ML20093N542

Revised Program Plan & Schedule for Resolution of 23 Issues Described in NRC

ML20093N542
Person / Time
Site:	Waterford
Issue date:	07/23/1984
From:	LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20093N540	List: ML20093N538 ML20093N542
References
PROC-840723, NUDOCS 8408020035
Download: ML20093N542 (28)

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July 23, 1984 WATERFORD 3 PROGRAM PLAN AND SCHEDULE I. INTRODUCTION AND PURPOSE This Program Plan outlines the methods by which the 23 individual issues described in the NRC letter, Docket No. 50-382, dated June 13, 1984, are to be resolved by LP&L. Further, the Plan provides a mechanism to address the cause of the issues, the generic implications and collective significance of the issues, and the programmatic and management changes designed to preclude recurrence of.such issues. The Program includes a separate review of the resolutions by the Waterford 3 Safety Review Committee (SRC)

Subcommittee ar.d the establishment of an independent Task Force to adv49e LP&L and evaluate LP&L's resolution of the issues.

.II. PROGRAM PLAN MANAGEMENT

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

.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 e support of any requisite LP&L and contractor managers and g~

staffs on a top priority basis. He will assure effective interfaces with external groups including the SRC and the UNC/NUS Task Force described in paragraph VI below.

2. The Project Manager - Nuclear reports directly to the Senior Vice President - Nuclear, who in turn reports directly to the President and Chief Executive Officer of LP&L. Both the Senior Vice President - Nuclear and the CEO are directly and

-actively involved in the management of the Program.

L .III. RESOLUTION OF ISSUES

1. Each issue will be analyzed to determine:

The cause

- The generic implication

- The actions and schedules to correct'both the specific problem and related generic concerns The safety significance with respect to fuel load and low power operation, and to operation above 5% power 0400020035 040727 PDR ADOCK 05000302 A PDR

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2. The intended manner in which each of the 23 issues are to be addressed is described in Attachment 1. It should be noted that the manner of resolution may need modification as actions necessary to resolve any related safety concerns are W. undertaken or additional sources of information become U available.

IV. COLLECTIVE SIGNIFICANCE AND PROGRAMMATIC CHANGES As early as feasible in the process of formulating the

.information' contained in paragraph III above, the LP&L Project

. Manager . Nuclear will:

~1. . assess the collective significance of the individual issues, and

2. recommend institutional or programmatic changes deemed appropriate to avoid recurrence of the types of problems underlying the issues being addressed.

4 JV. SAFETY REVIEW COMMITTEE 1

1. The Waterford 3 Safety Review Committee (SRC) has 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; Joseph M.

Hendrie, Consulting Engineer; Robert M. Douglass, Manager of Quality Assurance, Baltimore Gas and Electric-Company; and Raymond F. Burski, LP&L Engineering and Nuclear Safety Manager.

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VI. INDEPENDENT ASSESSMENT

1. An. independent assessEent of the resciutions and determination of safety significance will be provided 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 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 resolution of the istues, including the cause, generic implications and collective significance of the issues. The

. Task Force will also provide advice and assistance in the k endent resolution of the issues, anj will provide an in assessment of the safety significance of the iss witte

, 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 w; institutional or programmatic changes which may be necessary to prevent recurrence of the. issues.

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2.1 sThe charter, identification of principais, initial functions I have been formalized, as specified in Attachment 2 hereto.

,, VII.. RESPONSE TO NRC

+ ' _The it.dividual-issues vary considerably in both the degree of-

• concern-and complexity of resolution. Therefore, LP&L intends to 1 forward to the NRC the proposed resolution data individually or in packages.as they are completed and have undergot.e the degree of review specified herein. Some of'the resolutions may be submitted before completion of all requisite corrective actions, which-are underway or defined and. scheduled for accomplishment, have been accomplished. Upon submittal, each resolution will be

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added as Appendix A'of-the Program Plan to constitute a major part of-the final report.

3 I .VIII. SCHEDULE ,

The goal of LP&L is to submit by m'id-August 1984, the resolution of all issues, our assessment of the collective significance of those issues, and the programmatic changes deemed necessary to p ' avoid recurrence of those issues which indicate such changes are appropriate.

