ML20095F544
| ML20095F544 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/20/1984 |
| From: | Leddick R LOUISIANA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| W3B84-0473, W3B84-473, NUDOCS 8408270303 | |
| Download: ML20095F544 (27) | |
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Louisiama,
,.a ouAmoNoe s1nE<1 POWER & LIGHT / P O BOX 6008
- NEW ORLEANS. LOutSIANA 70174 (504) 366 2345 EuSNSYSSE ROTH S. LEDDICK Senior Vce President August 20, 1984 Nuclear operations W3B84-0473 Mr. Darrell G. Eisenhut Director of Nuclear Reactor Regulation l
Division of Licensing U.S. Nuclear Regulatory Commission Wa sh ing ton, D. C.
20555
SUBJECT:
Program Plan for Resolution of Pre-Licensing Issues
REFERENCES:
- 1) LP&L Letter W3B84-0459, "Waterford 3 SES Revised Program Plan" dated July 27, 1984 2)
Public Meeting on Subject Issues held in Your Offices on August 17, 1984
Dear Mr. Eisenhut:
On behalf of Mr. Cain, and per your request in the reference 2 meeting, this i
submits a revised attachment to the Program Plan, ref erence 1, formalizing the changes in the attachment discussed during the meeting. The attachment is re-issued in its entirety. In those instances in which changes were made, the page indicates, " Revised - 8/20/84", and the portions changed are indicated by sidelines.
l The meeting was very beneficial in helping us to formulate approaches to the issues raised in your letter of June 13th, and to address all of your concerns.
Please advise of any comments at your earliest convenience.
S cerely, I
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R.S. Leddick 60-3x2 RSL:DED:pbs 8408270303 G40920 Attachment PDR ADOCK 05000382 P
PDR cc: With attachment
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'"EIh Mr Dirrall Eirenhut, Dircct:r Pzg2 2 W3B84-0473 August 20, 1984 cc:
Mr. R.S. Leddick Mr. J. Harrison Waterford 3 QA Team Leader Mr. D.E. Dobson Region III 700 Rosevelt Rd.
Mr. R.F. Burski Glen Ellyn, IL 60137 Mr. K.W. Cook Mr. J.E. Gagliardo Director of Waterford 3 Task Force Mr. T.F. Gerrets Region IV 611 Ryan Plaza Suite 1000 Mr. A.S. Lockhart Arlington, TX 76011 Mr. R.P. Barkhurst Mr. S. Levine NUS Corporation Mr. L. Constabic 910 Clopper Road USNRC - Waterford 3 Gaithersburg, MD 20878 Mr. J.T. Collins Mr. R.L. Ferguson U.S. Nuclear Regulatory Commission UNC Nuclear Industries Region IV P.O. Box 490 611 Ryan Plaza Suite 1000 Richland, WA 99352 Arlington, TX 76011 Mr. L.L. Humphreys Mr. D. Crutchfield UNC Nuclear Industries U.S. Nuclear Regulatory Commission 1200 Jadwin, Suite 425 Washington, D.C.
20555 Richland, 99352 Mr. G. Knighton, Chief Mr. Gerald Charnoff Licensing Branch No. 3 Shaw, Pittman, Potts & Trowbridge Division of Licensing 1800 M. St. N.W.
Washington, D.C.
20555 Wa sh ing ton, D.C.
20555 Mr. M. Peranich Mr. J. Hendrie Waterford 3 Investigation and 50 Bellport Lane Evaluation Inquiry Report Team Bellport, NY 11713 Leader 434 0 E.W. Hwy. MS-EWS-3 58 Mr. R. Douglass Bethesda, MD 20114 Baltimore Gas & Electric 8013 Ft. Smallwood Road Mr. D. Thatcher Baltimore, MD 21226 Waterford 3 Instrumentation & Control Team Leader Mr. M.K. Yates, Proj ect Manager 7920 Norfolk Ave. MS-216 Ebasco Services, Inc.
Bethesda, Md 20114 Two World Trade Center, 80th Floor New York, NY 10048 i
Mr. L. Shao Waterford 3 Civil / Structure Team Leader Mr. R. Christesen, President 5650 Nicholson 1,n.
Ebasco Services, Inc.
Rockville, MD Two World Trade Center, 93rd Floor New York, NY 10048
PROGRAM PLAN ISSCE & TITLE DESCRIFTTON OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT 1.
