ML20137U653
| ML20137U653 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/02/1984 |
| From: | Crutchfield D NRC |
| To: | Harrison J, Shao L, Thatcher D NRC, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17198A272 | List:
|
| References | |
| RTR-NUREG-0787, RTR-NUREG-787 NUDOCS 8510030201 | |
| Download: ML20137U653 (1) | |
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s LOUISIANA / w e-e swer e aO eax ease POWER & LIGHT / NEW CFMANS LOUSANA 70160 e [=c41595-2204 MIDDLE SOUTH UTIUTIES SYSTEM J.M. CAIN President and Chief Executive Otticer June 28, 1984 W3B84-0449 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Program Plan for Resolution of Pre-Licensing Issues
REFERENCE:
NRC Letter Dated June 13, 1984, Docket No. 50-382.
Dear Mr. Eisenhut:
Louisiana Power & Light has established a major program, with significant commit =ent of management resources, to address the issues raised in your letter to me of June 13, 1984. I am enclosing for your information a program plan which describes the organization of our new program and the methods of approaching resolution of the issues you have raised. Key to our program is the designation of an outside, highly qualified Task Force to assist in the development of our plans for resolution and to independently assess the adequacy of the resolutions and their safety significance. The Task Force will consist of Larry L. Humphreys President, UNC Nuclear Industries, Inc., Saul Levine, Vice President, NUS Corporation, and Robert L. Ferguson, Chairman, UNC, assisted by suitable UNC and NUS personnel. The Task Force will independently review LP&L's proposed resolution of the matters, and will report directly to me. Formal reports to me will be simul-taneously provided to you. The Task Force's charter is set out in my June 20, 1984 letter to the Task Force, enclosed. We have also designated a top management team dedicated to resolution of the issues and administration of our program. The team is headed by Dale E. Dobson, Waterford 3 Project Manager, reporting directly to R.S. Leddick, Senior Vice President - Nuclear, and includes management involvement of the plant operational staff. I will be personally and directly overseeing the program
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Mr. Darrell G. Eisenhut June 28, 1984 W3BS4-0449 Page 2 In addition, the resolution of the issues raised by your staf f will be reviewed by the Waterford 3 Safety Review Committee (SRC) through a special subcommittee consisting of Kenneth W. Cook, LP&L Nuclear Support and Licensing Manager, ' Chairman; Joseph M. Hendrie, Consulting Engineer; Robert M. Douglass, Manager of Quality Assurance, Baltimore Gas & Electric Company; Raymond F. Burski, LP&L Engineering and Nuclear Saf ety Manager; and Thomas F. Gerrets, LP&L Corporate Quality Assurance Manager. You can be assured that LP&L is totally dedicated to achieving the highest level of safety achievable in the plant, and we take very seriously the matters you have set out in your letter. I do not intend to request a fuel loading / low power license, or a full power license, until I am personally satisfied that all issues necessary for those phases of plant operation have been satisfactorily addressed to assure the public health and safety. You have my personal assurance that necessary programmatic and management changes arising from our program to resolve these issues will be immediately and effectively implemented. The attachment to the program plan listing the LP&L approach to resolution of the individual issues has not yet been reviewed by the Task Force or the SRC, and is subject to modification as a result of reviews by those groups and your staff. The plan is intended to provide an early and high level of confidence in the successful resolution of the issues and concerns yod have raised. I welcome your comments and suggestions. Very truly yours, b t J. !!. Cain
Enclosures:
As Stated cc: With
Enclosure:
See next page w
Mr. Darr:11 G. Eie;nhut, Director Page 3 W3B84-0449 June 28, 1984 cc: R.S. Leddick Waterford 3 D.E. Dobson Waterford 3 Les Constable Waterford 3 Saul Levine NUS Corporation 910 Clopper Road Gaithersburg, MD 20878 Robert L. Ferguson UNC Nuclear Industries 1200 Jadwin, suite 425 Richland, WA 99352 Larry L. Humphreys UNC Nuclear Industries P.O. Box 490 Richland, WA 99352 J.T. Collins U.S. Nuclear Regulatory Commission Region IV Arlington, Texas 76011 Dennis Crutchfield U.S. Nuclear Regulatory Commission Washington, D.C. 20555 'N George Knighton, Chief , Licensing Branch No. 3 Division of Licensing Washington, D.C. 20555 Cerald Charnof f Shaw, Pittman, Potts & Trowbridge 18 00 M. S t. N.W. Washington, D.C. 20555
/ June 28, 1984 WATERFORD 3 PROGRAM PLAN AND SCHEDULE I. INTRODUCTION AND PURPOSE This Program Plan outlines the methods by which the 23 in-dividual issues described in the NRC letter, Docket No. 50-382, dated June 13, 1984, are to be resolved by LP&L. Further, the Plan.provides a mechanism to address the cause of the issues, the generic implications and collec-tive significance of the issues, and the programmatic and management changes designed to preclude recurrence of such issues. The Program includes the establishment of an in-dependent Task Force to advise LP&L and evaluate LP&L's resolution of the issues, and separate review of the reso-lution by the Waterford 3 Safety Review Committee (SRC). II. PROGRAM PLAN MANAGEMENT 1. The LP&L Project Manager - Nuclear is assigned re-sponsibility for management of the overall Plan and actions outlined in paragraphs III and IV below. He will perform these tasks in a normal line management role and have access to and the support of any requi-site LP&L and contractor managers and staffs on a top priority basis. He will assure effective interfaces with external groups including the SRC and the UNC/NUS Task Force described in paragraph VI below. 2. The Project Manager-Nuclear reports directly to the Senior Vice President-Nuclear, who in turn reports directly to the President and Chief Executive Officer of LP&L. Both the Senior Vice President-Nuclear and the CEO are directly and actively involved in the management of the Program. III. RESOLUTION OF ISSUES 1 1. Each issue will be analyzed to determine: The cause i q The generic implication ,, j..i. i.-- ] Y O h$ h,
The actions and schedules to correct both the specific problem and related generic concerns The safety significance with respect to fuel load and low power operation, and to operation above 5% power 2. The intended manner in which each of the 23 issues are to be addressed is described in Attachment 1. It should be noted that the manner of resolution may need modification as actions necessary to resolve any related safety concerns are undertaken. IV. COLLECTIVE SIGNIFICANCE AND PROGRAMMATIC CHANGES As early as feasible in the process of formulating the in-formation contained in paragraph III above, the LP&L Proj-ect Manager-Nuclear will: t 1. assess the collective significance of the indi-vidual issues, and 2. recommend institutional or programmatic changes ~~ deemed appropr.iate to avoid recurrence of the types of problems underlying the issues being addressed V. SAFETY REVIEW COMMITTEE 1. The Waterford 3 Safety Review Committee (SRC) has designated an SRC subcommittee to review the items outlined in paragraph III and IV above. 2. The SRC subcommittee consists.of Kenneth W.
- Cook, LP&L Nuclear Support and Licensing Manager, Chairman; Joseph M.
Hendrie, Consulting Engineer; Robert M. Douglass, Manager of Quality Assurance, Baltimore Gas and Electric Company; Raymond F. Burski, LP&L Engi-neering and Nuclear Safety Manager; and Thomas F. Gerrets, LP&L Corporate Quality Assurance Manager. VI. INDEPENDENT ASSESSMENT 1. An independent assessment of the renclutions and de-termination of safety significance will be provided by a Task Force reporting directly to the CEO of LP&L. The Task Force consists of officials of UNC i Nuclear Industries, Inc., Richland, Washington, and ' l
NUS Corporation, Gaithersburg, Maryland, who will be assisted by UNC and NUS staff members, as required. The Task Force will independently assess LP&L's reso-lution of the issues, including the cause, generic implications and collective significance of the is-sues. The Task Force will also provide advice and assistance in the resolution of the issues, and will provide an independent assessment of the safety sig-nificance of the issues with respect to fuel loading and low power testing, and operation above 5% power. It will assess the adequacy of LP&L QA/QC program in light of the NRC's iscues, and will recommend any in-stitutional or programmatic changes which may be nec-essary to prevent recurrence of the issues. 2. The charter, identification of principals, initial functions have been formalized, as specified in At-tachment 2 hereto. VII. RESPONSE TO NRC The individual issues vary considerably in both the degree of concern and complexity of resolution. Therefore, LP&L intends to forward to the NRC the proposed resolution data individually or in packages as they are completed and have undergone the degree of review specified herein. Some of the resolutions may be submitted before completion of all requisite corrective actions, which are underway or de-fined and scheduled for accomplishment, have been accom-plished. Upon submittal, each resolution will be added as Appendix A of the Program Plan to constitute a major part of the final report. VIII. SCHEDULE Attachment I lists the target dates for Project Management completion of resolution data on each issue. These dates include a period of time Project Management has scheduled for completion of its review and that of by the SRC and Task Force, although these dates are difficult to predict. Target dates for development of the collective signifi-cance of the issues and recommended programmatic changes outlines in paragraph IV above are to be established by July 6, 1984. I I PROCHAM Pt.AN CUkRENT ASSESSHENT OF SAFETY 31GN I FICANC E ISSut' & TI TI F. IIESCRIPTION OF ISSUE 1.P&l. APPROAril TO HFSOI.UTION DATE NONE FL TO %% >%% .IllSTI FICATION
- 1. Insicction Verify the proper
- 1. Pal. will verify 7/10 A preliminary evaluation of the Personnel certification of site the credentials of QA managers.
T-B and Hercury QC in spec t r,r s issues QA/QC personnel or supervisors and personnel certitying questioned by the NRC tudicated requality the work inspectors, and auditors. they were qualified and performed by these certified to perform their personnel. . assigned wosk function. ~ A verification of the certification ut It is important to note that the approximately 20% of all.yC inspectors inspectors for the major is being done to assess the salety installers of saf ety related significance of the concern. A equipment and systems (e.g., description of the certification Tompkins-Beckwith, Fischback & criteria (ANSI N45.2.6-1973), as Moore, Mercury, NISCO, American required by the Quality program. Bridge, J. A. Jones, and Culf) and a mat ris showing certification 3.crformed no non-destructive and supporting documentation will testing (NDT). NDT was provided be prepared. Further efforts, including by CEO. any necessary reinspections, will be based on specif ic prohlves and root cause An audit was performed on all analyses and will be as necessary to contractors performing safety verify the adequacy of the program and related work. An assessment of compliance with the program. the current audit results, which do not include American Bridge For the yC inspecturn, remaining onnite, and CE, inditate QC personnel a reveriiltation of proper certification were qualified and certified. in accordance with ANSI N4%.1.6-1971 is Additional bachup information being accomp!!shed. has been requested from CE and American Bridge to complete the Quality Control inspections currently evaluation. The preliminary being undertaken as part of other results of the audit are listed programs will be perturmed by yC beluw. personnel reverified as qualitied under 1. CEO (NDE) - 25 sampled /23 ANSI N4%.2.6-1971 qualliied r 2. Waldinger - 5 sampled /5 qua1itled 3. R&B - 8 sampled /8 qualified 4 Sline - 55 sampled /15 qualliicd um
Pkt N; HAM l*l.AN CURNENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSilE & TITLE DESCRIPTION OF ISSDE I.P&l. APPHOACil Ttt kEMil.IITION DATL NONE FL 'lO 5% >%Z .!USTIFICATION 2. Hissing NI instrument Verity compliatice with I. PSI,will review all NI instrumentation installed 7/6 To date, 90 locally 1.Ine Dotumentation NRC requirements for Ni during the period when class breaks were allowed mounted NI instruments instrumentation (prior to April 1, 1982), identity required have been identified installations. documentation to denenstrate correct installation as being installed and inspec t ion, and ident if y the documentat ion prior to April 7, 1981. available. A QA review of all safety-related NI To date, using ASHE Ill inst rumentat ion systeins has been per t urmed which documentation criteria vertiled that all trustallat ions we re pauperly as a basis f or compari-documented and inspected. son, full or partial compliance can be shown for the 12 installatton at issue. Of the remaining installations 3% had no class breaks, 19 were thermocouples with no tubing, and 24 had been reclassiited to N2 (i.e. not required for safe shutdown).