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ISSUE & TITLE DESCRIPTION OF ISSUE LP&L AFF30 ACE TO RESW2T15 CURRENT ASSESSMENT

'1. Inspection Personnel Verify the proper . A verification program has beam earahHahad to ,

To Be Determined

• Issues certification of site review the professional credentials of 100I of the QA/QC personnel or site QA/QC personnel incluetag empervisors and requalify the work managers. The discussion that fellous applies to performed by these all contractors except J.A. Jomme. Fegles and CEO.

personnel. which are addressed ta Issume 10 ami 20. Criteria for certification or qualifiestion of gh/QC ,

personnel will be bened an et program requiremmets

.t and contractual c e ===es.

The adequacy of credentials to support certif-ications and qualifications is being reviewed.

Criterid have been established to sort personnel files into 3 groups: ..;

A. Qualifications dommed adequate

% 5. landequate docummutatism as perform evaluation S C. Qualifications questionable.

Other site flies will them be researched and con-tractors contacted for persoummel in groups B and C to verify their acceptability. In addition, background investigattoms will be performed for a.

sample of personnel in all grumps. including essentially all Mercury pers-1 and a large sample of Tompkins- Beckwith personnel. If certification of an individual can not be -

justified, he will be placed is a fourth group i

designated group D (Qualification inadequate).

Appropriate site noncomfom docuamatation will be initiated to docummet evalmation of safety significance and corrective actions, including reinspections of work performed as necessary.

For Ebasco. LP&L. and other site esmatruction related QA/QC personnel r=4= seq om site, a reverification of proper certification is being accos ,11ehed in accordance with ANSI-N45.2.6-1973.

Quality t,antrol functions corrently being under-taken as part of the walkdowns in progress are being performed by personnel reverified as qual-ified under ANSI-N45.2.6-1973.

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D TSSUE & TIT 12 DescafFTTON OF ISSUE 1. PSI. APP 90&CB 10 RESOLUTION CURRENT ASSESSMENT

2. Missing El lastrument Yerify compliance with Frior to the NRC inspection, the Ebasco Quality The combination of the reviews ,

I. ire Doc e =eion NBC requirements for El Assurance Installation Records Group had reviewed described has provided assurance instrumentation the ASME Section III portions of the M1 instrument that documentation is available to installations. installations. Full documentation on the assure the quality installation of installations under the scope of this review is 'all N1 instruments, available.

The scope of this concern has been narrowed to 12' .

installations, 4 welded and 8 threaded. The documentation on the ANSI B31.1 portions of these instrument installations that were installed with class breaks (i.e. ASME Section III to ANSI B31.1) has also,now been reviewed and is summarized as ..

follows: ,

1. Final visual inspection documentation is now available.

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% 2. Ten installations have documented hydrostatic y

tests. The remaining two are HVAC welded connections and do not require hydrostatic testing.

3. Material traceability to the point of install-scion is not available, however, certificates of Conformance to specification requirements are available.

4. Welder identificaticas are not available in all cases. Bovever, all Mercury welders were required by procedure to demonstrate qualifi-cation for the appropriate welding process prior to being issued weldrod.

5. Nondestructive testing data is not required for these installations.

We have considered other design changes related to the classification of N1 instrument loops and have concluded that a similar situation has not occurred.

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. PROGRAM FtAN .

ISSUs & TIT!.E DgSCRIPTION OF ISSUE LP&L APPROACE TO RgSOLUTION CURRENT ASSESSMENT

3. Instruesatation Correct separation NCR-w3-7702 covers the systen 52A problems Although separation violations have .

gapassion Loop criteria violations and has been dispositioned to reauve the been found, none so far identified Separation found in systen 52A acd expansion loops in question and replace with would affect plant safety had they provide a program for straight tubing. been left uncorrected.

review of other safety-related systems for -NCR-W3-7730 was generated to track the generic This provides a high level of

. . separation violations- concern of tubing separation. In order to provide confidence that other design and take the necessary a basis for determining the scope of our approach, considerations and walkdcwns (i.e.

, corrective actions. a sample of 45 additional tastruent installatimes pipe rupture / jet impingement was reinspected. Those chosea were in coat = *ad analysis, non-seismic over seismic areas where separation viciaria== - 1A have the criteria and walkdowns) in highest probability of occurrence. Thirteen combination with the tubing

deficiencies were found out cf 276 locations, separation criteria have provided 4 $g and were evaluated. None required rework. adequate protection for the -

• f A QC verification of all other lines instrument installations. ' ';

(approximately 64) with red ==d- e cabing ruas in A final determination of safety proximity of each other will be performed. significance will be made upon com-pletion of the reinspection.

