ML20132G008

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Confirms 830408 Telcon Re Requested One Wk Extension of Deadline for Submission of Waterford Exercise Scenario
ML20132G008
Person / Time
Site: 05000000, Waterford
Issue date: 04/12/1983
From: Collins S
LOUISIANA, STATE OF
To: Hackney C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML082320156 List: ... further results
References
FOIA-84-206 NUDOCS 8510010454
Download: ML20132G008 (75)


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8. JIM PORTER DEPARTMENT OF NATURAL RESOURCES WILLIAM H. SPELL OFFICE OF ENVIRONMENTAL AFFAIRS

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NUCLEAR ENERGY DIVISION April 12, 1983 Mr. Charles Hackney U. S. Nuclear Regulatory Commission 1

Arlington Regional Office 511 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

Dear Mr. Hackney:

This letter is to document telephone conversations on April 8, 1983, with Mr. Charles Hackney of the U. S. Nuclear Regulatory Commission, Mr. Al Lookabaugh, FEMA, Mr. Steve Collins, Louisiana Nuclear Energy Division, and Mr. George Bailey of Louisiana Power and Light (Waterford 3).

The Louisiana Nuclear Energy Division requested a one week extension of the deadline for submission of the scenario for the Waterford 3 "for score" exercise to be held May 25, 1983. The reason for the request was that the Nuclear Energy Division and Office of Emergency Preparedness individuals working on scenario development were extremely busy with the severe storm and flooding problems in East Baton Rouge Parish, St. Charles Parish, St. John the Baptist Parish, and other areas during the week of April 4th through April 9th. The Louisiana Nuclear Energy Division staff member involved in this project had water inside his house above the baseboards and was too busy trying to save his belongings to finish development of the scenario.

The Louisiana Nuclear Energy Division sincerely appreciates your time and consideration for our request for this one week delay.

If you have any questions concerning this matter, please feel free to contact our office.

Sincerely, 8510010454 850227 m

PDR FOIA BERNAB EB4--206 PDR Steve C. Collins Manager, Nuclear Projects Section SCC:gwh g p,.55$

P.O. BOX 14690 BATON ROUGE, LOUISIANA 70898 PHONE 504/925-4518

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_I LOUISIANA Mlo0LE ' SOUTH U'luYlES SYSTEM September 6, 19E'4 W3P84-2478 3-A20.27 TO:

Distribution f

FROM:

G.E. Wull'er Onsite Licensing Coordinator

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Notes NRC Review of Fire Protection Program

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Inspection 84-40 August 27-31, 1984 In attenda.nce:

NRC LP&L M.E. Murphy K.N. Curley W.B. Jones J. Woods G.E. Wuller K.L. Brewster L.F. Storz 1

r A.L. Holder 0.9. Kilgore Other P. C'hristofakis - Ebasco M.R. Cumbest - MSS B.C. Collyer - MSS fopfy-zo6 o/s7

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NRC Exit Interviww Notes Review of Fire Protection Program Inspection Report 84-40 1.

Inspection conducted August 27-31, 1984.

Inspection report, when ismaed, will be 50-382/84-40.

Mr. Murphy stated that this inspection covered open items and deviations from Inspection Reports 84-28 and 84-20 and an open item from Inspection Report 84-07, 2.

Comments on Previous Inspection Findings A.

The following items remain open based on the inspection:

Open Item 8420-01: This item is open pending completion of the licensee's reanalysis of the effects of a fire in the control room without limitation to one control panel, such that the equipment and circuits necessary to provide the alternative shutdown capability are electrically isolated from the control room.

In addition, the licensee must identify the systems and/

or components required for safe shutdown, develop procedures to implement the alternative shutdown capability, and identify and train sufficient numbers of shif t personnel to implement the procedures.

The procedures must consider the unavailability of off-site power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Mr. Murphy stated that the tools and materials necessary for Jumper Isolation were in place'and part of this item was con-sidered closed. Alternate shutdown capability (based on control room fire) is not complete and this portion of Open Item 8420-01 remains open pending completion of spurious actuation study.

Open Item 8420-02: This item is open pending an NRC (NRR) resolution on installing smoke detectors in the control room cabinets. The licensee informed the NRC inspectors that they had a written commitment to install self-contained smoke detectors by 5% OL as an. interim fix until a per-annent detection system could be installed (1st refuel) but that we verbally indicated we would attempt to install the battery operated smoke detectors before fuel load and permanent detection by 5% OL.

The self-contained smoke detectors were scheduled to be installed by 8/31/84 in CIWAs; however, QC wanted a Station Modification

, Package before work continues. The work was not complete and remains "as an open item.

(Partial) Open Item 8420-05: Pending installation of neutron flux indication at the remote shutdown panel prior to startup following the first refueling outage and completion of the spurious operation study (12/1/84) and any subsequent modifications.

Inspection 84-40 Pegs 2 2

Open Item 8420-07: Pending completion of licensees' reanalysis of spurious

  • signals on associated circuits. Draft report from Ebasco has been submitted to LP&L for review.

R.F. Burski's group to have study completed by 12/1/84. This will remain an open item.

B.

Mr. Murphy reported that the inspection will close the following previously open items and deviations:

Item 8420-03:

Passive fire protection for the redundant chillers, chilled water pumps, and air handlers were not in accordance with NRR Guidalines. Closed based on draft SSER.

Item 8420-04: Required installation of additional local early warning fire detection at each auxiliary component cooling water pump. Closed.

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Item 8420-05 (Partial):

Licensee to provide local pneumatic operation capability for each ADV in lieu of chainfall, Closed.

Item 8420 06: Pending NRR action on the licensees deviation requests for numerous fire areas that do not meet Section III, G.2 of App. R.

Closed based on draft SSER.

Item 8420-09: Pending installation of additional y hour emergency lighting and adjustment of existing lighting to better illuminate desired areas.

Mr. Murphy commented that LP&L may want to run an illumination test.

L.F. Storz stated the need for maintenance to assure light adjustment redains as set and that an illumination test would be conducted.. Closed.

Item 8420-10: Pending NRR resolution of the' Reactor Coolant Pumps Oil

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CollectionESystem capacity and routing of the overflow. Closed. based on draft SSER.

Item 8420-14: Pending resolution by NRR of the fire door variances identified by U.L.

Closed based on draft SSER.

Item 8420-15: Pending revision to all Fire Protection Administrative procedures and resolution of inconsistencies and differences.

Closed.

Icem 8420-16: Pending revision of Housekeeping Procedure UNT-7-006 to include definitive administrative controls as required by 10CFR50,

. App. R,Section III.K.7.

Closed.

Item 8420-17:

Pending revision of procedures FP-1-003 and FP-1-004 to cover cleaning, maintenance, or repair of Fire Brigade Equipment.

Closed.

Deviations 8420-18 and 8420-20: The two deviations covered the need for providing a minimum inventory of personnel protective equipment, to ensure the minimum inventory of personnel equipment is verified, and to ensure that portable fire extinguishers are verified to be in an acceptable condition. Closed. Note:

Licensing was reminded

Inspsetion 84-40 Page 3 e

to make sure we address all three standard information requests in responding to deviations in the future, especially corrective steps which will be taken to avoid future deviation f rom commitments made to the NRC.

Item 8420-21:

Pending revision to FSAR and QA Manual to clearly 3

identify the QA programs for Fire Prevention / Protection that the licensee intends to implement. Closed.

Construction Appraisal Team (CAT) Item 8407-13:

Mr. Murphy stated that he had not received / reviewed sufficient information to close this item.

He specifically wanted to see a drawing / sketch showing the double-fusible links used on " Jumbo" fire dampers.

In addition to the Fusible Links, there was considerable discussion regarding functional testing vs. visual verification of damper operability and how the periodic maintenance was to be performed.

Af ter the exit meeting was concluded, A. Holder initiated an internal letter: W3M84-0395, R.P. Barkhurst to F.J. Drummond, dsted 8/31/84 This letter detailed the maintenance to be conducted. The letter was given to Mr. Murphy before he lef t the site. Also, Mr. Murphy was given a detailed verbal explanation of how the double fusible links were installed.

Mr. Murphy concluded that he thought he had suf ficient Onfo rmation to close this item and expected the inspection report to show the item closed.

(Open - Pending Report 84-40).

3.

There were no new items as a result of this inspection. Items not discussed were previously closed by Inspection Report 50-382/84-28.

4 There were no o't'her iteme of discussion and the meeting was dismissed.

GEW/KLB/pbs R.S. Leddick, D.F. Packer, T.F. Gerrets, A.D. Jones,' W.M. Morgan, cc:

F.J. Drummond, P.N. Backes, R.M. Nelson, K.W. Cook, R.B. Willis, D.E. Dobson, R.F. Burski, R.P. Barkhurst, L.F. Storz, S.A. Alleman, J.N. Woods, Z.A. Sabri, C.J. Decareaux, L.L. Bass, K.R. Iyengar, R.S. Savoie, Project Files, Administrative Supoorts, Licensing Files, K.N. Curley, G.E. Wuller, K.L. Brewster, A.L. Holder, 0.W. Kilgore, P. Christofakis; M.R. Cumbest, B.C. Collyer NRC - G.L. Constable,' T. A. Flippo

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l OUIEiANA POWE R & LIG HT / INTER-OFFICE CORRESPONDENCE E Assysy$

September 21, 1984 W3P84-2625 3-A20.27 TO: Distribution FROM:

G.E. Wuller Onsite Licensing Coordinator

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Notes NRC Resident Inspection Report Inspection 84-39 August L-31, 1984 In attendance:

LP&L NRC LP&L G.L. Constable T.F. Gerrets L.W. Meyers L.F. Storz W.M. Morgan D.W. Herrin 0.D. Hayes P.V. Prasankumar C.L. Skinner R.J. Bentley K.L. Brewster M.J. Meisner (Part)

W.J. Baldwin J.J. Denkevitz L.

