ML20096B218

Forwards Responses to NRC Program Plan for Resolution of Prelicensing Issues 5,7 & 21,per . Rept on Review & Analysis of Soil Backfill Densities in Response to NRC Concern 7, Also Encl

ML20096B218
Person / Time
Site:	Waterford
Issue date:	08/27/1984
From:	Cain J LOUISIANA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML20096B223	List: ML20096B218 ML20096B229
References
W3B84-0475, W3B84-475, NUDOCS 8409040047
Download: ML20096B218 (27)

Text

_ _, _ _ _ _ _ _ - _ _ - _ - -

{[g - b32 Louisiama es,-ermeer P O W E R & L I G H T ! NEWCALEANS.LOUsuWA m Oxe -

70160 9 [5041595-2204 MIDDLE SOUTH

, UTIUTIES SYSTEM August 27, 1984 J.M. CAIN lhesident and Chief Executive Officer W3B84-0475 Director of Nuclear Reactor Regulation ATTN:

Mr. Darrell C. Eisenhut, Director Division of Licensing U.S. huclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

Waterford 3 SES Partial Response to Items from Waterford Review Team

REFERENCES:

1) Letter, D.G. Eisenhut to J.M. Cain, "Waterford 3 Review," dated June 13, 1984

2) Letter W3B84-0473 R.S. Leddick to D.G. Eisenhut,

" Program Plan for Resolution of Pre-Licensing Issues" dated August 20, 1984

Dear Mr. Eisenhut:

The purpose of this letter is to submit Louisiana Power & Light's responses to issues 15, 7, and 21 as set forth in your June 13, 1984 letter (Reference 1).

The responses follow the approach set forth in Attachment i to the Program Plan sent to you by LP&L on August 20, 1984 (Reference 2).

The responses have been reviewed and verified by LP&L QA in accordance with procedure QASP 19-13.

The designated subcommittee of the Waterford Safety Review Committee also has reviewed the adequacy of the responses for resolving the issues raised. The subcommittee scope of responsibility does not include independent validation of the facts.

The Task Force has indicated by separate correspondence (enclosed) that it is satisfied with the logic of the responses, however, they have not yet completed their independent validation of the facts.

The Task Force has committed to notifying me and the NRC immediately should they find significant deviations in the course of their validation.

In the event of such notification, LP&L will amend individual responses as may be necessary.

O khh PDR g

V Yb

'Mr..Darrell G. Eisenhut,' Director.

-Page 2 W3B84 -0475 August'.27, 1984:

b _

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We request that you commence actions you deem necessary to-lead to--the resolution of these individual issues. Responses to-the remaining issues

- will be submitted as they are prepared.--. We have revised our schedule for p.

these submittals and currently expect 'to submit the majority of the remaining

-responses by mid-September.

SincervAy, J.M. Cain JMC:DAipbs Attachments-1

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[Mr.fDarre11G..Eisenhut, Director

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2.;W3B84--0475 ;

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TAugust 27,11984-

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ax 4 icc: SMr ?R.S. Leddick?

'Mr. J. Harrison-

? Waterford 3 QALTeam1 Lea' er d

' iMr.'D.E.iDobson;

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Region III 700 Rosevelt Rd.;

'Mr.-R.F.-Burskin

-Glen Ellyn, IL 60137-JMr. K.W. Cook--

'Mr.;J.E. Gagliardo-Director Of Waterford-3 Task

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Mr..T.F. Gerrets=

. Force Region 137

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2

.'Mr. A.S. Lockhart 611 Ryan Plaza Suite 1000 Arlington',- TX: 76011 Mr.;R.P. Barkhurst.

Mr.' S.~Levine-Mr. L.. Constable.

NUS Corporation USNRC -- Waterford 3 :

910_Clopper Road

' Gaithersburg, MD '20878 Mr. J.T.-Collins U.S. Nuclear' Regulatory Commission Mr. R.L. Ferguson Region-IV-UNC Nuclear ~ Industries-611 Ryan Plaza Suite 1000

.P.O.' Box 490

' Arlington, TX ~76011 Richland, WA 99352 Mr.

D.~ Crutchfield' Mr. L.L. Humphreys U.S. Nuclear. Regulatory Commission UNC huclear Industries -

Washington, D.C. 20555 1200 Jadwin. Suite 425 Richland, WA 99352 Mr. G. Knighton, Chief Licensing Branch No. 3.

Mr. G. Charnoff Division of Licensing =

Shaw, Pittman, Potts &

Washington,.D.C.

20555 Trowbridge 1800 M. St. N.F.

Mr. M. Peranich Washington, D.C.

20555 Waterford 3 Investigation and Evaluation Inquiry Report Team Dr. J. Hendrie Leader 50 Bellport Lane 4340 E.W. Hwy. MS-EWS-358 Bellport, NY 11713 Bethesda, MD 20114 7.

Mr. R. Douglass Mr.-D.. Thatcher Baltimore Gas & Electric Waterford 3' Instrumentation & Control 8013 Ft. Smallwood Road Leader Baltimore, MD 21226 5650~Nicholson Ln.

-Rockville, MD' Mr. M.K. Yates, Project Manager Ebasco Services, Inc.

Mr. L. Shao Two World Trade Center, 80th Waterford 3 Civil / Structure Team New York, NY 10048 Leader l

-5650 Nicholson Ln.

Mr. R. Christesen, President Rockville, MD Ebasco Services, Inc.

