ML20079M480

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Forwards Comments on SALP Rept 50-382/83-28 for Jul 1982 - June 1983.Independent Evaluation of Concrete Base Mat Conducted
ML20079M480
Person / Time
Site: Waterford Entergy icon.png
Issue date: 11/18/1983
From: Leddick R
LOUISIANA POWER & LIGHT CO.
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20079M321 List:
References
W3K83-1793, NUDOCS 8401270331
Download: ML20079M480 (27)
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  • - - Enclosure 3 fOUISIANA s.,ceu m0~oeerneer . nosox800e P O W E R & L 1 G H Tj NEW ORLEANS LOU 6'ANA 7017d-6000 9 (504]386-2345 UTititlES SYSTEM November 18, 1983 ROTH S. LEDDICK Senior wce President Nuclear Operat.'ons W3K83-1793 Q- 3-A35. 02. 01 7 -- t
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Mr. Eric Johnson Reactor Projects Branch I Region IV I

0. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

Dear Mr. Johnson:

SUBJECT:

Waterford 3 SES Comments To USNRC SALP Report 83-28 The subject report provided the USNRC 1982-1983 Systematic Assessment of Licensee Performance of the Waterford Steam Electric Station, Unit 3 facility.

The report provided recommended Louisiana Power & Light (LP&L) actions and the criterion on which the recommended actions were made. Louisiana Power & Light offers the attached comments concerning the evaluation of our performance.

R. S. Leddick Senior Vice President-Nuclear Operations RSL:WJB:JC Attachment cc: R. P. Barkhurst, R. F. Burski, K. S. Cook, F. J. Drummond, T. F. Gerrets, S. A. Alleman, L. L. Bass, L. F. Storz, W. M. Morgan, Central Record, Nuclear Records 8401270331 840104 DR ADOCK 05000382 PDR

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,. . ' ATTACHMENT

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SECTION IV A - SOIL AND FOUNDATION RECOMMENDED LP&L ACTIONS: Continue management attention until a resolution is reached on this issue.

LP&L RESPONSE: LP&L Commissioned an independent engineering firm, Harstead Engineering Associates, to perform an evaluation of the cracks in the concrete base mat. Results of evaluations are a follows:

HEA Report No. 8304-1 Scope: a. Engineering criteria employed in preparation of site.

b. Cracking and leakage in base mat,
c. Laboratory Tests performed on water and leachate samples.
d. Stability calculations performed for the Steel Containment Vessel.

Summary: "In conclusion, there is no evidence of any process which has been or could be detrimental to the structural integrity of the foundation mat."

HEA Report No. 8304-2 Scope: a. The geometric criteria employed by Ebasco to formulate the finite model used to evaluate the structural adequacy of base mat,

b. The magnitudes and distribution of the loads employed by Ebasco to evaluate the structural adequacy.
c. A benchmark comparison between the initial HEA test run against the comparable Ebasco base mat computer analysis.
d. A detailed comparison between a final HEA computer analysis and the corresponding base mat shear and moment capacity.

Summary: "It is cur conclusion that the design of the mat is extremely conservative, which, under the circumstances in which the design was carried out, we consider prudent and justifiable. Therefore, we see no need for any remedial measures or the necessity of additional analysis.

(1)

  • - ATTACHMENT SECTION IV B - SAFETY-RELATED STRUCTURES, AMERICAN BRIDGE STRUCTURAL STEEL RECOMMENDED LP&L ACTIONS: Assure all contractors and subcontractors provide high quality systems and fully documented work records.

The licensee should strengthen the LP&L Construction QA effort.

LP&L RESPONSE: 1. As a result of the established review process for records turnover, several documentation deficiencies were identified by Ebasco QAIRG (Quality Assurance Installation Review Group).

2.- During the LP&L task force audit, additional documentation problems were noted:

a. These led to a random reinspection of physical .

hardware by Ebasco QA surveillance, and the initiaticn of SCD's 73 and 78.

3. Ebasco committed to and completed a major reinspection of accessible hardware for welding and bolting performed by American Bridge to establish corrective action for SCD's 73 and 78.
a. Required rework is being performed by Ebasco Construction, and is 99% complete and scheduled to be completed by November 18, 1983,
b. Records generated from this task are being processed and reviewed as Ebasco construction records.
4. Ebasco QAIRG's review of American Bridge records has been completed,
a. Ebasco QAIRG's review of Ebasco Construction records generated from this task are approximately 65%

reviewed, with an estimated completion date of December 14, 1983.

(See response to Quality Assurance Construction,Section IV I).

(2)

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  • ATTACHMENT SECTION IV C - PIPING SYSTEMS AND SUPPORTS (INCLUDING HVAC)

RECOMMENDED LP&L ACTIONS: Assure that all Contractors and subcontractors provide high quality systems and fully documented work records.

The licensee should strengthen the LP&L Construction QA effort.