Inspection Personnel Verify the proper A verification program has been established to To Be Determined Issues certification of site review the professional credentials of 100% of the QA/QC personnel or site QA/QC personnel, including supervivors and requalify the work managers. The discussion that follows applies to performed by these all contractors except J.A. Jones. Fegles and CEO.
pe rsonnel.
which are addressed in Issues 10 and 20.
Criteria for certification or qualification of QA/QC personnel will be based on QA program requirements and contractual commitments.
1 The adequacy of credentials to support certif-ications and qualificacions is being reviewed.
Criteria have 'ocen established to sort personnel files into 3 groups:
A. Qualifications deemed adequate B. Inadequate documentation to perform evaluation Revised - 8/20/84 C. Qualifications questionable.
Other site files will then be researched and con-tractors contacted for personnel in groups B and C to verify their acceptability. In addition, background verifications will be performed for all personnel in all groups. If certitication of an individual can not be justified, he will be placed in a fourth group designated group D (Qualification inadequate). Appropriate site nonconformance documentation will be initiated to document evaluation of safety significance and corrective actions, including reinspections of work performed as necessary.
For Ebasco. LP&L. and other site construction j
related QA/QC personnel remaining on site, a reverification of proper certification is being accomplished in accordance with ANSI-N45.2.6-1973.
Quality Control functions currently being under-taken as part of the walkdowns in progress are being performed by personnel reverified as qual-ified under ANSI-N45.2.6-1973.
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PROCRAM Pl.AN l
ISSUE & TITI.E EESCRIPTION OF TSSUE
- 1. PAL APPROACH TO RESOLUTTON CURRENT AS$rSSMENT 1.
Com't s
Initial review of qualifications if 951 complete.
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Background checks are 15% complete.
l A sample reinspection of Mercury installations is l
being performed by 1.P&L.
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v PROGRAM PLAN ISSUE & TITLE Df:SCRIFTION OF ISSUE LP&l, APPROACII TO RESOLUTION CURRENT ASSESSMENT 2.
Missing N1 Instrument Terify compliance with Prior to the NRC inspection, the Ebasco Quality The combination of the reviews Line Documeetation 1,RC requirements for N1 Assurance Installation Records Croup had reviewed described has provided assurante instrumentation the ASME Section III portions of the NI instrument that documentation is available to j
installations.
installations. Full documentation on the assure the quality installation of installations under the scope of this review is all N1 instruments.
l available.
The scope of this concern has been narrowed to 12 installations. 4 we;ded and 8 threaded. The documentation on the ANSI B31.1 portions of these instrument installations that were installed with class breaks (i.e. ASME Section III to ANSI B31.1) has also now been reviewed and is summarized as follows:
1.
Final visual inspection documentation is now Revised - 8/20/84 available.
2.
Ten installations have documented hydrostatic tests. The remaining two are HVAC welded connections and do act require hydrostatic testing.
3.
Material traceability to the point of install-ation is not available. however. Certificates of Conformance to specification requirements are available.
4.
Welder identifications are not available in all cases. However, all Mercury welders were required by procedure to demonstrate qualifi-cation for the appropriate welding process prior to being issued weldrod.
5.
Nondestructive testing data is not required for 4
these installations.
We have considered other design changes related to the classification of N1 instrument loops and have concluded that a similar situation has not occurred.
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s PROCRAM PLAN ISSUE & TITLE DESCRTFTION OF ISSUE LPSL APPNDACM TO RESOLUTION CURRENT ASSESSIENT 2.
Can't To essere that the documentation for all NI instrumsets is consistent, the ANSI B31.1 portions of the 12 installations will be reworked, rei==paeted and documented la accordance with the ASIE III re p trements la the site program.
Revised 8/20/84 e
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P90 CRAM PTAN ISStE & TIT 1.E DFSCRIPT10N OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT 3.
