ML20101U351
| ML20101U351 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/25/1985 |
| From: | Bernabei L, Shohet G GOVERNMENT ACCOUNTABILITY PROJECT, JOINT INTERVENORS - WATERFORD |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20101U343 | List: |
| References | |
| OL, NUDOCS 8502070273 | |
| Download: ML20101U351 (54) | |
Text
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L January 25, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board
?
In the Matter of
)
)
l LOUISIANA POWER & LIGHT COMPANY
)
Docket No. 50-382 OL
)
i-(Waterford Steam Electric Station, )
Unit 3)
)
JOINT INTERVENORS' REPLY TO APPLICANT AND NRC STAFF'S RESPONSES TO JOINT INTERVENORS' MOTION TO REOPEN On November 8, 1984, Joint Intervenors filed a motion to L
reopen for litigation of three quality assurance and management integrity contentions.
Applicant Louisiana Power & Light Company
(
("LP&L") and the Nuclear Regulatory Commission ("NRC" or "Com-mission") Staff oppose the motion.1 Joint Intervenors submit the following reply to these motions.
- 1 10n December 18, 1984, the NRC Staff issued a low-power license to LP&L for Waterford 3 even though this Atomic Safety and Licensing Appeal Board
(" Appeal Board") still had, and cur-rently has, under consideration two motions to reopen on signi-ficant safety issues.
Joint Intervenors know of no other case in which the NRC Staff has issued a license wri:le the NRC's adjudicatory bodies were seriously considering motions to reopen on issues which call into question the safety of the facility.
The MRC Staff relied heavily on SSER 9 to close out the 23 problem areas outlined in the Eisenhut Letter of June 13, 1984.
Iherefore, Joint Intervonors waited for the issuance of SSER 9, which was roccived on or about January 11, 1995, prior to respond-g ing to the Staff and Applicant's responses.
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THE'NRC STAFF'S RESPONSE PROVIDES NO INDEPENDENT ANALYSIS OF JOINT INTERVENORS' MOTION AND SHOULD BE REJECTED.
The NRC Staff's response to Joint Intervenors' motion to reopen, filed on December 21, 1984, is copied, often word for word, from the applicant's brief.
- Compare, e.g.,
the following:
APPLICANT'S RESPONSE NRC STAFF RESPONSE
.Page 7 (citation)
Page 5 Page 9 ("In May, 1984...")
Page 6 Page 10 ("The other exhibits Page 7 submitted by Joint Inter-venors..."
Page 14 (citation and text)
Page 9 Page 15 (" Joint Intervenors Page 9 have failed to carry their
' heavy burden'...")
Page 15 (" Joint Intervenors Page 10 proposed quality assurance contention encompasses twelve general allegations...")
Page 16 (quotation)
Page 10 Page 16 (" Joint Intervenors' Page 11 quality assurance allegations are either entirely without factual support, are factually Wrong...")
Page 18 ("Many of Joint Page 11 Intervenors' allegations are clearly supported by the exhibits that Joint Intervenors have cited for factual support
")
Page 22 ("In support of their Page 13 contention, Joint Intervenors recite allegations in several areas...")
Page 28 (Joint Intervenors Page 15 allege in their motion at 2 8 -.' 9... " )
j na s
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'on >~
APPLICANT'S RESPONSE NRC STAFF RESPONSE Page 29
(" (g) Other Issues.
Page 16
- The organization of Joint Intervenors' motion...")
Page 31 (" Joint Intervenors' Page 18.
third proposed contention alleges that the NRC Staff's regulatory activities...")
It is clear that the NRC Staff placed little if any indepen-dent thought into the arguments in their brief.
They have relied on the applicant even to describe the staff's own efforts at
-Waterford 3.
The Appeal Board should reject the brief in its entirety.
The NRC Staff,.sometimes criticized for its role in licensing proceedings, here sees its role as to mimick, word for word, sen-tence by sentence, and argument by argument LP&L's position.
Their
. response, therefore, provides no assistance to this Board in deter-mining whether to admit Joint Intervenors' contentions.
. Joint Intervenors further believe that the NRC Staff's copying of the applicant's brief, often word for word, demonstrates the degree to which the NRC Staff's efforts at Waterford have been predetermined and,the Staff ordered to find the problems at Waterford are not significant enough to warrant denial of a license.
The affidavits attached to the NRC Staf f's response provide additional evidence of the' Staff's total submission to the appli-cant's interest-in obtaining a license as rapidly as possible.
a
1-e Task Force Director Dennis Crutchfield admits that LP&L made false statements in an April 26, 1984 letter responding to the NRC's CAT Inspection findings but adds that such false statements are'" understandable."
Crutchfield Affidavit at 1 16.
It appears that Mr. Crutchfield and the NRC Staff knew that the response was inaccurate but considered the fact that LP&L made such false state-ments, and failed to correct them, of no consequence.
The NRC Staff's cavalier attitude toward licensee's duty to the NRC to disclose'all material facts must be seen as further evidence that their efforts at Waterford cannot be expected to assure the safe construction and operation of Waterford.
As such, Mr. Crutchfield's statement that applicant's false statements are " understandable" provide additional support for Joint Intervenors' third contention.
II.
NRC STAFF'S FACTUAL MISSTATEMENTS.
The NRC Staff makes a number of factual misstatements in their attempt to attack the Joint Intervenors.
Mr. Crutchfield in.his affidavit states that CAT Team inspections such as the one conducted at Waterford are not conducted only at plants with construction and QA problems.
Crutchfield Affidavit, t 11.
However, Mr. Denton, in a June 8, 1984 public meeting on Waterford stated just that "Well, of course, we only send--teams to plants where we think there's some indication they may not be meeting requirements."
Exhibit 49 at 45.
Mr. Crutchfield also claims that Joint Intervenors stated thct the ::RC Waterforc' 3 Teck Force wac composed of 22
, i r.rpec tors.
In fact, Joint Intervenors state 6 that Water-f :>. : 3 Tcsh Focco was composed of 2,2 inspectors L
pp a
u i: w from various NRC regions and numerous NRC and outside consul-tants..."
Joint Intervenors' Motion to Reopen at 33.
Joint Intervenors. derived this information from the introduction to
~
SSER 7, at 2-3.
Mr. Crutchfield states somewhat mysteriously that at least one of the three affiants has contacted the NRC Staff but refused to identify safety issues.
Joint Intervenors have no information
.that any of the three affiants has contacted the NRC Staff but
- refused to speak to them about safety problems at Waterford.
Finally, Mr. Crutchfield suggests that the allegers who worked with the NRC Staff were not paid for their efforts but only reimbursed for expenses or lost wages.
Crutchfield Affidavit at-t 14.
This is contrary to statements made by George Hill, one of the main witnesses working with the Task Force, with whom Joint Intervenors' counsel has spoken on numerous occasions.
Joint Intervenors continue to believe that the NRC Staff's pay-ment to witnesses and former and current Waterford employees dis-closing potential safety problems improperly compromised their independence and pressured them to sign off on the staff's review
- and resolution of the allegations.
III.
SSER 7 AND SSER 9 DO NOT PROVIDE REASONABLE ASSURANCE THAT THE QUALITY ASSURANCE AND MANAGEMENT INTEGRITY FAILURES DURING WATERFORD 3 CONSTRUCTION HAVE BEEN ADEQUATELY RESOLVED TO ENSURE THE SAFE CONSTRUCTION AND OPERATION OF THE PLANT.
