B16497 SA-312TP304 3 .206, .201, .201, .175

.203, .201, .200,

.209, .202, .200

~

2" Sch 80 462774 SA-312TP304 3 .212, .212, .210, .191

.210, .211, .212,

.210, .212, .213

! 3/4" Sch 80 470382 SA-312TP304 1 .115, .124 .99

11" Sch 80 462800 SA-312TP304 3 .147, .147, .146, .127

.152, .148, .149,

.142, .144, .146

11" Sch 160 463001 SA-312TP304 3 .271, .268, .271, .246

.274, .273, .273,

.270, .268, .264

6

_

$/ f c.- 3

No. Min..

Size Heat No. ,, Type Lengths Measurements Acceptance

2" Sch 80 24257 SA-312TP304 3 .211, .211, .211, .191

.210, .210. 210,

.220, .220, .220

2" S/160 462843 SA-312TP304 3 .324, .325, .324, .300

.332, .331, .331,

.335, .340, .336*

The NRC inspector reviewed QCP-84, Revision 4 and found it acceptable,in addition, all measurtments of wall thickness perfonned by thelicensee and the NRC inspectors were acceptable.

h. (Closed) Open Item (456/85019-03; 457/85020-03): During aninspection of BCAP documentation and engineering analysis theinspector discovered a BCAP observation form which stated that acrack had been discovered in a cable tray support weld. Subsequentto the initial observation, the original BCAP inspector changed theobservation to a " shrinkage line." A decision was made that the NRC-

would inspect this weld in a subsequent inspection. (See NRCInspection Report No. 50-456/85019; 50-457/85020 fordetails).During this inspection the weld was inspected by the NRC inspectors.The weld contained no cracks and was acceptable.

1. (Closed)OpenItem(456/84034-02;457/84032-02): This item. concernsa Pullman Sheet Metal inspection procedure pennitting transversecracks to remain in the weld. Inspection Procedure PSM-WP-307,Addendum A, was prepared by Pullman Sheet Metal (PSM) andsubsequently was accepted by S&L on March 3, 1981. This inspectionprocedure was used by PSM to reinspect a random sample of 200 ducts.These inspections were used to disposition CECO NCR L-246 whichconcerned inspection of silicon bronze welt, with respect to overlapand weld profile. Production inspections were not perfonned usingthis procedure. Current PSM weld inspection procedures do not permitcracks of any orientation.

AWS DI.1 " Structural Welding Code," allows the use of alternateacceptance criteria, provided they are based on engineeringevaluation. The acceptance of PSM-WP-307, Addendum A, was basedon tensile testing of welds containing transverse cracks, asdocumented in a letter from PSM dated February 10, 1981. To

7

,. -, -_ _ _ _ . __ _ _ __

- __ - . = - . . _ . . _ _ _ _ _ _ _ - _ _ ..

[$ S C- 3

supplement the data provided in 1981, S&L reviewed the results of 80: tensile tests performed in 1983. This review has shown that this -

specific type of transverse cracks in silicon bronze welds, used forthe HVAC applications in question, has no significant effect on theability of the welds to perfom their design function. The NRCinspector reviewed the basis for acceptance of this inspectionprocedure and its limited application and found it acceptable.

3. Licensee Action on 50.55(e) Items

(Closed)50.55(e) Item (456/83004-EE;457/83004-EE),

This item concerns the use of Jam nuts in sliding structuralconnections. The inspector reviewed a sample of the design analysesof the sliding connections for the Byron and Braidwood containmentbuildings. In addition, selected exa;nples of sliding connectionsi

utilizing jam nuts were inspected. Both the design analyses and the *

installations inspected were acceptable.,

'

4. Exit Interview

The inspector met with licensee representatives (denoted in Paragraph 1),on October 24, 1985, and sumarized the scope and findings of theinspection. The inspector also discussed the likely informational contentof the inspection report with regard to documents or processes reviewed bythe inspector. The licensee did not identify any such documents orprocesses as proprietary,

;

.

.

e

8.

_ . - _ . _ _ _ _ . . _ _ . - _ - _ _ . _ . . . _ _ _ _ _ . . . _ _ _ ____. _ . . . _ _ _ _ _ _ _ _.

.