Two World Trade Center New York, NY 10048

T tNUS

" *o* * ***

NUS-W3-A710 August 23, 1984 Mr. J. M. Cain President and Chief Executive Officer Louisiana Power and Light Company 317 Barrone Street New Orleans, Louisiana 70160

Reference:

Letter from D. G. Eisenhut, Director, Division of Licensing, USNRC to J. M. Cain, President and Chief Executive Officer, LP&L, Waterford 3 Review, June 13, 1984

Dear Mr. Cain:

We understand that you plan to submit LP&L responses to the NRC covering Issues 5, 7 and 21 of the referenced letter.

The Task Force has no objection to this course of action. We have studied these issues and find the logic stated in the LP&L responses to be adequate.

You should note that the Task Force has not yet completed its independent validation of the facts presented in the responses. We will notify you and the NRC immediately if we find significant deviations in the course of our continuing validation effort. Of course, as you know, our work on all 23 issues and their collective significance is continuing and will culminate, in a formal report to you.

Sincerely, 9(

AAV WN Sdul Levine Vice President and Group Executive Consulting Group, NUS v

,=

Larry L. HumpMeys President UNC Operations Division d

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an Robert L. Ferg6s4n Chairman UNC Nuclear Industries SL/cn O

Q) A Halliburton Company J

RESPONSE' ITEM No.

5 TITLE:

Vendor Documentation - Conditional Releases NRC DESCRIPTION OF CONCERN:

.l As a part of the staff review of the QA Program, the staff evaluaced the Ebasco vendor QA program.

In assessing this program, the staff specifically looked at the receipt inspection program and the conditional release system.

As a result of its evaluation, the staff found deficiencies with the handling of conditional certification of equipment (C of E) for Combustion Engineering supplied equipment. For example, one conditional C of E for the reactor vessel and internals was issued because as-built drawings, material certifications, and the fabrication plans had not been forwarded when the equipment was delivered to LP&L in 1976. The missing documents were sent to Ebasco sometime in 1978, according to the Ebasco quality records supervisor, but were apparently lost prior to being placed in the Ebasco document control system. The conditional certification of equipment was found when a check of all filec was made in April or May 1984. The missing documents have been requested from CE, and a deficiency report was issued and placed on a master deficiency list.

This problem has existed since July. 20, 1976.

The safety significance of this is that problems with the vendor QA records could affect installed safety related equipment. LP&L shall examine their records and determine if all conditional certifications of equipment have been

, identified, reviewed and promptly resolved.

DISCUSSION:

LP&L has reviewed their records to ensure that Conditional Certifications of Equipment and other conditional release conditions have been identified, reviewed and resolved. The following discussion outlines the results of the review which indicate that such conditions are adequately under control and do not constitute a situation adverse to the health and safety of the public.

Combustion Engineering The quality records associated with Combustion Engineering material and equipment have been re-reviewed. The review concluded that Conditional

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Certifications of' Equipment had been received for 45 purchase orders, and that for 31 of these, Combustion Engineering had provided Unconditional Certifications of Equipment prior to the audit.

Ebasco Deficiency Report 84-5-3, was prepared and issued on May 1, 1984, identifying the items for which Unconditional Certifications have not been received. This Deficiency Report was entered into the site tracking system.

The issuance of Conditional Certifications of Equipment is controlled under CE's QA program. Although the probability is considered very low, there is a possibility that the operability of equipment could have been affected.

As described in CORRECTIVE ACTION, therefore, LP&L has committed to a review to mako such a determination.

5-1

Subsequent to the audit, 13 additional Unconditional Certifications have been received including the replacement copy of the unconditional certification for the Reactor Vessel Assembly. The issues concerning the remaining items relate to revision of the design drawings in the technical manual and to the addition of a section to the technical manual to show the proper stack-up of subcomponents during reassembly. These issues are currently being prepared by the equipment vendor. Neither of these items will affect the ability to properly operate the equipment, which has been assembled and checked out by the vendor at the site. The Unconditional Certification for this equipment should be issued by September 15, 1984.

LP&L acknowledges that Combustion Engineering issued Conditional Certifications of Equipment associated with the Nuclear Steam Supply System (NSSS) that were not being formally tracked as open itams.

The existence of Conditional Certifications of Equipment was not considered a problem based on the site's understanding that they reflected incompleted purchase orders as opposed to hardware or software deficiencies.

This situation has existed since the original shipments of material and equipment from Combustion Engineering. The site did informally track the Conditional Certifications of Equipment as open items.

In addition, letters were periodically sent to CE requesting the status and resolution of these items.

To provide further assurance, site activity associated with conditional certifications was assessed. As of August 7, 1984, LP&L operations has placed 69 purchase orders with CE for spare parts.

Of these 69 purchase orders, one had a CE Conditional Certification.

The equipment related to this Conditional Certification was issued to the plant on an LP&L QC Conditional Release in accordance with plant procedure QI-10.-006.

Other Vendors and Contractors To assess the potential for existence of other manufacturing open items not tracked in the site tracking system, the site's material receiving and control

=

system was reviewed.

It was found that the system was being properly implemented and that any problems identified during the, material receiving quality control inspection and manufacturing records review were being properly tracked as Discrepancy Notices (DNs) and Deficiency Reports (DRs), respectively.

However, it was realized that the potential for a similar situation existed in areas where problems are identified off-site relating to material to be shipped to the site. Based on this, three areas have the potential for similar situations, and were selected for additional evaluation:

a)

Concerns noted by Ebasco Vendor Quality Assurance Representatives (VQARs) on the Release for Shipment forms, b)

Nonconformance Reports (NCRs) controlled by Ebasco's Home Office, and c)

Material received at the site under manufacture, deliver and erect type contracts.