The NRC Staff largely relies on the SSER 7 and SSER 9 compiled b-/ the Waterford 3 Task Force, to resolve all issues raised in Joint Intervenors' Motion to Reopen.
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. Joint Intervenors anticipated the NRC Staff's response to their Motion to Reopen and provided representative examples of the serious flaws in SSER 7, which was issued 'on October 1, 1984.
Joint Intervenors' Motion to Reopen at 51-56.
Given the NRC Staff's total reliance on this document and SSER 9, Crutchfield Aff at t 7, 9, Joint Intervenors are compelled to demonstrate how the flaws outlined in their Mction to Reopen run throughout SSER 7 and show the inadequacy of the NRC Staff's efforts to ensure that the quality assurance breakdown at Waterford has been resolved.
First, Joint Intervenors note that the NRC Staff had deter-mined at the time of Mr. Eisenhut's June 13, 1984 letter to LP&L,
. that all 350 allegations, other than those specifically included in the letter, were of no safety significance and would be included in SSER 7.
This was only 72 days after the Task Force's creation on April 2, 1984.
Moreover, they drew this conclusion fully five weeks prior to issuance of Inspection Report No.
50-382/84-34, SSER 7, at Appendix C,and three and one-half months prior to issuance of SSER 7.
Further, the NT.C Staff made this predetermination prior to much of its now-heralde6 inspection efforts during the summer and early fall of 1984 and prior to any. review or reinspection by LP&L in response to the NRC-defined Concerns.
This predetermination is not surprising in light of the Waterford 3 Task Force's directions from Executive Director for Operations William J. Dircks to ensure that all allegations of t_
m
- o
.. 3 faulty QA and construction practices at Waterford be handled in a manner to ensure the expeditious licensing of the plant.
SSER 7, at 1.
(emphasis added)
Joint Intervenors provide the following further analysis of SSER 7 which demonstrates that the representative flaws pointed in'their early brief are inherent to SSER 7 and therefore it out cannot be used to establish an adequate resolution of the serious safety concerns raised during the NRC Staff's review and similar
. concerns identified in Joint Intervenors' Motion to Reopen.
A.
SSER 7 is organized to obfuscate the 350 allegations purportedly addressed.
SSER 7 organizes the 350 allegations into 104 issue areas.
Nowhere-does the document list all the allegations individually.
Thus, the Staff's characterization of the allegations cannot be examined for accuracy.
As a result, it is impossible to deter-mine whether the staff has investigated each allegation.
For example, in A-347-A, the Staff combines four allegations into one without describing each allegation separately.
(A-347, A-072, A-076, and A-077).
SSER.7, at.278.
Instead, the Staff.
characterizes the four allegations as follows:
It is alleged that EBASCO's Nonconformance Report (NCR)
W3-6514 was incorrectly resolved and. closed, and that uncertified steel was used for instrument tubing supports.
9 3
~
Mr. Dircks directed the Task Force to " assure issues are resolved on a schedule to satisfy hearing and licensing decision noods... leading to prompt licensing decisions."
Mr. Dirckd memo-randum was written after express orders from Chairman Palladino tc' speed up the NRC Staff's efforts to resolve construction and
- 01. flaws. -See Palladino Memo, attached and incorporated herein as Eur.ibit 1.
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The characterization suggests at least two issues and both have generic implications if true.
The'first issue relates to EBASCO's NCR W3-6514, which docu-ments that.the wrong heat number was stamped on a support angle.
Apparently, EBASCO QA dispositioned the NCR without requiring heat number traceability.
The Staff excused the heat number traceability requirement and noted that only a certificate of compliance was necessary to comply with the EBASCO QC program.
However, the Staff doe's not indicate whether such a certificate was provided or whether NCR W3-6514 was properly dispositioned.
The second issue discussed in A-347 is that uncertified steel was used to fabricate instrument tubing supports.
After admitting that traceability was lost on "some hanger material" the Staff quickly dismissed the significance of this fact by noting that Ebasco. reviewed all heat numbers furnished by suppliers of the structural steel.
This resolution of the problem is, as SSER 7 notes, "outside the Mercury program."
Again, the Staff fails to state whether the structural steel used in the program received a certificate.
The Staff has no reason to accept EBASCO's representa-tion, since EBASCO has in the past been unable to maintain accurate records and is alleged to have falsified documents.
A-33, SSER 7,
'at 86.
Therefore, the NRC Staff's facile conclusion that the
-structural steel used was " properly certified" is unsupportable without fu'rther. investigation.
Id.
at 278-279.
The Staff's rationale for organizing the allegations into 104 issue areas is to reduce redundancy and to help explain the Task Force's approach for resolving similar issues.
Id.
at 3-4.
m
However, the NRC Staff often analyzes related allegations separately.
This tends to de-emphasize their safety significance and generic implications.
For example, Allegation 308 relates to inadequate piping system documentation.
The Staff addressed this allegation by examining documentation procedures and-a small sample of turnover packages for " technical adequacy and content."
Id. at 267.
The sample size is clearly too small to support the conclusion that
'the. allegation is unsubstantiated.
More importantly, this analysis of Allegation 308 does not reflect the magnitude of the breakdown in Waterford's document control procedures.
The Appeal Board, to appreciate the problem fully, must examine A-308 in light of more than a dozen other allegations, including A-35, A-183, A-184, A-197 to A-206, A-223, A-230.
The following allegations are supportive of A-308: Mercury (1) failed to maintain accurate documentation in its Operation Control Record - (OCR) packages (A-183); (2) QC packages do not accurately reflect field construction (A-223); (3) documents are incomplete and do not match the as-built plant configuration (A-230); (4) corrective action for welds was not documented (A-97, 1,
et. al.).
4For_ example, in A-223 the Staff states: "2 [ R 7 e c o r d s w e r e poorly maintained; weld. history was difficult to follow; the filing system was extremely cumbersome; retrieveability was difficult; and records were not always original copies.
JJ!. at 203.
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2-The Staff resolved all these allegations about Mercury merely Hby reviewing ten Mercury work packages.
This paperwork review
.cannot sustain the Staff's' favorable conclusion yet these allega-tions do not demonstrate a safety problem.
Further, the Staff
- states no justification for its limited review of these particular packages.
With respect to allegations made against Tompkins-Beckwith, the Staff reviewed an unspecified number of work packages of three startup systems-(A-308).
Id. at 267.
Again, the Staff does not state why these packages were the only ones analyzed.
Based on the Staff's-limited review, the Staff concludes that all Tompkins-t Beckwith documentation ~is " adequate."
Ibid.
In its review'of Mercury and Tompkins-Beckwith document control procedures, the Staff fails to consider the critical issue'of whether-the documentation accurately reflects the as-built-condition of the plant.
The Staff's failure is particularly significant in light of EBASCO's prior misrepresentation that it
/"lh
'had~ compared = turnover records with as-built systems.
Joint Intervenors' Motion to Reopen, Exhibit 6 at 9.
-Additionally, A-35 involves the failure of LP&L and EBASCO tcr verify that piping systems were installed and inspected in ac-cordance with the ASME code.
SSER 7'at 92.
The staff acknow-
. ledges that " adequate documentation may not be available."
Ibid.
Nonetheless, after reviewing no more than the document control procedures, the staff concludes that:
Implementation Lof-the procedures 7 was verified by reviewing objective indications to substantiate doc-umentation adequacy."
