ML20114F847
Text
e, 50 - 3D
.:..- v, n
~
7 ovan, Assista.* 'tir"ctor
' ice :tinq, IL
.cv" r.'v' l10 affirjaV.t 0.f C,
, a !er%
r ru af fir'avit of T-Y Cheno corcerr.1. :
' :" I t, U.
I c ; c.-
"lat( tar filin evitti the '..a te r f ', e. -
tr :.
I F rank Schro_'!cr. Assistant ir"r r for Generic Projects
- ivision of Safety Technoler, cc
f.. t.niel Distribution Copies:
Aral Files GP r/f SHanauer DST c/f f
~
I3l
.rp 6
1 s
r....
,5 O f~l'I C 1/ L H L L O k u L U P t
~'_ M "2~2 L..
s T)fA b j
i i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COP 911SS10N BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of ll l
t LOUISIANA POWER AND LIGHT COMPANY l l
Docket No. 50-382 l
Iwaterford Steam Electric Station. ljl t' nit 3)
AFFIDAVIT OF TSUN-YUNG CHANG CONCERNING UNRESOLVED GENERIC SAFETY ISSUE A-46 (SEISMIC QUALIFICATION OF EQUIPMENT) 0.1.
Please state your name and by whom you are employed.
A.1.
% name is Tsun-Yung Chang.
I am employed by the United States Nuclear Regulatory Commission as Senior Mechanical Engineer.
Seismic and Dynamic Lead Que11fication Section. Equipment Qualification Branch Divisten of Engineering. Office of Nuclear Reactor Regulation.
A copy of my professional qualifications is attached.
Q.2.
Please describe the status of Unresolved Safety Issue (USI) l A-46 (Seismic Qualification of Equipment in Operating Plants) with respect to the WaterfoN Unit 3 facility.
.A.2.
USI A-46 only applies to operating plants which did not use current design criteria for the seismic qualification of mechanical and
'"ctrical equipment; US! A-46 does not apply to Waterford Unit 3 I
notwithstanding its having been mentioned in Appendix C to the Wateeford R. intsmuch as Waterford Unit 3 is being reviewed against current j
criteria.
I i
I i
1
~
{l 2-Q.3.
Will the outcome nf USI A-46 have any impact upon the Staff's seismic qualification review.for Waterford, Unit 37 A.3.
No. The purpose of A-46 is to decide whether the current criteria as applied to setsmic qualification of safety related equipment should be backfitted in part or in whole with regard to operating plants.
The resolution of A-46 is not expected to have any impact on the seismic qualification of equipment in Waterford Unit 3 inasmuch as Waterford Unit 3 is being reviewed against current seismic criteria, which are not expected to be revised following the resolution of US! A-46.
Q.4 Please describe the status of the Staff's seismic qualification equipment review for Waterford Unit 3 against current criteria?
l A.4.
The Staff's review, which is unrelated to USI A-46, is continuing at this time.
In order to assure that the Applicant has provided an adequate
. ogram for qualifying safety-related electrical and mechanical equipment 1or seismic and dynamic loading, the Seismic Qualification Review Team (SQRT) of the Equipment Qualification Branch performs a two-step review.
The first step involves a determination as to the acceptability of the procedures tesed, the standards followed and the completeness of the program in general; this is accompliched by review of the applicable sections of the Final Safety Analysis Report (FSAR) against the following current Itcensing criteria:
IEEE 344-1871, and additional requirements as spec'ified in Standard Review Plan (NUREG-75/087) Section 3.10, and f
Regulatory Guides 1.32 and 1.100. The second step consists of.an on-site audit of selected equipment to develop a basis for determining
I
. whether the implementation of the seismic and dynamic qualification program is adequate and complete.
The Staff's review of the Applicant's FSAR against current criteria is ongoing at this time. With respect to the SQRT on-site audit, en initial site visit was conducted on September 15-18, 1981, and a second site visit will be conducted during the week of August 30, 1982.
The msults of this review will be used to detamine the adequacy of the Waterford Unit 3 seismic and #namic qualification program. The Staff's evaluation of that review will be m ported in a future supplement to the SER.
Q.5.
Has the Staff determined whether it would be acceptable ~to permit Waterford Unit 3 to operate despite the incompleteness of the taf f's review against current criteria?
A.S.
The Staff's position is that the Applicant must demonstrate satisfactory seismic qualification of equipment against current criteria
,-ior to licensing. At this time. that demonstration has not yet been u tisfactorily. The Staff will require that a resolution of this provided prior to permitting the commencement of operation.
e
.m
w a
W-7
PROFE5510NAL QUALIFICATIONS OF T5UN-YUNG CHANG I an a senior anchanical engineer in the Seismic and Dynamic Load Qualification Section of the Equipment Qualification Branch, Division of Engineering. Office of nuclear Reactor Regulation. United States Nuclear Regulatory Commission. % duties and responsibilities involve the review and evaluetten of the strweturel integrity, operability, and functional capability of safety related mechanical and electrical equipment under all noma 1. abnorum1. and accident loadirq conditions, as well as seismic occurrences and other pertinent (ynamic loads.
I joined the IRC in January Ig80. serving as senior mechantcal, engineer in the Engineering tren3. Division of Operating Reactors. Office of Nuclear Reactor Regulation. % duties were to review and evaluate safety issues related ta mechanica1. meterial and strwetural engineering aspects of reactor a llties licensed for operation; to evaluate applications for construction 3
permits or operating licenses for non-power reactors evaluate the modification of ERA and DOD-owned fact 11 ties exempt from licensing.
In April 1980. I joined the Equipment Qualification Branch.
prior to joining the IRC. I served as a senior mechanical engineer with Stone and Mobster Engineering Corporation for over seven years, uhere I was involved in various aspects of pipe stress analysis for a nu d er of nuclear power plants.
l I have a Bachelor of Science degree in Mechanical Engineering from Taimen Nationel Cheng-Kung University, a Master of Science in Aeronautics
~
~-
u
.=
2 from California Institute of Technology, a Master in Mechanical Sciences from Princeton University, and a Ph.D. in Applied Mechanics from Polytechnic Institute of Brooklyn.
I as a registered professional engineer in the states of Massachusetts and California.
I as a member of the American Society of flechanical Engineers and the Society for Experimental Stress Analysis.
~
e l
q l
r;i n
..,-.-,-n-,
,_n.,..__.
,n',
-__.,_.,,.,,,_-,,,,.,,-....-.,n,.
g l
T)p46 4
UtilTED STATES OF AMERICA NUCLEAR REGULATORY C0f941SS10fi BEFORE THE AT00!C SAFETY AND' LICENSING BOARD
~
In the Matter of LOUISIANA POWER AND LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station.
Unit 3)
AFFIDAVIT OF CLIFFORD J. ANDERSON AND CNI-YU LIANG CONCERNING UNRESOLVED GENERIC SAFETY ISSUE A-45 (SHUTDOWN DECAY HEAT REMOVAL REQUIREMENTS)
Q.1 please state your names and by whom you are employed.
A.1 (a) % name is Clifford J. Anderson.
I an employed by the United States Nuclear Regulatory Comadssion as Senior Systems Engineer, Generic Issues l' ranch Division of Safety Technology, Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached.
(b) % name is Chu-Yu Liang.
I an employed by the United States Nuclear Regulatory Coundssion as Senior Reactor Systems Engineer,
..ctor Systems Branch. Division of Systems Integration. Office of
.. lear Reactor Regulation. A copy of my professional quellfications is attached.
0.2. Please state whether the feed and bleed discussion in Appendix C of the SER (at C-16) applies to the Waterford Unit 3 design.
_m
- A.2 In Appendix C of the SER the following statement appears:
" Pressurized water, reactors also have alternate means of removing decay heat if an extended loss of feed-water is postulated. This method is known as " feed and bleed" and uses the high pressure injection system to add water coolant (feed) at high pressure to the primary system. The decay heat increases the system pressure and energy is removed through the power-operated relief valves and/or the safety valves (bleed), if necessary.
This statement does not apply to Waterford Unit 3. inasmuch as the Waterford Unit 3 reactor coolant system (RCS) is designed without PORVs on the pressurizer. Rather, it is a generic statement applicable to most PWR plants; unfortunately it is worded in a manner that incorrectly gives the impression that all PWR plants have PORVs and a " feed and bleed" capability for removing decay heat. Not all PWR plants have this alternate means of removing i
decay heet. Moreover. not all plants with PORVs can successfully rumsve decay heat by " feed and bleed". While such a design feature may provide added capability for decay heat removal, the Staff has
.not yet found it to be a necessary design feature for PWRs.
Q.3. Please explain wh the Staff concludes in the SER for Waterford Unit 3 (at C-17) that the plant can be operated safely before l
ultimate resolution of Unresolved Safety Issue (USI) A-45 (Shutdown DecayMeathemovalRequirements).
l A.3. With respect to decay heat removal, the Staff has concluded that l
Waterford Unit 3 can be operated safely prior to ultimate resolu-l tion of USI A-46; however, with respect to depressurization
.. m 3
n bq capability, the Staf f has not yet concluded whether Waterford 4u Unit 3 can be operated safely prior to resolution of USl A-45.
'l
- I I
.1 (a) Decay Heat Removal i\\ t The overall purpose of Task A-45 is to evaluate the adequacy of current design requirements, in order to ensure that nuclear power plants do not pose an unacceptable risk because of failure to remove shutdown decay heat.
In addition, this USI will evaluate the benefit of providing alternate means of decay heat removal (DHR) which could substantially increase the plant's capability to handle a broader spectrun of transients and accidents. The study will include a number of plant-specific DHR systems evaluations and will result in recommendations regarding the desirability of. _and possible design requirements for, improvements in existing systems or an alternative decay heat removal method, if the improvements or j
alternatives can significantly reduce the overall risk to the
]
{fj public in a cost-effective manner.
s The Waterford Unit 3 decay heat removal capability relies upon the fk steam generators, using emergency feedwater and atmospheric steam dump valves and/or safety valves and the Residual Heat Removal NM (RNR) System. The staff's review of the RHR system is found in section 5.4.3 f the SER.
The Emergency Feedwater System (EFWS) is 71x importent in terets of providing the necessary heat sink capability.
(fg em Following the TMI-2 accident, the Staff embarked on a major upgrading gg 14 s&
w.
?
4-of the EFWS for all PWR plants including Waterford Unit 3.
A discussion of how the Waterford EFWS rneets these post THI-2 require-ments is provided in Section 10.4.9 of the staff's SER. The relia-bility of the EFWS is discussed at length in the Staff's " Affidavit of Richard Lobel, Brian Sheron and Ashok Thadani Concerning Feed-and-Bleed and Emergency Feedwater System Reliability," filed with 1
the Licensing Board on April 12, 1982.
Therein, the Staff indicates that feed-and-bleed is not deemed to be required solely to provide a back-up to the emergency feedwater system f or decay heat removal.
In sum, because of the upgrading of the current decay heat j
removal system and in consideration of the reliability of the-EFWS, the Staff has concluded that Waterford Unit 3 meets current NRC requirements with respect to decay heat removal ~ts found in the regulations and the standard review plan. We therefore conclude with regard to decay heat removal that Waterford Unit 3 can be operated prior to ultimate resolution of this generic issue without endangering the health and safety of the public.
(b) Depressurization Capability As a result of recent steam generator tube integrity questions and other considerations (e.g., ATWS), the Staff is considering requir-ing a means of rapidly depressurizing the RCS.
However, as was stated in the Staff's Affidavit of April 12, 1982 (referred to
.p*'
w g _; ;
~
. ebove). Waterford Unit 3 currently meets all regulatory require-ments without PORVs. Tl)e depressurization issue is being addressed 9enerically for all PWRs in U51 A-45.' For CE plants, the Staf f is reviewing the PORV depressurization issue with CE on an expedited senedule.
