ML20070F240
| ML20070F240 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/08/1982 |
| From: | Maurin L LOUISIANA POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20070F219 | List: |
| References | |
| W3I82-0096, W3I82-96, NUDOCS 8212200127 | |
| Download: ML20070F240 (9) | |
Text
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e LOUISIANA 242 o u AnoNoe s1n m POWER & LIGHT P O BOX 6008
- NEW ORLEANS. LOUISlANA 70174 * (504) 366 2345
'EN 50s$
November 8, 1982 U
l V MAUmN Voce Presdent Nuclear Operabons W3182-0096 Mr. G. L. Madsen Nhs h Q[- -" J 'Q; j SALP Board Chairman i
l Reactor Projects Branch 1
Region IV p
i U. S. Nuclear Regulatory Commission
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W Dl 611 Ryan Plaza Drive, Suite 1000 J!
Arlington, Texas 76012 u
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Dear Sir:
on October 14, 1982 the Systematic Assessment of Licensee Performance (SALP)
Board Report was transmitted to Louisiana Power & Light Company. The report evaluated the performance of Waterford 3 for the period of July 1, 1981 through June 30, 1982.
It was stated in the report cover memo that comments would be accepted. This letter and its attachments provide LP&L comments on the SALP Report for your review and consideration.
As stated in the introduction to the SALP Report, "The integrated assessment is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management". LP&L supports this process and feels that it provides a means to more effectively utilize resources by focusing on areas important to safety.
Furthermore, LP&L feels that objective performance evaluations can promote positive attitudes towards improving performance which will ultimately result in an improvement to plant safety.
In general, LP&L agrees with the findings, conclusions, and recommendations contained in the SALP Report for Waterford 3.
In a number of instances we recognized and began corrective measures prior to the areas being identified in the report.
For example, Piping Systems and Piping Supports and Instrument-ation and Control Systems were areas in which LP&L identified the need for improvement prior to the SALP report.
Further, LP&L had already taken corrective measures to upgrade and/or implement programs and controls to ensure that work and documentation was completed in the prescribed manner. Additionally, Transportation of Radioactive Materials and Radioactive Waste Management were already receiving significant management attention, prior and subsequent to the SALP report. This attention has been directed at establishing depart-mental responsibilities for Rad Waste management within the Nuclear Operations organization.
Programs and controls for Radioactive Materials and Waste Management activities have been formulated and approved by LP&L Management and implementing procedures are being prepared.
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Mr. G. L. Madsen W3182-0096 Page 2 Since the end of the SALP evaluation period on June 30, 1982, additional progress has been made in readying Waterford 3 for operation.
Emphasis has been placed on areas such as: personnel training, system transfer and testing, staff recruitment, procedure preparation, and development of an " operational" attitude by increased plant staff involvement in preoperational testing.
LP&L is committed to achieving and maintaining a superior nuclear power operation. This letter and the attached comments are intended to demonstrate our sincere interest in improving our performance at Waterford 3.
Very truly yours, 7
L. V. Maurin LVM/WAC:keh Attachment
COMMENTS ON SALP REPORT BY FUNCTIONAL AREA 1.
Functional Area Analysis (Construction) a.
Soils and Foundations No LP&L comment since there was no NRC assessment of this area.
b.
Containment and Other Safety-Related Structures LP&L agrees with this assessment.
c.
Piping Systems and Supports Potentially Reportable Deficiency (PRD) 84 was reclassified as Significant Construction Deficiency (SCD) 60 and a final report is scheduled to be submitted to the NRC.
The piping installation contractor, To=pkins-Beckwith (T-B) has completed a retraining program for their hanger engineering personnel and their quality control inspectors to requalify them to properly perform the field inspections of pipe supports / restraints and to complete the necessary documentation.
In addition, a reinspection was initiated of approxi=ately 5000 hangers which were installed and accepted prior to July 6, 1982. At this time approximately 72%
of the hangers have been reinspected and rework is being performed as required.
Ebasco Services has retrained the personnel involved in the review of piping hanger documentation. Both Ebasco and T-B have increased their documentation review staffs and supervision which have resulted in an improved review process.
In addition LP&L and Ebasco Quality Assurance Groups have increased hanger installation surveillances.
We believe that these changes reflect our commitment and have resulted in and will continue to improve the overall~ effectiveness of manage-ment in implementing the necessary programs and controls in this area.
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. d.
Safety-Related Components Including Vessels, Internals and Pumps Housekeeping walkdowns and equipment inspections are conducted frequently to identify and correct the problems identified.
In addition, a preventive maintenance program has been implemented which includes cleaning and testing plant equipment.
NISCO, the NSSS mechanical contractor, reindoctrinated their personnel responsible for access control. Additionally, sub-contractors were redirected by Ebasco to conform to procedural requirements for cleanliness and access control.
a.