D n
In fact this. representation is misleading since the Staff examined only one startup system.
The Staff has no basis for its " rosy" conclusion that "EBASCO...and LP&L have implemented the program requirements."
Ibid.
In this way the Staff effectively obscured a major documen-tation control breakdown at Waterford 3.
B.
THE STAFF'S ANALYSIS IS UNDULY RESTRICTIVE AND PROVIDES NO FACTUAL BASIS FOR THE CONCLUSIONS REACHED.
The NRC Staff applied a restrictive approach to its evaluationiof the allegations and failed in many cases to address their potential safety significance.
Additionally, the Staff more often than not failed to obtain, or provide in SSER 7, a factual basis for its conclusions.
ForLexample, in allegation A-341 the Staff noted that the alleger did not give specific information about the location
'of deformed cable trays.
The Staff apparently did not contact the alleger for clarification but instead chose this particular portion of cable tray to inspect. Nor did the Staff describe the rel-ative percentage of cable tray that this sa:rple represents. As a result it is ir:possible to assess whether the safety concerns have been addressed.
Another example of the S,taff's refusal to focus on the
'" heart" of the allegations is demonstrated by its treatment of allegation A-306.
A-306 relates to Tompkin-Beckwith's failure to '
adequatelg control measuring and testing equipment.- Id. at 266.
The Staff conducted a paperwork review of the contractor's procedures and work packages for hydrostatic testing.
- However, G
9
-u the Staff did not explain why it examined these particular work packages rather than others.
Further, the Staff apparently made no attempt to clarify the allegations.by contacting the alleger-and did not conduct any inspection of the equipment in question.
Such inspection would seem wise inlight of equipmant problems in the past.
- See, e.g.,
SSER 7 at 88-91, 93.
Another example of the Staff's failure or refusal to provide aay factual support for its analys'is is demonstrated by its discussion of Allegation A-283 which states OA/QC personnel were discouraged'from initiating NCR's. Id. at 246.
Tliis allegation
'was. reviewed in conjunction with allegations A-49 and A-123.
Id.
at'101-102.
These' allegations involve charges that management pres-sured contractor personnel so as to prevent identification of con-struction deficiencies.
The NRC Staff resolved these allegations by examining EBASCO procedures.for filing NCR's and related LP&L correspondence.
The Staff then dismissed the allegations on the basis of this paperwork review and concluded'the NCR's "have been entered into the NCR system and the issues resolved."
The Staff gives no reason for its discrediting of the al-
.legers testimony or its acceptance'of EBASCO and LP&L's represen-Ltations'as'to how the NCR system.on paper.was designed to work.
- Id..at 101.
~
The Staff similarly provided no factual basis for its reso-lution of" allegation A-123 which states EBASCO DA record reviewers were not allowed "to look in the field" because they found too many. problems with Mercury and Tompkin-Beckwith's work.
The Staff Ul ~
6
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dismissed this allegation by finding no requirement that record reviewers be permitted to go into the field.
Id,. at 102.
It ignored the real significance of the charge that docu-l ment reviewers were being obstructed in performing their job be-cause management did not want them to identify nonconforming con-ditions or_ documentation problems.
It is clear that SSER 7 was intended to disguise the signi-ficance~of the OA and " character" breakdown at Waterford 3 rather than provide an honest and searching review of the over 350 alle-gations.
As.such it cannot support a conclusion that the QA break-down at Waterford has been resolved so that the quality of the
' plant's construction can now be assured.
C.
SSER 9 WHICH ADDRESSES 23 PROBLEM AREAS PROVIDES NO ASSURANCE THAT. SAFETY PROBLEMS AT WATERFORD DO NOT PERSIST.
SSER~9, which-Joint Intervenors1 received on or about January ll,- 1985' was intended to address LP&L's resolution of thel 23 areas ~of safety significance listed in the Eisenhut
.: letter'of June 13, 1984.
O
e SSER 9's resolution of these problems, of acknowledged safety significance, is more seriously deficient than the S ta f fs ' efforts in SSER 7.
In large part the NRC Staff accepts minimal efforts by LP&L to justify past failures to meet basic
.uality assurance criteria, including qualification of OA/QC q
personnel; adequate qualification of welders; use of controlled welding procedures; proper documentation and resolution of non-conforming conditions; and proper control and traceability of materials.
In doing so, the NRC Staff has allowed LP&L to resolve the QA breakdown in a manner which falls far short of the standards required at the' Midland and Zimmer plants to ensure the quality of construction.
Moreover, the NRC Staff has for the first time at any nuclear' plant,. required nothing more of the licensee than it
' provide the NRC with " approaches" to problems and has permitted
~
a case-by-case negotiated. solution to each problem area.
At every other problem plant including Zimmer, Midland, Diablo Canyon, and Byron, the NRC Staff or the Commission itself has required anLapproved program plan-which outlined specifically how the utility will resolve OA and' construction deficiencies, i.e., whether by review of documents; reinspection;.nondestruc-
.tive or.other testing; or engineering analysis.
In the case of N
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- 15 Waterford 3, apparently because of the direction from Mr. Dircks, the NRC Staff has been satisfied with merely an " approach," which is revised at the utility's will.
In fact LP&L's " approach" to
-resolution of the most important problem area in the Eisenhut letter of June 13, 1984--unqualified QA/QC personnel--has been revised several times.
Further, the proposed resolution of the 23 problems of safety significance is clearly inadequate.
Joint Intervenors provide the following as examples of the basic prob-lems of SSER 9.
ISSUE 1 The NRC Staff originally required LP&L to verify the quali-fication.of 100 percent of site QA/QC personnel and to reinspect the work of all inspectors found to be unqualified.
LP&L's ef-forts, as described in Appendix J, at 7-18, fall far short of that directive.
LP&L goes to extreme lengths to find inspectors qualified.
And, at this time the status of qualification of QA personnel is
-unknown.
SSER 9 at 18.
More-importantly, it is unclear what percentage of the work of unqualified QC personnel has been' rein-spected.
The NRC Staff has permitted the utility to justify the
. quality of Waterford 3's construction not through requiring rein-spection but through a sample review of documentation and tor-tured reasoning as to how the work. inspected by QC inspectors.not
. meeting ANSI N4 5. 2. 6. -1973 requirements may be verified as safe.
For example, three unqualified LP&L QC inspectors were deemed to'be~ qualified to perform what were described as quality
-surveillances even though they were not qualified to do inspec-
~
tions.
Id. at 9.
Joint Intervenors know of no separate quali-fications required for QC personnel conducting surveillances rather than inspections.
It is stated that 61-Ebasco QC inspectors did not meet requirements.
Ibid.
The Staff fails to indicate what percentage of the total population of Ebasco QC inspectors this comprises.
The Staff then states that six unqualified QC inspectors were
-Level <III's but did not perform inspections.
Since it is likely that they were in supervisory or administrative roles, their lack of qualification or training.may have greater consequences than if they had-been merely inspectors.
As such their lack of qualifica-tion cannot be ignored, as the Staff does.
With respect to four unqualified individuals who worked in the concrete test station, their work was justified on the basis-it was " simplistic technician-type _ work."
Id. at 10.
In some instances,-the NRC Staff required no reinspection uof the work of unqualified inspe: tors but merely looked at the inspection paperwork to sign off cn1 the inspections.
The paper-work.for.one unqualified individual's nondestructive examination tests on 15 welds was examined by LP&L and documented and then-the NRC Staff merely reviewed LP&L's report.
