ML20094A448
| ML20094A448 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/02/1984 |
| From: | Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Johnson W, Kohl C, Wilber H NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#484-915 OL, NUDOCS 8411060423 | |
| Download: ML20094A448 (104) | |
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Christine N. Kohl W. Reed Johnson Administrative Judge Administrative Judge Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Cortmission Washington, D.C. 20555 Washington, D.C. 20555 Howard A. Wilber Administrative Judge Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Louisiana Power & Light Company (Waterford Steam Electric Statipn, Unit 3)
Docket No. 50-382O( ,
Dear Administrative Judges:
On October 29, 1984 I submitted to you and the parties in-formation related to the basemat issue and stated that additional information would be submitted to the staff on October 31. En-closed for your information is LP&L's October 31 response to 8411060423 841102 PDRADOCK05000g G
9503 .
1 J SHAw, PITTMAN. PoTTs & TROWZRIDGE !
A DAmTwtasMip OF NESSIONAL CORPOmATIONS Administrative Judges Page Two November 11, 1984 .
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Issues 10 and 20 of the staff's June 13, 1984 letter relating to the qualifications of inspectors and test personnel for concrete ,
and soil backfill. Also enclosed is an October 31 letter to the '
staff which confirms the plant's readiness for fuel loading.
That letter includes in its Attachment A information relating to Issues 10 and 20.
Sincerely yours, b
Bruce 1. _hurchill Counsel for Applicant Enclosures cc: Sherwin E. Turk, Esq.
Carole H. Burstein, Esq.
NRC Docketing and Service Section(3)
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, RESPONSE ITEM.50.: 10 TITLE: Inspector Oualification '(J. A. Jones and Fegles)
.NRC DESCRIPTION OF CONCERN: -
The NRC staff reviewed the qualification and certificaticns of QC inspectors.in the civil /st ructural area. The review included the qualifications of four Ebasco inspectors, five J.A. Jones inspectors, and eight Fagles inspectors. The inspector qualifications were compared against the requireecnts of ANSI N45.2.6 and the contractor's procedures.
The staff found that four of the five J.A. Jones. inspectors and two of the eight Fegles inspectors failed to meet the applicable certification requirements related to relevant experience. Since these inspectors were involved in the inspection of safety-related activities, the fact that they may not have been qualified to perform such inspections, renders the quality 1 of the inspected construction activities as indeterminant.
LP&L shafl review all inspector qualifications and certifications for J.A. Jones and Fegles against the project requirements and provide the information in such a form that each requirement is clearly shown to have been met by each inspector. If an inspector is found to not meet the qualification requirements, the licensee shall then review the records to determine the . inspections made by the unqualified individuals and provide a statement on the impact of the deficiencies noted on the safety of the project.
DISCUSSION:
A verification program was implemented to review the professional credentials of 100% of the site QA/QC personnel who may have performed safety-related functions at Waterford 3, including supervisers, managers and remaining QA/QC personnel.
The responses to Issues No. I and 20 discuss inspecter qualifications for Waterford 3 contractors other than J.A. Jones and Fegles.
The program, which is being performed under the overall direction of LP&L, consists of three major elements:
o Collection and verification of personnel data.
- o Evaluation of qualifications against specified standards.
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( o Dispositioning of deficiencies resulting from cases where inspections L and tests were conducted by personnel whose qualifications against the appropriate standards ceuld not be confirmed.
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~ Collection and Verification of Personnel-Data
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Personnel Idata were collected from - various sources , . including - site . files, contractor home office files, personal contact with individuals or supervisors and through a background verification program.
Efforts were made to verify the education and work experience of 100% of the J.A. Jones and Fegles QA/QC_ personnel by researching Waterford 3 contractor records and by contacting schools, former employers and others. The background verification effort for J.A. Jones and Fegles personnel was a joint LP&L/Ebasco effort. While the success rate of this' effort was good, there were cases where.
confirmatory information was not obtainable. In such cases, the judgement of the LP&L Review Board, as described below, was used to rule en the reliability of the available information.
Evaluation of Oualifications to Specified Standards QA/QC personnel data were evaluated in order to classify individuals as either having verified qualifigations or not.- Training, education and work experience were the qualifications of primary concern. These qualifications were verified against the follcwing griteria:
(1) Inspectors - ANSI N45.2.6-1973 ,
(2) Other QA/QC Personnel - QA Program requirements Initial qualification determinations for J.A. Jones and Fegles QA/QC personnel were performed first by Ebasco and then separately by an LP&L review group.
In order to control the consistency of these determinations, approved procedures were utilized. Determinations related primarily to balancing education, experience and training factors.
The LP&L review group qualification determinations were rendered in two 4
categories: " qualified" and "potentially not qualified"._ "Potentially not qualified" determinations were referred to an LP&L Review Board comprised of, senior LPSL QA personnel. The Review Board determinations were further reviewed by a contracted individual very familiar with inspector qualification and related standards. This process resulted in a final determination for all QA/QC personnel as either " qualified", or " unqualified".
The qualification review process is described in QASP 19.12 and QAI-32. The l following points further clarify the process:
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- 1. The meaning of the term " unqualified" must be amplified. In some cases determinations were made that, based on verified data, i individuals' backgrounds did not warrant qualification to ANSI l N45.2.6-1973. In other cases, however, individuals were considered l " unqualified" as an expedient in reaching resolution to the concern.
l This occurred in cases in which:
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- a. -Research of records, inquiries to past employers and employees, contact with schools and verification of training received . was either not possible or could not -be' concluded in a reasonable
-period of~ time.
- b. Apparent discrepancies existed between background information provided by some individuals and that obtained in the
- verification process, and resolution could not be achieved on a timely basis. Minor discrepancies- were excused; however, significant discrepancies ~ generally rendered any other significant-but unverified data as suspect.
- 2. In the process used, being judged as " unqualified" to ANSI N45.2.6-1973 did not automatically render the . individual's work as invalid. For example, an - individual may' not have the education and experience qualifications for1 all inspection work, yet _be fully competent through specific training or other means to perform the particular tasks assigned to him, which might have been very simple and repetitive in nature. Such an individual potentially satisfies ANSI requirements, which ultimately require that an individual's qualifications be sufficient to provide reasonable assurance that the
, individual can competently perform a pa::ticular task. Whether or not the individual-is technically qualified, the individual's work can be
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deemed valid.
- 3. During the construction period, sone contractors made undocumented judgements with respect to the need for eye examinations for inspection personnel. Such judgements were based on the level of visual acuity or color perception required to achieve competent inspections. Such judgements were also made as part of the verification program and disposition process and will be documented.
It is noted that such judgements ara specifically suggested in ANSI N45.2.6-1978. This factor was not deemed disqualifying.
Disposition of Deficiencies For J.A. Jones and Fegles, the LP&L Review Board compiled' a list of
" unqualified" inspector personnel, and Corrective Action Requests (CAR) were written to ~ formally track and disposition potential deficiencies. Limited background verification efforts remain for J. A. Jones and Fegles personnel.
Should completion of the verification cause a change in the results, the response will be amended accordingly.
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Included'in. Attachment 1 are the verification program results for J.A. Jones end Fegles. !
For J . A. . Jones, CAR EQAS4-22 identified 25 QC personnel who performed inspections while not meeting the requirements of ANSI M45.2.6-1973. The construction activities inspected by . the identified J. A. Jones personnel with respect to.the Common Foundation Basemat and Engineered Backfill were inspected by qualified Ebasco inspectors. Accordingly, inspection by the J.A. Jones personnel ~does not render the quality of the inspected construction activities -
.as indeterminate. Adequacy of the inspected construction activities was
' independently confirmed .by qualified inspectors. J.A. Jones inspector qualification deficiencies _in areas other than the Common Foundation Basemat and Engineered Backfill will be addressed in a supplemental response.
For Fegles, CAR EQA84-20 identified three QC personnel who performed inspections while not meeting the requirements of ANSI N45.2.6-1973. The three individuals performed preplacement inspections on a limited scope of slip form operations.
Duplicate preplacement inspections were performed by qualified Ebasco QC inspectors. Accordingly, inspection by the Fegles personnel does not render the quality of the inspected construction activities as indeterminate. Adequacy of the inspect 2d construction activities was independently confirmeJ by qualified inspectors.
CAUSE:
ANSI N45. 2.6-1973 allows substitution fo r education and experience levels by noting that "... education and experience requirements specified for the various levels should not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task." J.A. Jones and Fegles, to varying degrees, employed such substitutions in certifying the qualifications of their QA/QC personnel. However, the verification program revealed that verification of background data was not adequate or documented, documentation of the justification for substitution was sometimes not provided or lacked depth, and/or was not always totally in accord with J.A. Jones /Fegles procedures or the ANSI standards, as currently interpreted.
GENERIC UfPLICATIONS:
This issue has been treated generically. In response to this Issue and Issues 1 and 20, the verification program included 100% of the QA/QC personnel of all site contractors who performed safety related work.
! With regard to future work, qualification and certification of inspectors (including NDE personnel) will be administered through strict compliance with LPSL Nuclear Operations Procedures which meet the requirements of Regulatory Guide ~1.58 Rev. 1 (ANSI N45.2.6-1978) and SNT-TC-1A-1975, as applicable.
i SAFETY SIGNIFICANCE:
! Satisfactory disposition of CAR #EQA84-16 (J.A. Jones) and CAR #EQA84-7 (Fegles) will provide adequate assurance that the installations by J. A. Jones and Fegles will perform satisfactorily in service, l
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CORRECTIVE ACTION PLAN / SCHEDULE:
i Corrective achions required to disposition- CAR EQA84 (J. A. Jones) are in
. progress. The CAR EQA84-20 (Fegles) corrective action has been satisfactorily completed as described- in Attachment 1. To ~ date, no ' items of safety significance have been identified. .It is currently anticipated that the
- dispositions of QA/QC personnel qualification - ~ issues will . ~ be completed ' by .
November 21,1984.
ATTACHMENTS:
'1. Results of Verification Program for J.A. Jones and Fogles.
REFERENCES:
- 1. QASP 19.12, Review of Contractor QA/QC Personnel Qualification Verification
-2. QAI-32, Instructions for Verification of QA/QC Personnel Qualifications
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ATTACHMENT 1 A. J.A. JONES
- 1. On-Site Dates: October 1975 to March 1981
- 2. Scope of Work:
- a. -Concrete Construction
- b. Concrate Masonry
- c. -Concrete Reinforcing Steel
- d. Dewatering and Excavation
- e. Waterproofing ,
- f. Waterstops
- g. -Mechanical Splicing af Reinforcing Steel
- h. Filter and Backfill
- 1. Structural Steel
- 3. Scope of Insoections:
.a. Material Receiving Inspection
- b. Site Fabrication Assembly & Installation Inspections
- c. Structural Inspections
- d. Civil Inspections
- 4. QA Program Requirements / Contractual Commitment:
- a. QA/QC Personnel, except Auditors, ANSI N45.2.6 and Manual TR-1,
" Training / Certification Program", Procedure POP-N-505,
" Qualification / Certification of Personnel" and Procedure P0P-N-702, " Personnel Training / Qualification / Certification".
- b. Q.A. Auditors -
ANSI N-45.2.23 and Manual TR-1,
" Training / Certification Program", and Procedure POP-N-505,
" Qualification / Certification of Personnel" and Procedure P0P-N-702, " Personnel Training / Qualification / Certification".
- 5. Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified 25 J.A. Jones personnel who performed inspections and whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973. Corrective Action Request EQA84-22 was initiated to track the disposition of this deficiency.
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h-A review of the work of.the identified J.A. Jones inspectors has been
- completed 'with respect - to the
- Common Foundation -Basemat, including cadwelds.- .This review also included the identification of ,
overinspection performed by qualified Ebasco inspectors who inspected the construction of the Common Foundation Basecat.-
Where an ' inspection activity was1 performed by an identified J.A. Jones inspector, the qualifications of the Ebasco inspector who perforced
_ the overinspection -of the same activity was checked.
In this manner it. was demonstrated that each of the Common Foundation Basemat placements were inspected by one or more qualified inspectors.
The reinforcing bar cadwelds which were inspected by J.A. Jones have '
.also treen addressed in the response to NRC Concern No. 11 for tre entire JPIS. The cadwelds are deemed acceptable.
The structural backfill inspections performed - by J.A. . Jones were overinspected by qualified Ebasco inspectors. In addition, statistical studies were performed which demons,trate the consistency of the work.
The cla= shell Filter Blanket quality was addressed in NCR-W3-5997
_, including addressing. the uncertified J.A. Jones inspectors. The Blanket var found acceptable. ,
Accordingly, inspection by the J.A. Jones personnel does not render the quality of the inspected construction activities as ind! terminate.