I ~ pnuGH AM pl.AN CtfRPFNT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITIE DESCRIPTION OF ISSUE I pA!. APPROACH 10 HESOI.llTION DATE NONE Ft. TO %1 7 1 .it!STI FICATI ON ). Instrumentation Correct separation NCH-W1-1702 covers the system 52A psoblems 7/11 The walkdown to date Expansion Loop cuiteria violations and has been dispositioned to remove the represents approximate-Separation found in system 52A and expansion loops in question thus solving ly 20% of the installa-provide. program for the problem. tions to be walked down review of other safety-and the amount of related violations and NCR-W1-1710 was generated to track the generic rework being identified take the necessary concern. In order to provide some basis for has been found to be corrective actions. determining the scope of our program, a sample very mine,r (i.e. three of St instrument installat' ions were thosen for feet of tube track review in area of congestion, and walkdowns of cover). If the issue these lines were done. Thirteen violations were had gone undetected found out of 276 locations. although unty one it would not have been required rework. It was decided to perform a QC likely to cause a verification of all lines wl cre the redundant safety concern, tubing was run together and take the appropslate action. An interim response discussing the resolut ion of NCR-W1-1702 items and the status ot NCR-W1-1310 reinspections will be provided as well as a schedule for completion of the reinspecttuns. / u
5 PkoCRAM Pl.AN CURRtNT ASSESSMENT OF SAFFTY SIGNIFICANCE I SSill & TITI.E Di.SCRIPTION OF ISSHE 1.P&l. APPROACH 10 Rtsol.HTION DATE NONE Fl. TO %Z >%% JUSTIFICATION 4. Lowe r T ie r Co r r ec t ive t.P&L shall review all LP&L will review the lower tier document reporting 1/9 Based on the current Actions Are Not Being FCRs DONS, EDNs, and system to ensure it was sttuctured in such a review, LP&L expect s to Upgraded to NCRs T-B DNs to a,ssure that manner that procedures, integral to the Quality demonstrate that there proper corrective Program, provided a sound basis f or decisions re-has been adequate QA/QC act ion was tak en, garding the severity level of documents used to involvement in all including an adequate report deficiencies. The seview will s.pecifically lower tier documents r eview by QA. This consider QA and QC reviews of engineering / with regard to IOCFR50, corrective action tehall construction judgements on delicicucles ag it Appendix B corrective include the steps sclates to the corrective action and noncon-action and non-conform-required by 10CFR%U, tuumance requirements of lu t.FR %O Appendix B ante requirements. Appendix B. Cr iterion and the reporting requirements of 10 CFR 50.5%(e). This involvement is Kyl Corrective Action expected to show that and los t'onstruction The response will include an assessment appropriate corrective De f ic ienc y Repor t ing, et all the lower tier documents specifically actions, specif ic and %O.%%(e).
- Also, cited by the NRC to verity tlie.adequary of the generic, are identified included in this review proceduvalized sategnards in assuring that shall be the deliciencies with safety significance are Our currect evaluation examination of imptoper being properly dispositioned and reported.
of the examples of voiding of all other There will also be an assesr. ment of improper lower tier documents design changes or voiding. cited by the NRC demon-discrepancy notices strates that although a that affected 3,efety-small percentage should eclared systems or t h.i t have been upgraded to were misclassified as NCR's under the quality
- salcty, program in effect, none had adverse safety significance.
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j l'RIERAM l't.AN CUHktNT ASSESSHENT OF SAFFTY SIGNIFICANCE ISSUr & TITI E DESCRIPTION OF ISSt!E I P&l. Al'PROACH TO RFSol.!! TION DA1E NONE FL TO 5% >%% .lUSTIFICATION
- *. Vendor Documentation The concern relates to A problem did exist with foreul tratking of 7/13 The CE records and Condit ional Heleases whether shortcomings in Combustion Engineering Conditional Certific.itions other records with the cont ac t or 's documen-of Equipment. Herords a. soc iateel wit h CF. mat er ial exception of JA Jones tation which existed at and equipment will be r e-r ev iewed an<1 t ondit ional and Waldinger have been the time she materl.at ce s t if icat ions will 1:e ident it led and prompt l y reviewed.
To date 8 of was supplied have been resolved. Control of CE material.nid equipment 14 CE conditional cert-corrected. differs f rom that of othen cont r.se t or s. In order ifications have been to verify that a similar problem does not extut changed to uncondit-in the case of other contsactors, a sample audit of ional. No items other critical purchase osders will be perf ormed. affecting plant safety if the sample audit identities any other problems have been identified' with the handling of contractor material teleases, in any of the completed additional reviews will be initiated. reviews and dispo-ultions. e# f m
l'k(CNAH plan CUkkENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TlTI E 11ESCRIPTION OF ISSUL
- 1. pal. APPROA011 To HI Sul OT ION DATE NONE Fl. TO %% > %Z JUSTIFICATION ti. Disposittening ut L ee Fbasco.ind Hercury F i r s.t. the inplate progr..m for handling of lower 7/13 To date, the NCRs Non-conformance and NCNs ami Ihasco DRs tier documents such as I)Rs will be discussed.
cited by t he NRC have Disc u cpanty Rep..r t s were question 4hly dis-been evaluated. Five positioned an.I LP&L Secund, the specif ic NCRs and DRs cit ed by the of the 49 are being shall propose a program NRC will be evaluated for proper designat ion. further evaluated. to assure all NCks and disposition, and implementation of correttive Three impact hardware DRs are appropriately actton under the existing (Juality program, and two software. The upgraded, adequately balance have been shown ~ dispositioned and Third, a review of all NCRs was e.t arted by IP&L to be adequately dinpo-corrective attion in Janua ry to assess t he va lidit y of the dis-s i t i one d. The overali completed and that any position. the corrective. action taken, the com-review of NCRs has problems detected. ire pleteness et the document.ation and proper closure. been completed with corrected. the exception of Fmarth, a field verification will he conducted on approximately 300. This one hundred randomly selected NCHs to ensure the review showed 416 of connettive action resolve.1 the nonconformance. the total 71%0 NCRs were questtoned. 8%% If any problems are detected from ti.csc steps, a of these deficiencies plan of further correttive action will be estab-were documentation re-
- Iished, lated and were not significant. The balance will be closed.
To date 12 of 100 NCRs have been fteld we r i i 1: d. No con-clusions have been drawn as of yet. N @W l I
.j l'Hos. NAM PI AN CUkktN1 ASSISSHENT OF SAFETY SIGNIFICANCF 15S00 6 Tilt.E DISCRIPTION OF ISSUE I P&l. APPROACil 10 RtSul.UT ION DATE NONF Fl. 10 51 p%I . JUSTIFICATION 7. nat61til Soll Conduct a review of all The I acklill records are t.cing reviewed f or 1/11 The effect of any pos-Denstates soit packages for complet ion and t echnical adequat y, record packages tulated variations iis completeness acid are being located and.any t ec hn i c.e l issues will be density in the fill is technical adequacy. ev.a l ua t ed. not of u ly,n i f icanc e Where records.ame relative to the missing or t e c hn ic.a l seismic response of problems are detined, the plant as designed. take torrective action. in addition, should there be a few missing records, a satisfactory demonstration of the quality of the backfill w!Il be provided. 4 V N @W
I'ktnGNAM PI AN CtlNRENT ASSESSHFNT OF SAFETY S10NIFICANCF. ISSUf' & TITLE DFSCHIPTION OF ISSilE I. Pal. APPkOACH To kESOI.tiTION I) ATE NONE Fl. TO %Z >%% .j tlST I FICATION 8. Uisual Emanination Document inspections LP&L will provide documentation vertlying that 1/6 Investigations to date of Shop Welds during of shop welds during shop welds were inspected by <pulifiol show that shcp welds flyJrostatic Testing hydro tests or other-inspectors. were inspected and wise verify such accepted during inspection. hydrostatic tests by an Authorised Nuclear Inspector as demon-strated by reports. The ASHE N-$ code da ta reports also confirm that there was e inspection of shop welds. The methodology of clie field hydro-static tests provide additional qualifica-tion of testing. Documentation on the above will be provided. T 4 N R+N w.
l l'huGRAM l't.AN Ct!WRENT ASSESSMENT OF SAFETY SICNIFICANCE ISSUt & TITLE DFSCRirTitu et ISSt1E I Pal APPROACH 'to kFSOlUTION DATi. NONE Fl. To %% >%Z JUSTIFICATION 9. Welder Certilitation Iocate elusing ducuments NCR W1-7%49 v.as generate.1 on 1/4/H4 to track tiets 7/20 All welding evaluated for instrument cabinet problem. No documentation w.ss f oumi on three of to date has been found welds and determine if the eighteen cabinct= and partial documentation acceptable. welders were appro-found on four. All seven were reinspected and priately certified, found acceptable. Take appropriate action to assure the quality As a result of the missing documentation, a of the supports if review la being per f or me.1 to determine ot her documentat ion cannot miscellaneous cases wheir*lones performed welding. be located. Documentation for the welding identified will be reviewed. V%1 .lUSTIFICATION B0. Inspector Quall-Vecify the proper certi-A reassessment cf the adequancy of the program to 7/13 Preliminary evaluations itcation (J. A. fication of QA/QC certif y inspectors will be perf ormed for et J. A. Jones QC per-Jones and Fegles) personnel and evaluate approximately 201 of all QC inspectors to assess sonnel qualifications tlw impact of any the safety signtitcance of the concern. questioned by the NRC deficiencies fosnJ. Indicate they were Meere deficiencies are identified. Elw inspections qualilled and certified made by the subject QC personnel w!!! be reviewed to perform their and an evaluation made of the safety utgnificance assigned work function. with regard to design construction and operation. The sample size was The need f or additional corrective action will be twenty percent (20%). assessed as part of the safety evaluation. Nineteen of the 20 were qualified and one was-qualiiled pending i clarification. Additional backup l information was re. quested from Fegles to complete our evaluation. It is important to note that the inspectors per-formed no non-deatructIve g testing (NDT). NDT was provided by CEO. gs 4 ... v 9 g
. -.. -. - -. - ~. [ + a PRICHAM Pl.AN CUHWENT ASSESSHFNT OF SAFETY SIGNIFICANCE ISSUE & TITl E DESCRIPTION OF ISSUE t.l*41, APPROA83t 10 RESOLUTION DATE NONE Ft. TO %Z 252 JUSTIFICATION
- 11. C.sJwelding Provide the cadweld TI.e cadweld records will be transca thed onto 7/20 Prior reviews have data for the project in computer data storage including the placement already been accom-such a team that it can member, cadweld number, tear si re, bas position.
plislied under NCR be readily compared to visual inspection acceptance or selection. Wi-6214 and non-the testing criteria production splice tensile test acceptance or conf orming condit ions used for the W.etesford sejection, and mister splice tenulle tent resolved. 1 project with d.sta acttptance or sejection. broken down by various categories. Provide in this form the cadweld' data can be called up by data on welder quali-any of timese attributes to expedite review for fication and requali-specification compliance or oti.cr reason. Also, fIcation including physical location of cadwelds may then be readily dates. obtained by reference to ti.e concrete placement lift diagrams which locate the placements. Data on welder qualification and requalification will be gattnesed ami provided as part of this effust.
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a J 1*WiM;RAff I'l.AN Ct!RRtNT ASSESSMENT OF SAFETY SIGNIFICANCF IS;UV A TITIF IltSCRIPTle>N OF ISSUE I P Al. Arg'HOAc3l 7D RISHilfTitsN DATE NONE Fl. TO %2 )%2 nsyj p gg g
- 11. Nin Ste.emline Complete the document-SCD in was resolved and subsequent ly reopened upon 7/11 The saf ety significance t r aming If cat s.a s ut s
.ation for alt discovery that inspection > sn one area were not of not replacing the connections in the complete. MCH-WT-7 7 % i ssued to t r.as k resolut ion teolts which were steam generatur ir ming. of the deliciency. In onder to assure complete replaced is st ill undes resolution of this cont ein, l.I'&l. luit iated both a eva lu.s t ion.