In Supplement 3 to the SER (p. 5-2), the Staff indicated that it has requeste.1 additional information from Combustion Engineering, Inc.
(CE) and the Waterford Unit 3 Applicant, with respect to the need for rapid depressurization capability in Waterford Unit 3.
A response to the Staff's request has not yet been received.
If a response is not provided prior to the anticipated fuel load date for Waterford Unit 3, the Staff has required the Applicant to provide a justification for safe operation of the facility until the requested submittal has been made. By letter dated May 6,1982, the Applicant committed to provide a justification for interim operation if its PORY response can not be completed at least one month prior to the fuel load date. The Applicant's interin justification has not yet been received and it.would be premature for the Staff to determine whether that justification will be sufficient for the Comission to~
permit interim operation of the facility.
It should be noted that San Onofre Unit 2, a plant with a design si,milar to that of Waterford Unit 3. has submitted a justification for safe interim operation, notwithstanding the incomplete status of the Staff's depressurization capability review. After conducting
[
6-a caref ul review of that justification, the NRC Staf f and the Comission have approved power operation for that plant. The Staff expects that such a review will be conducted for Waterford Unit 3 before the plant will be pemitted to operate.
O w
)
)
l 1
.?
Y
---3
~
i Professional Qualifications
, Chu-yu Liang, Reactor Systems Branch Division of Systems Integration U.S. Nuclear Regulatory Comission I am employed as a Senior Reactor Systems Engineer, Reactor Systems Branch, Division of Systems Integration, U.S. Nuclear Regulatory Comission, Washington, D.C.
The Reactor Systems Branch is responsible for reviewing reactor license applications and evaluating the design of reactor systems, including the residual heat removal and emergency core
.onling systems, of the nuclear power plant with respect to nuclear
.ety.
As part of my duties, I have been responsible for reviewing the
~
operating license apolications of several facilities with respect to reactor systems, including Waterford Unit 3.
From 1965 to 1967, I was employed by Lockwood, Andrews and Newman, Inc. (Houston, Texas), where I worked on the design of mechanical systems for public buildings including heating, ventilation and air conditioning systems, central plant and emergency power systems.
From 1967 to 1969. I was employed as a mechanical engineer by Avondale Shipyards, Inc. (New Orleans, Louisiana), where I worked on the design of marine steam power plants for tankers, destroyers, and cargo ships.
From 1969 to 1974, I was employed as a Senior Engineer in the Department of Systems Engineering, PWR Systems Division, Westinghouse Electric Corporation (Monroeville, Pennsylvania), where I worked on the design and review of nuclear power plant auxiliary and power conversion systems.
I served as a lead engineer for 16 Westinghouse PWR plants, l
providing balance of plant design criteria and NSSS interface requirements and assisting pl, ant designers (e.g., Architect-Engineers) in the areas of auxiliary and power conversion system design.
From 1974 to the present, I was employed by the AEC, in the Auxiliary and Power Conversion Systems Branch, Division of Technical Review; following the reorganization of the AEC, I served as a systems engineer in the Auxiliary Systems Branch, Division of Systems Safety, U.S. Nuclear Regulatory Consnission.
In 1980, I commenced employment with the Reactor Systems Branch, Division of Systems Integration.
I attended the Cheng-Kung University Taiwan, and received a B.S.
Degree in Mechanical Engineering in 1960.
I received a Master of Science
~
Degree in Mechanical Engineering (majoring in steam power plant ~ des,ign) from the Oklahoma State University in 1965.
I have also attended the Graduate School of Engineering at Catholic University. Washington, D.C.,
where I took a course in Nuclear Engineering.
.I as a member of the American Society of Mechanical Engineers.
l
,--e-
,_y.,,,
-,.y,,.-.
_,,,.,,._m-.-_
._-.y._.--
- 1!!:
- 't:,'
O.
,. - ;- 1 t.
f.;':.t t t's R t '.:'; A IUP Y Ui""' ' ' ; ; 'i A i O*'I t 5 'd i T Y A*iD t 10 ti'.1 NT F. :. ;J.'!)
- .ef ore AS tr:itt rat ive
.lud.."a
'helcon J. Wo l f e, Cho i r..an Dr. Walter H. Jordan Dr. Harry f orerr.an
)
in in, Motter of
)~ '
)
10V!51 ANA POWIR AND t lGHT COMPANY,
)
Docket rio. 50- 3!J -0;
)
(Waterf ord St eam Electric Station.
)
August 12, IE Hnit 3)
)
)
M!.'40R A'iDUM AND ORDER (kequesting $1at f 's At 1idavit)
MEMORANDUM A;;"'ndix C of the Safety Evaluation Report (SER) (St af f Ex. ?) addrenas thirteen-une esolved generic safety issues.
Altriough these inues are unruntested, we are required to esamine them and to
<'ot er r ine ' e t her there is a reator.able basis for concluding that the etorc Plant can tie operated safely pending their resolut ion.
n t a f lec t ic & Power Ce rpeny (r.arth Anna ?.oclear Poner St at ion, 1.ind ?). AL AB-491, 8 NRC 245 (19/8).
V f
OA A (710 /\\ \\ 9 f j ()() I j uld W ( l -[*
_ m r- - w
= n :n
. i.
$+ i smi_c__Oua l i f ic at ion s _o_f Equ i pmen_t_.. ' n Op e r a_t i nc. F l o n t -..
W r. h respec t to Seismic Qualif icat ions of Equipmont, t r <
- u. -
th.' ' he St aff st ated that its review of Waterford 3 against o ri se r.mic crit eria was incomplete and that the results of it s evaluatit n would be reported in a future supplement to the SER.
However, Supplements 1, 2 and 3 (Staf f Exs. 3, 4, and 5) report ed that
.-~
this issue had not yet been resolved.
2.
Shutdown Decay Heat Removal Requirements ( A-45)
In Appendix C to the SER, the Staff concludes that Waterford 3 can be operated safely prior to resolution of the issue whether an alternative means of decay heat removal should be required in plant design.
The Staff bases its decision upon the capability of the
- cam generators to transfer decay heat to the main or auxiliary f sater systems, and u x.n the capability of the high pressure inject ion system to add coolant at high pressure to the primary system w r. : i e i.
gy irom decay heat is removed by releasino pressure throuch ee -operated relief valves (PORVs).
This latter method of dor ey h"at remov al is known as " feed and bleed"; however, the Waterford 3 r coes not have PORVs and hence has no feed and bleed
- slity.
This floard had previously raised the need for feed and bleed c apability as a sua sponte question; we withdrew the issue, not be tuse we were convinced that the question did not present a sericus.afetv matter, but because we were sat isfied that t he need f or feed. ost :,1 c ec
-?
^
6 I
g
, capability would be explored on a generic basis by 5taf f and the MP5.
(wmorandum and Order of April ?7,1982, at 2).
In reaching that dettston, we examined and found unconvincing the arguments prof f ered by Applicant and endorsed by the Staff that the reliability of the t e, d=ater systems obviated the need for feed and bleed c ;pubility.
- Id. at 3-8).
Similarly, in Supplement 3 to the SER (Staf f Ex. 5), t he Staff discusses the lack of feed and bleed capability in the reactor design and concludes that it is no longer confident that the steam generator is adequate as the sole means for shutdown decay heat removal.
(Id. at 5-2).
The Staff indicates that it is seeking more information and may require that Applicant provide justification for interim safe operation of the plant.
We, therefore, find Staff's conclusion that Waterfurd 3 can be operated safely pending resolution of generic issue A-45 to be without basis in the SER; Waterford 3 has no feed and bleed capability and the SER provides no support for relying solely on the steam generator /feedwater system to remove decay heat.
ORDER
~
1 With respect to A-45 and A-46, pursuant to viruinia Electric o.er Co_. (North Anna Nuclear Power Station, Units 1 and 2),
A'-491, P NRC 245 (1978), the Staff is requested to provide ue.,
in
.:f wit f orm, a full and detailed explanat ion of why it cent.ludes t hat it wauld be accept able to permit Waterf ord 3 t o nperat < <
,pi' e
~ 1 1.
a p.....
a 4
the inco:npleteness of the Staff's review, or, if the Staff's review is now completed, to provide a full and detailed explanation justifying why it concludes that Waterford 3 can be permitted to operate.
2.
The Staff's affidavit is to be filed by August 25, 1982 and the other parties may comment thereon by September 8,1982.
Judges Jordan and Foreman concur, but were unavailable to sign this issuance.
IT IS 50 ORDERED FOR THE ATOMIC SAFETY AND LICENSING BOARD
- Ob\\
M g
Sheldon J. Wo;
, Chairrflan ADMINISTRATIVL UDGE Dated at Bethesda, Maryland, this 12th day of August,1982.
e
-%-.y-,e-r-..
r
-,y--
e r
7 w
C umrao sTAvas NUCLEAR REQULATORY COMMISSION
.....)
seassensatoes.o c.rosse
/
/
H AUG 311982
[
T IW ORAN0434 FOR:
J. Lieberman, Director, Enforcement Staff, IE FROM:
T. L. Harpster, Chief, Quality Assurance Branch, Division of Engineering & Quality Assurance IE
SUBJECT:
REVIEW OF DRAFT ENFORCEMENT ACTION WATERFORD #3 REPORT NO. 50-382/82-14 At your request, draft inspection report 50-382/82-14 (enclosed) was reviewed tu assess the significance of the inspection findings at the Waterford #3 facility and the effectiveness of the Louisiana Power & Light (LP&L) quality asserence program, w inspection report identifies areas where the implementation of the LP&L and
.,r ractor QA/QC program has not been effective:
specifically. (1) the quality
,.rol inspection of hanger supports and welding installed by the contractor.
'es&Beckwith(page11)and 2) ESASCO quality assurance audits of the a turnover packapes (page 10)(.
These itsas have been identified as a erity Level !Y vio ation of 10 CFR 50, Appendix 8. Criteria II. The report also states that LPGL has in tho' past employed a minimal construction QA staff (en the order of 4 to 5) which results in an overreliance on EBASCO as construction annager(page8). ERASCO's on-site OA organization has only consisted of appresimetely 19 auditors. A potential root cause (page 11) has been identified as the LpSL spper senegement pressure to turn systems over in order to begin the teettag progma. This has created a situation where system quality apparently ces14 not he assured dee to the mettload involved in trying to track actual l
system status.
Based en sur rettom. the fellering comments are offered:
1.
These fladings are significant quality assurance program implementation deficiascies and steeld be elevated to a higher severity level (level
!!!). The beets for this is that the defic' encies had not been identified and eerfected by apre than'one 04/QC checkpoint relied upon to identify) vlelettees the contractors (T&S) QC inspection, contractors (T&B 5 pesprem, e..
SA audits, and LP6L OA overview. The licensee has been in asnesupItanes with Criterion !! (0A Criterien IV (Nonconforming components) program), Criterion X (Inspections
. Criterion XVII (QA records) and CriterienXVIII(Audits).
CNTACT:
E. J. Gallagher, I 4g-24g68 Fo / A l+3 W20TcT90MLX/4-N%
OfSZ-
AUG 311982
-2 J. Liebersen There appears to have been less than total commitment to quality by LP&L 2.
management since minimal LP&L QA resources have been dedicated to the project (i.e.
licensee staff of 4 to 6).
Siellarly, the construction i
I do not believe
)
manager has had a minimal QA staff of approximately 10.
that Lp6L has couarited sufficient resources to audit and control the l
Recent experience construction manager and subcontractor organizations.
has shown that sites with minimal licensee quality assurance resources j
such as Marble Hill. Midland and Zimmer have experienced significant breakdowns in quality assurance during construction.
)
The potential root cause identified may have generic implications to the Management appears to have put emphasis on meeting 3.
Waterford project.
system turnover schedules without the appropriate balance of the quality If Ly&L management does not establish a of the system prior to turnover.
quality poliqy in balance with the system turnover schedule then st ord #3 sight be expected to have quality problems similar to other Wefacilities that have had QA program breakdowns late in the project.