Adequacy of the inspected construction activities was independently confirmed by qualified inspectoi;s. J.A. Jones inspector qualification deficiencies in areas other than the Common Foundation Basemat and Engineered Backfill will be addressed in a supplemental response.
Completion of the review of the work of the concrete inspectors on the balance ' of the J.A. Jones construction activities is expected . by November 9. This report will be supplemented at that time to reflect the findings of that review.
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ATTACHMENT 1 B. FEGLES l.. On-Site Dates: December 1975 to August 1976 (Shield Wall)
February 1979 to February 1980 (Dome)
- 2. Scope of Work:
- a. Designing, furnishing, fabricating, erecting and dismantling-slip forns for shield wall construction 'and conventional formwork and supports for dome construction.
- b. Handling, placing and fastening reinforcing' steel.
c.- Detail reinforcing steel for shield wall slip form construction.
'd.- Handling, placing and setting to line and grade all items to be embedded in the shield wall and in the dome.
- e. Forming for blockouts in shield wall, installing waterstop, removing forms-and patching voids or honeycomb 'reas.
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- f. Placing, finishing and curing concrete by the slip form method for the shield vall and the dome by conventional 2 stage construction.
- 3. Scope of Inspections:
- a. . Material receiving inspection
- b. Form erection inspection
- c. Placement area preparation inspection
- d. Concrgte placement inspection
- e. Concrete finishing and curing inspecticn
- f. Concrete repair inspecticn
- g. Dome form decentering inspection
- h. Reinforcing steel placement inspection
- 4. QA Program Recuirements/ Contractual Commitments:
Fegles - Shield Wall Construction: December 1975 to August 1976
- a. QA/QC Personnel except Auditors -
ANSI N45.2.6 and Fegles Procedure QAP-303, " Quality Assurance Plan" and QAP-303 Supplement #2, " Personnel Qualitications".
Fegles - Dome Construction: February 1979 to February 1980
- a. QA/QC Personnel except Auditors -
ANSI N45.2.6 and Fegles Procedure QAP-303.21, " Qualification of Inspection Personnel".
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- 5. Inspector Qualification and Dispositioning of Deficiencies:
The Verification Program identified three Fcgles QC personnel (out of the ' original seven (7) identified on . CAR EQA84-20) who performed quality inspections and whose . qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973. Corrective Action Request EQA84-20 was initiated to track the disposition of this deficiency.
Ebasco QA has- determined that these three Fegles QC personnel were involved ~ only with the slip form operations - (placement series G-Sil) from April to May of 1976. Tha three Fegles QC inspectors only performe preplacement inspections. These inspections were documented on the preplacement ~ checklist. Further research concluded that although these three individuals did . perform inspections, qualified Ebasco 'QC inspectors performed 100% duplicate preplacement inspections.
Accordingly, inspection by the Fegles personnel does not render the quality of the inspected construction activities as indeterminate.
Adequacy ' of the inspected construction activities was independently
- confirmed by qualified inspectors.
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RESPONSE
ITEM NO: 20 TITLE: Construction Materials Testing (CMT) Personnel Qualification Records-NRC DESCRIPTION OF CONCERN:
The . Inquiry Team; ef fort included a review of the disposition of-the generic problem identified during the LP&L Task : Force verification relative - to GEO Construction Testing (GEO) documentation for ' personnel qualifications in' the
, area of CMT.
The utility 3 should- conduct a review of supporting documentation for GE0 corrective action stated in Attachment .6 of NCR ,W3-F7-116' (Ebasco W3-6487).
This review should focus'on the identification of CMT personnel placed . in GEO -
Categories 1, 2, or 3 who were apparently quali_fied solely on written statements
.by other individuals attesting to the individuals training and qualifications.
For such individuals, the applicant should pursue any new information or evaluations which could provide further assurance in support of the actual past work experience and training referenced by the written statements.
DISCUSSION:
As requested by the~ staff, LP&L has pursued and obtained additional information on the GEO individuals performing inspections and tests as will be explained in the sections of this response entitled " Collection. and Verification of Personnel Data" and " Disposition of Deficiencies". Also, evaluations have been --
made of work performed by GEO personnel as briefly outlined herein.
A verification program was implemented to review the professional credentials of 100% of the site QA/QC personnel who may have performed safety-related functions at Waterford 3, including supervisors, managers and remaining QA/QC personnel.
Assessment of the qualifications of all GEO Construction Material Testing (CMT) personnel, including those identified in Attachmant 6 of Ebasco NCR W3-6497 (the NRC reference to Ebasco NCR W3-6487 is apparently a typographical error), was a part of that verification program.
The responses to Issues No. I and 10 discuss inspector qualifications for other.
Waterford 3 contractor personnel.
The program, which is being performed under ' the overall direction of LP&L, consists of three major elements:
o Collection and verification of personnel data, o Evaluation of qualifications against specified standards.
o Dispositioning of deficiencies resulting from cases where inspections, tests or data collection were conducted by personnel whose qualifications against the appropriate standards could not be confirmed.
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I' Coll'ctien end Verificatidn of-Personnel Drta Personnel ' data were collected from various sources, including site files, contractor _home office files, personal contact with individuals oor supervisors and a thorough background verification program.- .
' Efforts were made to verify the education and work experience of 1007. of the GEC-CMT QA/QC personnel by researching Waterford 3 GEO-CMT records and .by.
contacting schools, former employers and others. While the success rate of the
-background verification effort for GEO-CMT was good, there were cases where confirmatory = informatipn was . not obtainable. In such cases, the judgement of the LP&L Review Board, as described below, was used to rule on the reliability of the available information.
Evaluation'of Qualifications to Soecified Standards QA/QC. personnel data were evaluated Lin order to classify individuals as either having verified qualifications or not. Training, education and work experience were the qualifications of primary concern. These qualifications were verified against the following criteria:
(1) Inspectors - ANSI N45.2.6-1973 (2) Other QA/QC Personnel - QA Program requirements-Initial qualification determinations for CEO-CMT personnel were performed first by Ebasco and then separately by an LP&L review group. In order to control'the consistency of these determinations, approved procedures were utilized.
Determinations related primarily to balancing education, experience and training factors.
The LP&L review group qualification determinations were rendered in two categories: " qualified" and "potentially not qualified". "Potentially not qualified" determinations were referred to an LP&L Review Board comprised of senior LP&L QA personnel. The Review Board determinations were further reviewed by a consultant very familiar with inspector qualification and related standards. This process resulted in a final determination for all QA/QC personnel as either " qualified", or " unqualified".
The qualification review process is described in QASP 19.12 and QAI-32. The following points further clarify the process:
- 1. The meaning of the term " unqualified" must be amplified. In some cases ' determinations were made that, based on verified data, individuals' backgrounds did not warrant qualification to ANSI N45.2.6-1973. In other cases, however, individuals were considered
" unqualified" as an expedient in reaching resolution to the concern.
This occurred in cases in which:
- a. Research of records, inquiries to past employers and employees contact with schools and verification of training received was either not possible or could not be concluded in a reasonabla period of time.
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,Q b. Apptr:nt discr:p ncics cxiatcd b0tw;cn b:ckgr;und inf0rmation
-provided by some individuals and that obtained in the verification process, and resolution' could not be achieved on a timely . basis. Minor discrepancies were excused; however,
.significant discrepancie9 generally rendered any other significant but unverified data as suspect.
~ 2. In the process used, being judged as " unqualified" to ANSI 945.2.6-1973 did not automatically render . the individual's work as invalid. For example, an individual may not have the education and experience qualifications for all inspection work, yet - be fully ccmpetent through specific training to perform the particular tasks assigned to him, which might have been very simple and repetitive in nature. 'Such-an individual potentially satisfies ANSI requirements, which ultimately require- that an individual's qualifications be sufficient to provide reasonable assurance that the individual can ccmpetently perform a particular taak. Whether or not the individual is technically qualified, the individual's' work can be deemed valid.
- 3. During the construction period, GE0 made undocumented judgements with respect to the need for eye examinations for inspection personnel.
Such judgements were based on the level of visual acuity or color-perception required to achieve competent inspections. Such judgements were also made as part.of the verification program and disposition
. process and will be documented. It is noted that such judgements are specifically suggested in ANSI N45.2.6-1978. This factor was not deemed disqualifying. ,
- 4. Some individuals were classified as inspectors but performed no safetf' related inspections and were otherwise not involved in quality related work. To the extent such individuals were identified, they were excluded from the overall inspector population.
Disposition of Deficiencies For those individuals found " unqualified" the LP&L review board initiated Corrective Action Request (CAR) EQA84-11 to formally disposition the identified deficiencies. Ebasco NCR-W3-6497 will be reopened to reficct the disposition of that CAR.
Disposition of CAR EQA84-11 was accomplished by 3 methods as follows:
- 1) Assessment of Key CMT tests and of skills required to perform these tests.
The key tests were as follows:
a) Concrete - The most important test is the final cylinder break test as this test serves to confirm the strength of the concreta actually placed in the structure. Other tests on concrete are generally either performed as measures to avoid subsequent replacement of sub-specification concrete or were performed in collecting the concrete for and preparing of the test cylinders.
The break test requires minimal skill in setting up and starting a compression device which compresses' a pre-molded cylinder to failure. A large gauge records the force required which is easily translated into the data required.
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- Further confidence in the quality of the as-built material is provided by.the fact that improper operator action would tend to degrade test results, i.e. . improper testing would - cause the concrete to appear.
less strong than it'actually is.
b) Soils - The most important test is the field density test as it measures whether the backfill material has been compacted to specific requirements. The' field portion of the work, which was performed by the technician, consisted of digging a small hole and placing the -
removed soil in an airtight container, positioning a rubber balloon apparatus over the hole, inflating the balloon to a predetermined ,
pressure and reading a volume indicator scele.
Further, - confidence in the quality of the as-built material is provided by the quantity of tests conducted. As stated in the engineering' . report supporting the response to issue 7, to insure control of backfill placement approximately three times as many field density tests were conducted as required ~ by the technical specifications.
c) Cadwelds - There was only one test on cadwelds conducted by GEO-CMT and that was the break test. This test is as simple as the concrete break test. The test specimens are secured in a tension device,
' tension is applied and the failure strength is read from a gauge and recorded.
- i The review indicates all cadweld tests were egducted by personnel qualified to ANSI 45.2.6 (73)
It has been determined that only minimal training would be required for an unskilled individual to become proficient in performing the above tests. A single demonstration coupled with minimal practice under proper supervision is sufficient. GEO has fornally confirmed that " Prior to being assigned to production work, all personnel were trained to perform the work required." On the basis of the above, though not strictly qualified to ANS1 N45.2.6-1973, individuals could be considered competent to perform the technician or data collection type functions described.
- 2) Ouality of Testing Performed by Personnel in Ouestion A detailed analysis was conducted of inspection / testing performed by a large sample of Level I personnel in question. This sample is felt to include the most significant exposure in terms of potential for inferior inspection / testing. Level II and III personnel either performing or directly supervising the performance of the tests described above should be competent to perform such functions.
20-4
. o I
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- 3. Engineerine Evaluation A statistical analysis was conducted, using industry standard techniques, to evaluate test results for concrete and the class A backfi1* (Reference 3). In the case of concrete both the overall and within-test coefficients of variation demonstrated excellent control of the product which would not be the case had the tests not been well conducted. Backfill test results also demonstrate good consistency. This evaluation verifies the overall adequacy of the work of all levels, Levels (I, 11 and III) of GEO-CMT QC personnel.
As stated before, all cadweld tests were conducted by personnel cor.sidered qualified.
CAUSE:
Implementation of ANSI N45.2.6-1973 allows substitution for education and experience levels by noting that " ... education and experience requirements specified for the various levels should not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task." CEO and its predecessor organizations issued certifications of qualificctions for testing personnel under successive programs which employed such substitutions and which became more detailed and better documented with time. Th'e program in place since 1978 generally parallels the ANSI Standard for inspector certification. However, the verification program revealed that verification of background data was not adequate or documented, documentation of tne justification for substitution of other factors for the requisite degree of training, education or experience was'sometimes not provided, lacked depth, was not totally in accord with contractor procedures or the ANSI standard, as currently.inte rp re ted.
GENERIC IMPLICATIONS:
This issue has been treated generically. The scope of the verification program included 100% of the QA/QC personnel of all site contractors who may have performed safety-related work, including CE0 CMT personnel.
With regard to future work, qualification and certification of inspectors (including NDE personnel) will be administered through strict compliance with LP&L Nuclear Operations Procedures which meet the requirements of Regulatory Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) and SNT-TC-1A-1975, as applicaole.
SAFETY SIGNIFICANCE:
The results of the verification program and evaluation of the work performed by
" unqualified" GEO CMT personnel provides reasonable assurance that the reisted installations will perform satisfactorily in service. There is no recognized reason that this issue should constrain fuci load or power operation.