LP&L RESPONSE: To assure adequacy of records to support the work activities, the fcilowing actions have been taken:

1. The Ebasco Quality Assurance Installations Records Group has been augmented and provided additional training to assure the adequacy of the records review for turnover and transfer.
2. The LP&L Construction QA Group has been increased in manpower to provide additional reviewers. (See response to Quality Assuranca Construction,Section IV I)

SECTION IV F - INSTRUMENTATION AND CONTROL SYSTEMS RECOMMENDED LP&L ACTIONS: Continue management attention in this area until all corrective actions are completed and final documentation is transferred to LP&L.

LP&L RESPONSE: The following are the continuing actions being taken by LP&L:

1. Prior to turnover of a Startup System for Testing, LP&L QA performs a physical walkdown to assure installation is adequate to support test activity.
2. A records review is performed by Ebasco QAIRG and LP&L Construction QA to assure adequacy of documentation supporting installation.
3. Demobilization of the Mercury contract and asstaption of remaining construction activities by Ebasco Construction (EC) has been accomplished. These activities of EC are being monitored by Ebasco QA and the LP&L Construction QA organizations, on an increasing basis. (See response to Quality Assurance - Construction,Section IV I).

SECTION IV G - DESIGN CONTROL RECOMMENDED LP&L ACTIONS: The licensee should increase surveillance of design and documentation control activities and careful scrutiny of as-built systems prior to system transfer to the plant manager.

(3)

r ATTACHMENT SECTION IV G - DESIGN CONTROL, (Continued)

LP&L RESPONSE: LP&L believes that corrective action taken as a result of deficiencies identified during the turnover and transfer activities provide reasonable assurance that those drawings required to operate the plant reflect as-built conditions. We will continue to review and evaluate L'ne review activities, and initiate additional surveillances as deemed necessary.

SECTION IV I - QUALITY ASSURANCE CONSTRUCTION RECOMMENDED LP&L ACTIONS: Ensure adequate LP&L oversight of all safety-related construction activities and that all contractors and subcontractors provide a high standard of quality. The Licensee should strengthen the Construction QA effort.

LP&L RESPONSE: Measures taken to provide greater reliability in the quality of construction activities are as follows:

1. Personnel changes within the Ebasco organization have been instituted. Positions which could effect quality have been strengthened by these personnel changes, creating a stronger quality program.

LP&L continues to emphasize the necessity that Ebasco Quality Assurance Organization provide the overview and direct control over contractors to assure construction activities are accomplished to requirements.

2. The Ebasco QA Surveillance Group was implemented to provide additional surveillance activities beyond the scope of the subcontractors QA program. This group has been instrumental for providing increased coverage allowing potential problem areas to be identified and corrected in a more timely manner.
3. The LP&L Construction QA Group has been augmented by personnel from:
a. MSS - used in hanger review and in-plant inspections.
b. Contract Personnel - Used in documentation reviews and in-plant inspections.
c. Operations QA Personnel - Used in performing audits and other support activities.

The current staffing of Construction QA consists of thirteen people, plus Operations QA personnel as needed.

(4)

l ATTACHMENT SECTION IV I - QUALITY ASSURANCE CONSTRUCTION, (Continued) s l 4. As Ebasco Construction (EC) assumes the remaining construction activities of'the subcontractors, LP&L Construction QA has increased surveillance and audit activities of Ebasco Construction.

A recent audit was performed by LP&L Construction QA, assisted by Operations QA, to ascertain Ebasco Construction's compliance to requirements. This audit is being processed as per the LP&L QA program. Efforts of the LP&L Construction QA organization toward the Ebasco Construction activities will be enlarged commensurate with the scope of EC activities to assure LP&L management of a continued quality program.

i SECTION IV K - PREOPERATIONAL TESTING i

RECOMMENDED LP&L ACTIONS: Increased management attention will be needed to verify that instrumentation and control systems will operate as designed and the present quality of the startup program is maintained by the new startup organization.

. LP&L RESPONSE: LP&L intends to review the installation of the flow instruments i

to ensure that these instruments will operate as designed and will provide satisfactory response and indication for the

operator.

SECTION IV L - PLANT OPERATIONS PREPARATION RECOMMENDED LP&L ACTIONS: Continue present level of emphasis on developing good overall plant procedures.

LP&L RESPONSE: Emergency Operating Procedures (EOP's) Currently the approved

" event based" procedures are being revised to " function based" procedures. This effort includes development of a writer's guide and training document and is expected to be completed by i

March 1, 1984. This effort is being conducted by Operations personnel and a Human Factors Consultant.

Technical Specifications surveillance procedures are scheduled for completion and issuance in Rev. O by January 1, 1984 and all required revisions in place by fuel load. This effort is

, being conducted by Operations personnel.

System operating procedures, off-normal procedures, general j plant operating procedures and refueling procedures are f undergoing review and revision by Operations personnel and will j be approved and in place by January 1, 1984. Annunciator i response procedure format was revised and these procedures I will be approved and in place by February 1, 1984.

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- ATTACHMEhT SECTION IV M - RADIOLOGICAL CONTROLS RADIATION PROTECTION RECOMMENDED LP&L ACTIONS: Management attention should continue to ensure that necessary action is taken to close the existing open items before an operating license is issued.

LP&L RESPONSE: It should be noted that an NRC inspection (83-23) conducted during the week of July 11-15, 1983 resulted in the closing cf 10 of the then remaining 12 open items in radiation protection.