A The imC constrection status report lists Waterford #3 as 94% complete.
review of the inspection affort at Waterford #3 indicates approximately 800 This ann-hours of taspection in all inspection areas this year as of August.
number appears las considering the level of continuing construction, system tureover and preoperational testing. Waterford #3 appears to be an ideal sendidate for a construction team (CAT) inspection.
$1 Terry L. Harps
. Chief Quality Assura a Branch Division of E neering gnd Quality Assurance Office of Inspection and Enforcement Enclosers:
4 ec: J.Tayier.IE J. Menderson. IE R. Vollmer. Iga
- 5. Black,imR G. Madsen RIV GuAs:lt
<e#
, g pg es r e sw.'
,j #. ** %.,
NUCLEAR REGULATORY COMMISSION g
[ 4c/
,[
neoios av s
\\
su avam nm omvc sunt some anuwcror. 7txas non g
DRAF.
Decket:
50-382/82-14 i
Louisiana Power and Light Company ATTW:
L. V. Maurin, Vice President Nuclear Operations 142 Delaronde Street New Orleans, Louisiana 70174 Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program by Messrs. G. L. Constable and J. E. Cummins of our staff during the 15, 1982, May 16 to July CPpt-103 for the Waterford Steam Electric Statio'n, Unit 3, and to the discussion of our findings with Messrs. D. 8. Lester, G. Rogers, and other members of Reference is also made to the your staff at the conclusion of the inspection.
esforcement conference held in your corporate offices on August 20, 1982.
Principal areas examined during the inspection and our fi'ndings are documented Within these areas, the inspection in the enclosed inspection report.
consisted of selective examination of procedures, drawings, representative records, interviews with personnel, and observations by the NRC inspectors.
- ring this inspection, it was found that certain of your activities were ia elation of IAC requirements.
Consequently, you are required to respond to Section 2.201 of the 18tC'g..in accordance with the provisions
.m s violation, in writin Federal Regulations.
Your response should be based on the specifics contained in tM hetice of Violation enciesed with this letter.
The enciesed hetice of Violation involving a failure to establish suitable l
controls ever activities the quality of safety systems, is classified as a Severity iolation.
This classification was.made l
safety significance in this specific instance efter careful considerat and uns based en your pregt identification of the probles to NRC and on your prompt reaction to LNiL 04 findings that resulted in extensive corrective action I
te evoid fvtere violations.
l One new unresolved item is, identified in paragraph 6 of the enclosed report.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be pieced in the NRC Public Document Room unless you notify this office, l
by telepWne, within 10 days of the date of this letter, and submit written application to withheld information contained therein within 30 days of the
~
l date of this letter.
Such application must be consistent with the requirements of 2.790(b)(1).
i
~
/
g* **%.
, 7gf,4 va,m o uam j
NUCLEAR REGULATORY COMMISSION g/
3gI
[ 4c/
d neo o= tv su evan etAra omvs surve wr
,{,
antwooroe, Traas mn Docket:
50-382/82-14 DRAFI Louisiana Power and Light Compariy ATTW:
L. V. Maurin, voce President euclear Operations 142 Delarence Street New Orleans, Louisiana 70174 Gentlemen:
This refers to the inspection conducted under the Resident
.spection Progras by Messrs. G. L. Constable and J. E. Cummins of our staf f du 'ng the period 16 to Jidy 15, 1982, of activities authorized by NRC Construction Permit 103 for the Waterford Steam Electric Statio'n, Unit 3, and to the discussion of our findings with Messrs. D. 8. Lester, G. Rogers, and other members of your staff at the conclusion of the inspection.
Reference is also made to the enforcement conference held in your corporate offices on August 20, 1982.
Principal areas examined during the inspection and our fi'ndings are documented in the enciesed inspection report.
Within these areas, the inspection consisted of selective examination of procedures, drawings, representative records, interviews with personnel, and observations by the NRC inspectors..
During this inspection, it uns found that certain of your activities were in violation of ISC requirements.
C== ;tly, you are required to respond to
.wction 2.201 of the IRC'g..in accordance with the provisions of is violation, in writin I
s " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Your response should be based on the specifics contained in the met <ce of Violation enciesed with this letter.
The enciesed listice of Violation involving a failure to establish suitable centrols over activities the quality of safety systems, is claselfied as a Severity iolation.
This classification was made after carefel consideret safety significance in thii specific instance and uns tened en your prompt identification of the problem to NRC and on your pregt reaction to LPGL 04 findings that resulted in extensive corrective action te sueld fetere violettens.
One new unresolved item is, identified in paragraph 6 of the enclosed report.
Im aceerdance with 10 CFR 2.790(a). a copy of this letter and the enclosures will be placed in the Inc Public Document Room unless you notify this office, ty telopenne, within 10 days of the date of this letter, and submit written application te withhold information contained therein within 30 days of the dote of this letter.
Such application must be consistent with the requirements of 2.790(b)(1).
l
,,,.,---,,_--,-,,----,--,,.m_-,.n
,n
-n--,--_.a-
_n-,---., _ _, -, _ _ _,,., _ _ - _ - ~ - - - - -. - -
._1.
! W Louisiana Power and Light 2
l Cogeny The response directed by this letter and the accompanying Notice is not sub) pct to the clearance proceoures of the Office of Management and Budget as j
required by the Paperwork Reduction Action of 1980, PL 96-511.
l Should you have ary questions concerning this inspection, we will be pleased j
to discuss thee with you.
Sincerely, G. L. Madsen, Chief Reactor Project Branch 1
Enclosures:
1.
Appendix A - Itetice of Violation 2.,
Appendix B - lac Inspection Report 50-382/82-14 cc w/encls:
Louisiana Power and Light Company ATTII:
F. J. Drummond, Project Support Manager 142 Delarende Street Iles Orleans, Louisiana 70174 Laurisiana Power and Light Campsey ATTII:
T. F. Garrets, QA Manager
)
(same h )
Louisiana Pouer and Light Campasy ATTIt:
- 8. B. Lester, Plant Manager P. 6. Sea B K111ans, Louisiana 70056' s
,---------r.n.s.- -,-n,,. -,. - - - - -, - - - -. - - - - -,. - -
,-,e.-
--~
APPENDIX A NOTICE OF VIOLATION Loutstana Power and Light Company Docket:
50-382/82-14 waterford SES, Unit 3 Permit:
CPPR-103 Based on the results of an NRC inspection conducted during the period of May 16 to July 15, 19h2, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated.Merch 9,1982, the following violation was toentified:
10 CFR 50 Appendix 8, Critation II, requires that, "The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and components to an extent consistent with their importance to safety.
Activities affecting quality shall be ac:asplished under suitably controlled conditions."
Ehesco Services, Inc., Procedure ASP-IV-50, " Release and Turnover from Construction to teaterford Startup," establishes controls and documentation requirements for' system turnover.
The procedure requires that contractors provide quality records, including exceptions, as part of the release and turnover packages; and, in addition, requires that Ebasco quality assurance review these records for completeness, accuracy of content, proper fors, and treceability.
Contrary to the above, on April 30, May 20, May 22, and June 22, 1982, -
Ehesco QA signed four ASP-IV-50-6 forms indicating that the pertinent fabricaties and installation records for four starte systems were ready for turnover to LP&L.- These startg systems were containment spray, low pressere safety in 1
ue to numerous que ty records and excep-tien 1 sts did not accurately identify.
s
,These LPGL findings included previously unidentified installation errors, as=heilt drawings that did met match actual field installation, field installations which included work that was not in compliance with pro-eedures and specifications,% inspections that had not identified l
uneeseptable field installations, and1)C records that were not consistent l
with current as-huilt drowings.
Taken together, these. findings represent a failure to adequately control the gus11ty of safety-related work at the contractor level and a failure by Ebasce services, Inc., as construction manager, to adequately control i
ses quality of safety systems and their records.
This is a Severity Level IV Violation.
(Supplement (11.0) 1 l
r
Louisiana Power and Light 2
Campaan Pursuant to the provisions of 10 CFR 2.201, Louisiana Power and Light Company is hereby required to suesit to this office, within 30 days of the date of ta.is metice, a written statement or explanation-in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
Dated:
e e
e M
z.
i 3...
Q l.
h.::-
E.,' M
(-
e ee
--e
U APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV Report: 50-382/82-14 Docket: 50-382 Permit:
CPPR-103 Licensee:
Louisiana Power and Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Facility Name:
Waterford Steam Electric Station, Unit 3 Inspection At:
Taft, Louisiana Inspection Conducted:
May 16 to July 15, 1982 1
Inspectors:
G. L. Constable, senior Resioent Inspector Date J. E. C m ins, Resident Inspector Date l
Assisting Personnel:
W. B. Jones, Engineering Assistant Date Approved:
W. A. Crossaan, Chief Date i
teacter Project Section B la msction $m mery i
Tien Conducted May 16 to July 15, 1982 (Report:
50-382/82-14) a Routine, unennounced inspection of:
(1) Site Tour; (2) to Heat Sink Test; (3) Preoperational Test Procedure Review; IGuelityAssuranceProgram;(7)OperationQualityControlProgram.lasta 1stian The
,A ion involved 260 inspector-hours by three NRC inspectors.
rF.
[~
h its:
In seven of the eight areas inspected, no violations or dev ations unre seentified.
One violat<en, failure to adequately control the quality of safety-related work, was identified in one area (paragraph 86).
qp 8.M.
r
p, 2
Details 1.
Persons Contacted "T. F. Gerrets, QA Manager D. B. Lester, Plant Manager "W. M. Morgan, QA Engineer "J. Woods, QC Engineer "G. Rogers, Site Director
- L. L. Bass, QA Engineer
- W. Cross, Site Licensing "F. Drumeond, Project Support Manager J. Bradley, Startup Engineer J. Rasbury, Startup Engineer "Present at exit interviews.
In addition to the above personnel, the inspectors held discussions with various operations, construction, engineering, technical support, and aeministrative members of licensee's staff.
2.
Plant Status The Idsterford 3 site is in the early phase of system turnover for preoper-ational testing.
The current published fuel load date is January 1983, with construction indicated as approximately 945 complete.
Although construction activity is still in progress, this percentage has not changed since January.
A new goal for fuel loading is expected to be announced in the near future.
A site manager, George Rogers, was added to the onsite Louisiana Power and Light (LP&L) staff.in May.
Mr. Rogers has responsibility for construc-f tion, engineering, and startup.
i 3.
Site Tour At various times during the course of the inspaction period, the NRC i
inspectors conducted general tours of the auxiliary building, fuel hand 1-i ing building, reactor building, and the turbine building to observe ongoing construction and testing.
the NRC inspectors noted that dry cooling tower fan l
On May 21, 1982, actor 1-58 had been removed from its permanent plant location; however, an equipment tracking / condition ID tag had not been hung on the location where the component was installed as required by Startup Administrative This Procedure SAP-06, " Condition Identification and Corrective Action."
condition was discussed with the systes startup engineer and a tag was hung.
The corrective action was adequate for this specific occ: ~ence.
-e n t The NRC inspectors have frequently noticed that instruments anc %
~~
1 b
3
/
have been removed without apparent controls *being established.
Im;:lemen-tation of equipment tracking procedures is an open item (8214-01) and will be reviewed during a subsequent inspection.
He violations or devations were identified.
4.
Ultimate Heat Sink Test Witnessing j
i The NRC inspectors witnessed portions of the performance of Prerequisite-Preservice Test SFG-36-004, " Wet and Dry Cooling Tower Fans Performance
~
Evaluation." This test is a part of the evaluation being done to deter-sine if the wet and dry cooling towers can perform their design functions for different operating conditions.
No violations or deviations were identified.
5.
Pmoperational Test Procedure Review The NRC inspectors reviewed Preoperational Test Procedure SPD-69-001,
" Vibration and Loose Parts Monitoring." The procedure was reviewed for technical adequacy, compliance with replatory requirements, and compli-ance with licensee commitments and adm<nistrative controls.