OOCommonwo. 6h Edison

./C- One Forst Peat.onal Plaza. Chcago. latences QAddress Fleply to. Post Ottece Box 767Checago, liimois 60690

April 15, 1985.

Mr. James G. KepplerRegional Administrator

,

U.S. Nuclear Regulatory ComissionRegion III799 Roosevelt RoadGlen Ellyn, IL 60137

Subject: Byron Station thits 1 and 2Braidwood Station Units 1 and 2IE Inspection r 50-454/84-71;50-455/84-49; 56/84-4 50-457/84-39

Reference (a): March 15, 1985 letter from J. F. Streeterto Cordell Reed.

Dear Mr. Keppler:

Reference (a) provided the results of inspections by Messrs.Muffett, Ward, Love, Jacobson, and Schapker at Sargent & Lundy Engineers andByron and Braidwood Stations from September 24, 1984 to February 4, 1985.During these inspections, certain activities were found to be not incompliance with NRC requirements. Attachment A to this letter containsCommonwealth Edison Company's response to the Notice of Violation which wasappended to reference (a).

Please direct any questions regarding this matter to this office..

Very y yours,

.

*_ _ _ _| ,-

- - --

D. L. FarrarDirector of Nuclear Licensing

im

.

cc: Byron Resident InspectorBraidwood Resident Inspector

Attachment

EPR16885.

h S C'Y.

.

ATTAC M NT A - -

,

.RESPONSE TO NOTICE OF VIQ.ATION

VIOLATION 1

10 CFR 50, Appendix B, Criterion XVII requires that records tofurnish evidence of activities affecting quality be identifiable andretrievable.

.

The CECO Corporate Quality As'surance Manual and the Ceco QualityAssurance Procedures Manual commit to the above 10 CFR, Appendix B require-ments in Section 17. The CECO Corporate Quality Assurance Mancal states," Quality Assurance records will be stored in a predetermined location asnecessary to meet the requirements of applicable standards, codes andregulatory agencies and shall be accessible to Edison."

Contrary to the above, the Sargent & Lundy Engineers calculationswhich provided the original justification for the g factor desip methodologyand napitude were not retrievable.

CORRECTIVE ACTION TAKEN APO RESLA.TS ACHIEVED

Additional calculations, in addition to the 1982 supplementarycalculations, were performed to justify the g factor methodology. As a resultof the additional calculations, revised g factor parameters were developed.Support desirs where the g factor was used were identified and reviewed. Inthose cases where the support desi p using the g factor methodology was notbounded by the revised g factor parameters, detailed individual calculationswere performed which showed that the support desips were within code

i allowable stresses..

_ CORRECTIVE ACTIONS TO AVOID FURTER NONCOPPLIANCE

Structural Design Standard for Mechanical Component Support SteelFraming (SDS-E37) is the document used by Sargent & Lundy (S&L) to governtheir desip of mechanical component supports. S&L issued a notification ofrevision (NORDS-32) to SDS-E37 on December 26, 1984. NORDS-32 incorporatesrevised bounding parameters for g factor methodology to be used in conjunctionwith the simplified analysis procedure in Section 37.6.3 of SDS-E37. NORDS-32was distributed to each engineer in S&L's Structural Engineering Division.PG DS-32 was discussed in Structural Department and Structural EngineeringDivision meetings which are held for dissemination of information such asthis. In addition, the technical support @==ntation for SDS-E37 will bemicrofilmed to ensure retrievability.

- - - - . . . _ - . . - ._ -- - - . _ - - . - _ . - _ _ _ _ - _ - ._.

_

[f SC */.

.

.

-2- c,

The cther Structural Engineering Design Standards are being reviewedto assure that adequate technical support documentation is available, that the@ =antation meets QA requirements, that it has been microfilmed and willtherefore be retrievable.

DATE WHEN FlLL COWLIAPCE WILL EE ACHIEVED

NCRDS-32 was issued on Decenber 26, 1984. The review of Byron andBraidwood to assure that support designs using the g factor methodology eithermet the revised g factor bounds or have detailed individual calculations inplace was coupleted on February 13, 1985. The technical support @ =antationfor SDS-E37 will be microfilmed by June 30, 1985. The technical supportdocumentation for the other Structural Engineering Design Standards will bereviewed, microfilmed and made fully retrievable by June 30, 1985.

i|

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9973N.