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d PROGRAN PLAN- .

i ISSUE & TITLE BESCRIPTION OF ISSUE LP&L APPROACH TO RR$0LUTION CURREAT ASSRSSMENT l

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4. Lower Tier corrective LP&L shall revies all LP&L has to date reviewed all FCRs, DCNs, IDNs and The current review has demonstrated .

l Actions Are Not Seing PCRs, DCNs, EDue, and Tompkins-Beckwith DNs cited by the NRC in the , that there has been adequate Q&/QC Upgraded to NCRs 7-5 Due to assure that . Description of Concern, as well as all voided EDNs. involvement in all lower tier proper corrective documents with regard to 10CFR50, j action was taken. LP&L's review has established that only two of the Appendix 5 corrective action and including an adequate fourteen cited FCRs/DCNs and three of the 22 cited non-conformance requirements. This tuview by QA. This EDNs and T-B DNs should have required an NCR. involvement ensures that appropriate corrective action shall In each case however, there uns no safety signifi- corrective actions, specific and include the steps cance as regards 10CFR50.55e and 10CFR21. None of generic, are identified.

i i required by 10CFR50, the voided EDNs required an NCR that was not i Appendix B Criterion generated. Our current evaluation of the XVI Corrective Action examples of lower tier documents

& and for Construction The reopense to this concern will provide an cited by the NRC demonstrates that

• F Deficiency Reporting, , assessment of the lower tier document Teporting although a small percentage should

, SS.55(e). Also, system. It will verify that it was structured in have been upgraded to NCR's under

$mcInded in this review such a manner that procedures, integral to the the quality program in effect, nome shall be the Quality Program, provided a sound basis for had safety significance.

asamination of improper decisions regarding the severity level of documents vM dtne of all other used to report deficiencies. The assessment Thus, LP&L has confidence that the

, design changes or specifically considers QA and QC reviews of sample review will provide discrepancy notices engineering / construction judgements on deficiencies additional evidence that the that affected safety- as it relates to the a rrective action and noncon- projects' system of " checks &'

related systems or that formance requirements of 10 CFR 50 Appendix B balances" ensures that, despite j unre mioclassified as and the reporting requirements of 10 CFR 50.55(e). isolated cases of judgemental or j safety. interparative errors, all lower tier i A random sample of approximately 700 FCRs, DCNs, documents, as well as FCRs and DCNs EDNs and T-B DNs will be formally reviewed.to receive adequate evaluation for determine if any should in fact have been reported safety significar.co.

as NCRs. Any so judged will then be reviewed for reportability under 10CFR50.55e and 10CFR21.

1 The results of this review will dictate whether there is a need to expand the sample size.

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PROCRAM Pt.nli .

ISSUE & TITLE DESCRIPTIutt OF ISSUE 1.P&L APPROACH TO RESOLUTION GRRENT ASSESSIENT

5. Vendor Documentation The concern relates to Records associated with CE material and equipment The existence of Conditionsi .

Conditional Releases whether shortcomings in were re-reviewed and Conditional Certifications Certifications on M equipment contractor's identified. An assessment of the potential for reflected incomplete Purchase documentation, the existence of other manufacturing open items Orders, not harduare or software particularly Combustion not being tracked in the Master Tracking System deficiencies.

Engineering's, which (MTS) was conducted. It led to the conclusion existed at the time the that the potential for a similar situation existed No items of safety significance have material was supplied have only in areas where problems are identified off- been found thus far on the other been corrected, site relating to material to be shipped to the three areas of concern.

site. As a result of this concern the following

%g areas are being evaluated:

Concerns noted by vendor QA P.eps on Release for -

shipment forms. -

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NCRs controlled by Ebasco's Home Office Material received at the site under mannfacture, deliver and erect type contracts. _

To date 8 of 14 CE Conditional Certifications have been thanged to unconditional. The remaining 6 vill have Unconditional Certifications by 9/15/84.

The issues that required resolution deal with tech-nical manuals and have no effect on equipment operation.

The review conducted on the other three areas of potential concern is nearing completion. .