Instrumentation Correct separation NCR-W3-7702 covers the system 52A problems Although separation violations have Expansion Loep criteria violations and has been dispositioned to remove the been found, none so far identified Separation found in system 52A and expansion loops in question and replace with would affect plant safety had they provide a progras for straight tubing.
been left uncorrected.
review of other safety-related systems for NCR-W1-7730 was generated to ciack the generic This provides a high level of separation violations concern of tubing separation. In order to provide confidence that other design and take the necessary a basis for determining the scope of our approach, considerations and walkdowns (i.e.
corrective actions.
a sample of 45 additional instrument installations pipe rupture / jet impingement a
was reinspected. Those chosen were in congested analysis, non-seismic over seismic areas where separation violations would have the criteria and walkdowns) in i
highest probability of occurrence. Thirteen combination with the tubing deficiencies were found out of 276 locations, separation criteria have provided 4
and were evaluated. None required rework, adequate protection for the l
Revised - 8/20/84 instrument installations.
A QC verification of all other lines (approximately 64) with redundant tubing runs in A final determination of ssfaty proximity of each other has been performed.
significance will be made upon com-plation of the reinspection.
Of the deficiencies noted, the preliminary evaluation had determined that one rework is required.
PROCRAM PLAN ISSUE & TITLE DESCRIPTim 0F ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT 6.
Lower Tier Corrective LPEL shall review all LP&L has to date reviewed all FCRs. DCNs. EDNs and The current review has demonstrated Actions Are Not Being FCRs. DCNs. EDNs. and Tompkint-Beckwith DNs cited by the NRC in the that there has been adequate QA/QC Upgraded to NC1s T-R DNs to assure that Description of Concern, as well as all voided EDNs.
involvement in all lower tier proper corrective documents with regard to 10CF150 action was taken.
LP&L's review has established that only two of the Appendix B corrective action and including an adequate fourteen cited FCRs/DCNs and three of the 22 cited non-conformance requirements. This review by QA. This EDNs and T-B DNs should have required an NCR.
involvement ensures that appropriate corrective action shall In each case hewever, there was no safety signifi-corrective actions, specific a,nd inciande the steps cance as regards 10CFR50.55e and 10CPR21. None of generic. are identified.
required by 10CFR50 the voided EDNs required an NCR that was not Appendix 5. Criterion generated.
Our current evaluation of the j
XVI Corrective Action examples of lower tier documents and for Construction The response to this concern will provide an cited by the NRC demonstrates that Deficiency Reporting, assessment of the lower tier document reporting alth wgh a small percentage should 50.55(e). Also, system. It will verify that it was structured in have been upgraded to NCR'e under included in this review such a manner that procedures. integral to the the quality program in effect, none shall be the Quality Program, provided a sound basis for had safety significance.
examination of improper decisions regarding the severity level of documents voiding of all other used to report deficiencies. The assessment Thus. LP&L has confidence that the design changes or specifically considers QA and QC reviews of sample review will provide discrepancy notices engineering / construction judgements on deficiencies additional evidence that the that affected safety-as it relates to the corrective action and noncon-projects' system of " checks &
related systems or that formance requirements of 10 CFR 50 Appendix 5 balances" ensures that, despite were misclassified as and the reporting requirements of 10 CFR 50.55(e).
isolated cases of judgemental or i
safety.
interperative errors, all lower tier A random sample of approximately 940 FCRs. DCNs.
documents, as well as FCRs and DCNs EDNs and T-3 DNs have been formally reviewed to receive adequate evaluation for determine if any should in fact have been reported safety significance.
as NCRs.
Approximately 7Z should have been NCR's.
None of these were judged to have been reportable under 10CTR50.55e or 10CTR21. The review also indicated that the dispositioning would not have changed had the documents been upgraded.
No additional review is required as the sample results give a 95% confidence level that 95% of the unsampled documents contain no reportable issues or a potential change in dispositioning.
PROCRAM FLAN IS$t*E & TITLE DESCRIF*IO!t Cy ISStt LP&I. APPROACH TO RESOLUTION CUREDIT ASSESSMDET
- 5. Vendor Documentation The concern relates to Records associated with CE material and equipment The existence of Conditional Conditional Releases whether shortcomings in were re-reviewed and conditional Certifications Certifications on CE equipment contractor's identified. An assessment of the potential for reflected incomplete Purchase documentation, the existence of other manuf acturing open items Orders, not hardware or sof tware particularly Combustion not being tracked in the Master Tracking System deficiencies.
Engineering's, which (MTS) was conducted. It led to the conclusion existed at t's time the that the potential for a similar situation existed No items of safety significance have e
material was supplied have only in areas where problems are identified off-been found on the other been site. As a result of this concarn the following corrected, site relating to i
areas are being evaluated:
material to be shipped to the three areas of concern.