All of these 10 items had been completed to the extent that they could have been conducted prior to the June 30 end of the SALP period. The first of the remaining open items (8204-04) involves the completion and implementation of 2 lesson plans for Health Physics Technician training. Plant Technical Training has indicated that this item will be completed by January 31, 1984. The second of the remaining open items (8204-14) involves the completion of 2 I&C procedures for ,

calibration of Health Physics equipment. One HP_ procedure revision necessary for closure of the open item has recently been approved. I&C has indicated that this item will be completed by December 30, 1983.

Summary The closing of 17 open items by the January 17-21 and July 11-15, 1983 inspections demonstrates strong management attention to radiation protection. The 2 remaining items require only minor work to close out.

RADWASTE SYSTEMS, EFFLUENT RELEASES AND MON 1TORING RECOMMENDED LP&L ACTIONS: Continued management attention is necessary to ensure that the backlog of work is completed prior to issuance of an operating license.

LP&L RESPONSE: 1. The completion of the solid radwaste facility (Portable) has been delayed by approximately six (6) weeks but will be completed by January 1, 1984. The inplant system will be completed by construction after fuel load, but will not be operational due to design problems. After gaining operational experience, a re-evaluation of the inplant system will be performed to determine if this system can be modified to provide economic, reliable operation.

(6)

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  • ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

RADWASTE SYSTEMS, EFFLUENT RELEASES AND MONITORING, (Continued)

2. The ALARA scetion of Health Physics in conjunction with Radwaste Department personnel has completed a second review of the TERA Corporation's ALARA Design Review of Waterford 3. The re-evaluation has examined the liquid, gaseous and existing solid waste systems, as well as looking at modifications made to these systems. An ALARA review has been performed for the new computer building and portable solidification facility. The two open items identified, 382/8322-02 and 382/8322-03, should be deleted by the NRC since Waterford 3's radwaste systems were designed and constructed prior to the recommendations of ANSI-55.2-1979, ANSI-55.4-1979 or ANSI-55.6-1979. LP&L made no commitment to use these standards in our design, construction or review process.
3. The effluent control program involves 6 HP procedures. Of these, 2 are approved, 3 are on the PORC agenda for November 10, and the remaining procedure should be completed by January 1, 1984.
4. HEPA and HECA cesting will be delayed until all applicable systems have been transferred to the Plant Staff.

Approximately sixty days prior to scheduled fuel load, Nuclear Consulting Services, Inc. (Nucon) will begin filter testing. It is estimated that filter testing will take approximately 20 days including loading charcoal into the units.

5. Revisions to Operations procedures on liquid, gaseous and resin vaste systems necessary to address all operational aspects will be completed by January 15, 1984.
6. Nuclear Auxiliary Operator Training has been initiated on the liquid and gaseous waste systems and will be completed by fuel load. Training on the Solid Waste Management System will start in December 1983 and be completed prior to fuel load.

Summary Of the 13 open items identified in this area, 6 items were related to construction /startup activities. Six of the remaining 7 open items have been addressed and completed and should be closed out during the next NRC inspection. The last remaining open item, Radwaste Operator Training, is currently being addressed, and will be completed in an expeditious manner.

(7) 1

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  • ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

TRANSPORTATION ACTIVITIES RECOMMENDED LP&L ACTIONS: Develop necessary procedures that include requirements appearing in the recent revisions of 10 CFR 20.311, 10 CFR 61, and 10 CFR 71.

LP&L RESPGNSE: The Radwaste Department has completed all procedures pertaining to transportation and is in the process of modifying / developing its procedures to address recent revisions of 10CFR20.311, 10CFR61, and 10CFR71, which will be complete by January 1, 1984.

Summary All open items under this area have been completed and it is felt that the NRC will close out all items pertaining to transportation. LP&L is currently making the necessary procedure revisions to incorporate recent revisions of 10CFR20.311, 10CFR61 and 10CFR71 as well as recent revisions to DOT regulations (49CFR).

CONFIRMATORY MEASUREMENTS, CH NISTRY/RADI0 CHEMISTRY RECOMMENDED LP&L ACTIONS: Increased management attention is necessary in this area to ensure that an adequate program is implemented prior to issuance of an operating license.

LP&L RESPONSE: Of the 15 Chemistry open items discussed herein, almost half are directly related to the status of construction and startup work. These items have been worked consistent with construction progress. Lack of earlier closure of these items cannot realistically be attributed to any " lack of management attention to Chemistry." A summary of these construction-related items is listed below:

382/8212-05 Awaiting verification of tank recirc times by riadwaste Startup.

382/8212-07 Awaiting completion of Chemical storeroom in the Turbine Building.

382/8212-08 Awaiting completion of summary sample line reroute, completion of installation and startup testing of the gas analyzer panel.

(8)

  • ATTACHMENT SECTIOP IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8212-09 Various online instruments (all conductivity monitors) had to be returned to vendor for repair prior to startup testing and acceptance.

382/8212-10 Post accident sampling system - awaiting construction completion.