Laughlin (Part)

Other J.R. McGaha G.E. Wuller J.B. Hart - Ebasco (Part)

Attached are notes on the exit interview held on September 17, 1984.

R.S. Leddick, R.F. Gerrets, F.J. Drummond, Z.A. Sabri, N.S. Carns.

Distribution:

D.E. Dobson, R.P. Barkhurst, P.N. Backes, K.W. Cook, R.F. Burski, M.A. Triggs, L.F. Storz, S.A. Alleman, J. Woods, W.M. Morgan, A.D. Jones, R.M. Nelson, R.B. Willis, L.R. Gilbert, M.R. Carpenter.

R.A. Savoie, Attendees fe/AJY 264 O/sy

NRC Exit Interview Notes j

- Rsaidrnt Inspection Program Inspection Report 84-39 1.

Inspection conducted August 1-31, 1984 Inspection Report, when issued, will be 50-382/84-39.

2.

Inspection findings A.

The following items were reported as apparent violations.

1) Violation - Failure to check oil level in HPSI prior to test.
2) Violation - CIWA procedure UNT-5-002 states that when a CIWA is closed, the copy in the control room is to be removed. Contrary to the procedure, CIWA 8402 has been closed but the copy was still in the control room file. No severity level was given by the inspector to this administrative violation.
3) Violation - Failure to take corrective action on a leak-ing HPSI pump oil level bubbler. No CIWA was written. According to L.F. Storz, PRE 84P-26 was written to evaluate specific and generic implications. The inspectors considered inadequate review was taken to determine generic implications.

NOTE:

NRC agreed to entertain further discussion on this subject prior to issuance of report.

B.

The following items were closed during the inspection.

1) Closed - SC3 - 96
2) Closed - TMI Item II.F.1
3) Closed - TMI Item II.F.2 C.

The following old issues were discussed and these will appear as open items in the inspection report.

1) Open - HEDs regarding banding of meters in the control room.

Banding of meters is not necessarily restricted to safety items.

L. Meyers stated the work is to be completed by mid October.

Mr. Constable wanted to know whether we have this as an item to be completed by fuel load and if it is not going to be completed, we may want to change commitment. This entire item is tied to TMI Item I.D.L.

2) Open - Discrepancy in procedure ME-4-155.

Section 7 and 8 yield different response times when testing reactor trip breakers. Needs to be changed to yield similar response times for bench and field testing.

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7 NRC Exit Intsrview Notes S1ptembe'r 21, 1984 Paga 2

3) Open - High points in instrument lines are not self-venting /

draining. When these lines are vented /draindd, it is not doc'umented by a CIWA or any other mechanism, so as to trend the conditionand identify in-leakage problems which may lead to erroneous instrument readings. Calibration of these instruments would not identify the in-leakage problem since the reference legs are not used in calibration (eg. an instrument can be in calibration and still give an erroneous reading due to in-leakage).

D.

The following items were stated to be NRC problem areas but will receive further consideration and, if necessary, appear in the September inspection.

1) Violation - 50.55(e) Reporting - Failure to report nonconforming lubricating oil condition in containment cooler fan motors as identified in NRC Inspection Report 84-25.

LIR 84-072 was issued 9/14/84.

NOTE:

Considerable discussion ensued regarding significance of issue.

NRC indicated the LIR may not be much help in resolving the issue. The inspectors indicated that we will be able to discuss j

this further and include the item in the September inspection report.

2) Violation - Safety Injection Valves Actuator - Basis for not reporting was handled inadequately via PRD-147.

Final acceptanen -f PRD-147 has not occurred.

LP&L requested tiarification as to why the NRC thought it should have been a 50.55(e). Will be discussed further and included as an item in the September inspection report.

E.

The inspectors made additional comments as follows:

1) There will be a new Region IV Administrator (R.D. Martin) effective October 1, 1984, 2)

Mr. Boardman is reviewing LP&L's responses to violations 8425-01 and 8425-02.

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2.9 457000198, Low Pressure Safety Injectica Pump Manual 2.10 457000272, High Pressure Safety Injection Pump Manual 2.11 PMD-Y83-061, Plant Lubrication Manual 4

{}09 2.12 LP&L Pump and Valve Inservice Test Plan 2.13 OP-903-033, Cold Shutdown ISI Valve Tests 3.0 PREREQUISITES i

3.1 Temporary test gauges as specified in section 6.0 have been installed prior to pump testing.

Suction and discharge pressure gauges should be located at the same reference elevation to avoid introducing inaccuracies into recorded parameters.

1 i

32 Either Mechanical Maintenance or Operations personnel are available to measure pump vibration ISI data.

~

3.3 Pump lubrication oil levels have been checked and adjusted as necessary in accordance with the Plant Lubrication Manual. Reference 2.11.

3.4 The RWSP level and temperature are within the allowable values (1475,500 gal and 55 IT 1100 degrees F) of Technical Specification LCO 3 1.2.8, aorated water Sources-Operating, to avoid introducing inaccuracies into recorded parameters.

4.0 PRECAUTIONS AND LIMITATIONS 4.1 During SI operation in the shutdown cooling mode, concurrent testing should be coordinated with OP-903-032, Quarterly ISI valve Tests, and OP-903-033, Cold Shutdown ISI Valve Tests, as applicable to minimize swapping shutdown cooling trains.

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DOC 1] MENTATION OF TELEPHCEE COMMUNICATIONS DATE:

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PARTY CALLING:

R. Bailey LP&L (Name)

(Company)

PARTY ANSWERING: Shelley Seabrook Mobile Oil Corp. (713) 224-1521 (Name)

(Company)

SUBJECT:

Lubrication for HPSI Pumps FILE:

SUNMARY:

(INCLUDING DECISIONS AND OR COMMENTS)

' Per my conversation with the above Mobile Representive, Mobile Oil DTE-797 or SHC-824 may be used to satisfy the oil specifications that apply to the High Pressure Safey Injection Pumps stated in manual 457000272 page 19.

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l.OUISIANA POWE R & LIG H T/ INTER-OFFICE CORRESPONDENCE rafatas July 17, 1984 W3K84-1636 Q-3-A35.02.01 TO: DISTRIBUTION LJ/l&

FROM:

W. M. Morgan Nuclear Oper ions Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Notes NRC Review of Significant Construction Deficiencies (SCDs)

Inspection Report 84-35 July 9-13, 1984 NRC LP&

Ebasco

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R. P. Barkhurst M. Harris J. Boardman T. F. Cerrets T. Flippo H. A. Canavier J. Woods M. A. Triggs T. Chiles F. J. Englebracht P. V. Prasankumar J. D. Lee R. Masters R. Savoie R. J. Bentley W. M. Morgan W. J. Baldwin C. N. Hooper J. R. Kirkland W. G. Hubacek W. S. Schum i

f0//}-bV~LOf d/Go -

s Lha NRC Exit Interview Notes Significant Construction Deficiencies Inspection 84-35 1.

The inspection was conducted by Mr. Boardman on July 9-13, 1984.

SCD 63, " Procurement of Spare / Replacement Parts" remains open due to inadequate documentation of the Burns and Roe review.

Mr. Boardman stated he reviewed approximately 12 purchase order and specification packages.

2.

Mr. Boardman further stated he still required documentation of the Reliance Motors for the Containment Cooling Fans, casing drain plug removal.

WMM:CNH:SSTG R. S. Leddick, R. P. Barkhurst, F. J. Drummond, T. F. Gerrets.

cc:

D. E. Dobson, N. S. Carns, L. F. Stors, S. A. Alleman, L. L. Bass.

A. D. Jones, K. W. Cook, J. Woods, O. D. Hayes, W. J. Baldwin, Project Files Nuclear Records Licensing Library Ebasco - M. K. Yates, M. Harris, A. M. Cutrona e

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J LOUISI AN A P O W E A & L1G H T/ INTER-OFFICE CO ARESPONOENCE EuiNsysYIU W3P84-1701 Q-3-P34 TO:

File FROM:

K.N. Curley

SUBJECT:

Fire Protection Meeting 6/15/84 NRC Exit Interview Mr. Mike Murphy of the NRC (Region IV) conducted an exit interview with LP&L Staff 5/15/84, to discuss the results of his on-site review of the 4/84 Appendix R Audit findings.

~

1.

The following previous audit findings will remain open pending completion of their associated station modification packagas:'

a.

Atmospheric Steam Dump valves - local pneumatic control b.

RCS Hotleg Pressure - reroute cable c.

ACCW Pump Smoke Detection - add two detectors d.

Emergency' Lighting - completion of previous installation commitments as well as resolution of new requirements identified during observation of Shutdown Outside Control Room procedure walk through.

e.