The fol h ing comments were discussed with the system startup engineer.
5p0-49-001 Pereseash No.
M 2.5.2 Referenced procedure was OP-VLP-100, " Vibration and Loose Parts Monitoring Operating Procedure," but the aperating procedure for vibration and loose parts asettoring is Op-04-017.
Referenced procedure number needs to be changed.
7.3.4.1 This paragraph requires that power spectral density (p 3 ) signatures be taken for each of the reactor coolant peps in accordance with the vibration and lesse parts monitoring operating procedure.
Vibra-tien and loose parts monitoring operating procedu a did not contain instructions for performing the PSD signatures.
Specific instructions should be provided i
for attaining the P50 signatures.
7.2.1.1 -
The reacter coolant systes being filled and the copr4111ty of running reactor coolant pumps are required prerequisites to performing the vibration and lease parts monitoring test, therefore, the precedures that accomplish these initial conditions 4
should be referenced.
t i
1.
E. ~
lr 4
l l
7.3.3.1 Paragraph did not icentify tne circuit creaker (power source) for removing 115 Vac power from the VLPM panel.
Startup Administrative Procedure SAP-12, paragraph 7.22, attachment 5.5, requires listing of power sgplies for electrical support systems.
7.3.2 Paragraph did not provide instructions on how to set up and use shaker table, or on how.to remove and reinstall sensors being tested.
Vendor Operation and Maintenance Manual Al-73-1 provides detailed instructions for installing sensors.
Paragraph
)
should provide instructions for using the shakar table and for installing the sensors.
This is an open item (8214-02).
~
6.
Installation of Safety-Related Instruments and Impulse Pipino The 8E inspectors inspected safety-related instrumentation installations.
(See m Inspection tapert 82-10, dated June 15, 1982.) The inspection revealed that mesy instruments and the associated ispulsa piping were not being installed in accordance with the instrument manufacturer's recom-mandstions and/or suggesticas.
The manufacturer's, Rosemount, instruction mensel nasher 4295 for Medal 1153, " Series A Alphaline Pressure Trans-sitters," recommends the following installation practices be'followed in order to ensure proper operation and einimize the possibility of errors:
a.
For 114prid flew or pressure measurements, the transmitter should be asusted beside er below the process connection taps so that gases will vest into the process line.
b.
51epe piping betmeen the process connection and the transmitter at least 1 tach per feet y toward the process connection for liquid and steen.
s.
Aseld hip pelats in liquid lines.
Ihe 9011ewleg testroemt installations are specific examples where the esse ressemondetiens or sugestions have not been followed:
1.
{'.
- 5. ~
- IFE1 F: Moeder B Outlet Flow - This transmitter aseseres nquis new 1s asunted approximately 20 feet higher fi;,.
See the process eennection and has a high point in the instrument POPleg.
r
[~.
h.
PPCS W - Centainment Sorav Moeder 8 - This transmitter which L
asseures Hguis new to asunted approximately 10 feet higher than the possess scenection and has a high point in the instrument piping.
tw b
In each of the three instument insta11ations listed below, the instrument tapelse piping contains a long run that has a high point approximately 12 feet ateve the process connection and the transmitter.
FT-SI-4 NGAS
FT-CS-7122A5 - Contaissent Spray Header A Flow These observations were identified to LP&L construction QA from June 7 temuriJune 10, 1982.
See paragraph 8 of this report for additional infometten em problems associated with instrument installation.
Eheece Services, Inc., (Ebasco) installation instruction IC-1, "Instruc-tien for Erection of Instumentation Systems," Revision 1, and Drawing um 1964 6-430 " Instrument Installation Details," do not distinguish hequeen an testa 11ation for the measurement of liquid as opposed to the measumeset of gas, nor de the sloping requirements avoid air pocket forestions in lastrument lines.
Mitpi points are allowed and minimum required slepe, where slepe is requ red, is k inch per foot from these high poista campared to standard industry practice of 1 inch per foot.
Failure to pnperly install instruments could lead to improper operation j
et asseurtag fastruments.
This is of particular concern where instruments are seed te provide safety system signals or where the instruments' provide tadleottees to be used by plant operators in evaluating safety system pareesters.
Neuever fastrument installation ccatrary to manufacturer's Niees is allemed en a case-by-case basis provided an engineering esehuettee is sempleted te verify that the instruments will respond as estped.
The starte testia0 program should identify whether instrument lastellettees are adeemste.
Its engi evolustions and test program results will tre reviewed e rtag future tems.
(Unresolved Item 8214-03).
7.
Pipseerattana) feet WItaessime hE witnessed the %st of battery chargers 3A81-5 and 394 ef.-
tees) Test Precedure Sp0-02-003.
he NRC inspectors emptfled to leu 4ag ukile witnessing the test:
4 I
4.
A test ses.esedseted in accordance with an approved procedure and Se preestre mes used and signed off by personnel conducting the 2
test et the site.
t b.
The test egeipment uns installed per test procedure instructions.
c.
Oste mes cellected au recorded as required by the test procedure.
d.
The peresanel condmeting the test did so in accordance with the precedure and other ade1nistrative controls.
f
.. _ - - I
,-a,,
_-.,y
.-.w
-,,--.,-w,,
,,w-w-_g.-,,.
.r--,
1m.-
r-w
6 The NRC inspectors observed that the voltaeter and ammeter for Dattery charger 3AR2-$ appeared to be out-of-calibration when compared to parallel instro ents.
A CIE was written for each respective instrumert to have the calibration checked.
The ammeter was later determined to be out-of-calibration.
The less of calibration of the instrument did not affact the valid 1 V of the test.
No violations er deviations were noted.
8.
LPE Ouelity Assurance Preorem - Onsite During this inspection period, the NRC inspectors completed a review cf the overall effectiveness of the LPE quality assurance program on the Waterford 3 site.
This inspection effort was initiated:
(1) as a result of previous MC cenerns regarding the adequacy of the LPE QA coverage for preoperational testing and operations, and (2) as a result of concerns raised by LPE startup engineers regarding the quality of systems and ecorts that were being evaluated by their organization.
LPE ensite @ is broken into two functional organizations, LPE'QA for aperations and LFE @ for construction.
Each of these organizational elements will be treated separately.
a.
LML Quality Assurance for Nuclear Operations LML sperations @ reviews these safety-related activities involved with startap testing and operations to verify compliance with all aspects of the gust,1ty assurance program.
LPR has been slow in establisti this portion of their quality assurance program.
NRC Inspectien 51-13, dated August 28, 1981, pointed out that prior to begi ing prosperational testing LPE had not established a nuclear ions gus11ty assurance greg as required by the FSAR.
It was
's intent to compensate for this lack of permanent oper-ettenal S staff by conducting audits using other available person-met.
la W !aspecties toport 81-23, dated October 14, 1981, it was noted that LPE $ had devloped plans to conduct a wide ranging audit to essensate for a lack of an ensite quality assurance organization for aparettees.
This report questioned whether LPE had the necessary maapeser and experience to successfully complete the audit. NRC
.Iaspection W. 82-03, dated March 18, 1982, documented the review of the above audit and concluded that the audit had covered less than one-half of the activities outlined in the audit checklist, and that the depth of the audit did not appear appropriate when compared to the level of safety-related activities in progress in those areas.
I During December 1981, LPE established Nuclear Operations QA by filling the first two of six permanent positions established in tw r ergenitatien and by bringing in three other auditors from other carts of the ergenization.
?
I
i w
7 The NRC inspec. ors reviewec the first three QA auc ts performec c.,
operations QA.
Number Title Issued 82-01 System Release and Turnover February 18, 1982 82-02 Code System Turnover May 25, 1982 42-04 Procurement Docuwent Control May 29, 1982 and Control of Purchasing Materials and Cervices In addition, the NRC inspector reviewed the general audit schedule for 1982-1983 and the initial response to audit 82-01.
Audits to
- date have identified a wide-range of procedural and technical problems that need to be resolved.
These problems point to inadequate proce-j dural controls that could lead to safety systems not meeting accepted quality standards.
i Typical examples of audit findings include the following:
(1) Vague procedures (2)
Imedequate procedures (3) Failure to follow' procedures (4) Apparent lack of training of unknown la addition, turnover documents reve 18.
system gueli As a example, the f 1982,(82-01 tas Release Turnow.'
to audit quality rt.
esastructica This is an FSAR (Chapter 14, Table 14, 2-3, Itan 6.2) tarsever.
Systems turned over prior to this audit include 125 Voc resettement.
statles betteries, startup transformers, safety-related 480 V/208 Preoperational tests had V/1 N Vac inverters and related busses.
In consider-been eenducted as the ' station batteries and inverters.
in t
.,. - a a& ion of this g
1
'~'
o i,r-N.......,,,.....
4
_.-- 9 gn s
of r.
pm a
system turnover packages (discussed below).
Im general, audits of tP&L startup and operational orgar.izations a-e late in getting started.
LP&L management appears to have recognizec
J i
8 i
I this weekness as evioenced by the growth in tu autnor1:ed QA organi-3ation and an apparent commitment to hire experienced incividuals.
The process of hiring these experienced workers takes a long time.
This shortage of available workers may impact on the overall audit schedule.
As of July 1982, the current approved organization chart for operational QA includes 13 positions.
Eignt of these positions are filled with permanent LP&L employees and tnree additional permanent LP&L employees froh the general office QA organiation have j
heen te p rarily assigned to assist operations QA.
In consideration i
of the nature and number of quality problems identified in the first half of 1982, this failure to conduct audits in a timely manner say, in turn, affect overall project schedule.
b.
LP6L Quality Assurance for Construction The IEC inspectors reviewed the ongoing activities of LP&L con-struction QA.
LPGL asintains a small construction QA staff (four to sia posittens) as a result of heavy reliance on Ebasco construction manager for ensita construction QA.
Ebasco QA, in turn, audits the 5 programs of other ensite contractors.
The Ebasco onsite QA iaatten consisted of approxbnately 10 auditors.
Until recently, construction QA had additional duties, beyond the audit respon-sibilities, that had li'aited their effectiveness.
These duties included tracking and coordinating issuance of construction deficiency reports and respostses to NRC inspection reports.
These responsibil-ities are now being transferred te nuclear project support.
During the course of this inspection, the NRC inspectors reviewed the fo11erlag:
i IJGL Construction OA Audits 82-27
. Annual Daview of Ebasco QA April 14, 1982 l
Auditing Program Centainment Spray System M4y 10, 1982 Audit 9N Iti Pressure Safety May 25, 1982 1
ion-
$4 teu Pressure Safety June 4, 1982 6'.r;s. i In,jection i
i...
M 30 Safety injection Tanks June 4, 1982 1
{
$b l
k, v..
.s
E I,
9 1
i l
Turnover Packages for Systems Date System Submitted i
Number l
l 59 Containment Spray April 30, 1982 i
l 60a High Pressur's Safety June 22, 1982 l
Injection l
600 Low Pressure Safety May 20, 1982 i
Injection 60c Safety Injection Tanks May 22, 1982 In addition, the NRC inspectors reviewed various correspondence between Waterford 3 startup group and Ebasco concerning system turnover.
The NRC inspectors reviewed LP&L's annual audit, of Ebasco. The audit consisted of a review of all 143 audits conducted by Ebasco QA during l
the calendar year 1981.
The audit was co ndividual 6 weeks.
j n
i s
summa i
that measures should be established by Ebasco QA to te, l
detareine the applicable elements of the contractor's QA program ar.d l
ta determine the effectiveness of the implementation of the contrac-ter's 04 program.
Ebasco QA's response to this audit addressed specific f4ndings, but did not address the summary comments.
As indicated above, Ebasce submitt y four ECCS systems to LP&L for turnover en the. dates indicated. # hose turnover packages were audited by LAPL construction QA and were reviewed by the Waterford starte M.