- However, L0ut if. reinspection of steam genciator fr.eming the actual restraint tonnections as well as.e neview on the American hiructure is not needed lir idge work scope agaisest the scope of SCI) JH until the reactor reinspections to assure t h.st reinspections were generates power and complete.
therefore the bolting is not a constraint All connections were reinspected. kequiste bolt to fuel load or replacement and NCR closure is scheduled to be operations up to $1 completed by July 6, 1984. J power. / e l i
i I i l l l l I l PhnCRAM FLAN Clf kRFJ4T ASSE 51. MENT of SAFFTY SIGNIFICANCE tsst:E & TITit I4SCRII7 Beel or IsstrF t r&L ArrRuACit Tu kFSul tillON DATE NONE Fi. TO %Z * %1 JtiST I F IC ATI ON i l I I. Missing kCRs IFAI. shall obtain the i.P&L is conduc t ing a review of closed and voided 1/6 A review to date missing NCRs. emplain ihasco hCRs to determine it they are not properly indicates that only wiey these NCNs wese indemed and filed in the QA returds vault. five out of more than not m.aintained in t he 7500 site-issued NCRs. t iling sy stem, review The evaluation will identity att NCks, whi.t are which have been closed t hem f or prorer lau ttat ed as c losed ce voided by site QA tracking or volded, are not solding, and assure mec hanisms but not vaulted, and provide an expland-indexed and 'lled. Of t hat wl.en an issue is tion as to why they are missing, assure proper t he five NCRs which raised to au bCR. It voiding, and assure prorc's liling and tracking. have not been indexed is proper ly filed for and filed, it can be tracking and closure. A stellar evaluation is being cundua t ed on NCRs demonstrated that they which were issued by Ebasco QA in New York. apparently were never issued. Sufficient documentation is on file to demonstrate the acceptability of the safety-related items desc ribed in t he log entries corresponding to a lw se five NCR numbers. 1he review indicates ti.e problem stems from NCR track-ing syst em utilf red prior to mid-1979, and that sinre t hen t he in-proved kCR tracking system has been ade-quate. In addit ion the review indicated that there were thirteen number s t hat were ap-parently never assigned to an hCR. LP&L is in process of confirming that NCRs with these numbers were never issued. I
rka CRAM l'I AN LURutNT AssFSSMENT OF SAFETY SIGNIFICANCE 15500 & T11 Lt 14 SCu l rT I t
- UF I NSU E t rat. ArrROACil Tu al sol ullie tiATE NONE II. 10 %17%%
JUSTIFICATION 10. .l. A. Jones S ece,i 1%:r tng the it,asco qA First, a review laas been s onduc ted of corses-7/20 To date about 1100 letters and Llus review of I. A. Jones pondence between J. A. Jones.sest than.to via Speed pieces of JA Jones speed letteus anJ wng-let ters anJ Liks. correspondence have inneering inform.ation been reviewed and 271 sequests, several items Second. a review of sut te correspoeidence in whic h designs changes identi-t h.st could aftest plant design changes we re (ce.veyed to J. A. Jones willa-iled. Of these, 190 satety were noted. out relesence to follow-up action to form.etire the have been approved as Based on its sample of c h.eng r u is belig conducted to determine safety acceptable. 27 are the these ac t ions. a lie statt utgnilicance. subject of field does not espect that any invest igat ions to of these items mill Third, a mintanum sample of ten pestent ut tin f or ma l develop information for significantly affect documents such as. peed letters.ais! Elks by other evaluation, and the p lanet salety. contractors performing safety-related work wlao balance are under nevertheless, t lie app-utilized these type of doci.eents is Iming review. To date no I! cant al.owld complete conducted. The need t o rev iew.edd it iona l safety problems have the actions tJentitled documentat ion will be deter mined based sni the been defined that would in these s eviews and reseelts of this review. require sework. Issue. raised steall be resolved promptly. For other contractors, the review has shown that 8 of 42 Fegles. 3 et II9 Waldinger, and 2 of 660 T-B linf ormal document s could involve design N s.hanges. These reviews ase outntant tally \\ complete and evalu- .stions are in process.
r l t*ke u;R AM Pl.AN LUkktNT ASSFSSMENT OF SAFETY SIGNIFICANCE I SSI'I & TITt E DtSCRlrTION OF ISSUE I PSI APrkOACll TO kthulHTluN DATE NONE FL TO %% >5% JUSTitlCATION 1%. w;lding os "D" level 1.ocate the documentation Irst will conduct a review to cont t re that 1/43 The CB4I QA manual tt.a t e r i a l leside for "D" level material material and weld rod retorJs e n a s.: to establish requirements for t.cn t.a t uaie n t welding aant vertly the m.aterial control for all "D" m.eterial welds; documentation of fit-up adequacy of the ident 6 f y and wer it y t he eeetilication of all and iinal weld information or perform a weldcas. anJ; provide inspec t ion, procedures and inspections do not material asulysis and data as well as af fid avit= trom inspectors. apply to "D" material NDL work, or rewonk Documentation wi!! l.e tied to s.pecilic welds as welding although weld t he welds. auch as possible. This wi'l include identification in.spections were per-of "D" material welds an.5 - cos.pi lat ion o f : formed. The work was !) applicable CB&I "as l>ullt" drawing numbers; perlormed by the same
- 2) ide-nt if icat ion of we lds t.y piece mark numbers welders and inspected' and material type (i.e. D to D. D to B. etc.);
by t he same welding
- 1) quantitles f or repet it ious weld I.D.'s; supervisors to the
- 4) weld type and size. and; %) indic.ation as to same standard as the sluip or field welds. l.rSt. w i ll e v.a lu.et e t he results rest of the CB&l work azul de t e mine wlw a he r reinspes'tlons are required for which documen-and what the scope et such a reinspection will be.
tation is provided. This provides a high degree of conf leience in ti.e quality of the finh.hed work. Additionally very low raten of rejection in NDE tests and in inde-pendent hurvelllances and audits indicates high wo r k qualit y, $g (s 9
9 a l*Wtu. rut t'I AN LilkHENT ASSESSMENT OF SAf TTY SIGNIFICANCE ' i' f,
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i l l l 1 l l l l l l l l l l'Me LkAM l'I AN CURRENT ASSESSHl.NT OF SAFETY SIGNIFICANCE ISSUI & TITIF DFSCR i t" TION OF ISStf E I.F11. Art kOACH 10 RE Sol.UTisv1 DATE NONE Ft. 10 %I > %I JUSTIFICATION l li. v.=: W s t l ic..: t s.n os lhe hEt is concerned on 1he conc ern st ems owes a tie tact that a 1981 1/6 Initial reviews show l t a pas.s i..n Ans leor whether these wJs rewIhion of an tubpect ion f orm ehhas put Ilbt the that the requis$te Cha r..< t er i st is m. sutticient UC verifica-s equisite QC inspec t iam ar t e tt.ut es. Tlie initial charactertatics were j t ion of the charat ter-review of this matter indscates t h.s t the requisite part of the procesture istics neressary to W reviews were maJe as seguired 13y the drawings (incorporated by ensure proper lastalla-which accompanied the inspestion losas. This was drawings). This tion of concrete sut.stantiated by a tior m gh review of Mercury provides reasonable expansion an<horm quality records.
- l. Fat, w i l l p rep.o r e a responme amsurante that QC Installed by Mercury.
Jim (ussing the inc or porse l.we ut drawings into the ver i f ic.at ion was prosedure, t r a ining of Me r c u r y pe r moruie t. t tee QC adequate. Previously review and substantiation of retoids anJ a root there were 896 re-rause evaluation of the problem. Inspections made of installed expansion anchor characteristics to confirm records validity. l 1 N s l I l I Ii
l l PWth: RAM PIAM CURNINT ASSFSSMFNT tsF SAFETY SIGNIFICANCF. Isset & TITi t. LiF5fRIFTitiN 06 ISSUE t rat. APPROACH TO kt SULitT ated DATE NONE FI. To %I >%I JUSilFICATION ID. thwisewnt ar t em ..f Ibcusment.st &ose >J=.u l d t>e The s e sswen se t ee t ie t s a sse.c dis unes s i.e amanne r 1/'a T t.c design and b.sikJowns et Ann-prov ided t hat alcasty in which Jesign assJ inestat tat tem constJesed the construction of Safety Related staows what equigment effetts of interattions el sum-se i sm ic w ille salety-W,aterford-) considered t-qwigeem t was revlawed Jur ises ttee related systems during an SSE. Ibcumen stion interactions of non-w.stkJowns anJ.no wh.st at test ing to t he scope, temJuct and resuelts of the seismic Hechanical, ba se s it was ca.nc luded review will t*e provided. Electrical,llVAC, Civil that the installat i.m and Instrumentation was acceptable. equipment wit ti saf e t y-related equipment. t The vaIkdown verii ted tiaa t such interactions do not constitute a matety concern. 4 /
l i 1 I ~ i ruth: RAM F1 AM CUkkiNT ASSESSMINT OF SAFLTY SIGNIFICANCE I sste t. s l i ti t DFVElrTION 4*F I SStt E trat. ArrSOACH TO FiSultillON l>AT F NONE ti. TO %Z 75% . lust I FICATION 19. Wa rr in h waat Review all conduit that A walkdows was per f ormed which identit led 19 F /f6 There was never a path fastrismentation pene:t r a t es the bases.it p lat e s where we t ness due to seepage from f or ground water to ConJuit anJ terminates above t i.e conJutts was f oeend. These cases will be flow in mutiicient top of the basemat t e, addressed by semoving t he es ist ing seals and quantity to flood the assure that these seplacing them witta a light densit y s&litune auniitary building poteattal dirett access ela s t ome r wh ic h ha s t he c.egub i l it y t( stop the basement, even before paths et water are seepage. This work will be performed at the the seals were properly sealed. convenience of tr&l. since the slow seepage through installed and before the seats is not a flooding hazard but rather a the troperary conduits ou tsance to maintenance. were grouted. The f loor drain and sump Temporary conduits whicle ent e r t he b.a semat from pump system was more outside, and which once allowed passage of ground tiaan adequate to handle water in quantitles that required periodic pumping, t he: quantity of water
- a.e sun, all t>cen pressure grooted and their which entered the t emput a r y b loc k out pits titled witto concrete and building during const-no longer serve as a te.k path for ground water.
auction, and is adequate to handle the The one piezweeter standpipe whith semains in much reduced quant ity service will also be groented since at moulturs a presently observed. Jeep aquifer of no preses.t interest. 4 - / O l
rNOL.N AH Ft Ah LllWkt NT ASSFSSH& MT OF SAFETT SICNIFICANCE I SSI:F & TtttE IWRII"Tlam OF ISSUE tr&B. ArrNOACit Tis stSolllTith laAT E NONE F1. To %1 7%1 .IUSTIFICATION lo. Constem:1.m Verify the pauper tr&L is rev iewing ti.e suppos t ing Jocumenta-7/11 Corrective action taken Matestalm Testing ces t if icat tam of const-tion for l lee correcttve as t iene ut NC N -W l-F 7 - I l f* as a result of an LFSL (CMT) re-tronnel tuttien materlats to ensum e the adequx y el tt.e s'ossective action. Task Force verification IN.n l i t it a t ion testing personnel. Additional supporting inform.atte.sa will be s..ught effort on GEO Jocusesit-It er o r d s. .3 % swe essar y in order to sentire aifeq.. ate atton for CMT personnel qualitications. Evaluatiews will be m..de of the qualit trat ions (See NCR adeqiucy vi certifications los andtvidu.at personnel W i-F 7-I l f.). amt11 certifications are 3 s.d ged luaJequate, the implied saf ety concerns that.are t.atsed will be addsessed. t T N R+N N.