Id. at 9.
The work of ten other unqualified ~ inspectors was determined sound based on the undefined and unexplained " limited type of inspection performed and documented'OJT and formal training." Ibid.
,(: '
Although it was determined that 27 Fishbach and Moore QC Linspectors were qualified, the NRC required no reinspection of their-wo'rk.
Their work was justified as complementary to the O
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, a inspections by qualified personnel and by later LP&L startup walk-downs and testing.
Id. at 12.
Ten' Gulf Engineering QC inspectors were found unqualified.
In the case of five inspectors LP&L and the NRC Staff largely relied on testing to ensure the adequacy of their work.
Id. at 13.
Fully 136 Mercury Company of Norwood (" Mercury") OC inspec-s tors were found unqualified.
The NRC Staff acknowledged that these
' unqualified personnel conducted inspections of N2 intrumentation.
Yet it found that 100 percent reinspection of N2 insturmentation was not.necessary.on the basis that "the same program controls were utilized to install the N1 systems" and the N1 systems reinspec-tion program found no significant problems.
Ibid.
As is the case with Gulf Engineering, LP&L and the NRC Staff rely largely on
.preoperational testing to ensure the quality of N2 instrumentation.
Finally, the work of unqualified Mercury QC inspectors was justified on the basis that Mercury and Ebasco did a 100 percent review of the documentation for the inspections.
But the documen-tation of Mercury work is notoriously deficient.
Therefore, it-is clear that a serious review of the documentation of these in-spections would-lead to greater doubts about the quality of the work.5 LP&L stated that five Nisco QC inspectors were not qualified.
.They attempt'to verify the quality of these inspectors' work in The NRC Staff, as in most sections of SSER 9, failed to indicate what percentage of N2 installation has been reinspected or what percentage of Mercury QC inspectors were found unqualified.
part by nondestructive examination by an independent subcontractor.
Since neither the subcontractor nor the time during which this examination was conducted is identified, one cannot determine whether it was in. fact completed by qualified individuals.
Id. at 14-15.
LP&L found 20 Sline QC inspectors did not meet requirements but again was permitted to justify the quality of work they inspec-ted by the evaluation that these inspections were"relatively simple" or had been previously reviewed by manufacturer representatives or through Ebasco surveillances.
As stated above, LP&L and the Staff' have failed to demonstrate that the personnel who conducted those other inspections and surveillances were qualified.
Id. at 15-16.
Thirty-eight Tompkins-Beckwith QC inspectors were found to be unqualified.
LP&L was permitted to justify their work in the piping area by a minimal and undefined (in percentage terms) of reinspection (2600 socket welds) and testing.
In the area of reis-mic supports and restraints, Ebasco conducted only undefined " field verification" activities and an undefined and apparently small relative amount of-reinspection (4500 safety-related pipe sup-ports and 200 highly-stressed hangers).
LP&L's QA reinspection of 2500 hangers.does not appear to be QC reinspection such as have been required at such plants as Zimmer and Midland.
Id. at 16-17.
In the case of nine unqualified Waldinger QC welding inspectors, LP&L did only a sample reinspection of their welds.
No' 100 percent reinspection ~of these safety-related welds was proposed or required.
Id. at 17.
r 4
- 19 The NRC Staff has apparently approved LP&L's response even though the qualifications of QA personnel at the time of issuance of SSER 9 have not been reviewed or resolved.
The Staff suggests March 1, 1985 as a target date for completion of this task.
In-explicably the Staff states that unqualified QA personnel should have no impact on the quality of Waterford's construction and is a problem which does not need to be resolved prior to full power operation of the facility.
Id. at 18.
ISSUE 6 The NRC Staff found serious problems with control and proper
'dispositioning of nonconformance reports - (NCR's).
It required that LP&L do a 100 percent review of NCR's and DR's to ensure they were-appropriately upgraded, dispositioned and all necessary cor-rective actions were taken.
Id. at 29-30.
LP&L's resolution, which :the Staff has accepted, is a review of only 28 percent of the NCR's and an undefined percentage of the DR's.
LP&L and Ebasco, even with this limited review, have found some NCR's which were not properly dispositioned.
Therefore it is certain similar problem NCR's would be found in the remaining 72 percent of the "potentially deficient NCR's".
Yet the NRC' Staff stated that cor-recting the improper dispositioning of this 28 percent sample, in-
- cluding in some cases, reinspection, engineering evaluation and re-rwork, is sufficient to ensure no problems will remain uncorrected
.due to impyoper dispositioning of the other 72 percent of NCR's.
Id. at: 31. : Joint Intervenors found no credible support for this
" Alice in Wonderland" reasoning.
Further,-LP&L's review of Ebasco NCR's closed after February,
1.
- 20
- o
-1984, at a time when the NRC had already warned LP&L of serious QA failings, still found improper dispositioning and documenta-tion problems.
Id. at 31.
It is. hard to believe that under these circumstances any-thing less than a 100 percent review of the NCR's will ensure all needed. corrective action has been taken.
The NRC Staff in its most recent review of LP&L's NCR system has concluded the NCR system has " programmatic problems" and " doc-umentation problems".-
Yet without explanation "they again con-clude that hardware in the plant was not affected."
Id. at 32.
Joint Intervenors believe that the fact that LP&L, to this day,~is unable to develop and implement an NCR system to identify and. disposition properly nonconforming conditions, is support for Joint.Intervenors' contention that LP&L lacks the character and com-petence_to_ operate Waterford safely..Further, it supports Joint Intervenors' argument that'the NRC Staff,is unable to identify the cause of the QA and character breakdown.at Waterford, much less enforce effective corrective action.
LP&L's review of a random sample of DR's -found similar de-ficiencies,-including ones needing engineering reevaluation.
Yet
'neither.LP&L nor the NRC Staff found any need to conduct a 100 per-E (cent" review of DR's as originally required.
Id. at 34.
The NRC Staff permitted.LP&L to resolve Issue 6 through an LPEL audit of-MercuryL and Tompkins-Beckwith DR's.
' Ibid.
Yet LP&L andthe:NRC Staff have already uncovered sufficient documentation
. deficiencies.to: demonstrate the uselessness of any such paperwork L
k audit.
ISSUE 22 The NRC Staff required LP&L to demonstrate the qualification of Mercury welders and justify using "rebake" temperatures which fail-ed to meet the requirements of ASME and AWS Codes.
With respect to the rebake temperatures it was acknowledged
'that rebaking of low hydrogen electrodes as done at Waterford did not meet AWS/ASME Code requirements.
Yet largely on the basis-of the electrode manufacturer's word that the procedure used at Water-ford 3:was adequate, the NRC Staff granted LP&L a waiver from Code requirements.
Id. at 83.
Neither LP&L nor the NRC Staff has provided any justifica-tion for permitting LP&L to,.on an ad hoc basis, modify the welding code requirements in this manner.
IV.
JOINT INTERVENORS' RESPONSE TO APPLICANT'S ARGUMENT THAT QUALITY ASSURANCE CONTENTION LACKS FACTUAL BASIS.
Licensee argues that Joint Intervenors' quality assurance contention is 1) not supported by the affidavits and" exhibits at-tached to Joint Intervenors' Motion to Reopen; and 2) the facts alleged.and supported through affidavits and documents evidence sufficient-to demonstrate unresolved problems of safety are not
? significance.at Waterford 3.