Fire wrap - boric acid makeup valves and RCB cable tray.

2.

The following items are considered closed:

a.

Firs Brigade Training b.

Diesel Fuel Oil Sampling c.

Fire Hose Testing 3.

Fire doors remain open pending satisfactory safety evaluation from Chemical Engineering Branch (NRC) 4.

Relay Isolation Panel concerns remain open until completion of panel circuit failure analysis 5.

Housekeeping procedures not approved yet 6.

Review of previous QA audit finding not completed by Mr. Murphy (NRC) 7.

Discrepancies ir documenting closure f fire barri - c 'ficie: ci e in fire area transfer package ASP-I W.40 8.

Fire extinguisher maintenance procedure not approved yet fD/k '

Abb C/6/

.. y.

o Mr. Flippo (NRC Resident) mentioned Mr. Fioravaate's positive comments on our procedure and training for shutdown outsids the Control Room during his brief visit coincident but independent of Mr. Murphy's re-audit.

Mr. Fioravante (NRC) will issue the safety evtluaticn of our alternate shutdown capability upon resolution of minor hardware deficiencies.

/b

-g K.N. Curley KNC/pco R.S.Leddick,D.E. Dobson,R.P.Barkhurst,L.F. Storz,M.I.Meye9 ec:

W.M. Morgan, F.J. Drummond, K.W. Cook, R.F. P*srski, R.M. Nelson /M '

L G. Buxton, A.L. Holder, M.J. Meisner, M.R. Cushest, T.A. Flippo (NRC Resident Inspector)', Project Files, Nuclear Records (2).

Licensing Library

l h '3 T G

3 9/24/84 Mr. T. A. Flippo Resident Inspector - W-3

SUBJECT:

Mr. Boardman's request for LP&L activity regarding unresolved items, IR 84-35.

1 This is in response to your verbal request for r. brief status report on the subject matter. The three items were discussed with the responsible LP&L personnel and showed that the following actions have been initiated.

i 1.

URI's 8435-01 and 8435-02.

The issue was discussed with Plant Administrative Services and other pertinent plant groups. PRD-169 resulted in the review of 1500 safety-related procurement packages. The QA group reaudit scheduled-i to be completed prior to September has been completed. Report SA-W3-QA-84-38.

No significant deficiencies were identified. An approach is being developed to review select procurement packages to assure that non-safety grade naterial has been controlled so as to have precluded use in Harsh Environments as well as safety grade systems. The extent and depth of the review, time required, and staff loading is being considered as part of the approach.

LP&L would like j

to ascertain some assurance regarding acceptability of the approach from Mr. Boardman prior to implementation of the review.

2.

URI 8435-03.

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An LIR was issued to the Technical' Services Department requesting a determination of the type of Speed Reducer Back Stop utilized on the dry cooling tower fan motors. The request also covered type of lubricant being used if the Speed-Reducer Back St'op was of an external design.

f641 ^^^h?= h - /Y 4 u p. /. 4 4..&. A., M d.&ww K.L. Brewster Licensing Engineer

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G.E. Wuller h cc:

R.M. Nelson /

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LOUISIANA P OW E R & LIG H T/ INTER-OFFICE CORRESPONDENCE soastao%t:

s June 28, 1984 W3K84-1501 Q-3-A35.02.0L Distribui TO:

Ur FROM:

W. M. Morgan Nuclear Operations Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Nctes NRC Review of Significant Construction Deficiencies Inspection Report 84-32 June 20, 1984 NRC LP&L K. Whittlesay L. L. Bass T. A. Flippo J. N. Woods W. S. Marini J. Somsel R. M. Gimelli G. Pittman T. F. Gerrets Other J. Pertuit fsM /Y-ZWo C/63

i

'f' NRC Exit Interview Notes NRC Review of Significant Construction Deficiencies Inspection 84-32 Inspector Flippo introduced Mr. Marini who spoke on SCD 84.

A summary of his concerns are as follows:

1.

NCR W3-6159 states WPSB used to weld track.

Procedure references ASME Section IX, QW-422 Group Pl.

ASTM 569, 570 are not included as P1 material.

Concern Appears tube track welding was performed using an unqualified procedure.

Also WPSB states minimum thickness is 3/16" while track is 12 gauge (.1046).

2.

NCR W3-6159 Attachment 3 states welds made using the GTAW process achieving full penetrations are acceptable. WPSB is a SMAW process - the disposition is inappropriate.

3.

The original disposition of W3-6159 (Attachment 3) does not address the generic implications of the " unknown quantity" of welding performed prior to July 1982. This item is not addressed until November 20, 1983 on Sheet 1 of 10 which statos "For item 2 (generic portion) of this NCR, it is reasonable to conclude that the QARC review of Mercury records will identify any remaining issue without Mercury QC signoff."

Concern This is not considered an acceptable means of addressing a generic nonconforming condition. How does reviewer know when inspection is needed when he doesn't know where the welds are.

4.

WI-6159 Attachment 8 Sheet 2 of 10 document welds which were repaired by Matcury in accordance with disposition on Attachment 3.

These sheets show that repair welding was performed using procedure WPS-E Revision 11.

This procedure also specifies base metal to be P-1.

Concern Therefore, these repair welds were also made using on inappropriate (unqualified) procedure.

5.

W3-6159 Attachment 9 accepts all welds based upon the results of a tension test performed on this type of weld.

The following are comments concerning this test:

a.

Test report section 3.1 sta tes:

" Test specimens shall be three weld joints...", however, only t wo joints were actually tested.

n NRC Exit Intervisw Notes Inspection 84-32 June 28, 1984 W3K84-1501 Page 2 5.

b.

Test report section 1.1 states:

"This test shall be performed to determine a static tensile value of the tube track welded joints at rupture", however, the welds were not, in fact, pulled to failure.

c.

1/2" 6 ASTM A-36 threaded rod was used to pull the welded section.

When the rod broke first it was assumed the weld was stronger than thetugetrackmaterial. The area of the rod is less than.2 2 inches while the area of the tube track tested is.55 inches.

The rod breaking first does not appear to prove anything Concern regarding the relative strength of the base metal and the weld. -

6.

W3-6159 Attachment 9 accepts all welded joints without any inspection required, on December 8, 1973 and the NCR was signed off on December 9, 1983. On January 5, 1983, NRC was notified'of final with no additional CA, required. February 27, 1984 Attachment 24 to W3-4352 stated:

a.

Several tests on tube track weldment have been conducted which have proven the weldment to be far superior to the track material.

b.

QC is requested to perform visual inspection of the as-built condition of old welding for the tube track on 10% safety related t

system.

c.

The inspection criteria shall consist of verifying existence of a minimum total length of 3 inches of weldment with a minimum of 1/2" length on any side of 2 inches each on both legs.

Concern 1.

Based on 5. statement a'.

is in error.

2.

Has this inspection been performed? How was it determined that 10% is enough? How was 10% calculated when the total population was unknown (or stated in W3-6159)? Was this 10% to be increased if defects were found?

3.

The weld lengths listed in c. are significantly less than the lengths on the test specimens. How is this justified?

r o

NRC Exit Interview Notes Inspection 84-32 June 28, 1984 W3K84-1501 Page 3 Mr. Marini also stated that he had examined SCD 107 and found it to be satisfactory for closure. He stated that SCD 57 was in review, SCD 35 could be closed upon further review, SCD 101 was satisfactory with the exception of concerns raised by J. Harrison's letter dealing with class breaks. This was the case with SCD 61 also (reference to J. Harrison letter item #6).

Inspector Flippo and khittlesay both addressed the problem of timely response to NRC questions, kMf:RMG:SSTG ec:

R. S. Leddick, R. P. Barkhurst, F. J. Drummond, T. F. Gerrets.

D. E. Dobson, N. S. Carns, L. F. Storz, S. A. Alleman, J. N. Woods, R. F. Burski, C. J. Decareaux, L. L. Bass, K. A. Iyengar, R. S. Savoie, M. I. Meyer, M. J. Wise, R. W. Lailheugue, H. J. Williams, Jr., T. Smith, B. Marshall, O. D. Hayes, D. Clark, R. W. Prados, Z. A. Sabri, LP&L Site QA Files, Licensing Library, Proj ect Files, Nuclear Records NRC -

T. A. Flippo 4

1 a

m/

LOUISIANA b'

P OW E R & LIG H T/ INTEA-OFFICE CORRESPONDENCE

" S $ sys E u

May 29, 1984 W3K84-1278 Q-3-A35.02.01 TO: Distributic FROM:

Morg Nuclear Operations Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Pre-Exit Interview Notes NRC Review of Operations Quality Assurance May 14-24, 1984 In Attendance:

NRC LP&L R. L. Constable R. S. Leddick T. A. Flippo 1 R. P. Barkhurst J. E. Gagliardo T. F. Gerrets M. I. Good S. A. Alleman C. Haughney W. M. Morgan D. Graves J. R. McGaha R. Persons J. N. Woods A. S. Lockhart F. J. Englebracht W. J. Baldwin J. K. Somsel J. B. Perez A. R. Roberts Other - MSS N. E. Dubry fD/h*

o/6s

d NRC Pre-Exit Interview Notes

" Review of Operations Quality Assurance" 1.

Inspection commenced May 14, 1984 2.