The evaluation conducted is described on Attachments 1, 2 and 3, respectively, and the results summarized as follows:

5-2

a)

A sample of 36 of a ' total of 118 Ebasco New York safety-related Purchase Orders for material / equipment were selected on a discipline-by-discipline (e.g.: Mechanical, Electrical, Instrumentation) basis and reviewed.

This sample entailed app.oximately 750 shipments and approximately 11,000 items. No items adversely affecting plant safety were identified.

b)

The status of Ebasco Home Office NCRs was reviewed to ensure adequate on-site identification and control. The review concluded that there exists adequate on-site identification and control of Ebasco Home Office NCRs.

c)

The evaluation of all safety-related manufacture, deliver and erect type contracts is complete.

No items adversely affecting plant safety were identified.

Therefore, based on this review, LP&L believes that vendor QA records are adequately administered.

CAUSE:

The reviews performed have indicated that the issue cone'erning the tracking of open items is limited to CE Conditional Certifications. The cause was identified as using informal rather than formal tracking methods.

This was due to the perception that the problems underlying the Conditional Certifications were limited to commercial concerns.

GENERIC IMPLICATIONS:

LP&L has addressed this concern generically. A review was conducted, as described above, and it was determined that there exists adequate identification and control of vendor material being shipped to the site.

Material tracking is currently being performed using detailed written procedures for materials received onsite both for the remaining construction activities and for plant operation activities.

SAFETY SIGNIFICANCE:

Based on the above evaluations, all items potentially affecting plant safety are being properly controlled on site.

CORRECTIVE ACTION PLAN /SCJEDULE*

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Based on the CE records review outlined in this Response, any CE open items that have been identified are now formally tracked. Any new CE Conditional Certifications will also be formally tracked.

A review will be conducted of the Conditional Certifications which had been received for 45 CE purchase orders to determine if these conditions could have affected the operability of equipment.

This review will be completed by September 30, 1984.

5-3

ATTACHMENTS:

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1)

Cor.cer.'s Noted by VQARs on the Release for Shipment Forms 1-A) Ebasco New York Safety Related Manufacturer Purchase Orders.

1-B) P0s Included in Scope of Audit.

2)

NCRs Controlled by Ebasco's'Home Office 2-A) Comparison of NYO NCR Log to the MTS Closed NCR Printout 2-B) NYO NCRs Regttiring Verification of Disposition j

2-C) Audited NYO NCRs 3)'

Material Received at the Site Under Manufacture, Deliver and Erect Type Contracts.

REFERENCES:

None O

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M 5-4

I ATTACHMENT 1

~ Concerns Noted by VQARs on the Release for Shipment Forms

'To resolve 1the NRC concern sad determine the basis for 'the sample audit of vendor documentation the following data base was generated.

AL11 sting was generated.of.all New York. Purchase Orders.

This was generated on a discipline basis with the following guidelines:-

-MechaEical:

~ASME Code Class 1, 2, 3, MC and/or ANSI Safety Class 1, 2, 3

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- Purchase Orders.

Electrical:

Class IE Purchase Orders.

I

'ASME Code Class 1, 2, 3; ANSI Safety Class'1, Instrumentation & Control:

2, 3; IEEE Class IE and/or Seismic Category I Purchase Orders.

Architectural - Stru'etural:

Seismic Category I. Purchase Orders.

i Miscellaneous: ANSI Safety Class 1, 2, 3; AMSE Code Class 1, 2, 3; IEEE

- Class IE and/or Seismic Category I Purchase Orders.

The Nuclear Steam Supply System (NY-403402 and Field Purchase Orders to CE) was reviewed in total during the audit.

(See Attachment 1-A for the listing generated.)

4-

. -A lists all of the one hundred-eighteen -(118) New York Office

!1 safety-related purchase orders.

From this the sample size of 36 (30%) was

}

chosen (see Attachment 1-B) for the breakdown of orders reviewed. The safety-

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1 related purchase order documentation packages identified on Attachment 1-B were l

researched.

b During this review a single concern was identified.

On purchase order number NY-403659, Material Receiving Inspection Report #83-00598 (FCR-E-3119) material was received and accepted on site with an outstanding Vendor Non-Conformance Report. The material (cable) was purchased on a Clasa IE Purchase Order, but was used in a Non-Nuclear Safety application. The disposition of this NCR (NY-586) required the' implementation of the referenced FCR. The corrective action was considered a " paper change" only and, therefore, there is no safety significance.

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---mm l l ATTACHMENT 1-A EBASCO New York Safety Related Manufacturer Purchase Orders

• Mechanical Electrical I&C Arch-Structural Miscellaneous 403418 (2) 403447 (IE) 403470 (2.3) 403407 (I) 403514 (Radwaste - 2,I) 403422 (2/MC) 403454 (IE) 403485 (IE) 403480 (I) 403518 (Radwaste - 2.lE) 403431 (3) 403455 (IE) 403489 (IE) 403509 (I) 403543 (HVAC - 3) 403433 (1,2.3) 403463 (IE) 403492 (2.3) 403513 (I) 403547 (HVAC - 2) 403436 (2) 403472 (IE) 403499 (2,3) 403532 (I.3) 403548 (HVAC - 3) 403452 (3) 403487 (IE) 403502 (1,2,3) 403533 (I) 403549 (HVAC - 3) 403458 (1,2,3) 403495 (IE) 403519 (IE) 403573 (I) 403555 (HVAC - 2,3) 403461 (2,3) 403496 (IE) 403523 (IE) 403574 (I) 403556 (HVAC - 2,3) 403467 (3) 403497 (IE) 403565 (2,3) 403578 (I) 403557 (HVAC - 3) 403469 (1,2,3) 403503 (IE) 403585 (I) 403582 (I) 403558 (HVAC - 2,3) 403479 (3) 403516 (IE) 403588 (IE) 403584 (I) 403559 (HVAC - 2).