382/8212-11 Facilities - awaiting completion of primary sample lina reroute and installation of the gas analyzer pansl.

382/8212-15 Procedures - awaiting verification of tank recirculation times 382/8212-01 Corporate Chemistry / Radiochemistry Organization.

This item open pending "the completion of the C/RC staff with qualified personnel and final approval of program procedures".

This item hus been completed and is awaiting NRC closecut.

382/8212-02 Onsite Chemistry / Radiochemistry Organization.

This item will remain open pending "the complete staffing of the Chemistry / Radiochemistry Department with qualified personnel".

The present Chemistry Department staffing requirements are:

a. 1 Department Head (vacant)
b. 2 Utility Engineers - Chemistry and Radiochemist (filled)
c. 2 Supervisors - Radiochemistry and Secondary Chemistry (filled)
d. 6 Technical Specialist
e. 4 Technicians The Chemistry Department staff at present is lacking a Department Head and 2 technicians. Additional requirements for the technicians are 6 of the 10 available positions have to be ANSI qualified. At present the Chemistry Department has 4 ANSI qualified technicians and is actively recruiting to fill tL; remaining technician positions with ANSI qualified personnel.

(9)

ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROL _S. (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8212-02 Onsite Chemistry / Radiochemistry Organization, (Continued):

One additional technician, ANSI qualified (Navy ELT) scheduled to start 11/28/83, this leaves only 1 technician slot open. 11/10/83.

382/8212-03 Chemistry / Radiochemistry Organization Qualifications This item open pending " review of all resumes of the corporate and onsite Chemistry / Radiochemistry personnel and the development of selection and qualification criteria for onsite Chemistry / Radiochemistry personnel to meet, as a minimum, ANSI N18.1-1971 qualifications."

1. The present method of personnel selection is as follows:
a. Resumes are received from Personnel Department.
b. The resumes are reviewed for qualifications under ANSI 3.1-1978 (FSAR chance pending to commit to ANSI 18.1-1971).
c. If applicants do not meet ANSI 3.1-1978 guidelines, the resumes are returned to Personnel for filing / future use,
d. If applicants meets ANSI 3.1-1978 guidelines, the resume is compared to the present Chemistry Technical Specialiet-Nuclear and Chemistry Technician- Nuclear Position Descriptions.
e. Those applicanto whose experience compares best with the position descriptions are selected for interviews ,
f. Based on results of the interviews by supervisory personnel, job offers are made.
2. The present Position Descriptions for the Chemistry Department are used for personnel selection. The Position Task Analysis Group is presently evaluating and are revising the Chemistry Department Position Descriptions to provide a more detailed analysis of job requirements. ANSI N18.1-1971 requirements will be incorporated into these Position Descriptions.

i (10)

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  • ATTACHMENT a

SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8'212-03 Chemietry/ Radiochemistry Organization Qualifications, (Continued)

3. After discussions with Blair Nicholas of the NRC a change to the FSAR will be submitted to require 6 of the present 10 technician / technical specialist positions moet ANSI N18.1-1971 guidelines. This will allow for training positions with the Chemistry Department. It is not consfiered practicable or even possible to always have all members of the Chemistry Department fully qualified to ANSI N18.1-1978.

382/8212-04 Chemistry / Radiochemistry Training Program This item open pending "1. Hiring of a Chemistry Training Coordinator and/or Chemistry Instructor, 2. Implementation of an official training program for Chemistry /Radicchemis-try personnel, 3. Complete qualification training of all Chemistry / Radiochemistry personnel, and 4. final review of Chemistry / Radiochemistry individual personnel training records, including written exams and qualifications records."

STATUS

1. Chemistry Training Coordinator is hired.
2. The Chemistry training program has been implemented.

All Chemistry technicians on site prior to June 1, 1983 have completed the course (presented in formal classroom lectures by EDS). All Chemistry technicians

( on site after June 1, 1983 are presently working on the training program in a self study mode.

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3. Qualification of technicians currently in progress.

382/8212-05 Primary Chemistry (Radiochemistry) l l- This item open pending "1. Completion of primary chemistry i system procedures, surveillance procedures, radiochemistry L analytical procedures, instrument calibration procedures, l

instrument calibration check procedures, and post accident I primary chemistry procedures, 2. Completion of instrument l

calibrations, 3. Development of detailed preparation I procedures for all nuclear instrument radioactive calibration standards, 4. Development and Implementation (11) i

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. . ATTACHMENT

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SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8212-05 Primary Chemistry (Radiochemistry), (Continued) of detailed sampling procedures for every primary system to be sampled including sampling times for each primary sample point to prcduce a representative sample, 5.

Verification of tank recirculation times to produce reptesentative samples, 6. Verification of all analytical procedures using known standards."

STATUS

1. a. All primary system procedures are complete and approved.
b. Surveillance procedure- CE-2-100 scheduled for PORC 10/27/83.
c. Radiochemistry analytical procedures are complete and approved.
d. Instrument calibration procedures are incorporated into radiochemistry analytical procedures and are completed and approved.
e. Instrument calibration check procedures are also included in radiochemistry analytical procedures and are complete and approved.
f. Post accident primary chemistry procedures are complete and approved.
2. Instrument calibration - all radiochemistry analytical instruments have been calibrated and calibrations are being maintained on instruments in routine use.