Concerns noted by vendor QA Reps on Release for shipment forms.
NCRs controlled by Ebasco's Bone Office Material received at the site under manufacture, deliver and erect type contracts.
To date 12 of 14 CE remaining Conditional i
Certifications have been changed to unconditional.
The remaining 2 will have Unconditional Certifications by 9/15/84. The issues that required resolution deal with technical manuals and have no effect on equipment operation.
The review conducted on the other three areas of potential concern is complete. No items adversely affecting plant safety were identified.
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ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT 6.
Diapositioning of Some Ebasco and Mercury First, the in-place program for handling of lower To date none of the potentially non-conformance and NCRs and Ebasco DRs were tier documents such as DRs will be discussed.
Discrepancy Reports questionably deficient NCRs that have been reviewed and evaluated have safety dispositioned and LP&L Second, the specific NCRs and DRs cited by the NRC significance.
shall propose a program have been evaluated for proper designatten.
to assure all BCRs and disposition, and implementation of corrective action A final determination of safety DRs are appropriately under the existing quality program. Six of the significance will be made upon l
upgraded, adequately fifty NCRs were determined to not have been j
dispositioned and adequately dispositioned and are under evaluation.
potentially deficient NCRs and the completion of the evaluations of corrective action field verification.
Third, a program review of Ebasco NCRs was started completed and that any problems detected are by LP&L in January,1984 to assess the validity of I
corrected, the disposition, the corrective action,taken, the
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completeness of the documentation, and their proper closure. Approximately 499 (6%) of the more than v
7750 NCRs reviewed have been identified as having Revised - 8/20/84 potential deficiencies in the above attributes.
These are being evaluated. The deficiencies that have thus far been evaluated have no safety significance.
Fourth, a field verification will be conducted on a random sample of 124 of the potentially deficient l
Ebasco NCRs to ensure that the hardware and/or softvare corrective action has been completed.
Finally, the Mercury NCR's and Ebasco DR's cited by the NRC have been reviewed against the attributes mentioned in the concern. Information from this review is currently being evaluated.
y PROGRAM PLAN ISStlE & TITLE DFSCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT AS!;ESSMENT 7.
Backfill Soil Conduct a review of all A review of backfill records (i.e. backfill soil The soll density is in compliance Densities soil packages for density laboratory test data and inspection with specification requirements.
l completeness and reports) was initiated to determine completeness technical adequacy.
and technical adequacy. A three stage program for Where records are the evaluation of soil backfill densities was missing or technical implemented to (a) locate all backfill soil data.
problems are defined.
(b) review the test records for completeness and take corrective action.
utilize these for the construction of relative density overlay plots, and (c) evaluate documentation and overlays for compliance with specification requirements.
Revised - 8/20/84 It was determined that a complete set of soils test data exists at the site, and that the field and laboratory testing and insitu relative density of the class A backfill were in compliance with specification requirements.
A review for completeness of the remainder of the soil package data for attributes other than density, which includes all inspection reports, is complete; results indicate specifications were met.
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PROGRAM PlJL1 i
ISSUE & TITLE DESCRIPTION OF ISSUE 1.P&L APPROACH TO RESottTTION CURRENT ASSESSMDIT 8.
Visual Framination Document inspections Shop welds were inspected and accepted during No deficiency exists.
of Shop Welds during of shop welds during hydrostatic tests by an Authorized Nuclear Hydrostatic Testing hydro tests or other-Inspector.
vise verify such inspection.
The ASME N-5 code data reports also confirmed that there was inspection of shop welds.
j The methocology of the field hydrostatic tests provided additional assurance that shop welds were l
inspected.
t A statement from the authorized Nucle s Inspector i
has been received confirming that shop welds were inspected.
Revised - 8/20/84 4
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.. I PROGRAM PLAN TSSUE a TITLE DESCRTPTIN M TSSM USL APPROACE 10 RESOLUTION CURRENT ASSES $NEart 9.
Eelder Certification Locate missing documents NCR W3-7549 was generated on 2/1/84 to track this.