403482 (3) 430517 (IE) 403594 (I) 403592 (I) 403566 (HVAC - 3) 403483 (2,3) 403530 (IE) 403627 (I) 403593 (I) 403567 (HVAC - 3) 403484 (1,2,3) 403534 (IE) 403641 (2) 403608 (I) 403621 (Applied Physics - I) 403488 (2,3) 403535 (IE) 403642 (1,2,3) 403611 (I) 403639 (HVAC - 3) 403493 (2,3) 403536 (IE) 403649 (IE) 403613 (I) 403675 (Applied Physics - IE) 403500 (2) 403550 (IE) 403681 (1,2) 403620 (I) 403501 (2,3) 403552 (IE) 403688 (1,2,3) 403647 (I) 403504 (3) 403615 (IE) 403694 (2.3) 403648 (I) 403505 (2,3) 403623 (IE) 403802 (IE) 403506 (1,2,3) 403625 (IE) 403507 (1,2,3) 403638 (IE) 403511 (1,2) 403640 (IE) 403512 (3) 403644 (IE) 403522 (3) 403657 (IE) 403528 (3) 403659 (IE) 403539 (2,3) 403542 (2) 403546 (2)

• Information in parentheses after P.O. number refers to the following safety related classes:

403591 (I) 1,2,3 - ASME Code Class 1,2,3 and/or ANSI Safety Class 1,2,3 403606 (1,2,3)

MC - ASME Code Class MC 403650 (3)

IE - IEEE Class IE 403661 (2)

I - Seismic Category I 403674 (1,2,3) 403676 (1,2,3) 403699 (1,lE) 403801 (1,lE) 5-6 g,

'l]

ATTACHMENT-1-B POs Included in Scope of Audit ELECTRICAL PURCHASE ORDER SAFETY RELATED

1. OF' SHIPMENTS NUMBER CLASS COMPONENT (MRIRs) *

1. OF ITEMS

'NY403447 IE 5 and 15 KV_ Power Cable 25 72 NY403455 IE 480V Volt Power Centers 26

~1,812 NY403463 IE Storage Batteries 1

3 NY403496 IE Electrical Penetrations 35 403-NY403497 IE 480 Volt Motor Control Centers 34~

139 NY403516 IE Static Uninterrupted Power Supply, 6

28 NY403659 IE Refueling Disconnect and Missile Shield 55 1,111-Cable 7

182

-3,568 SUB TOTAL' ARCHITECTURAL - STRUCTURAL PURCHASE ORDER SAFETY RELATED

1. OF SHIPMENTS NUMBER CLASS COMPONENT (MRIRs)

1. OF-ITEMS NY403407 I

. Reactor Building Crane 10 5 (lots)

NY403582 I

Maintenance & Hatch Shielding Door

.5 6

NY403584 I

Anchor Bolts & Anchor Studs 5

1,164-NY403613 I

RAB - Structural Steel 22 22 (lots).

NY403532 1.3 Misc. Shop Fabricated Tanks 2'

6 5

44-1,203 SUB TOTAL

• Material Receiving Inspection Report 9

5-7 t.

ATTACHMENT 1-B (Continued)

MECHANICAL PURCHASE ORDER SAFETY RELATED

1. OF SHIPMENTS NUMBER CLASS COMPONENT (MRIRs)

1. OF ITEMS

'NY403422 2/MC Containment Piping Penetrations 41 L78' NY403458 1.2.3 2 " and Larger Stainless Station Valves 142 147:

NY403469 1.2.3 2 " and Larger Stainless Steel Valves 8

8' NY403484 1.2.3 Control Valves 5'

11

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NY403506 1.2.3 600# and Higher Gate and Check' Valves 70

'656

.1 NY403507 1.2.3 Stainless Steel Valves 30

~177 NY403511 1.2 Safety and Relief Valves 23 29 CY403606 1.2.3 Control Valves and Accessories 8

-50 NY403674 1.2.3 Line Service Solenoid Valves 8

39 NY403676 1.2.3 Self Contained Regulating Valves 1

8 NY403699 1.lE Limit, Switches 4

94-NY403801 1.lE Pilot Solenoid Valves 2

51-12 342 l'.348' SUB TOTAL 5-8 te

ATTACHMENT 1-B (Continued)

IhSTRUMENTATION & CONTROL PURCHASE CRDER SAFETY RELATED

1. OF SHIPMENTS NUMBER CLASS COMPONENT (MRIRs)

1. OF ITEMS NY403485 IE Differential Pressure Switches 15 136 NY403519 IE Process Analog Control 83 3,684 NY403585 1

Local Instrument Cabinets & Racks 10 86 NY403627 1

Annubars 1

4 NY403642 1,2,3 Low Differential Pressure Transmitters 4

28 NY403681 1,2 Thermocouple Assemblies 4

291 NY403688 1,2,3 Low Differential Pressure Transmitters 4

39 7

121 4,268 SUB TOTAL MISCELLANEOUS PURCHASE ORDER SAFETY RELATED

1. OF SHIPMENTS NUMBER CLASS COMPONENT (MRIRs)

1. OF ITEMS NY403518 2 lE Hydrogen Analyzing 3

7 (Radaaste)

