ML20098F052
| ML20098F052 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/28/1984 |
| From: | Cain J LOUISIANA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| W3B84-0491, W3B84-491, NUDOCS 8410020267 | |
| Download: ML20098F052 (66) | |
Text
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LOUISIARIA f m e - s w er ma eox em40 POW E R & L1G t81/ NEW OREMS, LCUSANA 70160 e [504] 59}2dO4 MIDCLE SOUTH UTluT'ES SYSTEM September 28, 1984 J.M. CAIN Prcside' t and n
Chief Executive Othcer W3B84-0491 Director of Nuclear Reactor Regulation NfTN:
Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Waterford 3 SES Partial Response to Items frot: 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 17 and 23 as set forth in your June 13, 1984 letter (Reference 1).
The response to Issue 17 follows the approach set forth in Attachment 1 to the l'rogram Plan sent to you by LP&L on August 20, 1984 (Reference 2).
Limited revision has been made in the Program Plan for Issue 23 (enclosed) in order to reflect the information given to you at the August 17, 1984 e2eting in Bethesda. The response to Issue 23 follows this revised approach.
Current assessment of each of the issues is as set forth in the responses.
Included with this letter is a supplement tc, the response to Issue 4,
reflecting information developed since our August 27, 1984 submittal. The information contained in this supplement was informally provided to your staff. The logic in our original response to Issue 5 remains unchanged.
The responses and the supplement have been reviewed and verified by Li'6L QA in accordance with procedure QASP 19-13.
The designated subcommittee of the Waterford Safety Review Committee also has reviewed tha adequacy of the responnes and the supplement for resolving the issues raised. The subcommittee scope of responsibility does not include independent validation Y(
of the facts.
I I: I 8410020267 840928 PDR ADOCK 05000382 PDR A
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Mr. Darrell G. Eisenhut, Director Page 2 W3B84-0491-September 28._1984
.The Task Force has indicated by separate correspondence (enclosed) that it is
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satisfied with-the logic ~of the responses:to Issues 17 and 23.
However, it
'has not-yet completed its independent validation of the facts. -The Task Force has committed to notifying me and 'the-NRC immediately should it find
- significant deviations in the course of its validation. In the event of such notification, LP&L will amend individual responses as may be necessary.
We request that you-commence actions you deem necessary to lead to the
. resolution cf these; individual issues.
Sincerely,.
5.M. Cain.
s JMC:DA:pbs Attachments F
4 f
y Mr. Darrell G. Eisenhut, Director Page 3
- W3B84-0491-September 28, 1984 cc:
Mr. R.S. Leddick Mr. J. Harrison Waterford 3 QA Team Leader Mr. D.E. Debson Regica III 700 Roosevelt Rd.
Mr. R.F.JBurski Glen Ellyn, IL 60137 Mr. K.W. Cook Mr. J.E. Gagliardo Director of Waterford 3 Task Mr. T.F. Gerrets Force Region IV Mr. A.S. Lockhart 611 Ryan Plaza Suite 1000 Arlington, TX 76011 Mr. R.P.?Barkhurst Mr. S. Levine Mr. L 1 Constable.
NUS Corporation USNRC.- Waterford 3 910 Clopper Road
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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 Nuclear Industries L-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.W.
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 Mr. R. Douglass Mr. D. Thatcher Baltimore Gas & Electric
.Waterford 3 Instrumentation & Control 8013 Ft. Smallwood Road Leader Baltimore, MD 21226
'7920-Norfolk Ave. MS-216 Bethesda, MD. 20114 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 5650 Nicholson Ln.
Mr. R. Christesen, President Rockville, MD Ebasco Services, Inc.
Two World Trade Center
'New York, NY 10048 a
tNUS CORPORATION
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h(([dfavt.mo ace 78-tase NUS-W3-A727 September 28, 1984 Mr. J. M. Cain President and Chief Executive Officer Louisiana Power and Light Company 317 Barrone Street New Orleans, Louisiana 70160
Dear Mr. Cain:
I have been authorized by the Prelicensing Issues Task Force to forward to you the attached letter relating to the submittal of Louisiana Power and Light Company responses to Issues 17 and 23 of Mr. Eisenhut's letter to LP&L dated June 13, 1984.
Since rely, L
Peter V.
dd Project Manager Prelicensing Issues Task Force Support Group PVJ/en Attachment i
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SNUS l
CORPORATION l
E g %"$ g' d b - oeoo7s CG-SL-25-84 September 28, 1984 Mr. P.
V. Judd Pre-Licensing Task Force Support Group Louisiana Power & Light Company Waterford #.3 SES Highway 13 Taft, Louisiana 70066 Ref erer.ce :
Letter from D. G. Eisenhut, Director, Division of Licensing, U. S. Nuclear Regulatory Commis-sion to J.
M. Cain, President and Chief Execu-tive Officer, Louisiana Power & Light Company, Waterford # 3 Review, June 13, 1984
Dear Mr. Judd:
We understand that Louisiana Power & Light plans to submit re-sponses to the Nuclear Regulatory Commission covering Issues 17 and 23 of the referenced letter.
The Task Force has no objections to this course of action.
We have studied these issues and find the logic stated in the LP&L responses to be adequate.
Mr. Cain should note that the Task Force has not yet completed its independent validation of facts presented in the responses.
We will notify Mr. Cain and the NRC immediately if we find significant deviations in the course of our continuing validation efforts.
Of course, as Mr. Cain knows, our work on all 23 issues and their collective significance is continuing and will culminate in a formal re-port to him.
I have discussed this matter with Messrs. Robert.Ferguson and Larry Humphreys and we have agreed to this together.
Please forward this to Mr. J. M. Cain.
m..,-...
a.
Sincerely, t
1 Saul Levine Vice. resident and Group Executive Consulting Group
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PROCRAN PLAN DESCRIPTION OF ISSUE' LP&L APPROACH TO RESOLUTION CURRENT -
ISSUE & TITLE
- 23. QA Program Breakdown The N9" 9taff review First. LP&L'is conducting a thorough review of the
. The review insiem that there are between Ebasco and indicated that IE&L.
underlying causes and corrective actions associated
- no open items.sfacting plamt safety.
Ebasco and Mercury did with the 1982 NRC enforcement actions mad civil
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not followup on penalty to determine the adequacy of follow-up-f corrective action related to corrective a-tions.
4 commitments made to the NRC following NRC Second. LP&L is conoucting a thorough review of its unforcement action, that QA audit program, which has been in effect since
.LP&L. Ebasco and Mercury January 1982. as it related to Mercury activities.
failed to audit the Attention will be placed on the adequacy of the entire QA Programs as audit schedule and whether such audits could have
. required, and that a identified the Met ury problem earlier, failure to determine root I
cause and the lack cf-Third. LP&L is perform..g an overall assessment of corrective action allowed
.the LP&L QA construction program based on the the Mercury problem to results of the 23 Mac concerns to identify lessons persist.
learned and to determine if any improvements are required to assure adequacy of future operational LP&L chall provide an QA program activities. This response will-include assessment of the overall lessons learned from the Item 23 review. Overall QA program and determine
. assessment of the operational QA program will be cause of the breakdown.
presented in a separate submittal addressing together with corrective collective significance of the 23 issues.
)
. action to prevent recurrence. This overall This respense demonstrates that the extensive assessment is necessary management and quality assurance actions taken by l
to provide assurance that LP&L. Ebasco and Mercury subsequent to June,1982, the QA program can
.were appropriate; that most of the problems function adequately when identified were part of the corrective actions on h
the plant proceeds into work previously done and are not indicative of operation.
continued inferior performance; and that the partial program breakdown did not persist.
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B SUPPLEMENT TO RESE9NSE TO CONCERN NO. 5 SUBMITTED AUGUST 27, 1984
' DISCUSSION:
- The Pre-Licensing Issues Task Force Support Group, during its validation review in support of the. Task Force effort,. identified two additional CE purchase orders for which unconditional certifications did not exist in the files.
This finding prompted a 100% re-review of the quality records associated with CE material and equipment for the existence of conditional certifications. The following revisions to the response of August 27, 1984, have been identified.
. Conditional Certifications of Equipment had been received on 54 instead of 45 CE purchase orders.
Of the additional nine purchase orders which had Conditional.
Certifications of Equipment only one is remaining without an unconditional certification.
fit'is believed that there are two reasons for not identifying the additional nine purchase orders which had Conditional Certifications of Equipment: (A) In 1978 CE changed the form used. The earlier fcrm had no check-off boxes to clearly state whether the certification was conditional or unconditional. (B)
During the initial review, the reviewers saw the unconditional certification and
' overlooked the possibility that a conditional certification had existed ~for the purchase order being reviewed.
In conclusion, there remain only two construction related, CE purchase ordern
- that have outstanding conditional certifications.- it is anticipated that both of~these purchase orders will have unconditional certifications by September 30, 1984.
CAUSE:
There is no change to the previously stated Cause.
GENERIC IMPLICATIONS:
There is no change in the previously stated Generic Implications.
SAFETY SIGNIFICANCE:
There is no change in the previously stated Safety Significance.
CORRECTIVE ACTION PLAN / SCHEDULE:
The only change to the Corrective Action Plan / Schedule, is that the operability review will now cover 54 instead of 45 purchase orders to determine if thess
_ conditions could have affected the operability of equipment.
This review will be' completed by October 15, 1984.
l l
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RESPONSE
P ITEM NO.:
17 L
TITLE:
QC-Verification of Expansion Anchor Characteristics NRC DESCRIPTION OF CONCERN:
'A review of Mercury Construction Procedure SP-666, Revision 8, " Drilled-In Expansion Type Anchors in Concrete for Category I Structures " revealed that it Jdoes not require QC verification of many characteristics necessary to ensure proper installation of concrete expansion anchors.
These characteristics include:
Spacing between adjacent anchors Spacing between an aachor and the edge of a concrete surface Spacing between an anchor and an enbedded plate Minimum anchor embedment depth Grouting of unused / abandoned holes in the concrete Mounting plate size Size of holes in mounting plates and hole distance from plate edges
- Although most of the above characteristics are addressed in Section 6.1
" installation," they are not included within Section 6.2 " Inspection," as items requiring QC. verification.
In addition, QC Inspection Report Form 277A, Rev.
.May 1982, " Equipment Installation (Anchors)." does not list these attributes as inspection points.-
-Therefore, Procedure SP-666 should be revised to include all necessary inspection attributes, and a reinspection program should be initiated. This
_ program should be of sufficient size and scope to indicate whether these concrete anchors, in general, are able to perform their intended function.
Detailed results should be made available to the NRC staff for review.
DISCUSSION:
LP&L acknowledges that not all of the expansion anchor characteristics cited by the NRC were specifically included in Mercury QC Inspection Report (Form 277A),
although all necessary criteria were included in inspection procedures either by referencing the governing procedure (SP-666) or other inspection checklists.
. Mercury is no longer on site and it would therefore be of no positive consequence to revise SP-666. The procedures currently used on-site to install expansion anchors, however, will be revised to ensure all necessary inspection attributes are explicitly included on the inspection checklists. The five-part discussion that folicvs, including a discussion of the LP&L reinspection in-progress, will demonstrate that the overall expansion anchor installation program has led to an and product which will adequately perform its required safety functfon. The discussion is formatted as follows:
I.
Comparison of Characteristics Cited By the NRC versus Mercury Procedures and Inspection Checklists.
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II.
Training of Mercury Personnel on Expansion Anchor Installations.
III. Corrective Action Programs for Deficiencies Identified While Mercury Was On-site.-
IV.
Reinspections After Mercury Left the Site.
V.
Analyses Demonstrating the Conservatism of the Mercury Expansion Anchor Installations.
I.
A Comparison of Characteristics Cited By the NRC versus Mercury Procedures and Inspection Checklists.
Mercury Company Procedure SP-666 establishes the method for the installation and inspection of Seismic Class 1 drilled in expansion type at.cho rs.
It references project installation documents such as Ebasco Drawings ' LOU-1564-B430 (Instrument Installation Details) and also states in Section 5.0 that:
" Mercury QA is responsible for the completeness of all documents and to ensure that the quality requirements of this procedure are met."
Included in these " quality requirements" are adherence to the project's
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installation documents, referencad in SP-666, the Mercury QC Inspection Report (Form 277A) (Attachments 1 and 2) and other Mercury procedures.
The following is a cross reference of the characteristics cited by the NRC to these other documents. Also included is a reference to other parts for this discussion for pertinent reinspections or analyses:
A.
Spacing Between Adjace nt Anchors This criteria is addressed in Ebasco Anchor Installation Specification 1564.468, which is referenced in all revisions to SP-666 and was directly.cranscribed into revision 7 (9/28/82).
Ebasco and LP&L QC reinspections to this crituria are discussed in Sections III and IV, respectively.