I t knu1AM rt AN CUNutNT ASSLS'MNT OF SAFETY SICNIFICANCF. R $stik & T I Ti t trtsCRIFTi(W OF SSSUt t r&L AFFROACll Tis utsut tri tim DATE NONE Ft. TO %1 > %1 .luSTIFICATION l
- 21. trtL Ca struction
. concern entsts over A review of t ransler cor sespondence on time F/6 A review of 100% of l System 5tatus and whether a.mstruction systems which were the canae of s te l s cemce r n turnover / transfer Transies uewiews. del ic tenc ies we s e will be performed. A review will 1.c c oeiduc t ed sorrespondence showed properly dispositioned t. werity that de f ic ienc tem in transferred no adJitional or identified during systems had no impact== testing. correspondence was tlee process et outstanding beyosa that t ransf er ring syst ems previously identified. tros construction t.. Dettetencies identified ~ plant cperati.ms, on the outstanding cor-respondence (1) SUS) h4ve been reviewed by' t.P&L start-up/oper-ations and it was deter utned that alwre was no impact on testing. 1 s 1 eh Re 1 l
rkta.kAf* tl AM CIIENthT ASSFS5 MENT OF SAFETY SIGNIFICANCE I SSI'l & T11t t g)t M R l rTItW OF I SStf F t r&B ArrkOAGI To pt sul Jglas DATE BONE F1. Tt: %I 751 JUSTIFICATION 21. n-e lde s Quallt t r at i m Yestty welder qual 61-LFat. has conductcJ a review et att t$escury 716 Document at ion to sup-(N-rcury) amt filler cations or assure t he welders. The review c eus t s e ns J t l.a t s ie doc u-port the proper Materlat t'o.itrol qualit y of all welds. mentation to support their ps ope s qualitisation qualtlication of all ($1:e wtJc) is available. Sabing/tchakang is not allowed on Mercury welders is Provide engineering just-the site and the complete anwer will Jescribe available. NCR-W1-7724 it scat ion f or the allow-alw mis e procedures anJ ag plicable code require-was opened to document ance cf "rebake" temper-erats and show that handi s e.g of tiller material qualifications sheet 4tures and t.olJing times meets sl e required codes. errors for 1 welders. that ditter to.= the requaerecats of atw ASMt. i and AWS CoJes. No code deviations esist. [T N R+k i A
i I'Et 4: RAM Ft.AN ClfRRtNT ASSESSMitsT OF SAFFTY SIGNIFICANCE IS$t'E & TITtF l>EM:Rlrfl(W ( F ISSUE g r&L AFFRtlACis Til RFSa rt t,tism DATE teUNE FL Ttt %I >%I JtJSTIFICATION 29 QA Progr am Bs eakJown Iktermine the cause of EF&L will review correct ive act ion commitments Flti The Mercury reviews betueen thasco and t he br eak Jwn, t he ad e-m.ade on the NRC enf orc e=nt act ion 4.=1 ps ovide have been completeJ Mercury. quacy of the cosrecttwe a detailed evaluation at the actions taken. A with the exception of act Ica. and provide eview of she and1t p:ogsans viII be periormed to SCD-64 " Linear Crack assurance on ti.e aJe-evalu.ite frequency and followup of required in Stainless Steel quacy of the operational corres-Elve actions of tt.e program. 11.e indepen-Tubing"(cur rently under QA Frogram. dent management asseshnesets will be reviewed with reevaluation). The ac t ioses taken. review indicates that there are no open items tr&L will provide an assessment of tt.e overall qA affecting plant salety, program to provide assurance that the QA program can iunction adequately dariug operattons. 4 [T N R+$ O I
LOUIStANA P O W E R & L 1 G H T ! Nrw cae.ssrcx. SANA a,2 a.m sm, a c m ma o vosso e isodisas-w VICOLE SOUTH UT:UT;ES SYSTEM JM. CAIN President and June 20, 198", Chief Executive Otticer W3B84-044 5 Mr. Saul Levine NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878 Mr. Robert L. Ferguson UNC Nuclear Industries, Inc. 1200 Jadwin, suite 425 Richland, Washington 99352 Mr. Larry L. Humphries UNC Nuclear Industries, Inc. P.O. Box 490 Richland, Washingten 99352
SUBJECT:
Pre-Licensing Issue Assessment Task Force Charter RITERINCE: Discussions in the Of fices of Shaw, Pittman, Potts & Trowbridge, Washington, D.C., June 13, 1984 Dcar Messrs: Levine, Ferguson and Humphries: Pursuant to discussions in the ref erenced meeting, this f ormalizes agreements reached between us at to the charter of the subject Task Force. The roles of UNC and NUS will be to act as a task f orce in providing assessment anc a.. ice in responding to the NRC letter of June 13, 1984 It is important to e hasize that both UNC and NUS will maintain suf fi:icnt independ:nce in c order to provide to me as Chief Executive Officer of LP&L an independent pro-fessional assessment regarding the functions listed below. Your assessments will be formalized and sent to the Director of the Of fice of Nucicar Reactor Operations at the same time they are provided to me. 8 The Program Plan and implementation schedule requested in the NRC letter. 8 The adequacy of responses and resoliitions (including validation of data and sources, as appropriate) of the matters sce out in the NRC letter.
Pro-Licensing Issus Assessment Page 2 ,Tcsk icrea Chartcr Juna 20, 1984 e The safety significance of the matters listed in the NEC letter with respect to: - Fuel load and testing up to 5% power - Operation above 5 pcwcr e The adequacy of the past QA/QC program in light of the catters listed in the NRC letter, and the resolution of such matters, e Recommend institutional or programmatic changes that are deemed appropriate during plant operation in light of the lessons learned as a result of the matters set forth in the NRC letter, and the LPLL respenses hereto. The following abbreviated organization chart is provided to cicarly depict that the Task Force is t,o have access to and interf ace with all necessary elements of the Waterford staff but is to report directly to me. President & Chief Executive Of ficer (LP&L) (J. Ca in) Task Porce Senior Vice President - !;uclear Operations (LP6L) (M. Leddick) Safety Review i ................ Ccanittee I l Quality Assurance ----..- Proj ect Manager (LP&L)-------Plant !bnager (LP&L) ' ' ' ' ~ ' Manager (LP&L) (D. Dcbson) (R. Barkhurst) (T. Gerrets) 8 ..........................____..._____q-............. Ebasco 6 Staff LP&L L Staff Reporting --..------ - Interface Very tro y yours, e Yhb J.M. Cain JMC:; ;;ph cc ?. Charnof f, R.S. Lcddick, D.E. Dobson
Ep,2 4 f l Cne tL (Uc 7 ( 7 1 s LOUISIANA 7 NEWCREANS.WUrSANA3p J h if cp aw o - es m er O [; POWE A & LIGHT 70 Gb e [504 204 uINSYS <m J.M. CAIN President and '] Chief Executive Otticer -r 2 ~ June 28, 1984 W3B84-0449 Mr. Darrell G. Eisenhut, Director Division of Licensing Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Program Plan for Resolution of Pre-Licensing Issues
REFERENCE:
NRC Letter Dated June 13, 1984, Docket No. 50-382. Dear Mr. Eisenhut Louisiana Power & Light has established a major program, with significant commitment of management resources, to address the issues raised in your letter to me of June 13, 1984. I am enclosing for your information a program plan which describes the organization of our new program and the methods of approaching resolution of the" issues you have raised. Key to our program is the designation of an outside, highly qualified Task Force to assist in the development of our plans for resolution and to independently assess the adequacy of the resolutions and their safety significance. The Task Force will consist of Larry L. Humphreys President, UNC Nuclear Industries, Inc., Saul Levine, Vice President, NUS 'N Corporation, and Robert L. Ferguson, Chairman, UNC, assisted by suitable UNC and NUS personnel. The Task Force will independently review LP&L's proposed resolution of the matters, and will report directly to me. Formal reports to me will be simul-taneously provided to you. The Task Force's charter is set out in my June 20, 1984 letter to the Task Force, enclosed. We have also designated a top management team dedicated to resolution of the issues and administration of our program. The team is headed by Dale E. Dobson, Waterford 3 Project Manager, reporting directly to R.S. Leddick, Senior Vice President - Nucicar, and includes management involvement of the plant operational staff. I will be personally and directly overseeing the program cfforts. e <uyp., t pp. ~
i a i i i Mr. Darrell G. Eisenhut June 28, 1984 W3B84-0449 i Page 2 t l i In addition, the resolution of the issues raised by your staff will be reviewed by the Waterford 3 Safety Review Committee (SRC) through a special subcommittee i . consisting of Kenneth W. Cook, LP&L Nuclear Support and Licensing Manager, Chairman; Joseph M. Hendrie, Consulting Engineer; Robert M. Douglass, Manager of Quality Assurance, Baltimore Gas & Electric Company; Raymond F. Burski, I LP&L Engineering and Nuclear Safety Manager; and Thomas F. Gerrets, LP&L l Corporate Quality Assurance Manager, i You can be assured that LP&L is totally dedicated to achieving the highest l l . level of safety achievable in the plant, and we take very seriously the matters you have set out in your letter. I do not intend to request a fuel loading / low l power license, or a full power license, until I am personally satisfied that j all issues necessary for those phases of plant operation have been satisfactorily addressed to assure the public health and safety. You have my personal assurance 2 that necessary programmatic and management changes arising from our program to-e l resolve these issues will be i= mediately and effectively implemented. i i l The attachment to the program plan listing the LP&L approach to resolution of j the individual issues has not yet been reviewed by the Task Force or the SRC, l and is subject to modification as a_ result of teviews by those groups and your staff. The plan is intended to provide an early and high level of confidence in the successful resolution of the issues and concerns you have raised. l 1 welcome your comments and suggestions. l j Very truly yours, } J. M. Cain j i
Enclosures:
As Stated I cc: With
Enclosure:
See next page i i f ) l I
Mr. Dirrell G. Eistnhut, Director Page 3 W3B84-0449 June 28, 1984 cc: R.S. Leddick Waterford 3 D.E. Dobson Waterfcrd 3 Les Constable Waterford 3 Saul Levine NUS Corporation 910 Clopper Road Gaithersburg, MD 20878 Robert L. Ferguson UNC Nuclear Industries 1200 Jadwin, Suite 425 Richland, WA 99352 Larry L. Humphreys UNC Nuclear Industrics P.O. Box 490 Richland, WA 99352 '.T. Collins U.S. Nuclear Regulatory Commission Region IV Arlington, Texas 76011 Dennis Crutchfield U.S. Nuclear Regulatory Commission Wa shing t on, D. C. 20555 George Knighton, Chief Licensing Branch No. 3 Division of Licensing Washington, D.C. 20555 Gerald Charnoff Shaw, Pittman, Potts 6 Trowbridge 1800 M. St. N.W. Washington, D.C. 20555
June 28, 1984 WATERFCRD 3 PROGRAM PLAN AND SCHEDULE I. INTRODUCTION AND PURPOSE This Program Plan outlines the methods by which the 23 in-dividual issues described in the NRC letter, Docket No. 50-382, dated June 13, 1984, are to be resolved by LP&L. Further, the Plan provides a mechanism to address the cause of the issues, the generic implications and collec-tive significance of the issues, and the programmatic and management changes designed to preclude recurrence of such issues. The Program includes the establishment of an in-dependent Task Force to advise LP&L and evaluate LP&L's resolution of the issues, and separate review of the reso-lution by the Waterford 3 Safety Review Committee (SRC). II. PROGRAM PLAN MANAGEMENT 1. The LP&L Project Manager - Nuclear is a,ssigned re-sponsibility for management of the overall Plan and actions outlined in paragraphs III and IV below. He will perform these tasks in a normal line management role and have access to and the support of any requi-site LP&L and contractor managers and staffs on a top priority basis. He will assure effective interfaces with external groups including the SRC and the UNC/NUS Task Force described in paragraph VI below. 2. The Project Manager-Nuclear reports directly to the Senior Vice President-Nuclear, who in turn reports directly to the President and Chief Executive Officer of LP&L. Both the Senior Vice President-Nuclear and the CEO are directly and actively involved in the management of the Program. III. RESOLUTION OF ISSUES 1. Each issue will be analyzed to determine: The cause The generic implication 9 o,j /m r/n./ I m # 9g N f I P O))U M J J G)U f -
The actions and schedules to correct both the specific problem and related generic concerns The safety significance with respect to fuel load and low po.wer operation, and to operation above 5% power ~ 2. The intended manner in which each of the 23 issues are to be addressed is described in Attachment 1. It should be noted that the^ manner of resolution may need modification as actions necessary to resolve any related safety concerns are undertaken. IV. COLLECTIVE SIGNIFICANCE AND PROGRAMMATIC CHANGES As early as feasible in the process of formulating the in-formation contained in paragraph III above, the LP&L Proj-ect Manager-Nuclear will: 1. assess the collective significance of the indi-vidual issues, and 2. recommend institutional or programmatic changes deemed appropriate to avoid recurrence of the types of problems underlying the issues being addressed V. SAFETY REVIEW COMMITTEE 1. The Waterford 3 Safety Review Committee (SRC) has designated an SRC subcommittee to review the items outlined in paragraph III and IV above. 2. The SRC subcommittee consists of Kenneth W.
- Cook, LP&L Nuclear Support and Licensing Manager, Chairman; Joseph M.
Hendrie, Consulting Engineer; Robert M. Douglass, Manager of Quality Assurance, Baltimore Gas and Electric Company; Raymond F. Burski, LP&L Engi-neering and Nuclear Safety Manager; and Thomas F. Gerrets, LP&L Corporate Quality Assurance Manager. VI. INDEPENDENT ASSESSMENT 1. An independent assessment of the resolutions and de-termination of safety significance will be provided by a Task Force reporting directly to the CEO of LP&L. The Task Force consists of officials of UNC Nuclear Industries, Inc., Richland, Washington, and. l
NUS Corporation, Gaithersburg, Maryland, who will be assisted by UNC and NUS staff members, as required. The Task Force will independently assess LP&L's reso-lution of the issues, including the cause, generic implications and collective significance of the is-sues. The Task Force will also provide advice and assistance in the resolution of the issues, and will provide an independent assessment of the safety sig-nificance of the issues with respect to fuel loading and low power testing, and operation above 5% power. It will assess the adequacy of LP&L QA/QC program in light of the NRC's issues, and will recommend any in-stitutional or programmatic changes which may be nec-4 essary to prevent recurrence of the issues. 2. The charter, identification of principals, initial functions have been formalized, as specified in At-tachment 2 hereto. VII. RESPONSE TO NRC The individual issues vary considerably in both the degree of concern and complexity of resolution. Therefore, LP&L intends to forward to th,e NRC the proposed resolution data individually or in packages as they are completed and have undergone the degree of review specified herein. Some of the resolutions may be submitted before completion of all requisite corrective actions, which are underway or de-fined and scheduled for accomplishment, have been accom-plished. Upon submittal, each resolution will be added as Appendix A of the Program Plan to constitute a major part of the final report. VIII. SCHEDULE .. lists the target dates for Project Management completion of resolution data on each issue. These dates include a period of time Project Management has scheduled for completion of its review and that of by the SRC and Task Force, although these dates are difficult to predict. Target dates for development of the collective signifi-cance of the issues and recommended programmatic changes outlines in paragraph IV above are to be established by July 6, 1984. pRtu;HAN Pl.AN CURRI.NT ASSESSNI.N1 OF SAFETY SIGNIFICANCE ISSUI. & TITIE IWSCRII' TION (W ISStf t, l.P&l. ApPHOACH TO HFSOt.IITION DA'IE NONE Ft. TO 51 7%% itiSTI FI CA rl ON 1 Inspection Verify the proper
- 1. Pat. will verif y 7/20 A preliminary evaluation of the personnel certilleation of site the credentials of QA nian.sgers.