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ISSUE & TITLE BERERIPTIS W ISSUR Ly&L AppBGAG 10 RESOLUTION CURRRIrf ASSESSIWlf

6. Dispositioning of Sems Ebesce and Mercury First, the in-place program for headling of lower Non-conformance and NCRs and shameo Dea were To date mone of the potentially tier documsats such as DRs will be discussed. . deficient NCRs that have been Discrepancy Reports F ia==hly dispositiamed and IML reviewed and evaluated have safety Second, the specific NCRs and DRs cited by the NRC . significance.

shall propose a program - have been evaluated for proper designation, to assure all NCRs and disposition, and implemestation of corrective action .A final determination of safety Nas are appropriately mader the existias quality program. Six of the significance will be made upon

=myrad=J, adequately fifty NCBs were determined to not have been kf caegletica of the evaluations of dispositioned and adequately dispositioned and are under evaluation. potentially deficient NCRs and the corrective action completed and that any Third, a program review of Ibasco NCRs was started field verification.

proh3ams detected are by LP&L in January,1984 to assess the validity of earraerad. the dis' position, the corrective action rah ==, the -

completeness of the decisnestation, and their proper ";

closure. Approximately 460(6Z) of the more than 7700 NCRs reviewed have been identified as having potential deficiencies in the above attributes.

These are being evaluated. The deficiencias that have thus far been evaluated have no safety significance.

Fourth, a field verification will be conducted ca a random semple of 122 (over 25Z) of the potentially deficient Ebasco NCRs to ensure that the hardware and/or software :orrective action has been completed.

Finally, the Mercury NCR's and Ebasco DR's cited by the NEC have been reviewed against the attributes mentioned in the concern. Information from this review is currently being evaluated.

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• PROGRAN M .

ISWE & TITLE DESCRIPTION OF ISSUE LP&L AFFRDACE TO RESOLUTICW CURR E T ASSESSH M T

7. Backfill Soil Conduct a review of all A review of backfill records (i.e. backfill soil The soil density is in compliance .

Densities . soil packages for density laboratory test data and ingyection with specification requiremmats.

completeness and reports) was initiated to determias completeness technical M . y. and technical adequacy. A three stage program for there records are the evaluation of soil backfill densities was missing or technical implemented to (a) locate all backfill soil data.

problems are defined. (b) review the test records for completeness and take corrective action. utilize these for the construction of relative density overlay plots, and (c) evaluate documentation and overlays for compliance with g specification requirements.

It was determined that a compaete set of soils .

test data exists at the site, and that the field .-

'and laboratory testing and insitu relative density ~7 of the class A backfill were in compliance with specification requirements. ,

A review for completeness of the rematader of the soil package data for attributes other than density, which includes all inspection reports, is presently being performed.

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ISSCE & TITLE DESCRIPTICII OF ISSUE I.P&I, APPROACM TO RESourrION CURRENT ASSESSMENT

8. Visual Examination Document inspections Shop welds were inspected and accepted during Mo deficiency exists.

of Shop Welds during of shop welds during hydrostatic taats by an Anthertsed h lmar Hydrostatic Testing hydro tests or other- Inspector.

wise verify such inspection. The ASIE N-5 code data reports also esafirasd that there was laspectise of shop welds.

The methodology of the field hydrostatic tests provided additional assurance that shop welds were inspected.

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d PROGRAN F u N ISSUE & TITLE DESCRIPTION OF ISSUE 1.P&L APP 90ACM TO RESOLUTTON CURRENT ASSESSMENT

9. Helder certification Locate missing documents NCE W3-7549 was generated on 2/1/84 to reack this All welding evaluated to date has for instrument cabinet problem. No documentation was found on three of been found acceptable. A final

• welds and determine if the eighteen cabinets and partial documentation determination of safety significance welders were appro- found on four. All seven were reinspected and will be made upon completion of the priately certified. found acceptable after evaluation by Engineering. review.

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 ,

%g documentation cannot- miscellaneous cases where J.A. Jones performed 4

eF' welding. Documentation for the welding identified be located.

will be reviewed.

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i l TSSUE & TITLE D.'.SCRTFTION OF ISSUE LF&L APPROACE TO RESOLUTTON CURRENT ASSESSMENT

10. Inspector Quali- Verify the proper certi- A verification program has been established to To Be Determined -

fication (J. A. fication of QA/QC review the professional credentials of 100% of the Jones and Fegles) personnel and evaluate site QA/QC persammel for J.A. Jones and Fagles. in-the impact of any cluding supervisors and managers. Critaria for deficiencies found. certification or qualification of QA/QC personnel '

will be based om QA program requiremmats and contractual commitammte. ,

% The adequacy of credentials to support f -- certifications and qualifications is being reviewed. Criteria beve been established to mort personnel files into 3 groups:

A. Qualifications deemed adequate .. '

5. Inadequata Joc===*1aa to perform evaluation

- C. Qualifications questionable Other site files will than be researched, and J.A.

Jones and Teglas coar e*=d for pernammel in arcups B and C to verify their acceptability. In

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addition. background investigations will be performed for a sample of pereceael ta all groups.