B.
Spacing Between an Anchor and the Edge of a Concrete Surface This criteria is addressed in Ebasco Anchor Installation Specification 1564.468, which was referenced in all revisions to SP-666 and was directly transcribed into revision 7 (9/28/82).
Ebasco and LP&L QC reinspections to this criteria are discussed in Sections III and IV, respectively.
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C.
Spacing Between an Anchor (Plate) and Embedded Plate l
There are essentially two cases found in the field which related to this characteristic.
First, anchor plates may be welded to embedded b
plates.
Second, an anchor plate may be immediateiy adjacent to an embedded plate.
These situations are allowable per design drawings and therefore were not included in the inspection requirements. See Section V for a discussion of each case.
D.
Minimum Anchor Embedment Depth This criteria was required to be verified in Sectiva 6.2 (Inspection) in all procedure revisions of SP-666 and was noted in checklist item 3 of Form 277A associated with SP-666.
Ebasco and LP&L QC reinspections to this criteria are discussed in Sections III and IV, respectively.
E.
Grouting of Unused / Abandoned Holes in Concrete This characteristic was addressed in all procedure revisions of SP-666 and war noted as checklist item 13 of 277A form threugh revision 4 of SP-666 - (5/18/82).
In later revisions, SP-666 required that Ebasco be notified to fill unused holes.
Section V presents the results of an analysis demonstrating the conservatism of the design in regard to this criteria.
F.
Mounting Plate Size This item was verified and signed off by the Q.C. inspector as part of the support inspection checklist (Form 262), which is addressed in Mercury procedures SP-654 and SP-655.
In addition, revisions 7 and 8 of SP-666 referenced the Ebasco B-430 drawings which detailed the mounting plate sizes.
The specific B-430 drawing used for a particular application was indicated on the completed inspection report ferm 277A.
G.
Size of Holes in Mounting Plate and Hole Distances from Plate Edges Per paragraph 6.1.2 of all SP-666 procedure revisions, a carbide bit of the same nominal diameter as the expansion bolt was to be used to
-drill the hole, unless otherwise directed by the Engineer.
The hole distance from place edge was part of the configuration checkpoint verified by Q.C. during support fabrication noted in Mercury procedures SP-654 and SP-655 and documented on form 262-1.
This attribute was also detailed on the Ebasco B-430 drawings which is referenced it revisions 7 and 8 of SP-666. The specific B-430 detail drawing used for installation was referenced on the corpleted inspection checklist form 277A.
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II.
Training of Mercury Personnel on Expansion Anchors The following is a discussion of the training program developed and implemented by Mercury. This program provides additional confidence concerning anchor bolt installations.
All revisions of Mercury procedure SP-666 required training on expansion anchor installation techniques. Revisions 2 through 8 required that this training be documented.
Initial training and indoctrination was given by Hilti representatives.
Hilti training sessions were conducted on 2/1/79, 6/28/79, 1/29/80~and (8/29/80. Approximately 40 Mercury personnel were trained by Hilti on these dates.
Subsequent training was conducted by Mercury.
The Hilti sessions provided the following information:
A.
Proper identification of Hilti bolt lengths. Trainees were instructed to ensure the expansion bolt was identified by a letter designator on the bolt end which identified the bolt lengch and subsequent embedment after installatior.
It is noted that H11ti's Manual required considerably shorter embedment depth than that required by Mercury.
Because of the seismic considerations, Hilti initiated recommendations exclusive to the site contractors for installing anchors. The Hilti criteria for embedment depths for expansion anchors was incorporated into Mercury's procedure. The embedment depths are as follows:
c MINIMUM EMBEDMENT Hilti Recommends Hilti Recommends Mer ary Proce-Bolt Size For Commercial Use For Site Contractors dure Requires 3/8" 1 5/8" 3 1/2" 3 1/2" 1/2" 2 1/4" 5 1/2" 5 1/2" 5/8" 2 3/4" 6 1/2" 6 1/2" 3/4" 3 1/4" 7"
7" B.
A discussion on the drilling of concrete with Hilti equipnent stressing the use of Hilti drill motors and drill bits.
C.
A demonstration on how to drive the bolt into the drilled cut bolt hole.
D.
Instructions for the proper number of turns to " set" and torque the bolt.
Mercury's training program on expansion anchor installation was an on going activity. Documented training sessions, which included anchor bolt training, were administered by Mercury on April 5, April 28 and June 25 of 1982. Mercury memos WA-980 (7/1/82), WA-1047 (7/29/82) and WA-1049 (8/3/82) document the extension of their retraining program to individuals not on site at the time of previously held indoctrination sessions.
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III. Corrective Action Programs for Deficiencies Identified While Mercury Was On-site The site anchor installation activity was addressed by Ebasco in December of 1981.
Ebasco Corrective Action Report (C.A.R.) 82-3-2 was written against all companies installing safety related expansion anchors.
Ebasco nonconformance report NCR-W3-3316 was written in conjunction with the C.A.R. 82-3-2.
The C.A.R. identified the fact that contractors installing expansion anchors did not fully comply with design specifications 1564-468 (seismic applications) and 1564-467 (non-seismic applications).
The specific violation noted in the C.A.R. was that the spacing distance of anchor bolts between adjacent plates was less than 10 bolt diameters and the distance of installed anchors to free edge was less than 5 bolt diameters.
It should be noted that this spacing criteria was not included in the Hilti training sessions described in Section III.
As a result of this Corrective Action Report:
A.
Nonconformance Report (NCR-W3-3316) was initiated to evaluate all identified cases where the spacing criteria was not met.
This NCR required a valkdown by Ebasco Quality Control to identify previcus installations and required Ebasco Design Engineering to evaluate those cases identified as violations. This walkdown was completed, violations were evaluated and the NCR was closed after all identified items were resolved.
B.
Mercury was required by the C.A.R. to retrain perscnnel on the installation of expansion anchors relative to the distance between anchors and the distance between anchors and a free eds,e.
C.
Mercury was required by the C.A.R. to revise its procedures as neces=ary to include the spacing criteria required by Ebasco Specification 1564-468.
IV.
Reinspection After Mercury Left the Site A.
Mercury Records Transfer Review and Field Verification (ECRRI-1)
When Mercury Company lef t the jobsite, Ebasco assumed the responsibility for the review of' Mercury QA records prior to transfer of the records to LP&L. During the course of this review, Ebasco's Quality Assurance Installation Review Croup (QAIRG) identified expansion anchor concerns due to incomplete installation or incomplete / questionable documentation (note that some of these conditions were in process when Mercury left the site).
When any one of these conditions occurred, a field verification was performed by the Ebasco Quality Control Department utilizing Ebasco Procedure ECRRI-1.
I'-5 L-
The intent of.tha field verification by Ebasco QC was to confirm the as-built-condition of the expansion anchors and. supplement the Mercury QC documentation accordingly. The program utilized " inspection
' requests" which were initiated by the QAIRG and implemented by Quality Control. There were 896 requests made and implemented relative to the expansion anchor program.
Each of the following actions was taken and checked off when an inspection request form was initiated:
1) the Ebasco QC inspectors witnessed the torque verifications of the expansion bolts; 2) the Ebasco.QC inspectors checked the identification mark on the anchor bolts to ensure adequate embedment depth of.the anchor.
If no.identificatica mark was visible, a.
Discrepancy Notice was initiated and the' bolts were ultrasonically
-measured and replaced as necessary; 3) the Ebasco QC inspectors providedla sketch as necessary, of the expansion plate and the
' location of the bolts on the plate. This information was then transmitted to the reviewers to determine compliance to the B-430
. drawing details.
From this field verification, a total of 196 Discrepancy Notices were written by Ebasco Quality Control.
Of the 196 DNs written, fifteen-required rework. This rework primarily consisted of changing out one bolt,per DNLdue to unachievable torque. The remaining 181 DNs were resolved as appropriate by ultrasonic measurement, initiation of a Design Change, torquing bolts to proper range or attaching additional documentation. Documentation of the field verificatica program performed in accordance with Ebasco Procedures ECRRI-1 and ECRRI-3 is available.
s B.-
Additional QA Inspection of Instrument Installations
-LP&L'has embarked on a reinspection of 100% of the Mercury N1 instrument installations.- It is being implemented under LP&L QA
- procedure QASP 19.15. The program was initiated primarily in response
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. co NRC Concern No.1 (Inspection Personnel Issues).
It does, however, include requirements for reinspection of the following three attributes:
1.
Inspection of expansion anchors on adjacent plates to verify adequate spacing becween anchors.
2.
' Inspection of anchors to a free ed e to verify sufficient 3
-distance between the anchor and the free edge.
3.
_ Inspection of the bolt marking on top of the anchor bolt to verify the embedmont.
The reinspection of the Reactor Containment Building has been completed. Very few expansion anchor installation discrepancies were
-found. 'Ihose identified have undergone angineering evaluation and no rework is required. The reinspection is expected to be complete by October 15, 1984..The results thus~far, indicate that the Mercury program in conjunction with Ebasco and LP&L corrective actions and reinspections has been effective.
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V.
Analysis Demonstrating Conservatism of the Mercury Expansion Anchor Installation A.
Analysis of spacing between Embedded Plates and Anchor Plates Conditions may exist'in which an embedded plate is immediately adjacent to an anchor plate. This apparently raised a concern that the anchor bolts and nelson studs may be so close as to create overlapping shear cones with resulting reduction in the capacities of I
both plates. There is a detail on Ebasco Drawing 1564-G-896S02. Rev.
j 11 which allows an anchor plate with the drilled in anchor bolt to be j
adjacent to the edge of an embedded plate.
To fully address this concern, however, a detailed analysis (reference
- 1) was conducted which considered four combinations of anchor plates installed by Mercury butting up against embedded plates. The combinations chosen represent the cost critical cases. The analysis took into account the concrete cone capacity, the ultimate load capacity of an anchor or stud per original design and the required factor of safety per the original design. The results (Attachment
- 3) indicated that the cone. rete pull out shear cone capacity is greater than the design pull-out load by a factor of about two with an additional safety factor of at least four.
It should be noted that since the loads on the Mercury anchor plates are actually much less than the ultimate load capacity, this was a very conservative analysis.
B.
Evaluation of Plate Spacing Concerns Cited by the NRC The NRC identified six specific cases of concern involving spacing between ancher and embedded plates. As discussed in section V.A above, such configurations are in accordance with Ebasco design drawings and supporting analyses were conducted on varibus combinations of Mercury anchor plates butting up against embedded plates. However, a specific evaluation (reference 1) of each of the six identified cases was conducted. The results indicate that the concrete pull-out shear cone capacity is much greater than the design pull-out load.
C.
Evaluation of Abandoned Holes Adjacent to Installed Hilti Anchor Bolt An analysis was conducted that assumed the entire shear cone area of a drilled in expansion anchor was damaged by abandoned holes with a depth extending two inches to the outer edge of the reinforcing bars.
The analysis is contained in reference 2 and shews that 'he shear cone pull-out capacity is greater than four times the allowable.
-CAUSE:
The basic cause for this concern was the fact that not all expansion anchor characteristics were specifically delineated on the Mercury inspection checklist.
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-GENERIC IMPLICATIONS:'
)
l This concern has been treated generically.
The generic review began with the j
corrective actions undertaken while Mercury was on-site, and continued through the reinspections that took place after their departura, and the 100%
reinspections of N1. installations in progress.
In regard to expansion anchors installed by other contractors, the common.
interface criteria are the distance between adjacent anchors and the concrete edge distance of anchors. These criteria were site addressed and resolved by tha previously mentioned Corrective Action Report and NCR-W3-3316. These criteria are also being checked in the LP&L reinspection of the N1 instrument
' lines.
=.,
SAFETY SIGNIFICANCE:
It is LP&L's position that the Mercury expansion anchor installations are capable of performing their design safety-related function based on:
1)
The requirements within SP-666 as well as those requirements provided in the design documents referenced in SP-666.
2)
The in-depth review and subsequent fielt verification and Discrepancy
. Notice program initiated by Ebasco.
9 3)
The results of the inspection of instrument installations performed
-per procedure QASP-19.15.
Thus, LP&L believes this issue is not a constraint to fuel load or power
-ascension. provides a matrix overview of the inspections, reinspections and analyses discussed in this response.
CORRECTIVE ACTION PLAN / SCHEDULE:
The Mercur Company is no longer on site and it would be of no positive consequence to revise SP-666 as recommended.- However, the installation of expansion anchors for instrumentation continued for any remaining work under the Ebasco Force Account Program utilizing CP-674 (Constraction Installation Procedure). This procedures is more in-depth relative to installation techniques ar.d inspaction attributes but has been revised to ensure all necessary attributas for expansion anchor installatians are explicitly included on the inspection checklists.
t i 17-8
a-The reinspection being performed under QASP 19.15 is expected to be complete by October 15, 1984.
