ML20092M978

Program Plan & Schedule

ML20092M978
Person / Time
Site:	Waterford
Issue date:	06/28/1984
From:	LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20092M967	List: ML20092M963 ML20092M978
References
PROC-840628, NUDOCS 8407020435
Download: ML20092M978 (28)

Text

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L June 28, 1984  ?

I WATERFORD 3 PROGRAM PLAN AND SCHEDULE I. INTRODUCTION AND PURPOSE l

This Program Plan outlines the methods by which the 23 in-  !

dividual. issues described in the NRC letter, Docket No.  ;

. 50-382, dated June 13, 1984, are to be resolved by LP&L. I Further, the Plan provides a mechanism'to address the i cause of the issues, the generic. implications and collec-  ;

tive significance of the issues, and the programmatic and i management changes' designed to preclude recurrence of such  ;

issues. The Program includes the establishment of an in- i dependent Task' Force to advise LP&L and' evaluate LP&L's l resolution of thetissues, and saparate review of the reso- .

lution by the Waterford 3 Safety Review Committee (SRC). {

l LII. PROGRAM PLAN MANAGEMENT i I

1. The LP&L Project Manager - Nuclear is assigned re- f

-sponsibility for management of the overall Plan and actions outlined in paragraphs III and IV below. He  ;

.will perform these tasks in a normal line management ~!

role-and have access to and the support of any-requi- t site LP&L and contractor managers and staffs on a top .

priority basis. He will assure effective interfaces  !

with-external groups including the SRC and the {

LUNC/NUS. Task Force l described in paragraph VI below. '

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2. .The Project Manager-Nuclear reports directly to the  !

Senior'Vice President-Nuclear, who in turn reports l 1,. directly-to the President and Chief' Executive Officer i I

~ . of LP&L. Both the Senior Vice President-Nuclear and.

g :the CEO are directly and actively involved in the  ;

management of the-Program.  ;

III'. RESOLUTION OF ISSUES l l

=1. -Each issue will be analyzed to determines  ;

-~ The cause '

The generic. implication i

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-' The actions'and schedules.to correct both the specific. problem and related generic concerns

Th'e. safety significance with respect to fuel

. load and low power operation, and to operation above 5% power 2.. -The intended' manner in which each of the 23 issues care to be addressed is described in Attachment 1. It

, ~s hould be noted that the manner of resolution.may

.need: modification as actions necessary to resolve any

.related safety concerns are undertaken.-

IV. COLLECTIVE SIGNIFICANCE AND PROGRAMMATIC CHANGES

As early as feasible in the process of formulating the in-

formation contained irt paragraph III above, the LP&L Proj-ect Manager-Nuclear wills'

1.  : assess'the collective significance of the indi-vidual-issues, and-

2. recommend. institutional or programmatic changes

~ deemed appropriate to avoid recurrence of the types of problems underlying the issues being addressed

't iV. SAFETY REVIEW COMMITTEE

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1. - The Waterford~3. Safety Review Committee (SRC) has i designated an SRC: subcommittee to' review the items outlined in paragraph III and IV above.

2. The'SRC. subcommittee consists of Kenneth W. Cook,

.LP&L' Nuclear ~ Support and. Licensing Manager, Chairman; i

' Joseph M.JHendrie, Consulting Engineer; Robert M.

.Douglass, Manager of Quality Assurance, Baltimore Gas and. Electric-Company;-Raymond F. Burski,'LP&L Engi-neeringfand' Nuclear Safety Manager; and Thomas F.

Gerrets,.LP&L Corporate' Quality Assurance Manager.

VI . - ' INDEPENDENT ASSESSMENT

1. An independent assessment of the resolutions and de-i termination of safety significance will be provided

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by a Task Force reporting directly to the CEO'of LP&L. The Task. Force consists of officials of UNC Nuclear Industries, Inc., Richland, Washington, and

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NUS Corporation, Gaithersburg, Maryland, who will be assisted by UNC and NUS staff members, as required.

The Task Force will independently assess LP&L's reso-lution of the issues, including the cause, generic implications and collective significance of the is-sues. The Task Force will also provide advice and assistance in the resolution of the issues, and will  ;

provide an independent assessment of the safety sig- ,

nificance of the issues with respect to fuel loading and low power testing, and operation above 5% power.

It will assess the adequacy of LP&L QA/QC program in light of the NRC's issues, and will recommend any in-stitutional or programmatic changes which may be nec-essary to prevent recurrence of the issues.

