ML20070L990
| ML20070L990 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/04/1983 |
| From: | Maurin L LOUISIANA POWER & LIGHT CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 820104, EA-82-109, W3I83-0001, W3I83-1, NUDOCS 8301120175 | |
| Download: ML20070L990 (7) | |
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s LOUISIANA f 242 OctAnONOe sincer POWE R & L1G H T/ P O BOX 6008. NEW ORLEANS. LOUIStANA 70174. (504) 366 2345
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L. V. MAURIN January 4, 1983 Voce Presnient Nuclear Operations W3I83-0001 Q-3-A35.02.01 Mr. Richard C. DeYoung Director of Inspection & Enforcement US Nuclear Regulatory Commission Washington, D. C.
20555
SUBJECT:
Waterford 3 SES Response to EA 82-109
REFERENCE:
Docket No.:
50-382 Construction Permit: CPPR-103 EA 82-109 December 6, 1982
Dear Mr. DeYoung:
USNRC letter 50-382/EA 82-109 dated December 6, 1982 from Mr. J. T. Collins to Mr. L. V. Maurin contained as an appendix a Notice of Violation and Proposed Imposition of Civil Penalty. This action was based on inspections conducted during the period May 16 to July 15, 1982 under the Resident Inspection Program by Messrs. G. L. Constable and J. E. Cummins, in which a partial breakdown was identified in the quality assurance program for Waterford SES Unit 3.
In accordance with your letter and pursuant to the provisions of 10CFR2.201, following is the Louisiana Power & Light Co. reply to the Notice of Violation.
Yours very truly, L. V. Maurin cc:
Mr. John T. Collins Regional Administrator USNRC Region IV Mr. E. L. Blake Mr. W. M. Stevenson 8301120175 830104 I[" I
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Mr. Richard.C. DeYoung W3183-0001 Page 2-
'bec:
R. Barkhurst, R. K. Stampley (2), F. J. Drummond, T. F._Gerrets, C. J. Decareaux, T. K. Armington, L. L. Bass, R. W. Prados, Central Records, L. V. Maurin, G. B. Rogers, Nuclear Records, Licensing Library, R. A. Savoie, W. A. Cross, G. D. McLendon, S. A._Alleman, W. M. Morgan, G. L. Constable (NRC),'W. F. Axtman, J. Gutierrez, L. A. Stinson, M. Clary, Z. Sabri, R. Burski, K. Iyengar, !!. Meyer, Ebasco
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Mr. Richard C. DeYoung.
' W3183-0001
-REPLY TO NOTICE OF VIdLATION Admission or denial of the alleged' violation; LP&L acknowledges'that there was~a partial Quality Program 9
breakdown at Waterford 3 at the sub-tier levels and. involving.
contractor / subcontractor organizations identified in USNRC Inspection Report' 50-382/82-14.
2.
.The reasons for the violation; 7
' Deficiencies noted in Inspection Report 50-382/82-14, were due to i
insufficient' overview and support activities, (i.e., training) necessary to assure compliance to specified quality requirements.
Specifically, areas which contributed'to the noted violation are as follows:
a.
Training - training of craftsman, QC. Inspectors and reviewers was apparently insufficient to provide adequate guidance / direction to assure quality results
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within the-principal contractor organization and two subcontractor organizations.
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b.
Staffing staffing of personnel was inadequate, and as a result, personnel were extended beyond their capability to adequately address quality inspections and reviews within the principal contractor organization and two subcontractor organizations.
Walkdowns of completed systems were inadequate as a c.
result of Items a and b.
3.
The corrective steps which have been taken and the results 1
achieved; Tompkins - Beckwith 2
Following an intensive training / retraining program Tompkins -
Beckwith (T-B) initiated a reinspection of approximately 5000 i
hangers which were completed and accepted prior to July 6, 1982.
NCR W3-4010 was issued to track and document the disposition
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and corrective action taken for hangers found to have deviations from design requirements. As of this date, hanger reinspection / rework is approximately 85% complete.
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-V 2 REPLY TO NOTICE OF VIOLATION Mr. Richard C. DeYoung W3I83-0001 Page 2 l
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i Mercury Company i
Mercury Company identified reinspection teams and proceeded with l
reinspection / rework activities (af ter retraining)' for acceptable construction completion. As of this date 42 systems have been satisfactorily reinspected and approximately 75% of the required rework is completed, t
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The corrective steps which will be taken to avoid further i
violations; (a) Tompkins-Beckwith - T-B has retrained the personnel involved in piping hanger field inspection and documentation review.
T-B has increased its documentation review, quality control, engineering and supervisory staffs which has resulted in an t
improved level of quality. Training / retraining efforts will
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continue in order to maintain the proficiency of these personnel.