-ATTACHMENTS-
' l 1)
Form 277A to SE-666 Procedure (Blank) l 2)
Completed form 277A to SP-666 Procedure 4
3)-
Results of Analysis of Four Cases of Anchor Plates Adjacent to Embedded Plates 4)
Summary of Verifications of Expansion Anchor Characteristics Cited By the
'NRC
REFERENCES:
, 1)-
Report on Attachment 4 to Allegation 4-84-A-06 #110 and #119 (NRC Concern No. 17) 8/20/84.
l 2)
Report on Abandoned Holes Adjacent to the Installed Anchor Bolt 9/11/84.
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CuST. ORDER NO. t:3-Ny-15 EQUIPMENT It'STALLATION PROJECT k'aterford III i.. J OF NORWOOD. INC.
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REFERENCES:
Dwg. No.
Rev.
Proc. No.
S?-666 Rev. _ _
Dw'g. No.
Rev.
Proc. No.
_Rev.
D.ig. No.
Rev.
Proc. No.
Rev.
Dwg. No.
Rev.
Proc. No.
Rev.
INSPECTION CHECK 1.IST MQC. INIT.
_ACC lREJ 1*
PonDFR TNTAT.T AT TOV T oraTTOY 2.
PROPER INSTALLATION EOUIPMENT S b' 3.
PROPER LENGTH (Bv ID M5rk on BoltJ_Li_s_t_lene 4.
5.
PROPER THRF_4D ENCACE'!ENT (0
7.
8.
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- 10. TOROUE TESTING 1RENCH NO _
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QUANITY 11.
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' ATTACHMENT 4
SUMMARY
CF VERIFICATIONS CF EXPANSION ANCHOR CHARACTERISTICS CITED BY NRC I
- Sample Reinspected
. Reinspection Explicit Allowed by Under CAR Reinspection to be Conducted Attribute Checkpoint Checkpoint Design 82-3-2 Under ECRRI-l under QASP19.15 i Cited By on Form via Reference (G-896 SO2)
Analysis (See para.
.and.3 (See (See para.
NRC 277A on Form 277A (See para.V)
(See para.V)
III).
para. IV).
IV).
- 1. Sp;cing between X
X X-l adjacent-(Checklist cnchors.
Item 1)
- 2. Spicing between X
X X
cn anchor and the (Checklist l
edgn of a Item 1) ccncrete surface.
- 3. Spacing between X
X an tnchor (plate)
(Anchor plate (Anchor plate and an embedded welded to butts up embedded against embed-plate.
plates) ed plate)
- 4. Minimum anchor X
X X
cab dmenc depth (Checklist Item 3)
- 5. Grouting of X
X unu.cd/ abandoned (Checklist holss in the Item 13) concrete.
- 6. Mounting plate X
X cize.
- 7. Size of holes in X
X mounting plates.
- 8. Holes distance X
X from plate edges.
(Checklist Item 1)
A
s-
- s.,
RESPONSE
ITEM No.: 23 TITLE: QA Program Breakdown Between Ebasco and Mercury DESCRIPTION OF CONCERN:
~
The staff review included evaluation of the implementation of the QA programs of LP&L, Ebasco, and Mercury. The staff performed a follow-up on the previous 1982 NRC review that resulted in NRC enforcement action and a civil penalty. The most'recent staff review indicated that LP&L, Ebasco, and Mercury did not followup on the corrective action commitments made to
-the NRC.
Additionally, LP&L, Ebasco, and Mercury failed to audit the entire QA
-programs as required (LP&L only performed one-third of their scheduled audits for a five year period). The audits that were conducted identified some problems, however, the required corrective actions were not completed.
Management audits, performed by outside consultants, identified problems and concerns that LP&L also failed to take corrective action on.
The results of the NRC task force effort indicate that an overall breakdown of the QA program occurred. Most problems identified by the NRC had been previously identified by the QA programs of LP&L, Ebasco and Mercury.
But the failure to determine root cause and the lack of corrective action allowed the problem to persist.
LP&L shall provide an assessment of the overall QA program and determine the cause of the breakdown, together with corrective action to prevent recurrence. This overall assessment is necessary to provide assurance that the QA program can function adequately when the plant proceeds into operations.
23-1
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DISCUSSION:
Issue #23 stands apart from the other NRC concerns with Mercury Company of Norwood in addressing, primarily, the circumstances surrounding the 1982 NRC enforcement action and civil penalty. To paraphrase the NRC concern, issue #23 centers on whether or not the cause of the Mercury problems that led to Enforcement Action 82-109 was identified, corrective action implemented, and recurrence prevented. The central issue is derived from the following specific NRC concerns:
1.
LP&L failed to determine the root cause of the Mercury problems (Section II.A);
2.
LP&L/Ebasco/ Mercury did not followup on corrective action commitments (Section II.B);
3.
LP&L/Ebasco/ Mercury failed to audit the entire QA program (Section II.C);
4 The audits that were done identified problems but corrective actions were not implemented (Section II.D);
5.
Management audits identified problems on which LP&L failed to take corrective action (Section II.D);
6.
The failure to derctmine root cause of the Mercury problem, and the lack of corrective action, allowed the problem to persist into an overall QA breakdown (Section II.B);
e 7.
On the assumption that an overall QA breakdown occurred, the NRC concludes that an assessment of the overall QA program is necessary, including a determination of the breakdown cause and corrective action to prevent recurrence (Section IV).
Based on the present review, LP&L has concluded that an overall QA program breakdown has not occurred at Waterford 3.
The discussion which follows is not intended to minimize the seriousness of the concerns regarding Mercury. Nor is LP&L maintaining that there were no areas needing improvement in the QA program--such areas will be addressed under the " collective significance" assessment of the 23 NRC concerns.
While, in retrospect, there may have been more effective means to resolve the Met.ory situation, what deserves emphasis is that a situation such as existed with Mercury has not recurred and furthermore, under the present management philosophy and implementation of quality assurance, adequate assurance exists that such a situation would be unlikely to recur.
23-2
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a I.;
Background - Identification of the Mercury Problem During the spring of 1982 the first major piping and instrumentation safety-related systems'were approaching construction completion. The
~first four such systems submitted by Ebasco'for turnover were reviewed
'and rejected as a yesult of the LP&L Construction QA audits of system turnover packages.
The following excerpt from NRC Inspection Report 50-382/82-14 dated December 6, 1982 characterizes the results of the
~
Construction QA audits:
S "LP&L learned that, although Ebssco QA had represented the
^
systems as being rerly for turnover and had included statements that the quality records had been reviewed, LP&L found that Ebasco QA had.not actually compared the records with the as-built systems and that,' in fact, the records did not actually represent a true status of the systems at that time.
In addition, the turnover packages contained statements by contractors and Ebasco QA indicating that portions of the turnover packages were incomplete and not QA/QC acceptable."
During subsequent review LP&L reported potential significant construction deficiencies related to inadequate instrumentation and control system installation and turnover documentation for the four systems in question.
In July, 1982 LP&L reported to the NRC through Significant Construction Deficiency (SCD) 57 that a significant construction deficiency existed and~ outlined corrective actions. On December 6,-1982 the NRC, via Enforcement' Action 82-109, provided
. formal' notification of a Level III Violation and civil penalty with regard-to the turnover package deficiencies.
The Enforcement Action noted,'in part, that "[w]hile we recognize that the quality assurance program did not' totally breakdown,-there was a breakdown in the subtier programs of your contractor and subcontractor." The NRC further noted that the penalty was mitigated: "[t]he bases for this mitigation are the corrective action you have' initiated-(the extensive revision of your system turnover process) and your role in identifying 4
and reporting the breakdown of quality assurance programs to the NRC."
1
~
It is worthy of note.that the four subject systems were the first
' safety-related instrumentation system documentation packages submitted by Mercury'for turnover acceptance. Prior to the time of submittal of the documentation packages each of the instrumentation installat!ons was still L
in an "in-process" status (i.e. not accepted by the Mercury QA l
~ organization)..
i 23-3
__________-.a
--____----..--_____.__.--_____.--___---_-.---..____.---__.______------.-....a
II.
Current NRC Concerns A.
Source of the Mercury Problems Consistent with the Notice of Violation LP&L acknowledged (LP&L letter W3I83-0001 dated January 4, 1983) that a partial Quality Program breakdown occurred at Waterford 3 at the subtier levels involving contractor / subcontractor organizations.
In the present concern, the NRC has stated that there was a
"... failure to determine root cause..." of the Mercury situation.
However, during a meeting with the NRC in November, 1982 (as documented in NRC letter from J.T. Collins to L.V. Maurin dated December 6, 1982) LP&L identified the principal cause of the breakdown as "... insufficient participation by LP&L in the implementation of quality assurance programs. LP&L failed to exercise adequate oversight and control over contractors to whom implementation of quality assurance programs had been delegated, and dedicacci.o'cly minimal LP&L resources to quality assurance programs."
This root cause findite was further refined in the LP&L response to the Notice of Violatio: (W3I83-0001 dated January 4, 1983):
" Deficiencies noted in Inspection Report 50-382/82-14, were due to insufficient overview aci support activities, (i.e.,
t, raining) necessary to assure compliance to specified quality requirements.
a Specifically, areas which contributed to the.noted violation are as follows:
a.
Training - training of craf tsmen, QC Inspectors and reviewers was apparently insufficient to provide adequate guidance / direction to assure quality results within the principal contractor organization and two subcontractor organizations.
b.
Staffing - staffing of personnel was inadequate, and as a result, personnel were extended beyond their capability to adequately address quality inspections and reviews within the principal contractor organitation and two subcontractor organizations.
c.
Walkdowns of completed systems were inadequate as a result of Items a and b."
These root cause findings were factored into the Mercury corrective actions described in the following section.
23-4
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=
B.
Corrective Actions
.As to. corrective' actions, the NRC notes that "[t}he most recent staff review indicated that LP&L, Ebasco, and Mercury did not followup.on the corrective action commitments made to the NRC."
.However, LP&L is confident that corrective action commitments in a
respect to Mercury and the Notice of Violation were implemented i
in an effective manner to. produce quality hardware installations.
'During walkdowns conducted.by LP&L and Ebasco in-preparation for turnover of certain Mercury-installed systems in the Spring of 1982, numerous installation deficiencies were identified to
. Mercury. Despite repeated walkdowns with Mercury and meetings with Mercury management, problems continued to exist to the extent that nene of the Mercury systems were acceptable for turnover.
Consequently, on June 23, 1982, with'the Mercury bulk construction approximately 90% complete, project management ordered Mercury to
- cease installation of safety relate'd systems - equivalent to a Stop Work Order (SWO), which will be referred to as such in the following discussion.
^
. Based on LP&L's conclusions relative to the significance of the partial QA breakdown in the Ebasco/ Mercury organizations, and 4
- taking into account the root cause determination, an extensive corrective action plan was initiated and executed. This plan met or exceeded the corrective. action commitments made in response to the Notice of.-_ Violation. A summary of the immediate (June, 1982) corrective actions initiated in conjunction with the SNO follows:
L a.
DevelopmentLand implementation of a retraining program involving Mercury personnel including craft, foremen, field engineers. QC inspectors and supervision.
b.
System by system walkdowns on the basis of the startup schedulelof all safety class installations for~the purpose of identifying hardware deficiencies for evaluation and rework, plus updating the as-built drawings..This effort was initially a joint LP&L, Mercury and Ebasco effort using retrained personnel.
c.
Implementation of extensive organizational changes within Mercury, including assignment of Ebasco Management personnel and engineers to Mercury.
d.
A dramatic increase in the number of Mercury QC Inspectors and QA Engineers.
(Questions as to the qcslifications of Mercury Inspectors are addressed in the response to NRC Issue #1.)
23-5 e
e.
l Mobilization of an Ebasco QA Management Team to support and oversee the Mercury Program.
-f.
Other corrective actions taken not specifically related to Mercury, included the increase in LP&L and Ebasco QA Staff, formation of Ebasco QA surveillance and quality analysis groups, and' enlargement of the scope and size of the Ebasco QA records review group.
- Attachments 1 and 3 provide detailed discussicas of these immediate corrective actions and subsequent corrective actions taken as the Mercury problem became well defined.
It is important to point out that prudence dictated that Mercury be retained as the N stamp holder of instrumentation systems to preserve-the documentation and installed system ASME Code integrity until another stamp holder could take over the work in a phased manner.