If certification of an individami casmot be justified, he will be placed in a fourth group designated group D (Qualification inadequate).

Appropriate site noncomformance dociminatatica vill be initiated to document evaluation of safety significance and corrective actions, including reinspection of work performed as necessary, e

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- PROGRAN P1.AW ,

ISSCE & TTTLE EgSCRIFTION OF ISSUE LP&L AFFROACE TO RF W1.UTION CURRENT ASSESSMENT

11. Caduelding Previde the cadweld The cadweld records have been transcribed onto Based on the previous disposition of data for the project in computer data storage. This includes the placement NCR W3-6234. there is no reason to such a form that it can area, cadueld number, cadwelder, bar size. bar anticipate any significant be readily compared to position. visual test. production test, sister deficiency. +

the testing critatia test. cadwelder qualification dates and used for the Esterford inspector name and qualification dates.

3 project with data broken deva by various In this fora the cadweld data can be called up by

1. categories. Provide any of these attributes to expedite review for c)g

, data on welder quali- specification compliance or other reason. Also.

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ficacias and requali-fication including physical location of cadwelds may then be readily obtained by reference to the concrete placement dates. lift diagrams which locate the placements. ..

Prior reviews have already been accomplished ~ ~ ~ -~

under NCR W3-6234 (opened 5/16/83) and nonconforming conditions resolved. A re-evaluation is being conducted now that the cadweld data is in a more systematic, auditable format.

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ISSUE 4 TTT1.E MSCRIPTION OF ISSUE I.P&L APPenars TO RESOLUTION CURRENT AgSESSIBIT -

12. Main Steamline 6 place the document- SCD 78 was resolved and subsequently reopened upon All corrective action has bass .

Framing Restraints n ica for all discovery that inspections in the steam generator coe leted in accordance with the connections in the framing were not complete. WCR-W3-7736 was issued to criteria stated in the SCD 78 steam generator framing. track resolution of the deficiency. A 100% QC Doc ====rar W Package.

, , reinspection of steam generator framing connections as well as a review of the American Bridge work-scope against the scope of SCD 78 reinspections was '

s performed.

• This verified that only steam generator framing connections were omitted from the original scope of SCD 78. All corrective action has been completed. .

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ISSUE & TITLE DESCRIPTION OF ISSUE LP&L AFF30 ACE TO RESOLUTION CURRENT ASSESSMENT

13. Missing NCRs LP&L shall obtain The caecera specifically stated that there were 10- As a result of tr.e raview all NCRs the missing NCR's. NCR numbers missing from the QA vault and card not on file in the QA vault were explain why these NCR's indes file. This is correct and is due to the fact either found. located or probably not were not maintained in that all of these NCRs were voided or cancelled issued, the filing system, review prior to issuance as indicated in the manual log them for proper voiding. that was maintained at that tias. The purpose of the and assure that when as card index file is to locate NCRs which are actually issue is raised to an om file in the vault, not those that were voided or NCR. it is properly filed never issued.

for tracking and elseure.

However in response to the NRC's general statement that "Others were also noted to be missing from the Ibasco Q& Vault". LFEL has: , , ,

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• Reviamed for accountability all Ebasco Site and New York Office issued closed or voided NCRs for accountability (8200 total NCRs).

'Provided substantiating evidence on those NCRs indicated as void in the logs.

'Provided substantiating evidence that NCR numbers in the sequence indicated not to have been assigned to an NCR is correct.

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C FROGRME M -

ISSUE a TITLE - DESCRIPTIGE OF ISSUE LP&L AFF90Am 10 reg 0LUTION CURRENT ASgEgSENT

14. J. A. Joams Speed' During the Eb w QA First, a review has been conducted of corres;- '-- - No problems of safety significance 1etters and EIRs review of J. A. Jones between J. A. Jones and Ebasco via Speed letters and were found la the J.A. Jones .

speed letters and eag- E!Rs. Second, correapa-aaaea which conveyed design correspondence. The review of other contractors is nearing complettaa and inseriap information changes to J. A. Jones without reference to requeste, several items follow-up actica to formalise the changes was no problems of safety significance that could affect plant conducted to determine safety significance. ' have been found to date.

safety were acted. ,

Based on its sample of- Of approximately 1100 J.A. Jones documsats reviewed. -

these actions, the staff 271 appear to convey design changes. These 271 have does not expect that any been evalosted and researched ca a case-by-case of these items will basis and determined to be acceptable as is even-significantly affect though ,they represent a procedure violation. No plant safety, safety problems have been identified.*

Nevertheless, the app-licant should complete Third, a minimum of 101 of engineering information the actions identified requests generated by other safety-related

$g in these reviews and contractors was sampled to determine if they used issues raised shall be design changes conveyed by such informal documents.

resolved promptly. The sample size was espanded depending on the results of the initial review.