20-5
- s_ .
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CORRECTIVE ACTION PLAN /CO'2EDL1Et
~
On the' basis of Reference 3, CAR EQA84-11 has been dispositioned.
REFERENCES:
- 1. QASP 19.12 Review cf Contractor-QA/QC Personnel Qualitication Verification ,
- 2. - QAl-32, Instructions for Verification of .QA/QC Personnel Qualifications.. !
- 3. Engineering Evaluation of Report.on the Review and Analysis of the work of CEO - Construction Material Testing. ,
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Octobcr 31, 1984 J.M. CAIN Presiden' t W3P84-3086
.. 3-A1.01.04 A4.05 Director of Suclear Reactor Regulation ATTN: Mr. Darrell G. Eisenhut Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Co= mission E:shington, D.C. 20555
SUBJECT:
WATERFORD 3 SES REQUEST FOR OPERATI'*G LICENSI .
REFERENCES L) Letter W3A84-0133, J.M. Cain to D.G. Eisenhut, dated October 5, 19S4
- 2) Letter, D.G. Eisechur to J.M. Cain, dated June 13, 1984
- 3) Letter W3BS4-0807, J.M. Cain to D.G. Eisenhut, dated October 31, 1964 -
On October 5, 1984, I submitted a request for authori:stion to load fuel and pcrform pre-criticality hot functional testing, subject to our completion of the pertinent elements of the Licensing Program Plan and other identified activities. This is to inform you that Waterford-3 is physically complete and ready for fuel loading. '
. Responses to all of the 23 issues identified by the NRC in Reference 2 have now been submitted. While the responses to Issues 1, 6 and 10 will be supple-mented in November (see Reference 3), the current status of our resolution ot the issues fully supports issuance of an operating license conditioned to preclude initial criticality until the NRC has fully resolved the 23 issues.
This position represents our desire to confirm LPSL's confidence in the hardware cceeptability to the NRC and the public served by LP&L prior to going critical cnd proceeding with the low power testing and pcwer ascension program. The lack of fission products and decay heat, prior to initial criticality, assure that no significant hazard exists for fuel loading and subsequent pre-criticality testing.
The safety reviews of plant systems against each of the 23 NRC issues described in Reference i have been completed for the systems required by Technical Specifications for Modes 6 through Mode 3 (Fuel Load and Post-core Hot Functional Testing). As presented in Attachment A, only three instances were determined to require a limited safety review. A limited safety review is defined as a
T '
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Mr. Darr d i G. Eisenhutt
-W3P84-3086
'Paga 2'
.I saf0ty review.in which the basis for;the evaluation requires that credit must b3 taken for lack of fission products and decay heat. An additional safety review would be performed prior to initial criticality. In these instances the resolution of the issues were evaluated to be sufficient to proceed with operation
'in Modes 6 through 3. Further resolution would be a prerequisite to removing _ !
-tha limiestion on initial criticality. Attachment'B provides' a summary of the scfGty reviews performed for the systems required by the Technical Specifications for operation in Mode 2 and Mode 1 (initial criticality to full power operation).
Attcchment D of Reference 1 included a listing of licensing commitments, significant ,
.etnatruction deficiencies inspec. tion report open items and fuel load prerequisite cystem completion work items. -These items, with the exception of items listed in Attachment C, have been completed by LP&L or have been judged not to be truly.
prerequisite to fuel load and post-core hot functional testing. These , j udgements ,
which are few in number, have been reviewed with the Resident NRC Inspectors.
An cdditional-area which must be addressed relative to actual fuel load'.is completion of the surveillances required by Technical Specifications prior to cntering Mode 6 (Fuel Load). These surveillances are basically comp 1ste, as- .
- pr0 tented in Attachment C. Completion of prerequisite surveillances for Modes 5,
'4 cud 3 are not expected to impact the performance of post-core hot functional tooting.
Your timely action on this matter is requested. With both the plant and its staff in their current state of readiness, our ability to begin fuel loading and pre-criticality testing in the near term will avoid unnecessary delays in the
- schtdule for achievement of commercial operr. tion.
Sincerely, - .
a& '
J.M. Catn .
JMCsKWC:sms
'Attcchments cc (with Enclosure): R.S. Laddick, D.E. Dobson, K.W. Cook, J.T. Collins (NRC) D. Crutchfield (NRC),'
G. Knighton (NRC), G. Charnoff, L.L. Humphreys, .
R.L.. Ferguson, J. Wilson (NRC), L. Constable (NRC),
Project Files
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-ATTACHMENT A
, SAFETT REVIEWS OF PLANT SYSTEMS REQUIRED BY TECHNICAL SPECIFICATIONS FOR 6
FUEL LOADING AND PRECRITICALITY POST-CORE LOAD HOT FUNCTIONAL ,
TESTING e
1 0
1 I
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. LICENSING PLAN FOR' FUEL LOADING AND PRECRITICALITY POST CORE LOAD HOT FUNCTIONAL TESTING .-
LA Licensing Program Plan has been structured to institute safety reviews of thsse plant systems required for fuel load and post fuel load testing, '
criticality and-low power testing (to 5% power) and full power operation. ,
A detailed review of the technical specifications was performed to
_. dctermine the listing of plant systems required for fuel loading and -
post-core hot functional testing under the limited license (Table A-1).
Forty-nine plant systems have been identified as being required to be opsrable by Waterford SES #3 technical specifications in modes 6,'5, 4, 3 *
(rafueling through hot standby) and these systems.are the subject of this
Attachment (Attachment A). These are the modes involved with fuel load and pre-criticality, post fuel load hot functional testing. This is a conservative approach because many of these requirements assume the *
- prcsonce of irradiated fuel and therefore are not of significance to the initial core loading and testing processes. This program will assure LP&L management that the impact of any concern raised is properly assessed and roco1ved in the context of safe plant operations and protection of the public health and safety as will be specified in our operating license / standard technical specifications and FSAR.
Safety reviews were performed on each of the plant systems in Table A-1,
- egninst each of the 23 issues (Table A-2). Table A-3 provides a complace matrix indicating'those safety reviews which have been successfully ,
completed. Table A-4 provides the footnotes associated with the Table A-3 mrtrix indicating outstanding actions required to complete the matrix. ~
Wh:re successful completion of the safety review is indicated in Table A-3, tha safety review assures completion of those actions necessary to insure tha system is constructed and functions according to the requirements of .
ths FSAR in light of the 23 issues, without consideration of the lack of ficsion products (due to not having gone critical). In' three instances it w:s judged to be necessary to perform limited safety reviews (credit must ,
b3 taken for lack of fission products in order to justify safety significance). The matrix references a footnote describing the circumstances and basis for the limited review for each of the instances.
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A-1
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i During the safety evaluation of these 49 fuel load systems they were i categorized into subgroups that logically represent the potential issue by '
tasue safety tapact. The subgroups are defined in Table A-6 as:
-A. The issue does not have a safety related effect on the system because:
+
a)- the~ contractor in question did not do work on the system under evaluation, or b) the procedure or. process in question did not apply to the system under evaluation. -
B. The issue does not have a safety relatec effect on the system because: !
a) the contractor in question did not do any safety related work on the system under evaluation, or the procedure or process in question did not apply to any safety related portions of the system under evaluation, and b) any non-safety related activities performed on the system of concern does not have any significant effect on the safety related function of the system under evaluation. .
~
C. The issue does have a potential safety related effect on the system because:
a) the contractor in question did work of safety significance on the system under evaluation, or
- b) the procedure or process in question did Apply to safety-significant activities of the system under evaluation.
Safety evaluations were performed and vertfted (as necessary) to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the pubite. The subgroup for each system, as it relates to each of the twenty-three issues, is presented in Table A-6. In performing the evaluations, it was determined'that it would be more effective to subdivide the first' tssue (Inspection Personnel Issues) into three subissues covering 1A - Mercury, 13 - Thompkins-Beckwith and IC - Other Contractors. This resulted in effectively 2:5 issues being evaluated for each of the 49 plant systems. Since this res.ults in a total of 1225 safety reviews '(each consisting of several pages) te is not '
feasible to present all of the documentation in this tr'ansmittal. The full documentation of the safety reviews is on file at the Waterford SES #3 On-stte Licensing Unit offices for inspection and review by the NRC staff.
The individual safety reviews were reviewed and summaries prepared, for those falling within Subgroup C. The summaries are included in ehts attachment (Table A-5) for emph issue and subissue.
l A-2
TABLE A-1 PLANT SYSTEMS REQUIRED BY TECHNICAL SPECIFICATIONS DtiRING FUEL LOADING AND PRE-CRITICAL PUST-CORE LOAD HOT FUNCTIONAL TESTING MODE OPERABILITY ACRONYM SYS. NO. DESCRIPTION IS REQUIRED l
DC 02A 125v DC SAFETY MODE 1-6 MT 03 SWITCHING STATION MODE 1-5 ST 04 STARTUP TRANSFORMERS MODE 1-6 4ky 06A 4.16kv ELEC. DISTRIBUTION MODE 1-6 SAFETY SSD 07A 480v ELEC. DISTRIBUTION SAFETY MODE 1-6 LVD 08A 208/120v ELEC. DISTRIBUTION MODE 1-6 SAFETY ID 09A INVERTERS & DISTRIBUTION MODE 1-6 SAFETY 10 COMMUNICATIONS MODE 1-6 HT 13A-1 HEAT TRACE SAFETY MODE 1-6 EM 16 ENVIRONMENTAL MONITORING ALL MODES SM 17 SEISMIC MONITORING ALL MODES ARM /RMC/ 18-1 RADIATION MONITORING SYST$M ALL MODES PRM 18-2 18-3 18-4 18-5 SS 20 SECURITY SYSTEM
. ALL MODES FPD 21 FIRE DETECTION ALL MODES FP 22 FIRE PROTECTION ALL MODES CC 36-1 COMPONENT COOLING WATER MODE 1-6 36-2 ACC 36-3 AUXILIARY COMPONENT COOLING MODE 1-4 WATER EG 39 EMER0ENCY DIESEL GENERATOR MODE 1-6 CRN 40-2 CRANE & HOIST FHB MODE 6 ONLY CCS 43A RCB CONTAINMENT COOLING MODE 1-4 SEV 43B SHIELD BLDG. VENTILATION MODE 1-4 A-3
v-r . . TABLE A-1 PLANT SYSTEMS REQUIRED BY TECHNICAL SPECIFICATIONS DURING FUEL LOADING AND PRE-CRITICAL POST-CORE LOAD HOT FUNCTIONAL TESTING MODE OPERABILITY ACRONYM SYS, NO. DESCRIPTION IS REQUIRED CVR 43E CONTAINMENT VACUUM RELIEF MODE 1-4 HVC 46B CONTROL ROOM HVAC ALL MODES HVR 46D RAB HVAC MODE 1-6 CHW 46E RAB CHILLED WATER HODE 1-6 FP 46K FIRE DAMPERS ALL MODES CB 48 '
LRT CONTAINMENT VESSEL MODE 1-6 PAC 49 PROCESS ANALOG CONTROL MODE 1-6 IC SOB MISC. PANELS MODE 1-6 RCS 52A REACTOR COOLANT SYSTEM MODE 1-6 52B *
- 52C CVC 53A CHARGING & LETDOWN MODE 1-6 BAM 53B BORIC ACID MAKEUP , MODE 1-6 PSL 54-9 PRIMARY SAMPLING , MODE 1-5 GWM SSA GASEOUS WASTE MANAGEMENT ALL MODES LWM SSB LIQUID & LAUNDRY WASTE ALL MODES SSE MANAGEMENT SI 58 SAFETY INJECTION MODE 1-6 -
60A ,
60B -
60C CS 59 CONTAINMENT SPRAY MODE 1-4 .
~
FHS 61 FUEL HANDLING & STORAGE MODE 6 ONLY .
PPS 66 PLANT PROTECTION SYSTEM ALL MODES 63 ENI 65A-1 EXCOBE NUCLEAR INST. MODE 1-6 65A-2 CMU 71B CONDENSATE MAKEUP MODE 1-3 EFW 73 EMERGENCY FEEDWATER MODE 1-3 l l
A-4 .
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.cf TABLE A-1 1
PLANT SYSTEMS REQUIRED BY TECHNICAL SPECIFICATION 3 DURING
- FUEL LOADING AND PRE-CRITICAL POST-CORE LOAD HOT FUNCTIONAL TESTING 1
MODE OPERABILITY l ACRONYM SYS. NO. DESCRIPTION IS REQUIRED 2 SSL 75 SECONDARY SAMPLING MODE 1-4 SG 76 STEAM GENERATORS & MSIV MODE 1-4 TUR 88 TURBINE & TURBINE CONTROLS MODE 1-3 91 SEISMIC SUPPORTS L MODES 19-16 WHIP RESTRAINTS ALL MODES 19-17' SYSTEM SUPPORTS (HANGERS) ALL MODES SEISMIC STRUCTURES ALL MODES i 6 e
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.~ . TABLE A-?