NY403547 2

Check Valves 2

6 (HVAC)

NY403556 2,3 Electric Heating Coils 11 159 (HVAC)

NY403559 2

Containment Fan Coolers 10 24 (HVAC)

NY403675 IE Accidential Radiation Monitoring / System 30 349 (Applied Physics) 5 56 545 SUB TOTAL 5-9 ie

ATTACHMENT 1-B (Continued)

SUMMARY

f 0F PURCHASE DISCIPLINE ORDERS AUDITED SHIPMENTS ITEMS i

ELECTRICAL 7

182 3,568 ARCH /STRUCT 5

44 1,203 MECHANICAL 12 342 1.348-i I&C 7

121 4,268 MISCELLANEOUS 5

56 545 TOTAL 36 745 10,932

-a, 5-10 n.

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ATTACHMENT 2 NCRs Controlled by Ebasco's Home Office 1.

In June,198'*, a review of all NYO (New York Office) issued NCRs has been accomplished to determine if any NYO NCRs still open have been properly identified as open by the site in the Master Tracking System.

The result is that there is one NYO NCR still open (NCR 646), and it was and still is properly identified on the Master Tracking System as an open item.

(See Attachment 2-A) 2 Concurrently,-a review was also conducted to determine if NYO NCRs that required corrective action and Verification of Disposition were closed properly. The Criteria for correct closure were:

a)

Item (s) repaired, repir.ed, or otherwise rendered correct before receipt at site.

b)

Item (s) were identified as requiring corrective action upon receipt at site and tracked until accepted disposition was verified.

A total of 144 NCRs were identified as requiring Verification of Disposition. A sample of 20 were reviewed. One concern was noted.

The Temporary Fuel Storage Racks should have been identified as having incomplete documentation (analysis of fuel drop impact) when received on 5/21/81. NCR 628 was not issued until 11/10/83 to identify the problem and implement a solution. DCN-NY-AS-758 was issued on 3/14/84 and Station Modification Package 84-133 was issued on 4/4/84 to implement the corrective action. This item has been properly tracked since the issuance of NCR 628.

Temporary Fuel Storage Racks will not be used until installation of modifications described in SMP 84-133 is complete. There is no safety implication.

Therefore, the QA process for controlling NYO NCRs requiring corrective action and Verification of Disposition is acceptable.

l 5-11

'Y

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ATTACHMENT 2-A Comparison of NYO NCR Los

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to the MTS Closed NCR Printout Comparison:

1..- All items listed in MTS as closed were also listed as closed in NYO NCR

. log.

Perblems Identified:

4

_ a)

NCR 30 was' listed as closed in MTS and NCR 30 was superseded by NCR 40 per NYO NCR log. NCR 30 and the closed copy of NCR 40 are located in the correct file under P.O. NT403405 in the QA Records Vault.

.b)

NCR 576 was listed as voided in NTS. NCR-576 was closed per NYO NCR log. The closed copy of NCR 576 is located in the correct file under P.O. NY403458 in the QA Records Vault.

The NYO NCR log was correct in both cases. The errors do not affect the validity of closed status. MTS has been updated.

C$rparison:

2. - There vers'111 NCRs indicated as being closed in the NYO NCR log but were not listed in MTS. As MTS only tracks those NCRs which require corrective

{-

action by the site, a 100% review of these NCRs was performed.' NCRs which required correceive action are closed and located in the files in-the QA Records Vault.

- Problems Identified:

None 3

't.

av 5-12

ATTACHMENT 2-B NYO NCRs Requiring Verification of Disposition 011

• 133 251 349 390R1 012 136 254 351 498 019 147 256

• 361 518 024

• 155

• 263 360R1

• 549 026 156

• 264 361R1 551R1

• 028

• 170 265 367 557 031 171 266 371 563 034 176

• 268 379 569 036 179 277 380 575 037 192 278 385 585 040 195 279 387 587 042 197

• 284 389 588 043 201 285 397 589 050 206

• 286 410 590

• 054

• 207 296 411 593 055 208 297 412 601R1 059 209 300 317R1 606 068

• 210 302 423 607

• 081 218 310 428 611 082

• 221 311R1 429 612 083 225 312R1 430 613

• 093 228 316 431 613R1 103

• 232 317 447 617 108 236 318 448 618 112 237 320 449 622 119 241 321 453 625 121 243 332 454

• 628 118 284

• 347 467 635 129 246 348 457R1

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• Items audited, see Attachment 2-C 5-13

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ATTACHMENT 2-C Audited NYO NCRs Total of 144 NYO NCRs required verification of disposition. A random sample for investigation follows.

1. - NCR 28, P.O. NY403509. C-3660-N, C3661-N

- Verify UT was performed.

- UT performed.

- NCR closed prior to shipment.

2. - NCR 54, P.O. NY403487

=

4

- Verify flux and other material removed from tray.

- Reinspection performed.

- NCR closed prior to shipment.

3. - NCR 81, P.O. NY403405 L

- Wide gap weld.

- Procedure required and reviewed without comment.

- NCR closed prior to shipment.

4. - NCR 93, P.O. NY403439

- NCR 93 superseded by W3-1518.

1

- W3-1518 tracked until closure.

5. - NCR 133, P.O. NY430539

- Confirm castings meet ND 2571 of ASME III ND.

- NCR closed prior to shipment.

6. - NCR 155, P.O. NY403484

- Verify conformance to ASTM standard for 2" 6-C70-28-1.

- Item is non-safety /non-seismic per Purchase Order spec.