All umiding sealuated to date has for instrument cabinet problem. No documsstation was found on three of been found acceptable.' A final welda and determine if the eighteen cabinete ar.d partial documentation determination of safety significance welders were appro-found ce four. All seven were reinspected and will be ande upon campistion of the.,
priately certified.
found acceptable after evaluation by Engineering.
review.
Take appropriate action to assure the quality As a result of the missing documentation, a of the supports if review is being performed to deteruime other.
documentation cannot miscellaneous cases where J.A. Jones performed be located.
welding. Documentation for the welding identified will be reviewed or inspection perforand where l
required.
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1 PROCRMt FIES IsSEE & TITLE DESC2f FTTCat CF 15511 LP&L APPROACH TO RESOLUTION CURRENT AS9ESSMENT
- 10. Inspector Qasli-Terify the proper certi-A verification program has been established to To Be Determined fication (J. A.
ficatico of QA/QC review the professional credentials of 100% of the Jones and Fegles) persammel and evaluate site QA/QC personnel for J.A. Jones and Fegles, in-the impact of any cluding supervisors and managers. Criteria for deficiencies found.
certification or qualification of QA/QC personnel wili be based on QA program requirements and contractual commitments.
The adequacy of credentials to support certifications and qualifications is being reviewed. Criteria have been established to sort personnel files into 3 groups:
gewised - 8/20184 A. Qualif1 cations deemed adequate i
- 3. Inadequate documentacima to perform evaluation C. Qualifications questionable other site files will then be researched and J.A.
Jones and Fegles contacted for personnel in groups B and C to verify their acceptability. In addition. background investigations will be performed for all personnel. If certification of an l individual cannot be justified, he will be placed in a fourth group designated group D (Qualification ind.quate). Appropriate site nonconformance documentation will be initiated to document evalettion of safety significance and corrective acttu s, incladt_.s.sinspection of work performed as accessary.
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PROGRAM PLAN ISSUE & TITLE
-DESCRIPTIObi OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT
- 11. Cadwelding Provide the cadweld The cadweld records have been transcribed onto Based on the previous disposition of.
- data for the project in computer data storage. This includes the placement NCR W3-6234, there is no reason to.:
such a form that it can area, cadweld number. cadwelder, bar size, bar
. anticipate any significant be readily compared to position, visual test. production test, sister deficieucy, the testing criteria test, cadwelder qualification dates and 1
used for the Waterford inspector name and qualification dates.
3 project with data broken down by various' In this form the cadweld data can be called up by categories. Provide any of these attributes to expedite review for data on welder quali-specification compliance or other reason. Also.
fication and requali-physical' location of.cadwalds may then be readily.
i fication including obtained by reference to the concrete placement dates.
lift diagrams which locate the placements.
Prior reviews have 'already been accomplished.
under NCR W3-6234 (opened 5/16/83) and nonconforming conditions resolved. A re-evaluation q(
is being conducted now that the cadweld data is in
- ghv, a more systematic, auditable format.
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i PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROA~H TO RESOLUTION CURRENT ASSESSMENT
- 12. Main Steamline Complete the document-SCD 78 was resolved and subsequently reopened upon All corrective action is in progress i
Framing Festraints ation for all discovery that inspections in the steam generator in ace.;,rdance with the criteria connections in the framing were not complete. NCR-W3-7736 was issued to stated in the SCD 78 Documentation steam generator framing, track resolution of the deficiency. A 1001 QC Package.
reinspection of steam generator framing connections as well as a review of the American Bridge work-scope against the scope of SCD 78 reinspections was performed.
This verified that only steam generator framing connections were omitted from the original scope of SCD 78.
Reinspection of all American Bridge bolted connections is complete. Corrective Action is in progress.
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Revised - 8/20/84
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5 if PROGRAM PLAN ISSUE & TITLE
~ DESCRIPTION OF TSSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT l
13.
Missing NCRs LP&L shall obtain
. The concern specifically stated that there were 10 As a result of the review of Ebasco the missing NCR's, NCR numbers missing from the QA vault and card NCR's, all not on file in the QA-explain why these NCR's index file. This is correct and is due to the fact vault were either found located or were not maintained in that all of these NCRs were voided or cancelled
-probably o_t issued.
the filing system, review prior to issuance as indicated in the manual log l
them for proper voiding, that was maintained at that time. The purpose of the and assure that when an card index file is to locate NCRs which are actually issue is raised to an on file in the vault, not those that were voided or NCR it is properly filed never issued.
l for tracking and closure.