SAFETY REVIEW ISSUES l 1
l ISSUE NO.
1 (A) Inspection Personnel Issues - Mercury l (B) Inspection Personnel Issues - TSB (C) Inspection Personnel Issues - Other Contractors 2 Missing NT Instrument I.no Documentation I 3 Instrumentation Expanston Loop Separation ..
4 Lower Tier Corrective Acetons are not being Upgraded to NCRs 5 Vendor Documentation - Conditional Releases 6 Dispostetoning of Nonconformance and Discrepancy Reports 7 Backft11 Soil Denstetes 8 Visual Examination of Shop Welds During Hyrdrostatic Testing 9 Welder Certtiteation .
10 Inspector Qualtitcations (J. A. Jones & Fegles) 11 Cadwelding 12 Main Steamitne Framing Restraints 13 Missing NCRs 14 J. A. Jones Speed Letters and EJaa 15 Welding of "D" Level Material Inside Containment 16 Surveys and Exit Interviews of QA Personnel '
17 QC Vertiteation of Expanston Anchor Characteristics 18 Documentation of Walkdowns on Non-Safety Related Equipment ,
19 Water in Basemat Instruments
- 20 Construction Materials Testing (CMT) Personnel Qualtftcation Records 21 LP&L QA Construction ,Sysram Status and Transfer Reviews 22 Welder Qualtiteations (Mercury) and Ft11or Material Control (Site Weld) 23 QA Program Breakdown Between Ebasco and Mercury A-6
___....._..__.___..__..________.__._.1__1_,_..._.__._-.___.m. . . . _ . . . _ . _ _ . , _ . _ . __. m, i
TABLE A-3 . SYSTU6 / NF SAFEIT NEfrIm wtrRIX Indicaces that Tem.13LC. POCC and Plant Lanager review compleceJ.
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- TABLE'A-4 SYSTEMS /1SSUES SAFETY REVIEW RESOLUTION MATRIX:-
- FOOTNOTES NOTE OUTSTANDING ACTIONS "
ISSUE 19 NONE (3) ISSUE 20 LIMITED SAFETY REVIEW. REQUIRES NEW REVIEW PRIOR TO ENTERING MODE 2.
ISSUE 21 NONE ISS,UE 22' NONE ISSUE 23 NONE '
A-13
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- t. . . _ _ _ .- . . . . - . .-- .- - - - - .
Issue #1 - Inspection Personnel Issues This issue was evaluated on a contractor basis.
Issue #1A - Mercury Subgroup C - Mercury did perform safety related work on the system and safecy Gvaluations were performed to assure LP&L management that Waterford Steam Electric Station #3 can be safely operated without compromising the health and safety of the public.
Issue #1 does have a potential effect on:
System # System Description Evaluation 18-3 Radiation Monitoring System Installation of safety related instrumenta-22 Fire Protection tion was inspected by potentially unqualified 36-1 Component Cooling Water inspectors. The quality of safety related instru-36-2 Component Cooling Water mentation associated with this system was verified.
36-3 Aux. Component Cooling Verification was accom-Water plished by reinspection of N1 instrument loops.
39 Emergency Diesel Generator Satisfactory completion of this program involving 43A RCB Containment Cooling Mercury installations verifies acceptance of the 43B Shield Bldg. Ventilation installations. Accordingly, this issue does not serve 43E Containment Vacuum Relief as a constraint to the safe operation of these systems, 46B Control Room HVAC and has been resolved and closed out by LP&L.
46E RAB Chilled Water 52A Reactor Coolant System 523 Reactor Coolant System
- 52C Reactor Coolant System 53A Charging & Letdown 53B Boric Acid Nhkeup l
l A-15
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! System'#- System Description ,
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55A Gaseous Waste Management
~
SSB Liquid Waste Management 5
.8 Safety Injection 60A Safety Injection 60B Safety Injection- . .
-60C Safety Injection 59 Containment Spray 66 Plant Protection System 63 Plant Protection System 71B Condensate Make-up 73 Emergency Feedwater ,
76 Steam Generator and MSIVs G
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A-16
Issue flB - Tompkins-Beckwith Subgroup C - Tompkins-Beckwith did perform safety related work on the system, end safety evaluations were performed to assure LP&L management that Waterford SES #3 can be safely operated without. compromising the health and l
, oafety of the public. l Issue il does.have a potential-effect on:
System # System Description Evaluation 18-3 Radiation hbnitoring Work performed on this system was inspected by 22- Fire Protection potentially unqualified inspectors. To close out 36-1 Component Cooling Water the concern LP&L verified the qualifications of the 36-2 Component Cooling Water initial inspectors. LP&L also verified qualifica-3 Aux. Component Cooling tions of the inspectors Water performing any over-inspec-tion. Over-inspection 39 Emergency Diesel Generator provided.to meet the ASME Code requirements for third 43B Shield Bldg. Ventilation party Authorized Nuclear ~
Inspection services and 43E Containment Vacuum Rell'f e independent Preservice Inspection in conjunction 46B Control Room HVAC with other inspection I
programs, hydrostatic 46D RAB HVAC testing, and Pre-Core Hot Functional Testing confirm 46E RA3 Chilled Water the acceptability of hard-ware installed by Tompkins-48 LRT Containment Vessel Beckwith.
52A Reactor Coolant System .
52B Reactor Coolant System 52C Reactor Coolant System .
53A Charging and Letdovn 53B Boric Acid Makeup 54-9 Primary Sampling SSA Gaseous Wast'e Management
- '55B Liquid and Laundry Waste Management i
9 A-17
- b' System i System Description 55E Liquid and Laundry Waste Management 58 Safety Injection 60A Safety Injection 60B Safety Injection 60C Safety Injection 59 Containment Spray 61 Fuel Handling and Storage 65A-1 Excore Nuclear Instrument 71B Condensate Make-up 73 Emergency Feedwater ,
76 Steam Generator and MSIV 08 Turbine and Turbine Controls 19-16 Whip Restraints 19-17 System Supports 8
l A-18
Issue #1C - Other Contractors Subgroup C - Other Contractors (other than Mercury and Tompkins-Beckwith) did )
perform safety related work on a number of systems and safety evaluations are being performed to assure LP&L management that Waterford SES #3 can be safely i operated without compromising the health and safety of the public. 1 Issue #1C does have a potential effect on:
System # System Description Evaluations All Table A-1 See Table A-1 A ltatted safety review Systems was performed based upon the results of inspector qualtftcation validation to date and the lack of fission products and decay heat prior to intetal criticality.
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Issue #2 - Missing N1 Instrument Line Documentation Subgroup C - Instrumentation installations that were identified to have cdequate documentation to support the quality of the installations but a l decision was made to rework the installations to comply with ASME III l documentation requirements are contained in this system and a safety ;
cvaluation was performed to assure LP&L management.that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #2 does have an effect on: 1 1
System # System Description Evaluation 36-1 Component Cooling Water 36-2 Component Cooling Water 36-3 Aux. Component Cooling These systems were reworked Water to correct documentation to ' demonstrate system 39 Emergency Diesel Generator operability and remove tube class breaks from 43B Shield Building Ventila- ASME III to ANSI B31.1.
tion All work is completa.
66 Plant Protection System 63 Plant Protection System 73 Emergency Feedwater 76 Steam Generator and MSIV E
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Issue #3 - Instrumentation Expansion Loop Separation Subgroup C - It has been determined that there is identified installation deficiency regarding tubing separation criteria in the system and a safety cvaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compro 21 sing the health and safety of the public.
Issue #3 does have a potential effect on:
System # System Description Evaluation 66 Plant Protection System New tube tracks and supports were installed to 63 Plant Protection System correct the deficiencies.
Accordingly, this issue does not serve as a constraint to the safe operation of these systems, and has been resolved and closed out by LP&L.
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Issue #4 - Lower Tier Corrective Actions Are Not Being Upgraded to NCR's
'_ Subgroup C - DCN's, FCR's, EDN's and T-B DN's have been reviewed and it was determined that some documents should have been upgraded to NCR's. A safety cvaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #4 does have a potential effect on all systems in Table A-6.
The Evaluation reveals that a statistically acceptable number of lower tier documents were reviewed showing no significant quality impact Gno cases were detected which were safety significant and would be reportable under 10CFR50.55e). Therefore it is possible to conclude with a 95% confidence level that 95% of the unsampled documents contain no significant deficiencies. Accordingly, this issue does not serve as a constraint to safe cperation of the systems.
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A-21
Issue #5 - Vendor Documentation - Conditional Releases Subgroup C - With a review of QA/QC records it is concluded that there are no unresolved items which affect the systems, however Issue #5 does have a potential effect on all systems in Table A-6.
The Evaluation reveals that during the review of QA/QC records conditional release items which affected systems were evaluated and closed out by LP&L with receipt of the " unconditional" paperwork. No items exist to affect the safety function of the systems.
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Issue #6 - Dispositioning of Non-Conformance and Discrepancy Reports ,
Subgroup C - It was noted during a review of NCR's that some of the reports had questionable dispositioning potentially rendering the quality of installation indeterminate.
Issue #6 does have a potential effcet on all systems in Table A-6.
Tha Evaluation included a combination screening and sampling method to review EBASCO NCR's including NCR's identified by the NRC and no items were identified which had significant safety impact on the systems. . Mercury NCR's were reviewed for upgrade and sampled to determine reportability to support the conclusion that the safety review is not effected.
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A-23
Issue #7 - Eackfill Soil Densities Subgroup C - Data from the in-place density tests.on the class A fill was e
potentially not traceable relative to the technical adequacy of the placements, therefore the impact on the the quality of the system may have
.been indeterminate. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #7 does have a potential effect on all systems in Table A-6.
The Evaluation reveals that the data for the in-place density tests performed on the class A fill has been located and has been transmitted to the QA records vault. Review and analysis of the records indicates that the Class A i backfill soil densities are fx Sccordance with specifications and FSAR requirements except for analytically non-significant deficiencies and does provide the required design structural capacity for the plant under seismic r loadings. Accordingly, this issue does not serve as a constraint to safe L operation of the system, and has been resolved and closed out by LP&L.
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. - - . _ . . . - - - . . - .. __~ - . .. ~
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--Issue. #8 - Visual ~ Examination of Shop Welds During Hydrostatic Testing Subgroup C - The system does include ASME Class 1 & 2. welds (shop and field) that were inspected during total system hydro in the field. A safety cvaluation was performed to assure LP&L management that Waterford SES #3 can
~
be safely ' operated without: compromising the health and safety of the public.
Issue #8.does have a potential effect on:
System # System Description Evaluation ...
18-1 Radiation Monitoring System ASME Class 1 & 2 welds (shop and field) were 18-2 Radiation Monitoring inspected and documented on f
ASME N-5 code data reports 18-3 Radiation Monitoring during total system hydro in the field. The ASME 18-4 Radiation Monitoring Class 1 & 2 welds (shop and 4
field) were tested and 18-5 Radiation Monitoring inspected in accordance '
with ASME code, in the 36-1 Component Cooling Water fiqld. There is no devia-
- tion from FSAR require-36-2 Component Cooling Water ments. Accordingly, thi's issue does not serve as a 36-3 Aux. Component Cooling- restraint to safe operation Water of these syste=s, and has
.' been resolved and closed 52A Reactor Coolant System out by LP&L.
52B Reactor Coolant System 52C Reactor Coolant System 53A Charging And Letdown 53B Boric Acid Makeup 54-9 Primary Sampling 55A Gaseous Waste Management t
k 55B Liquid and Laundry Waste Managemeat SSE Liquid acd Laundry Waste Management 58 Safety Injection .
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A-25
1 System # - System Description
'60A- Safety Injection 60B Safety 'Inj ection 60C Safety Injection 59 Containment Spray
.713 Condensate Makeup . -
73 Emergency Feedwater 76 Steam Generator and MSIV O
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Issue #9 - Welder Certification Subgroup C - During the NRC Staff review of the records for the installation cf the supports for certain instrumentation cabinets in the RCB, it was determined the same documentation was apparently missing. This apparent missing documentation pertained to support welds and certificar. ion of some welders. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising ;he health and safety of the public:
Issue #9 does have a potential effect on: .-
System # System Description Evaluation 48 Containment Vessel The review and evaluation of the welding for the RCB 52A Reactor Coolant System instrument cabinets in question is complete with 52B Reactor Coolant System confirmation of its capability to adequately 1
52C Reactor Coolant System perform its safety function under design conditions.