Due to concerns raised by the audity, LP&L construc-tien 04 extended their audit to include actual system walkdown toLP&L allow cooperisen of quality records with the installed systems.
1 earned that, although Ebasco QA had represented the systees as being l
t the quality ree$ for tornover and had ver packages conta tenents and thesco QA indicating that portions of the turnover j
were intag lete and not QA/QC acceptable.
Ebasco Services, Inc.
ASP-IV-50, " Release and Turnover from Construction to Waterford Startup," establishes controls and documentation ~ require-l The procedure requires that contractors monts for system turnover.
provide gus11ty records'; including exceptions, as part of the release i
and turnover packages; and, in addition, requires that Ebasco qua14 ty assurance review these records for completeness, accuracy of centent,
,---,n----,
.,--,---,.._-_n,,n,
l 10 proper form, and traceability.
The above statements contracict the requirements of the turnover procedures.
Since the inaccurata and incomplete records in the turnover packages indicate a breakdown in the controls coverning these activities, this represents a violation of Criterion II of 10 CFR 50, Appendix B, j
requirement that a quality assurance program provide control over ectivities affecting quality.
LPE seseguently rejected all four turnover packages and proceeded to further evaluate the systems status and to identify the signific-i ante of the numerous findings.
As a result of these reviews, on LP&L reported a potential construction deficiency to R g 26, 1982, E related to inadequate instrumentation and control system instal-letten and turnover dociamentation involving startup system 59, Containment Spray Systan.
These concerns were later identified to eles esist in system 60s, High Pressure Safety Injection; 606, Low pvessure Indection; and 60c, Safety Injection Tanks.
On July 8, i
1982. LPGL confirmed in en interim report (SCO 57) that a significant construction duficiency isted and outlined their corrective actions.
w%=1.1 D.h\\.
u bd the IAC system tion had revealed problems such as Audits (1) the "as-huilt" drawings did not accurately reflect field condi-tiens; (2) reverse slope of tubing runs; (3) incorrect seismic seppert designations; (4) dimensional errors; (5) supports not installed; (5) leproper belting; (7) deformed tubing, and (8) tubing tauchia0 tredt er helt heads not allowing for thermal expansion.
Corrective actions regarding this specific situation were as follows:
On June 23, 1982, Mercury Campag of Norwood, Inc., (Mercury) was directed to:
(1) Seessign crofts off safety-rel'ated systems installation and romerk.
Ih etify remerk teams of craft, foremen, field engineers, QA (I) lespectors and sapervision who, upon completion of an immediate retreteleg progree, will proceed with rework required for esemptele construction coupletion, documentation, and. turnover of the getees.-
(3) tevelop a documented retraining program related to correcting the prehless being encountered.
2, (4) Upon approval, implement this program.
(S) iAten this retreining program has been properly executed for the teams, reassign craft to safety-related work.
Is.:
i y
(6) Estend the retraining program to all Mercury personnel.
f.
~
- \\
11 (7) Implement organuational changes.
(8) Reinspect reworr. in progress.
Corrective action applicable to the other safety-related instrumenti-tion systems will be established upon assessment of the results of the above actions for the four systems currently in quettion.
In addition to I&C problems, LP&L also, on July 1.1982, reported a potential construction deficiency (PRD 84) regarding turnover docu-mentation problems related to hanger and weld problems associated with hangers involving Tompkins-Beckwith (T&B).
Early findings on system 60b, Low pressure Safety Injection, involving the inspection of 20 hangers, indicated that 16 of these hangers had quality problems that needed evaluation.
These findings resulted in a commitment by T&B to commence a 1005 inspection 6f installed hangers followed by a 1005 Ebasco re-review.
Of appreminately 338 hangers on system 60b, 50 hangers were found to he acceptable.
About 140 hangers require engineering evaluation heesume of rejectable indicatnons, to determine if the hangers are adegeste as-is.
The typical problems on these hangers were under-stand welds that should have been QC rejected.
Another 166 hangers were not installed in accordance with as-built drawings.
The majority of these hengers were not in their prog)er location or orientation.
It is estimated that less than 105 of the hangers will actually require rework due to the built-in safety margins.
Information on the status of the other three systems was not immediately available but was espected to be similar.
During the NRC inspection conducted April 5-4,1982, the IRC inspectors identified similar hanger problems related to the sentrel of documents and safety related work activities, i
la trying to detamine the root cause of the number of deficiencifes.
l identified daring the turnover process, a number of engineers com-l mested that thq felt that a significant influence say have resulted free gper leoel egnagement's pressure to turn systems over in order l
to proceed with the testing program.
Of those interviewed by the NRC i
I inspectors, as one as willing to say that there was management l
preneure to falsify documents or to do the work incorrectly.
Several perusas said, however, that management decisions to begin review of l
tanceplete postages created a situation where system quality could est be assured due to the workload involved in trying to track actual systen states.
'The E inspectors noted several references in turnover procedures These regarding completing work activities and meeting schedules.'
precedural statements could result in persons being in violation of i
the precedure as a result of circumstances beyond their control.
- -, - ~, -
--,a-n----
,,-r---,--
-c,--
u i
l 1
LP&L's Vice Presioent for Nuclear Operations, when cuestionec about whether pressure had been applied to force system turnover, statec that pressure was evident and expected, but that no one shoule imply that such pressure was intended to cause people to take shortcuts where safety was concerned.
He went on to comment that there was no Centrac-economic incentive not to do the job right the first time.
tors were paid to complete their work in whatever time it takes.
Wnen tne work was cone, it should be right.
The NRC inspectors concluded that individuals directly involved in the review and turnover process may have been responding to schedule This was evident from the amount of incomplete information pressure.
included in the turnover packages.
Discussions with LP&L management indicate that there was no intent that systes quality suffer as a result of system turnover.
It did not appear that deficiencies found j
j at the craft level were a result of schedule pressure.
Conc 1'usions c.
The recent chain o' cvents, beginning in January 1982; have led to an austeness en the part of LP&L that the expected level of quality has not been built into certain systass of the Waterford 3 plant.
LPEL has taken prompt and extensive actions to identify and correct the The LP&L construction QA problems before accepting system turnover.
organization has grown from approximately five positions in January itions, with tarse additional personnel brought in to to seven assist.
QA has grown from 10 to 17, and, in addition, another N records, reviewers have been brought onboard.
Ebasco's chief QA i
engineer fram their New York corporata office is onsite to assist, as i
necessary, turrent plans are for Ebesco to formalize a program to.
audit the effectivness of contractor QA/QC programs.
LP&L's new site directar plans to ensure that the testing program adequately evalu-l stes installed lastrumentation.
In addition, recent letters clarify--
tag terseeer requirements are currently being implemented.
i Corrective actions to avoid recurrence of the above problems will be reviamed during future inspections.
9.
LNL tuolity Centrol - Oserstions en May 17, last, the NRC inspectors began a review of the LP&L quality control program.
The Lp6L quality control organization reports to the plant manager and is responsible for identifying quality problems with the Wetarford 3 organization.
LP&L QC consists of two supervisors, six permement LP&L employees and nine contract employees.
The QC organization conducts a day-by-day review of startup and operational activities, Discussions were heldyith several QC inspectors and their supervisors.
i l
The QC inspectors commented that they felt free to identify any issue I
adoerse to quality and that they had no problems with the workers on the Waterford 3 site.
Ne one recalled any serious instance of att-oted L
b 13 intimidation while performing their QC activit'ies.
Several OC inspectors commented that it takes mu;;h too long for their findings to be evaluated They were concerned that after identification of what and acted upon.
appeared to be a generic deficiency, work frequently continued for some time before corrective action was initiated.
LPE QC has stop-work autority that can be used if appropriate.
The NRC inspectors reviewed all QC surveillance reports form #40-81, cated May 27, 1981 to #99-82, dated May 7, 1982.
Overall it appeared that the LPE QC organization was in piece and functioning as expected.
Many responses to QC findings were overdue.
However, the lead QC engineer was escaleties the level of visibility of their findings to higher levels of assagesent encoureging more prompt resolution.
The NRC inspector noted that asse roepenses to the QC findings were vague and somewhat unprofes-stenal. This was discussed with LPE management.
We violations er. deviations were identified.
38.
Unroselved/Open Items Weresolved items are matters shout which more information is required in ester to ascertain dether they are acceptable items, violations, or egetatlees.
An enresolved item related to instrument installations
~
(Weresolved Item 8D4-03) is discussed in paragraph 6.
Den items are specific items that will be reviewed during a subsequent legeetles, spen items identified and the paragraph of this report in 1
sh4th they are discussed are:
Parecrash M
l Equipment tracking (884-01) 3 Gements en
.retional test preendere 9>001(SD4-02) 5 i
- u. ' Enfilstanties The W leepectors met with the licensee representatives (denoted in
~
The l
paragrgh 1) at verious times during the course of the inspection.
scope and findings of the inspection were discussed.
t I
'o 0m% & 'h DISTRfBUTION Central File /
e F P r 4 w.:,,
TERA QAB Chron File QAB Projects WVJohnston Rdg. File JG11 ray EMORAN!UM FOR: Richard H. M11aer. Director Division of Engineering THRU:
William V. Johnston, Assistant Director Materials & Qealifications Engineering Division of Engineering FROM:
Walter P. Names, mief. Quality Assurance Branch Division of Engineering SWJECT:
EVIEW 0F T. MAIFS1ER'S IGWRANENM ON EGIGl IV's DRAFT ENFONEIGIT ACTIM Gl WA1ElFORD #3 T. Navyster's memoranden of August 31,1982 to J.L. Lieberman (enclosed) discussed' comments en Negion IV draft enforcement action on Waterford #3 Report No. 50.-38t/82-14 (also enciesed). QAB has reviamed these documents and has the following comments in response to your handwritten note:
A.
T. Harpster's memorandum of August 31,1982.
1.
The intredaction gives a tapression that LPE's and contractor's QA program deMciencies were detected by NK inspectors. when in fact, all deMetencies were ident1Med by LPE prior to NRC inspection.
Itiss ted that LPE's rene in detecting and correcting the deMet es he clartfled.
2.
T. Navpster's succ1mmedstian (comment #1) that the Notice of Violation he elevated from IV to a !!! appears inaporepriata since LPE had discovered these deficiacies ad was in the process of correcting them prior to NRC inspecties. It is suggested that ths recommendation be deleted.
3.
Comment #2 suggests a lad of Lptt QA staffing in the auditing area.
This may be true; however, without a sufficient understanding of the capabilities and qualifications of the QA auditing organization and the contract responsibilities and arrangements between LPE and Ebasco (construction manager) it is difficult and unwise to judge the accept-ability of the staffing sine.
4.
Caumont #3 makes a piedicties that if LPE management does not establish a strong quality policy in balance with system turnover schedule, then Waterford #3 might be espected to have quality problems similar to other treeled facilities. This comment is too subjective in nature. It is suggested that this comment be expanded with clear suggestions as to what would constitute a strong LPE quality policy.
Mc9290280 e20934 Fo/A-Wm ADOCM 05000382 YN XF I
,di..
MYJohnk.,.E.
AD: M..&..Q..E : (
,nco y
g "% FOIWp
'VAMAn
- Eltay.:an..
aass...
ton..
' 9/.l.l82
,9/j/,82,,,-,,9], pf,gg,,
~ %
a nrriciitaccano_capv
SEP 141902
~
Richard H. Vollmer B.
Region IV draft enforcement paper No. 50-382/82-14.
1.
It would seem appropriate to identify and emphastre a concern regarding LPR's experiences with respect to the quality of other documentation and harhare that has been pvwviously turned over to LPR for the testing program, or is in process of being turned over to LPE.
It ts suggested that LPE be requested to sumerize their experience in this regard.
Origigniaired by weher.m Maa*..
Walter P. Naass. Oiief Quality Assurance Branch j
Division of Engineering 1
1 l
Enclosures:
1.