Because Mercury continued tp be unable to support the project schedule, and due to management concern with respect to the effort required for future quality installation, the Mercury work scope was gradually reduced through June, 1983 when Mercury was_ relieved of P3-P8 tubing work and all seismic support work including review. Mercury was directed, at that
- 6'ame, to only complete and code stamp P2 instrumentation installation. Ebasco, meanwhile, had obtained an ASME Code Installer's Stamp, allowing then to complete s.pbsequent Code work.
Following the completion of Mercury's initial retraining program Mercury was released to resume safety related installations.
However, only personnel success 'ully completing the retraining program were selected for safety related work.
Throughout the period subsequent to the SWO until Mercury was fully demobilized in November of 1983 LP&L and Ebasco maintained an exhaustive management and QA overview relative to Mercury's
'overall performance. This_ scrutiny resulted in the following:
a.
Continuation of management and organization changes within Mercury.
i-b.
A continuous reduction'in Mercury's work scope. Refer to Attachment I for details.
c.
An improvement in new system installation quality and documentation for work activities initiated after the June, 1982 SWo. Refer to Attachment 2 for details.
d.
Imposition of program changes, both administrative and E
quality related, on Mercury by LP&L and Ebasco.
Refer to Attachment 3 for details.
e.
Decisions on the part of LP&L and Ebasco to remove Mercury'from the quality recorda review program. Refer to Attachment 5 for a discussion of the Ebasco QA records review process and statistics.
22-M
As a result of the continued oversight of LP&L and Ebasco the corrective action commitments made in response to the Notice of Violation were completed. The specific ccmmitments and their resolutions are discussed in Attachment 3.
The issue #23 concern states that "... failure to determine root cause and the lack of corrective action allowed the problems to persist." As previously noted, root cause was identified and corrective action implemented. LP&L believes that the partial QA Program breakdown did not persist; programmatic corrective action to prevent recurrence of the construction deficiencies in any subsequent work activity was prompt and decisive.
The initial rejection of the four major piping and instrumenta-
-tion safety-related systems by LP&L and the resulting corrective action is indicative of a working quality management systeu. The four rejected systems were not unique. Many other Mercury systems were nearing completion in July, 1982. Although deficiencies were identified in subsequent Mercury systea packages, the deficiencies were due to similar reasons at the first four on work completed prior to initiation of corrective action.. Having identified serious problems with four Mercury systems it was expected that some degree of the same types of problems would exist in other Mercury systems that were substantially completed at the time of the SWO.
Howevar, with
.the initiation of corrective actions those problems were.
identified and reworked after the SWO at the Ebasco/ Mercury level,
resulting in generally acceptable turnover packages to LP&L.
a In initiating corrective action on all Mercury systems, manpower availability was taken into account.
Ebasco proposed, and LP&L agreed to, an orderly approach on a system by system basis rather than addressing all Mercury systems at once. This syst'ematic approach was thorough but also extended the time required to close SCD-57 and NRC Inspection Report 50-384/82-14 into the Spring of 1984.
It is possible that this approach may have given the appearance of a continuing Mercury problem to the NRC Inspectors.
-In actuality, Non-Conformance Reports (NCRs) continued to be written for some time on Mercury. work completed prior to July, l
1982. Attachments 2, 3 and 3F provide details and a graphic presentation of the Mercury NCRs'.
Referring to Attachment 3F, the prominent peaks in the number of NCRs at 11/82 and 3/83 are a manifestation of the continuing walkdowns of old (i.e. work completed prior to July, 1982) Mercury work as opposed to an indication of a continuing problem.
A sampling of construction packages was taken to provide evidence that the majority of NCRs written on Mercury systems were related to work completed prior to July, 1982. The results of this review are contained in Attachn.ent 2, providing further confirmation that the partial breakdown with Mercury did not 23-7
,s.. - -
a
persist; actually, because of the corrective actions taken, the quality of Mercury. work improved.
It must be emphasized that the timing of the NCRs is not significant except that it could give the appearance of a continuins problem. Corrective actions proceeded, and were completed, in an orderly fashion on a schedule consistent with the startup schedule of Waterford 3.
The final' phase of corrective action is, of course, verification
~
of installation adequacy. Although addressed in part in various attachments to this response, the bases for Mercury installation verification are collected together in Attachment 5.
Based upon the multiple levels of satis factory review and corrective actions taken, LP&L now has a high degree of confidence that Mercury installations will perform in accordance with design requirements.
This is being further confirmed by the
_reinspections in progress in response to NRC Issue #1.
In summary, the root cause of the Mercury problem was identified and. corrective action was implemented both to correct Mercury work prior to July, 1982 and to prevent cecurrence. Once the Mercury problem was identified, and corrective action begun, the problems did not persist to the degree that existed prior to the SWO.. In fact, the Mercury quality performance improved.
Deficiencies in work prior.to July, 1982 were, identified and reworked on a system by system basis resulting in an extension of the corrective action duration.
C.
Audit of Mercury Installations G
The NRC.has raised the question that:
"...LP&L, Ebasco, and Mercury failed to audit the program as required (LP&L only performed one-thirdyntire QA of their scheduled audits for a five year period).
The audits that were' conducted identified some problems, however, the required corrective actions were not completed."
~
LP&L committed to perform a documented schedule of audits based upon the status and safety importance of the activities to be audited.
The audits were to be' initiated early enough to assess and assure ~ effective control of quality. LP&L maintained a monthly audit schedule and revised it as necessary to assure that the. coverage and schedule reflected current activities and delays in construction scheduling.
In the case of Mercury, during the life of the Mercury contract (approximately 4 years) LP&L scheduled 1
Audits were often deferred from month to month (e.g. due to slippage in construction schedule; higher priority audits; QA support of NRC inspection
. audits; etc.).
As an example, upon completion of one audit scheduled in each of four consecutive months, the appearance of a.25% completion rate of 4
scheduled audits would be given. The audit schedule was a guide to provide LP&L QA management overview of construction activities.
~
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- twenty-eight audits'of the_ contractor. ~ Twenty-four'of the audits (85% of those schedeled)'were completed. Although not a f-commitment.in the QA program, thirteen unscheduled surveillances of.the Mercury program were also conducted. LP&L delegated the
-routine auditing:of_the Mercury QA program to Ebasco Services.
DV
_The Ebasco QA program was structured with an audit schedule based upon a yearly audit of applicable 10CFR50, Appendix B criteria.
=Over the course of the' contract, Ebasco went beyond the minimum requirement in performing 114 audits of Mercury.
Surveillances which supplemented the audit program were also performed on
[
Mercury activities.-
r The Mercury program commitments were to perform a minimum of one 4
. Internal Audit on each auditable section of the QA manual each calendar year. Mercury performed. seventy-four audits during the life of their contract.
In preparation of.this response, the Mercury audit schedule was reviewed and shown to be deficient in not completing' audits of all QA Manual sections in 1981, prior to l
the SWO.~ Following the SWO Mercury met their commitments to the end of their contract.
v Additional detail as to the audit activities of LP&L/Ebasco/ Mercury is provided in Attachment #4 All audits conducted by LP&L and Ebasco of Mercury activities, including audits performed by Mercury, were reviewed for completion of required corrective action.- This_ review was performed by LP&L QA in conjunction with-the preparation for this t
response. The review revealed that corrective actions _ required l,
to close identified audit findings were completed.
During the review of the Mercury Audit File the LP&L reviewer had
' difficulty determining if findings.were closed because files were not organized for ease of followup.
It appears that this file organization led to the NRC reviewer's assertion that "[t]he i
~
audits that were conducted identified some problems, however, the
[
required corrective' actions were not completed."
The' file has since.been re-organized to contain audit packages together with-the supporting information, and is'available for NRC review.
LP&L management questioned if pre-June, 1982 audits could have identified the overall Mercury p'oblem prior to the SWo.
The r
early audits identified many of the individual Mercury problems.
i However, in retrospect, the_ collective implication of these audit 4
i findings on Mercury. was not systematically assessed and therefore the root cause and generic significance were not adequately addressed in corrective actions.
Identification of this approach, whereby the individual problem / solution was addressed rather than overall significance, is a major lesson learned from the Mercury situation.
4 i
i 23-9
_i-D.
Management Assessments by Outside Consultants Issue #23 states that "[m}anagement audits, perfecmed by outside consultants, identified problems and concerns that LP&L also failed to take corrective action on."
It appears that the management audits referred to by the NRC concern are in actuality management assessment evaluations requested by the executive management of LP&L to provide an independent assessment of nuclear project performance during the early years (1977-1980) of construction. These assessments were evaluated by the appropriate LP&L management and actions taken where it was deemed appropriate. Of the concerns noted during these assessments, the majority dealt with organization and staffing matters that were later implemented. LP&L has previously stated before the ACRS in May, 1982 that management was slow to respond to some of the assessment results.
LP&L management, in recognizing the value of independent management audits, contracted Management Analysis Company (MAC) in 1982 to assist in auditing the Waterford 3 plant training program. Audit findings vera promptly presented to management and addressed in a timely cashion. As a result of the audit, the plant training prosram was improved.
t c
4 G
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23-10 u__
-III. Lessons Learned While the corrective actions required because of Mercury's poor performance were adequate to resolve the quality problems and prevent recurrence, in retrospect, _LP&L management would proceed differently today. The listing which follows summarizes the lessons learned from the Mercury experience (both pre-and post-SWO).
They will be further addressed in the " collective significance" submittal for the 23 NRC Concerns.
1.
Delegation to a contractor of the routine QA auditing overview of a subcontractor without adequate utility involvement inhibits the timely recognition by the utility of quality problems, q -
2.
More emphasis should be placed on a QA management overview designed to distinguish generic problem trends and root causes of audit findings from isolated occurrences.
3.
Staffing-levels should have been higher.
These lessons learned were nainly addressed during the Mercury corrective actions.
For instance, LP&L/Ebasco/ Mercury QA i
organizations were increased and LP&L took an active QA role in the review of contractor /sub-contractor. programs. Presently, the QA Program reflects lessons learned from the construction phase in the inclusion of requirements for evaluation of root cause and generic significance of audit findings, and'the implementation of a trending 4
program to identify and correct adverse quality trends. These subjects are expanded upon in the " collective significance" submittal.
1 4
23-11 e
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IV.
Conclusions This issue concentrates on the implementation and adequacy of the corrective action commitments made by LP&L to the NRC in response to Enforcement Action 82-109.
There were aspects of the documentation and historical development which may have been difficult to follow. As noted in Section II.C the manner in which the Mercury audit file was organized did not clearly reflect the completion of audit corrective actions. The management decision to address the Mercury work prior to July, 1982 on a system by eystem basis rather than as a whole could give the appearance of a persisting problem with Mercury due to the continuing number of NCRs written, the majority of which were actually written against pre-July, 1982 Mercury work.
As demonstrated in this response, however, LP&L is conf. dent that corrective action commitments resulting from Enforcement Action 82-109 were effectively implemented to assure quality hardware installation.
The Mercury problem, which gave rise to the Enforcement Action, did not persist nor has it recurred. An overall QA program breakdown has not occurred.
LP&L has established a comprehensive program for quality assurance during the operating phase of Waterford 3.
The QA Program, which includes provisions for requisite staffing and program audits, is described in Chapter 17.2 of the Waterford FSAR and the LP&L Quality Assurance Manual.
Control of all quality related work, a key element of the QA Program, includes use of Condition Identification and Work Authorization (CIWA) procedures. These procedures apply whether work is conducted by LP&L employees or vendors.
P*ocedure implementation was initiated several months ago, along with appropriate training, to ensure worker and supervisor familiarity and capability to' maintain the tight quality control required in an operating environment. Due to the tighter quality controls and the direct LP&L authorization, review and closure of CIWA items, there is reasonable assurance that a partial QA program breakdown of the Ebasco/ Mercury type should not occur during plant operations.
A more detailed description of how the QA program and procedures function and reflect lessons learned during the construction phase and from resolution of the twenty-three NRC issues will be found f r. the " collective significance" response.
9 23-12 m
m CAUSE:
The essence of NRC issue #23 is that, relative to the Mercury problems previously identified by LP&L, there may have been a failure to determine root cause and it'lement corrective actions thereby allowing the problem to persist resulting in an overall QA breakdown. This review concludes that an overall QA breakdown did not occur.
GENERIC IMPLICATIONS:
With respect to the Mercury deficiencies, this issue has been treated generically. From the initiation of corrective actions following the SWO the generic implications for other contractors were taken into account.
For instance, as noted in Attachment 3, the LP&L lask Force charged with physical verification walkdowns of pre-June, 1982 work covered installations by 15 contractors other than Mercury.
The Quality Assurance Installation Review Group software review was directed at all site contractors. Given the quality controls existing in the operations phase QA Program the potential for recurrence of a Mercury type partial QA breakdown has been minimized. Generic implications with respect to the current LP&L QA Program will be appraised in the LP&L response regarding the collective significance of the 23 NRC issues.