Joint Intervenors will not address the second argument since Ihis Appeal' Board should at th'is point be making a threshhold determination of whether Joint Intervenors have presented suffi-cient'information_to warrant admission of three new contentions, not whether Joint Intervenors have proven their case.
Therefore,
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22 this reply does not address the specific allegations brought out in applicant's affidavits.
However, intervenors will address the argument that specific documents do not support the allegations made in Joint Intervenors' Motion.
First, applicant contends that Exhibit 1 does not support the statement that LP&L failed, even after notification, to en-sure, administrative procedures were instituted to cover the inter-face between on-site and off-site' personnel.
Exhibit 1, a MAC Audit, recommends that the LP&L Project Manager should establish an office at the site and more generally that LP&L should gain greater familiarity with and control over Ebasco and other contrac-tors.
Exhibit 1 at 3-6.
Applicant states _that Exhibit 4 does not support the allega-tion that construction'had effective control over day-to-day opera-tions of the QA department and the major policy decisions.
- However, it is cleas from the QA Manual, a draft of which constitutes Exhibit 4, that the Power Production Manager controlled the overall policy of the QA Department and had direct supervisory control over the QA Manager.
Moreover, the Quality Assurance Committee which was charged with resolving disputes between the Project Manager and the QA Mana-ger, reported directly to the Manager of Power Production.
As such, the Power Production Manager, whose major concerns were construc-tion, cost, and scheduling, controlled both the policy and implemen-tation of the QA program in most important respects.
This is in direct violation of 10 CFR Part 50, Appendix B, requirements that the QA program'be independent of; construction and that the organization 4
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" report to a management level such that this required authority and organizational freedom fee 7 provided."
Criterion, Organiza-tion.
See portions of Exhibit 4, attached and incorporated herein as Exhibit 2.
~ Applicant states that Exhibits 1, 8 and 22 do not support the allegation that LP&L failed to provide QC coverage for work done-on the night shift.
Clearly Exhibit 8,at 6, states precisely that.
Exhibit 22, which is a partial response to the audit findings of Exhibit 1, states, at 1, "I'm not sure of the necessity of shift coverage of proper installation," which according to one of Joint Intervenors'affiants involved OC coverage on the night shift.
There,
fore, both Exhibits 8 and 22 demonstrate LP&L's failure to provide QC coverage on the night shift, even though it is apparent from Ex-hibit 22 that some LP&L personnel were recommending QC coverage for all cable installation. Exhibit 22 at 1.
' Applicant states that Exhibits 25 and 26 do not support Joint Intervenors' statement that LP&L lacked a records index as commit-ted to in LP&L's PSAR and as required by ANSI N.45.2.9.
In fact both documents address errors in manufacturers'; drawings which should have been identified and sent to site engineering for review and cor-rection but were not detected except by Information and Records Man-agement System; personnel.
Both memoranda demonstrate that LP&L did not maintain _ adequate control over EMDRAC controlled drawings and that errors on the drawings were not found and corrected.
This 11s a problem' which would be cured or avoided altog ether by a records index such as the one to which LP&L had committed and was required.
a.
9 Finally, LP&L states that Exhibit 29 does not support Joint Intervenors' allegation that LP&L did not maintain adequate oversight of procurement activities.
Joint Intervenors agree that in this instance Exhibit 29 does not support that proposition and was misidentified.
Joint Intervenors attach as Exhibits 3, 4 and 5, respectively, three memoranda which support that proposition.
Ex-hibit 3 is a November 9, 1979 Memorandum to the NRC from the Manager of Power Production; Exhibit 4 is a memorandum on ASME Survey Prob-lems and-Shortcomings,which includes problems with oversight of procurement activities; Exhibit 5 is a memorandum which includes open audit items which has taken a long time to close out due to poor cooperation or unsatisfactory responses by Ebasco or other con-Included is an item described as " Control of Receiving,
-tractors.
Handling and Storage.
The review of documentation packages for non-safety items."
Id.at 4.
V.
CONCLUSION In consideration of the above, Joint.Intervenors request
(
that this Appeal Board grant their motion for admission of three new contentions.
Respectfully submitted, t
-s be',2< ~_o(
(jgeg Lyn'ne Bernabei h
/mc<L.
J, a
Geofge Shodet Government Accountability Project 1555 Connecticut Avenue, N.W.
Washington, D.C.
20036 (202) 232-8550 DATEL:
January 2",
1985 Attorneys for Joint Intervenors L1
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. UNITEDSTATEs EXIIIBIT 1 NUCLEAR REGULATORY COMMISSION
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April 23,1984
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.,. o 9 MEMORANDUM FOR:
Commissioner Gilinsky
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Commissioner Roberts Commissioner Asselstine Commissioner Bernthal-c FROM,i Nunzio.J.. Pall adino
SUBJECT:
APRIL'24, 1984 MEETING ON STEPS T0 AVOID i
i LICENSING DELAYS l
Attached is a copy of a paper on the purpose of and agenda for the April 24, 1984 Commission meeting on potential licensing delays..
On Mat ch 9 P1984.. the EDO: notified 'the Commission. of-significant potential licensing delays.
Specifically, the i
ED0 indicated potential delaff.of *14 addths, weherens:our-January report to Congress forecast a total deGay..of only 7 months.
Subsequently, based on information provided by the staff, it became clear to me that additional delays were also possible, and I informed you of the general cir.cumstances in my memorandum of March 20, 1984.
The April 24 meeting should provide an opportamity for Commissioners:to keep current. about.the status:of thpse plants approaching a licensing decision by the agency so as to avoid ~a surprise tuch as deyeloped several years ago, I understand, about forecast licensing delays The April 24 meeting can also address the extent to *hich ttie
~
Commission's Policy'and Planning Guidance objective on this matter is being carM ed out.
The PPG includes the statement that " actions should continue to be. taken to
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eliminate unwarranted delay in reaching decistens consistent with not compromising safety."
Furthermore,,an early meeting on this subject helps to preserve the widest range of options for addressing potentia 1 delays.
Tiie purpose of the meeting includes hearing from-the EDO and 0I on actions they control which affect ifcensing' schedules, or which could be affected by resource.needs.
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With regard to board panel Chairmen (i.e., Tony Cotter and Alan Rosenthal), discussions might center on general workload plans and problems anticipated due to the timing of EDO or 01 staff inputs.'
Howevers the subject of
oxpediting -. proceedings _invo.1ving. par _ticular plants will be' discussed with the Commissioners by, our~immEdiate advTsTrs.
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OGC and OPE, under appropriate procedural safeguards...
Finally, the April 24 meeting will give the Commission the opportunity to address the issue of.how to deal with t
last-minute allegations in our licensing decisions.,
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7 APRIL 24MEETINGONSTEPSTOAV0kDLICENSINGDELAYS f
Purpose
-1.
To inform the Commission of the status of plants in'
, the licensing.proi:ess with particular attention to matters which could impac~t the ability of NRC to complete its. actions before some plaats.are ready for operation.
l 2.
To inform the Commission of steps befag taken or planned (by the EDO staff 01 staff, and the Boards)
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to address possible delays in particular cases.
3.
To consider with OPE and 06C possible Commission l
actions to address delays in speciffe proceedings (this could include having 06; prepara options for later considerption by the Commission, or the Commission could consider proposals,made _ prior to the meeting or ad. hoc at the meeting).
4.