Mr. Constable opened the meeting by introducing Mr. Charlie Haughney, the inspection team leadar.

3.

Mr. Haughney stated the inspection had been going for approximately two weeks but was not finished. He stated that inspector Mr. Mark Good would return next week to continue inspecting his area of concern, and that he would return the week of 4 June for at least another week. He stated that next Thursday he would contact Mr. W. Morgan and Mr. J. Woods to arrange a number of interview appointments with key personnel for him.

Mr. Haughney stated that the ir.spection team had been examining the following areas; Document Control; Maintenance; Design Changes / Modifications; Surveillance Testing; Special Tests / Experiments; Measuring and Test Equipment; QA/QC Administration - Management; Audits; Procurement; Receipt / Storage / Handling of - Material and Equipment; and Records.

Mr. Haughney stated thus far his team had experienced excellent cooperation and frank, candid comments from all personnel of whom they had come in contact with.

Mr. Haughney stated he would have each inspector present his area of expertise and again he stressed that the inspection had just commenced in some areas and some of the concerns would go away and others appear as the inspection progressed.

Mr. Haughney introduced Mr. Roger Persons.

4 Mr. Persons stated Mr. Andy Gavin was not able to attend this meeting and that he would present Mr. Gavins' concerns first.

Mr. Gavin has been inspecting the area of Maintenance and Records.

I.

Concerns / Findings 1.

There seems to be a lot of confusion generated as a result of UNT-5-002 regarding the CIWAs.

Personnel he talked with were not sure of'the difference between " quality related" vs " safety related". The procedure gave no guidance concerning this area of concern nor where to look for guidance.

2.

Position discriptions had been written and approved for maintenance positions but were not in place and were not being utilized.

. ~ __

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NRC Pre-Exit Interview Notes Page 2 I.

Concerns / Findings (Continued) 3.

MD-1-004 requires department supervisor review PM work packages but j

there is no requirement for review of corrective maintenance work packages.

Back of CIWA's may require this review. The inspector states he has not actually reviewed the CIWA form.

4.

Procedura MD-1-003 contains a list of items which can be done without a CIWA. This list contains sensing lines which could be safety related.

Mr. Gavin feels sensing lines should be documented 1.e. not included on this list.

Procedure UNT-5-002 states work on safety related systems should not be done without a CIWA.

Mr.

Constable engaged in a conversation with Mr. Barkhurst concerning documentation.

Mr. Ccnstable stated be would take this item for action.

1

~

5.

Procedure MD.i

'^6 requires an impound area be established for radioactive scetaminated material. This item had been identified on an OPS /QA audit in early 1982.

As of this date no RCA has been identified.

6.

In the area of Preventive Maintenance no one is required to. review equipment history record cards.

4 7.

UNT-5-002 change 3 changes requirement for mainter.ance supervisor to sign to cognizant supervisor / signature. The procedure does not specify which block the change applies to.

I 8.

MD-1-007 mentions a PM Committee.

There is no document specifying the charter for this committee.

4

  • )

1 II.

Records 1.

A new area has recently been designated for records storage and the records turnover has commenced.

It appears this area should be reevaluated for storage area. There does not appear to be enough space alloted.

This completed Mr. Andy Gavins report.

I

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NRC Pre-Exit Interview Notes Page 3 III. Mr. Roger Persons reported he was responsible for reviewing Surveillance testing. He submitted the following comments regarding surveillance testing.

1.

Mr. Person stated he could not determine if the shif t supervisor or Control Room Supervisor gets notified when something fails to meet the technical specifications criteria. He thinks reportability needs to be clarified in this area.

QP-11.002 should address this area.

2.

In several of the procedures the titles have not been changed as in the case of shif t supervisor and Control Room Supervisor. This caused some confusion in control.

Only about 50% of the procedures

~

contain the new titles.

3.

He found considerable concern with personnel in control concerning access to technical specifications.

He understands there will be a terminal put in soon that will allow access to our computer but he is not sure this will be sufficient.

4 Mr. Persons stated he realized the M&TE progras is being changed.

UNT-5-006 is being deleted and being replaced by QP-12. He reviewed a draft of this procedure and was very concerned with the scope of the procedure.

It appears M&TE will only apply to calibrations required by the Technical Specifications under the new procedure.

5.

Mr. Persons stated he found considerable concern in the M&TE lab concerning staffing.

Mr. McGaha stated a lot of equipment required during construction would be taken off the M&TE list which should remove a lot of the workload in this area. He feels their concerns are premature.

6.

Mr. Persons stated the M&TE lab was very cluttered and crowded and the possibility of more space allowance for this area should be considered.

This completed Mr. Persons report.

IV. Mr. David Graves stated he had just arrived on-site and had just started his part of the inspection.

He stated he was responsible for Special Tests Control review.

1.

Mr. Graves stated QP 11.001 had been deleted on 5/18 and the new procedure had been approved by PORC but had not been issued.

m

1 i

NRC Pre-Exit Interview Notes Page 4 IV. (Continued) 2.

Mr. Graves stated it did not appear that the departments had adequate departmental procedures for review and approval of special testing.

This completed Mr. Graves report.

V. Mr. Mark Good stated he was responsible for reviewing document control and design changes / modifications. He offered the following comments:

1.

Mr. Good stated he had reviewed FSAR 17.2, QA Manual Chapter 6 and UNT-4-006 regarding control of documents. He had found that UNT-4-006 did not mention the NonConformance Reports and that FSAR Chapter 17.2 and QA Manual listed it as a controlled document.

Mr.

Barkhurst and Mr. Woods stated we did not have a nonconformance report and that they would talk with Mr. Good about it.

2.

Procedure UNT-4-007 is not consistent in mention of titles. He used as examples; control of Technical Manuals; Control of Plant Manuals and PMP's mention control of Vendor Manuals. He believes all these titles represent the same manual.

3.

Procedure UNT-4-009 requires that a stamp be use for field control.

The stamp specified in the procedure is not the one being used in the field.

]

a 4.

Procedures PMP 301-304 does not address the fact that changes to design modifications must undergo the same review as the original.

He references QA Manual Chapter 3.

i 5.

Mr. Good stated there are multiple documents in existence to control 1

documents. He used as an example, PMP-004, UNT-4-006, and Executive Directive 20.

He stated this caused confusion.

Mr. Englebracht I

stated UNT-4-004 would go away as soon as Project Group got control of this area.

t 6.

Mr. Good stated UNT-1-003, Procedure Development does not specify who fills out the block for PORC review.

Mr. Barkhurst, Mr. Woods, and Mr. Gerrets engaged in some conversation concerning this matter.,

I Mr. Good stated that the procedure still does not specify who j

l decides upon which procedures will receive PORC review.

i I

.. _.. _,. _ _. _ _ _ _ _. _. - ~..,... _ _ _ _ _ _ -

i NRC Pre-Exit Interview Notes Page 5 j

V. (Continued) 7.

Mr. Good stated procedure UNT-TEM-003, System Transfer references Configuration Control Board Charter but does not address it.

He stated it appears a Executive Directive supercedes this with the change Management System Charter.

There was considerable discussion between Mr. Leddick, Mr. Barkhurst, and Mr. Englebracht.

It was decided this area would be reexauined.

8.

In the area of drawing control Mr. Good stated he had located 10 different EBASCO indexes which covered approximately 50,400 drawings. He stated he could not locate a list of drawings required to operate the plant. However, he had been told approximately 3500 drawings were needed by the operators in control.

Mr. Good stated he took a sampling of 10 drawings from plant records and attempted to match these with drawings in the control room. Only 2 drawings matched.

Mr. Good stated there was a variation of differences; in one case one drawing had a SMP posted and the other one didn't.

There was also differences in the DCN's and FCR's posted on each drawing.

Mr.

Good stated he was also concerned that some drawings had 5 or 6 DCN's posted against them and there was no indication they were being revised. He is concerned that this is not covered in a procedure.

Mr. Good stated that a number of these DCN's and SMP's had been posted against the instrument list and set point document but no changes had been made to the documents. He felt this could result in considerable confusion to the operators during an emergency.

Mr. Barkhurst stated he had issued a memo of the list of drawings required in control and he considered this the " official list" of the drawings required to operate the plant.

Mr. Good stated he would like to have a copy of the memo. He informed Mr. Barkhurst that plant document control did not have a copy of the memo.

9.

Mr. Good stated that control of documents in the procurement area was excellent. However, he stated that he had noted that the titles had not been changed in some of the procedures.

10.

Mr. Good stated UNT-8-001 did not state who was responsible for procurement of quality related material.

t NRC Pre-Exit Interview Notes Page 6 V.

(Continued) 11.

Mr. Good stated the Change Management System charter had not been incorporated into the station modification system in the procurement area. There was considerable discussions between Mr. Leddick and Mr. Barkhurst.

It was decided this area would be looked at some more.

12.

Mr. Good stated he had noted some problems with the Material Services Request, Procurement Request, and MSR's not being completely filled out.

He stated he did not know if this was a problem but the procedure requires that these forms be filled out completely.

13.

Mr. Good stated the warehouse; in the area of wrapping, packing, handling and shelf life was excellent. He detected no problems he.re.

14.

Mr. Good stated there was no training program in effect for buyers and supplier evaluators.