[ 3. Chemistry Department procedure CE-3-328, " Preparation l of Radioactive Calibration Sources" has been written i and is awaiting Group Head approval.

l l 4. Chemistry Department procedure CE-3-327, " Operation of the Primary Sample Panel" has been written and approved.

l l 5. Verification of tank recirculation times is presently in progress by the Radwaste Startup Group ECD 1/1/84.

6. Verification of all analytical procedures using known standards has been completed.

l l

l (12)

'. ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8212-06 Secondary Chemistry Program This item open pending:

1. a. Completion of secondary chemistry procedures
b. Surveillance procedures
c. Secondary chemical control and analytical procedures
d. Instrument calibration procedures
c. Instrument calibration check procedures
2. Development and implementetion of detailed sampling procedures for every secsudary syster to be sampled including sampling times for each secondary sample point to produce a representative sample.
3. Verification of tank recirculation times to produce representative samples.
4. Completion of instrument calibration.
5. Verification of all analytical procedures using known standards.

STATUS

1. a. All secondary chemistry procedures are complete and approved.
b. Surveillance procedure CE-2-100 scheduled for PORC 10/27/83.
c. Secondary chemical control and analytical procedures are complete and approved.
d. Instrument calibration procedures are included in secondary chemical control and analytical procedures and are complete and approved.
e. Instrument calibration check procedures are also included in secondary chemical control and analytical procedures and are complete and approved.

(13)

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- ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY ME/SUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8212-06 Secondary Chemistry Program, (Continued)

STATUS, (Continued)

2. A secondary sample panel operation procedure is not required. Most samples are continuous on line with flows controlled by the on line instruments. To obtain a grab sample from the sample panel only one valve has to be opened and the sample collected.
3. There are presently no tanks in the secondary system to which this applies.
4. All secondary analytical instruments have been calibrated and calibrations are being maintained on instruments in routine use.
5. Verification of all analytical procedures using known standards has been completed.

382/8212-07 Chemical Inventory Program This item open pending:

1. Complete implementation of the proposed program.
2. Establishment of a safe area for storage of flammable chemicals other than laboratory amounts stored in the respective laboratories.
3. Consideration of establishment of a computer program

! to handle inventory and accountability of chemicals.

STATUS

1. The PMD for Chemical Inventory has been deleted. The implementing procedure CE-1-008 has established the requirements and provisions of the program.
2. A chemical and reagent storeroom is presently being constructed on the mezanime level (+40) of the Turbine building. This storeroom will have a 45 gallon capacity flammable storage locker. The storage locker is presently on site and will be installed when construction is complete. Estimated construction complete 12/1/83.

(14)

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  • ATTACHMEhT a

SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY / RADIOCHEMISTRY, (Continued) 382/8212-07 Chemical Inventory Program, (Continued)

STATUS, (Continued)

3. A computer program has been considered for use on the ND 6620 for chemical inventory and control. At the present time a manual system is in use and is functioning well so the computer program has been assigned a very low priority as a " nice to have" but not necessary.

382/8212-08 Primary Sampling System This item open pending:

1. Complete checkout of the primary sampling panel.
2. Completion of sampling procedures and valve lineups for use of the sampling panel.
3. Complete calibration and checkout of the automatic gas analyzer panel.

STATUS

1. Primary sample panel preop test complete, panel was tested during Hot Functional Testing and is operational. New sample lines have been completed, hydrostatic testing completed and verified. Primary sample panel is operational.

l 2. CE-3-327, " Operation of the Primary Sample Panel" has

' been written and approved. This procedure has valve lineups, sample recire and purge times listed for each sample point.

l l 3. The gas analyzer preop test has been completed and the H and 0 analyzers calibrated. Several minor design 2 2 deficiencies were noted during the preop test.

However the panel is operational and is performing as designed. Combustion Engineering is presently evaluating the current design for possible modifications.

(15)

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. . ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY / RADIOCHEMISTRY, (Continued) 382/8212-09 Secondary Chemistry Sampling System This item open pending:

1. Complete checkout of the secondary sampling panel.
2. Completion of sampling procedures and valve lineups for use of the sampling panel.
3. Complete calibration and checkout of the process analyzers.

STATUS

1. The preop test on the secondary sample panel is completed. The panel was used during Hot Functional Testing and performed satisfactory. The secondary sample panel is operational. There is presently one CIWA to verify a sample flow from the MSR's. This was not performed during Hot Functional Testing and is the only deficiency presently carried against the secondary sample panel.
2. A secondary sample panel operation procedure is not required. Samples are continuous on line, with flows controlled by the online instruments. To obtain a grab sample from the sample panel only one valve has to be opened and the sample collected.
3. All process analyzers have been installed, tested and calibrated.

382/8212-10 Post Accident Sampling System This item open pending:

1. Installation completion, checkout, and calibration of the proposed system.

STATUS

1. The Post Accident Sample System installation is complete and has been released to Louisiana Power &

Light Startup. The system is presently being checked out by the Startup engincer and testing will commence shortly. The present system is scheduled for transfer to Plant Staff 60 days prior to fuel load. All Chemistry Department procedures for use of the system have been completed and approved.