To consider a Commission policy of handling last-minute allegations and, in particular, a policy for deciding which allegations sha11 be addressed / resolved before licensing action (M.,
thresholds).
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l Meetino Agenda
~0verview of sYatu's-6f El near-term ~ operating-11 cense 1.
l plants, and-discussion of status of s'pecific plants delayed or possibly delayed by NRC actions -- EDO (open) t 2.
Discussion by Board Panel Chairmen of general policies to avoid' delay and general problems anticipated due to the timing of'ED0 and 01 staff inputs -'
Cotter /Rosenthal-(open)-
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NRC staff actions to address delay assediated with NRd' staff proces:.-- ED0 (open) 4 Discuss policy on allegations -- OGC/0PE (open) 5.
OI ' actions to address delay associated with pending 10 investigations -- 01. (closed under Ex. 5.and.7) 6.
. Identify possible Commission actions,te address
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procedural delay in pending litigated cases -- OGC and l
OPE (closed under Ex. 10)
(ED0 and 01 not present)
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Possible Outcomes:
IT~~ Ciiiiiiiilssion guidaricTe76 EDD s'taff or11 staff.
2.
Commission request to OGC to prepare options or draft orders in particular. cases.
3.'
Commission guidance on allegations policy.
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EXHIBIT 2
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g FORW D
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Ih0ISIANA POWER & LIGHT COMPANY POLICY STATEMENT
-[#g " FY'EOPc K A T/oNA L O
QUALITY ASSURANCE PROG 3AM
@*FufM It is the policy of Louisiana Power & Light Company (LP&L) that the LP&LA Quality Assurance Progracf[of%e design, procurement, fabrication, construc-tion and testing of LP&L's nuclear generating station () shall comply with the requirements of Appendix B to 10CFR50 and shall follow the guidance o'f WASH 1283 (dated 5/24/74) and WASH 1309 (dated 5/10/74).
Thel &i,[Q Assurance Manuah D hbasis of the ua i A u nce Program. The Quality 1:;.:....: Manual outlines the responsibilities of LP&L
.[j#dE*M,d g sibggLg' maj r e
actor The position of Manager of Power Production is the highest level of corporate management responsible for establishing Quality Assurance policies, goals and objectives.
The Nuclear Project Manager ha,11be responsible for Nelear froject functions other than Quality Assurance 4 uTetions, and for developing and implementing safety-related programs, Quality Procedures and Quality Instructions which shall be used by the Nuclear Project Group.
The Quality Assurance Manager shall have the ap[tdeveloping, coordinating and im rity a d esponsibility for Quality Assurance Engineers shall assist the Quality. Assurance Manager by aiding other LP&L groups in their development of safety-related programs and yualityproc ya d),y pr,e
,tfngQg"ljty suragee training and indoctrination es,
-Yn vTduWls and organizations respon-programs, an sible for implementing requirements of the Program in order to verify compliance with requirements of the M 4ty ^r r ::: Program.
N1beresponsibleforresolvingdisputes, The Qualit i tee l
for review nee Program policies and activities and for followi'g-up c -- W 8 commended actions to assure compliance. The Quality n
Assurance Committee shall deliberate on Quality Assurance problems, shall be cognizant of the Quality Assurance programs and changes thereto, and shall make recommendations, act as an advisor to, and report through its chairman to, the Manager of Power Production. The Quality Assurance Committee may communicate directly with the Manager of Power Production.
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2 Implementation of this corporate Policy is ingerative in order to achieve the safety and reliability which is required at our nuclear generating station /(s).
Individuals and organizations involved in safety-related activities shall be respon'sible for assuring the quality of their work and for complying with the requirements of the Program.
Therequirementsconpaned.ingualitypolicies,QualityProceduresandQuality ssiu ance Manual are mandatory and must be imple-Instructionsandefe,,
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mented, enforced, and adhered to by LP&L individuals and organizations engaged in safety-related activities.
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@ k a 71 J LP&IgQualitf Msurance Program I A0W 4 Approved By:
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D. L. Aswell Date Manager of Power Production
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QR 1.0 I
ORGANIZATION 1
P 1.1 General.
Criterion I of Appendix B to 10CFR50 requires that the management of LP&L establish measures which assure that the individuals or groups assigned the responsibility for checking, auditing,. inspecting, or otherwise veri-fying that an activity has been correctily performed are independent of the individuals or groups directly responsible for performing the specific activity. In accordance with the requirements of criterion I, "this Quality Requirement (QR) establishes the organizational structure (e@-
and delineates the authority and responsibilit'ts of individuals and organizations performing quality assurance function's and activities.
Gw9MM 1.2 LP&lAQuality Assurance Organization.
Assurance Nganization c' hart fee-4he
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Figure 1-1, the re rtreeth; ph::: f th: :::1.::: preject(?), illustrates 'the line of authority and areas of responsibility for the major organizations which are involved ingquality ahd/or safety-related activities. The organizations listed below have quality assurance responsibilities. !;r-f4 oIgani-L W
sational responsibilities for implementation of t Quality Assurance Program are described in the corresponding sections.
1.2.1 LP&L Management 1.2.2 LP&L Nuclear Project Group 1.2.3 LP&L Quality Assurance Group
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QR 1.0 t
ORGANIZATION 2
- 1. 2'. 4 LP&L Quality Assurance Geesp-1.2.5 Major contractors 1.2.1 LP&L Management Louisiana Power & Light Company is e telly responsible for Quality Assurance (QA) for the LP&L nuclear generating station (s). The Power Production Department of LP&L, directed by.the Manager of Power Production" has overall responsibility for LP&L)bduelear projec q. The Manager of Power Production reports directly to the President of LP&L.
The Manager of Power Production is the highest level of corporate mana-gement responsible for establishing Quality Assurance policies, goals and objectives. As part of his continuing involvemen n
< n s ~ f Power Production shall request that a n
the Manager o Assurance program 4 management audit of the '"" tility ?zer--- hogram be conducted at least twice a year by auditors from LP&L's Internal Auditing Group.
The Manager of Power Production shall also approve correspondence to the major contractors, shall approve the General Office Quality Assurance audit reports, shall receive Site' Quality Assurance Audit Reports, and shall approve the Environmental Report, Safety Analysis Reports, and the ce Manual M M.
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QR 1.0
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ORGANIZATION 3
ifb 1.2.2g Nuclear Project Group The Nuclear Project Manager reports to the Manager of Power Production.
He and his staff have authority and responsibility for nuclear project functions. The Nuclear functions other than Quality Assurance 4 Project Manager coordinates the activities of Nuclear Project Group W
personneltoaccomplishthefollowingutiytim Reviewing (tnd concurring with the PSAR, the Environmental a.
Report, and ensing documents for th ect(s),
Verifying the review or approval of safety-related specifi-b.
cations and revisions, and drawings and revisions prepared by I
the Architect Engineer (A-E) and the Nuclear Steam Supply System (NSSS) Vendor.
Reviewing A-E recommendations for purchase and recommending c.
selection of vendor (s) to LP&L management.
Developing Quality Procedures and Quality Instructions to d.
be used by the Nuclear Project Group in the performance of safety-related activities.
Developing, implementing, and maintaining a document control e.
and records manageeent program for the project (s).