4 This completed Mr. Goods' report.

VI.

Mr. Charlie Haughney continued the meeting by reporting on his area of inspection.

1 1.

Mr. Haughney stated he had been doing a quality review of the P0M's and he was disturbed with some of the issues that were coming out of his review.

Mr. Haughney stated he was concerned with how the POM's were being selected for QA review. He stated the QC staff was very small compared to the QA staff and was lacking in some of the areas of expertise that QA possessed. He stated he was very concerned with the quality review the procedures were receiving. He did not feel the procedures were being reviewed against higher tier doeurents such as ANSI, Reg Guides, and other Standards. He stated he would have a number of examples to offer and one famous one was the example in UNT-4-009 and UNT-4-002 about the " sequence of steps".

He stated that QC was also burdened with a heavy inspection schedule.

Mr. Haughney stated he was concerned how the QA comments

' vere resolved on the procedures they did review. He stated some QA comments had never been answered.

Mr. Woods and Mr. Barkhurst stated QA comments were treated the same as any other departments' comments.

Mr. Haughney stated some problems will be caught by Plant Quality and PORC however; he stated that Plant Quality review of procedures does not require review for inconsistencies, upper tier document review or Technical Specification compliance.

i

=

1 NRC Pre-Exit Interview Notes Page 7 VI.

(Continued) 1.

Mr. Woods stated his inspectors were not experts in Technical Specifications requirements.

Mr. Haughney stated he was talking about quality review for compliance with the Quality Assurance Manual.

Mr. Woods stated procedures have elements which are important to review, but the review does not cover all ANSI standards. He stated that the FSAR and Quality Assurance Manual are considered in his review.

Mr. Haughney stated the procedures did not comply with upper level guidance and he would of fer a number of examples he was working on when he came back. He stated a lot of I

his notes were rough and he did not want to get into it at this i

time.

I 2.

Mr. Haughney states he has some problem with document control. The QASP Manual is missing some procedures and the index is inconsistent for the POM's.

Mary of the directives do not have the titles or list key management personnel.

3.

Mr. Haughney stated that quality assurance training was behind.

i 4.

Mr. Haughney stated he was also concerned with what he is hearing about the " turf war" between QA and QC. !!c stated he was hearing this from many sources so there must be something to it.

He stated j

QA was a strong resource and encouraged the plant to use them in every way they could.

5.

Mr. Haughney stated he would examine the issue of safety related l

verses quality related when he returned on June 4.

6.

Mr. Haughney stated he was concerned that there was no system for management escalation as required in the QA Manual. He stated there needed to be a procedure on this.

1 I

4 7.

Mr. Haughney stated that in the area of QC surveillance and QA monitoring, there could be a lot of duplication of work. He stated he would look into this area further.

Mr. Barkhurst requested that he see him on this area because he had some written agreements on this subject.

1

1 NRC Pre-Exit Interview Notes Page 8 VI.

(Continued) 8.

Mr. Haughney stated he had found inconsistencies in definitions in the procedures. He stated he had found at least four different definitions for a " hold point".

Mr. Haughney completed,his report by stating he sees several strong points:

a.

Plant quality can look at anything.

b.

The staffing level in OPS /QA is very good and the expertise and capability are very strong. The capability of the Operations Staff is very good, judging by the results of the operator examinations.

c.

The attitude is good and everyone has the same goal in mind, to do it right the first time.

d.

QA is doing a good job and is being received well - an example was the recent procurement audit where QA had several substantial findings and the plant responded in an appropriate and timely manner.

This completed Mr. Haughneys' area of the report and he asked for questions or comments.

There were no questions or comments and Mr. Gagliardo dismissed the meeting.

WM: ARR:VBR cc:

R. S. Leddick, R. P. Barkhurst, F. J. Drummond, T. F. Gerrets'.

D. E. Dobson, N. S. Carns. L. Stors, S. A. Alleman, J. N. Woods, R. F. Burski, C. J. Decareaux, L. L. Bass, K. A. Iyengar, R. S. Savoie, M. I. Meyer, M. J. Wise, R. W. Lailheugue, H. J. Williams, Jr., T. Smith, B. Marshall, O. D. Hayes, D. Clark, R. W. Prados, Z. A. Sabri.

LP&L Site QA File, Licensing Library, Project Files, Nuclear Records, NRC - G. L. Constable, T. A. Flippo

I Sy-q 9

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7 t

4 LOUISIANA h

P O W E R & L IG H T/ INTER-OFFICE CORRESPONDENCE

'Eds*vsN August 16, 1983 W3C83-0216 i

To:

F. J. Dru=mond i

FROM:

R. P. Barkhurst

SUBJECT:

Response to W3P83-1921 In response to IE Bulletin 83-05, plant staff has determined that Waterford d:es not use any pu=ps manuf actured by Hayward Tyler Pump Company (HTPC) and therefore action item #1 of IEB 83-05 does not affect Waterford.

W:terford does use ASME code pumps originally manufactured by Babcock & Wilcox Canada Ltd. who sold their pu=p product line to Hayward Tyler Co.

We have pur-chased and installed parts obtained from HTPC for these pumps.

that action item #2 of IEB 83-05 be addressed.

This requires i

Tha specific discussion of action item 2a, b, e and d is included in Attachment 1.

The identification of all pumps with their service application and spare p rts ordered by plant staff is included in Attachment 2.

i WJ request that Licensing ensure that the action required in section 2c of t is placed on the Coc:mitment Tracking List.

If you have any questions please feel free to contact us.

i f f-t

f. P. Barkhurst RPB/fnb W. Cavanaugh, L. Storz, S. A. Alleman, P. V. Prasankumar, J. R. McGaha, cc M. P. Flasch, W. K. Pinson, M. J. LeBlanc, M. I. Meyer, R. W. Prados.

J. Woods, C. Savage RECElvgo CLEAR RECORDS AUG 17 1993 fotA fY-zof eja

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(,0 m

Louisiama P OW E R & LiG H T/ INTER-OFFICE CORRESPONDENCE June 13. 1984 W3K84-1394 Q-3-A35.02.01 1

TO: Distribution U$b W FROM:

W. M. Morgan /

Nuclear Operations Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Exit' Interview Notes NRC Review of Operations Quality Assurance Inspection Report 84-31 May 14 - June 8, 1984 In attendance:

NRC LP&L T. A. Flippo T. F. Gerrets C. Haughney R. F. Burski J. Boardman J. R. McGaha L. F. Storz K. A. Simister W. M. Morgan R. B. Willis J. M. Cuillot K. Do M. J. Meisner J. K. Somsel D. T. Simpson T. Chiles P. V. Prasankumar W. J. Baldwin J. B. Perez R. G. Bennett J. N. Woods A. R. Roberts Other-Ebanco J. R. Portuit K. M. O'Cara J. B. Hart f~sM-8Y-z o s 0/67

1 4

} 4 i

NRC Exit Interview Notes

" Review of Operations Quality Assurance" Inspection Report 84-31 1.

Inspection commenced May 14, 1984.

Inspection report will be 84-31.

I 4

2.

Mr. P11ppo opened the meeting by introducing Mr. Charlie Haughney, the inspection team leader.

3.

Mr. Haughney stated he had been here for the past week finishing up the inspection of the Operations Quality Assurance Program. He stated the other inspectors that had assisted him had completed their sections and i

departed earlier.

1 Mr. Haughney stated the inspection team had examined the following areas:

1 I

Document Control, Maintenance, Design Changes / Modifications, Surveillance 1

Testing, Special Tests / Experiments, Measuring and Test Equipment, QA/QC j

Administration / Management, Audits, Procurement,. Receipt / Storage / Handling j

of Material and Equipment, and Records.

Mr. Haughney stated he would not repeat the complete report of the other r

inspectors that had assisted him but would only report what he considered the most important:

)

I.

Surveillance Testing j

1.

Lack of prompt notification to Control Room personnel when

.l something fails to meet technical specifications criteria.

)

II.

Maintenance and Records 4

)

1.

The confusion generated as a result of UNT-5-002 regarding I

the CIWas.

Personnel are not sure of the difference between i

l

" quality related" vs. " safety related".

The procedure gives l

very lis'.ted guidance.

This area needs to be addressed.

l 2.

Procedure MD-1-006 requires an impound area be established i

for radioactive contaminated material.

As of this date no j

RCA has been identified.

j 3.

In the area of Preventive Maintenance, no one is procedurally required to review the machinery record cards.

1 l

4 MD-1-007 mentions a PM Committee. A charter for this committee could not be located. Mr. Haughney engaged into a discussion with Mr. McGaha and Mr. Frasankumar regarding this item. Mr. McGaha stated he had minutes of the FM Committee i

l meetings for the past 2 years. Mr. Haughney stated he would

{

drop this item.

i i

ii I

Inspection Report 84-31 Page 2 III.

Procurement, Receipt / Storage / Handling of Material and Equipnent I

l Mr. Haughney stated there were only a few minor concerns in this area.

l j

I IV.

Document Control and Design Changes / Modifications

)

j 1.

In the area of drawings, Mr. Hauglacy stated the drawings in i

i the control room do not reflect the "as built" conditions of i

the plant. He stated that he considered this area of concern very important.

This completed Mr. Haughney's report of what he considered the most important concerns raised by the inspectors who assisted him during the j

inspection.