SAFETY SIGNIFICANCE:
In view of the adequate corrective act' ions initiated in response to the Notice of Violation as summarized in this submittal there is no current safety signficance associated with Issue #23.
CORRECTIVE ACTION:
There is no further corrective action outstanding for this issue. The Mercury corrective actions were extensive and effective in preventing the continuation of the partial QA program breakdown.
Corrective actions for other identified Mercury concerns (e.g. issues 1, 6) are documented in the responses to those concerns.
Several significant lessons learned from the subject of issue #23 have been factored into the post-SWO corrective actions and are reflected in the present QA Program.
The current status of the LP&L QA Program will be further discussed in the " collective significance" submittal.
ATTACHMENTS 1.
Chronology of Organizational / Management and Scoping Changes for o
Instrumentation Activities 2.
Analysis of Mercury Tubing, Tube Track and Support Installation Records 3.
Corrective Action Status 4.
Audit of Mercury Installations 5.
Verification of the Acceptability of Mercury Installations 23-13
- ~
ATTACHMENT 1 Chronology of Organizational / Management and Scoping Changes for Instrumentation Activities-lI.
General The following Sections II-III contain a summary description of the
_ organizational and management changes implemented in the Ebasco and Mercury p
Organizations as a result of the deficiencies identified in SCD 57 and Enforcement Action 82-109.Section IV discusses the reduction in Mercury work-scope following June, 1982.
II.
Chronology June 1982:
Ebancs notifies Mercury of the documentation discrepancies associated with
-systems 59, 60A, B, & C.
Mercury is ordered to cease safety related activities.. Agreement is reached to assign Ebasco personnel within the Mercury organfhation, reporting to Mercury. Three (3) Ebasco Craft Supervisors are assigned to Mercury.
L July 1982:
a
' As a result of _ meetings and discussions 'amongst LP&L, Ebasco, and Mer y,
it is determined that the overall problem is a result of poor communis-. ion and' inappropriate' management action in Mercury's organization. Mercury agrees to replace their key personnel, but they are unable to provide-replacements.. Ebasco provides personnel for the key positions of Project
' Manager and Construction Superintendent.
In order that Mercury could retain legal control of their obligations.(financial), Mercury establishes
' a new position of Project Administrator to handle personnel and billings.
The most significant organization change is implemented _at this time. The Joint Walkdown Teams (initially 5 teams) are established consisting of an individual from the following: Mercury Engineering, Mercury QC, Ebasco Engineering, LP&L (or Ebasco) QA, and LP&L Start-up.
August 1982:
It is agreed that the personnel supplied by Ebasco to the Mercury organization are temporary, in that, if and when Mercury could supply qualified personnel, then the Ebasco personne1'would be returned. To facilitate'this move, Mercury establishes the position of General Superintendent (filled by Ebasco personnel) while the position of Construction' Superintendent _is reassigned to a Mercury employee.
LP&L Start-up develops a reasonable level of confidence in the walkdown effort resulting in the removal of their members from the Joint Walkdown Team.
23-14
September 1982:
QA/QC reorganizes below the QA/QC Site Manager.
Supervisors are assigned to assist in Field Inspection, Records, and Administration.
By this time Mercury has added (from Ebasco) 3 Construction Supervisors, 12 Engineer /
Designers, and 3 Schedulers. Additionally, Mercury hires 37 QA/QC personnel and 9 engineering personnel.
October 1982:
At this time, while it appears that the quality-related issues are being addressed, Mercury is still not supporting the project schedule.
For this reason,- Ebasco assigns a small Task Force with members from Construction Management, Design Engineering, and Quality Assurance to work closely with the various organizations and personnel to determine if improvements could be developed. One of the Task Force's initial actions is to increase the Joint Walkdown Teams from 5 to 8.
A positica of Project Coordinator is established to provide a means of communicating status to other organizations and communicating priorities within Mercury. Also, an additional Craft Supervisor is assigned to Mercury.
November 1982:
As a result of evaluating the causes for missing completion schedules on open items identified by the Joint Walkdown Teams, the following changes are implemented:
(
System Administrators are assigned to Mercury, reporting to the Project Coordinator.
They are assigned a particular system and responsibility to track all items for that system through the various groups to completion while providing status information to other groups.
It is agreed that the. key to getting Mercury on track is to define the remaining scope of work..Therefore the Joint Walkdown Team is again increased to 12 to expedite identification of status.
December 1982:
Because of the release of Mercury's Project Engineer and the resignation of Mercury's QA/QC Site Manager in November, and because Mercury has difficulty finding qualified replacements, the following reassignments are implemented:
Mercury's Construction Manager assumes the position of Project Manager.
The Project Manager assumes the position of Project Engineer. The Project Administrator position is eliminated and the individual is reassigned as Assistant Project Manager. Mercury's Corporate QA Manager is sent to the site and assumes the responsibilities of the QA/QC Site Manager.
23-15
[
'A new Mercury position of Lead System Administrator is established.
January 1983:
After considerable discussion concerning the QA/QC Site Manager, Mercury assigns the V.P. of F&M Technical Services, as Manager. This new Manager resigns af ter approximately 2 weeks on the project. An acting QA/QC Site Manager is temporarily assigned and proves capable of retaining the
-position.
February 1983:
Mercury releases Ebasco personnel asrigned as General Superintendent and Assistant to the Construction Superintendent.
March 1983:
Ebasco assigns a new Construction Manager.
August-1983:
Mercury releases the last assigned Craft Supervisor back to Ebasco.
III.. Staffing In addition to the organizational changes described above, the following covers Mercury staffing levels during this time period.
Manual Non Manual June 1982 140 100 July 1982 125 110 August 1982 150 130 September 1982 135 145 October 1982 140 175
. November 1982 180 215 December 1982 160 200 January 1983 190 175 February 1983 110 175 March 1983 90 195 April 1983 95 160 May 1983 85 150 June 1983 80 135 July 1983 70 120 August 1983 45 75 September 1983 15 15 October 1983 0
7 November 1983 0
5 j
23-16 O
6
l l
IV.
Reduction in Mercurv Work-Scope Because Mercury continued to be unable to support the project schedule, and due to canagement prudence with respect to the effort required for future quality installation, the Mercury work-scope was gradually reduced over the following year.
In order to preserve the documentation and installed system ASME Code integrity'until another stamp holder could take over in an orderly manner, Mercury was retained on the job.
Shortly aft.er Mercury resumed safety-related work (June / July, 1982) at Waterford 5 the ANSI B31.1 work was reassigned from Mercury to Ebasco.
This was accomplished in several ways:
- 1) by changing the responsibility of work itens on Start-up System Punchlists during daily Start-up meetings,
- 2) by assigning the Completion Verification Sheets of DCNs/FCRs to Ebasco instead of Mercury, and 3) by assigning CIWAs to Ebasco instead of Mercury.
By early 1983, Mercury had been directed not to perform any work in the Turbine denerator Building or the Yard Areas, such work being reassigned to Ebasco.
In March, 1983 Mercury was informed that Secondary Sampling System work would be performed by Ebasco and that LP&L would install six temperature elements in the Reactor Coolant System.
In April,1983 a significant portion of work, installation of instrument
- l drain lines, was deleted from Mercury's scope and transferred to Ebasco.
Additionally, the responsibility for performing integrity tests of ANSI B31.1 installations in the Turbine Generator Building was renoved from Mercury and assumed by LPAL/Ebasco, a
Ccncurrently, from June, 1982, Ebasco wcs preparing to assume Mercury responsibilities.
Ebasco had assigned a separate group of Construction Engineers, Supervisors, and Quality personnel to prepare procedures, develop detail sketches, work packages, etc. in order that work could be deleted from the scope of Mercury's contract.
By July,1982 Ebasco had initiated procedure preparation; by September, activities were progressing in the field; and by early 1983 Ebasco had received an ASME Survey and "N" Stamp.
As a result of this concurrent ongoing program, in July, 1983 Mercury was relieved of further responsibilities save for ASME P2 work. All other work including engineering and documentation review would be performed by Ebacco.
Finally, in late July, Mercury was requested to terminate all work except turnover of QA records and other relevant documentation. The P2 work was accepted by the ANI in July / August of 1983 and Mercury was relieved of further scope. Mercury's last craf t personnel were on-site September 13, 1983. The last non-manual and QA personnel vere on-site November 22, 1983.
23-17
\\
ATTACHMENT 2 Analysis of Mercury Tubing, Tube Track and Support Installation Records As a result of the corrective actions initiated in response to the Mercury problems which led up to the June, 1982 Stop Work Order, an improvement in Mercury's quality performance, with respect to hardware installation, is expected.
It is reasonable to expect this assumption to be reflected in the Mercury QA records documentation submitted to Ebasco for review.
This analysis is intended to provide confirmation of the accuracy of this assumption.
Documentation records for the 19 Mercury OCRs (installation travellers) which were initiated for new system installation begun after the SWO on tubing, tube track and support installations were compared to 19 Mercury OCRs on system work near completion (other than subsequent corrective rework) at the time of the SWO.
The 19 post-SWO OCRs comprise the entirety of new Mercury tubing, tube track and support safety-related instrumentation system installations initiated after the SWO.
Two aspects of the documentation were analyzed:
1.
Documentation deficiencies were categorized and the quantities of deficiencies for the pre-and post-SWO packages were compared (see the following Section I).
2.
The Mercury Non-Conformance Reports (NCRs) written against the systems comprising the 19 pre-SWO OCRs were identified and categorized as to when the work was completed (see the following Section II).
Based on the present review, adequate documentation erists to confirm a definite improvement in the quality of Mercury work following the SWO and initiation of corrective actions.
In addition, confirmation was'obtained that during the period 6/82 - 8/83 the majority of Mercury NCRs were written against work completed prior to the SWO.
I.
The 38 OCRs were reviewed for documentation deficiencies in two areas
- tubing installation and tube track / support installation.
The documentation categorization and review results are as follows:
TUBING INSTALLATION Category Description A
Software discrepancies requiring no QC reinspection or rework to resolve (minor paperwork problems).
B Software discrepancies requiring Ebasco QC reinspection to resolve; no rework required (e.g.
verify support type or heat number).
C Documentation discrepancies which were upgraded to discrepancy notices or NCRs
~
~
23-18
Results i
Category Installation Prior to 7/1/82 Installation After 7/1/82 A-40 (31%)
183 (90%)
B 62 (48%)
8 ( 4%)
C 27 (21%)
10 ( 5%)
TOTAL 129 201 TUBE TRACK / SUPPORT INSTALLATION Category Description A
Support or tube track documentation packages with no deficiencies.
B Support or tube track documentation packages with-documentation deficiencies which required Ebasco QA reinspection to resolve; no rework required.
C Support or tube track installations with missing or incomplete documentation; reinspection required.
Results Category Installation Prior to 7/1/82 Installation After 7/1/82 A
109 (51%)
147 (65%)
B 48 (23%)
39 (17%)
C 55 (26%)
39 (17%)
TOTAL 212 225 A comparison of the significant documentation deficiencies, Categories
-l B and C, indicates improved quality performance.
The improvement is particularly evident with respect to tubing installations. Although this comparison is limited by the number of OCRs that represent completely new (post-SWO) work, the data suggest that corrective action measures and continued management overview of Mercury were effective in bringing about an improvement in Mercury's quality related activities with respect to hardware installations.
23-19
II. Using the same pre-SWO OCRs as the previous section, a review was conducted to identify all NCRs written against the OCRs. During the review, NCRs were categorized according to the following scheme:
Category Description 1
NCRs written prior to 6/23/82 against work performed prior to 6/23/82, 2
NCRs written subsequent to 6/23/82 against work performed prior to 6/23/82.
3 NCRs written subsequent to 6/23/82 against work performed subsequent to 6/23/82.
Category 1 reflects NCRs written prior to corrective action; Category 2 covers those NCRs written during the corrective action walkdowns of pre-SWO Mercury work; and_ Category 3 NCRs are those written against work performed following corrective action.
The review results are as follows:
NCRs on Installations Primarily Completed Catenory Prior to 6/23/82 1
25 2
65 3
37 TOTAL 127 Of importance is the relationship between Category 2 and Category 3 NCRs - nearly a 2 to I ratio betwen NCRs written on pre-SWO work and NCRs written on post-SWO work. The present review supports the position that the majority of Mercury NCRs written during the 6/82 -
8/83 period (see Attachment 3H) were actually written during the corrective action phase against Mercury work completed prior to 6/23/82 and are not indicative of a continuing problem with Mercury.
23-20 e
h _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _. _. _
m___._
ATTACHMENT 3 Corrective Action Status In response to the Mercury problems encompassed by Issue #23 a number of corrective actions were implemented, several of which went well beyond the Mercury concern by addressing generic problems. The following material details Mercury corrective actions. To assist in identifying those which were commitments to the NRC in response to the Notice of Violation, the table in A is provided.