2. The' charter, identification of principals, initial functions have been formalized, as specified in At-tachment 2 hereto.

VII. RESPONSE TO NRC The individual issues vary considerably in both the degree  !

of concern and complexity of resolution. Therefore, LP&L '

intends to forward to the NRC the proposed resolution data individually or in packages as they are completed and have undergone the degree of review'specified herein. Some of the resolutions.may be submitted before completion of all requisite corrective actions, which are underway or de-fined and scheduled for accomplishment, have been accom-plished. Upon submittal, each resolution will be added as Appendix A of the Program Plan to constitute a major part of the final report.

VIII. ECHEDULE ,.

Attachment 1 lists the target dates for Project Management completion of resolution data on each issue. These dates  ;

include a period of time Project Management has scheduled for completion of its review and that of by the SRC and Task Force, although these dates are difficult to predict. t Target dates for development of the collective signifi- i cance of the issues and recommended programmatic changes outlines in paragraph IV above are to be established by July 6, 1984.

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PRt K: RAM PLAN CURRENT ASSESSMLNT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF IESUE LP&L APPROAril TO RESOLUTION DATE NONE FL TO 5% 25% JUSTIFICATION

1. Inspection Verify the proper LP&L will verify 7/20 A preliminary evaluation of the Personnel certification ci site the credentials of QA managers. T-B and Mercury QC inspectors issues QA/QC personnel or supervisors and personnel certitying questioned by the NRC indicated requality the work inspectors, and auditors, they were qualified and performed by these certified to perform their personnel, assigned work function.

A verification of the certification of it is important to note that the dpproximately 20% of all QC inspectors inspectors for the major is being done to assess the saf ety installers of saf ety related significance of the concern. A equipment and systems (e.g.,

description of the certification Tompkins-Beckwith. Fischback &

criteria (ANSI N45.2.6-1971), as Moore. Mercury NISCO, American required by the Quality program, Bridge, J. A. Jones, and Gulf) and a matrix showing certification performed no non-destructive and supporting documentation will testing (NDT). NDT was provided be prepared. Further efforts, including by CEO.

any necessary reinspections, will be based on specific problems and root cause An audit was performed on all analyses and will be as necessary to '

contractors performing safety verify the adequacy of the program and related work. An assessment of compliance with the program. the current audit results, which do not include American Bridge For the QC inspectors remaining onsite, and CE. Indicate QC personnel a reverification of proper certification were qualified and certified.

in accordance with ANSI N45.2.6-1973 is Additional backup information being accomplished, has been requested from CE and American Bridge to complete the Quality Control inspections currently evaluation. The preliminary being undertaken as part of other results of the audit are listed programs will be performed by yC below, personnel reverified as qualilled under 9 1. GEO (NDE) - 23 sampled /23

%ggf ANSI N4%.2.6-1973. qualified

/ S, 2. Waldinger - 5 sampled /5

.' qualified

3. B&B - 8 sampled /8 qualified

4. Sline - 15 sampled /15 qualified

PktCRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITI E DESCRIFTION OF ISSUE LP&l. APPROACH TO HESOt.UTION DATE NONE FL TO 5% M2 .lUSTIFICATION

2. Mis.ung NI lastrument Verity compliance with LP&L will review all N1 instrumentation installed 7/6 To date, 90 locally 1.ine Documentation NRC requirements for N1 during the period when class breaks were allowed mounted N1 instruments instrumentation (prior to April 7, 1982), identify required have been identified installations. documentation to densonstrate correct installati.n as being installed and inspection, and identify the documentation prior to April 7, 1982.

available. A QA review of all safety-related NL To date, using ASME Ill instrumentation systems has been perf ormed which documentation criteria verified that all installations were properly as a basis for compari-documented and inspected, son, full or partial compliance can be shown for the 12 installation at issue. Of the remaining installations 35 had no class breaks, 19 were thermocouples

, with no tubing, and 24 had been reclassified to N2 (i.e. not required for safe shutdown).