V.

Mr. Haughney continued the meeting by reporting on his area of inspection.

i 1

1.

Mr. Haughney stated he was not able to resolve hie-concern about how the POMs received a quality review. He stated he had been told this area was being looked at again by all personnel involved and was pleased that corrective action was l

l being considered. He stated that procedure problems have passed by the Plant Quality Group undetected and that the problem seems to be inadequate staffing. The staff consists of 7 people who have to review hundreds of procedures in addition to their inspection responsibilities. Some key i

review criteria is being missed; such as reviewing for j

compliance with upper tier documents and lookin6 sideways at interfaces with other procedures.

2.

Mr. Haughney stated he considered the issue raised regarding UNT-4-009 and UNT-5-002 about the " sequence of steps" very important. He stated it appears to his LP&L may be in violation of their own procedures.

(He found another 4

procedure that states that a procedure shall be followed in

{

sequence.)

1 3.

Mr. Haughney stated that document control was not good; i

l especially in the control room. He stated that the binder in the control room was missing some Executive Directives. He i

i stated the ids appeared to be very important in representing l

I management's latest guidance regarding matters and more j

effort should be expended getting these out and in all the binders right away.

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Inspection Report 84-31 Page 3 J

i i

V.

4.

Mr. Haughney stated he had gone to training to review how each department was trained on procedures. He was not pleased with what he found. He stated QP-015-001, i

l "Nonconformance and Corrective Action" was required reading j

for only the Plant Quality Group. He stated some areas such as Operations had an elaborate system for training on 4

l procedures.

Mr. Haughnay engaged in conversation with Mr. D. T. Simpson regarding this item and stated he would i

look at it some more after this meeting.

4 5.

Mr. Haughney stated he reviewed the procedure for Design Control, PE-02-006 and could see where the FMPs were starting i

to be used. He has some concern here because the system is not fully operational yet.

l 6.

Mr. Haughney stated he could not find where Emergency Modification was addressed in any procedure. He did not think this was necessarily bad based on his past experience.

However, he stated this area may need review.

7.

Mr. Haughney stated there should be a procedure describing the system for management escalation as required in the QA Manual.

1 Mr. Haughney completed his report by stating he sees several strong pointer i

a.

The capability of the Operations Staff is very good and flexible.

l The success of the operator examinations is a good example.

b.

The staffing level of OPS QA is very good and the expertise and I

capability are very strong. Other parts of the organisation are i

starting to use Operations QA while QA is still maintaining their

{

independence.

l l

c.

Plant Quality can look at anything (balance of plant).

d.

The memoranda of Understanding with other Middle South companies 4

establishing the Nuclear Oversight Committee represent a step in the l

right direction. This could prove to be entremely valuable to all i

i personnel concerned as the plant goes on to an operating stage.

u i

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4 Inspection Report 84-31 Page 4 Mr. Haughney stated there were three potential violations:

1.

Document control, especially in the area of drawing control.

2.

Insufficient quality review of procedures.

3.

The issue regarding " sequence of steps".

This completed Mr. HaughneyJs area of the report and he asked for questions or consents.

There were no questions or comments and Mr. Flippo dismissed the meeting.

WMN:ARR:SSTG cc:

R. S. Leddick, R. P. Barkhurst, F. J. Drummond. T. F. Gerrets, D. E. Dobson, N. S. Carns, L. F. Stors S. AI. Alleman, J. N. Woods, R. F. Burski, C. J. Decareaux. L. L. Bass, K. A. Iyengar, R. S. Savoie, M. I. Neyer, M. J. Wise, R. W. Lailheugue. H. J. Williams, Jr., T. Smith, B. Marshall O. D. Hayes, D. Clark, R. W. Prados Z. A. Sabri. LP&L Site QA Files, Licensing Library, Project Files Nuclear Records NRC - G. L. Constable..T. A. Flippo

T

/

I LOUISIANA P OW E R & LIG H T/ INTER-OFFICE CORRESPONDENCE

=4sas:

June 22, 1984 W3K84-1465 Q-3-A35.02.01 TO: Distributio Nd FROM:

W. M. Morgan Nuclear Operations Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Notes NRC Review of Signj Qcant Construction Deficiencies (SCD)

Inspection Report '8fr29--

June 19-21, 1984 NRC Ebasco LP&L T. A. Flippo J. Portuit L. L. Bass R. Hall H. Harris C. N. Hooper MM

-K. O'Cara R. Bently J. N. Woods

[C/M*dY"Idd 6/G

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NRC Exit Int 0rvica N2tco

~

i Significant Construction Deficiencies

_ Inspection 84-29 1.

The inspection was conducted by Messrs. R. Hall and R. Rahl on June 19-21, 1984.

Inspection Report number will be 84-29.

i 2.

Mr. Hall closed the following SCD's.

SCD-68, " Spurious Actuation of ESFAS - J3109 Connectors" SCD-96. " Failure of CVCS Pump Train "A" to Start on SIAS" SCD-99 " Safety Injection Tank (SIT) Isolation Valve" SCD-97, " Diesel Generator "B" Turbocharger Failure (pending receipt of change 2 to MM-3-015)"

3.

Mr. Rahl closed the following SCD's.

SCD-102, " Dowels and Shear Blocks" SCD-103, "Radflex Wall Penetrations" SCD-88, "RWSP Nozzle / Liner Overstress (pending receipt of calculations from Ebasco)"

4.

Mr. Hall recommended amending the final report of SCD-96 due to the further evaluation that has l'essened the safety significance of the electro switch relays.

He also, commented on the lack of material failure analysis on the gears of the Safety Inspection Tanks Isolation Valves.

He further, stated he was looking at NCR 7680, pertaining to SCD-74, which was closed on inspection 84-24.

problems are generated by this NCR review.

He will inform LP&L if any WMMtCNHtVBR R. S. Leddick, R. P. Barkhurst, F. J. Dr' ummond T. F. Gerrets.

cc D. E. Dobson, N. S. Carns, L. F. Stors, S. A. Alleman, L. L. Bass, A. D. Jones, K. W. Cook, J. N. Woods, O. D. Hayes W. J. Baldwin, Project Files, Nuclear Records, Licensing Library I

t o

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l OUISIANA P O W E R & Ll G H T/ INTER-OFFICE CORRESPONDENCE N@NbsNU June 18 1984 W3K83-1424 Q-3-A35.02.01 TO: D i

FROM:

W. M... organ Nuclear Operations Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Note _..

NRC Review of Op SCD's Inspection Repo t 84-25 June 4-8. 1984 I In Attendance:

NRC LP&L eissm47444ppo1 R. F. Burchi C. Haughney T. Chiles J. Boardman T. F. Cerrets W. M. Morgan K. A. Simister J. R. McCaha R. B. Willis J. M. Guillot K. Do M. J. Meisner J. K. Somsel D. T. Simpson P. V. Prasankumar W. J. Baldwin J. B. Perez R. C. Bennett J. N. Woods A. R. Roberts Other - Ebasc3 J. R. Portutt J. B. Ilart K. M. O'Cara f0/k *0Y 6/69

4 NRC Exit Interview Notes

" Review of Open SCD's" Inspection 84-25 1.

Inspection commenced June 4 1984..

Inspection report will be 84-25.

2.

Mr. Flippo opened the meeting by introducing Mr. John Boardman.

3.

Mr. Boardman thanked everyone for the excellent cooperation and good response he had received during his inspection.

He stated that his inspection had concerned the closure of SCD 79, acceptance and Reliability of Motors.

He stated that as a result of information he had acquired during this inspection he would close SCD 79. However, during the conduct of this inspection he had opened other concerns which may represent potential violations.

4.

Mr. Boardman provided the following information concerning potential violations or unresolved items he had discovered while trying to close SCD 79.

LP&L's lubrication program does not comply with manufacturers' a.

reccamendations. The lubricant being used by LP&L is not the one listed in the technical manual.

LP&L's instructions are in accordance with the technical manual and has resulted in not overlubrication of equipment.

b.

There is no maintenance being performed by LP&L.

Mr. Boardman asked if Ebasco performs the maintenance, he stated that if they did, he needed to know.

Mr. Boardman stated he had reviewed the technical manual for c.

the Joy blowers in the containment coolers. He had reviewed the A490 fasteners installed and did not think installation was in accordance with ANSI N45.2.5. Section 5.4.

Fans were torqued in the range of 850-1100 foot 1bs.

It requires daily verification of the torque wrenches.

He could not find a record of this verification.

d.

Mr. Boardman stated he could not find any reference in Ebasco's procedures to an Environmental Qualification Program for lubricants.

Indicating the lubricant used on the electrical equipment has not been approved and is not in accordance with manufacturers' instructions, Mr. Boardman stated he had found numerous occasions where site e.

procedures are not in accordance with technical manuals.

l

1 s NRC Exit Interview Notes

" Review of Open SCD's" Inspection 84-25 Page 2 l

4.

f.

Mr. Boardman stated the program for control of technical manuals in general was unsatisfactory. He referenced an Operations QA audit that had " frozen" a large number of manuals. However, he cited a case of an uncontrolled manual being issued to a worker while he was in the document control area.

Mr. Boardman also cited a letter from licensing (letter 83-28 " Salem letter") where one of the manuals on " hold" by the l

QA Audit was being referenced. He expressed concern that these incidents imply that uncontrolled technical manuals are being l

used for work performance.

g.