Fourth, any design changes identified are being reviewed for safety significance.

The initial review of the other safety related contractors has been completed. No safety related problems have been identified to date. -

Additional sampling is being performed on three contractors.

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l ISSUE & TITLE DESCRIPTION OF ISSUE 1. pal' AppeNW 70 RESOTETI0It g #~ frp1 TENT ASSFSM

15. WeUtag of "D" level 'locatethedocumentabp The CB4I QA manual requirements for documentation Preliminary results from the ongoing Material Inside 4.'fi,r "D" 1avel materts: _

of fit-ep and final us1d inspections do not apply, inspection indicate'that the "D"

• per their amaual. to "D" material vens. This 7 Containant ' welding and. verify the - materetal welds are acceptable. A *

, I~ ,m auleguacy of ".he / f.ocumentatica is;ghsrefore not available for all fiaal determination of safety ' - '  !

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1.sformation or perform a _ "D" material s.41ds.x _ significance will be made upon material analysis and I' 'fy ~ completion of the reinspection.

NDE work. or rework The "D" material we16 were performed by the the welds. same welders and taspected by the same welding . ,

supervisors and to the same standards as the / 9' rest of the C341 work for which documentation is provided. Considering this, and the quality of CBSI work on this project. it is not expected that any quality problem exists with "D" material g

welds. IPAL will, however, in accord nce with ,

g a formal QA procedure: '

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• Strip paint off of a 51 sample of "D" material i

welds for which no documentation is available -

and provide full visual inspection.

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• Reinspect another 51 sample of "D" material welds without attipping paint.

.' The results of this reinspection wf31 determine

_ e if there is a need to expand the sample size.

- c l To address the NRC's specific concerns. Ebasco has * . '

l evalteted the containment spray piping weld -

, , '; attachments. All containment spray piping weld ,

attachments were installed and documented by '

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Tompkins-seckwith except for twn. The results w ,

far demonstrate that failure of these two welds

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, will not precluda the piping tros performing its design basis function. Ebasco is presently finalizing the analysis by redistributing the lands to other supports under the assumption that the two "D" level attachments do not exist.

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ISSUE a TITLE 3est2IFrie Op 138Us Lyst Appsoa m 10 RESOLUTION CURSerr ASSESSMENT

16. Surveys and Exit IML ehould develop and Lp6L has secured the services of Quality Technology - Reviews to date have not identified Intervious of qa implament a formal program Company (QtC) to implemmat an enhanced program to safety conceras act already personnel for h w itag 1samme raised conduct emit interviews of persommel departing the identified.

by individuale. One of ette. QTC will also review the interviews conducted the fivut tasks to be to date to assess whether the corrective actions dealt with by the program for the concerns identified thereos are should be the review of appropriate. procedures have been approved ubich the t v previously assure -ag-r. involvement. ,

provided to the Q& survey and during the exit intervious.

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PROGRAM PI4N < *

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ISSUE & TITLE  % DESCRIPTION OF ISSUE

• LP&L APPRoacB to RESotJTION CURRENT ASSESSENT

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' 17.. QC Verification of, \'. N NRCdis concerned 3 The review of this matter indicates that six of the . h review of Mercury @ records hj\.t*h: f . Expansion Anchor whether there was -

. sufficisat QC verifica-esven cited QC reviews were made as required by the

, drawings which were refersaced on the inspectica conducted by Ebaece prior to 174L -

LCharacteristics  % turnover.' the resultaat field

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% tionN f the,{haracter- forms. This was substantiated by a thorough review verifications, and.the directions l' '

Qa;

>J ef Mercury quality recorda. LP&L will prepare a provided by the docummats referenced j ',; ,*f istics ascessary'cy. , 3 ensure proge ir.atalls-Q~ '~ response discussing the incorporation of drawings . in the Nercury Nwpamaton Anchor g tion of concrete . into the procedure, training of Mercury personnel, a , Frocedure provide assurance that QC expansion anchors d*. the QC review and substantiation of records and < verificaria= ps ' ; --a.

,T installed by Mercury. y evaluation of the cause of the problem, h N. '

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_ this procedute is no, longer in use et.the site.