1 1.
Mercury Company, as a result of the Stop Work Order on 6/23/82, reassigned craft off safety-related system work and began developing a reindoctrination/ reorientation program. LP&L QA was directly involved in the development of the documented retraining program which was completed and approved on June 25, 1982. The Mercury program included training for record reviewers, QC inspectors, craft and engineering personnel. The program was submitted and documented in Mercury Letter WA-964 dated June 25, 1982 and reviewed / approved by Ebasco letter F-58853 dated June 25, 1982. The implementation of the retraining of reinspection / rework teams began on June 26, 1982. Verification is available in Ebasco letter F-58490-AST dated June 28, 1982. The Ebasco/LP&L concurrence of proper execution of the retraining program was accomplished on June 29, 1982 and is documented in Ebasco letter F-58490-AST dated June 28, 1982 which released Mercury on safety-related work by retrained personnel. The Mercury retraining program continued through March, 1983.
2.
Following the Stop Work Order, Mercury began implementation of corrective action commitments. Concurrently, Ebasco mobilized a QA Management Team on 7/6/82 to support and oversee the Mercury program. On 7/7/82 the Team outlined an action plan which assigned, to Ebasco QA Managers, responsibilities in the areas oft A.
Improvement in tracking and timely completion of Significant Construction Deficiencies, Nonconformance Reports Deficiency Notices and Audits.
B.
Increased contractor QA Surveillance (actual as-built verification by assigning a QA Surveillance Engineer to Mercury).
C.
Reorganization of Ebasco QA auditing functions and organization to improve the quality and content of sub-contractor oversight.
D.
Establishment of a QA Records Turnover Review system and organization, by assigning an Ebasco QA Records Group to work parallel with the Contractor's QA reviewers.
23-21 O
e
While the action plan of the QA Management Team was initiated in response to the problems identified with Mercury, the scope of the plan included all sub-contractors. Additionally the action plan provided for an increase in the Ebasco document review, QC and supervisory staffs and retraining of personnel involved in documentation revieu.
The action plan items were implemented as follows:
Area A - established by week 8/30/82.
Area B - established by week 8/30/82 (for detailed information see Item #4 below).
Area C - established by week 7/26/82.
Area D - Ebasco QA Records Coordinator was assigned on 7/26/82.
3.
With LP&L concurrenca, Ebasco formed a Quality Assurance Surveillance Group (Action Item B, abore) to increase involvement in the in-process construction activities including hardware installation, system turnover, walkdown inspection and system testing.
Actions taken after formation of the Surveillance Group include:
A)
Issuance of a new procedure QAI-15 " Surveillance of Site Contractors" Rev. O, 7/26/82.
B)
Issuance of a new procedure QAI-16 " Qualification of Quality c
Surveillance Personnel" Rev. O, 7/30/82.
C)
The QA Surveillance personnel were trained and recertified to the new procedures.
D)
A QA Surveillance Plan and Schedule was completed on 8/17/82.
The concept of full time QA surveillance of site contractor activities can play an important role in the construction management process. The extent and effectiveness of the surveillance group in identifying deficiencies which addressed not only Mercury but other site contractors is evidenced by the surveillances conducted, and resulting nonconformances identified, which were then resolved by the Site Quality Program.
For example, a total of 48 surveillances were conducted on' Mercury from 8/82 thru 5/83 which identified non-conforming conditions such as undersize welds (Ref. SH-1, 12/21/82 & TM-1, 12/27/82) and unacceptable welder qualifications (Ref.
NB-17, 10/11/82). A listing of the Mercury surveillances is included in B.
4 The Quality Programs and Procedures of affected organizations were reviewed and revised, as applicable.
23-22 e
t
Mercury Company during the time period from March, 1982 thru June, 1983 revised 32 of the existing 48 approved procedures for use on Waterford 3.
This involved a total of 70 actual procedural revisions.
Included in these revisions were installation procedures, QA program auditing and process control traveler preparation and control (see Attachment 3D).
Ebasco during the time period from May, 1982 thru May, 1984 revised, voided or issued a total of 30 procedures which are listed in Attachment 3C.
The program revisions / additions included the following which are detailed in other corrective action responses or available on site for review:
A.
Establishment of a QA Surveillance Group.
B.
Redefinition / assignment of site training responsibilities.
C.
Establishment of a Quality Analysis Group.
D.
Separation of the Quality Assurance Installation Review Group (QAIRG) from QA Engineering and increased staff levels.
E.
Development of specific records review forms for individual Contractors.
F.
Stricter controls on the system turnover process.
5.
A Task Force was developed, established and staffed separately by the Corporate Management of LP&L to perform Quality Records Review and physical verification by walkdowns of selected activities, of contractors and subcontractors who performed safety-related work prior to June 1, 1982, to aseure compliance with the QA program.
The LP&L Task Force was comprised of personnel from LP&L QA and the LP&L Nuclear Project Support Engineering Group. The action plan for the Task Force was approved by the LP&L Vice-President-Nuclear Operations.
LP&L procedure QP19.1, " Task Force Installation Verification" was approved and issued on January 11, 1983, under the direction of the QA Manager.
The procedure provided direction for the implementation methods and reporting mechanisms necessary to ensure adequacy of contractor work prior to June 1, 1982.
Specifically, for 15 contractors, walkdowns were performed using checklists to verify that the installed condition was in accordance with related documentation.
Where system walkdowas' vere impractical, analytical means were employed to confirm the adequacy of the installation. Where applicable, dimensional checks of mechanical components, inline equipment, cable tray and pipe supporta, component locations, welds, and terminations (separation) were verified to ensure agreement with engineered /as-built drawings. Checklists were sufficiently detailed to ensure necessary discipline items were verified. Record reviews were performed on the supporting documentation for the physical activities verified during walkdowns. Checklists were used to document these record reviews Verification of the as-built drawings to the physical configuration as installed was the prime concern of the record reviews.
23-23
In April 1983'the:LP&L Task Force review was completed. The Task Force
~
findings.were transmitted to Ebasco as LP&L Audit-W3S-83-QP19.1/W3S-83-3 in accordance with the LP&L Quality Assurance Program.
In September, 1983, following corrective action,'LP&L Audit.W3S-83-QP19.1/W3S-83-3 was closed.
iThe Task Force review identified some record and system' installation
. deficiencies-requiring further reinspection and corrective actions as Ldocumented.in W3I83-0115 (4-8-83) and W3K83-1808 (11-21-83).
The NRC (in Inspection Report 50-382/84-34) reviewed the LP&L Task Force
. implementation and results. _An open' item was identified by the NRC concerning physical verifications of Chicago Bridge and Iron-installations.
lAs noted by the LP&L Task Force, the Hot Functional Testing during the
- ' period of their review prevented a walkdown of the physical installations, however, a review of radiographic documentation was conducted. The open item notrichstanding, the NRC indicated that "[t]he-Task Force verification effort and findings did. contribute to the overall LP&L and NRC assessment
'of the acceptability of the contractor work and effectiveness of LP&L's QA program."
6.
- The LP&L QA organization was enlarged and supplemented with contract personnel in order to provide broader'QA coverage of safety-related site activities. Attachment 3E details the LP&L QA staffing history
. demonstrating the dramatic increase in QA personnel over the last half of 1982.
7.
The LP&L QA organization developed procedures and conducted audits to verify. system configuration and documentation prior to turnover to LP&L Start-up. Procedure QASP 17.5, " Quality Records Review" assures
. verification of system configuration and documentation prior to system c
-turnover' to LP&L.
8.-.
Plant staff, in conjunction with start-up engineers -performed system walkdowns and verified status of the configurations of the systems prior to transfer to the plant staff. Thirty days prior to any scheduled system transfer the cognizant Plant Staff engineer along with the Startup and Ebasco engineers perform a system walkdown to generate deficiency lists and review the system configuration to determine that it is constructed as depicted in system drawings. A walkdown by the same personnel and other Plant Staff personnel is then conducted fourteen days prior to scheduled
. system transfer to verify, among other things, acceptable progress in addressing system deficiencies. The pre-transfer walkdown process is identified in Startup procedure SAP-40, " System Transfer from Startup to
' Plant Staff", and Plant Operating Manuel Procedure UNT-TEM-003 (previously, UNT-1-008), " Review and Approval of System Transfer".
9.
The responsibility for Significant Construction Deficiencies, Inspection Reports and other required reporting was transferred from LP&L QA to LP&L Licensing. This change allowed more time for direct involvement by LP&L QA in construction activities.
1 F
23-24 4
f L
l'
7 w
.,g
-10. - A review of the Mercury Historical Nonconformance Report files indicated a
'significant increase in the, generation / resolution of nonconformance reports after'the 6/23/82.Stop Work Order. A total of approximately 436 NCRs had been generated by Mercury prior to the SWO and a total of approximately 3323 NCRs were' generated subsequent to the SWO. During the entire program Ta total of approximately 1632 Mercury Nonconformance Reports were upgraded to Ebasco-NCRs.- This increase in NCRs can be correlated to the corrective-action walkdowns conducted during 1982/83 as shown in Attachment 3F.
The increase is indicative of corrective actions taken particularly in management / supervision attention and the retraining of QC inspection personnel together with a better definition of inspection criteria.
It is also indicative of the methodology employed whereby the inspection activities instituted to assure acceptance of all Mercury safety-related work was completed on a system by system basis rather than trying to address all Mercury systems at once. This approach resulted in the identification and closure of deficiencies over a longer period of time.
For additional analysis of the Mercury NCRs please see Attachment-2.
11.
As effective as the corrective actions were in resolving hardware related concerns and upgrading the Waterford III QA program, problems with Mercury still' occurred, but with much less frequency. Examples of these concerns include the reopening of SCD 61 (Sandvik tubing defect) and SCD 84 (tube track welding) cited in NRC Issue #6. Many of the documentation and hardware problems identified after the_SWO can be attributed to ineffectual programs in existence prior to_the SWO. Nonetheless, the SWO corrective actions were effective in not allowing the partial QA breakdown to continue. The overall impact of the Mercury issues will be addressed in
" collective significa1ce".
e t
[
23-25 e
s
=_
ATTACIDfENT 3A Location in
~
Issue #23 Where Noticelof Violation Commitments ~
Addressed
- 1. :.
'An. extensive training / retraining' program Attachment #3, was : implemented by Mercury for their-Item I records review, QC inspector, craft and I
engineering personnel.
This program will continue in order to maintain the-proficiency of these personnel.
22.
Joint system walkdowns with Mercury Attachment #5, and Ebasco have been' initiated for Item 1 the purpose of problem identification Attachment #3, and resolution prior to system Item 10 release and turnover.
3.
Mercury has increased their'documention Attachment #1 review and QC inspection staffs.
4 '.
Ebasco formed a QA Surveillance Group Attachment #3,
~
to perform random physical inspections Item 3 to assure contractor compliance to established requirements.-
5.
Ebasco has increased its document review, Attachment #3, l?C and supervisory staffs and has Item 2 retrained personnel involved in review of documentation.
6.-
The LP&L QA organization has been Attachment #3, enlarged and supplemented with contract Item-6 personnel _in order to provide broader QA coverage of safety-related: site activities.
7.
LPSL QA has developed procedures and Attachment #3, will conduct audits to verify system Item 7 configuration and documentation prior to turnover to LP&L Start-up.
8.
Plant staff, in conjunction with' Attachment #3, Start-up engineers, wi11 ' perform -
Item 8 system walkdowns and will verify the' status of the current as-built configuration of the system prior to transfer to plant staff.
9.
Responsibility for Significant Attachment #3, Construction Deficiencies, Inspection Item 9
' Reports, and other required reporting has been transferred-from QA to Licensing.
23-26
. Location in Issue #23 Where Notice of Violation Commitments Addressed 10.
LP&L has developed an aggressive plan to Attachment #3, establish methods for quality record Item 5 reviews and applicable physical verification for selected activities performed by 15 contractors who performed safety related activities pr.'or to June 1, 1982.
The plan will be implemented by LP&L QA and Engineer-ing personnel, 11.
LP&L and its contractors have. reviewed Attachment #3, for adequacy those procedures related Item 4 to the turnover process and have revised them as necessary to assure that review requirements are clearly stated.
O e
I t
e 0
23-27 e
4 h.