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=4 9 9 PntCRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE IS$t:E & TITtE DESCRil'IluN OF ISSUE LP&L APPROACH TO RESOLUTION DATE NONE FL TO %1 % % .IUSTIFICATION

3. Instrumentation Correct separation NCR-W3-7702 covers the system 51A problems 7/13 The walkdown to date Expansion Loop criteria violations and has been dispositioned to remove the represents approximate-Separation found in system 52A and expansion loops in question thus solving ly 20% of the installa-provide a program for the problem. tions to be walked down review of other s.sfety- and the amount of related violations and NCR-W3-7730 was generated to track the generic rework being identified takt the necessary concern. In order to provide some basis f or has been found to be corrective actions, determining the scope et our program, a sample very minor (i.e. three of 51 instrument installations were chosen for feet of tube track review in area of congestion, and walkdowns of cover). If the issue these lines were done. Thirteen violations were had gone undetected found out of 276 locations, although only one it would not have been required rework. It was decided to perf orm a QC likely to cause a verification of all lines wtwre the redundant safety concern.

tubing was run together and take the appropalate action. An interim response discussing the resolution of NCR-W3-7702 items and the status og NCR-W3-7330 reinspections will be provided as well as a schedule for completion of the reinspections.

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I v o PkuCRAM PtAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSLE & TITLE DiSCRIPTION OF ISSUE LP&L APPROACH TO HFSOLUTION DATE NONE FL 1U %% >%% JUSTIFICATION

4. Lower Tier Corrective LP&L shall review all LP&L will review the lower tier document reporting 7/9 Based on the current Actions Are Not being FCRs. DCNs. EI21s. and system to ensure it was structured in such a review. LPSL expecta, to t!pgraded to hCRs T-B DNs to assure that awnner that procedures, integral to the Quality demonstrate that there proper corrective Program, provided a sound basis for decisions re- has been adequate QA/QC action was taken, garding the severity level of documents used to involvement in all including an adequate report deficiencies. The review will specifically lower tier documents seview by QA. This consider QA and QC reviews of engineering / with regard to 10CFR50 corrective action shall construction judgements on d-ficiencies as it Appendix B corrective include the steps relates to the corrective action and noncon- action and non-conform-required by 10CFRSO. 1ormance requirements of 10 CFR %0 Appemlix B ance requirements.

Appendix B. Criterion and the reporting requirements of 10 CFR 50.5%(e). This involvement is XVI Corrective Action expected to show that and for Construction The response will include an assessment appropriate corrective Det iciency Reporting, of all the lower tier documents specifically actions, specific and 50.5%(e). Also, cited by the NRC to verity the adequacy of the gen ric. are identified included in this review proceduralized saieguards in asmuring that shall be the deficiencies with safety significance are Our currect evaluation examination or improper being properly dispositioned and reported. of the examples of voiding of all other There will also be an assessment of improper lower tier documents design changes or voiding. cited by the NRC demon-discrepancy notices strates that although a that affected safety- s. null percentage should related systems or that have been upgraded to were misclassified as NCR's under the quality safety. Program in etfect, none had adverse safety aignificance.

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PROGRAM PLAN CURRENT ASSF.SSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE 1.P&L APPROACH TO HESU!UTION DA1E NONE Ft. TO %I >5% JUSTIFICATION

%. Vendor Documentation The concern relates to A problem did exist with formal tracking of 7/13 The CE records and Conditional keteases whether abortcomings in Combustion Engineering Conditional Certitications other records with the cont ractor' documen- of Equipment. Records associated with CE material exception of JA Jones tation which existed at and equipment will be re-reviewed and conditional and Waldinger have been the time the material certifications will be identified and promptly reviewed. To date 8 of was supplied have been resolved. Control of CE material and equipment 14 CE conditional cert-corrected. differs from that of other contractors. in order ifications have been tu verify that a similar problem does not exist changed to uncondit-in the case of other contractors, a sample audit of ional. No items other critical purchase orders will be performed. affecting plant safety if the sample audit identilles any other problems have been identified with the handling of contractor material releases, in any of the completed additional reviews will be initiated, reviews and dispo-sitions.