55B Liquid and Laundry The welding on instrumenta-Waste Management tion cabinets supports that affect these systems has' 55E Liquid and Laundry been reinspected and verified Waste Management as acceptable with no rework required. No further correc-58 Safety Injection tive action is required.
, 60A Safety Injection j 60B Safety Injection
, 60C Safety Injection 66 Plant Protection System .
63 Plant Protection System 76 Steam Generators and MSIV .
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6 Issue #10 - Inspector Qualifications - (J. A. Jones and Fegles)
Subgroup C - J.A. Jones and Fegles were responsible for the construction of the basemat and all structural concrete on the basemat. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #10 does have a potential effect on:
System # System Description Evaluation Seismic Structures A limited safety review was
^
performed based upon the results of inspector qualification verification to date, lack of fission products and decay heat prior to initial criticality and low probability of a seismic event during the timie period from Fuel Load to* initial criticality.
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i Issue #11 - Cadwelding Subgroup C - Data from the cadweld testing program was potentially not l traceable relative to the technical adequacy; therefore the impact on.the I system could have been indeterminate. A safety evaluation was performed to tssure LP&L management the Waterford.SES No. 3 can be safely operated without compromising the health and safety of the public.
Issue #11 does have a potential effect on all systems in Table A-6.
The Evaluation of cadweld records concluded that discrepancies noted were not significant to safety and would not have had any effect on the structural capability of the. NPIS during operation and safe shutdown. The probability of an accident previously evaluated in the FSAR is not increased.
Accordingly, this issue does not serve as a constraint to the safe operation of the systems, and has been resolved and closed out by LP&L.
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Issue #12'- Main Streamline Framing Restraints Subgroup C - Apparent failure to inspect the installation of the main streamline framing restraints may rendered the quality of the system indeterminate. A safety evaluation was performed to assure LP&L management that Waterford.SES #3 can be safely operated without compromising the health end safety of the public..
Issue #12 does have a potential effect on:
System # System Description Evaluation 76 Steam Generators and -
The deficiencies noted MSIV during the reinspection have been corrected and 91 Seismic Supports all hardware corrective actions have been completed 19-16 Whip Restraints and verified by LP&L.
Accordingly, this issue 19-17 System Supports does not serve as a (Hangers) . constraint to safe operation of these systems, Seismic Structures and has been resolved and closed out by LP&L.
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I Issue #13 - Missing NCRs Subgroup C_- It was noted that there were missing reports in the consecutively numbered EBASCO and Mercury NCRs implying missing NCRs that may have rendered system quality indeterminate. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely cperated without compromising the heath and safety of the public.
Issue #13 does have a potential effect on all systems in Table A-6.
The Evaluation includes reviews of EBASCO and Mercury NCR documentation completed by LP&L QA. EBASCO and Mercury missing / voided NCRs and Mercury NCRs closed administratively have been determined to be properly dispositioned and closed. There are no unreviewed safety questions for this system pcrtinent to this issue.
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. . l Issue #14 - J.A. Jones Speed Letters and EIRs Subgroup C - Contractors performing safety related work generated EIRs and Speedy Memos which transmitted design information that could potentially cffect system quality. A safety review was performed to as.sure LP&L management that the system can be safely operated without compromising the health and safety of the public.
Issue #14 does have a potential effect on all systems in Table A-6.
The Evaluation included a sampling program to evaluate informal. documents requesting engineering information from safety related contractors. Of all the samples reviewed those that resulted in design change deficiency had no cafety significance. The program provides reasonable assurance that informal documents were not used to transmit design changes which have safety significance.
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A-31
Issue #15 - Welding of "D" Level Material Inside Containment Subgroup C - Class "D" material installation inside containment does have a potential effect on:
System # System Description Evaluation 08A 208/120v Elec. Distribucion During the evaluation of Safety Class "D" material installation inside 17 Seismic Monitoring containment the work and material under review was 18-1 Radiation Monitoring verified by LP&L.
System Contractor QA is of satisfactory qaality, and 18-2 Radiation Monitoring this issuc does not have System an adverse effect on the safety analysis, system 18-3 Radiation Monitoring operability or margin to System safety on these systems.
18-4 Radiation Monitoring .
System .
18-5 Radiation Monitoring System 21 Fire Detection 22 Fire Protection -
36-1 Component Cooling Water 36-2 Component Cooling Water 40-2 Crane & Hoist FHB 43A RCB Containment Cooling 43E Containment Vacuum Relief 48 LRT Containment Vessel
~
52A Reactor Coolant System 52B Reactor Coolant System 52C Reactor Cool, ant System 53A Charging & Letdown 54-9 Primary Sampling A-32
System # System Description-
-58 Safety Injection
- 60A Safety Injection 60B Safety Injection 60C Safety Injection 59 Containment Spary . .
l
.61. Fuel Handling & Storage 65A-1 Excore Nuclear Inst.
65A-2 Excore Nuclear Inst.
4 713 Condensate Makeup 76 Steam Generators & MSIV 91- Seismic Supports ,
19-16 Whip Restraints 19-17 System Supports (Hangers)
Seismic Structures i
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Issue #16 - Surveys and Exit Interviews of QA Personnel '
Subaroup C - An interview program was instituted by LP&L to provide an additional avenue of communication to elicit information on quality concerns from personnel prior to leaving the Waterford SES No. 3 project. The concern was that the LP&L program may not have promptly or thoroughly examined the cpecific areas of concern and the programmatic implications of these systems.
Issue #16 does have a potential effect on all systems in Table A-6.
The Evaluation reveals that all concerns are being reviewed under an improved quality concera program. Where there are issues not previously. identified with potential safety related consequences, these issues are promptly reported to LP&L management. These concerns are properly addressed unde.r LP&L required and approved management programs in a timely fashion. The program does not involve unreviewed safety' issues.
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Issue #17 - QC Verification of Expansion Anchor Characteristics Subgroup C - Mercury, the subject of this concern, did install safety related instrumentation expansion anchors in these systems. A safety evaluation was performed to assure LP&L management that the system can be safely operated
- .without compromising the health and safety of the public.
Issue #17 does have a potential effect on:
System # System Description Evaluation 18-1 Radiation Monitoring Inspection forms were used 18-2 System that do not explicitly 18-3 cover all inspectica 18-4 attributes. The reinspec-18-5 tion of all Mercury installed N1-instrumentation 36-1 , Component Cooling Water and subsequent engineering evaluations indicates that 36-2 Component Cooling Water .the issue of expansion anchor characteristic 36-3 Aux. Component Cooling Water inspection forms have no safety significance for 39 Emergency Diesel Generator these systems.
43A RCB Containment Cooling 43B Shield Bldg. Ventilation
- 43E Containment Vacuum Relief.
52A Reactor Coolant System 523 Reactor Coolant System 52C Reactor Coolant System 53A Charging and Letdown 53B Boric Acid Wakeup SSA Gaseous Waste Management A-35
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JN- . Issue ' #18 i Documentation of Walkdowns on Non-Safety Related Eouipment Subgrod6'C - Documentation'of walkdown on non-safety related equipment does have aspotential effect on:
System # System Description Evaluation t
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I 02A 125v DC Safety Area inspections where the
~ ' ' l system is present indicate 06A 4.16kv Elec. '
no interactions of_ safety Distribution Safety significance...Accordingly, this issue does not serve
.07A 480v Elec. as a restraint to safe Distribution Safety operation of these systems, and has been resolved and 08A 208/120v Elec. closed out by LP&L.
~
Distribution Safety t
09A Inverters &
Distribution Safety 10 Cocaunications .
, s 13A-1 Heat Trace Safety p-
-16 Environmental '
Monitoring 17 Seismic Monitoring 18-1 Radiation Monitoring System 18-2 Radiation Monitoring '
System 18-3 Radiation Monitoring .
System 18-4 Radiation Monitoring '
System 18-5 Radiation Monitoring System 20 Security System 21 Fire Detect 1,on i
22 Fire Protection i
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. i System i System Description 36-1 Component Cooling Water
. 36-2 Component Cooling Water. .
36-3 Aux Component Cooling Water
- 39. Emergency Diesel Generator 40-2 Crane & Hoist FHB 43A RCB Containment Cooling 43B Shield Bldg. Ventilation 43E Containment Vacuum Relief 46B Control Room HVAC 46D RAB HVAC .
46E RaB Chilled Water 46K Fire Dampers 48 LRT Containment Vessel -
49 Process Analog Control -
50B Misc. Panels 52A Reactor Coolant System 52B Reactor Coolant System 52C Reactor Coolant System' 53A Charging & Letdown 53B Boric Acid Makeup 54-9 Primary Sampling SSA Gaseous Waste Management r
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t System #- System Description-
~55B Liquid & Laundry Waste Management SSE Liquid & Laundry Waste Management 58 Safety Injection 60A Safety Injection -
60B Safety Injection- ~'
60C Safety Injeccion 59 Containment Spray 61 Fuel Handling & Storage 66 Plant Protection System 63 Plant Protection System .
65A-1 Excore Nuclear Inst.
65A-2 Excore Nuclear Inst.
71B Condensate Makeup 73 Emergency Feedwater 75 Secondary Sampling 76 Steam Generators & MSIV 91 Seismic Supports .
19-16 Whip Restrainta 19-17 System Supports (Hangers) ,
Seismic Structures l
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,. , _ _ _ . - - - - ~ . - ~ , . -- -.
Issue #19 - Water in Basemat Instruments Subgroup C:- Water in basemate instruments does have a potential effect on:
System # System Description Evaluation 08A 208/120 v Elec. Distribution The present analysis for ,
Safety moderate energy pipe 1 rupture flooding per the i 10 Communications FSAR envelopes the concern for water seepage since :
13A-1 Heat Trace Safety this flow rate would be.
minimal. Accordingly, 17 Seismic Monitoring this issue does not serve as a restraint to safe 18-1 Radiation Monitoring- operation of these System systems, and has been-resolved and closed out 18-2 Radiation Monitoring by.LP&L.
System 18-3 Radiation Monitoring .
System .
18-4 Radiation Monitoring System 18-5 Radiation Monitoring System 20 Security System 36-1 Component' Cooling Water 36-2 Component Cooling Water
, 36-3 Aux Component Cooling Water .
43A RCB Containment Cooling 46D RAB HVAC- .
46E RAB Chilled Water 53A Charging & Letdown i
53B Boric Acid Makeup e
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System # System Description SSA Gaseous! Waste Management 55B Liquid & Laundry Waste Management SSE -iLiquid & Laundry Waste Management
- 58. Safety Injection - -
60A- Safety Injection
'I 60B Safety Injection 60C Safety Injection 59 Containment Spray 71B Condensate Makeup 73 Emergency Feedwater .
Seismic Structures I
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. o Issue #20 - Construction Materials Testing (CMT) Personnel Qualifications Records Subgroup C - Construction Material Testing (CMT) personnel did do work on the Oystem and a safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #20 does have a potential effect on:
System # System Description Evaluation Seismic Structures An Engineering Evaluation of CMT for backft11 sotis indicates no defective work of safety significance was accepted as a result of testing personnel actions.
A limited safety review was performed based upon the results of inspector qualification vertftcation to date, lack of fission. '/
products and decay heat prior to initial criticality and low probability of a seismic event during the time period from Fuel Load to initial criticality.
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, e Issue #21 - LP&L QA Construction System Status and Transfer Reviews
' Subgroup C - Open walkdown comments did have a potential impact on the system even though startup and system engineering evaluated the walkdown concerns and determined that there is no adverse impact on system / testing or cperability.
Is. sue #21 does have a potential effect on:
4 System # System Description Evaluation *-
71 Condensate Makeup All~open walkdown comments have been resolved / closed.
91 Seismic Supports All significant construction QA findings have been identified and properly dispositioned.
Accordingly, this review does not serve as a constraint to safe operation of these systems, and has been resolved and
) closed out by LP&L.
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Issue f22 - Welder Qualifications (Mercurv) and Filler Materials Control (Site Wide)
Subgroup C - The LP&L review of qualifications status documentation for all Mercury welders has been completed and the program does have a potential impact on the system. The weldment filler material controls did apparently deviate from code requirements.
Issue #22 does have a potential effect on all systems in Table A-6.
The Evaluation contains a clarification of the review finding on welder qualifications, and there are no potential unreviewed safety questions pertinent to this issue. "Rebaking" of low hydrogen electrodes was not practiced on the site and engineering justification demonstrates that while there were limited deviations from code specifications however this did not cause degradation of quality of weldment filler material.
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Issue #23 - QA Program Breakdown Between EBASCO And Mercury The-concern is not directly related'to the systems under review and is considered to be programmatic in nature.
There are no Subgroup C systems.