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PROGRAll F W

• ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APF904CN TO RESOLUTION CURRENT ASSESSlet?

18. Documentation of Documentation should be Docu===ratian attasting to the scope, conduct and . The design and construction of W ikdowns of Non- provided that clearly results of the unikdawns will be provided. Waterford-3 considered interactions Safety Related shows what equipme.t was of non-seismic Mechanical.

4 Equipment reviewed during the The rav= to this issue will also establish that Electrical. EVAC. Civil and walkdowns and on what in our opinion, the design and installation Instrumentation equipment with

, bases it was concluded adequately considered the effects of interactions of safety-related equipment.

that the installation non-seismic with safety-related systems during an ,

was acceptable. SSE. The walkdous verified that such interactions do not constitute a safety concern.

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PROGRAN PLAN ISSUs & TITLs DgSCRIFFIS OF ISSUg' 'LFSL APpROACE TO RgSOLUTION' CURssNT ASSgSSIENT

19. Water in Basemat Review all conduit thae, A walkdous was performed which identified 28 places There was never a path for ground Instrumentation penetrates the basemat where wetness due to seepage from conduits was found water to flow in sufficient quantity Conduit. and terminates above the and 12 places where evidence of past leaking from to flood the muziliary building top of the basemat to conduits was found. Neither the present slow basement. even before the amm1m were

-assure that these seepage thru some of the seals nor the seepage that .

installed and before the temporary potential direct access would result from a gross failure of the seals conduits were grooted. The floor paths o2 water are presents a flooding hasard. The decision to replace erain and sump. pump system was more properly sealed. the seals will be based strictly on operational and than adequate to handle the quantity maintensace considerations. Any replacement seals . of water which entered the building

. will consist of a light density silicone elastomer during construction, and is adequate which has the capability to stop the seepage. to handle the auch reduced quantity presently observed. ' '>

Tempors'ry conduits which enter the basemat from ,

outside, and which once allowed passage of ground -;

water in quantities that required periodic pumping, have now all been pressure grooted and their

% t g rary blockout pits filled with concrete and no -

S longer serve as a leak path for ground water.

Two piesometers still in use utilise one riser which will be sealed with a light density silicone elastomer. The standpipe of one piezameter no longer in use will be pressure grouted.

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PROGRAN FIAN TSSUE & TITLE DESCRIPTION OF ISSUE LP&L APPRQAG TO RESOLUTION CURRFET ASSESSMINT

20. Construction Verify the proper Gao has been contacted to assist in providing The initial evaluation of this Materials Testing certification of coast- additiceal hackground information or justification concern indicated "no safety (CNI) Personnel ruction materials testing for certification of QA/QC personnel identified significance" based on evaluation of Qualification personnel, as part of NCE MG-F7-116. nonconformance report N3-F7-116. We Records. are again reviewing the A verification program has been established to qualifications of QA/QC personnel on review the professional credentials of 100% of the the nonconformance report and others GB0 CMI ante Q&/qC personnel, including supervisors to recorAira our initial evaluation.

and managers. Criteria for certification or qualification of QA/QC personnel will be based on QA program requirements and CEO's contractual requirassacs.

The i ,_:y of credentials to support -m certifications and qualifications is being reviewed.

. Criteria has been established to sort personnel -

files into 3 groups.

A. Qualifications deemed adequate.

p%s 3. Inadequate d - atation to perform evaluation.

C. Qualifications questionable Other site files will then be researched, and CEO contacted for personnel in groups B and C to verify their acceptability. In addition, background investigations will be performed for a sample of personnel in all groups. If certification of an individual can not be justified, he will be placed in a fourth group designated Group D (Qualification inadequate). Appropriate site nonconformance documentarian will be initiated to document evaluation of safety significance and corrective actions, including reinspection of work performed as necessary.

For CEO QC Inspectors remaining on site. a reverification is being completed of proper certification in accordance with ANSI-N45.2.6-1973.

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. PROGRAM PIAN .

ISSUE & TITLE DESCRIPTI(Bi OF ISSUE LP&L APPROACII 10 RESOLUTIOtt CURRENT ASSESSMENT

21. USL Construction A concern exists over A review of transfer correspondence on the A review of 100% of .

System Status and whether construction systems which were the cause of this concern turnover / transfer correspondence Transfer Reviews. deficiencies were has been performed. A review has also been showed no additional correspondence properly closed out. conducted to verify that deficiencies in was outstanding beyond that or identified during transferred systems had no impact on testing. previously identified. Deficiencies the process of identified on the outstanding i transferring systcas_ A review was also conducted of hardware and soft- correspondence (13 SUS) have been from construction to were commento generated during status and trans- reviewed by LP&L start-up/

plant operations. for of safety-related systems. operations and it was determined that there was no impact on testing.