T-H.and Hercusy QC inspectors issues QA/QC personnel or supervisors and personnel certitying questioned by the NHC indicated requalliy the work inspecturn, and.euditors. they were qualified and performed by these cer tille d y perf orm their petsonnel. assigned work function. ~ A verification of the certific.ition ut it is important to note that the approximately 20% of all QC inspectors inspectors for the major is being done to assess the safety lost.elice s of saf ety related significance of the concern. A equipment and systems (e.g., description of the certification Tompkins-Beckwith. Fischback & criteria (ANSI N45.2.6-1911), as Moore, Herrury. HISCO. American required by the Quality program, Bridge, J. A. Jones, and Gulf) i and a matris showing certification performed no non-destructive and supporting documentation will testing (NDT). NUT was provided he prep.sted. Further efloats, including by CEO. any necessasy reinspections, will be based on specille probicas and root cause An audit was performed on all nalyses and will be as necessary an contractors perfoaming safety verify the adequacy of the progr.em and related work. An assessment of compliance with the program. the current audit results, which do not include American Bridge For the QC inspectors remaining onsite, and CE, indic ate QC personnel a teverif icat tim of proper certtitration were qualified and cert ified. in accordance with ANSI N4%.2.6-19/.I is Addition.at backup information heing accomplished. has been requested from CE and Amerit.an Hridge to complete the Quality Control inspections curiently evaluation. 1 he preliminary be ing undertaken as p.a r t of other results et the audit are Itsted programs will be performed by yC below. personnel reverified.a qualitied under 1. CEO (NDE) - 23 sampled /23 ANSI N4%.2.6-1973. qualleled 4 v 2. Waldinger - 5 sampled /5 f' qua1ifled 1. R&B - 8 sampled /tl quallfled 4. Silne - 15 sampled /15 qualifled N
PkOGHAM l'I.AN CtlHRENT ASSESSHENT OF SAFETY SIGNIFICANCE ISSitE & TITI E DESCRIPTION OF I SSLIE I. Pal. APPHOACil '80 NESOIllTION 11 AT E NONE Ft. TO 51 >5% .IllSTI FI CATION 2. Missing N1 Instrument Verily compliance with I.I'&l. will review all NI instrumentation installed 1/6 To date, 90 locally I. i ne Documentation NRC requirements for NI during the period when clat.s breaks were allowed mounted N1 instruments inst rumentat ion (prto to Apri1 1, 19 t12 ), identily requireil have been identifled is.st alla t io is. <locumerit eit ion to demonst rate co: rect i n s t a l l;it ion as heliig installed and inspection, and ident it y t he document at ion prior to April 7, 1982. av.nilable. A (J A review ol all safety-related N1 To date, using ASME Ill inst rumentat ion systems has been perlorme 1 whicle documentation criteria vertiled that all installations were pauperly as a basis for comparl~ documented and inspected. son, full or partial compliance can be shown f or the 12 installattin at issue. Of the renainIng installatlons 3% had no class breaks, 19 were thermocouples witle no tubing, and 24 had been reclassiiled to N2 (i.e. not required for safe shutdown).
i PKiK;HV1 Pl.AN CtlHitENT ASSLSSMENT OF SAFETY SIGNI FICANCE I SSt!F. & TITI E DFSCHIPilON OF ISSUE 1 PAL APPROACH 10 MSOI.tlTION I)ATl? NONE FL TO %I 7 % .lUSTIFICATION 3. Instrumentation Correct separation NCR-Wl-7702 covers the system $1A problems 7/11 The walkdown to date Expansion Loop criteria viol.ticas and has been dispositioned to r eamve the represents approximate-Separation found tr. system 52A and expansion loops in question thus solving ly 20% of the installa-provide a progr. for the problem. tions to be walked down review of other nalety-and the amount of related violations and NCR-Wl-7730 was generated to track the generic rework being identified take the necessary concern. In order to provide some basis for has been found to be corrective actions. determining the scope of our program, a sample very minor (i.e. three of 51 instrument installations were thosen for feet of tube track review in area of congestion, and walkdowns of cover). If the issue these lines were done. Thirteen violations were had gone undetected f ound out of 276 locations, although only one it would not have been required rework. It was decided to perform a QC likely to cause a verification of all lines where the redundant safety concern, tubing was run together and take the appropalate action. An interim response discussing the resolut ion of NCR-W1-7702 items and the status of NCR-Wl-7310 reinspections will he provided as well as a schedule for completion of the reinspections. / (
I'ktu. NAM PLAN Ct!NNENT ASStSNMENT OF SAFTY SIGNIFICANCE I S$t.E & TITI.E DESCRIPTljH OF I S$11i. LP&l. APPHOACl! 10 ktSul.UTlHN DATE NONE kl. TO %I > %% JUSTlFICATION 4. Lower Tier Cottertive IP&l. shall review all LP&l. will review the lower t ier doc ument reporting 7/9 Based on the current Actions Are Not being FCHs, DCNs. FDNs.,a n d sy:.t em to ensure it was stauctured in such a review, l.P&L expec t s t o Upgraded to tsCHs T-B DNs to asbute that su nne r that procedures. integral to the Quality demonstrate that there proper corrective Program, provided a sound basis tor decisions re-has been adequate QA/QC act ion was t aken, garding the severity level.I documents. used to involvement in all including an adequate sepost deficiencies. The review will specifically lower tier documents seview by yA. This consider QA and QC reviews ut engineesing/ with regard to 10CFR%0, corrective action shail construction judgements on delicienstes as it Appendix B corrective include the step s relates to the corrective action.ind noncon-action and non-conform-required by 10064%0 f us mance requirements of 10 CFH %O Appesidix H ance seguirements. Appendix B. Cr it er ion anJ the reporting requirements at 10 CFH 50.55(e). This involvement is XVI Corrective Action expected to show that and for Construction The response will include an assessment appropriate corrective Def iciency Report in;;. of all the lower tier documents specifically actions, specif ic and 50.5%(e). Also, cited by the NRC to veri 1y the adequacy of the generic, are identifled included in this review psoceduseelized sateguards in assuring that shall be the deliciencies with satety signtitcance are Our currect evaluation examination ot triproper being properly dispositioned and reported, of the examples of voiding of all other There will also be an assessment of improper lower tier documents design changes or voiding. cited by the NRC demon-discrepancy notices strates that although a that afietted safety-small percentage should related systems or th.et have been upgraded to were misclassified.ss NCM's under the quality s.e l e t y. program in effect. none had adverse safety significance. \\ @W L
PROGRAM l't AN CtfRHFNT ASSESSMENT OF SAFETY SIGNIFICANCE ISSilE & TITI.E DESCR I PT I ON OF 1 S 5 411'. I P&L Al'PROACll TQ resol.tlTION DA1 E NONE l'I. TO 51 >5% JilSTlFICATION 5 Vendor I)ocumentation The concern relaten to A problem did exist with formal tracking of 1/l1 The CE records and Condit ional Heleases whether shortcomings in Combustion Engineering Condit ional Cer tit icat ions other records with the contractor's documen-of Espipment. Records associated with CE material exception of JA Jones tation which existed at and equipment will be re-reviewed and conditional and Waldinger have been the time the materl.il critifications will be identified and promptly reviewed. To date 8 of was supplied have t,cen resolved. Control of CE material and equipment 14 CE conditional cert-corrected, differs from that of othen contractors. in order ifications have been to verify that a similar problem does not exist changed to uncondit-in the case of other contractorr., a sample audit of tonal. No it ems other critical purchase orders will be performed. affecting plant safety e li the sample audit identities any other problems have been identified with the handling of contractor material releases, in any of the completed additional reviews will be initiated. reviews and dispo-d mitions.
- +
N
j iW CRAN P;.AN CURHENT ASSLS$ MENT OF SAFI'TY SIGNIFICANCE ISSUE & TITLE 11FSCRIPflON sfF I S5 alt I t'&L APPROACH To RL508.UTION DATE NONE ti, Tu %1 > %Z _lUSTIFICATION t>. Dispositioning ut Some thasco and Nercury First. the inplace program for handling of lower 7/13 To date, the NCRs Non-centurmance and NCRs and El asco DRs tier documents such as DRs will be discussed, cited by the NRC have Disciep.sucy Reports were ouestionably des-been evaluated. Five positioned and IPPt. Second, the specific NCRs and DRs cited by the of the 49 are being shall psiepose a psogram NRC will be evaluated f or proper elesignat ion. further evaluated. to assure all NCks and disposition. and implementation of corraative Threc Impact hardware DRs are appropriately action under the existing Quality program. and two sof tware. The upgraded, adequ.itely bstance have been shown dispositinued ns: Third, a review of all NCFs was statted by I.P&L to be adequately dispo-corrective attion in January to assess the validity of the dis-sitioned. The overall complcted and ti..*t any postrion, the corrective action taken. t he com-review of NCRs has problems detected arc pleteness ot' the documentat ion and proper closure, been completed with corrected. the exception of Four t h, a f ield ver !! irat ion will be conducted on approximately 300. This 1.undred randomly selected NCRs to ec mre the review showed 416 of one corsettive action resolved the nonconformance. the total 7150 NCRs were questtoned. 8%% If any problems are detected from ti.ese steps, a of these deficiencies plan of further corrective action will be estab-were documentation re-lished. lated and were not significant. The balance will be closed. To date 12 of 100 NCRs have been ileId vetiiled. No con-clusions have been drawn as of yet. N N h M
i PPf CHAM l't.AN CUkM NT ASSISSMENT OF SAFZTY SIGNIFICANCE 1 S501: & Till.h DLSON il'I'lete OF ISSt:E I P&l. APPROAril 10 k t Sol.Ul l t ald itAT V. NONE Ft. 10 %17%% JUSTIFICATION 7. ILichlill soll Conduct.e revitw of all lhe b.ich f 118 records.ar e be ing reviewed for 7/83 TI.e ef f ect of any pos-Densities soit packages for completion and technical...lequaty. eccord packages tulated variations in complet eswss.and are being located and any technieal 13. hues will be density in the fill is technic.at adequary. eva i n.s t ed. not of significance kihere rec ords are relative to the afsning or L o t hn i c.e l tic i sm ic response of p s e.b i t as a r e.Ic i I r.cel, the plant as designed. take torrectivt-acri.m. In addition, should there be a few missing records, a satisfactory demonstration of the quality of the backfill will be provided. 4 V NW
l l l PkOGRAH Pl.AN CllRRENT ASSESSHFNT OF SAFETY S10NIFICANCE I SSUI: A TITI.E 1)FSrHipTlHN OF ISSilE
- 1. Pal. APPROACH TO HEStH.lfTION
!) AT E NONE Ft. TO %7 >%Z .lUSTIFICATION 8. Visual Examin.ation liocume nt inspections I. Pal, will provide documentation verifying that / /f) Investigations to date of Shop Welds during of shop welds during shop welds were inspected by spulifie_<l show that shop welds Hydrostatic Testing hydro tests or other-in re pe c t o r s. were inspected and wise verity such .sccepted during inspection. hydrostatic tests by in Authorized Nuclear inspector as demon-st rat eel by repor ts. The ASHE N-5 code data reports also confirm that there was inspection of shop welds. The methodology of the field hydro-s t.it ic testa provide additional qualifica-tion of testing. Document.ition on the above wait be provided. T 4 N R*N e