. - - . _ - , . -_. _._-. ___ _ _ __ _ _ _ _ _ _..__ _ __ _ _ _ _ . _ _ _ _ - _ _ _._ _ _ _ _ _ , . . _ _ .-

l

Y- bf. [ C - 1|

-3-.

.

VIOLATION 2

!10 CFR 50, Appendix B, Criterion III requires that design controlI

! measures include provisions to assure that appropriate quality standards arespecified and included in design documents and that deviations from suchstandards are controlled.

CECO Quality Procedure QP No. 3-1 requires that "... design require-ments, including regulatory requirements, codes and standards be utilized inthe development of specifications, drawings, procedures, and instructions."

The AISC Steel Construction Manual (Section 1.8) committed to in theFSAR identifies the slenderness ratio (KL/r) for structural steel menbers as at

| controlled design parameter for conpression menbers.!

Contrary to the above, CECO employed designs for safety-related HVM qyS&L's Structural Standard Document which did not limit tne slenderness ratioduct supports based on Chapter E36.0, " Safety-Related HVAC Duct Supports," of J(KL/r) for ceiling mounted duct supports.

CORRECTIVE ACTION TAKEN AND RESILTS ACHIEVED

A notification of revision (NORDS-28 dated October 31, 1984) wasissued to SDS-E36, the Structural Steel Standard for Safety-Related DuctSupports. NORDS-28 limits the slenderness ratio for ceiling mounted ductsupports. Safety-related duct support desi ps were reviewed and it wasdetermined that the slenderness ratios met the limits stated in NORCS-28.

CORRECTIVE ACTION TAXEN TO AVOID FURTER NOPC0bPLIAPCE.

NORD S28 was distributed to each engineer in S&L's StructuralEngineering Division and was discussed at Structural Department and StructuralEngineering Division Meetings. The other Structural Design Standards thatgovern the design of safety-related supports for other components such ascable trays, conduits, and piping have been reviewed and it was determinedthat these documents contained appropriate limits for slende: ness ratios.

DATE WEN Fli.L CORIAPCE WILL BE ACHIEVED

The corrective action has been completed. NORDS-28 was issued onOctober 31, 1984. The review of Byron and Braidwood safety-related HVAC ductsupport desips to assure that slenderness ratios met t:w limits stated inNDRDS-28 was completed on January 31, 1985. The review of the otherStructural Design Standards for safety-related supports to verify theycontained appropriate slenderness ratio limits was completed by October 31,1984.

9973N

___ _

. f S*$ d@ -Y 5Commonwealth EGeon [f g c - yone First National Plats. Chicago. Ilhnoes

' Address Reply to. Post Othce Box 767>

Chicago, Mhnois 60690

. ,

April 22, 1985

..... . .w.g:f i'

f ~~.'''3 fair.+e n ::ne. 4 ,fy.k.m**" ~ ~ r - ..

- - ' ' - ~.Qy : PO:::5 t-

9 D A W [ . .j,. (_ , . % .,,f ,; i. K:.igfy.;q g.g;g: .;. . :<:g: ..W ,y

-: .-,

-

.,. .. <;. u .v ... .

. .. .

Mr. James G. KepplerRegional AdministratorU.S. Nuclear Regulatory CommissionRegion.III799 Roosevelt RoadGlen Ellyn, IL 60137

.

Subject: Byron Generating Station Units 1 and 2Braidwood Generating Station Units 1 and 2Design ConcernsI&E Inspection Report Nos. 50-454/84-71,50-455/84-49, 50-456/84-43 and 50-457/84-39

References (a): October 22, 1984 letter from L. O. DelGeorge .to J. G. Keppler.

(b): Deceeer 11, 1984 letter from T. R. Tram- to J. G. Keppler.

1

(c): March 15, 1985 letter from J. F. Streeter|

to Cordell Reed.t

Dear Mr. Keppler:

This' letter provides for the record corrected pages for two letterswhich were previously supplied by Comonwealth Edison to the NRC. Thisinformation relates to the tac's investigation of design concerns expressedby an Intervenor's expert witness which was documented in reference (a).These revisions are submitted to fulfill commitments made during the PRCinvestigation. They contain no new information.