In reference to Environmental Qualification procedure for Maintenance Mr. Boardman stated he could not find Appendix A to the procedure. He stated he had been given a letter which appeared to represent the master list of items that could be used but it did not state it was the appendix to the procedure.

He also stated he could not find the lubricant LP&L was using on the list..

l h.

In the area of vendor manuals. Mr. Boardman stated it was his understanding all manuals were supposed to be reviewed or validated by Ebasco and then placed on the EMDRAC system. He found at least 140 manuals being used that had not gone through the EMDRAC system. He stated the CE manuals are not on the f

EMDRAC system indicating that they are not being reviewed by anyone. Also there is no list that he could find of the CE manuals that were required by the plant.

1.

Mr. Boardman stated he looked at some CE-ADPs (Available Data Program).

He stated there was a file of the 1984 ADPs, but wondered about the ones from 1971 to 1984.

He felt there should be a program established to review these along with the GE Technical Bulletins.

J.

In the area of Uncontrolled Manuals Mr. Boardman stated he had found abnormalities between the installation and calibration l

procedures for crimpers.

He stated the manuals being used as l

references in the work area had no review or approval stamp and the work procedures being used were not in the document control system.

l k.

Mr. Boardman stated the Limitorque operators manual being used on site had not been validated.

l

1 l

N NRC Exit Interview Notes

" Review of Open SCD's" Inspection 84-25 Page 3 l

l 4.

1.

The lubrication manual has a list of items requiring j

lubrication and the valve operators are not listed. The lubricant being used is not identified.

I i

m.

Mr. Boardman stated when conflicts were identified in the l

manuals he could not find where it was being referred to the j

manufacturer for resolution or correction.

I l

S.

Mr. Boardman finished his section of the meeting by stressing his l

concerns which were:

i s.

The control of Technical Manuals on site.

i

)

b.

Not following the Technical Manual in work practices as in t

J using the wrong lubricant and overlubrication.

)

c.

The use of uncontrolled technical manual in work practices.

1 1

d.

No maintenance being performed, he stated maybe Ebasco is l

performing maintenance for LP&L.

I WMM:ARRtVBR l

i cc R. S. Leddick, R. P. Barkhurst, F. J. Drummond, T. F. Gerrets, j

.j D. E. Dobson, N. S. Carns, L. F. Stors, S. A. Alleman, L. L. Bass, 3

J. N. Woods, R. F. Burski, C. J. Decareaux, R. A. Iyengar R. S. Savoie, j

M. I. Meyer, M. J. Wise, R. W. Lailheugue, H. I. Williams, Jr., T. Smith, B. Marshall, O. D. Hayes, D. Clark, R. W. Prados, Z. A. Sabri.

[

j W. J. Baldwin, Licensing Library, Project Files, Nuclear Records i

NRC - G. L. Constable. T. A. Flippo l

3 i

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((8d g g 'D DOCUMENTATION OF W

M TELEPHONE COMMUNICATIONS

/

DATE:

s ne.=her 27. 1984 TIME:

9:20 A.M.,

R2MI v

PARTT CALLING: C.E. Wuller/D.W. Herrin

)

LP&L (Licensing)

(Name)

/

(Company)

PARTY ANSWERING:

John Boardman NRC (Region IV)

(Name)

(Company)

SUBJECT:

LP&L Response to Violation PILE:

3-A20.27 8425-01

~

SUMMARY

(INCLUDING DECISIONS AND OR COMENTS)

LP&L returned Mr. Boardman's (NRC) call to discuss questions he had concerning Violation 8425-01. These questions, along with any LP&L reply, are outlined in the attachment to this ferm.

1 l

ACTION REQUIRED:

Provide input on questions 4, 6, 7, 8, and 10 to Mr. Boardman on Monday 10/1/C4.

DISTRIBUTION: r.u. cank n.M. Neinen. L.F. Storr. J.R. McCaha, R. Seidt, 2

n. uf11(a. M. Triere. C. Bryan. Protect Files, Administrative i

Support, Onsite Licensing Files foM-dY2.06 61s

1.

NRC:

Is 11/15/85 the date when the VETIP will be finalized at Waterford 37 LP&L: Yes.

(Portions of the VETIP have already been implemented).

2.

NRC:

Is 4/30/85 the date when evaluations of all deviations from vendor recommendations, as prescribed in vendor manuals for safety-related and environmental qualified equipment, will be complete?

LP&L: Yes.

3.

NRC: On page 3 of 10. item #2. top of the page, contains a typo.

11/30/84 should be 11/30/82.

LP&L: Noted.

4.

NRC:

How many more " uncontrolled" nanuals were issued without completion of an " Uncontrolled Document Request Form"? What mechanism existed prior to issuance of PMP-0027 LP&L: Action required.

5.

NRC: Of the 638 vendor manuals with access numbers greater than 457001259 79 are related to Ebasco purchase orders.

How are the remaining 559 vendor manuals being reviewed and controlled?

LP&L: A special task force will review and approve those 559 vendor manuals utilizing the guidance contained in PMP-306. as appropriate.

6.

NRC:

If vendor manuals are not designated as " safety-related" or "non-safety related." what prevents someone from using a "non-safety-related" vendor manual for maintenance on a safety-related piece of equipment?

LP&L: Action required.

7.

NRC:

Did-CE issue a document similar to a CE ADP Infobulletin prior to 19787 If so, they should be reviewed.

LP&L: Action required.

8.

NRC: The LP&L response did not mention resolution of the fact that ME-4-811 referenced Okonite Bulletin 776 which could not be located in the document access system.

LP&L: Action required.

9.

NRC:

Page 7 of 10, item 4.a.6.5 mentions Chevron 011 instead of Chavron Crease.

LP&L:

Noted.

10.

NRC:

LP&L's response concerning CMI #174 is not clear. Was the purging ever performed? Was Mobilux EP-2 grease or Mobil SHC-32 used to purge the Chevron SRI-2 grease? What is presently in those actors?

LP&L:

Aciton required.

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11.

NRC:

Page 8 of 10. item #4 under full compliance dates - During review of deviations from vendor recommendations LP&L should consider applicability 1

of 10CFR50.55(e) reportability.

LP&L: Handle reportability under the scope of PRD-180 unless specific case evaluation dictates otherwise.

(Note:

Mr. Boardman related his is intention to pursue this approach in further detail with Region IV management).

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--.._____ - _._,_,-__...,_,_ _._ -_,~.,

t DOCUMENTATION OF TELEPHONE COMMUNICATIONS 6

DATE:

October 1, 1984 TIME:

4:00 XE, n PARTY CALLING:

G.E. Wuller/D.W. Herrin 0

LP&L (Licensing)

(Name)

/

(Company)

PARTY ANSWERING:

J.R. Boardman NRC (Region IV)

(Name)

(Company)

SUBJECI:

LP&L Response to Violation FILE:t 3-A20.27 8425-01

SUMMARY

(INCLUDING DECISIONS AND OR CottfENTS)

REFERENCE:

Telecon dated 9/27/84 between G.W. Wuller/D.W. Herrin and J.R.

Boardman (NRC).

As a result of the above referenced, telecon, LP&L was asked to provide additional input on five (5) of the initial questions Mr. Boardman had concerning violation 8425-01. Four of those five (5) questions (numbers.4, 6, 7 and A) are addressed by LP&L via this telecon. The restated questions and LP&L's input are attached.

1 1

4 i

t ACTION REQUIRED:

1 i

Provide input on question #10 by 10/3/84 l

DISTRIBUTION:

K.W. Cook, R.M. Nelson, L.F. Storz, J.R. McGaha, R. Seidl, B. Willis, M. Triggs, R. A. Savoie, H. Canavier, Project Files, Administrative Support, Licensing Library, Onsite Licensing Files l

w --. -

i.

4 N3C:

How many more " uncontrolled" manuals were issued without completion of an " Uncontrolled Document Request Form"? What mechanism existed prior to ' issuance of PMP-0027 LP&L:

PMP-002 was issued apprcxima.tely three (3) months ago and Document Control personnel were required to read and sign of f on the procedure.

The case sited in NRC Inspection Report 84-25 is considered to be the exception rather than the rule.

(Subsequent to this inspector observation, Document Control personnel were reinstructed on the requirements of PMP-002.)

Prior to issuance of PMP-002, UNT-4-007 addressed the issuance of uncontrolled vendor manuals.

UNT-4-007 only required that a check-out card and simple request form be filled out.

No justification for uncontrolled vendor manual issuance was required.

NRC:

Be careful that spare parts are not ordered from uncontrolled 4

vendor manuals.

6.

NRC:

If vendor manuals are not designated

  • as " safety-related" or "non-saf ety-related," what prevents someone from using a "non-saf ety-related" vendor manual for maintenance on a " safety-related" piece of equipment?

LP&L: The Maintenance Department CIWA work package planners consult i

various controlled cross-ref erence listings to determine which vendor manuals are specified in the purchase order for the piece of equipment to be worked on.

AMaster Equipment List is currently being developed which will directly cie a Unic I.D. number to' the associated purchase order and correct vendor manual. This effort should be complete in approximately one (1) year.

7.