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QR 1.0 ORGANIZATION 4
1.2.3 ality Assurance Group The LP&L Quality Assurance Group is composed of the LP&L Quality Assurance Manager and his staff (those individuals who are organi-zationally under his control). His staff includes General Office
/
Quality Assurance Engineers, the Project Quality Assurance Engineer, Site Quality Assurance Engineers / Technicians and, as needed, specialists and consultants.
n as unw Figure 1-1 depicts the LP&L project er;; _M-ti~t and shows the 4
independent relationship of the Quality Assurance Group to the Nuclear Project Group.
~
I Both the Quality Assurance Manager and his staff of Quality Assurance
/.bM a w Engineers 4are independent of undue influences. and, responsibilities..
for production schedules or costs. They do not have direct respons'ibi-Idl$$o lity for performing the work which they verify to be in conformance3*e established quality nts. Therefore, they are sufficiently independent to enable them to assure that the LP&L organizations performing quality ctivitiesconformtodtApIogramrequirements.-
The Quality Assurance Manager reports to, and receives technical direc-tion and administrative control from the Manager of Power Production.
Regat.
QR 1.0 (1
ORGANIZATION 5
The Quality Assurance Manager and his staff have sufficient authority and organizational freedom to:
a.
Identify quality b.
Initiate, to reconunend, or to provide solutions through designated channels.
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Verify implementation of solutions.
The Quality Assurange Manager and his staff have the authority and responsibility for developing, coordinating and implementing the LP6 urance Program.
'I The qualifications for the Quality Assurance Manager are listed in QR 2.0, Section 2.8.
His principal ' responsibilities are:
AL9fL W I
Establishing and approvinggQuality Assurance ?rogram,Micy, a.
which is directed toward implementing applicable regulatory x,
J.c 4c requirements and in particular the Quality Assurance Criteria of Appendix B to 10CFR50.
b.
Reviewing, approving and maintaining management control of the LP&
rance Program and changes thereto,
~
and implementing the QA functions of audits and corrective action.
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QR 1.0 v
7 ORGANIZATION
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6 c.
Assuring effective implementation of the LP Quality Ass rance Program throughout the design, fabrication, construction, and testingphasesofLP&L,nucleafproject$)
d.
Integrating the QA programs and activities of LP&L's major tab W uc, contractors to assure that Quality Assurance program objectives g
are obtained.
Integration shall b'e achieved through:
(1) Review and concurrence with the m'jor contractors' QA a
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programs and any subsequent changes thereto.
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(2) L&esen with the Quality Assurance Manager of each major
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contractor.
(3) MaintenanceofclearandeffectivelinesofcommNicati.on between the LP&L Quality Assurance Manager and the Project Quality Assurance Manager of each major contractor.
(4) Level III audits by LP&L to evaluate-each major contractor's i-performance.
l-The Qu.tlity Assurance Manager, the Project Quality Assurance Engineer, and
~ the Quality. Assurance Engineersg/Sk * ' =>
have authority, delineated in writing, to
' istop. unsatisfactory work or, control further processing,' delivery, or installa-
-tion of nonconforming material. They have the authority to direct work stop-page when work is not being performed in accordance with approved drawings,
. specifications, procedures, or regulatory requirements and/or when' conditions yp,, wat.mh cou1d he signmcane, a-e to,..my 1, th..orh.er. t. con a # 3a., pan 3,,,,
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QR 1.0
~b ORGANIZATION 7
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1.2.3.1 -General Office Quality Assurance The principal-responsibilities of the General Office Quality Assuranc Engineers are:
Developing;and maintaining LP&L's4 uality Assurance Program Q
a.
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documents.
b.
Assisting other LP&L groups in the development of Quality Procedures and Quality Instructions.
Conducting audits of the major contracturs and other vendors as c.
deemed necessary by-the Quality Assurance Manager in order to verify compliance with applicable requirements -and guidance.
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-d. - Developing and maintaining the Quality Assurance Training and s t.
L t.
Indoctrination Program.
e.
Raudew
'and NSSS Vendor procurement documents selected-by L a-the quality Assurance Manager to insure inclusion. of Quality sc.
Assurance requirements.
f.
Auditing those groups within LP&L who perform safety-related activities for the nuclear project (s).
g.
Maintaining documentation of QA activities.
1.2.3.2 Site Ouality-Assurance The LP&L Project' Quality Assurance Engineer shall report to the Quality
. Assurance Manager, and shall be located at the' site during the construc -
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QR 1.0 ORGANIZATION
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8 tion phase of a nuclear project (See Figure 1-2).
The Project Quality Assurance Engineer shall direct and shall coordiaate the LP& contractor s s-sc Quality Assurance efforts at the site.
In th*.s capacity, he interfaces directlywiththevarious'Qhality'AssuranceandhalityNntrolorgani-zations at the site.
He shall be assisted by Site Quality Assurance Engineers / Technicians.
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The project Quality Assurance Egn3eer and the Site Quality Assurance Engineers / Technicians shall be responsible for:
and e pry dur a.
Dev i g cons tiong e Q 11 sura i
t, gio for mo oring Q lit 9' Con ol ap qual t ur nee activi ies.
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Establishing and implementing an auditgprogram of site construc-tion activities to verify compliance with' applicable require-l ments.
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Identifying qualityyroblems affecting site construction.
l d.
Initiating, recommending or providing solutions, and verifying implementation of solutions, to site quality 4N s.
Performing follow-up aci. ion on audit results, including re-audit e.
u of deficient areas.
f.
Auditing the action taken concerning nonconforming material.
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QR 1.0 i:
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ORGANIZATION 9
1.2.3.3 Specialists and Consultants Engineering specialists and consultants shall be used as necessary by the Quality Assurance Manager to supplement the technical competence of his staff.
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1.2.4 -g Quality Assurance Committee The Quality Assurance Committee (QAC), shown on Figure 1-1 is chaired i.
by the LP&L Quality Assurance Manager and i.s composed of the LP&L Nuclear' Project Manager, engineers from the LP&L Power Production b
Department andfEngineering Departrent, and a Quali?.y Assurance Engineer
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cfrom Fuddle South Services. The QAC has engineering specialists within
-LP&L~~and nuclear specialists from Middle Scuth Services, a consultant, available~forconsuitation.
-The Quality Assurance Committee shall be responsible for:
a.
Resolving disputes arising from differences of opinion between QA/QC personnel and other organizations.
~
4s ReviewingthhQu kEyAs'suianceProgram,policiesandactivities.
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b.
A
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Following-up committee recommended action to assure compliance.
m.-9:: J g(4,ifyAssurance$rogram,policiesandact-
- Semi-annual reviews of th Qual ivities shall be scheduled in addition to reviews requested by the Quality Assurance Committee chairman or a member as circumstances A
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-Regat.
QR. 1.0 ORCANIZATION
-i.
10 dictate. The' Quality Assurance Committee may communigate directly with the Manager of Power Production as indicated in Figure 1-1.
The responsibilities of the Quality Assurance Committee shall end when the nuclear steam electric station begins commercial operation.
~
1.2.5 Major Contractors The major contractors involved in implementing the Qu ance Program are:
a.
The Architect-Engineer (A-E).
b.
The Nuclear Stea:n Supply Syr*em (NSSS) Vendor.
"The Construction Manager and/or constructor.-
c.
/ The NSSS Vendor's scope of responsiblity shall include the design,.
procurement, fabrication and construction (if applicable) of the NSSS and 3
....., n a q
the initial fuel supply. TheLevelIandLevelIIqualityjactivities associated with this scope of work shall be delegated to the NSSS Vendor.