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PktCHAM Pl.AN CURHENT ASSESSMENT OF SAFETY SICNIFICANCE ISSUE & TITI.E DESCRIPTION OF ISSUL LP&l, APPROACH To RESOLUTION DATE NONE FL TO 51 >5% JUSTIFICATION

6. Dispositioning of Some Ebasco and Hercury First, the inplace program for handling of lower 7/13 To date, the NCRs Non-conformance and NCRs and Ebasco Dks tier documents such as DRs will be discussed, cited by the NRC have Discrepancy Reports were questionably dis- been evaluated. Five positioned and LP&L Second, the specific NCRs and DRs cited by the of the 49 are being shall propose a program hRC will be evaluated for proper designation, further evaluated, to assure all NCRs and disposition, and implementation of corrective Three impact hardware DRs are appropriately action under the existing Quality program, and two software. The upgradeJ. adequately balance have been shown dispositioned and Third, a review of all NCRs was started by LP&L to be adequately dispo-corrective action in January to assess the validity of the dis- sit ione d. The overall completed and that any position, the corrective action taken, the com- review of NCRs has preblems detected are pleteness of the documentation and proper closure, been completed with corrected, the excent ion of Fourth, a field verification will be conducted on approx 4mately 300. This ,

one hundred randomly selected NCRs to ensure the review showed 416 of corrective action resolved the nonconformance. the total 7750 NCRs were questioned. 85%

If any problems are detected from these steps, a ut these deficiencies plan of further corrective action will be estab- were documentation re-lished. lated and were not significant. The balance will be closed.

To date 12 of 100 NCRs have been iteld verified. No con-clusions have been drawn as of yet.

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I PROGRAM Pl.AN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCF.

ISSt:F & TITLE DLSCRIPTION OF ISSUE I.P&t. APPROACH TO RESOL _UTiuN DATE NONE FI. TO 5% >%% JUSTIFICATION

7. Backfill Soil Conduct a review of all The backfill records are being reviewed for 7/13 The effect of any pos-Densities soll packages for completion and technical adequacy, record packages tulated variations in compiereness and are being located and any technical issues will be density in the fill is technical adequacy. evaluated. not of significance Where records are relative to the missing or technic.sl seismic response of p rt,b lems a re de t ined , the plant as designed.

take currective action. In addition, should there be a few missing records, a satisfactory demonstration of the quality of the backfill will be provided.

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PkOGRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION DATE NONE FL TO 5% >%1 JUSTIFICATION

8. Visual Examination Document inspections LP&L will provide documentation verifying that 1/b Investigations to date of Shop Welds during of shop welds during shop welds were inspected by qualified show that shop welds itydrostatic Testing hydro tests or other- inspectors. were inspected and wise verify such accepted during inspection. hydrostatic tests by an Authorized Nuclear Inspector as demon-strated by reports.

The ASME N-5 code data reports also confirm that there was inspection of shop welds. The methodology of the iteld hydro-static testa provide additional qualifica-tion of testing.

Documentation on the above will be provided.

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.y PMERAM Pl.AN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DFSCRII" TION 06 ISSUE t.P&I. APPROACH To kESol.UTION DATE h0NE FL Tu 5% >%% JUSTIFICATION

9. Welder Certification Locate missing documents NCR W -7549 was generated on 2/1/84 to track this 7/20 All welding evaluated for instrument cabinet problem. No documentation was found on three of to date has been found welds and determine if the eighteer cabinets and partial documentation acceptable, welders were appro- found on four. All seven were reinspected and priately certif ied, found acceptable.

Take appropriate action to assure the quality As a result of the missing documentation, a of the supports if review is being performed to determine other documentation cannot misce!!aneous cases where Jones performed welding.

be located. Documentation for the welding identified will be reviewed.

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PROGitAM PLAN Ct!RkFNT ASSFSSMENT OF SAFETY SIGNIFICANCE ISSUE & TITI.E DESCRIPTION OF ISSUE I.P&L APPHOAC1170 kFSOLUTION DATE NONE FL 1U %Z >%Z JUSTIFICATION 1% Inspector Quali- Verify the proper certi- A reassessment of the adequancy of the program to 7/13 Preliminary evaluations f ication (J. A. fication of QA/QC certify inspectors will be performed for of J. A. Jones QC per-Jones and Fegles) personnel and evaluate approsimately 201 of all QC inspectors to assess sonnel qualifications the impact of any the safety significance of the concern. questioned by the INtC deficiencies founJ. Indicate they were lasere deficiencies are identified, the !=spections qualified ar.d certified made by the subject QC personnel will be reviewed to perform their and an evaluation made of etw safety significance assigned work function.

with regard to design construction and operation. The sample size was The need f or additional corrective action will be twenty percent (201),

assessed as part of the safety evaluation. Nineteen of the 20 were qualified and one was qualified pending clarification.

Additional backup information was re-quested from Fegles to complete our evaluation. It is I

important to note that the inspectors per-formed no non-dentructive g testing (NDT). NDT was provided by CEO.