However, in response to the NRC's general statement that "Others were also noted to be missing from the Ebasco QA Vault". LP&L has:
Revised - 8/20/84
- keviewed for accountability all Ebasco Site and New York Office issued closed or voided NCRs for accountability (8200 total NCRs).
- Provided substantiating evidence on those NCRs indicated as void in the logs.
- Provided substantiating evidence that NCR numbers in the sequence indicated not to have been assigned to an NCR is correct.
A review of all. Mercury NCR's to insure they were properly filed, tracked and closed is in process.
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PROGRAM PLAN
' ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION -
CURRENT ASSESSMENT 14.
J. A. Jones Speed During the Ebasco QA First, a review has been conducted of correspondence No problems of safety significance '
letters and EIRs review of J. A. Jones between J. A. Jones and Ebasco via Speed letters and were found in the J.A. Jones speed letters and eng-EIRs. Second, correspondence which conveyed design correspondence. The review of other~
ineering information changes to J. A. Jones without reference to contractors is nearing completion and requests, several items follow-up action to formalize the changes was no problems of safety significance that could affect plant conducted to determine safety significance, have been found to date, safety were noted.
Based on its sample of Of approximately 1100 J.A. Jones documents reviewed, these actions, the staff 271 appear to convey design changes. These 271 have does not expect that any been evaluated and researched on a case-by-case of these items will basis and determined to be acceptable as is even significantly affect though they represent a procedure violation. No plant safety.
safety problems have been identified.
Nevertheless, the app-licant should complete Third, a minimum of 10% of engineering information the actions identified requests generated by other safety-related M
in these reviews and contractors was sampled to determine if they used W
issues raised shall be design changes conveyed by such informal documents.
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resolved promptly.
The sample size was expanded depending on the 04 results of the initial review.
Fourth, any design changes identified are being reviewed for safety significance.
The initial review of the other safety related contractors has been completed. No safety related problems have been identified to date.
Additional sampling is being performed on three j
contractors.
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PRCSRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSZSSMENT r 15. Welding of "D" level Locate the documentation The CB&I QA manual requirements for documentation.
Preliminary results from the ongoing Material Inside for "D" level material of fit-up and final weld inspections do not apply, inspection indicate that the "D" Containment welding and verify the per their manual, to "D" material welds. This material welds are acceptable. A adequacy of the documentation is therefore not available for all final determination of safety inzormation or perform a "D" material welds.
significance will be made upon material analysis and completion of the reinspection.
NDE work, or rework The "D" material welds were performed by the the welds.
same welders and inspected by the same welding supervisors and to the same standards as the rest of the CB&I work for which documentation is provided. Considering this, and the quality of CB&I work on this project. it is not expected that any quality problem exists with "D" material welds. LP&L will, however, in accordance with a formal QA procedure:
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- Strip paint off of a 5% sample of "D" material welds for which no documentation is available eq q.
and provide full visual inspection, i
- Reinspect another 5% sample of "D" material welds without stripping paint.
The results of this reinspection will determine if there is a need to expand the sample size.
To address the NRC's specific concerns. Ebasco has evaluated the containment spray piping veld attachments. All containment spray piping veld attachments were installed and documented by Tompkins-Beckwith except for two. The results so far demonstrate that failure of these two welds will not preclude the piping from performing its-design basis function. Ebasco is presently finalizing the analysis by redistributing the loads to other supports under the assumption that the two "D" level attachments do not exist.
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PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION '
CURRENT ASSESSMENT
- 16. Surveys and Exit LP&L should develop and LP&L has secured the services of Quality Technology Reviews to date have not identified Interviews of QA implement a formal program Company (QTC) to implement an enhanced program to safety concerns not already Personnel for handling issues raised conduct exit interviews of personnel departing the-identified.
by individuals. One of site. QTC will also review the interviews conducted the first tasks to be to date to assess whether the corrective actions dealt with by the program for the concerns identified thereon are should be the review of appropriate. Procedures have been approved which the responses previously assure management involvement.
provided to the QA survey and during the exit interviews.