'1'W The NSSS Vendor shall supply sufficient interface information to the w ^ A n, d k)
A-E so that the A-E can, effectively hteg;;te the Balance of Plant (BJP) f (and NSSS.
rfditie,. 6 Iong.
t' ; the =^P --' "SSS, the A-E shall be responsible 3-L l
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Regat.
QR 1.0 1
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ORGANIZATION 11 fordesigningtheBOPstrLutures, systems,andcomponents.sedforpro-a n-
., a ne.
j curing dquipment for dGlivery to the site 3 Level II quality [:f'd.!
hk W M![W g u l li.a.j associated with this scope Q work shall be delegated to the A-E.
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1The scope of responsibility for the Construction Manager and/or Constructor shall include the receipt, storage, handling, construction and erection of the total plant exclusive of the construction, if applicable, within the NSSS m.. _ : =
Vendor's scope of responsibility. LevelIandLevelIiquality[ activities associated with this scope of work shall be provided by the' Construction Manager and/or Constructor.
A The major contractors shall be named and the interfaces among them and the LP&L nuclear project organization shtl1 be further described in
- Chapter 17.1 of the SAR's for the LP&L nuclear project (s).
% es -_ -Am Y $1L / (.0 Auf 2,y "% $:^ d' V
k 1 indic;t:d in Sci:. L 2.? ef *'i: ^",3the LP&L Quality Assurance Group shall audit.the-QA psessem activities of the major contractors to determine whether or not individuals and organizational units performing QA functions within the major contractors' organizations have sufficient authority and
-organizational freedom to effectively implement QA programs withfn their Organizations.
~By contractural agreement.LP&L shall require that the major contractors eval-uste, approve and audit their suppliers and subcontractors to assure that
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Req 1t.
QR 1.0
('
ORGANIZATION 12 their' suppliers and subcontractors have implemented QA programs which meet applicable requirements of Appendix B to 10CFR50.
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EXHIBIT 3 e,
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p 0UISIANA ur ottaaoNor sarer P O W E R. & L i G H T P Q. BOX 6008 + NEW ORLEANS. LOUISIANA 70174 * (504) 366-2345
$ 0Y O 8sYel November 9, 1976 LPL 6066
- Q-3-A35.02.0 Mr. W. C. Siedle, Chief Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Office 'of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
SUBJECT:
Waterford SES Unit No. 3 Docket No. 50-382 Construction Permit No. CPPR-103 IE Inspection Report No. 50-382/76-08
Dear Mr. Siedle:
LP&L's response to the iters of noncompliance in the subject report is given below:
Item I.A.2.a - Lack of Inspection Records for NSSS Ecufement I
Hawl!.teo end sterage inspections of the reactor pressure vessel and steam generator No. 2 were not performed in accordance with the provisions of Ebasco Procedure QCIP-16 in that records documenting these inspections were not pre-pared by QC personnel.
- 1) Corrective steps which have been taken and results achieved:
i All required documents have been completed and are in the o
appropriate files.
This information was retrieved from the QC Inspector's notes that were recorded during this period.
- 2) Corrective steps that were taken to avoid further non-l compliance: Additional qualified QC Material Control per-sonnel have been assigned to assure full compliance with inspection requirements. QC Material Control personnel have been instructed or reinstructed as to the requirements of Ebasco Procedure QCIP-16,
- 3) 'Ihe date when full compliance will be achieved:
Full Compliance was achieved October 18, 1976.
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2 Movimbs'r 9, 1976
~
Ar. W. C. Sisdio, Chief Item I.A.2.b - Acceptance of Electrical Penetration Assemblies i
Control of purchased items received and accepted at the site was not performed in accordance with the provisions of Ebasco Proca-dure ASP-III-14 in that material received inspection reports for twelve (12) electrical penetration assemblies indicated that the assemblics were accepted prior to the completion of a documenta-tion review by the site Quality Assurance Department. Subsequent to acceptance by Ebasco Materials Control, documentation for the assemblies was found to be deficient by Site QA.
Corrective steps which have been taken and results achieved:
1)
All required documents have been updated to reflect the correct status of the equipment.
Corrective steps that were taken to avoid further noncompli-2)
Additional qualified QC Material Control personnel ance:
have been assigned to assure full compliance with inspection QC Material Control personnel have been requirements.
instructed or reinstructed as to the requirements of Ebasco Procedure ASP-III-14.
- 3) The date when full compliance will be achieved:-
Full Compliance was achieved October 18, 1976.
Yours very truly, D. L. Aswell Manager of Power Production DIA:AEH:gmw bec: Ebasco (2), J. M. Brooks, J. O. Booth (2), D. L. Aswell, L. V. Maurin A. E. Henderson, D. B. Lester, P. V. Prasankumar, H. W. Otillio, l
.F. X. Shaughnessy, L. Biondolillo,_C. C. Chezem, T. F. Cerrets, D. N. Calligan, C. J. Decareaux l
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UNITED STATES OF AMERICA '
o NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD QQP In the Matter of
'85 FEB-6 P4 44 LOUISIANA POWER AND LIGHT COMPANY
)
Docket No. 50-382 4 (Waterford Steam Electric Station.
l URCf N 3Ew;f; Nfjf"O Unit 3)
)
Joint Intervenors' Reply to Applicant and NRC Staff's Responses to Joint Intervenors' Motion to Reopen have been served this 25th day of January,1985 by mailing a copy, first class, postage pre-paid, to the following:
- Christine N.. Kohl, Chairman Dr. Harry Foreman, Director Atomic Safety and Licensing Administrative Judge Appeal Board University of Minnesota U.S. Nuclear Regulatory Commision Box 395, Mayo Washington, D.C 20555 Minneapolis, MN 55455
- Dr. W. Reed Johnson E. Blake. Esq.
Atomic Safety and Licensing Appeal
- B. Churchill, Esq.
Board Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
Washington, DC 20555 Washington, DC 20036
- Howard A. Wilbur Luke B. Fontana, Esq.
~ Atomic Safety and Licensing Appeal 824 Esplanada Avenue Board New Orleans, LA 70116 U.S. Nuclear Regulatory Commission Washington, DC 20555 Malcolm Stevenson, Esq.
Monroe & ~Lemann Sheldon J. Wolfe, Esq., Chairman 1424 Whitney Building Administrative Judge New Orlean, LA 70130 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Gary L. Groesch Washington, DC 20555 2257 Bayou Road New Orlean, LA 70119 Dr. Walter H. Jordon Administrative Judge Ian Douglas Lindsey, Esq.
881 West Outer Drive 7434 Perkins Road Oak Ridge, TN 37830 Suite C Baton Rouge, LA 70808 Brian P. Cassidy Regional Counsel Atomic Safety and Licensing FEMA Appeal Board Panel John W. McCormack U.S. Nuclear Regulatory Commission Post Office and Courthouse Washingtori, DC 20555 Boston, MA 02109
- /
o 7{
William J. Guste,.ir., Esq.
Docketing and Service
~
Attorney General for the Section State of Louisiana Office of the Secretary 234 Loyola Avenue, 7th Floor U.S. Nuclear Regulatory New Orleans, LA 70112 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Carole H. Burstein. Esq.
U.S. Nuclear Regulatory Commission 445 Walnut Street Washington DC 20555 New Orleans, LA 70118
- Sherwin Turk, Esq.
Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 D
vik ua %+ Q L)(ine Bernabei
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