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L PktCkAM PLAN CURkENT ASSESSMFNT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTI N OF ISSUE LP&L APPROACII TO kESOLUTION DATE NONE FL TO 51 >5% JUSTIFICATION

11. Cadwelding Provide the cadweld The cadweld records will be transcribed onto 7/20 Prior reviews have data for the project in computer data storage including the placement already been accom-such a form that it can number, cadweld number, be size, bar position, plished under NCR be readily compared to visual inspection acceptance or rejection. Wi-6234 and non-cl.e testing criteria production splice tensile test acceptance or conforming conditions used for the Waterford rejection, and sister splice tens'le test resolved.

3 project with data acceptance or rejection.

broken down by various categories. Provide In this torm the cadweld data can be called up by data on welder quali- any of these attributes to expedite review for fication and requali- specification compliance or uti.cr reason. Also, fication including physical location of cadwelds may then be readily dates. obtained by reference to the concrete placement lift diagrams which locate the placements.

Data on welder qualification and requalification will be gathered and provided as part of this elfort.

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PROGRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITI.E DESCRIPTION OF ISSUE I.P&L APPROACH TO REsotUTION DATE NONE FI. TO 5% >%% JUSTIFICATION I2. Main Steamline Complete the document- SCD 78 was resolved and subsequently reopened upon 7/11 The safety significance Framing Rentraints ation for all discovery that inspection = in one area were not of not replacing the connections in the comp le t e. NCR-W1-7736 issued to track resolucion bolts which were steam generator framing. of the deficiency, in order to assure complete replaced is still under resolution of this concern, LP&L tuitiated both a evaluation. Howe.ve r ,

100% QC rein pection of steam generator framing the actual restraint connections as well as a review on the American structure is not needed Bridge work scope against the scope of SCD 78 until the reactor reinspections to assure that reinspections were generates power and complete. therefore the bolting is not a constraint All connections were reinspected. Requiste bolt to fuel load or replacement and NCR closure is scheduled to be operations up to 5%

completed by July 6, 1984. power.

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itoCRAM PLAN CURRENT ASSESSMENT OF SAFFTY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE iPhl APPROACll TO RESO!.UTION DATE NONE FL lu %% >%% JUSTIFICATION

13. Missing NCRs LP&L shall obtain the LP&L is conducting a review of closed and vuided 7/6 A review to date missing NCRs. explain Ebasca hCRs to determine it they are not properly indicates that only why these NCRs were indexed and filed in the QA records vault. five out of more than not maintained in the 7500 site-issued NCRs.

filing sy stem, review The evaluation will identify all NCRs. whith are which have been closed them for proper indicated as closed or voided by site QA tracking or voided, are not vulding, and assure mechanisms but not vaulted and provide an explaua- indexed and filed. Of t hat when an issue is tion as to why they are missing, assure proper t he five NCRs which raised to an NCR. it voiding, and assure proper filing and tracking. have not been indexed is properly illed for and filed, it can be tracking and closure. A similar evaluation is being conducted on NCRs demonstrated that they which were issued by Ebasco QA in New York. apparently were never issued. Sufficient documentation is on file to demonstrate the acceptability of the safety-related items described in the log entries corresponding to these five NCR numbers. The review indicates the problem stems from NCR track-ing system utilized prior to mid-1979 and that since then the in-

\ proved NCR tracking system has been ade-quate, in addition the review indicated that there were thirteen numbers that were ap-parently never assigned to an NCR. LP&L is in process of confirming that NCRs with these numbers were never fssued.

PROGRAM PLAN CURKENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSt'E & TITLE DESCkiPTION OF ISSUE I.P&L APPROACH TO RESULUTiuN DATE NONE FL TO %% 7%% JUSTIFICATION

14. J. A. Josses Speed l>uring the ESasco QA First , a review has been conducted of corres- 7/20 To date about 1100 letters and ElRs review c1 J. A. Jones pondence between J. A. Jones and Ebasco via Speed pieces of JA Jones speed letters and eng- letters and ElRs. correspondence have ineering information been reviewed and 211 requests, several items Second, a review of such correspondence in which design thanges identi-that could affect plant design changes were conveyed to J. A. Jones with- fled. Of these, 190 safety were noted. out reterence to follow-up action to formalize the have been approved as B. sed on its sample of c hanges is being conducted to determine salety acceptable, 27 are the these actions, the staff significance. subject of field does not expect that any investigations to of these items will Third, a minimum sample of ten peacent of informal develop information for signif icant ly af f ect documents such as speed letters and Elks by other evaluation, and the plant satety. contractors performing saf ety-related work who balance are under Nevertheless, t he app- utilized these type of documents is being review. To date no lican, should complete conducted. The need to review additional safety problems have the actions identified documentation will be determined based on the been defined that would in these reviews and results of this review. require rework.