T. Harpster Namorendum of 8/31/82 2.
Waterford #3 Report No. 50-382/82-14 2
. - r>
I DeIf )
OFFICIAL RECORD COPY EE eac eoau sie o..,,
acu e<=>
[W.,
',,g UNITED STATES NUCLEAR REGULATORY COMMISSION 2
e I
was.mearoes. o c. 2om y ' %<
,e
=...+
J ',
AUG 311982
[-)
'T MEMORAfiDLM FOR:
J. Lieberman. Director., Enforcement Staff. IE FROM:
T. L. Harpster Chief Quality Assurance Branch, Division of Engineering & Quality Assurance. IE
SUBJECT:
REVIEW OF DRAFT ENFORCEMENT ACTION WATERFORD #3 REPORT NO. 50-382/82-14 At your request, draft inspection report 50-382/82-14 (en:losed) was reviewed to assess the significance of the inspection findings at the Waterford #3 facility and the effectiveness of the Louisiana Power & Light (LP&L) quality assurance program.
The inspection report identifies areas where the implementation of the LP&L and contractor QA/QC program has not been effective:
specifically. (1) the quality control inspection of hanger supports and welding installed by the contractor, Tompkins&Beckwith(page11)and(2)ESASCOqualityassuranceauditsofthe systemturnoverpackages(page10). These items have been identified as a I
severity Level IV violation of 10 CFR 50. Appendix 8. Criteria II. The report also states that f.p6L has in the past esployed a minimal construction QA staff (on the order of 4 to 6) which results in an overreliance on EBASCO as construction manager (page B). EBASCO's on-site QA organization has only consisted of approximately 10 auditors. A potential root cause (page 11) has been identified as the LPSL upper management pressure to turn systems over in order to begin the testing program. This has created a situation where system quality apparently could not be assured due to the workload involved in trying to track actual system status.
[ased on our review, the following comments are offered:
1.
These findings are significant quality assurance program implementation deficiencies and should be elevated to a higher severity level (level III). The basis for this is that the deficiencies had not been identified and corrected by more than one QA/QC checkpoint relied upon to identify violations, e.g.
the contractors (T&B) QC inspection, contractors (T&B)
OA program. EBASCO QA audits. and LFAL QA overview. The licensee has been
'n noncospliance with Criterion II (QA program), Criterion X (Inspections),
. riterion XV (Nonconforming components). Criterion XVII (QA records) and
'.riterion XVIII (Audits).
CONTACT:
E. J. Gallagher. IE F
49-24 % 8
_,,_ _ _ _ _ _ J g
a m 8 xm oo y a
J. Lieberman AUG 311982 2.
There appears to have been less than total cosmitment to quality by LP&L management since minimal LP&L QA resources have been dedicated to the project (i.e., licensee staff of 4 to 6). Similarly, the construction manager has had a minimal QA staff of approximately 10.
I do not believe that Lp6L has comadted sufficient resources to audit and control the construction manager and subcontractor organizations.
Recent experience has shown that sites with minimal licensee quality assurance resources such as Marble Hill. Midland and Zismer have experienced significant breakdowns in quality assurance during construction.
3.
The potential root cause identified may have generic implications to the Waterford project. Management appears to have put emphasis on meeting system turnover schedules without the appropriate balance of the quality of the system prior to turnover.
If LP&L management does not establish a strong quality polic;y in balance with the system turnover schedule then Waterford #3 sight be expected to have quality problems similar to other facilities that have had QA program breakdowns late in the project.
The NRC construction status report lists Waterford #3 as 945 couplete. A review of the inspection effort at Waterford #3 indicates approximately 800 men-hours of inspection in all inspection areas this year as of August. This number appears low considering the level of continuing construction, system turnover and preoperational testing. Waterford #3 appears to be an ideal candidate for a construction team (CAT) inspection.
l(,,d-Qg(ca Terry L. Harpst
. Chief Quality Assurar Branch Division of Eng neering and
. Quality Assurance Office of Inspection and Enforcement
Enclosure:
l Draft Inspection Report 50-382/82-14 J. Tay' lor. IE cc:
J. Henderson. IE R. Vollmer. NRR j
- 5. Black. NRR G. Madsen. RIV QUAB:!E
es
- 51 t.5 3.,-
NUCLEAR REGULATORY COMMISSION
[
{ Wl J I
5 crosos av
-[/
y' sii nyas ns.n naivt suirt icoo t
Doctet:
50-382/82-14 DRM-,,
Louisiana Power and Light Company ATTN:
L. V. Maurin, Vice President Nuclear Operations 142 Delaronde Street New Orleans, Louisiana 70174 Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program by Messrs. G. L. Constable and J. E. Cummins of our staff during the period May 16 to July 15, 1982, of activities authorized by NRC Construction Permit CPPR-103 for the Waterford Steam Electric Statioh, Unit 3, and to the discussion of our findings with Messrs. D. B. Lester, G. Rogers, and other members of your staff at the conclusion of the inspection.
Reference is also made to the enforcement conference held in your corporate offices on August 20, 1982.
Principal areas examined during the inspection and our fihdings are documented in the enclosed inspection report.
Within these areas, the inspection consisted of selective examination of procedures, drawings, representative records, interviews with personnel, and observations by the NRC inspectors.
During this inspection, it was found that certain of your activities were in violation of NRC requirements.
Consequently, you are required to respond to this violation, in writing..in accordance with the provisions of Section 2.20.1 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.
The enclosed Notice of Violation involving a failure to establish suitable controls over activities the quality of safety systems, is classified as a Severity iolation.
This classification was made after careful considerat safety significance in this specific instance and was based on your prompt identification of the problem to NRC and on your prompt reaction to LP&L QA findings that resulted in extensive corrective action to avoid future violations.
One new unresolved item is identified in paragraph 6 of the enclosed report.
accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures 1 be placed in the NRC Public Document Room unless you notify this office,
.eicphone, within 10 days of the date of this letter, and submit writter,
,lication to withhold information contained therein within 30 days of the cate of this letter.
Such application must be consistent with the requirements of 2.790(b)(1).
k
--.-,-,-w,.
-.---9.
e.e.-,
w--,---
,,-,---,..,--,-,.,,,-,,,----,,,----------+-----w-w,-
--w.-w---
uNiTto iI Atu f,
/
,.****'4..,
NUCLEAR REGULATORY COMMISSION p
e a
[ [C/
CEcloN tv 811 PYAN PLAZA DetlVE SulTE ior
,8 ARLINGTON. T[x At Moti
\\
Docket:
50-382/82-14 BRU4 t Louisiana Power and Light Company ATTN:
L. V. Maurin, Vice President Nuclear Operations 142 Delaronde Street New Orleans, Louisiana 70174 Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program by Messrs. G. L. Constable and J. E. Cummins of our staff during the period May 16 to July 15, 1982, of activities authorized by NRC Construction Permit CPPR-103 for the Waterford Steam Electric Statioh, Unit 3, and to the discussion of our findings with Messrs. D. B. Lester, G. Rogers, and other members of your staff at the conclusion of the inspection.
Reference is also made to the enforcement conference held in your corporate offices on August 20, 1982.
Principal areas examined during the inspection and our fihdings are documented in the enclosed inspection report.
Within these areas, the inspection consisted of selective examination of procedures, drawings, representative records, interviews with personnel, and observations by the NRC inspectors..
During this inspection, it was found that certain of your activities were in violation of NRC mquirements.
Consequently, you are required to respond to this violation, in writing..in accordance with the provisions of Section 2.201 of the mtC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.
The enclosed Notice of Violation involving a failure to esthblish suitable controls over activities the quality of safety systems, is classified as a Severity iolation.
This classification was made after careful considerat safety significance in this specific instance and was based on your prompt identification of the problem to NRC and on your prompt reaction to LP E QA findings that resulted in extensive corrective action to avoid future violations.
One new unresolved item is, identified in paragraph 6 of the enclosed report.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, f
by telephone, within 10 days of the date of this letter, and submit written l
application to withhold information contained therein within 30 days of the date of this letter.
Such application must be consistent with the requirements of 2.790(b)(1).
I
5 Lcuisiana Power and Light 2
Company The response directed by this letter and the accompanying Notice is not subject to the clearance proceoures of the Office of Management and Budget as required by the Paperwork Reduction Action 'of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, G. L. Nadsen, Chief Reactor Project Branch 1
Enclosures:
1.
Appendix A - Notice of Violation 2..
Appendix B - NRC Inspection Report 50-382/82-14 cc w/encis:
Louisiana Power and Light Company ATTN:
F. J. Drummond, Project Support Manager 142 Delaronde Street New Orleans, Louisiana 70174 Louisiana Power and Light Company AU N:
T. F. Gerrets, QA Manager
(<ane address)
Louisiana Power and Light Company ATTN:
D. B. Lester, Plant Manager P. O. Box 8 Killona, Louisiana 70066~
e e
6 9
p e.
je V
E ADPENDIX A NOTICE OF VIOLATION Docket:
50-382/82-14 Lcuisiana Power and Light Company Waterford SES, Unit 3 Permit:
CPPR-103 Based on the results of an NRC inspection conducted during the period of May 16 to July 15, 1982, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated, March 9, 1982, the following violation was ioentified:
10 CFR 50 Appendix B, Criterion II, requires that, "The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and components to an extent consistent with their importance to safety.
Activities affecting quality shall be ac:ceplished under suitably controlled conditions."
'l Ebasco Services Inc., Procedure ASP-IV-50, " Release and Turnover from Construction to Waterford Startup," establishes controls and documentation requirements for' system turnover.
The procedure requires that contractors provide quality records, including exceptions, as part of the release and turnover packages; and, in addition, requires that Ekasco quality assurance review these records for completeness, accuracy of content, proper form, and traceability.
Contrary to the above, on April 30, May 20, May 22, and June 22, 1982, -
Ebasco QA signed four ASP-IV-50-6 forms indicating that the pertinent i
fabrication and installation. records for four startup systaas were ready for turnover to LPE.
These startg systems were containment spray, low tion lists did not accurately identify.
f
,T)ese LPE findings included previously unidentified installationj rrors, as-built drawings that did not match actual field instal]ation, field installations which included work that was not in compliance with pro-ceduresandspecifications,*%Cinspectionsthathadnotidentified
- unacceptable field installations, and1)C records that were not consistent a
with current as-built drawings, t
Taken together, these. findings represent a failure to adequat.ely control the quality of safety-related work at the contractor level and a failure by Ebasco Servic::, Inc., as construction manager, to adequately control the quality of safety systems and their records.
This is a Severity Level IV Violation.
(supplement (11.0)
I d
Louisiana Power and Light 2
Company
- Pursuant to the provisions of 10 CF L 2.201,- Louisiana Power and Light Co rar.c is hereby required to suomit to this office, within 30 days of the cate ct
- s Notice, a written statement or explanation in reply, including
(1) the corrective steps which have Dean taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be gi.an to extending pur response time for good cause shown.
Dated:
e 9
e i
9 l
\\
I
\\
4
~,, _,,.
,----n-
. - ~ -. - - -, - - - - - - - - - - -
APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV Report: 50-382/82-14 I
l Docket: 50-382 Permit:
CPPR-103 Licensee:
Louisiars, Power and Light Company 142 Delaronde Street
~
New Orleans, Louisiana 70174 Facility Name:
Waterford Steam Electric Station, Unit 3 Inspection At:
Taft, Louisiana Inspection Conducted:
May 15 to July 15, 1982 t
Inspectors:
E. L. Constable, senior Resioent Inspector Date J. E. Cummins, Resident Inspector Date
)
';sisting Personnel:
W. B. Jones Engineering Assistant Date A: proved:
W. A. Crossaan Chief Date Reactor Project Section B l
u.e: tion Summary Inspection Conducted May 16 to July 15. 1982 (Report:
50-382/82-14)
Areas Inspected:
Routine, unannounced inspection of:
(1) Site Tour; (2) i Witnessing Ultimate Heat Sink Test; (3) Preoperational Test Procedure Review; (4) Installation of Instruments and Tubing; (5) Preoperational Test Witnessing; (6) Quality Assurance Program; (7) Operation Quality Control Program.