Fire Protection
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LP&L will continue to give a high level of control and attention to this area.
f.
Electrical Power Supply and Distribution As stated in the SALP report, corrective actions have been taken and proper controls are being maintained.
g.
Instrumentation t.nd Controls Systems Potentially Reportable Deficiency (PRD) 80 pertains to an instrumentation and controls installation problem which was identified by LP&L on May 25, 1982. This was reclassified as Significant Coastruction Deficiency (SCD) 57 and a final report is scheduled to be submitted to the NRC. Corrective action has been taken to correct identified problems and to prevent their recurrence. An extensive training / retraining effort was implemented by the contractor, Mercury Company, for their records review personnel, QC inspectors, and craft personnel. Joint system walkdowns with Mercury and Ebasco engineering and QA personnel have been implemented since June 1982 for purposes of problem identification and resolution prior to system turnover. Additionally, LP&L and Ebasco QA l
Groups have increased installation surveillances.
l Ebasco's QA documentation review has been improved by an increase in supervision, staff, and training / retraining of the reviewers.
When the specific design was contrary to manufacturer's generic recommendations, it was only after a design verification of the adequacy of the specific installation. Some such designs included the need to fill and vent lines and the Maintenance Department is preparing a generic procedure for filling and venting of such instrument lines.
In addition. I&C Maintenance procedures individually direct special precautions when calibrating affected instruments.
I&C technicians are reviewing the installatior.s for problems during the installation checks and instrument calibrations.
9.
h.
Licensing Activities In the area of Licensing Activities, LP&L's communication with the NRC Licensing Project Manager has been aimed at responding to licensing and technical issues in a thorough and timely manner.
Additionally, cataloging and tracking of LP&L commitments to regulatory issues through a Licensing commitment tracking program will provide a means to ensure' continued management review and timely response to Licensing matters.
2.
Functional Area Analysis (Preoperational) a.
Plant Operations Preparation LP&L recruiting efforts since July 1, 1982, have resulted in the hiring of 42 Plant Staff personnel, 8 QA employees, 4 persons in Training, and 20 in the Nuclear Project Support Group.
Intensive recruiting efforts including an aggressive advertising campaign and recruiting trips continue.
On April 20, 1981, a coc=itment was made to the NRC to have on board 45 mutually agreed upon key personnel. At one time all of these positions were filled but there is now one vacancy following the August, 1982 resignation of the Assistant Plant Manager -
Operations & Maintenance.
The Plant Staff is being augmented by four contract shift supervisors to allow the permanent shift supervisors to attend cold license training classes. Permanent plant shift supervisors were on shift for six weeks to support the Cold Hydrostatic testing of the Reactor Coolant System.
There are presently 24 permanent plant " Hot" license candidates on shift supporting the plant startup and directly involved with preoperational testing.
In addition, all permanent plant operators were placed on shift for the six week period during which the RCS " Cold Hydro" and Steam Generator Hydros were performed. All permanent plant operators will be placed on shif t during the Hot Functional Test Program.
While permanent operators are not actually writing all of the Operating Procedures, LP&L supervisors are providing oversight and guidance to the procedure writing group. LP&L operators and super-visors are performing the majority of the technical and departmental reviews of the Operating Procedures. Additionally, Operators are being assigned and scheduled to perform in-plant "Walkthroughs" of their procedures both to familiarize them with the procedures and plant systems and to ensure that the procedures are adequate.
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b.
Security and Safeguards The security and safeguards program has been emphasized b, LP&L corporate and plant staff management and is considered to be effective.
i c.
Preoperational Testing i
1 System transfer and turnover has received an increased level of involvement by Startup, Quality Assurance, and Plant Staff groups to expedite the process while assuring the proper attention to quality. Plant Staff Engineering Operations, and Maintenance personnel are becoming increasingly more involved with the progression and conduct of preoperational test programs. A plan has been devised whereby opportunities presented by the hot functional test period will be fully utilized in gaining experience for LP&L staff members.
1 d.
Surveillance The operational Corrective and Preventive Maintenance programs are being implemented by plant staff as systems are transferred for operation. These programs are designed to correct the weaknesses identified by the NRC.
The Corrective Maintenance Program requires a Condition Identification and Work Authorization (CIWA) to identify discrepancies. Personnel are being trained on the use and processing of the operational CIWA. Also, Maintenance Department personnel have been processing and using CIWA's designed for use in the Startup program. There is a continuing effort to make all maintenance procedures clear to the workman.
The Preventive Maintenance Committee continues to identify and document maintenance requirements to ensure that pertinent requirements are included in the Preventive Maintenance Program.
NRC Region IV inspectors performed an audit since the SALP evaluation and have noted significant improvement in the Preventive Maintenance Program.
e.