f.ssues raised shall be resolved promptly. For other contractors, the review has shown that 8 of 42 Fegles, 3 of 119 Waldinger, and 2 of 660 T-8 informal documents could involve design changes. These reviews are substantially complete and evalu-ations are in f, process.

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ISSUE & TITLE DESCEIPTION OF ISSUE LPal APPROACH TO RESut.trTiuN DATE NuNE FL TO $% %% JUSTIFICATION 15 Welding of "D" level Locate the documentation LPal. will conduct a review to confirm that 7/13 The CB&I QA manual Material Inside for "D". level material material and weld rod records exist to establish requirements for Containment welding and verify the material control for all "D" material welds; documentation of fit-up adequacy of the identify and verify Etw certification of all and final weld information or perform a . welders, and; provide inspection, procedures and inspections do not.

material analysis and data as well as afildavits from inspectors, apply to "D" material NDE work, or rework Documentation will be tied to specific welds as welding although weld t he welds. auch as possible. This will include identification inspections were per-of "D" material welds and comp 11ation of: formed. The work was

1) applicable CB4I "as built" drawing numbers; performed by the same

2) identification of we!Js by piece mark numbers welders and inspected and material type (i.e. D to D, D to B, etc.); by the same welding

3) quantities for repetitious weld I.D.'s; supervisors to the

4) weld type and size, and; %) indication as to

. same standard as the shop or field welds. LPAL will evaluate the results rest of the CB&l work and determine whether reinspections are required for which documen-and what the scope of such a reinspection will Ie. tation is provided.

This provides a high degree of confidence in the quality of the finished work.

Additionally very low rates of rejection in NDE tests and in inde-pendent surveillances

' and audits indicates high work quality.

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i PWUGMAM PIAN CURRENT ASSESSMENT OF SAFETY SIGNI F!CANCF. [

ISSer & TITR E TA % )rTION OF ISSUE LP&L APPMOAOI TO kESol.UTION DATE NONE FL TO % D*Z Jf373FICATION Ib Surveys zed Estr The NHL was critical of The interview f orms h ave been personally reviewed 7/9 Reviews to date P. ave

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Interview of QA the w.a.er in wt.ich a by the Senior V.P.- huclear to assess whether the not identified dignift-Personnel pau.a.a et interviewing program met his intent and the basis tur the NHC cant safety concerns sitei QA/y* personnet kn comments. Two further LP&L staff actions tramin. not alreaay facntirica.

urder to LJent if y and I) A seview by the Independent Satety Evali:4 tion <

take apprg. sate action Group (ISEG) primarily to assure staat the regardi;.g their concerns concerns received daring the ist Srviews were or will ta:

was conducted. appropriately addressed and necessary corrective actions taken

2) A determinattua ss to Etc. Scope and manner in y which future merbods et addressing, isse s raised by individuals are addresmed.

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I PktEkAM PIAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE I P&L APPirOACH TO RESOLUTION DAT E NONE FL TO 5% 75% JUSTIFICATION

17. yC Verification of The hkC is coacerned on 1he concern stems over the f act that a 1982 7/b Initial reviews show Espansion Anchor whether these was revision of an inspection form does not list the that the requisite Cha rac t er ist ics suiticient QC verifica- sequisite QC inspection attributes. The initial characteristics were tion of the character- review of this matter indicates that the requisite part of the procedure istics necessary to QC reviews were made as sequired by the drawings (incorporated by ensure proper installa- which accompanied the inspection lures. This was drawings). This tion of concrete substantiated by a thorough review of Mercury provides reasonable expansion anchors quality records. LP&L will prepare a response assurance that QC installed by Mercury. discussing the incorporation of drawings into the verification was procedure, training of Mercury personnel, the QC adequate. Previously review and substantiation of record = and a root there were 896 re-cause evaluation of the problem. inspections made of installed expansion anchor characteristics to confire records validity.