(16)

.* I ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /R/J)IOCHEMISTRY, (Continued) 382/8212-11 Controls for Effluent Releases This item open pending completion of all effluent release procedures.

STATUS This item is presently assigned to the Health Physics group. The Health Physic's group has identified 6 procedures necessary to meet this item, 4 release permit procedures. HP-01-231 thru HP-01-234, 1 setpoint procedure HP HP-01-235, and the ODCM HP-01-230. Of these procedures HP-01-233 and HP-O'-230 are presently written and PORC approved. HP-01-231, 232, and 234 are written and swaiting PORC approval. HP-01-235 is being written and the estimated completion date is January 1, 1984.

382/8212-12 Facilities This item open pending completion of construction and occupancy of the chemistry / radiochemistry facilities.

STATUS Items listed as incomplete on the report.

1. Water plant laboratory was listed as temporary, incomplete.

The water plant laboratory trailer has now been completed. Lab furniture, fume hood and utilities have been completed. The emergency generators are on site and can be used for emergency power.

2. The chemistry supervisors office -4 RAB hae been equipped but is not presently occupied due to the technicians still being located in the trailer adjacent to the Administration Building. It would not be prudent to move the supervisors at the present time.
3. Primary Sample Room (-4 RAB)

The primary sample panel has been installed, new sample line installaticn has been completed and sample lines have been tested. Primary sample panel is operational.

(17)

.** j ATTACHMENT SECTION IV M'- RADIOLOGICAL CONTROLS, (Continued)

C0NFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382/8212-12 Facilities, (Continued)

STATUS, (Continued)

4. Gas Analyzer Room The gas analyzer has been completed, tested and calibrated.

382-8212-13 Chemistry / Radiochemistry Analytical Instrumentation, Calibration and Quality Control This item open pending:

1. Receipt of remaining instrumentation and supplies.
2. Completion of quality control procedures for analytical instruments.
3. Verification of operability and calibration of all i analytical instrumentation.
4. Implementation of the instrument calibration check program.

STATUS

1. All equipment identified has been received.
2. Quality Control of analytical instruments is incorporated into several procedures, all of which are completed and approved.
3. All analytical instruments have been tested and -

calibrated, calibrations are presently being maintained on instruments in use.

4. Instrument calibration check program has been instituted and is in progress.

382-8212-14 Audits and Reviews .

This item open pending implementation of a comprehensive audit / review program for Chemistry / Radiochemistry activities.

(18)

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  • ATTACHMENT

-SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382-8212-14 Audits and Reviews, (Continued)

STATUS, (Continued)

This item has been assigned to the Operations QA group.

Chemistry / Radiochemistry audits have been performed by the Operations QA Group under procedure QP-18.10.

382-8212-15 Procedures This item open pending:

1. Completion and approval of procedures referenced in Section 18.b of this report.
2. Licensee evaluation of procedures addressed in Section 18.c of this report.

STATUS

1. Of the 9 procedures 'isted as "to be completed" in Section 18.b 6 have oeen completed and approved, 2 procedures CE-2-100 has been writtea and is awaiting PORC approval.
2. Of the procedures listed in Section 10.c:
a. Tank recirc times - at the present time tank recirc times are being calculated. When the testing is completed a Chemistry Department Standing Instruction will be written which will contain the sample points, the tank recirc times, snd sample purge times,
b. Specific detailed sampling procedures for all manually taken samples including valve lineups, labeling, handling precautions, safety considerations, and flush times to provide representative samples. Where necessary this information has been incorporated into the system chemistry procedures and laboratory general practices. A specific detailed procedure for every case is not required.

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. ATTACHMENT SECTION IV M - RADIOLOGICAL CONTROLS, (Continued)

CONFIRMATORY MEASUREMENTS, CHEMISTRY /RADI0 CHEMISTRY, (Continued) 382-8212-15 Procedures, (Continued)

STATUS, (Continued)

2. Of the procedures listed in Section 18.c:
c. Preparation of instrument radioactive calibration standards. CE-3-328 has been written and is currently awaiting Group Head approval.
d. Determination of Lithium - covered by CE-3-400 which is written and approved.
c. Determination of Sodium - same as (d) above.
f. Determination of Radio Iodine in the Reactor Coolant System (Extraction eethod) - at this time a procedure of this type is not necessary. This information is provided by a gamma isotopic analysis. However if required in the future ASTM D-2334-73 method C can be used for this analysis.
g. Determination of Iodine Equivalence in the Reactor Coolant System - this is presently part of the software on the Nuclear Data System computer.

(APS.IODEQ) and is run as a routine part of a gamma isotopic analysis. A separate procedure is not necessary.

h. Determination of Radiocesium in the Reactor Coolant System (Extraction method). At this time a procedure of this type is not nececsary. This information is provided by a gammt isotopic analysis. However, if required in the future ASTM D-2577-72 (1977) Method C can be used for this analysis.