t I'kOGRAM Pl.AN OdHRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSilE & TITLE DESCHiPTION OF ISSUE 1.P&l. Art'kOACil 10 HESOI.llTION DATE NONE FL TO %I >5% JllSTIFICATION 9. We lele r Cer t i f icat ion Locate missing documentu NCR W1-7%9 was generated on 2/1/34 to track this 7/20 All welding evaluated for instrument cabinet problem. No documentation was found on three of to date has been found welds and determine if the eighteen cabinets and parti.nl documentation acceptable. welders were.sppro-f ounit on f ou r. All seven were reinspected and priately certifled. found acceptable. Take appropriate action to assure the quality As a result of the missing documentation, a of the supports if review 1N being performed to determine other documentatinn cannot miscellaneous cases where Jones performed welding. be located. Documentation for the welding identified will be reviewed. 4 V NW
m 4 PRICHAM PEAN Ct!kkFNT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUF. & TITI E DESCRIPTitei 0F ISSUF IPal. APPHOACal TO RESul.UTION DATE NONE F1. TO %2 >%Z .lUSTI FICATi uN i 10 Inspn tor Quall-Verliy the prcper certi-A reassessment of the adequancy of the program to 7/13 preliminary evaluations t tication (f. A. f irat iam of yA/QC certify inspectors will be performed for of J. A. Jones QC per-Jones and Fegies) personnel and evaluate approximately 20Z of all QC inspectors to assess sonnel qualifications l the impact of any the safety significance of the concern. questioned by the NRC deficiencies f our.J. Indicate they were bleere def iciencies are identified, the inspect ions qualified and certified made by the sul> Ject QC persnnnel will be reviewed to perform their and an evaluation made of the safety significance assigned work function. l with regard to design const ruction and operat iem. The sample size was. 1he need for additional corrective action will be twenty percent (20%). assensed as part of the safety evaluation. Nineteen of the 20 were qualifled and one was qualifled pending clarifIcatlon. Additional backup internation was re-quest ed f ros. Tegles to complete m i evaluation. It is important to note that the Inspectors per-iorond no I sum-des t ruc t ive i testing (NDT). NDT was provided by CEO, 49 c*.W <v 9 +. r ? i I t
- - - -_... _... ~ i 4 Y PkHGRAM PI AN CUkMENT ASSESSMFNT OF SAFETY SIGNIFICANCE I SSL'E & TITI.E DESCRIPTION OF ISSUE I.P&l. APPHOACH 10 HESpl.IITlHN DATE NONE Fl. TO il >5% JUSTIFICATION ll. C.edwelding Provide sl.e cadweld The radweld records will be t r. inst a lbril onto 1/20 Prius reviews have data for the project in corputer data storage including the pl.stement already been accom-such a form that it t..s o number, cadweld number har size, har pusition. plished under NCR he readily compared to vir.ual inspection acceptance or rejection, W1-6234 and non-the testing criteria prinluction splice tensile test acceptance or conforming conditions us.ed for the Waterford rejection, and sister splice tensile test resolved. 3 project with d.ita acceptance or rejection. broken dom by various categories. Provide In this term the cadweld d.ita cin he called up by dat.: on welder quall-any of these attributes to expedite review for fication and requalt-specif ication compliance or utlier reason. A l e,o, fication incluiting physical location of cadwelds may then be readily dates. ol,t.sined by reference to the concrete placement lift diagrams which locate the placements. Data un welder qualific.etion and requalification will be gathered and provided as part of this eflust. cb q4jr
i I t PHOT l RAM l'I.AN Ct!NRFNT ASSESSHENT OF SAFETY SIGNIFICANCF. ISSilt. & TITI F. DESCRIPTION OF ISSIIE 1.P Al, APPROACll 10 RESOI.llT ION DA1 F. NONE Fl. TO 5% >%% llf STI FICAT I ON
- 12. Main Steamline Complete the document-SCD 1H was resolved and subsequently reopened upon 1/11 The safety significance Framing Rests.sints
.s t ion, lor all discovery that inspectl.ns in one area were not of not replacing the connections in t he complete. NCR-W1-1716 issued to track resolution teolts which were steam generates traming, of the deficiency. In onder to assure complete replaced is still under resolution of this concean, l.P&l. initiated both a evaluation, lloweve r, l001 QC reinspection of steam generator framing the actual restraint connections as well an a leview of the American structure is not needed firidge work scope against the scope of SCis 18 until the reactor reinspect ions to assur e.t hat reinspections were generates power and complete. therefore the bolting is not a constraint
- All connections were reinspected. kequiste !>ntt to luel load or replacement and NCR closuie is scheduled to be operations up to 5%
completed by.luly 6, 1984. power.
- +/
0
I l'I:OGRNt l't.AN CilkNENT ASM SSMENT OF SAFETY SIGNIFICANCE ISStlE & TITir DESCk i pT l e lN Or' I SSl!F l l'AI. ArrROAtti TO RE501.tll lON DATE NONE l't. 10 %% 75% .lUSTIFICATION l l. Missing NCRs I.P&l. Sha ll obt ain the it&l. is conduct ing a review of closed.and voided 7/6 A review to date missing NCHs, explain thasco NCHs to determine il they are not properly indicates that only why these NCNs wene indexed and filed in the QA retoads vault. five out of more than not maintained in the 7%00 site-issued NCRs. filing a.ystem, review The evaluation will identity all NCHs, which are which have been closed them for proper indicated as closed or voided by site QA tracking or volded, are not voiding, and assure mechanisms but not vaulted, and provide an explana-indexed and filed. Of that when an assue is tion as to why they are missing, assure proper the five NCHs whicle raised to an hCH, it voiding and assure proper filing and tracking. have not been indexed and filed, it can be is properly tiled tor tsacking and closure. A similar evaluation is being conducted on NCRs demonstrated that they whict. were issued by Ebasco QA in New York. apparently were never issued. Sufficlent documentation is on file to demonstrate the acceptabliity of the saf et y-related items described in the log entries corresponding to thche five NCH numbers. 1he review i nd i c.it es the problem stems from NCR track-N ing syst em utilized prinr to mid-1979, and that ninte then the in- \\ proved NCH tracking nystem has l>cen ade-quate. In addition the review indicated that there were thirteen n ual>e r s that were ap-parently never assigned to an NCR. LP8L is in process of conf irming that NCRs with these numbers were never issued.
t l'M1 CRAM PIAN CURNLNT ASSESSMENT OF SAFETY SIGNIFICANCE I SSl't: & TITit DESCRIPTION of ISSif E 1.P&l. ArrROACil TO RLSOI.tri luN 11AT E NONE Fl. TO 51 7%% .lllSTI F ICATION 14 J. A. Jesses Spee d Durirg the Ibasco QA Fit st, a review ha s been conduc t ed of cor res-7/20 To date about 1800 letters and Liks review cl .l. A. .lones pondence between J. A..lones and thast o via Speed pieces of JA Jones speed Ictters and eng-letters and Elks. currespondence have incering information lic en reviewed and 211 requests, sieve ra l items Second, a review of such corre.pondence in which design thangen identi-that rould aftetr plant design changes were conveyed to.l. A..lones with-Iled. Of these, 190 s.stety we e noted. out reference to follow-up.sction to formalize the have been approved as liased on its sample al changes is being conducted to determine safety acceptable. 21 are the these acttons, the stafI signitScance. subject of fleid does not expect that.a n y investigattans to of these items will L.ted, a minimum sample of ten peicent of informal develop information fo'r significantly affect documents such as speed letters and Elks by other evaluation, and the plant salety. cont s actor s pe r f orming s.nl et y-related wor k wlio balance.sre under Nevertheless, the app-ut ilized these type of documents is being review. To date no licant should complete conducted. The need to review addition.a1 safety prohicas have t he ac t ions identitled documentation will be determined based on the been delined that would in these reviews anu results of this review, require rework, issues raised shall be resolved promptly. For other contractors, the review has shown that 8 of 42 Fegles, 1 ul 189 Waldinger, and 2 of 660 T-8 informal documents could involve design N& <hangen. These reviews ase r,ubstant f ally complete and evalu-attuns aie in process. m
_.._m_ _, _ _.. ~ _. _. _. _, _ _. _ ~. _ i l r i t i L t$us:NAH Pl.AN CUNNENT ASSESSMIDT OF SAFETY SIGNIFICANCE ISSttE & TITI.E DFSCRIPTION OF I SMIE I.rSt. ArrHOACal TO RESpl.liflON DATE NONE FI. Tu %% >51 JUSTIFICATION 1%. Welding of "D" level I.ocate the documentation I.P&t. will conduct a review to confirsi that 7/13 The CBal yA manual L Material Inside for *D" level material material and weld rod secords ents,t to establish requirements for Containment welding and verify the material control f or all "D" material welds; documentat ion of fit-up l adequacy os the identify and verify the acrtification of all and final weld 1iformation or perform a welders, and; provide inspection, procedures and inspections do not i matettal analysis and data as well as affidavits from inspectors. apply to "p" material NDE work, or gewosk Documentation will be tied to specific welds as welding although weld the welds. much as possible. This will include identification inspections were per-of "D" material welds and compilation of : formed. The work was i l) applicable CB&l "as built" drawing number., performed by the same
- 2) identification of welits by piece mark numbers welders and inspected j
and material type (i.e. D to D. D to B. etc.); by the same welding k
- 1) quantitles f or repet it ious weld 1.D.'s; supervisors to the
- 4) weld type and cire, and; 5) indication as to same standard as the shop or iteld welds. 1r&L will evaluate the results and determine whether reinspections are required rest of the CB&I work 6
for which documen-and what the scope of such a reinspection will be. tation is provided. This provides a high degree of confidence in the quality of the I finished work. Additionally very low rates of rejection in NDE tests and in inde-pendent hurveillances and audits indicates 4, high work quality. S+' l f I
l'HOGRAM l't AN L:liRRENT ASSESSMENT OF SAFETY SIGNIFICANCIC I SSLIE 8. Till.E DE%CRfrTION OF ISSllE I. Pat. Al'I'HOACll TO k f SeH.tfTlHN DATE NONE fl.10 %1 7'*% JUSTIFICATION I f>. Surveys and Exit The NRC was (titical of The intesview forms have been pert.onally reviewed 7/9 l(eviews to date have Int es views of QA t he m.mner in which a by the Senior V.P.- Nuclear to assess whether the not identitled utgnifi-l'es sonne t progn e el interviewing program met his intent.md t he ha.,i s f or t he NkC cant salcty concerns sit e QA/yC pert.onnel in c ommen t s. Two further l l' At. st al f at t ions rema in. not alreaty identified. eerder to identity and
- 4) A review by the indspendent S.alety Evaluation take appropst.+tc at' tion Os oup (ISEG) pr imar ily t o assure t h.e t the reg.ording their contemos concerns received dur ing the interviews were or will Ic was conducted.
appropriately addrensed and neccusary corrective actions taken
- 2) A determination as to the Scope and manner in which future methods ut addressing issues raised by individuals are addressed.