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CURRENT ASSfSSMFNT 0" SAFETY SIGNIFICANCE

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! ISSUE & TITLE DESCRIPTION OF ISSUE if&l. APPROACH TO RESOLUTION DATE Nf kE Fl.'TO %1 75% JUSTI FICATION k ,

18. Documentation of Documentation should be The resmmse . to this issue discusses the manner 7/6 Tim design and Walkdowns of Non- provided triat clearly in whicn design and installation considered the -

construction of Safety Related shows what equipment effects of interactions 01 non-seismic with safety- ilaterford-3 considered Equipment a was reviewed during the related systems during an S5E. Documentation ' interactions of non-walkdowns and on what atte. sting to the scope, conduct ar.d results of the seismic Mechanical, bases it was concluJed review will be provided. Electrical, HVAC, Civil that the installation and Instrumentation was acceptable. equipment with safety-f related equipment.

The walkdown verified that such interactions do not constitute a safety concern.

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. o PROGRA*1 PIAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE I.P&L APPROACH TO RESOtllTION DATE NONE FL TO 5% M% J USTI FICATION

19. Water in Basemat Review all conduit that A walkdown was performed which identitled 19 7/6 There was never a path Instrumentation penetrates the basemat places where wetness due to seepage from for ground water to Conduit and terminates above the conduits was found. These cases will be flow in sufficient top of the basemat to addressed by removing the existing seals and quantity to flood the assure that these replacing them with a light density milicone ausiliary building potential direct access elastomer which has the cap bility to stop the basement, even before paths of water are seepage. This work will be perf ormed at the the seals were properly sealed. convenience of LP&L since the slow seepage through installed and before the seals is not a flooding hazard but rather a the temporary conduits nuisance to maintenance, were grouted. The floor drain and sump Temporary conduits which enter the basemat from pump system was more outside, and which once allowed passage of ground than adequate to handle water in quantities that required periodic pumping, the quantity of water have now all been pressure grouted and their which entered the temporary blockout pits tilled with concrete and building during const-no longer serve as a leak path for ground water. ruction, and is adequate to handle the The one piezometer standpipe which tem. sins in much reduced quantity service will also be grouted since it monitors a presently observed.

deep aquifer of no present interest.

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PROGRAM Pl.AN CURRENT ASSF.SSMFNT OF SAFETY SICNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPkOACH TO RESOI.UTiuN DATE NONE 11. Tu %% > 5% JUSTIFICATION

20. Construction Verify the pauper LP&L is reviewing the supporting documenta- 7/11 Corrective action taken Materials Testing certification of const- tion for the corrective action of NCR-W)-F7-Ilb *s a result of an LP&L (CMT) Personnel ruction materials to ensure the adequacy of the corrective action. ask Force verification Qualification testing personnel. Additional supporting information will be sought effort on GEO document-Records. as necessary in order to contire adequate atton for CMT personnel qualifications. Evaluation will be u de of the quellfications (See NCR adequacy of certifications fur individual personnel W3-F7-Il6).

and it certifications are judged inadequate, the implied safety concerns that are raised will be addressed.

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PROGRAM Pl.AN CUHkENT ASSESSMENT OF SAFE 1Y SIGNIFICANCE I SSUE & TITI.E l>ESCRIPTION OF ISSUE LP&L APPROACit TO RESOLUTION DATE NONE FL TO 51 25% JUSTIFICATION

21. IPAL Construction A concern exists over A review of transler correspondence on the 7/h A review of 100% of System Status and whether construction systems which were the cause of this concern turnover / transfer Transfer Reviews. deficiencies were will be performed. A review will be conductcd correspondence showed properly dispositioned to verify that deficiencies in transferred no additional or identified during systems had no impact on testing. correspondence was the process of outstanding beyond that transf erring systems previously identified.

from construction to Deficiencies idencified plant operations. on the outstanding cor-respondence (13 SUS) have been reviewed by LP&L start-up/oper-ations and it was deter mined that there was no impact on testing.