T-B Quality Assurance has performed hanger installation surveillances and this will continue through the system release and turnover process. Additionally, T-B is performing monthly hanger inspection program audits of a i
sample lot of hangers to verify that reinspections and i
inspections are properly performad.
(b) Mercury Company - An extensive training / retraining program h
was implemented by Mercury for their records review, QC inspector, craft, and engineering personnel. This program L
will continue in order to maintain the proficiency of these i
personnel. Joint system walkdowns with Mercury and Ebasco have been initiated for the purpose of problem identification and resolution prior to system release and turnover.
Additionally, Mercury has increased their documentation l
review and quality control inspection staffs.
I (c) Ebasco - With LP&L's concurrence, Ebasco formed a QA i
Surveillance Group to increase Quality Assurance involvement in in-process construction activities including hardware
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installation, walkdown inspections, system testing and system turnover. A major objective of this group is to perform random physical inspections to assure contractor compliance l
to established requirements. This group is performing hanger and instrumentation installation surveillances.
i Ebasco has increased its documentation review, quality control and supervisory staffs and has retrained the personnel involved in the review of documentation.
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4 REPLY TO NOTICE OF VIOLATION
.Mr. Richard C. DeYoung.
W3I83-0001 Page 3 (d) LP&L - The'LP&L QA organization has been enlarged and supplemented with contract personnel in order to provide broader QA coverage of safety related site activities.
' Quality Assurance has developed procedures and will conduct audits to verify system configuration.and documentation prior to turnover to LP&L Startup. Plant. staff, in conjunction with startup engineers, will perform system walkdowns and will verify the status of the current as-built configuration of the system prior to transfer to the plant staff. These measures will provide assurance of the quality and readiness of systems to support safe plant operations.
Responsibility for Significant Construction Deficiency, Inspection Reports,-and other required reporting has been transferred from QA to Licensing. This permits more time for-direct involvement by LP&L QA in construction activities.
5.
The date when full compliance will be achieved:
The Tompkins-Beckwith retraining program is complete and at this time the hanger reinspection / rework program is approximately 85%
complete.
It is anticipated that the hanger reinspection /
corrective action program will be complete by February 15, 1983.
Mercury's training / retraining program is complete and the system walkdown/ corrective action program is presently scheduled for completion by April 4, 1983.
Additional Information In addition to the above, the NRC requested'that LP&L provide information relative to actions taken or planned which would ensure that work completed prior to the identification of this breakdown was properly accomplished.
The information that follows was discussed with Mr. J. T. Collins and members of his staff during a meeting at the Region IV office in Arlington, Texas on December 27, 1982.
LP&L has developed an aggressive plan to establish methods for quality record reviews and applicable physical verification for selected activities performed by 15 contractors who performed safety related activities prior to June 1, 1982. The plan will be implemented by LP&L QA and engineering personnel.
Walkdowns will be performed, using checklists to verify that the installed condition is in accordance with related documentation. Where system walkdowns are impractical, analytical means will be employed to confirm the adequacy of the installation. Where applicable, dimensional checks of
REPLY TO NOTICE OF VIOLATION' Mr. Richard C. DeYoung W3I83-0001 Page 4 Addition Information (Continued) mechanical components, inline equipment, cable tray and pipe supports, component locations, welds, and terminations (separation) will be verified to assure agreement with engineered /as-built. drawings. Checklists will be sufficiently detailed to ensure necessary discipline items will be verified.
Record reviews will be performed on the supporting documentation for the physical activities verified during walkdowns. Checklists will be used to document these record reviews. Verification of the as-built drawings co the physical configuration as installed will be the prime concern of these-reviews.
The schedule for completion of the above activities is as follows:
January 7, 1983 Complete walkdown and records review procedures and checklists January 10, 1983 Commence record reviews & walkdowns March 15, 1983 Complete record reviews and walkdowns; compile results Results of the walkdowns and record reviews will be documented,' compiled and potential findings will be processed in accordance with the LP&L Quality Assurance Program.
A report summarizing the results of this effort will be submitted to the USNRC on or before March 31, 1983.
Finally, LP&L and its contractors have reviewed for adequacy those procedures related to the turnover process and have revised them as necessary to assure that review requirements are clearly stated.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Louisiana Power & Light Company
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Docket No. 50-382 Waterford 3 Steam Electric Station
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AFFIDAVIT L. V. Maurin being duly sworn, hereby deposes and says that he is Vice President Nuclear Operations of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response W3I83-0001 to the Notice of Violation appended to USNRC Enforcement Action EA 82-109; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
fmnE L. V. Ma' urin
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Vice President Nuclear Operations STATE OF LOUISIANA)
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ss PARISH OF ORLEANS )
Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 9-day of 7AdvAre,
, 1983.
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