ENVIRONMENTAL SURVEILLANCE RECOMMENDED LP&L ACTIONS: Management attention is necessary to close open items identified during previous inspection and that the proposed radiological effluent monitoring program is implemented prior to issuance of an operating licence.

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. -g ,- t nc i';' 3. ATTACHMENT l i

SECTION IV-M - RADIOLOGICAL CONTROLS, (Continued)

~ ENVIRONMENTAL" SURVEILLANCE, (Continued)

'LP&L RESPONSE: LThis SALP report, covering the period through. July 1983 indicates that four previously identified open items in this area were closed, and six new open items were reported. These

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six open items were subsequently closed during an inspection

.of the Waterford 3 environmental monitcring programs performed August 22-26, 1983. No violations, deviations nor new open items were identified.- The NRC inspector concluded from that i- inspection, "that due to LP&L's timely resolution to outstanding open items; functionally reorganizing the

t. management structure for the operational environmental 1 monitoring activities; and implementing the REMP (Radiological

[ Environmental Monitoring Program) in cdvance to debug the program, there are no reservations in the area of the REMP to deter the issuance of an operating license to LP&L for WSES, i, Unit 3."

SECTION IV O - MAINTENANCE ,

RECOMMENDED LP&L ACTIONS: Increase management attention in-the area of assigning qualified personnel to support startup activities e and overall maintenance training.

LP&L RESPONSE: In October 1983,.the Maintenance Department was divided into i two (2) groups (Startup Maintenance and Plant Maintenance) to facilitate startup activities and ease the supervisory burden on permanent LP&L Maintenance supervisors. Startup now supervises Startup support directly. Maintenance supervision has been moved closer to Maintenance personnel and an operational maintenance environment is being stressed.

i Maintenance management has emphasized to supervisors the importance of ensuring that personnel are technically knowledgeable and competent to perform assigned work activities.-

(' Present corrective and preventive maintenance procedures require NOS authorization to commence activities and NOS I.

notification upon termination. NOS signatures are required on corrective maintenance work authorizations and preventive maintenance task cards. A breakdown in communications during l Hot Functional Testing resulted in Operations not being kept up to date on status of pressurizer level instrumentation This was corrected immediately and all supervisors were instructed on following procedures. Necessary corrective action was discussed with all Maintenance personnel.

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  • ATTACHMENT

,e SECTION IV O - MAINTENANCE, (Continued)

LP&L RESPONSE: (Continued)

A " Conduct of Maintenance" procedure will be implemented by December 15, 1983 and will cover:

1. Organization - to support startup, construction, outages and special projects.
2. Procedures / Instruction - to ensure that equipment is maintained to design specifications.
3. Administrative Controls - to ensure that Maintenance is authorized by the NOS (controlled maintenance) and proper documentation is maintained.
4. Personnel Qualifications and Training - to ensure that Maintenance personnel are knowledgeable and competent to perform assigned work activities.
5. Interfaces / Communications - to ensure that Maintenance personnel interface with other departments as required during the performance of their assigned work activities, i.e., keeping NOS appraised of the work status, check with Health Physics for RWP and ALARA purposes as required, QC for " witness" and "holdpoint" etc.

SECTION IV P - EMERGENCY PREPAREDNESS RECOMMENDED LP&L ACTIONS: Management should increase its knowledge of emergency preparedness regulatory requirements and guidance criteria. Management attention should be given toward assuring that the Waterford 3 training program, equipment installation, and approved procedures are accomplished to meet the licensing schedule.

LP&L RESPONSE: Since the emergency preparedness appraisal, LP&L has been upgrading its Emergency Preparedness Program. The Nuclear Operations Department organization has been modified to include an Emergency Planning Manager uho reports directly to the Nuclear Services Manager, with responsibility for all aspects of emergency preparedness. The Emergency Planning Manager has a staff directly reporting to him, as well as personnel matrixed from other organizations with in the Nuclear Operations Department, to effectively manage Waterford 3 emergency preparedness and to assure that the Waterford 3 Emergency Preparedness Training Program, equipment installations, and procedures are completed consistent with the licensing schedule.

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LP&L RESPONSE, (Continued):

The emergency preparedness appraisal items are being actively worked consistent with responses provided to the NRC in letters W3P63-2529 dated July 29, 1983 and W3P83-3356 dated October 18, 1983. The revisions being made to the Waterford 3 Emergency Plan and Emergency Plan Implementing Procedures will resolve many of the appraisal concerns with the balance of the appraisal concerns being handled, as appropriate, by other organizational actions.

Discussions are taking place with NRC Region IV concerning the scheduling of a follow-up appraisal consistent with our licensing schedule.

SECTION IV Q - SECURITY AND SAFEGUARDS RECOMMENDED LP&L ACTIONS: Examine the avenues of Communication between the divided management activities of those responsible for (1) setting up the physical / electronic security systems, and (2)those who are to implement the total protection program under 10CFR73.

LP&L RESPONSE: We have established a security task force with representation from Startup, Plant Operations, Plant Security, Corporate Security, anu Nuclear Services to enhance the communication avenues among the participating groups. This task force was set up well before the end of the evaluation period.