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i ir f n e_ t TABLE A-6 ISSUES No. I No. 2 No. 3 No. 4 No. $ No. 6 No. 7 No. 8 Inspection Misstag NI Instrumen- Lower Tier . Vendor Docu- Disposition- Backftll Visual Exam-Personnel Instrument ration Ex- Correcttwe mentation - ing of Non- Soil ination of Issues Line Docu- pension Loop Actions are Conditional conformance Denstetes Shop Welds mentation Separation not being Releases and Discrep- During SYSTEM .3 Upgraded to ancy Reports Hydrostatic _ +
(A)(3)(C) ,NCRs Testing 62A - 125, DC Safety A B C A A C C C 'C A C3 - Switchlag Startoq. J B C A A C C C C A 04 - Starrup Transformers A B C A A C C C _C A 06A - 4.16kw Elec. A B C A A C C C C A Distriburton Safety C7A - 4a0v Elec. A B C A, A C C C C A Distribertaa Safety 084 - 200/I20v Elec. A B C A A C C C C A Distriburton Safety 09A - Inv.:rters & A B C A A C C C C A Distriburton Safety . . .
13 - Communicartons A B C A A C C C C A 13A Heat frace Safety A 'E C A A C C C C A 16 - Invironmental A B ,C A , A C C C C A Womitoring
- 17 - Seismic Monitoring A B C A A C C C C A A-44 l J--___- .- ~ ----_-___na
. . . m k-TABLE A-6 ISSUES No. I h.2 No. 3 No. 4 No. 5 No. 6 No. 7 No. 8 inspection Nissing N1 Instrumen- Lower Tier Vendor Docu- Disposition- Backftll Visual Exam-
+
Personnel Instrument tation Ex- Corrective mentation - ing of Non- Soil 'ination of I
lasses Line Docu- pansion Loop Actions are Condtrional conformance Denetties Shop Welds mentation Separation not being Baleases and Discrep- During Upgraded to ancy Reports Hydrostatte 4
SYSTEM (A)(B)(C) NCBs Testing ,
v i 18-I - Badiation hattoring B B C A A C C C C C
~
System .
18-2 B B C A A C C C C C 18-3 C C C A A C C C. C' C 18-4 A B C A A C C C C C 18-5 A B C A A C C C C C 20 - Security System A B C A A C C C C A 21 - Fire 3 erection A B C A B C C C C A 22 - Fire Protection C C C A B C . . C C C B 36 Component Cooling Water C C C C B C C C C C
~
36-2 C C C C B C C C C C 36 Aux Component Cooling . C C C . C B ,
C C C C C Water i I f 39 - Emergency Diesel Generator C C C C B C C C C B i !
y 40 Crane & Hotst DIB A B C A A C C C C A 41A - BCB Containment Cooling C B C A B C C C C. A A-45 4
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-I, TABLE A-6 ' !i ISSUES 4-No. I No. 2 No. 3 No. 4 No. 5 No. 6 No. 7 No. 5 Inspection Missing N1 Instrumen- Lower Tier Vendor Docu- Disposition- Backft11 Visual Exam-Personnel Instrument ration Ex- Corrective mentation - ing of Non- Soil ination of 1ssues Line Docu- paaston Loop Acetons are Conditional conformance Denstetes Shop Welds mentation Separation not betag Beleases and Discrep- During Upgraded to ancy Reports Hydrostatic SYSTEMS (A)(B)(C) NCBs
- Testing 435 - Shield Bldg. Ventilation C C C C B C C C C A 43E - Containment Vacuug Belief C C C A B C C C C A 468 - Control Boon HVAC C C C A B C C C C A 46D - BAB HVAC C C C A B C C C C A 46E - BAB Chtlled Water C C C A B C C C C 3 46K - Fire Dampers A B C A" A .C C C C A 48 - LRT Containment Vessel A C C A B C C C C. A 49 - Process Analog Control A B C A B C C C C A
! 508 - Misc. Panels A B C A B C C. C C
. . A l 52A - Beactor Coolant System C C C A B C C C C
! C 525 C C C A B C C C C C 52C C C C A B C C C
, C C A-46 i .
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TABLE A-6
, 4
! rssues N2 I No. 2 No. 3 No. 4 No. 5 No. 6 No. 7 No. 8 Inspection Missing N1 Instrumen- Lower Tier Vendor Docu- Dispostrion- Backfill Visual Exam-Personnel Instrument ration Ex- Corrective mentation - tag of Non- Soil inattom of Issues Line Docu- panston Loop Actions are Conditional conformance- Denstetes Shop Welds mentation Separation not being Seleases and Discrep- During i
Upgraded to ancy Reports Mydrostatic l SYSTEMS (A)(B)(C) NCBs *
. Testing t
i l
4 l 534 - Charging & Letdown C C C A B C C C C C 538 - Boric ActJ Makeup C C C A B C C C C
, C 54 Primary Sampling 5 C C A B C C C -C C 55A - Caseous W ste Management C C C A 8 C C C C C 555 - Ltquid & Laundry Este C C C .A B C C C C Management
- C 55E B C C A B C C C C C l 54 - Safety injection C C C A B C C C C C 60A C C C A B ,
C C, ,
C C C 605 C C C A B C C C C C 60C C C C A B C C C C C
, 59 - Contatement Spray C C C A B C C C C
- = C l .
61 - Fuel Nanditag & Storage A C C A B C C C C 3
l
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_ _ _ , _ _ _ . m _._ _ _ _. . _ . _
i -
.J,J :
f TABLE A-6 l
TSSWES I Mo. 1 .No. 2 me. 3 so. 4 No. 5 me. 6 me. 7 me, a l Inspection Misstag MI ]astruere- Lower Tier Vendor Docu- Disposition- Backft11 Visual Ex.e-Personnel Instrument ration Es- Corrective mentation - tag of Non- So tl inatio* of Issues Line Docu- paasten Loop Actions are Conditional canformance Densities Shop licide mentation Separattaa mac being Releases and Discrep- Duttag Upgraded to ancy Reports Mydrostatic SYSTDeS (A)(3)(C) 3CEs J Testing 66 - Plant Protection Systee C E C C C C C C C A C3 ,
C B C C C C C C C A f 5A Escore Nuclear Inst. A C C A A C C C C A C5A-2 A B C A A C C C C A 713 - Condensare Makeup C C C A B C C C C C 73 - Emer8ency Feedwater C C C C* 3 C C C C C 75 - Secondary saepitag 3 3 C A B C C C C 5 76 - Steam Cenerators & MSIT C C C C 3 C C C C C
- SS - Turbtae & Turbine Controls B C C A B C C C C 4 91 - Setsetc Supports A B C A A C C C C A 19 liktp Restratars A C C A &- C C C C A -
19 Systee Supports (Mangers) A C C' A
- A C- C C C A
- - Seismic Structures A B C A A C C C C '
A A-48
e.
b
-l
- TABLE A-6 ISSUES Wo. 9 No. 10 No. Il No. 12 No. 13 No. 14 No. 15 No. 16 hider Cer- Inspector Cadwelding Main Steam- Missing NCRs J.A. Jones Welding of Surveys and
- tification Qualifica- line Framlag Speed "D" Level Exit Interviews tions (J.A. Bestraints Letters Material of QA Personnel Jones & and ElRs Inalde SYSTEM Fegles) Containment 02A - 125v CD Safety A A C A C C A C 03 - Suiteklag Station A A C A C C A C 04 - Startup Transformers' A A C A C C A C 064 - 4.16kw Elec. A A C A C C A C Distribution Safety 2n - 480w Elec. A A C A C C A C Distributtaa Safety Gea - 200/120v Elec. A A C A C C C C Distribution Safety 09A - leverters & A A C A C C A C D1;tribution Safety 1") P-==1 cations A A C *A C *
- C A C 13& Beat Trace Safety A A C A C C A C 16 - En:1ronmental A A C - A C C A C Nor.itoring 17 - Seismic Monitoring A A C A C C C
- C A-49 F
e
.-= . .- . _ - .
I*
TA4LE A-6 ISSUES No. 9 No. 10 No. 11 No. 12 No. 13 No. 14 No. 15 No. 16
- Welder cer- Inspector Cadwelding Main Steam- Missing 3CRs J.A. Jones Welding of Surveys and tification Qualifica- line Framing Speed "D" Level Exit Interviews tions (J.A. Bestraints Letters Material of QA Personnel Jones & and Elts inside SYSTEM Fegles) Containment
- 18 Radiation Monitoring A A C A C C C C System J
18-2 A A C A C C C C 18-3 A A C A C C C C 18-4 A A C & C C C C 18-5 A A C & C C C C
'23 - Security System A A .
., C A C C A C
- 21 - Fire Detection A A C A C C C C "22 - Fire Protection A A C A C C C C l36 Component Cooling Water A A C A C C C C 36-2 A A C A C C C C i
'36 Aux Component Cooling A. A C .A C C A C Water l39 - Emergency Diesel Generator A -
A - C A ,
C C A C
- 40 Crane & Holst FnB B A C A C C C C
- 43A - RCS Containment Cooling A A C A C C C C ,
4 1 A-50 l J
i
?
- .. -. ~ .. -
TABl.E A-6 ISSUES No. 9 Wo. 10 No, il No. 12 No. 13 No. 14 No. 15 No. 16 W 14tr Cer- Inspector Cadwelding Hain Steam- Missing NCRs J.A. Jones Welding of Surveys and tification Qualifica- line Framing Speed "D" Level Exit Interviews tions (J.A. Restraints i.etters Material of QA Personnel .
Jones & and EIRs Inside-SYSTDES Fegles) Congainment 438 - Shield Bldg. Teat 11ation A A C A C C A C 43E - Containment Tacuum Relief A A C A C C C C 46B - Control Saam MVAC A A C A C C A C 46D - RAS STAC h A C A C C A C 41E - RAR Oatlled hter A A C .A C C A .C 46E - fire Dampers A A' - C A C C A C 48 - LRT Caatainment Tassel C A C A C C C C
'49 - Frocess Analog Control A A C A C C A C 505 - Misc. Laels B A C A C C A C 52A - Reactar Caolant System C A C A C C C C 525 C. A C A C C C C 52C C A C A C C C C e
t A-51
n _
np-
.a L.
TABLE A-6 ISSUES ,
No. 9 No. 10 No. 11 No. 12 No. 13 No. 14 No. 15 No. 16 Walder Car- Inspector Cadwelding h in Steam- Missing NCRs J.A. Jones W 1 ding of Surveys and tification qualifica- line Framing Speed "D" Level Exit Interviews tions (J.A. Restraints Letters Material of QA Personnel Jones & and EIRs Inside SYSTDe$ Fegles) Costalanent 53A - Charging & Letdown A A C A C C C C 535 - Boric Acid Makeup A A C A C C A C 54 Primary Sampling
- A A C A C C C C 554 - Caseous Waste Management A A C A C C A C 555 - 11guld & Laundry W ate C A C A C C A C ,
knagement SSE C A -
C A C C A C ,
58 - Safety Injectica C A C A C C C C .
60A C A C A C C C C 608 C A C A C C C C 60C C A C A C C C C b9 - Containment Spray A A C A C C C C bl - Fuel Mandling & Storage B A C A C C C C A-52
~
. .s.
TABLE A-6 ISSUES Mo. 9 No. 10 %. 11 No. 12 No. 13 No. 14 No. 15 No. 16 Walder Cer- Inspector Cadwelding Main Steam- Missing NCRs J.A. Jones Welding of Surveys and efficattoa Qualtitca- Itne Framing Speed "D" Level Extc Interviews tions (J.A. Restrature Letters Material of QA Personnel-Jones & and E1Rs Inside SYSTEMS Fegles) Containment 66 - Plant Protection Systee C A C A C C A C '
g t
63 C A C A C C A C 05A Escore Nuclear lasi. A A C A C C C C 05A-2 A A C A C C C C 715 - Condensate Makeup A A C A C C C C 73 , Emergency Feedvarer A A C A C C A C 75 - Secondary Samp1 tag & A C A C C A C 76 - Steam Cenerators & MSIT C A C C C C C C 88 - Turbine & Turbine Controls A A C A C C A C 91 - Setssic Supports & A C C C' C C C 19 E lp Restraints 3 A C C C C C C 19 System Supports (Bangers) S A C' C C C C C
- Setsste Structures C
- C
- C C . C C C C A-53
a TABLE A-6 ISSUES No. 17 No. 18 Wo. 19 No. 20 No. 21 No. 22 Wo. 23 QC Verift- Documen- Water in Construction LP&L QA Welder QA Program cation of tation of Basemat Materials Construc- Qualifica- Breakdown Expansion Walkdowns on Instruments Testing tion System tions Between Ebasco Anchor Char- Non-Safety (CHT) Status and (Marcury) and Hercury acteristics Related Personnel Transfer and Filler Equipment Qualifica- Reviews Material ,
tion Records Control SYSTEM (Site Wide) 02A - 125v DC Safety A C A A A C A C3 - Switching Station A A A A A C A 04 - Strrtup Transformers A A A A A C A 06A - 4.16kw Elec. A C A A A C A Di:tribution Safety
'7A - 480v Elec. A C A A A C A Distribution Safety 08A - 208/120v Elec. A C C A A C A Dirtribution Safety "'
09A - Ilverters & A. C A *A A *
- C A 51 tribution Safety 10 - Communications A C 'C A A C A 13A Hert Trace Safety A C C A p. C A 16 - Environeestal A C A A A C A .