- NCR closed.

7. - NCR 170, P.O. NY403509 3

- Problem with heat treatment temperature.

- Resolved through evaluation.

- NCR tracked until closure, h

8. - NCR 207, P.O. NY403578 G

- Lakeside Steel to furnish shims.

S-

- Letter dated 12/18/78 states shim material provided to J. A. Jones.

Problem resolved through NCR 210. As-Built installation verified by letter dated 12/18/78.

c

- NCR tracked until closure.

9. - NCR 210, P.O. NY403578

's

- See NCR 207.

3

- NCR tracked until closure.

10. - NCR 221, P.O. NY403573

- High silicon content.

- Problem resolved.

- NCR closed prior to shipment.

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5-14

v.

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ATTACHMENT'2-C.

.(Continued).

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11.- NCR 232,'P.O. NY403583

- Missing documentation.

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- Qualification reports accepted.

- NCR tracked until closure.

'12.- NCR 263. P.O. NY403483'

- Weld repair on end prep.

- Part not used.

-- NCR closed prior to shipment.

'13.- NCR 264, P.O. NY403483

- Wald repair and prep.

- Repair complete.

- NCR closed prior to shipment 14.- NCR 268, P.O. NY403557

- Confirm correct type motor supplied.

- Confirmed.

- NCR closed prior to shipment.

l 15.- NCR 284 P.O. NY403496

- Missing documentation.

- Reports accepted.

- NCR tracked until closure.

}

~16.- NCR 286, P.O. NY403583

- Missing documentation.

- Reports accepted.

- NCR tracked until closure.

17.- NCR 347, P.O. NY 403613

- Spray Booth doors require repair.

- Repaired.

- NCR closed.

18.- NCR 361 P.O. NY403557

- Rev. I replaced - verify motor extension leads consist of acceptable material.

- Verified by VQAR.

- NCR closed prior to shipment.

19.- NCR 549. P.O. NY403640

- Need to identify unique color on CWDs 2945, 2646.

- CWDs issued.

- NCR tracked until closure.

20.- NCR 628, P.O. NY403608

- P.O. requires drop analysis.

- Items received 5/21/81; NCR issued 11/10/83.

- Problem not promptly identified.

- NCR is being tracked.

- NCR-628 superceded by SMP 84-133.

- SMP 84-133 tracked until closure.

5-15

t'

= ATTACHMENT 3i

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e.

iMaterial Received at the Site Under Manufacture.

Deliver and Erect Type Contracts LScope ER Deliver and Erect Purchase Orders and Contracts-(Safety Related Only)-

Purchase Orders:

1MY403405 NY403508 NT403525 Contracts; W3-F-6 W3-NY-4 W3-NY -W3-NY-23 W3-NY-27 Discussion

Deliver and Erect N.Y. Purchase Orders and Contracts Due to'the differing nature of each Deliver and Erect (D&E) purchase order and contract, the definition of the scope of r,esearch differed.

Essentially for each of the following, a review was performed to assure that problems identified on material, parts or components were tracked.

Deliver and Erect Purchase Order Review Scope and Results NY403405; Chicago Bridge & Iron; Steel containment Vessel; Safety Class 2/ Seismic I A review of all Ebasco Vendor QA Release for Shipment (form 1035) Vendor QA Release Reports (forn 719) and Ebasco New York office reviewed NCRs was performed.

Additionally, a review of the CB&I Non-Conformance Control List, Shop Release for Shipment Checklist and Site Receiving Inspection J

Reports was performed.

The review identified one Ebasco Release for Shipment (form 1305) which

.noted that 12 items required sandblasting at the site.

The associated CB&I Release for Shipment form did not identify the condition and there are no

~C8&I records to support that sandblasting was done. Of the 12 items, 7 are embedded in concrete and did not require sandblasting. The remaining 5 items are part of the construction hatch storage rack located 'inside containment and would have been repainted had any coating distress appeared per'NCR-W3-4825 (PRI-94). Furthermore, these 5 items are of small surface area. The failure of the coating of such small and scattered areas during a DBA vould not be of any safety significance.

In addition, there is no-indication that any of these materials will have adverse interactions with engineering safety features.

5-16

ATTACHMENT 3 (Continued)

NY403508; Nooter Corporation; Fuel Pit and Canal Liners; Safety Class NNS/ Seismic Class I A review of all of the Ebasco Vendor QA Release for Shipment (form 1305) and Vendor QA Release Reports (form 719) was performed.

All documentation for each fabricated item was also reviewed for inclusion of appropriate Ebasco QA review stamp and/or signature.

The review did not identify any problems which were not tracked and resolved.

NY403525; Chicago Bridge & Iron; Diesel Oil Storage Tanks; Safety Class / Seismic Class I The safety related tanks on this order consist of the 1) - Diesel Oil Storage Tanks (2 each) and 2) - Diesel Oil Storage Feed Tanks (2 each).

A review of all of the Ebasco Vendor QA Release for Shipment (form 1305) and Vendor QA Release Reports (form 719) was performed. Additionally, a review of all documentation packages was performed which included the vendors Receiving Inspection Reports.

The review did not identify any problems which were not tracked and resolved.