The inspection involved 260 inspector-hours by three NRC inspectors.
Results:
In seven of the eight areas inspected, no violations or deviations were toentified.
One violation, failure to adequately control the quality t' 1
safety-related work, was identified in one area (paragraph 8b).
._...-_C_____._,__,_______..
...n 2
2 Details 1.
Persons Contacted 4
.l
'T. F. Gerrets, QA Manager
."D. 8. Lester, Plant Manager "W. M. Morgan, QA Engineer "J. Woods, QC Engineer "G. Rogers, Site Director "L. L. Bass, QA Engineer "W. Cross, Site Licensing
- F. Drummond, Project Support Manager J. Bradley, Startup E inser J. Rasbury, Startup inser "Present at exit interviews.
In addition to the above personnel, the inspectors held discussions with various operations, construction, engineering, technical support, and administrative members of licensee's staff.
2.
Plant Status The Waterford 3 site is in.the early phase of system turnover for preoper-ational testing.. The current published fuel load data is January 1983, with construction indicated'as approximately 945 complete.
Although construction activity is still in progress, this percentage has not.
changed since January.
A new goal for fuel leading is expected to be announced in the near future.
A site manager, George Rogers, was added to the onsite Louisiana Power and Light (LP&L) staff.in May.
Mr. Rogers has responsibility for construc-tion, engineering, and startup.
3.
Site Tour At various times during the course of the inspection period,.the NRC inspectors conducted general tours of the auxiliary building, fuel handl-ing building, reactor building, and the turbine building to observe ongoing construction,and test'ng.
j the NRC inspectors noted that dry cooling tower fan On May 21, 1982, motor 1-58 had been removed from its pemanent plant location; however, an etsipment tracking / condition 10 tag had not been hung on the location where the component was installed as required by Startup Administrative This Procedure SAP-08, " Condition Identification and Corrective Action."
condition was discussed with the system startup engineer and a tr.g was hung.
The corrective act kn was adequate for this specific occurrence.
I The NRC inspectors have frequently noticed that instruments and equipment
--- wwww-v.-ww-,-,w..*-y-., -,- - -,- - - -,.
wwy, w -.
y---m--.r.
3 f
have been removed without apparent controls *being established.
Im;;lemen-tation of equipment tracking procedures is an open item (8214-01) and wiii be reviewed during a subsequent inspection.
No violations or devations were identified.
4.
Ultimate Heat Sink Test Witnessing The NRC inspectors witnessed portions of the performance of Prerequisite-Preservice Test SFG-36-004, " Wet and Dry Cooling Tower Fans Performance Evaluation." This test is a part of the evaluation being done to deter-sine if the wet and dry cooling towers can perform their design functions for different operating conditions.
No violations or deviations were identified.
5.
Preoperational Test Procedure Review The NRC inspectors reviewed Preoperational Test Procedure SP0-69-001,
" Vibration and Loose Parts Monitoring." The procedure was reviewed for j
technical adequacy, compliance with regulatory requirements, and coupli-ance with licensee commitments and administrative controls.. The following comments were discussed with the system startup engineer.
i SPD-69-001 Paraoraph No.
C4mment 2.5.2 Referenced procedure was OP-VLP-100, " Vibration and Loose Parts Monitoring Operating Procedure," but the operating procedure for vibration and loose parts monitoring is 0P-04-017.
Referenced procedure l
number needs to be changed.
l 7.3.4.1 This paragraph requires that power spectral density (P50) signatures be taken for each of the reactor coolant pumps in accordance with the vibration and loose parts monitoring operating procedure.
Vibra-tion and loose parts monitoring operati' g procedure did n
not contain instructions for performing the PSD i
signatures.
Specific instructions should be provided for obtaining the PSD signatures.
7.2.1.1 The reactor coolant system being filled and the capability of running reactor coolant pumps art required prerequisites to performing the vibration and loose parts monitoring test, therefore, the procedures that accomplish these initial conditions should be referenced.
l
f e
7.3.3.1 Daragraph did not identify the circuit creaker (power source) for removing 125 Vac power from the VLPM panel.
Startup Administrative Procedure SAP-12, paragraph 7.22, attachment 5.5, requires listing of power supplies for electrical support systems.
7.3.2 Paragraph did not provide instructions on how to set up and use shaker table, or on how.to remove and reinstall sensors being tested.
Vendor Operation and Maintenance Manual Al-73-1 provides detailed instructions for installing sensors.
Paragraph should provide instructions for using the shaker table and for installing the sensors.
This is an open ites (8214-02).
6.
Installation of Safety-Related Instruments and Impulse Pipino The NRC inspectors inspected safety-related instrumentation installations.
(See NRC Inspection Report 82-10, dated June 15, 1982.) The inspection revealed that mary instruments and the associated impulse piping were not oeing installed in accordance with the instrument manufacturer's recom-mendations and/or suggestions.
The manufacturer's, Rosemount, instruction manual number 4295 for Model 1153, " Series A Alphaline Pressure Trans-mitters," recommends the following installation practices be' followed in order to ensure proper operation and minimize the possibility of errors:
a.
For liquid flow or pressure measurements, the transmitter should be mounted beside or below the process connection taps so that gases will vent into t.he process line.
b.
Slope piping between the process connection and the transmitter at 1 east 1 inch per foot up toward the process connection for liquid and l
steam.
c.
Avoid high peints in liquid lines.
The following instrument installations are specific examples where the above recommendations or suggestions have not been followed:
a.
FT-SI-039085 - HPSI Pumps Header B Outlet Flow - This transmitter which measures liquid flow is mounted approximately 20 feet higher than the process connection and has a high point in the instrument piping.
b.
FT-CS-712285 - Containment Spray Header 8 - This transmitter which measures liquid flow is mounted approximately 10 feet higher than the process connection and has a high point in the instrument piping.
g----
g
-,--,._,.,_,,---,-,,w--,,.
e e.-.--w-m--,_..-_--__,.y-,.
,.w-,.-
-ii
5 In each of the three instument installations listed below, tne instrument impulse piping contains a long run that has a high point approxi.e.ately 12 feet above the process connection and the transmitter.
FT-SI-0390AS - HPSI - Pumps header A Outlet Flow FT-CC-7570A25 - Containment Fan Cooler (3A-SA-CCW Outlet Flow)
FT-CS-7122AS - Containment Spray Header A Flow These observations were identified to LP&L construction QA from June 7 through June 10, 1982.
See paragraph 8 of this report for additional information on problems associated with instrument installation.
Ebasco Services, Inc., (Ebasco) installation instruction IC-1, "Instruc-tion for Erection of Instueentation Systems," Revision 1, and Drawing LDU 1564 6-430. " Instrument Installation Details," do not distinguish between an installation for the measurement of liquid as opposed to the measurement of gas, nor do the sloping requirements avoid air pocket formations in instrument lines.
High points are allowed and minimum required slope, where slope is required, is k inch per foot from these high points compared to standard industry practjce of 1 inch per foot.
Failure to properly install instruments could lead to improper operation of measuring instruments.
This is of particular concern where instruments are used to provide safety system signals or where the instruments' provide indications to be used by plant operators in evaluating safety system parameters.
However, instrument installation contrary to manufacturer's recommendations is allowed on a case-by-case basis provided an engineering evaluation is completed to verify that the instruments will respond as designed.
The startup testing program should identify whether instrtwent installations are adequate.
The engineering evaluations and test program results will be reviewed during future inspections.
(Unresolved Item 8214-03).
7.
Preoperational Test Witnessino The NRC inspectors witnessed the test of battery chargers 3AB1-5 and 3AB2-5 of Prooperational Test Procedure SPD-02-003.
The NRC inspectors 1
verified the following while witnessing the test:
a.
The test was, conducted in accordance with an approved procedure and the procedure was used and. signed off by pe:sonnel conducting the test at the site.
'b.
The test equipment was installed per test procedure instructions.
c.
Date was collected and recorded as required by the test procedure.
l
=
d.
The personnel conducting the test did so in accordance with the procedure and other administrative controls.
=!
[
1
l 6
The NRC inspectors observed that the voltmeter and ammeter for battery charger 3AB2-5 appeared to be out-of-calibration when compared to parallel instruments.
A CIWA was written for each respective instrument to have the calibration checked.
The ammeter was later determined to be out-of-calibration.
The loss of calibration of the instrument did not affect the validity of the tast.
' No violations or deviations were noted.
8.
LPE Ouality Assurance Prooran - Onsite During this inspection period, the NRC inspectors completed a review of the overall effectiveness of the LPE quality assurance program on the Waterfort' 3 site.
This inspection effort was initiated:
(1) as a result of previous MC conerns regarding the adequacy of the LPE QA coverage for preoperational testing and operations, and (2) as a result of concerns raised by LPE startup engineers regarding the quality of systems and records that were being evaluated by their organization.
LPE onsite S is broken into two functional organizations, LPE QA for aparations and LPE S for construction.
Each of these organizational elements will be treated separately.
[
a.
LPE Ouality Assurance for Nuclear 5 rations LPE operations S reviews those safety-related activities involved with startap testing and operations to verify compliance with all aspects of the qual'ty assurance program.
LPE has been slow in establishing this portion of their quality assurance program.
NRC Inspection Report 81-19, dated August 28, 1981, pointed out that prior to beginning preoperational testing, LPE had not established a nuclear operations quality assurance group as required by the FSAR.
It was LPE's intent to compensate for this lack of permanent oper-ational S staff by conducting audits using other available person-nel.
In NRC Inspection Report 81-23, dated October 14, 1981, it was noted that LPE QA had devloped plans to conduct a wide ranging audit to i
campensate for a lack of an onsite quality assurance organization for operations.
This report questioned whether LPE had the necessary manpower and esperience to successfully complete the aud.it. NRC
,1nspection Report 82-03, dated March 18, 1982, documented the review i
of the above audit and concluded that the audit had covered less than i
ene-half of the activities outlined in the audit checklist, and that the depth of the audit did not appear appropriate when compared to the level of safety-related activities in progress in those areas.
)
During December 1981, LPE established Nuclear Operations QA by filling the first two of six permanent positions established in their organization and by bringing in three other auditors from other parts i
of the organization.
[1 7
The NRC inspectors reviewec the first three QA aucits performec by operations QA.
Number Title Issued 82-01 System Release and Turnover February 18, 1982 82-02 Code System Turnover May 25, 1982 82-04 Procurement Doc.unent Control May 29, 1982 and Control of Purchasing Materials and Services In addition, the NRC inspector reviewed the general audit schedule i
for 1982-1983 and the initial response to audit 82-01.
Audits to date have identified a wide-range of procedural and technical problems that need to be resolved.
These problems point to inadequate proce-L dural controls that could lead to safety systems not meeting accepted j
quality standards.
Typical examples of audit findings include the following:
i (1) Vague procedures (2)
Inadequate procedures (3)
Failure to follow' procedures (4) Apparent lack of training In addition, turnover documents reveal na of unknown l
system quality.
As a example, the fi 1982,(82-01 System Release Turnover) 4 j
construction QA to audit quality rela 2-3, Item 6.2)
This is an FSAR (Chapter 14, Table 14, idit include 125 Vdc turnover.
i Systems turned over prior to this at requirement.
station batteries, startup transformers, safety-related 480 V/208 i
V/120 Vac inverters and related busses.
Preoperational tests had been conducted on the' station batteries and inverters.
In consider-ation of this f....
e din.s in the i
~:-.
-y gang
.- - -mv.m,,,
7
. r - =...........
l
~~. 'q,
a., w nss se A s
i
. PeCt resu o
u.
of system turnover packages (discussed below).