On Thursday, January 31, 1985, Mr. T. G. Longlais of Sargent &Lundy, met with Mr. J. Muffett of tac Region III to discuss the supportmee er that was reported to have a slenderness ratio (Kl/r) over 300. Mr.Longlais stated that based upon further review of hanger nurter S-2214 cndrawing M-1326-4, the revised Kl/r value is 291. This revision was due tothe selection of an original K value of 2.0, which ignored the presence of abrace. The brace provides lateral support and a 1.2 value for K is moreapprcpriate. Page 15 of reference (a) has been appropriately revised. Itis enclosed and is labeled " Table 1".

. APR2: 1985. .___ __ _ . _ - .

$1 SC~Y.

.

I'J. G. Keppler -2- ' April 22, 1985*

.

Also enclosed are revised pages 15 and 16 of the attachment toreference (b). Typographical errors have been corrected.

Please direct further questions regarding these matters to this

Very truly yours,.

K '[, hjw- - -

T. R. TrammNuclear Licensing Administrator

1m

.

:Attachnurit

.

9997Ne

:

1

1..

.

I

e

|

|

'

|=1

_ , _ - . ._, _ _ _ _ _ _

.

km -

t

uD5 ' TABLE 1'

BYRON - UNIT 1s!b HVAC MEMBER SLENDERNESS RATIO SURVEY\

.

.

TENSION SYSTEM (CEILING MOUNTED).

Drawing Member K1Serial Floor Number Hanger Type r* - ,

f, F, f,Number Elev. M- Number 1 2 3 4.

*

(ksi) (ksi) FaAl 364-0 * 1311-5 S-322 X 237 1.33 4.27 0.31A2

X 237 1.33 4.27 0.31.

A3 401-0 1313-3 S-1210 X 2$2 1.12 5.33 0.25A4 .

X 212 1.12 5.33 0.21A5 401-0 1313'3 S-1211 X 219 0.20 4.97 0.04A6 .

X 219 , 0.20 4.97 0.04A7 401-0 1313-5 S-1104 X 285 0.47 2.96 0.16A8 .

X 285 0.47 2.96 0.16*

A9 401-0 1313-5 S-1108 X 219 1.75 4.98 0.35,A10

X 219 1.75 4.98 0.35All 401-0 1313-5 S-1110 X 245 0.29 3.98 0.07

.

A12X 245 0.29 3.98 0.07 .

A13 463-5 1326-4 S-2214 X 291 0.36 1.76 0.20A14

X 291 0.36 1.76 0.20.

NOTE: Pa is based on 1.6 x AISC equation 1.5-2 *

All of these hangers are located in the Auxiliary Buidling..

'S.

.

-- - _ _ - _

& [ C - '+.. '* *

., .

r*

. .

*..

.-

e. Load Direction...'

.

. .

,The most critical applied piping load is a load cr a', ting

torsion on a member. The 5 factor does' not account for this,

effec.t and thuh, separate hand calculations must be performed~

t.

to account for this effect. - -

!-

1

An applied vertical piping load on a member produces no tor-

sion and thus, a load from any tolerance creating. torsion -

changes a torsional stress from On to some finite numberi which theoretically is an infinite percentage increase; whereas,

a load from any tolerance causing torsion on a member alreadyi

,

designed for an applied piping load that produces torsioni will have a substantially lower percentage increase than;

one with a vertically applied loading producing no torsion.,

All (factor calculations were performed with the most conser-

:

-vative direction of the applied piping load - the directionvertical to the member. In an actual calculation where thei

actual applied piping load is at an angle' to the member,

the components of this loading are considered in a manuallyperformed detailed analysis.

.

1.

f. Load magnitude--

-

various magnitudes of loadings were selected to assure I RD

15.

-_ - . - . . - - - - - . - - - . . _ _ _ . . . - - - - - - - - . . -

M S c-Y5 * *

.- <.

-o.

.

= 1.0 or as close as possible This has the same effect.

Ras ensuring that various loading magnitudes were considered.

. Tables 15.1 and 15.2 summarizes the calculations,p*erformed,,

andadetaileddiscussionontheresultsobtainedhollows..

,.e .

.