NRC:

Did 'CE issue a document similar to a CE ADP Infobulletin prior to l

19787 If so, those documents should be reviewed.

i LP&L:

In a telecon between LP&L and Mr. George Hess (CE), it was verified that CE issued API-17 " Reporting of Safety Hazards" on 7/6/77 to address 10CFR21 concerns.

In early 1978, the ADP Program was initiated to provide a formal means to inform utilities of reliability problems. Prior to this time, CE issued advisories on an ad hoc basis through CE engineering / project offices.

Retrieval of this ad hoc information would be very difficult.

{

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l 8.

NRC:

The LP&L response did not mention resolution of the fact that HE-4-811 referenced Okonite Bulletin 776 which could not be i

located in the LP&L document access system.

LP&L: Okonite Bulletin 776 has been deleted f rom ME-4-811.

This bulletin dealt with environmental qualification of Okonite products and did not belong in ME-4-811 as a reference.

Drawing LOU-1564-B-288, sheets 34, 35, 36, 37, 38C, 38C-1 and 39, whic!. is referenced in ME-4-811, provides instructions on how to use Okonite products.

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____. _.. _. _. _ _., _.. _,. ~... __ _ _, _,, _ _

4 DOCUMDITATION OF i

TELEPHONE COMMUNICATIONS DATE:

October 3, 1984 TIME:

12:45 g, g

?

PARTY CALLING:

G.E. Wuller/D.W. Herrin ~ M()LP&L (Licensing)

(Name)

(Company)

PARTY ANSWERING:

J.R. Boardman NRC (Region IV)

(Name)

(Company)

SUBJECT:

LP&L Response to Violation FII.E.

3-A20.27.

8425-01 i

I SUMMART:

(INCLIIDING DECISIONS AND OR COMMINTS)

TelecoA ated 9/27/84 between G.E. Wuller/D. Herrin

REFERENCES:

1) d and J.R. Boardman (NRC) g

2) Telecon dated 10/1/84 between G.E. Wuller/D.W. Herrin and J.R. Boardman (NRC) l Ao required by Ref erence 2, LP&L provided input to question #10 of Reference 1 to Mr. Boardman. That question (restated) and LP&L's input are attached.

ACTION REQUIRED:

1 None DISTRIBUTION:

K.W. Cook. R.M. Nelson, L.F. Storz, J.R. McGaha, R. Seidl,

8. Willis, M. Triggs, R.A. Savoie, H. Canavier, Project Files.

Administrative Support, Licensing Library, Onsite Licensing Files

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10.

NRC:

LP&L's response concerning CMI #174 was not clear. Will the lubrication frequency and method of lubricating the contain -

ment cooler fan motors be revisited?

LP&L: As mentioned in LP&L's response to violation 8425-01, LP&L will perform an evaluation of deviations from vendor recommendations contained in vendor technical manuals. Additionally, the environ-mental qualification of the containment cooler fan motors containing Mobil SBC-32 grease is under evaluation by LP&L.

NRC:

Be careful that the vendor who actually environmentally qualified the equipment is contacted for deviations from vendor recommenda-tions. Be sure to consider the legal aspects as well as technical aspects of environmantal qualification.

1 1

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LOUISIANA P OW E R & LIG H T/ INTER-OFFICE CORRESPONOENCE EUdvs$

May 21, 1984 W3K83-1210 Q-3-A35.02.01 TO: Distribu ion h

NV FROM:

W. M. Morgan /

Nuclear Operations Quality Assurance Manager

SUBJECT:

Waterford SES Unit No. 3 Exit Interview Notes NRC Review of Significant Construction Deficiencies (SCD) dnspectiongRsporte84-24c May 14-18, 1984 NRC Ebasco LP&L G. L. Constable A. M. Cutrona R. P. Barkhurst 6 ppo M. R. Harris L. F. Storz W. A. Crossman J. Pertuit T. F. Gerrets J. E. Gagliardo K. O'Gara J. Woods T. F. Westerman S. A. Alleman H. D. Chaney W. M. Morgan J. E. Bess L. L. Bass R. E. Hall J. B. Perez J. R. Boardman R. M. Gimelli C. N. Hooper J. Somsel R. J. Bentley W. J. Baldwin

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T 3' p NRC EXIT INTERVEEW NOTES g

SIGNIFICANT CONSTRUCTION DEFICIENCIES Inspection 84-24 1.

The inspection was conducted by Messrs. R. Hall, J. Boardman, and J. Bess on May 14-18, 1984.

Inspection report will be 84-24, 2.

The following SCD's were closed (13).

SCD Bingham Williamette Emergency Feedwater Pumps SCD RCB Linear Plate Nuclear Coating Failure SCD G.E. 480V Switchgear Trip Coils Do Not Drop Out SCD T&B Undersize Schedule 80 Socket Welds SCD Heat Tracing Deficiencies Identified During HFT SCD 3A-S Safety Inverter Out Put Capacitor Wiring Burned SCD High Pressure Safety Injection System Performance SCD CVCS Heat Trace Temperature Drif t SCD EPSI "A" & A/B" Failed to Start on a SIAS SCD-100 - GE Switchgear Terminations SCD-104 - Wiring Errors Discovered During Pre-Op Testing SCD-106 - Bonney Forge Part 21 SCD-110 - GH Bettis Actuators Part 21 PRD 157 - Spawled concrete was closed.

3.

The following SCD's remain open.

SCD Same as 84-17 status SCD Still reviewing SCD Seismic Qual of relay - wrong wiring - ppplication of coil.

SCD Procedure control for technical manuals - maintenance procedures and greasing, alignment of motor to pump.

WMM:CNH:VBR cc:

R. S. Leddick, R. P. Barkhurst, F. J. Drummond, T. F. Gerrets, D. E. Dobson, N. S. Carns, L. F. Storz, S. A. Alleman, L. L. Bass, A. D. Jones, K. W. Cook, J. N. Woods. O. D. Hayes, D. F. Packer, W.'J. Baldwin, Licensing Library, Central Records, Nuclear Records

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UNITED STATES f g. J ";

NUCLEAR REGULATORY COMMISSION

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July 26, 1984 Docket No. 50-382 APPLICANT: Louisiana Power and Light FACILITY:

Waterford Unit 3

SUBJECT:

SUMMARY

OF JULY 10, 1984 MEETING A meeting was held between the NRC Staff and Louisiana Power anc Light (LP&L) representatives on Tuesday, July 10, 1984 at the Waterford Steam Electric Station, Unit 3 site.

Also attending the meeting were representatives of Muenow and Associates, a consultant to the applicant and EBASCO Services Inc., the Architect engineer.

A list of attendees is included as Enclosure 1.

The purpose of the meeting was to discuss LP&L's proposed program for the non-destructive examination of cracks in the Waterford 3 common foundation concrete basemat. The program was presented to the staff by R. A. Muenow of Muenow and Associates who will be performing the non-destructive microseismic evaluation of the concrete using the pulse echo method.

The program will define the vertical extention of East-West cracks located at the top of the mat including those beneath the reactor building.

In addition, one NE-SW crack, northeast of the reactor building and one f4W-SE crack, northwest of the reactor building will be examined and evaluated.

The examination will attempt to define crack depth, width, length, orientation, and proximity to, or linkage with, other cracks in the lower portion of the mat.

It is expected that the examination of the cracks and the evaluation of the collected data will take approximately three weeks. At that time LP&L and their consultant Mr. Muenow will present their findings to the staff.

Their report will include the effect of the findings on the basemat design assumptions, and any corrective actions required.

The staff will review the data prior to making a safety determination of the mat's integrity.

Lisamarie Lazo, Pro.)ect Manager Licensing Branch No. '

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i UATERFORD BASEMAT fide PP.0 GRAM MEETING July 10, 1984 ATTENDEES NRC L. Lazo D. Crutchfield J. Pta 3

'Mitabith, T. Flippo APPLICANT K. Cook, LP & L T. Gerrets, LP & L R. Leddick, LP & L D. Dobson, LP & L R. Burski, LP & L R. Bagnetto, LP & L P. Liu, Ebasco N. Hasan, Ebasco A. Wern, Ebasco R. fluenow, Muenew & Assoc.

T. Hedgecoe, Fuenow & Assoc.

P O W E R & Li G H T! P o box 6000

  • NEW ORLEANS LOutSIANA 7017 8 142 OELARONDE STREET

. (504) 366-2345 UTiuT:ES SVSTEM September 6, 1984 EDe>3 W3F84-0151 3-A45 Mr. J.T. Collins Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

SUBJECT:

Louisiana Power & Light Company Waterford 3 SES NRC Finding 8308-118

REFERENCE:

Telecon on July 25, 1984 between Paul Backes and Charles Hackney

Dear Mr. Collins:

This letter addresses the August 24, 1984 completion date for the NRC emergency preparedness appraisal finding item 8308-118, operator walk-throughs of.the Radiation Monitoring System. The walk-throughs have been completed for all operators. The walk-throughs were completed prior to August 24, 1984 with the exception of one operator who, due to an unavoidable conflict between the training schedule and his vacation, did not complete the training until August 30, 1984.

Very truly yours, fl 7

e K.W. Cook Nuclear Support & Licensing Manager KWC/ASL/mim i

ec:

W.M. Stevenson, E.L. Blake, b. Churchill, L. onstable

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