ATTACHMENT 3B Ebasco Surveillance Group Surveillances of Mercurv 8/18/82 W3-NY-15 NB1 Surveillance - Walkdown 8/18/82 W3-NY-15 NB2 Procedure Revision Form 276-1 8/25/82 W3-NY-15 NB3 Review OCR Package 607 8/23-24/82 W3-NY-15 NB4 Review OCR Package 607 SP-660 8/26-27/82 W3-NY-15 NB5 Review OCR Package 1312 9/1/82 W3-NY-15 NB6 Piping & Tubing - Code Stamping 9/7/82 W3-NY-15 NB7 Walkdown - Welding 9/8-12/82 W3-NY-15 NB8 Walkdown & Review Instr. Packages 9/15/82 W3-NY-15 NB9 Weld Machine Calibration 9/18/82 W3-NY-15 NB10 Measuring & Test Equipment 9/23/82 W3-NY-15 NB11 Walkdown 9/27/82 W3-NY-15 NB12 Visual Exam Proc. QCP-3110/R3 9/30/82 W3-NY-15 NB13 Mercury Removal of Items 10/1/82 W3-NY-15 NB14 Walkdown of Sys RCP Support IB 10/4/82 W3-NY-15 NB15.
FCR-AS-2066 10/5/82 W3-NY-15 NB16 Instrument / Support 10/11/82 W3-NY-15 NB17 Welder Qualifications 10/14/82 W3-NY-15 NB18 Audit of QA/QC Personnel - Cert 10/14/82 W3-NY-15 NB19 In process support 10/14/82 W3-NY-15 NB20 Storage SS Tubing 10/19/82 W3-NY-15 NB21 NCRs Assoc Sus 46 10/21/82 W3-NY-15 NB22 DN USE 11/12/82 W3-NY-15 NB23 Walkdown OCR 670 11/12/82 W3-NY-15 NB24 Removal of Items 11/12/82 W3-NY-15 NB25 Walkdown OCR-388/758 11/18/82 W3-NY-15 NB26 Removal of Items 11/19/82 W3-NY-15 NB27 Walkdown OCR 1756 11/19/82 W3-NY-15 NB28 Thermovell Installation Procedure 11/20/82 W3-NY-15 NB29 NCR-W3-4504 SUS 47 11/23/82 W3-NY-15 NB30 OCR 1687 11/29/82 W3-NY-15 NB31 Mercury QA Training 12/3/82 W3-NY-15 NB32 NCR Admin. Closure 12/3/82 W3-NY-15 NB33 Instrument TE-MS-83455 1/6/82 W3-NY-15 NB34 Use of Form 211 to Doc. NCR Condition Program 12/21/82 W3-NY-15 SH1 Walkdown SUS 43A-9 12/27-31/82 W3-NY-15 TM1 Walkdown Instr. Lines 12/28/82 W3-NY-15 TM2 Walkdown Surveillance 12/29/82 W3-NY-15 TM3 CAR #129 Review 1/4/83 W3-NY-15 TM4 Pneu Test Witness 1/6/83 W3-NY-15 TP1 Walkdown Inst. Lines 1/17-18/83 W3-NY-15 TP2 Training 1/26/83 W3-NY-15 NB35 ISO Revision 2/15/83 W3-NY-15 SH2 QCP-3110.5 2/18/83 W3-NY-15 TM5 Use of Cerrespondence 4/18/83 W3-NY-15 TM6 Inst. Cabinets & Racks 4/25/83 W3-NY-15 TP3 SP-663 (R-2) 5/20/83 W3-NY-15 TM7 Hydro /Pneu Testing 5/27/83 W3-NY-15 CM1 SP-664 23-28 e
ATTACHMENT 3C Ebasco Procedural Revisions May 1982 - June 1984 Procedure No.
Procedure Title Revision /Dateg QAI-1 QA Records Management Instructions 11 2/8/84 10 8/5/82 9
8/3/82 QAI-2 QA Review of Site Gen. Procedure of 3
7/2/82 Activities Afteccing Quality QAI-6 Processing of Safety Related PR/PO 7
6/4/84 6
5/9/84 5
10/28/82 4
7/1/82 QAI-7 QA Instruction for Surveillance &
2 2/21/84 Corrective Action 1
7/2/82 QAI-9
- Reviev & Handling of Construction 2
4/20/83 Installation Records QAI-14 Training & Qualification Requirements for 4
6/5/83 QA Records Personnel 3
9/24/82 2
8/24/82 1
8/10/82 0
7/26/82 QAI-15 Surveillance of Site contractors 4
6/5/83 3
9/24/82 2
8/24/82
- 1 8/10/82 0
7/26/82 QAI-16 Qualification of Quality Surveillance 2
3/13/84 Personnel 1
9/28/82 0
_7/30/82 QAI-18 Data Report Processing Quality Assurance 3
10/3/83 Engineering Department 2
8/30/83 1
8/3/83 O
6/1/83 QAI-19 Processing of Discrepancy Notices (DNs) and 2
2/10/84 Engineering Discrepancy (EDNs) 1 7/15/83 0
6/15/83 QAI-20 Walkdown Reverification of flangers 1
7/11/83 0
6/27/83 23-29
Ebar:0 Procedural Revisions May 1982 - June 1984 Procedure No.
Procedure Title Revision / Dates QAI-22 Preparation of Response to NRC Iu.pection 1
8/30/83 Reports 0
8/2/83 QAI-23 Review of Ebasco Construction Quality 4
2/4/84 Records 3
11/30/83 2
11/8/83 1
10/18/83 0
8/29/83 QAI-25 QA Instruction for Auditing at Waterford 3 0
8/22/83 QAI-26 Initiation / Preparation of PRI/SCD Reports 0
2/10/84 QAI-29 Review & Recurrence Control of Adverse Trends 0
1/30/84 Reported by the Ebasco Trend Analysis QAI-30 Documentation Statusing Review Instruction 0
2/1/84 QAI-31 Processing of Nonconformance Reports 0
2/9/84 WQC-167 Review /Trans. of Quality Related Records 1
5/24/82 WQC-168 Inspection of' Instrumentation Installation 3Al 6/22/82 i
WQC-169 Ceneral QC Inspections 1
6/22/82 WQC-200 Inspection & Test Status ASME QC VOIDED WQC-201 Control of Wald Filler Metals ASME QC VOIDED WQC-202 Inspection of Piping llangers/ Supports 2A3 10/18/82 Including Rupture & Whip Restraints WQC-204 ASME Piping / Tubing Installation Inspection 1
10/20/82 WQC-205 Inspection of In-Place Storage & Maintenance 0
10/26/82 of Mech. Piping Permanent Plant Items WQC-208 Piping System Cleanliness Ihspection 3Al 9/9/82 Procedure ej WQC-209 Inspection & Surveillance of Ebasco 0
10/26/82 Installed Cond!tional Acceptance Items WQC-212 Ebasco QC Requirements of NDE Services ASME 2
10/20/82 WQC-213 Quality Control Review of ASME Section !!!
0 10/25/82 Piping / Tubing Travelers 23-30 H
ATTACHMENT 3D Mercury Procedural Revisions May 1982 - June 1984 Precedure
' No.
Procedure Title Revisions / Dates MCP-2100.
Welding Centrol 13 3/3/83 12 1/13/83 11 9/27/82 MCP-2101 Welding Repair 4
1/25/83 3
10/13/83
~MCP-2170 Pressure Testing 8
4/19/83 7
2/20/83 6
6/22/82 5
5/3/82, PCP-2010 Document Control 10 5/17/83 9
10/4/82 8
6/4/82 7
6/2/82 6
3/11/82 PCP-2030
-Material & Equipment Control 5
10/11/82 QCP-3010 QA Records Control 4
10/16/82 QCP-3020 QA Program Auditing 4
9/13/82 3
7/26/82 QCP-3050 Qualification of Inspection & Test Personnel 4
10/17/82 QCP-3110 Visual Examination 4
9/30/82 QCP-3110.4 Pipe & Tubing Inspection 10 2/18/83-
~
9 9/29/82 QCP-3110.5 Welding Inspection 8
2/21/83 7
1/19/83
'N 6
8/6/82 5
4/5/82 SP-650.
Preparation, Review & Approval of Special.
4 3/15/82 Procedures s
s
~
SP-652 Installation of.' Process Pipe Hanger Supports 10 1/14/83 9
10/17/82 4.
8 6/29/82 s.
'7 6/12/82 1
1.,
y,
- s.,
, 31 s
- v. m.
Mercury Procedural Revisions May 1982 - June 1984 Procedure No.
' Procedure Title Revision / Dates SP-653 Fabrication & Installation of Safety Class 2 & 3 6
1/13/83 Process Pipe 5
10/12/82 SP-654 Tube. Tray Hanger Fabrication & Installation 9
1/14/83 8
12/20/82 7
9/28/82 6
7/21/82 SP-655 Construction Procedure for Assembly Fabrication 5
1/12/83
& Installation of Seismic Class 17 c'st Instrument Assemblies57-656 Fabrication of Local Instrunent Piping & Tubing 5
1/13/83 Assemblies 4
10/12/82
~SP-657 Installation of Impulse Lines 6
3/2/83 5
1/13/83 4
10/12/82
-SP-658 Installation of Seismic 1 Tube Tray for ASME 4
3/15/83 Class 2 & 3 Tubing SP-659
. Procedure for Receiving Interface 4
2/8/82 SP-660 Procedure-for Preparation & Contrel of the
-7 12/17/82 Process Control Traveler 6
10/21/82 5
9/27/82 4
6/7/82-SP-661 Welding NDE Interface 4
4/4/83 SP-664 Handling of Noncomformances & Corrective Action 4
6/20/83 3
5/10/83 2
3/8/83 1
9/27/82 SP-666-
~ Drilled-InExpansionTypeAnchobsInConcrete 8
2/24/83 for Category I Str2ctures Seismic Class I 7
9/28/82 6
8/16/82 5
5/18/82 SP-667 Control of As-Built Information 5
9/30/82 4
5/14/82 23-32 c.
r.
Mercury Procedural Revisions May.1982 - June 1984
" Procedure.
No.
Procedure Title Revision / Dates SP-671 Release and Turnover from Mercury to Ebasco 1
2/14/83 Construction SP-672 Welding Parameter Card Procedure 0
8/13/82 WPS-B Welding' Procedure "B" 12 11/2/82 11 8/12/82 WPS-D Welding Procedure "D" 13 11/2/82 12 8/12/82 WPS-E.
. Welding Procedure "E" 11 11/2/82 WPS-G Welding Procedure "G" 11 11/2/82 10 8/12/82 WPS-Y' Manual Gas Tungsten Arc / Shield Metal Arc Welding 10 8/13/82 ASME Section IX Group Hetal Thickness Range t
4 9
9 0
W 23-33
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ATTACIDiENT 3E 23-34
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MERCURY NCR'S WRITTEN BETWEEN 6/23/82 8 8/83 4
i i
800-l.
708 1
700-i, 600-F l
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500-N m
ix M
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208 z 200-17 9 167 179 16 4 14 9 i
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100-I MERCURY WALKDOWN ENGINEERING WAl KDOWN 42 28
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7 8/83 9-
ATTACHMENT 4 Audit of Mercury Installations The established Quality Programs of LP&L, Ebasco and Marcury were approved and accepted by all required organizations.
They meet the requirements of 10 CFR 50 Appendix B Criterion XVIII and ANSI N45.2 standards invoked on the Waterford III project. With respect to the NRC concern regarding the apparent failure to audit the entire QA Program the following is provided.
.I.
LP&L QA Audit Program As documented in the Waterford 3 PSAR, during the construction phase
-LP&L Quality Assurance was committed to function primarily as a Quality Surveillance group.
Ebasco was responsible for assuring contractor compliance with their respective QA program requirements.
In fulfillment of its role, LP&L QA conducted audits of contractor activities as deemed necessary. LP&L QA maintained a monthly audit schedule and revised it based upon available resources and criticality of activities to be monitored.
In the case of Mercury, a total of 28 audits were scheduled. Attachment 4A is a summary of the completed LP&L QA aucits of Mercury. Additionally, 13 unscheduled surveillances of Mercury were conducted by LP&L as shown in Attachment 4B.
i
,II. Ebasco QA Audit Program The Ebasco QA audit program was structured to audit contractors yearly for compliance with the applicable 10CFR50 Appendix B criteria.
In the case of Mercury, Mercury compliance to criterion IV was not audited by Ebasco since permanent installation material procurement was handled by Ebasco. C provides a matrix of Ebasco audits of Mercury with respect to the Appendix B criteria. This
. attachment demonstrates that the required audits were conducted.
III. Mercury OA Audit Program The Mercury Quality Assurance Program required a minimum of~one internal audit'be conducted annually on each auditable QA Manual Section. The Mercury audit schedule was reviewed and shown to be deficient in not completing audits of all QA Manual sections as-required during 1981, prior to the SWO.
Following the SWO, Mercury met their commitment requirements to the end of their contract.
Information on the Mercury internal audits is available for NRC review.