, e#

.

e

e

0

e

e

e

.

9

.

9

9

O

M

0

%

98 e

O

e

e

.

16.

_ _ ,- , ___ ___ _ _ _ . ___ _ __ _ _ _

- 42 -

SEBCONTENTION 6.F,

Rorem QA Subcontention 6.F, as admitted :n this proceeding, states,

'

as follows:

6. Contrary to Criterion V, " Instruction, Pro-cedure and Drawings," of 10 CFR Part 50,Appendix B, Coninonwealth Edison Company hasfailed to ensure that activities affectingquality are prescribed by documented instruc-tions, procedures, or drawings, and areaccomplished in accordance with theseinstructions, procedures, or drawings.

, F. In June 1984, Phillips Getschow, pipingcontractor, found piping that violated minimumwall requirers:nts. This defect was notreported to owner in accordance with10 CFR 21.21. (Inspection Report 84-21/20,Exhibit 20.)

In its Motion for Sunenary Disposition, Applicant acknowledges that

the failure of Phillips Getschow to submit a report to Comonwealth

Edison regarding this deficiency pursuant to 10 C.F.R. Part 21 and

QAP-110 is a violation of Criterion V of 10 C.F.R. Part 50, Appendix B.

Applicant's Motion 6.F at 6. However, Applicant argues that the

deficiency which Phillips Getschow failed to report under QAP-110,was of

a limited nature and that the incident has no significant implications

for the quality of the Braidwood facility, and concludes that the item of*

noncocpliance, the failure to report, was an isolated occurrence.

Applicant's Motion 6.F at 7 and 11. Therefore, according to

Applicant there is no genuine issue of material fact to be heard with

respect to this subcontention. Applicant's Motion, 6.F at 12. The Staff

agrees.

The failure of Phillips Getschow to notify the Applicant of a

potential 10 C.F.R. Part 21 deficiency, the subject of this

- 43 -

.

subcontention, was identified by Region III NRC Inspector Robert D.,

Schulz during a routine unannounced documentation review of the material

traceability program. Affidavit of Robert D. Schulz in Support of NRC *

Staff's Response to Applicant's Motion for Sumary Disposit. ion of Rorem

QA Subcontention 6.F at 1 5. See also Exhibit 6.F-2. Phillips Getschow

Co. Procedure QAP-110 " Reporting of Defects and Noncompliance," requires

that such incidents (a minimum wall violation in this case) be reported

on Form PG/QA-15-7. Schulz Affidavit 6.F at 11 5 and 6. Failure to

report this item of noncompliance precluded notification of the pipe

supplier or manufacturer so that delivery of defective pipe to other

nuclear sites could be prevented. M.

Subsequent to the issuance of the NRC inspection report

(Exhibit 6.F-2) the Applicant took corrective action which included

notifying the pipe supplier of the deficiency and reinstructing Phillips

Getschow piping personnel regarding their reporting responsibilities to_

,

the Applicant. Schulz Affidavit 6.F at 17. Mr. Schulz verified that

under the current procedure, Phillips Getschow performs a documented

review of all NCRs for rep 6rtability under 10 C.F.R. Part 21. M.

Mr. Schulz determined that the Applicant's co.rrective actions involving

supplier notification and reinstruction were appropriate. Based on this

determination he closed the item in NRC Inspection Report

Nos. 50-450/85007 and 50-457/85007. See Ex. 6.F-3. The Staff agrees

with the Applicant that the incident described in Subcontention 6.F was

an isolated incident of failure of one contractor to report a single

deficiency pursuant to procedures and does not represent a pervasive

breakdown in the Applicant's QA program. None of the information

,

,- --un ,- , - - , , - --. - - - . - - - - - ,- - . - , - - - - , . - - --- -,

- 44 -

available to the Staff indicates any subsequent failure to comply with,

10 C.F.R. Part 21 reporting requirements. Intervenor has not provided

any information during discovery which supports a contrary view.

Therefore, there are no genuine issues of material fact to be heard

regarding this subcontention and Applicant is entitled to a favorable

decision on this subcontention as a matter of law. Based on the dis-

cussion above, the Staff concludes that Applicant's Motion for Summary

Disposition of Subcontention 6.F should be granted.

.

4

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