4 W+4
PHOGkAH l'l AN CilRRI NT ASSESSNLNT OF SAFETY SIGNIFICANCE I SS110 & TITI.E DESCkil'IBON OF I SSilE I Pal APPROACil TO RLSOlt! TION DA'll NONE Fl. TO 5% >%% .IllSTI FICATI ON g 11. QC Verification ot' 1he NHL is concerned on 1he concern stems oves t he f.a c t that.e 19H2 7/6 Initial reviews show Expansion Anchor whether t iae s e was revision of an inspection inte does not list the that the requisite Cha r ac t e r ist it s suiticient QC vtrifaca-requisite QC inspect ion at t r ibut es. The initial characteristics were t ion of t he charac ter-review of this matter indicates that the requisite part of the procedure istics necessary to QC reviews were made as acquired by the drawings (incorporated by ans.ure proper installa-which accompanied the inspection tuses. This was drawings). This tion of concrete suhntantiated by a thorough review of Hercury provides reasonable e x pa 31s.n ancim r s quality records. l.P&L will prepate a response assurance that QC inst alled by Mercury. discussing the incorporation of dr.awings into the verification was piocedure, training of Herrury persennel, the QC adequate. Previously e review and substantiation of records and a root there were 896 re-cause evaluation of the problem. inspections made of^ installed expansion d anchor characteristics to confirm records validity. s&+
l PROGR Aft l't.AN CURktNT ASSESSMf NT OF SAFETY SIGNIFICANCE ISSUE & TITI.E liESCRIPTION OF I SStJ E I.P&l. APPROACll TO kESOt.llTION DATE NONE Fl. TO 5% >5% lOSTIFICATION 18. Document.stion of thicumentat ion aliould be The response to this issue discusses the manner 7/6 The desige. and Kalbdowns of Non-provialed th.et r i c.a r l y in which elesign and inst.sil.at ion consides ed the construction of Safety Related shows what equipment effetts of interactions et non-se i sm ic witts salety-Waterford-3 considered Equig> ment was reviewed during the related systems during an SSE. Documentation interactions of non-walkdowns and on what attesting to the scope, conduct and results of the scismic Hechanical, bases it was roncluded review will be provided. Elect rical, ilVAC, Civil that the instati.stion .i nal knstrumentation was acceptahlc. equipment with safety-ret.sted equipment. The walkdown verified. that such interactions do not constitute a safety concern. 4 $+4 f
PHOGEMI l't.AN CUkRI.NT ASSESSMI.NT OF SAFETY SIGNIFICANCE ISStlE & TITI.E DESCRIPTION OF I SStlE I.PAI. APPkOACll 10 kt Sul.tlTION DAT F. NONE FI. TO %I 75% .luSTIFICATION 19. Water in lia sema t Revie=r all conduit that A walkdown was per formed whi<:h ident it led 19 7/6 There was never a path Instrumentation pent: t r a t e n the basemat places where wetness due to seepage from for ground water to Conduit and terminates above the conduits was found. These cases will be flow in sufficient top of the basemat to addressed by removing the exist ing seats and quantity to flood the assure that these seplacing them with a light density milicone ausiliary building potential direct access elastomer which has the capability to stop the basement, even before paths of water are seepage. This work will be performed at the the seals were properly scaled. convenience of LP&L since the slow seepage through installed and before the seats is not a flooding hazard but rather a the tesiporary conduits nuisance to maintenance. were grouted. The floor drain and sump Temporary conduits which enter the basemat from pump nystem was more outside, and which once allowed passage ni ground than adequate to handle water in quantities that required periodic pumping, d the quantity of water have now all been pressure grouted and their which entered the temporary blockout pita illied with concrete and building during const-no longer serve as a leak path for ground water. ruction, and is adequate to handle the lhe une piezometer standpipe which remains in much reduced quantity service will also be gr out ed since it monitors a presently observed, deep aquifer of no prescot interest. 4 %+/ 8
l'HOCWAM l*l.AN CUHktNT ASSESSHLNT OF SAFETY SIGNIFICANCE l SSUF. 8. T ITI.F. DF.5CHIPflON OF ISSUE l l'&l. Al'l'HOACil TO RI Sol.Il fluN DATF. NONE Fl. To %% >%1 .luSTIFICATION 10 Constnuttlun Verify Elie psoper I.P&l. is reviewing tlee supporting documenta-7/11 Corrective action taken Hat er l.e ls Test ing cer t if icat ion of const-tion for tlie corrective action of NCR-Wl-F1-lif> as a result of an 1.P&l. (CHT) Personnel rus.tlon mat.rlaim to ensiere tlie adequary of time t or ecct ive ac t ion. Task Fusce verification qualifttation testing personnel. Ailditional supporting information will t>e souglit effort on CEO document-
- Records, as netchsary in order to confism adequate atton for CHT personnel qualifications. Evaluat ion will lie made of alie qualitications (See NCR adequacy of certifications for in<lividual personnel W 3-F1-116).
and il certifications are judged inadequate, t lic Implied saf ety concerns that.ir e raised will l>e .iddressed. T Y Ngs q+h N
f l'RtW; RAM l'l AN CtlkHENT ASSLSSMFNT OF SAFETY SIGNIFICANCE I SSi l( & TITI.E ltESCki PTION i>F ISSUE I.P&l. APPROACil TO HESOLU'l lON DATE NONE Ft. TO %1 751 JilS f'I FICATION
- 28. IP&l. Constrintion A concern exists over A review of transfer corsespondence on the 1/6 A review of 100% of Syst em Status and whether construction systems which were the cause of t his concern turnover / transfer T r.in s t e r Neviews, deliciencies vs.se will he performed. A review will be conducted correspondence showed properly dispositiontd ti verity that deficiencies in tsausterred no additional or identified during systems had no impact on testing.
correspondence was t he proc ess of outst.ending beyond that translerring systems previously identifled. from construction to Deficiencias identified plant operations, on the outstanding cor-respondence (13 SUS) have been reviewed by I.P&L start-up/oper-ations and it was deter 4 mined that there was no impact c,n test ing. k Re+ c W
\\ - ? PktH: Matt P:.AN CUkNtNT ASSFSSMENT OF SAFETY SIGNIFICANCE I SSill. & TITI.F. DESCRIPTION OF I SS11E
- 1. Pal. Al'I' ROACH TO lit.SOI.lfTION DATE NONE Fl. TO %1 75%
JUSTIFICATION 22. Welder t]ualittration Verity welder qualif-I.P&L has conduc ted a review of all Mercury 7 / f> Documentation to sup-(Mercury) anal Filler cations or assure glie welders. The review contirmi.l that a l.c doc u-port the proper Matert.el Control quality of all welds, mentation to support their psoper qua l il lt:a t ion qualitication of all (site Wide) is available. Raking /rchaking is not allowed on Mercury welders Is Provide engineering just-the site and the cumplete answcr will describe available. NCR-Wi-7724 titcation for the allow-tlw mate procedures and applicable code require-was opened to document ance of "rebake" temper-ments and show that handling of illier material qualifications sheet atures and holding times meets the required codes. errors for 3 welders. that all i f er iaon the requirements of the ASME and AWS Codes, a No code deviations exist. [T N R+D
e PMtN; HAM Pt.AN CtfRRENT ASSESSMENT OF SAFFTY SIGNIFICANCE ISSitE & TITIF DESCk i t"I'I(.N OF ISSt!E I PAL APPROACil TO RFSot tf710N DATE NONE tl. TO %2 >%% JUSTIFICATION 23 QA Program Breakdown Determine the cause et LPAL will review corrective action commitments 7/13 The Mercury reviews between Ebasco and the breakdown, the ade-made on the NRC enforcement action and provide have been completed Mercury. quacy of the cor rective a detailed evaluation of the actions taken. A with the exception of action, and provide review of the audit programs will be performed to SCD-61 "I.inear Crack assurance on the ade-evaluate frequency and followup of required in Stainless Steel quacy of the operational corrective actions of the program. Tiw indepen-Tubing"(currently under QA Program, dent management assessments will be reviewed with reevaluation). The actions taken. review indicates that there are no open items LP&L will provide a.: assessment of the overall QA affecting plant safety. program to provide assurance that the QA program can function adequately during operations. o s T 5 N
gv LOUISIANA P O W E R & L I G H T ! NEW CREANS.LCX.pS: asve - es - c oc-ANA 70160 4 [So4l 595 a2One MIDDLE SOUTH UTIUTIES SYSTEM J.M. CAIN President and June 20, 1984 Chief Executive Othcer W3B84-044 5 Mr. Saul Levin. NUS Corporation 910 Clopper :'ead - Caithersburg, Maryland 20878 Mr. Robert L. Ferguson UNC Nuclear Industries, Inc. 1200 Jadwin, suite 425 Richland, Washington 99352 Mr. Larry L. Hu=phries UNC Nuclear Industries, Inc. P.O. Bcx 490 Richland, Washington 99352
SUBJECT:
Pre-Licensing Issue Assessment Task Force Charter
REFERENCE:
Discussions in the Offices of Shaw, Pitt=an, Potts & Trowbridge, Washington, D.C., June 13, 1984
Dear Messrs:
Levine, Ferguson and Humphries: Pursuant to discussions in the ref erenced meeting, this for=alizes agreements s-- reached between us as to the charter of the subj ect Task Force. The roles of UNC and NUS will be to act as a task force in providing assessment and advice in responding to the NRC letter of June 13, 1984 It is important to emphasize that both UNC and NUS will maintain suf fi:ient independance in order to provide to me as Chief Executive Officer of LP&L an independent pro-fessional assessment regarding the functions listed below. Your assessments will be formalized and sent to the Director of the Office of Nuclear Reactor Operations at the same ti=e they are provided to me, e The Program Plan and implementation schedule requested in the NRC letter. 8 The adequacy of responses and resolutions (including validation of data and sources, as appropriate) of the matters set out in the NRC letter. I a
Wre-Lice = sing Essue essessment vage z ,. Task Forca Charter June 20, 1984 e The safety significance of the matters listed in the NEC letter with respect to: - Fuel load and testing up to 5% power - Operation above 5% power e The adequacy of the past QA/QC program in light of the matters listed in the NRC letter, and the resolution of such matters. Recommend institutional or program $atic changes that are ~ 9 deemed appropriate during plant operation in light of the lessons learned as a result of the matters set forth in the NRC letter, and the LP&L responses hereto. The following abbreviated organization chart is provided to clearly depict that the Task Force is t,o have access to and interface with all necessary elements of the b'aterford staff but is to report directly to me. President & Chief Executive Officer (LP&L) (J. Cain) Task Force ~~ Senior Vice President - l Nuclear Operations (LP&L) (M. Leddick) i Safety Review _______________ Committee e i I Quality Assurance -------Proj ect Manager (LP&L) -------Plant bbnager (LP&L) Manager (LP&L) (D. Dobson) (R. Barkhurst) +-%-, (T. Gerrets) i f -__________________________{_____________ Ebasco & Staff LP&L & Staff Reporting
Interface
-==- Very tr y yours, a-J M. Cain JMC:D ':ph cc: C. Charnoff, R.S. Leddick, D.E. Dobson 4 A ,.e w - -, e 4-.. r-,,y w
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LOUISIANA / a,7e - s - m oo - o POWER & LIGHT / NEW CALEANS, LOUSIANA 70160 4 *C41595-22C4 M100LE SOUTH UTIUTIES SYSTEM J.M. CAIN President and July 27, 1984 Chief Executive oflicer W3B84-0459 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Co= mission Washington, D.C. 20555
SUBJECT:
Waterford 3 SES Revised Program Plan
Dear Mr. Eisenhut:
The purpose of this letter is to submit to you for your review and comment LP&L's revised program for resplution of the twenty-three (23) issues described in your letter of June 13, 1984 The enclosed program has been reviewed by the Safety Review Committee (SRC) Subcommittee and by the Task Force whose functions were described to you in my letter of June 28, 1984 Please note that our ap-proach to resolution and our assessment of the 23 issues in the revised program plan reflect our current views and are subj ect to change based on NRC staff comments and our completion of these issues. The SRC Subco=mittee has been reconstituted and now consists of Ken Cook, Bob Douglass, Ray Burski and Joe Hendrie. The schedule for submittal of our response to each issue is being discussed by our staffs. The majority of the responses are in near final form and I hope to have all responses as well as our assessment of the collective sig-nificance and the intended programmatic changes submitted by mid-August. Sincerely, J.M. Ca in JMC:DA:pbs of=j g 7,6 0 ,1 Attachments 0 gL g i q a
e Mr. Darrell Eisenhut, Director Page 2 W3B84-0459 July 27, 1984 cc: R.S. Leddick R.F. Burski Waterford 3 Waterford 3 D.E. Dobson K.W. Cook Waterford 3 Waterford 3 Les Constable T.F. Gerrets Waterford 3 Waterford 3 Saul Levine A.S. Lockhart NUS Corporation Waterford 3 910 Clopper Road Gaithersburg, MD 20878 R.P. Barkhurst Waterford 3 Robert L. Ferguson UNC Nuclear Industries Joseph Hendrie 1200 Jadwin, suite 425 50 Bellport Lane Richland, WA 99352 Bellport, NY 11713 Larry L. Humphreys Robert Douglass UNC Nuclear Industries Baltimore Gas & Electric P.O. Box 490 8013 Ft. Smallwood Road Richland, WA 99352 Baltimore, MD 21226 J.T. Collins Mike K. Yates, Proj ect Manager U.S. Nuclear Regulatory Commission Ebasco Services, Inc. Region IV Two World Trade Center, 80th Floor Arlington, Texas 76011 New York, NY 10048 Dennis Crutchfield Russell Christesen, President U.S. Nuclear Regulatory Commission Ebasco Services, Inc. Washington, D.C. 20555 Two World Trade Center, 93rd Floor New York, NY 10048 George Knighton, Chief Licensing Branch No. 3 Dale Thatcher Division of Licensing Waterford 3 Instrumentation & Control Washington, D.C. 20555 Team Leader 7920 Norfolk Ave. MS-216 Gerald Charnoff Bethesda, MD 20114 Shaw, Pittman, Potts & Trowbridge 1800 M. St. N.W. Larry Shao Washington, D.C. 20555 Waterford 3 Civil / Structure Team Leader 5650 Nicholson Ln. Mark Peranich Rockville, MD Waterford 3 Investigation and Jay H M sm Evaluation Inquiry Report Team Waterford 3 QA Team Leader Region III 4340 E W. Hwy, MS-EWS-358 Bethesda, MD 20114 Glen Ellyn, IL 60137 ___.m.