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PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT
- 17. QC Vsrification of The NRC is concerned The review of this matter indicates that six of the
. The review of Hercury QA records Expansion Anchor whether there was seven cited QC reviews were made as required by the conducted by Ebasco prior to LP&L-Characteristics sufficient QC verifica-drawings which were referenced on the inspection turnover, the resultant field i
tion of the character-forms. This was substantiated by a thorough review verifications, and the directions i
istics necessary to of Mercury quality records. LP&L will prepare a provided by the documents referenced ensure proper installa-response discussing the incorporation of drawings in the Mercury Expansion Anchor.
tion of concrete into the procedure, training of Hercury personnel, Procedure provide assurance that QC expansion anchors the QC review and substantiation of records and verification was adequate.
installed by Mercury.
evaluation of the cause of the problem.
The seventh attribute cited by the NRC is spacing between anchor and embedded plate. The response will refer to Ebasco design drawings which allow anchor plates to overlap and be welded to embedded plates. It will also provide the results of an anaylsis performed on worst case situations of Mercury anchor plates butting up against embedded plates of different sizes which demonstrates that the anchor and embedded plates are still capable of Revised - 8/20/84 withstanding the original design loads.
Since LP&L is performing a sample reinspection of Mercury installations, attributes have been incorporated into the program for spacing and embedment. This will provide assurance that installations are according to design.
No revision is necessary to procedure SP-666 since this procedure is no longer in use at the gite, I
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PROGRAM PLAN I
i ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION l
CURRENT ASSESSMENT
- 18. Documentation of Documentation should be Documentation attesting to the scope, conduct and' The design and construction of Walkdowns of Non-provided that clearly resulte of the walkdowns will be provided. LP&L Waterford-3 considered interactions Safety Related shows what equipment was will provide documentation that shows the equipment of non-seismic Mechanical.
Equipment reviewed during the that was reviewed during the walkdowns.
Electrical, HVAC, Civil and walkdowns and on what Instrumentation equipment with bases it was concluded The reeponse to this issue will also establish that safety-related equipment. That that the installation in our opinion. the design and inatallation walkdown verified that such was acceptable.
adequately considered the effects of interactions of interactions do not constitute a non-seismic with safety-related systems during ae.
safety concern.
SSE.
In addition, a walkdown of the non-saf:ty related portions of the Instrument Air Sys'.en in the *ee: Lor Containr.ent Building, Reactor Aux!.liary Ouilding and the Fuel Handling Building will be o*:sormed. The walkdown will be accomplished utilizing an LP&L procedure and a multi-discipline Engineering Croup.
Revised - 8/20/84
W PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT ~
- 19. Water in Basemat Review all conduit that A valkdown was performed which identified 28 places There was never a path for ground Instrumentation penetrates the basemat where wetness due to seepage from conduits was found water to flow in sufficient quantity Conduit and terminates above the and 12 places where evidence of past leaking from to flood the auxiliary building.
top of the basemat to conduits was found. Neither the present slow basement, even before the seals were assure that these seepage thru some of the seals nor the seepage that installed and before the temporary potential direct access would result from a gross failure of the seals conduits were grouted.' The floor paths of water are presents a flooding hazard. The decision to replace drain and sump pump system was more.
properly sealed.
the seals will be based strictly on operational and than adequate to handle the quantity maintenance considerations. Any replacement seals of water which entered the building vill consist of a light density silicone elastomer during construction, and is adequate which has the capability to stop the seepage.
to handle the much reduced quantity 2
presently observed.
Temporary conduits which enter the basemat from outside, and which once allowed passage of ground j
jfI water in quantities that required periodic pumping, have now all been pressure grouted and their
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temporary blockout pits filled with concrete and no longer serve as a leak path for ground water.
Two piezameters still in use utilize one riser which will be sealed with a light density sslicone elastomer. The standpipe of one pie.ometer no longer in use will be p casure grouted.
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PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT
- 20. Construction verify the proper CEO has been contacted to assist in providing
' The initial evaluation'of this Materiala Testing certification of const-additional background information or justification concern indicated "no safety (CMT) Personnel ruction materials testing for certification of QA/QC personnel identified significance", based on evaluation of Qualification personnel, as part of NCR #W}-F7-116.
nonconformance report FW3-F7-Il6. We Records.
are again reviewing the A verification program has been established to qualifications of QA/QC personnel on review the professional credentials of 100% of the the nonconformance report and others GEO CMT site QA/QC personnel, including supervisors to reconfirm our initial evaluation, and managers. Criteria for certification or qualification of QA/QC personnel will be based on QA program requirements and CE0's contractual requirements.