Audits, Reviews, and Committee Activities The Operations Quality Assurance Group (Onsite) was established in l
November of 1981 with the appointment of the OPS QA Group Super-visor. The OPS QA Group's authorized staffing level at that time was established as six (6) QA engineers. As recruitment efforts obtained personnel for this Group, an audit proEram was developed and Laplemented. Through the process of audits and reviews, the role and scope of the OPS QA Group became better defined.
In July of 1982 LP&L management authorized an increase in the staffing level of the OPS QA Group to 13 QA engineers. The current number of QA engineers assigned to the OPS QA Group is eight (8) with intensive recruitment continuing.
. In October 1982, a detailed analysis of the audits and reviews required to support system transfer and fuel load was conducted.
This analysis indicated that additional manpower was needed in order to provide an adequate assessment of LP&L's Quality Assurance Program requirements. This analysis resulted in the authorization to engage up to 21 contract employees to assist in the audits and reviews required prior to fuel loading. Efforts are currently underway to bring these personnel on site as soon as possible. The first of these contract personnel reported to work on November 1, 1982.
f.
Initial Fuel Load Preparations The current date for receiving fuel onsite is now late January of 1983. This schedule change was made to allow for completion of necessary startup and construction activities in the Fuel Handling Building. Work is progressing on all systems in the building. The four radiation monitors in the FHB have now been activated to read out on the radiation monitoring computer; rework of the fuel pool gate seals has begun, although the seals are not required for fuel receipt; and pre-requisite testing of the FRE ventilation and emergency ventilation systems is nearing completion.
Discussions have been held on a continuing basis with the senior NRC resident inspector about ccncerns over the 15% sample, rather than the 100% sa=ple, that was taken to verify the presence of boron in the high density fuel racks in the spent fuel storage pool. LP&L has also agreed to perform an analysis of two adjacent new fuel assemblies in clean, cold, unborated water to demonstrate the inability of such a system to achieve criticality.
g.
Chemistry / Radiochemistry The Chemistry Department has now installed its major equipment in the permanent laboratory spaces. Routine laboratory work is now being performed in the new laboratories. Equipment checkout, calibration and training are now underway for the new equipment. Most of the analytical procedures have been tested and a program of revisions is now underway. The new primary sample panel has been installed and the Post Accident Sampling System (PASS) panel has been received on site.
h.
Radiation Protection The observation in the SALP report results from an NRC audit conducted during the week of March 1, 1982. Considerable progress has been made since that time. Overall staffing has increased from 52%
to 85% of the authorized level. All critical positions have been filled with LP&L personnel although some consultants are being retained for specialized areas of a developmental nature. Procedure completion has increased from 67% to 96% with the remaining procedures scheduled for completion in the near future. All essential equipment is onsite
.' I U or has been procured, with calibrations scheduled in the coming months. The Radiation Worker portion of the General Employee Training program has been provided to approximately 1300 personnel to date. The Health Physics Technical training program was initiated in July 1982 for a portion of the staff; another cycle is scheduled to begin in January, 1983 for the remainder of the staff.
1.
Effluent Controls This item results from an NRC audit conducted in April 1982. While progress has been made in this area, there still remains a significant amount of work to be. ready for operation. Work tasks were defined shortly after the NRC audit and responsibilities were assigned to correct deficiencies. Completion of these work tasks is scheduled such that adequate effluent controls will be in place prior to fuel load.
The Health Physics Group initiated procurement of the computer software for performing effluent release calculations. Release permit procedures, based upon this software, are scheduled for completion by January 1983.
- j. Transportation of Radioactive Materials A program description has been formulated and approved designating the Radwaste Department as the responsible group for transportation activities associated with radwaste shipments. This program also delineates specific responsibilities for groups which support the transportation program. Operating procedures concerning packaging and shipping of radioactive waste have been developed and are in the final stages of approval.
k.
Radioactive Waste Management A program description has been formulated and approved delineating specific areas of responsibilities for the radwaste management program. This program covers the areas of responsibility for corporate groups as well as on-site groups and also addresses organizational interface relationships between the various groups and departments.
This program also identifies the Radwaste Department as being responsible for the following areas:
a.
Solid radwaste compaction b.
Decontamination c.
Radwaste packaging d.
Radwaste shipments e.
Solidification f.
Laundry handling g.
Radioactive material handling
In addition to these functions, the Radwaste Department is responsible for generating operating procedures for these areas.
These procedures are currently being formulated and are approximately 797, complete. The Radwaste Department also has responsibility for identifying and correcting design related problems concerning radwaste systems using approved procedures. A special task force reporting to the Site Director has been formulated to address design problems and to pursue startup and testing of radwaste systems.
Prior to the Region IV audit of the Radwaste area in April, 1982, LP&L had identified:
1) the need to establish a separate Radwaste Department within the Plant Staff and 2) the need for increased attention to design and installation of the Waterford 3 waste systems. At the time of the audit, the Radwaste Department was in its infancy and responsibilities were being assigned. The audit provided increased emphasis in these areas.
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