Monitoring 17 - Seismic Monitoring A C C A A C A A-54 e
--m-m- ,- . _ - - - , - - - u .---e , -+,a4- a.w ~'
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TABLE A-6 ISSUES 1
No. 17 No. 18 No. 19 No. 20 No. 21 No. 22 No. 23 QC Verif t- Documen- Water fa Construction LP&L QA Welder QA Program cation of tation of Basemat Materials Construc- Qualifica- Breakdown Expansion Walkdowns on Instruments Testing tion System tions Between Ebasco Anchor Char- Non-Safety (CWT) Status and (Mercury) and Mercury acteristics Related Personnel Transfer and Filler .
Equipmenc Qualifica- Reviews Material tion Records Control SYSTEM (Site Wide) i 18-1 - Radiation Monitoring C C C A B C A Systen i
18-2 C C C A B C A 18-3 C C C A B C A 18-4 C C C A B C A 4
18-5 C C C A B C A 20 - Security System A C C A A C A 21 - Fire Detection A C A A A .C A 22 - Fire Protection A C A A *A
- C A
{ 36 Component Cooling Water C C C A B C A j 36-2 C C C A B C A 36 Aux Component Cooling C* C* C A B C A Water
- 39 - Emergency Diesel Cenerator C C A A A C A 2
40 Crane & Holst THE A C A A A C A '
43A - RC8 Containment Cooling C C' C A A C A 1 A-55 9'
. .-- . - - ._ . . - . _ ~ . ~ _ - . - - . . . . - . -__... - .. . _ . _ . -. - ,
e TABLE A-6 ISSUES No. 17 No. 18 No. 19 No. 20 No. 21 No. 22 No. 23 QC Verift- Documen- Water in Construction LP&L QA Welder @ Frogram cation of tagion of Basemat Materials Construc- Qualifica- Breakdown Expansion Walkdown on Instruments Testing tion System tions Between Ebasco Anchor Char- Non-Safety (Cft) Status and '(Mercury) and Mercury acteristics Related ?arsonnel Transfer and Filler _,
Equipment Qualifica- Reviews Material t2am Records Control SYSTEMS
- (Site Wide)
- 438 - Shield Bldg. Ventilation C C A A B C A
. 43E - Containment Vacuum Belief C C A A A C A f
465 - Control Room HVAC C C A A Be* C A 46D ,- RAS NVAC C C C A A C A -
46E - RAB Chilled Water C C C & B C A 46K - Fire Dampers & C A A A C A
{
l 48 - LRT Containment Vessel A C A A A C A i
a 49 - Process Analog Control A C A
- A 1
- C A 4
50s - Misc. Fanels C C A A A C A 4
52A - Reactor Coolant Systes C C A A A C A I
1 528 C - C. A $ A C A i 52C C C A A A C A i
- ** - This system was incorrectly identified as 4389 in this issue.
A-56 i
l 4
]
~
TABLE A-6 ISSUES No. 17 No. 18 No. 19 No. 20 No. 21 No. 22 No. 23 QC Veriff- Documen- Water in Construction LP&L QA Walder QA Program cation of tation of Basemar Materials Construc- Qualifica- Breakdown Expansion Walkdowns on Instruments Testing tion System tions Between Ebasco Anchor Char- Non-Safety (CMT) Status and (Mercury) and Mercury acteristics Related Personnel Transfer and Filler Equipment Qualifica- Beviews Material
- tion Records Control SYSTEtS (Site Wide)
.i 53A - Charging & Letdown C C C A A C A 335 - Boric Acid Makeup C C C A A C A 54 Primary Sampling A C A A A C A 55A - Caseous Beste Management C C C A B C A 555 ' - Li p id a Laundry Waste A C C A A C A Management 55E A C C A A C A SS - Safety Injection C C C A B C A 60A C C C A B' C A 605 C C C A B C A 60C C C C A B C A 59 - Conta1 ament Spray C
- C* C A B C A dl - Fuel Bandling & Storage C C A A A C A i
A-57 1
.f
TABLE A-6 ISSUES No. 17 No. 18 No. 19 No. 20 No. 21 No. 22 No. 23 ,
QC Vertft- Documen- Water in Construerton LP&L @ Nsider @ Program
- cation of tation of Basemar Materials Construc- Qualtitca- Breakdown Expansion Walkdowns on instruments Testing rien System tions Between Ebasco Anchor Char- Non-Safety (CMT) Status and (Mercury) and Mercury acteristics Belated Personnel Transfer and Filler Equipment Qualtitca- Reviews Material .
rion Records control SYSTDIS (Site Wide) 66 - Plant Protection System C C A A A C A 63 C C A A A C A 65A Excore Nuclear Inst. A C A A A C A 65A-2 A C A A & C A 715 - Condensate Makeup C 'C
- C A C C A 73 - Emergency Feedwater C C C A A C A 75 - Secondary Sampling A C A A A C A 76 - Steam Cenerators & MSIV C C A ,
A A , ,
C A
- 88 - T rbine & Turbine Controls A A A A A C A l
- 91 - Setsste Supports A- C A A C C A
!!9 W ip Restraints A C A A & C A
- 19 System Supports (Hangars) C C A A A C A
- - Setsate Structures C C C C A C A 1
A-58 1 .
h 1
o - - _ _ _ _ _____m
1 i-ATTACHMENT B
< SAFETY REVIEWS FOR PLANT SYSTEMS REQUIRED BY TECHNICAL SPECIFICATIONS FOR CRITICALITY, LOW POWER ,
TESTING AND FULL POWER OPERATION 5
6 e
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LICENSTNG PLAN FOR CRITICALITY, LOW POWER TESTING i AND FULL POWER OPERATION *-
The program discussed in Attachment C and appited to Fuel load and
! Precriticality Post Core-Load Hot Functional Testing in Attachment A is being appited to those systems required for Criticality, Low Power Testing !
and Full Power Operation. These syshms are itsted in Table B-1. This ;
- process has been completed to the extent feastble pending final resolution of Issue #1C.
Suasaries have been prepared (as described in Attachment A, Table A-4) and full documentation will be filed in the Waterford .3 On-Site Licensing Unit offices for inspection and review by the NRC staff. ,
4 l
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31
n TABLE 5-1 i
^ PLANT SYSTEMS REQUIRED FOR CRITICALITY AND LOW PvWER ise nNG TO FIVE PD uant. AND FULL POWER OFDATION 0FDABILITY ACROImt SYS. NO DESCRIPTION REQUTRED l
1
. PMC 15 FLANT MONITORING COMPUT H NODE 1 ( 20%)
f FF 22-3* FIRE PROTECTION - HALON ' MODE 1 ( 20%)
i HEA 438 RCB NYDROGEN RECOMBINDS/ MODE 1-2 ANALYZD CEC 64 CONTROL ELIMINT ASST. MODE 1-2 CALCULATOR INI 655 INCORE NUCLEAR INSTRUMENTATION MODE 1 ( 20%)
WI 65C MOVABLE INCORE NUCLEAR INSTR.
l MODE 1 ( 20%)
VLF 69 VinRATION & LOOSE PARTS MODE 1-2 MONITOR e
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Indicates that Team.ISSC. PotC '
Table B-2 SYSTCIS / ISSUES SAFETY RESOIMf!ON ItATRIX /i/ and Plant Manager review canalated.
SYSTEN I NUMBER SYSTDs 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 A B C D (I) 15 PLANT HONITORING COMPUTEN X X X X X X X X.
X X X X X X X X X X X X X X X X 22-3 FIRE PROTECTION - HALON X X X X X X X, X X X X X X X X X X X X X X X X X 4 318 RCB HYDROCEN RECOMBINERS/
ANALYZER X X X X X X X X X X X X X X X X X X X X I I X X 64 CONTROL ELD 1ENT ASSY.
CALCULATOR X X X X X X X X X X X X X X X X X X X X X X X X rut AT N X X X X X X X X X X X X X X X X X X X X X X X X -
1 65C, NOVABLE INCORE NUCLEAR X X X X X X X X X X X X X X X X X X X X X X X X .
INSTRIRfENTATTON 69 VIBRATION & LOOSE PARTS X X X X X X
, X X X X X X X X X X X- X X X X X X X 1 MONITOR 4
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E e TABLE B-4 s
SAFETY REVIEW SUMMARIES e
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4 3
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p B-7
Issue il - Inspection Personnel Issues This issue was evaluated on a contractor basis.
Issue #1A - Mercury Subaroup C - Mercury did perform safety related work on the system and safety evaluations were performed to assure LP&L management that Waterford Steam Electric Station #3 can be safely operated without compromising the health and safety of the public.
Issue il does have a potential effect on:
System i System Description Evaluation 43-H RbBHydrogenRecombiners/ Installation of safety 4
Analyzers related instrumenta-tion was inspected by 64 Control Element Assy. potentially unqualified Calculator inspectors. The quality of safety related instru-mentation associated with this system was verified. "
Verification was accom-plished by reinspection ~
of N1 instrument loops.
Satisfactory completion of this program involving Mercury installations verifies acceptance of the installations. Accordingly, this issue does not serve as a constraint to the safe
' operation of these systems, and has been resolved and closed out by LP&L. ,
I B-8
Issue #1B - Tompkins-Beckwith Subgroup C - Tompkins-Beckwith did perform safety related work on the system, and safety evaluations were performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #1 does have a potential effect on:
System # System Description Evaluation 43-H RCB Hydrogen Recombiners/ Work performed on this Analyzers system was inspected by potentially unqualified
. inspectors. To close out the concern LP&L verified the qualifications of the initial inspectors. LP&L also verified qualifications of the inspectors performing any over-inspection. Over-ingpection provided to meet the ASME Code requirements -
for third party Authorized Nuclear Inspection services and independent Preservice Inspection in conjunction with other inspection programs, hydrostatic testing, and Pre-Core Hot Functional Testing confirm i the acceptability of hardware installed by Tompkins-Beckwith.
e .
h B-9
Issue #1C - Other Contractors Subgroup C - Other Contractors (other than Mercury and Tomkins-Beckwith) did perform safety related work on a number of systems and safety evaluations are being performed to assure LP&L management that Waterford SES #3 ca2 be safely cperated without compromising the health and safety of the public.
Issue #1C impact beyond initial criticality remains to be evaluated.
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l B-10
- Issue #2 - Missing N1 Ihstrument Line Documentation None of the instrument installations to be reworked to comply fully with ASME III requirements are contained in the systems.
- There are no Subgroup C. systems.
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B-11
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-Issue #3 - Instrumentation Expansion Loop Separation '
1 There are no instrument expansion loop separation violations of safety significance in these systems.
There are no Subgroup C systems.
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B-12
l 1
Issue #4 - Lower Tier Corrective Actions Are Not Being Upgrcded to NCR's Subgroup C - DCN's, FCR's, EDN's and- T-B DN's have been reviewed and it was determined that some documents should have been upgraded to NCR's. A safety !
cvaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #4 does have a potential effect on all systems in Table B-5.
i The Evaluation reveals that a statistically acceptable number of lower tier documents were reviewed showing no significant quality impact (no cases were detected which were safety significant and would be reportable under 10CFR50.55e). Therefore it is possible to conclude with a 95% confidence level that 95% of the unsampled documents contain no significant deficiencies. Accordingly, this issue does not serve as a constraint to safe
-operation of the systems.
1 S
S e
s B-13 3-
Issue #5 - Vendor Documentation - Condicional Releases Subgroup C - With a review of QA/QC records it is concluded that there are no ,
unresolved items which affect the systems, however Issue #5 dcas have a potential effect on all systems in Table B-5 The Evaluation reveals that during the review of QA/QC records c:nditional release items which affected systems were evaluated and closed out by LP&L with receipt of the " unconditional" paperwork. No items exist to affect the cafety function of the systems.
4 4
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4 9
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B-14
Issue #6 - Dispositioning of Non-Conformance and Discrepancy Reports Subgroup C - It was noted during a review of NCR's that some of the reports had questionable dispositioning potentially rendering the quality of installation indeterminate.
Issue #6 does have a potential effect on all systems in Table B-5.
The Evaluation included a combination screening and sampling method to review EBASCO NCR's including NCR's identified by the NRC and no items were identified which had significant safety impact on the systems. , Mercury NCR's were reviewed for upgrade and sampled to determine reportability to support the conclusion that the safety review is not effected.