Deli"er and Erect Contracts W3-F-6; Louisiana Industries; Concrete Supply and Delivery; Seismic I W3-NY-4; J. A. Jones; Civil Erection; Concrete and Structural Steel W3-NY-23; Sline Industrial Painting; Application of Nuclear Coatings and Painting; Nuclear Safety Related - Inside Containment Coatings W3-NY-27; B&B; Installation of Penetration Radiation Seals Fire Stops and Air Seals for Electrical, Mechanical and HVAC Systems; Non-Nuclear Safety - Fire Protection The contracts listed above did not have QA programs which allowed for conditional releases. Upon receipt the material was inspected and documentation was reviewed or verified complete. Any discrepancies either in hardware or software required the material to be placed on hold, in a hold area or rejected as appropriate. The material remained unavailable for issue until the noted discrepancies were dispositioned and closed.

Because of the contractor's programs only acceptabic material was available for installation.

5-17

ATfACHMENT 3 (Continued)

W3-NY-17; The Waldinger Corporation; HVAC Ductwork, Supports and Accessories; HVAC Safety Class 1 (Safety Related/ Seismic I),

Class 2 (Non-Safety Related/ Seismic 1), and Class 3 (Non-Safety Related/Non-Seismic)

' A search was made of Waldinger Deficiency Reports generated at their shop in Des Moines. This search revealed 12 Shop DRs which were transferred to the jobsite for closure. Tracking and closure has been verified for all of these DRs.

It should also be'noted t. hat subsequent to May of 1979 a 100%

review of.the Waldinger shop sanufacturing records was performed by Ebasco QA Records personnel. Documentation deficiencies identified during the review were addressed and closed at that time.

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5-18

l

RESPONSE

~ ITEM NO:

7 TITLE:

BACKFILL SOIL DENSITIES NRC DESCRIPTION OF CONCERN:

i The. staff ~found that records are missing for the in-place density test of

-backfill in Area 5 (first 5' starting at Elevation -41.25').

These documents are important because the seismic response of the plant is a function of the soil densities..

LP&L shall' (1) Conduct a review of all' soil packages for completeness and technical adequacy and locate all records and provide closure on technical questions, or (2) conduct a review of all soil packages for completeness and technical adequacy and where soil volumes cannot be verified by records as meeting criteria, perform and document actual soil conditions by utilizing penetration tests or other methods, or (3) Justify by analysis that the soil volumes with missing records, or technical problems as defined after the records review, are not critical in the structural capability.of the plant under seismic loads.

DISCUSSION:

LP&L has reviewed all soils packages for completeness and technical adequacy, has located the items found missing by the staff, has identified those soil volumes for which complete records were not found, and has justified by analysis that the structural capability of the plant under seismic loads is assured. A detailed engineering report has been prepared and attached to this response describing the review and analysis of the soil backfill densities, which

. reconfirms the adequacy of the backfill. This was also repeatedly demonstrated in the seven (7) statistical studies of backfill densities performed during the construction period, which showed good control of the work was achieved and specification requirements generally exceeded.

The following discussion is a summary of the findings of the attached report.

The design criterion for the backfill was to obtain a liquefaction free material at 75% relative density. To confirm compliance with this design criterion, a detailed three stage program was implemented to perform a review for completeness and analysis of backfill soil density and inspection reports for technical adequacy which verifies the structural capability of the plant under seismic loading conditions.

The program effort was conducted under the direction of the Ebasco Site Soils Engineer who was present during the performance of the majority of the actual backfilling operations. Two basic sets of evaluations were performed, the first on soil backfill test records, and the second on the corresponding inspection Reports.

During the Stage I effort, a detailed search was made of all locations containing soil backfill data. Additional test records and inspection reports were obtained from contractor and laboratory files and also Engineering.

i Laboratory and Quality Control indices and tabulations were retrieved.

i 7-1 1

f

Once the packages of soil data were located and collected, Stage II activities concentrated on a review of the documents for completeness and a compilation of the data into a format amenable to review of the NRC concerns.

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Included in the review were each type of Inspection Report and each type of test record in the soil packages.

It was determined that the complete set of test records and a nearly complete set of inspection reports had been located.

In direct response to the first paragraph of the Description of the NRC Concern, the data for the 34 in-place density tests performed in the first 5.5' of Class A fill placed in Fill Arca #5 from Elevation -41.75 to EL -36.25, has been located.

Stage III activities consisted of engineering evaluation of the data gathered and organized in Stages I and II.

The results of the Stage II and III evaluations for completeness and technical adequacy for both the test records and inspection reports are summarized as follows:

(A) EVALUATION OF TEST RECORDS Test records deal with quantitative attributes of the fill such as density, moisture content and gradation. The test most indicative of quality is density, since it relates directly to liquefaction potential, however, the other actributes were also reviewed for acceptability.

Utilizing the complete package of backfill density records, overlay plots of relative density were constructed at each one foot interval of elevation during the Stage II effort. These documents represent a graphical plot of density test frequency and distribution, and tabulate and display the final insitu relative densities.

The Stage III review and evaluation of the technical adequacy of the Class A backfill to provide structural stability of the plant under seismic loadings was based upon a comparison of the design requirements as stated in the Ebasco Specification LOU-1564.482 with existing documentation and with the relative density plots prepared in this review. These plots are available in the Site Quality Assurance Records Vault. These plots demonstrate satisfaction of requirements for test frequency and distribution throughout the fill volume.

The evaluation included each type of test record required by the governing specifications and procedures and analyzed:

The completeness of all test records The testing frequency and distribution of in place density tests The frequency of laboratory control tests The performance of statistical studies The Class A Backfill relative density 7-2

.The results of these analyses are as follows:

(1) 'The Class A backfill soil testing records are complete.

(2) Field density and laboratory density and gradation tests were generally performed in accordance with the specified frequencies.

In less than'8% of the cases reviewed. the laboratory control tests-were run at intervals slightly larger than the specified i.