1 In general, audits of tP&L startup and operational organizations ce late in getting started.
LP&L management appears to have recoor.ue-1 Ia r
,.-,=-w
--w,-
we,---.ra.~~w---
- - + - - -. - - - - - - -, - -,,, - -, - - -
- - - - - - - =
S I
this weakness as evioenced by the growth in tne autnorized QA organi-zation and an apparent commitment to hire experienced individuals.
The process of hiring these experienced workers takes a long time.
This shortage of available workers may impact on the overall audit schedule.
As of July 1982, the current approved organization chart for operational QA includes 13 positions.
Eight of these positions are filled with permanent LP&L employees and tnree additional permanent LP&L employees froh the general office QA organiation have been temporarily assigned to assist operations QA.
In consideration of the nature and number of quality problems identified in the first half of 1982, this failure to conduct audits in a timely manner say, in turn, affect overall project schedule.
b.
LP&L Sality Assurance for Construction The NRC inspectors reviewed the ongoing activities of LP&L con-LP&L maintains a small construction QA staff (four to struction S.
six positions) as a result of heavy reliance on Ebasco construction Ebasco QA, in turn, audits the manager for onsite construction QA.
The Ebasco onsite QA QA programs of other onsite contractors.
Until recently, organization consisted of approximately 10 auditors.
LP&L construction QA had additional duties, beyond the audit respon-These duties sibilities, that had li'aited their effectiveness.
included tracking and coordinating issuance of construction deficiency These responsibil-reports and respostses to NRC inspection reports.
ities are now being transferred to nuclear project support.
During the course of this inspection, the NRC inspectors reviewed the following:
LP&L Construction OA Audits 82-27
. Annual Review of Ebasco QA April 14, 1982 Auditing Program Containment Sprey Systen Miy 10, 1982 Audit 82-38 High Pressure Safety May 25, 1982 Injection 82-40 Lnw Pressure Safety June 4, 1982
\\
Injection 82-39 Safety Injection Tanks June 4, 1982
-=
1 4
'E k
al Turnover PacLaoes for Systems System Date y
Number Submitted 59 Containment Spray April"30, 1952 60a High Pressur's Safety June 22, 1982 2
Injection
=
5 60b Low Pres.sure Safety May 20, 1982 j
Injection 60c Safety Injection Tanks May 22, 1982 In addition, the NRC inspectors reviewed various correspondence 3
between Waterfoni 3 startup group and Ebasco concerning system 5
turnover.
1 p
The NRC inspectors reviewed LP&L's annual audit,of Ebasco. The audit
-4 consisted of a review of all 143 audits conducted by Ebasco QA during the calendar year 1981.
The audit was co ndividual weeks.
s summary s
L te, but that measures should be established by Ebasco QA to detemine the applicable elements of the contractor's QA program and to determine the effectiveness of the implementation of the contrac-tor's QA program.
Ebasco QA's response.to.this audit addressed E
specific findings, but did not address the summary comments.
j As indicated above, Ebasco submit four ECCS systems to LP&L for turnover on the dates indicated.
hese turnover packages were audited by L&PL construction QA and were reviewed by the Waterford startup group.
Due to concerns raised by the audits, LP&L construc-tion QA extended their audit to include actual system walkdown to allow comparison of quality records with the installed systems.
LP&L learned that, although Ebasco QA had represented the systems as being ready for turnover and had t the quality i
d M
na urnover packages conta ned s stements 2
by contractors and Ebasco QA indicating that portions of the turnover
- packages were incomplete and not QA/QC acceptable.
Ebasco Services, E
Inc. Procedure ASP-IV-50, " Release and Turnover from Construction to Waterford Startup," establishes controls and documentation require-3 ments for system turnover.
The procedure requires that contractors i
provide quality recordr; including exceptions, as part of the release i
and turnover packages; and, in addition, requires that Ebasco cuality i
assurance review these records for completeness, accuracy of content, i
_a
10 1
i proper forre, anc traceability.
The above statements contradict the requirements of the turnover procedures.
Since the inaccurate and incomplete records in the turnover packages indicate a breakdown in the controls governing these activities, this represents a violation of Criterion II of 10 CFR 50, Appendix B, requirement that a quality assurani:e program provide control over activities affecting quality.
LP&L subsequently rejected all four turnover packages and proceeded ta further evaluate the systems status and to identify the signific-ance of the numerous findings.
As a result of these reviews, on May 26, 1982, Lp&L reported a potential construction deficiency to IRC misted to inadequate instrumentation and control system instal-lation and turnover documentation involving startup system 59, Containment Spray Systam.
These concerns were later identified to also exist in system 60a. High Pressure Safety Injection; 60b, Low Pmssure Injection; and 60c, safety Injection Tanks.
On July 8, 1982, LP&L ::enfirmed in an interim report (SCD 57) that a significant construction duficiency isted and outlined their corrective actions.
.,%m't.1. 3 E. %
u t u4 Audits the IAC s tion had revealed problems such as (1) the "as-built" ystem drawings did not accurately reflect field condi-tiens; (2) reverse slepe of tubing runs; (3) incorrect seismic support designations; (4) dimensional errors; (5) supports not installed; (5) faproper belting; (7) deformed tubing, and (8) tubing touching tradk er bolt heads not allowing for thermal expansion.
Cormetive actions regarding this specific situation were as follows:
On June 23, 1982, Mercury Caspary of Norwood Inc., (Mercury) was directed to:
(1) Rorssign crafts off safety-rel'a'ted systems installation and rework.
(2) Identify rework teams of craft, foremen, field engineers, QA inspectors and supervision who, upon coupletion of an immediate retraining program, will proceed with rework required for acceptable construction completion, documentation, and turnover of the systems.
'(3) Develop a documented retraining program related to correcting the problems being ancountered.
(4) Upon approval, implement this program.
l (5) When this retraining program has been properly executed for the teams, reassign craft to safety-related work.
(6) Extend the retraining program to all Mercury personnel.
- L------ -.-
11 (7)
Implement organuational changes.
(8) Reinspect rewort in progress.
Corrective action applicable to the other safety-related instrumenta-tion systems will be established upon assessment of the results of the above actions for the fo.ur systems currently in question.
In addition to I&C problems, LP&L also, on July 1, 1982, reported a potential construction deficiency (PRD 84) regarding turnover docu-mentation problems related to hanger and weld problems associated with hangers involving Tompkins-Beckwith (T&B).
Early findings on system 606, Low Pressure Safety Injection, involving the inspection of 20 hangers, indicated that 16 of these hangers had quality prob' ens that needed evaluation.
These findings resulted in a commitment by T&B to commence a 100%
inspection 6f installed hangers followed by a 100% Ebasco re-review.
Of approximately 338 hangers on system 60b, 50 hangers were found to be acceptable.
About 140 hangers. require engineeri.ng evaluation because of rejectable indications, to determine if the hangers are adequate as-is.
The typical problems on these hangers were under-sized welds that should have been QC rejected.
Another 166 hangers were not installed in accordance with as-built drawings.
The majority of these hengers were not in their pro $er location or orientation.
It is estiasted that less than 1 5 of the hangers will actually l
require romert due to the built-in safety margins.
Information on the status of the other three systems was not immediately available but was espected to be siellar.
During the NRC inspection conducted.
April 5-8,1982, the MC inspectors identified similar hanger problems related to the control of documents and safety-related work activities.
In trying to determine the root cause of the number of deficiencises.
identified during the turnover process, a number of engineers com-mented that they felt that a significant influence say have resulted free upper level management's pressure to turn systems over in order to proceed with the testing program.
Of those interviewed by the NRC inspectors, no one was willing to say that there was management pressure to falsify documents or to do the work incorrectly.
Several persons said, however, that management decisions to begin review of incomplete packages created a situation where system quality could not be assured eue to the workload involved in trying to track actual system statas.
'The NRC inspectors noted several references in turnover procedures regarding completing work activities and meeting schedules.
These procedural statements could result in persons being in violation of the procedure as a result of circumstances beyond their control.
I
12 LP&L's Vice Presioent for Nuclear Operations, when questionec about whether pressure had been applied to force system turnover, stated that pressure was evident and expected, but that no one should imply that such pressure was intended to cause people to take shortcuts where safety was concerned.
He went on to comment that there was no economic incentive not to do the job right the first time.
Contrac-tors were paid to complete their work in whatever time it takes.
, nen tne work was cone, it should be right.
W The NRC inspectors concluded that individuals directly involved in the review and turnover process may have been responding to schedule pressure.
This was evident from the amount of incomplete information included in the turnover packages.
Discussions with LP&L management indicate that there was no intent that system quality suffer as a result of system turnover.
It did not appear that deficiencies found at the craft level were a result of schedule pressure.
c.
Conc,1psions The recent chain of events, beginning in January 1982, have led to an awareness on the part of LP&L that the expected level of quality has not been built into ca m in systems of the Waterford 3 plant.
LP&L has taken prompt and extensive actions to identify and correct the problems before accepting system turnover.
The LP&L construction QA organization has grown from approximately five positions in January to seven positions, with tarse additional personnel brought in to assist.
Ebasco QA has grown from 10 to 17, and, in addition, another 30 records reviewers have been brought onboard.
Ebasco's chief QA engineer fram their New York corporate office is onsite to assist, as necessary, turrent plans are for Ebasco to formalize a program to.
audit the effectivness of contractor QA/QC programs.
LP&L's new site director plans to ensure that the testing program adequately evalu-ates installed instrumentation.
In addition, recent letters clarify-ing turnover requirements are currently being implemented.
Corrective actions to avoid recurrence of the above problems will be '
reviewed during future inspections.
9.
LP&L Quality Control - operations On May 17, 1982, the NRC inspectors began a review of the LP&L quality control program.
The LP&L quality control organization reports to the plant manager and is responsible for identifying quality problems with the Waterford 3 organization.
LP&L QC consists of two supervisors, six permanent LP&L employees and nine contract employees.
The QC organization conducts a day-by-day review of startup and operational activities.
Discussions were held with several QC inspectors and their supervisors.
The QC inspectors commented that they felt free to identify any issue adverse to quality and that they had no problems with the workers on the Waterford 3 site.
No one recalled any serious instance of atterated
{
a
13 intimidation while performing ~their QC activit'ies.
Several QC inspectors commented that it takes much too long for their findings to be evaluated and acted upon.
They were concerned that after identification of what appeared to be a generic deficiency, work frequently continued for some time before corrective action was initiated.
LP&L QC has stop-work autority that can be used if appropriate.
The NRC inspectors reviewed all Qc surveillance reports form M D-81, dated May 27, 1981; to #99-82, dated May 7, 1982.
Overall it appeared that the LPE QC organization was in place ano functioning as expected.
Many responses to QC findings were overdue.
However, the lead QC engineer was escalating the level of visibility of their findings to higher levels of ennessment encouraging more prompt resolution.
The NRC inspector noted that same responses to the QC findings were vague and somewhat unprofes-sional.
This was discussed with LPk management.
No violations or. deviations were identified.
10.
Unresolved /0 pen Items Unresolved items are matters about which more informIntion is required in order to ascertain whether they are acceptable items, violations, or deviations.
An unresolved item related to instrument installations (Unresolved Item 8214-03) is discussed in paragraph 6.
Open items are specific items that will be reviewed during a" subsequent inspection.
Open items identified and the paragraph of this report in l
which they are discussed are:
Open Itan Paragraph Equipment tracking (8214-01) 3 Conrnents on preoperational test procedure SDP-69-001 (8214-02) 5 11.
Exit Interviews 4
The NRC inspectors met with the licensee representatives (denoted in paragraph 1) at various times during the course of the inspection.
The scope and findings of the inspection were discussed.
.e 4
,~v
.--n------,,,,,,-...,mn--..,_-,-.._
_._--.__wr,,,_,,,,s-a,,,_-r
---m,_,-
, nw m -,., -.
,,wm
_,e,-,-n..,,-e--,