4 The adequacy of credentials to support certifications and qualifications is being reviewed.
Revised - 8/20/84 Criteria has been established to sort personnel files into 3 groups.
A. Qualifications deemed adequate.
~ ~ " ~ ~ ' ~ ' '
B. Inadequate documentation to perform evaluation.
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C. Qualifications questionable Other site files will then be researched, and CEO contacted for personnel in groups B and C to verify their acceptability. In addition, background investigations will be performed for all personnel.
If certification of an individual can not be justified, he will be placed in a fourth group designated Group D (Qualification inadequate).
Appropriate site nonconformance documentation will be initiated to document e'saluation of safety significance and corrective actions, including reinspection of work performed as necessary.
For CEO QC Inspectors remaining on site, a reverification is being completed of proper certification in accordance with ANSI-N45.2.6-1973.
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PROGRAM PLAN ISSUE & TITLE DESCRTPTION OF ISSUE LP&L APPROACH TO RESOLUTION Ct!RRENT ASSESSMENT' 21 LP&L Construction
- f. concern exists over A review of transfer correspondence on the A review of 100% of System Status and whether construction systems which were the cause of this concern.
turnover / transfer correspondence i
Transfer Reviews, deficiencies were has been performed. A review has also been showed no additional correspondence properly closed out
}
conducted to verify that deficiencies in was outstanding beyond that or identified during transferred systems had no impact on testing.
previously identified. Deficiencies the process of i
transferring systems A review was also conducted of hardware and sof t-identified on the outstanding correspondence (13 SUS).have been
.from construction to i
ware comments generated during status and trans-reviewed by LP5L start-up/.
plant operations.
fer of safety-related systems.
l operations and it was determined that there was no impact on testing.
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PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ' ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT
~'
ii 22.
Welder Qualification Verify welder qualif-The welder documentation is available which All welders were found to be properly-(Mercury) and Filler cations or assure the demonstrates that the welders were properly qualified. NCR-W3-7724 addressed and Material Control quality of all welds.
qualified, resolved qualification sheet errors (Site Wide) for 3 welders (clerical errors which Provide engineering just-The response summarizes the site requiresents for.
were committed after the welders left ification for the allow-handling of welding electrodes and demonstrates that site).
ance of "rebake" temper-ASME code requirements are met; and that AWS DI.1 atures and holding times code requirements, through a documented deviation to Code requirements for receiving that differ from the the holding oven temperature, are also met.
shipping, storage and issuing and requirements of the ASME control of welding electrodes were and AWS Codes.
met.
The only deviation from explicit code requirements was a documented reduction in specified holding oven temperatures.
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-M' PROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT-
- 23. QA Program Breakdown LPSL shall provide an First, LP&L is conducting a thorough review of 'the
.To date the specific issues involve between Ebasco and assessment of the overall corrective actions associated with the 1982 NRC inadequate or inconsistent closure.
-QA program and determine enforcement actions and civil penalty to determine,
documentation, and not hardware.
cause of the breakdown, the adequacy of follow-up related to corrective impacting concerns.. Thus far the -
together with corrective action commitments.
review indicates that there are no action to prevent open items affecting plant safety.
recurrence. This overall Second. LP&L is conducting a thorough review of its assessment is necessary QA audit program which has been in effect since July to provide assurance that 1982. Particular attention will be.placed on audits'.
the QA program can related to Mercury activities. This review will function adequately when include an evaluation of the methods used for the plant proceeds into determining cause of identified problems and the operation.
systems used to assure effective follow-up and continued compliance with corrective action commitments.
p e
Third LP&L is performing an overail assessment of s
n-the LP&L QA construction program based on the results of the above reviews co identify lessons s
'Ie learned and to determine if any improvements are required to assure adequacy of future operational QA program activities.
The above actions are ongoing. Based on efforts to date, it is believed that LP&L can demonstrate that the extensive management and quality assurance actions taken by LP&L. Ebasco and Mercury sub-sequent to June,1982 were appropriate; that most of the problems identified were part of the carrective actions on work previously done and are not indicative of continued inferior performance; and that the partial program breakdown did not persist.