23-36
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ATTACHMENT 1A LP&L AUDITS OF MERCURY COMPANY (1979 - 1983) 1979 W3S79-6 1/15/79 EEI Checklist W3S79-18 3/19/79 EEI Checklist.
W3S-79-36 5/29/79 Criteria V - Mercury Procedures W3S-79-37 6/7/79 Criteria VI - Mercury Procedures W3S-79-41 6/25/79 Critaria X - Mercury Procedures
'W3S-79-42 12/5/79 Criteria IX - Mercury Procedures
-1980 W3S-80-35 9/12/80 Criteria II, X - Mercury Procedures W3S-80-39 7/2-10/2/80 QA Program Review 1981 W3S-81-8 1/12-2/23/81 SP 654, 666 W3S-81-15 3/25/81 SP-655, MCP 2140 W3S-81-32 8/27/81 Hercury QA Program W3S-81-36 8/21-9/2/81 Criteria XIII - Mercury Procedures W3S-81-39 10/8/81 Criteria V - SP-660 W3S-81 10/16/81 Criteria II - Mercury Procedures W3S-81-51 12/7/81 Criteria III - SP-667 6
4
~1982 W3S-82-13 1/20/82 Criteria XI - Mercury Procedures.
W3S-82-14 2/4/82 Criteria XII - Met. Lab W3S-82-62 7/22/82 Criteria V', X, III W3S-82-62 7/22/82 Criteria III, V, X W3S-82-64 7/30/82 Ceiteria XV, XVI' W3S-82-77 10/5/82 Criteria II, X, QCP-3050 W3S-82-84 11/8/82 Criteria VI W3S-82-85 10/25-11/8/82 10CFR50/ ANSI N45.2 1983 W3S-83-10 7/8/83-Criteria V - Mercury Procedures 9-4 e
e s
23-37
~
ATTACHMENT 4B LP&L'SURVEILLANCES OF MERCURY COMPANY (1979-1983) 1979 No Surveillance Performed 1980 W3S-80-8s.
2/21/80 Mercury Walkdown RAB W3S-80-36s 9/22/80 Mercury Criteria V W3S80-40s 10/17/8C Protection of SR Instrument Impulse Line
' 1981 W3S-81--31 s 8/7/81 Mercury Mechanical Separation 1982
.W35-82-56s
- 7/6/82 Mercury 10CFR50/ ANSI N45.2 W3S-82-57s 7/11/82 Mercury 10CFR50/ ANSI N45.2 W3S-82-54s 6/28/82 Mercury 10CFR50/ ANSI N45.2 W3S-82-55s 6/74/82 Mercury 10CFR50/ ANSI N45.2 W3S-82-59s 7/23/82 Mercury SP-665 W35-82-61s 7/21/82 Mercury ANSI N45.2.2 W3E-82-73s 9/23/82 Seismic / Tube Track W3S-82-79s 10/18/82 Mercury Criteria V W3S-82-81s 10/28/82 SP-667, QCP-3110.4
- 1983 W3S-83-19s' 8/19/83 Hydro-Pneumatic Testing
(
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9 9
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9
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23-38
l ATTACllMENT 4C Ebasco 18 CRITERIA - 10 CFR50 APPENDIX B i
Audits cf Mercury' I.
II III-Iy v.
y1
'VII V111 IX-Note 2 79-11-1 79-12-4 N/A 79-2-1 79-10-2 79-11-2 79-2-3 79-11-3 79-7-1 79-10-3 79-2-3 79-4-4 79-1-8 79-1-1 79-6-6 79-1-8 79-1-5 79-2-3 79-7-3 79-1~5 79-3-3 79-8-2 1979 79-3-2 79-8-4 79-3-1 79-4-3 79-8-5 79-4-3 79-8-7 79-5-3
.79-10-4 1
79-6 :
l 80-12-1 80-2-3 80-9-1 N/A 80-9-2 80-4-6 Note 5 80-2-8 80-7-2 80-6-2 1980 80-4-7 80-6-1 80-2-1 80-7-1 80-8-4 80-4-2 81-9-1 81-1-4 81-9-3 N/A 81-4-1 81-2-2 Note 5 81-1-3 81-2-3 1981 81-3-2 81-5-2 81-12-1 82-2-1 82-11-1 82-7-6 N/A 82-2-1 82-5-1 Note 5 82-11-2 82-1-2 82-10-1 82-6-1 82-2-2 82-2-1 82-10-2 1982 82-7-1 82-7-11 82-11-1
?
1983 83-2-3 83-2-3 83-1-2 N/A 83-5-1 83-3-1 Note 5 83-6-2 83-6-1 NOTES:
1.
Pertinent Chronological Events 1978 - Fall Mercury Mobilization 1980 - Mercury Audit for, code stamping (80-3-7) 1981 - Mercury Audit for seismic support (81-11-1) attachment 1983 - Mercury de. mobilized August 1983 t
2.
Mercury organization was reviewed by Ebasco as part of the QA Program Manual Review conducted in 1978 and 1979.
Ref. file folder F NY-15 Ebasco QA Records Vault 3.
ASME hydro testing commenced in late 1981 4.
Audits not performed due to Contract Closure 5.
Ebasco audits of services used by Mercury would be conducted as part of Ebasco audits performed relative to other Criterion (e.g. Criterion XII) 23-39 m.
A'lTACllMENT 4C (CONT'D) 18 CRITERIA - 10CFR50 APPENDIX H Ebasco Audits cf j
Mrreury X
XI XII XIII XIV XV XVI XVII XVIII l
79-11-4 79-3-3 79-8-6 79-4-5 79-12-4 79-10-4 79-10-4 79-11-2 79-9-4 79-6-2 79-2-1 79-8-2 79-3-1 79-4-2 79-4-7' 79-6-3 79-2-3 79-3-6 79-4-2 79-4-6 79-3-7 79-2-1 1979 79-3-7 79-2-2 79-3-3 78-12-2 79-2-1 79-2-3 80-3-2 80-4-8 o0-7-2 80-10-5 80-1-3 80-1-3 80-6-4 80-8-3 80-1-1 80-3-8 80-3-8 Program 80-1-2 Audit 1980 i
80-3-1 Note 3 80-5-1 80-7-3 80-7-4 81-2-1 81-3-1 81-9-4 81-9-2 81-1-1 81-1-1 81-4-2 81-5-1 1981 81-3-4 Note 3 81-12-3 i
82 7-9 82-11-3 82-12-2 82-4-2 82-4-2 82-6-5 82-6-1 82-7-4 82-5-3 1982 1
82-7-5 1983 83-5-2 83-6-1 83-2-2 Note 4 Note 4 83-6-2 83-6-2 Note 4 83-5-2 l
~
O 23-40
ATTACEMENT 5 Verification of the Acceptability of Mercury Installations Since the Stop Work Order on Mercury safety related activities in June
.1982, Mercury installed systems have been heavily scrutinized by LP&L and Ebasco. The Mercury! installations have also been subjected to NRC field review. Additionally, Kemper Insurance participated in the ASME Section III N-Stamp application process and, as such, was required to witness hydrostatic testing of all ASME Safety Class 2 installations.
In consideration of these activities and corrective action taken, LP&L now has a high degree of confidence in the adequacy of the Mercury
- installations.
- The following is a brief discussion of s' ome of the significant LP&L and Ebasco verification activities with respect to Mercury installations.
1.
A direct result of the Stop Work Order, was the initiation in July 1982_of joint Mercury and Ebasco walkdowns of instrumentatelon installations on a startup system basis. LP&L QA and Startup were involved in the initial phases of the program. Walkdown results were documented on punch lists and evaluated for nonconforming conditions and establishment of corrective action.
The walkdowns were conducted in two phases. The first phase consisted primarily of tubing along with the associated tubetrack and clamps. The second phase consisted of-a walkdown of supports which commenced in January 1983.
The walkdowns resulted in the generation of a large number of NCRs and rework. Attachments 2, 3 and 3F discuss the significance of the NCRs.
2.
In addition to LP&L QA participation in the corrective action walkdowns' discussed above, LP&L QA performed a status review at the time of system turnover in accordance with the requirements of LP&L procedure QASP 17.5.
This review consisted of a minimum 10 percent
_ review of the documentation, and a random field sampling of hardware versus as-built drawings.
Portions of the Mercury installation for j
the following startup systems were field verified:
18-3, 36-1, 36-3, 39, 43A, 43B, 43E, 43H, 43J, 46A, 46B, 46C, 46D, 46E, 46H, 52A-1, 52A-2, 52B, 52C, 53A, 55A, 56A, 58, 59, 60A, 60B, 60C, 66, 71B, 73 and 76.
L As a result of these reviews LP&L was able to conclude that the as-built conditions generally reflected the system drawings, and that no significant hardware de.ficienciec were encountered.
3.
Ebasco conducted various other field verif t:ation activities relative to Mercury installations. These are summarized as follows:
23-41 I
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a.
As part of the closure of SCD 57, Ebasco QA initiated a corrective action supplement which consisted in part of a sample field inspection of various attributes related to Mercury installations.
This inspection took place in February, 1984.
b.
Ebasco engineering conducted a plant walkdown in order to identify and correct miscellaneous hardware deficiencies which normally result from ongoing construction activities.
This walkdown was conducted in accordance with Ebasco procedure ASP-TV-141 and included all safety related areas of the plant. Deficiencies, along with QA/QC verification of corrective action on safety related items, were documented on punch lists.
The program was established in support of the area closecut and transfer process, which took place in March, 1984 through May 1984. This walkdown provided another level of assurance on the Mercury installations.
c.
Since August, 1982 the Ebasco QA Surveillance Group has conducted 48 documented surveillances of Mercury hardware e
and documentation.
Any findings were resolved and, when necessary, NCRs were initiated to evaluate potentially significant discrepancies.
The activities of the Ebasco QA Surveillance Group are discussed in greater detail in Generally, this in-process surveillance program provided another means of monitoring Mercury activities, thus ensuring the adequacy of the installations.
4 The most significant activity, aside from the corrective action walkdown discussed in item 1, involved the Ebasco QA records review of Mercury documentation. This review was necessary due to the demobilization of Mercury in August of 1983 without the completion of the Mercury records review. The review commenced in November, 1983 and was completed in March, 1984. A group of 46 QA reviewers, inspectors, supervisors and clerical staff was assembled for this
-effort. The review was conducted in accordance with QA instruction
~
QAI-23. As deficient or missing documents were identified QC inspectors were dispatched to re-verify the installations. As a result, approximately 67% of tube track installations were reinspected; approximately 35% of Seismic Category 1 supports were reinspected; and approximately 24% of.the Mercury installed anchors were reverified for proper torque. Attachment SA provides a summary of the review and reinspection scope resulting from the Ebasco QA records review. Availabla records indicate that an insignificant amount of rework resulted from the reinspection process.
5.
The adequacy of Mercury installations is being further confirmed by reinspections in progress in response to NRC issue #1.
23-42 e
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ATTACHMENT 5A Summary of the Ebasco.QA Records Review I.
The following is a summary of the work scope related to the Mercury documentation review conducted by Ebasco QA. Further, a summary of field QC verifications resulting from the review process is provided in Section II.
A.
Tubing Installations Records Review ASME Section ASME Section Review Scope III-Class 2 III-Class 3 Total Number of Systems 13 36 49 Number of Mercury Travelers (OCRs) 86 284 370 Number of Instruments 150 835 985 B.
Seismic Category 1 Support, tube track, and other miscellaneous hardware installations Review Scope Quantity Tube track supports 5142 Primary sample line pipe supports 314 Tube track installations 665 Instrument stands 184 Bulk fabricated supports / fittings /
7230 (approx.)
anchor plates Instrument mounts 267 II.~ QC reinspections were initiated in order to resolve documentation deficiencies identified in the review process. A summary of re-inspections is as follows:
A.
Tubing Installations Reinspections were initiated.to verify the following:
Attribute Q
,uantity Heat number 30 Material Identification 15 Welder's I.D.
11 Tube Slope 4
Verify repair of damaged tubing 7
Wall thickness 2
Defective weld 1
Instrument installation 3
TOTAL
.73 (Note 1) 23-43 pmm
B.
Supports / tube track and other miscellaneous Seismic Category 1 installations Reinspections were initiated to verify the following:
Attribute Quantity o
Support configuration, location 2058 and welds Tube track 514 Instrument Stands 211 Torque verification of anchor 896 bolts including proper imbedment and thread engagement Support type only 159 Final visual of support veld only 88 Pipe support configuration 77 Miscellaneous attributes (Ht. No.,
216 Welder I.D., etc.)
TOTAL 4219 (Note 1)
As a result of these-re-inspections a total of 113 NCRs, and 1035 Discrepancy Notices were dispositioned.
Note 1 - Some duplication of reinspection or unsuccessful inspection is included in these numbers.
23-44 r-e