(one control set per ten field density tests) criteria. The backfill'placed during these periods was randomly located throughout the fills'and the relative densities obtained during these intervals were~found to be in compliance with the

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r specification requirements.

This variance.was therefore evaluated to be. acceptable.

(3) Field tests were located in accordance with the specified randon I

distribution.

In less than 5% of the tests reviewed, the location coordinates of the inplace density tests were found to be in error. These tests were still a valid indicator of the relative density of the backfill at a random spot at a known.

elevation in a known fill area and were therefore deemed to be acceptable tests.

(4) Statistical studies of relative density were performed in accordance with the specification requirements.

(5) The Class A backfill soil densities are in accordance with the specification requirements and will provide the required design i

structural capability to the plant under seismic loads.

(B) EVALUATION OF INSPECTION REPORTS Inspection records generally deal with qualitative attributes of the fill such as proper preparation of the fill surface and cleanliness of fill received. Production-related quantitative information such as. fill location, elevation.and area are also provided.

During the Stage II review activity, the total file of inspection reports for Class A backfill was inventoried and combined into compatible soil packages.

Included in the inventory were approximately 12,000 inspection reports ranging from EL -44 to EL+20 throughout all seven fill areas. The T

.s reports were grouped and compiled by fill location, elevation and placement i

date for each of_the five types of inspection forms and summarized in i

several tabulations.

The evaluation of these inspection reports was divided into two phases:

the evaluation of the inspection reports to determine their overall completeness, and the evaluation of the frequency and distribution of inspection reports to determine their content.

1Two comparative analyses were performed to determine tha relative

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completeness of the inspection documentation. The first analysis performed

.is a comparison of the quantity of inspection packages to testing pucAages throughout the fills, while the second compared the documented U

surface area of inspection to the total surface areas of the fill placement.

7-3

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Once completeness of inspections was established, an additional analysis.

-l was performed to define the magnitude, the' distribution and significance of j

the. documentation found to be missing.. This' analysis evaluated the-distribution of each type of~ inspection report by fill location and Jelevation,'and determined types of missing documentation and the amounts of

' backfill by volume affected. The results of this analysis are as follows:

.(1) The distribution of the. existing inspection 1 documentation throughout the backfill _is. essentially identical.co the distribution of the field

. testing' effort,'thus indicating a one.to one relationship between J

inspection and testing activities. This is an expected _ trend since the inspection-activity included ordering tests performed.. It is therefore concludedLthat the inspection activity took place whenever tests are found and'that missing inspection reports are not indicative of lack of inspection activity.

'(2) Eighty percent.of the volume of the-backfill has a sufficient. quantity

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of each type of inspection report to fulfill'the requirements of the-specification and inspection procedures.

.(3) For the 20% of the volume of the backfill which was missing some of the required inspection' reports, 16% has an average ~of 81% of the reports: required, 3.8% has one or more type of inspection missing, and 0.2% clustered together in groups on three (3) fills has no inspection' reports at all.

For details, see the. Report, Section 4.B. and Table No. 2.

The effect on each of these types of deficiencies was evaluated based upon the i

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quantity and type of inspection documentation existing above, below and around the affected fill areas, the relative density results in the affected areas and the relatively small volume of fill affected. 'It was concluded that the deficiencies found in the inspection documentation.are most probably due to lost folders, are not indicative of a lack of inspection effort, and will have no effect on the structural capability of the plant under'peismic loads.

i CAUSE:

i. ~

The cause of this concern was the fact that some of the field inspection and laboratory test records for.the Class A backfill were still in the contractor's

_(

QA records vaults. This contractor is still active on site and had not

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initiated the transfer of' documentation to the LP&L-Ebasco Quality Assurance a

Vault.- All available soil records'are now permanently stored in this vault.

' GENERIC IMPLICATIONS:

Based upon the'results of'the detailed review and analysis of backfill soil.

i j_

densities'and corresponding inspection reports described in the discussion-

.above,.the Class A backfill was found to be sufficiently in compliance with the l

specification requirements.-

I I) -

7-4

The large. effort required to establish the completeness of the records is due to the intrinsic difficulty.of scoping a bulk process such as backfill in the absence of'an administrative control tool, such as a logbook of inspections,-

which was not required by the implementing procedures. This scoping problem is

- believed to be unique to the soils / backfill effort.

1

- Difficulty in establishing records completeness also was due to incomplete records turnover from the onsite contractor involved. Therefore, a generic concern exists as to the extent to which there has been incomplete records turnover on the.part of remaining site contractors. This is addressed in the

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CORRECTIVE ACTION PLAN below.

SAFETY SIGNIFICANCE:

Test records ~and inspection reports were located and analyzed demonstrating compliance with the specification. Therefore, the Class A backfill will perform its function with respect to structural design capability under seismic loads.

LP&L therefore believes that this, issue-is of no safety significance with

- respect to fuel load,-power ascension or operat' ion.

CORRECTIVE ACTION PLAN / SCHEDULE:

i i.

The complete set of laboratory test records, along with the attached report and corresponding documents, has been transmitted to the LP&L-Ebasco Quality Assurance Records Vault.

1 An inventory of remaining site subcontractor records is being conducted to determine the extent of records in their possession which should be transferred to Ebasco. This inventory will provide a basis for assuring accessibility and r,etrievability of subcontractor records and ultimate turnover to LP&L in accordance with the established records turnover program. This' effort will be completed by October 1, 1984.

ATTACHMENTS:

" Report on the Review and Analysis of Soil Backfill Densities" - NRC Concern No. 7.

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