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PROGRAM PtAN ,. ,

TSSUE & TITI.E DESCRIPT10tt OF ISSUE LP&L APPROACE TO RESOLUTION CURRENT ASSESSIENT

22. Welder Qualification Verify welder qualif- The welder documentation is available which All velders were found to be properly *

'(Mercury) and Filler cations or assure the demonstrates that the velders were properly! qualified. NCR-W3-7724 addressed and Material Control quality of all welds. qualified. ~ resolved qualification sheet errors (Site Wide) for 3 welders (clerical errors which Provide engineering just- 'The response p rises the site requirements for- were committed after the velders left i ification for the allow- hand 1Lg of welding electrodes and demonstrates that site),

ance of "rebake" temper- ASME code requirements are met; and that AWS Dl.1 atures and holding times. code requirements, through a documented deviation to . Code requirements for receiving that differ from the the holding oven temperature, are also met, shipping, storage and issuing and requirements of the ASME cootsol of welding electrodes were

, and AWS Codes. met.

4 The only deviation from explicit code requirements was a documented _..j reduction in specified holding oven A temperatures.

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PROGR#38 PLAN ISSUE 4 TITLE DESCRIPTION OF ISSUE LPSL APPROACH TO RESOLUTTON CURRENT ASSYSSMENT

23. QA Program Breakdown LP&L shall provide an First. LPSL is conducting a thorough review of the To date the specific issues involva between Ebasco and ussessment of the overall corrective actions associated with the 1982 NRC inadequate or inconeistent closure Mercury. QA program and determine enforcement actions and civil penalty to determine. documentation, and not hardware cause of the breakdown. the adequacy of follow-up related to corrective impacting concerns. Thus far the j together with cervective action commitments. review indicates thet there are no.

j action to prevent open items affecting plant safety.

I recurrence. This overall Second. LP&L is conducting a thorough review of its assessment is necessary QA audit program which has been in ef fect since July to provide assurance that 1982. Particular attention will be placed on audits the QA program can related to Mercury activities. This review will fusction adequately when include an evaluation of the methods used for the plant proceeds into determining cause of identified problems and the operation, systems used to assure effective follow-up and ,,

continued compliacca with corrective action 4

g cosmitynts.

Third. LP&L is performing an overall assessment of the LP&L QA construction program based on the results of the above reviews to identify lessons learned and to determine if any improvements are required to assure adequacy of future operational QA program activities.

The above actions are ongoing. Based on efforts to date, it is believed that LP&L can demonstrate that the extensive management and quality. assurance actions taken by LP&L. Ebasco and Mercury sub-sequent to June.1982, were appropriate; that most of the probletas identified were part of the corrective actions on work previously done and are not indicative of continued inferior performance; and that the partial program breakdown did not persist.

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l OUISIANA m . .o .ox r-P O *N E R & LI G H T ! wwoazma m-m n=rr mso e um MIOOLE SOUTH UTruTIES SYSTEM

.l.M. CAIN June 20,1984 President and Chief Execut/ve C///cer 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 Nuclear 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 'Jumphries: -

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 sufficient 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.

9 The adequacy of responses and resolurions (including validation of data and sources, as cypropriate) of the matters set out in the NRC letter.

, pre-Licensing issue Assessment Fage 2 Task Force Chartar Juna 20, 1984 9 The safety significance of the matters listed in the NRC letter with respect to:

- Fuel load and testing up to 5% power

- Operation above 5Z power ,

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

O 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 Torce is te.have access to and interface with all necessary elements of the hterford ' staff but is to report directly to me. -

President &

Chief Executive Officer (LP&L)

(J. Cain)

Task Force T'

Senior Vice Bresident - !

Nuclear Operations (LP&L)

(M. Leddick)

E

. . , . l Safety Review

__________ Committee l .

l .l l Quality Assurance --- Project Manager (LP&L)-- -Plant Manager (LP&L)

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

(T. Garrets).

l l__ ______________i _ _

8 Ebasco & Staff LP&L & Staff Reporting Interface l- Very tru y yours, 7

l.

I J.M. Cain JMC:DED:ph cc: - G. Charnof f, R.S. Leddick, D.E. Dobson I

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