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PROGRAM PLAN CUNRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE I.P&L APPROACH R) RESolMrION DATE NONE FL TO 5% 75% JUSTIFICATION

22. Welder Qualification Verily welder qualif- LP&L has conducted a review of all Mercury 7/6 Documentation to sup-(Mercury) and Filler cations or assure the welders. The review confirmed that the docu- port the proper Material Control quality of all welds. mentation to support their proper qualification qua1111 cation of all (Site Wide) is available. Baking /rebaking is not allowed on Mercury welders is Provide engineering just- the site and the complete answer will describe available. NCR-W3-7724 ification for the allow- the site procedures and applicable code require- was opened to document ance of "rebake" temper- ments and show that handling of filler material qualifications sheet atures and holding times meets the required codes. errors for 3 welders.

that differ from the requirements of the ASME and AWS Codes. No code deviations exist.

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l PROGRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE IP&L APPROACH TO RESOL.UTION DATE NONE FL TO 5% >5% JUSTIFICATION

23. QA Program Breakdown Determine the cause ot' LP&L will review corrective action commitments 7/13 The Mercury reviews between Ebasco and the breakdown, the ade- made on the NRC enforcement action and provide have been completed Mercury. quacy of the corrective a detailed evaluation of the actions taken. A with the exception of action, and provide review of the audit programs will be performed to SCD-61 " Linear Crack assurance on the ade- evaluate f requency and f ollowup of required in Stainless Steel quacy of the operational corrective actions of the program. The indepen- Tubing"(currently under QA Program. dent management assessments will be reviewed with reevaluation). The actions taken. review indicates that there are no open items LP&L will provide an assessment of the overall QA affecting plant eafety.

'rogram p to provide assurance that the QA program can functica adequately during operations.

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LOUISIANA / an Am~~e smer e a c. ecx eo340 P O W E R & L I G H T / NewCREANS.LOUSANA 7o160 4 (50dl59tH204 M100LE SOUTH UTIUTIES SYSTEM J.M. CAIN President and June 20, 1984 Chief Executive Otiscer W3B84-0445 Mr. Saul Levine NUS Corporation 910 Clopper Road -

Gaithersburg, Maryland 20878 Mr. Robert L. Ferguson ,

UNC Nuclear Industries, Inc.

1200 Jadwin, Suite 425 Richland, Washington 99352 Mr. Larry L. Humphries UNC Nuclest Industries, Inc.

P.O. Box 490 Richland, Washington 99352

SUBJECT:

Pre-Licensing Issue Assessment Task Force Charter

REFERENCE:

Discussions in the Offices of Shaw, Pittman, Potts & Trowbridge,' Washington, D.C. , June 13, 1984

Dear Messrs:

Levine, Ferguson and Humphries:

Pursuant to discussions in the referenced meeting, this formalizes agreements reached between us as to the charter of the subject Task Force.

The roles of UNC and NUS will be to act as a task force in providing assessment and advice in responding to the NRC letter of June 13, 1984 It is important to emphasize that both UNC and NUS will maintain suf fi;ient independence in order to provide to me as Chief Executive Officer of LP&L an independent pro-fessional assessment regarding the functions listed below. Your assessments will be formalized and sent to the Director of the Office of Nuclear Reactor Operations at the same time they are provided to me.

4 The Program Plan and implementation schedule requested in the NRC letter.

8 The adequacy of responses and resolutions (including '

validation of data and sources, as appropriate) of the matters set cut in the NRC letter.

! . Prc-Licensing Issue Assessment Page 2 Tcsk Icrc9 Chartcr

. 7,- Juna 204 1984 e The safety significance of the matters listed in the NRC letter with= respect to:

-; Fuel load and testing up to 5% power

- Operation above 5% power

-0 The adequacy of the past QA/QC program in light of the matters listed ht the NRC letter, and the resolution of such-natters.

9 Recommend institutional or programmatic changes that are deemed appropriate during plant operation in light of the lessons learned as a result of the matters set forth in the '

NRC letter, and the LP&L responses hereto.

The following abbreviated organization chart is provided to clearly depict that the Task Force is t,o have access to and interface with all necessary '

elements of the Waterford staff but is to report directly to me.

President &

Chief Executive Of ficer (LP&L)

(J. Cain)

Task Force Senior Vice President -

Nuclear Operations (LP&L) ,

(M. Leddick)

Safety Review Committee a

l I Quality Assurance - Proj ect Manager (LP&L)--- Plant Manager (LP&L)

Manager (LP&L) (D. Dobson) (R. Barkhurst)  !

(T. Gerrets)

Ebasco'& Staff LP&L & Staff Reporting

---

--- Interface Very t y yours, 7

J M. Cain JMC:DID:pb ,

cc: G. Charnof f, R.S. Leddick, D.E. Dobson

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