SECTION IV R - LICENSING ACTIVITIES RECOMMENDED LP&L ACTIONS: None LP&L RESPONSE: The SALP report rated the category " Licensing Activities" highly in the areas of Fire Protection, Emergency Planning and Core Performance. The major area of deficiency noted in the report was the lack of a structured and planned approach to developing acceptable emergency operating procedures (EOPs).

However, as noted in the report, near the end of the rating period significant personnel changes occurred, including the operational areas responsible for ECP development.

Verbally in July then in September 1983 via Letter W3P83-2782, LP&L committed to a complete rewrite of the E0Ps through implementation of Emergency Procedure Guidelines developed by the CE Owners Group and a1 proved by the NRC. The Procedure Generation Pcckage will be provided for NRC review in December, 1983 and the new E0Ps will be completed by March, 1984, in time to support operator training prior to scheduled fuel load.

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, - . *x*- ATTAoM SECTION IV R - LICEMSING ACTIVITIES, (Continued) b" LP&L' RESPONSE, (Continued):

During the EOP rewrite process, operator inptt and feedback has been actively sought. ,As procedures are completed they will be turned over to Training for development of lesson plans and training of operators. Additionally, both the Licensing _and Operations sections have been in continuous contact with members of the NRR Procedures and Test Review Branch to maintain the NRC up to date on progress and resolve any problems. These factors combined with a structured-approach to E0P development based on the requirements of NUREG

, 0737 Supplement I has resulted in an on-schedule activity i- ' which we are confident will produce a high quality set of E0Ps for Waterford 3.

Appendix A, Item IV.G of the SALP report rates Training as a category 3 area. This area has been addressed in the everall Training comments provided in response to Section IV.T of the main body of the SALP report.

As pointed out in Section F of Appendix A actual staffing at

the end of the SALP period was short of stated goals; however,

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i LP&L continues with its aggressive recruiting effort and as a result several key staff positions-have been filled with personnel having extensive commercial experience.

I -Although overall a rating of 2 was achieved in the area-of j licensing activities it is LP&L's intention to apply the level of Management involvement, responsiveness, and effort necessary to resolve technical issues such that a higher performance standard can be recognized during the present SALP period.

SECTION IV S - MANAGEMENT CONTROL 4

RECOMMENDED LP&L ACTIONS: The licensee should continue management effort to

. stay' involved and provide appropriate oversight to all functional areas.

LP&L RESPONSE: Changes to the Nuclear Operations organization continued to a limited degree during the assessment period. Significant and more aggressive changes have occurred since July 1, 1983. The latter stated changes are designed to provide the means for LP&L to have the onsite and offsite management and technical personnel resources to complete plant construction and conduct preoperational/startup testing in a timely manner.

Additionally, the most recently published structure establishes an integrated project organization to support the safe and effective routine operation of Waterford 3 and includes the capabilities to respond to any plant emergency.

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  • ATTACHMENT 4

'SECTION IV S - MANAGEMENT CONTROL, (Continued)

LP&L RESPONSE, (Continued):

Although structural changes to the Nuclear Operations organization were formulated during tha period April 11, 1983 to June 30, 1983, the actual physical restructuring primarily was accomplished subsequent to July 1, 1983. Therefore, it may be more appropriate to reserve detailed comments in regard to management control aspects of the restructured organization for the next assessment response. Suffice to say that the changes formulated during the April - June, 1983 time frame were intended to simplify communications and emphasize consistency of purpose toward that goal. Administrative and training functions were more closely integrated with their operating plant constituents, and were brought under overall control of plant management. On an interim basis, construction responsibility was reinforced by moving startup under plant responsibility. Executive actions since September 1, 1983 to current date have altered the foregoing to a certain extent and rightfully should be commented upon during future evaluation of the Waterford 3 project.

SECTION IV T - TRAINING RECOMMENDED LP&L ACTIONS: The licensee should take advantage of the time remaining to fuel load to provide refresher training to licensed operators and STA candidates in areas for which they have been shown to be weak by qualification or certification exams. The licensee should review the program descriptions which define the training progress and consolidate or revise them, as necessary, to eliminate duplication and to provide clear overall direction to the training program.

LP&L RESPONSE: 1. A requalification training program has been formulated for licensed operators and will be initiated prior to Fuel Load. A major input to the requalification program will be areas shown to be weak on qualification and certification exams.

2. Due to a change in philosophy a new STA training program will be initiated for newly selected " full-time" STAS. In the interin, previously certified STAS will fulfill this function until other STAS are qualified. They will receive portions of the operator requalification program and requalification on topics specific to the STA function.
3. The training Program Descriptions have been eliminated and are being replaced with a Training Manual which includes detailed course descriptions and training procedures which will describe who gets trained and when. This will eliminate any confusion existing from the Program Descriptions.

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1 ao a ATTACHNENT

.o SECTION IV T - TRAINING, (Continued) l - . . . ..

LY6L Kesrunst, ..

(concinuca):

4. Regarding operator training on E0P's, as the E0Ps are generated by operations personnel, training will be incrementally accomplished on these procedures. This training will start January 1984, after receipt of the approved procedures, i

P (26)

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