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B-15 t
Issue #7 - Backfill Soil Densities Subgroup C - Data from the in-place density tests on the class A fill was potentially not traceable relative to the technical adequacy of the placements, therefore the impact on the the quality of the system may have been indeterminate. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compromising the health and safety of the public.
Issue #7 does have a potential effect.on all systems in Table B-5.
The Evaluation reveals that the data for the in-place density tests performed on the class A fill has been located and has been transmitted to the QA records vault. Review and analysis of the records indicates that the Class A backfill soil densities are in accordance with specifications and FSAR requirements except for analytically non-significant deficiencies and do's provide the required design structural capacity for the plant under seismic loadings. Accordingly, this issue does not serve as a constraint to safe operation of the system, and has been resolved and closed out by LP&L.
e e
4 4
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e B-16
Issue #8 - Visual Examination of Shop Welds During Hydrostatic Testing Subgroup C - The system does include ASME Class.1 & 2 welds (shop and field) that were inspected during total system hydro in the field. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without compronising the health and safety of the public.
Issue #8 does have a potential effect on:
System # System Description Evaluation ..
43-H RCS Hydrogen Recombiner/ ASME Class 1 & 2 welds Analyzer (shop and field) were
. inspected and documented on ASME N-5 code data reports during total system hydro in the field. The ASME Class 1 & 2 welds (shop and field) were tested and inspected in accordance with ASME code, in the fipid. There is no devia-tion from FSAR require-ments. Accordingly, this issue does not serve as a restraint to safe operation of these systems, and has been resolved and closed out by LP&L.
i i
. l B-17
4 l Issue #9 - Welder Certification !
Subgroup A - The instrumentation cabinet support welding performed by J.A.
Jones does not have an effect on the systems in Table B-5.
There are no Subgroup C syatems.
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j B-18 1
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Issue #10 - Inspector Qualifications --(J.A. Jones and Fegles)
No work was performed on these systems by J.A. Jones and Fegles.
There are no Sabgroup C systems.
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B-19
. . _. - . . . . . , . - . .. - ~ , ,. ,, . . .
4 Issue #11 - Cadwelding Subgroup C - Data from the cadweld testing program was potentially not traceable relative to the technical adequacy; therefore the impact on the system could have been indeterminate. A safety evaluation was performed to cssure LP&L managcment the Waterford SES No. 3 can be safely operated without compromising the health and safety of the public.
Issue #11 does have a potential effect on all systems in Table B-5.
The Evaluation of cadweld records concluded that discrepancies goted were not significant to safety and would not have had any effect on the structural capability of the NPIS during operation and safe shutdown. The probability of an accident previously evaluated in the FSAR is not increased.
Accordingly, this issue does not serve as a constraint to the safe operation of the systems, and has been resolved and closed out by LP&L.
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Issue #12 - Main Streamline Framing Restraints The main streamline framing restraints do not impact these systems.
1 There are no Subgroup C systems.
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9 B-21 I l
Issue #13 - Missing NCRs Subgroup C - It was noted that there were missing reports in the consecutively numbered EBASCO and Mercury NCRs implying missing NCRs that may have rendered system quality indeterminate. A safety evaluation was performed to assure LP&L management that Waterford SES #3 can be safely operated without ,
compromising the health and safety of the public. '
Issue #13 does have a potential effect on all systems in Table B-5.
The Evaluation includes reviews of EBASCO and Mercury NCR documentation completed by LP&L QA. EBASCO and Mercury missing / voided NCRs and Mercury NCRs
, closed administratively have been determined to be properly dispositioned and closed. There are no unreviewed safety questions for this system pertinent to this issue.
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l B-22
Issue #14 - J.A. Jones Speed Letters and EIRs Subgroup C - Contractors performing safety related work generated EIRs and Speedy Memos which transmitted design information that could potentially affect system quality. A safety review was performed to assure LP&L management that the system can be safely operated without compromising the health and safety of the public.
Issue #14 does have a potential effect on all systems in Table B-5.
The Evaluation included a sampling program to evaluate informal. documents requesting engineering information from safety related contractors. Of all f the samples reviewed those that resulted in design change deficiency had no safety significance. The program provides reasonable assurance that informal documents were not used to transmit design changes which have safety significance.
e 4
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B-23
Issue #15 - Welding of "D" Level Material Inside containment Subgroup C - Class "D" material installation inside containment does have a
_ potential effect'on:
. System # System Description Evaluation 43H RCB Hydrogen Recombiners/ During the evaluation of Analyzer Class "D" material installation inside 64 Control Element Assy. containment the work and Calculator material under review was verified by LP&L.
65B Incore Nuclear Contractor QA is.of Instrumentation satisfactory quality, and this issue does not have
, 65C Movable Incore Nuclear an adverse effect on the Instrumentation safety analysis, system operability or margin to t 69 Vibration & Loose Parts safety on these systems.
Monitor .
e D
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l 1
B-24
Issue #16 - Surveys and Exit Interviews of QA Personnel Subgroup C - An interview program was instituted by LP&L to provide an cdditional avenue of communication to elicit information on quality concerns from personnel prior to leaving the Waterford SES No. 3 project. The concern was that the LP&L program may not have promptly or thoroughly examined the cpecific areas of concern and the programmatic implications of these systems. l Issue #16 does have a potential effect on all systems in Table B-5.
The Evaluation reveals that all concerns are being reviewed under an improved quality concern program. Where there are issues not previously.. identified with potential safety related consequences, these issues are promptly reported to LP&L management. These concerns are properly addressed under LP&L required and approved management programs in a timely fashion. The program does not involve unreviewed safety issues.
e 1
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B-25
Issue #17 - QC Verification of Expansion Anchor Characteristics Subgroup C - Mercury, the subject of this concern, did install safety related instrumentation expansion anchors in these systems. A safety evaluation was performed to assure LP&L management that the system can be safely operated without compromising the health and safety of the public.
1; sue #17 does have a potential effect on:
System # System Description Evaluation 43H RCB Hydrogen Recombiner/ Inspection forms were used Analyzer that do not explicitly cover all inspection 64 Control Element Assy. attributes. The reinspec-tion of all Mercury installed N1 instrumenta-tion and subsequent engineering evaluations indicates that the issue of expansion anchor characteristic inspection forms have no safety significance for these systems.
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B-26 I
- - ~ - - --' ~ ' ' ' ' " ' "~
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Issue #18 - Documentation of Walkdowns on Non-Safety Related Equipment Subgroup C - Documentation of walkdown on non-safety related equipment does have a potential effect. A safety review was performed to assure LP&L Management that the System can be safely operated without compromising the health and safety of the public.
Issue #18 does have a potential effect on all systems in Table B-5.
The Evaluation included area inspections where the system is present and indicate no interactions of safety significance. Accordingly, this issue does not serve as a restraint to safe operation of these systems, and has been resolved and closed out by LP&L.
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B-27
Issue #19 - Water in Basemat Instruments J
Subgroup C - Water in basemat instruments does have a potential effect on:
System #' System Description Evaluation 15 Plant Monitoring Computer The present analysis for moderate energy pipe rupture flooding per the FSAR envelopes the concern for water seepage since this flow rate would be minimal. Accordingly, this issue does not serve
. as a restraint to safe operation of these systems, and has been resolved and closed out by LP&L.
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B-28
. Issue #20 - Construction Materials Testing (CMT) Personnel Qualifications
' Records The contractor in question did not do work on these systems.
There are no Subgroup C systems. j I
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O B-29
I' Issue #21 - LP&L QA Construction System Status and Transfer Reviews All significant documentation and hardware dispositions were_ identified ac the time status and transfer letters were transmitted for these systems.
There are no unreviewed safety questions pertinent.
There are no Subgroup C systems.
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B-30
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Issue #22 - Walder Qualifications (Mercury) and Filler Materials Control (Site Wide)
Subtroup C - The LP&L review of qualifications status documentation for all 3 Mercury welders has been completed and the program does have a potential impact on the system. The weldment filler material controls did apparently deviate from code requirements.
Issue #22 does have a potential effect on all systems in Table B-5.
The Evaluation contains a clarification of the review finding os. welder qualifications, and there are no potential unreviewed safety questions pertinent to this issue. "Rebaking" of low hydrogen electrodes was not practiced on the site and engineering _ justification demonstrates that while there were limited deviations from code specifications however this did not cause degradation of quality of weldment filler material.
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e B-31
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Issue #23 - QA Program Breakdown Betreen EBASCO And Mercury l i
The concern is not directly related to the systems under review and is considered to be programmatic in nature.
There are no Subgroup C systems.
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B-32
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. e l .e TABLE B-5 ISSUES No. 1 No. 2 No. 3 No. 4 No. 5 No. 6 No. 7 No. 8 8 Inspection Missing N! Instrumen- Lower Tier Vendor Docu- Disposition- Backfill Visual Exam-Personnel Instrument tation Ex- Corrective mentation - ing of Non- Soil ination of Issues Line Docu- pansion Loop Actions are Conditional conformance Densities Shop Welds mertation Separation not being Releases and Discrep . During l
SYSTEM Upgraded to ancy Reports Nydrostatic '
(A)(B)(C) NCRs ,
Testing
'15 - Plant Monitoring Computer A 5 A B C C C C A
- 22 Fire Protectica - Naloa A 5* A B C C C C A L .
43N - RCS Nydrogen Recombiner/ C C A B C C C C C Analyser a
64 - Control Element Assy. C 5 A B C C C C A Calculator 65B - incore NucIsar A B A . B C C t: C A Instrumentation 65C - Kaveble incera Nuclear A B A B C C C C A Instrumentarica 69 - Vibration & Loose Parts A B A B C C C C A Monitor . . .
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B-33 1
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t TABLE B-5 ISSUES No. 9 No. 10 No. !! No. 12 - No. 13 No. 14 No'. 15 Bo. Idb 'I Welder Car- Inspector Cadwelding Main Steam- Missing NCRs J.A. Jones Welding of Surveys and tification Qualifica- line Framing Speed "D" Level Exit Interviews- ,
tions (J.A. Restraints Letters Material- of d)A Personnel l Jones & and EIRs Inside' SYSTEM Fegles) Containment 15 - Plzat Monitoring Computer A A C A C C A C 22 Fire Protection - Halon A A C A C C A C 43H ' - RCB Hydrogen Recombiner/ A A C A C C C C Analyzer b4 - Control Element Assy. A A C A C C C C Calculator b58 - Ipcore Nuclear A A, C A C C_ C C lutrumentation b5C - Movable Incore Nuclear A A C A C C C C Instrumentation b9 - Vibration & Loose Parts A A C A C C C C Monitor
. 9 B-34 l J
o 9
TABLE B-5 ISSUES No. 17 . No. 18 No. 19 No. 20 No,' 21 No. 22 -No. 23 l QC Verifi- Documen- hter in Construction LP&L QA Wider QA Program cation of tacion of Basemat Materials Construc- Qualifica- Breakdown Expansion Wikdowns on Instruments Testing tion System tions Between Ebasco Anchor Char- Non-Safety l (CMT) Status and (Mercury) and Parcury acteristics' Related Personnel Transfer and Filler Equipment Qualifica- Reviews Material tion Records Control SYSTEM (Site Wide) 15 -
Plant Monitoring Computer A C C A A C A 22 Fire Protection - Halon A C A A A C A 43N - RCB Hydrogen Recombiner/ C C A A A C A Anilyzer 54 - Control Element Assy. C C A A A C A Cilculator 55B - IIcore Nuclear A C A A A~ C A Inttrumentation ESC - Novable incore Nuclear A C A A A C A Isztrumentation 59 - Vibration & Loose Parts A C A A A C 'A Honitor O
B-35
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ATTACHMENT C STATUS OF CO.MPLETION OF FUEL LOAD ITEMS J
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STATUS OF COMPLETION OF FUEL LOAD ITEMS LICENSING COMMITMENTS All licensing commitment action required by LP&L are completed.
SIGNIFICANT CONSTRUCTION DEFICIENCIES Final reports or interim reports with justifications .for interim operation will be complete and submitted to Region IV by COB this date.
INSPECTION REPORT ITEMS Completion of LP&L required actions for inspection report items is complete with the exception of five (5) items from a recent inspection report (84-31) which are expected to be complete by 11/5/84.
FUEL LOAD (MODE 6) PREREQUISITE WORK ITEMS
- Work items required for Mode 6 will be complete by COB this date.
TECHNICAL SPECIFICATION SURVEILLANCES Surveillances required by technical specifications prior to entering into Mode 6 i
will be complete by COB thfs date with the exception that specific items which are related to being performed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to fuel load and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to fuel load. These exceptions will be completed on the required schedule following a licensing decision and establishment of a fuel load date.
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