p-zw -M;.~jv3.=%&L:% MD-W: MMC W = 'e.' & % ** E d D.a L_ -, ~ i'i tE L n a e ~ July 23, 1984 ( WATERFORD 3 PROGRAM PLAN AND SCHEDULE I.. INTRODUCTION AND PURPOSE This Program Plan outlines the methods by which the 23 individual issues described in the NRC letter, Docket No. 50-382, dated June 13,~1984, are to be resolved by LP&L. Further, the Plan provides a mechanism to address the cause of the issues, the generic implications and collective significance of the issues, and the programmatic and management changes designed to preclude recurrence of such issues. The Program includes a separate review of the resolutions by 'the Waterford 3 Safety Review Committee (SRC) Subcommittee and the establishment of an inde~ pendent Task Force to advise LP&L and evaluate LP&L's resolution of the issues. II. PROGRAM PLAN MANAGEMENT 1. The LP&L Project Manager - Nuclear is assigned responsibility for management of the overall Plan and actions outlined in paragraphs.III and IV below. He will perform these tasks in a normal line management role and have access to and the -support of any requisite LP&L and contractor managers and staffs on a top priority basis. He will assure effective interfaces with external, groups including the SRC and the UNC/NUS Task Force described in paragraph VI below. i e I
- 2. 'The Project Manager - Nuclear reports directly to the Senior Vice President - Nuclear, who in turn reports directly to the President and Chief Executive Officer of LP&L. Both the Senior Vice President - Nuclear and the CEO are directly and actively involved in the management of the Program, t
III. RESOLUTION OF ISSUES 1. Each issue will be analyzed to determine: The cause I The generic implication p L I The actions and schedules to correct both the specific problem and related generic concerns [ The safety significance with respect to fuel load and low { power-operation, and to operation above 5% power 4; o ,4 f' _ _ j g
7. 2.,, .s ,e. ) i l \\ l 'i 2. The intended manner in which each of the 23 issues are to be addressed is described in Attachment 1. It should be noted that the manner of resolution may need modification as actions necessary to resolve any related safety concerns are undertaken or additional sources of information become available. IV. COLLECTIVE SIGNIFICANCE AND PROGRAMMATIC CHANGES i As early as feasible in the process of formulating the information contained in paragraph III above, the LP&L Project Manager - Nuclear will: 1. assess the collective significance of the individual issues, and 3 2. recommend insetoutional or programmatic changes deemed appropriate to avoid recurrence of the types of problems underlying the issues being addressed. V. SAFETY REVIEW COMMITTEE 1. The Waterford 3 Safety Review Committee (SRC) has designated j an SRC subcommittee to review the items outlined in paragraph ( III and IV above. 4 2. The SRC subcommittee consists of.Kenneth W. Cook, LP&L j Nuclear Support and L{ censing Manager, Chairman; Joseph M. j Hendrie, Consulting Engineer; Robert M. Douglass, Manager of 1 Quality Assurance, Baltimore Gas and Electric Company; and Raymond F. Burski, LP&L Engineering and Nuclear Safety Manager. 4 VI. INDEPENDENT ASSESSMENT ? 1. An independent assessment of the resolutions and i determination of safety significance will be provided by a i Task Force reporting directly to the CEO of LP&L. The Task j Force consists of officials of UNC Nuclear Industries, Inc., j Richland, Washington, and NUS Corporation, Gaithersburg, Maryland, who will be assisted by UNC and NUS staff members, i j as required. The Task Force will independently assess LP&L's resolution of the issues, including the cause, generic L implications and collective significance of the issues. The ] Task Force will also provide advice and assistance in the a resolution of the issues, and will provide an independent assessment of the safety significance of the issues with { respect to fuel loading and low power testing, and operation l above 5% power. It will assess the adequacy of LP&L QA/QC program in light of the NBC's issues, and will recommend any institutional or programmatic changes which may be necessary to prevent recurrence of the issues. 1 l 1 1
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f f t1 E 1 l 2. The charter, identification of principals, initial functions have been formalized, as specified in Attachment 2 hereto. iij VII. RESPONSE TO NRC u The individual issues vary considerably in both the degree of L concern and complexity of resolution. Therefore, LP&L intends to j forward to the NRC the proposed resolution data individually or in packages as they are completed and have undergone the degree of review specified herein. Some of the resolutions may be submitted before completion of all requisite corrective actions, which are underway or defined and scheduled for accomplishment, have been accomplished. Upon submittal, each resolution will be j added as Appendix A of the Program Plan to constitute a major part of the final report. l VIII. SCHEDULE 1 The goal of LP&L is to submit by mid-August 1984, the resolution of all issues, our assessment of the collective significance of j those issues, and the programmatic changes deemed necessary to j avoid recurrence of those issues which ipdicate such changes are appropriate. e. ) A l 9 i .) i li i I 1 ? 1. 4 ll.
z ' w.. - - -~=nm&, M. ;wrc~:.2... ~.nm. n-c..,&-esa.a.*- a u. 1 -. ~ * - ~ = ^ ^ "" L A *-~ " ' ~ ' ' ^ ' * " - ) :Y t .a FROGRAM PLAN 'i ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACM TO RMS01RTION CURRENT ASSESSMENT 9 I 1. Inspection Personnel Verify the proper A verification program has been established to To Be Determined Issues certification of alte review the professional credentials of 1001 of th,e g QA/QC personnel or site QA/QC personnel. includtag supervisors and i requalify the work managers. The discussion that follows applies to performed by these all contractors except J.A. Jones. Fegles and CEO. -j . personnel. which are addressed la Issues 10 and 20. Criteria i for certification or qualification of QA/QC Q personnel will be based on QA program requirements and contractual commitments. ,{ The adequacy of credentials to support certif- ~ ications and qualifications is being reviewed. Criterid have been established to sort personnel ~- files into 3 groups: ..g* f M A. Qualificatione deemed adegaste g
- 5. Inadequate docummatation to perform evaluation S
4 h C. Qualifications queettomable. S 7 . Other site files will then be researched and con-tractors contacted for personnel in groupe B and C to verify their acceptability. In addition. background investigations will be performed for a sample of personnel in all groupe, including essentially all Mercury personnal and a large sample of Tompkins-Beckwith personnel. If certification of an ladividual can not be - Justified, he will be placed in a fourth group l! designated group D (Qualification inadequate). Appropriate alte nonconformance documentation will be initiated to document evolmation of safety sigafficance and corrective actions. including reinspections of work perforund as necesoray. ,1,, For Ebasco. LP&L. and other site construction related QA/QC personnel remata$ag ou site, a revertf t:stion of proper certificatica is being accomplished la accordance with ANSI-545.2.6-19M. Qus11ty Control functions currently being under-taken as part of the walkdouns in prostees are being performed by personnel reverified as qual-ified under ANSI-N45.2.6-1973. b U. I* I L ,t. "h s
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ISSUE a TIT 12 DESCRIPTION OF TSSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT 4 i 2. Missias M1 imetrument Terify compliance with Frior to the Nec inspection, the Ebasco quality The combination of the reviews Line Doc - ration NRC requirements for M1 Assurance Installation Records Group had reviewed described has provided assurance instrumentation the ASME Section III portions of the N1 instrument that documentation is available to e installations. installations. Full documentation on the assure the quality installation of installations under the scope of this review is all N1 instruments. available. .? The scope of this concern has been narrowed to 12 installations. 4 welded and 8 threaded. The documentation on the ANSI B31.1 portions of these ~, instrument installations that were installed with class breaks (i.e. ASME Section 111 to ANSI B31.1) has also,oow been reviewed and is summarized as follows: '~': 1. Final visual inspection documentation is now 5 j available. 4 2. Ten installations have documented hydrostatic tests. The remaining two are MVAC welded connections and do not require hydrostatic testing. 3. Material traceability to the point of install-ation is not available however Certificates of Conforasaca to specification requirements are available. 4. Walder identifications are not available in all case s. However, all Mercury welders were required by procedure to demonstrate qualifi-cation for the appropriate welding process ~ prior to being issued weldrod. 5. Nondestructive testing data is not required for these installations. We have conaldered other design changes related to the classification of N1 instrument loops and have concluded that a similar situation has not occurred. 3 T . l.
- [
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pwrg. _ sxrcrv- : - ~. - g...,__w__ m.,__, ,,a, n .,... n -*[ e t1 I N ~ i y 's pt0 CRAM p1El l i ISSUE & TIT 1.E DEscalpTION Op ISSUE 1.p4L AppBOACE TO RESO1.UTION QfRRENT ASSESSMDIT \\- 3. Instrumentation Correct separattoa Mct-v3-7702 covers the system 52A probleme Although separation violations have Expanaloa Loop criteria violations and has been dispositioned to remove the been found, none so far identified Separation found ta systea 52A and espanaloa.loope in questica and replace with would af fect plant safety had they provide a program for stratsht tubing. been left uncorrected. p review of other safety. related systema for NCR-W3-7730 was generated to track the generic This provides a high level of i separatico violations concern of tubing separation. la order to provide confidence that other design M + and take the necessary a basta for determintag the scope of our approach, considerations and usikdowns (i.e. ,N corrective actions. a sample of 45 addittomal tastrummet tascallaciana ylpe rapture / jet impingement was reinspected. Those choses were la congested analysia, non-seismic over estamic ..i areas where separatico violataans would have the criteria and walkdovna) in highest probability of occurrence. Thirteen combination with the tubing deficiencies were found out of 276 locations, separatico criteria have provided. $g and were evaluated. None required rework. adequate protection for the f instrument installations. "7 A QC verificattoo of all other limes (approatmately 64) with red = h r tubing ruas in A final determination of safety proximity of each other will be performed. algnificance will be made upon com-plation of the reinspection. 9 l: 4 W la 6 ? h , ~ e i 1 e , c [- [. 1 _n.
% = ~ % r. wiw w s.W2.aa m.w ' - - m.__a m.. m.x ~ _ w.; - w-. ~ ~...w., -m b 8' g s h 4 Gr f .p PROGRAN PtAl .6 ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTTON CURRENT ASSESSMENT l 4. Iower Tier Corrective LF4L shall review all LP&L has to date reviewed all FCRs. DCNe, EDNs and The current review has demonstrated Actione Are Not Being TCRs. DCNs. EDNs. and Tompkins-Beckwith DNe cited by the NRC in the that there has been adequate QA/QC Upgraded to NCRs T-R DNs to assure that Description of Concern, as well as all voided IDNs. involvement in all lower tier + proper corrective documents with regard to 10CFR50 ',tl action was taken. LP&L's review has established that only two of the Appendix B corrective action and tacluding an adequate fourteen cited FCRs/DCNs and three of the 22 cited non-conformance requirements. This veview by QA. This EDNs and T-R DNs should have required an NCE. involvement ensures that appropriate corrective action shall in each case however, there was no safety signifi-corrective actior.s. specific and include the steps cance se regards 10CFR50.55e and 10CFR21. None of generic, are identified. j required by 10CFR50 the voided EDNe required an NCR that was not Appendix 8. Criterios generated. Our current evaluation of the XVI Corrective Action examples of lower tier documents g and for Construction The response to this concern will provide an cited by the NBC demonstrates that C Deficiency Reporting, assessment of the lower tier document Teporting although a small percentage should, 50.55(e). Also, system. It will verify that it was structured in have been upgraded to NCR's under
- 1ecluded in this review such a meaner that procedures. integral to the the quality program in effect, none aball be the Quality Frogram. Provided a sound *> asis for had safety significance.
i asamination of improper decisions regarding the severity level of documents vaiding of all other used to report deficiencies. The assessment Thus. LP&L has unfidence that the / deatgn changes or specifically considers QA and QC reviews of sample review will provide discrepancy notices engineering / construction judgements on deficiencies additional evidence that the j that af fected safety-as it relates to the corrective action and noncon-projects' system of " checks a related systems or that formance requirements of 10 CFR 50 Appendix B balances" ensures that, despite were misclassified as and the reporting requirements of 10 CFR 50.55(e). 1solated cases of judgemental or
- safety, interparative errors, all lower tier A random sample of approximately 700 FCRs. DCNs.
documents, as well as FCRs and DCNs EDNs and T-B DNs will be formally reviewed to receive adequate evaluation for determine if any should in fact have been reported safety significance, as NCRs. Any so judged will then be reviewed for reportability under 10CFR50.55e and 10CFR21. The results of this review will dictate whether there is a need to expand the sample sire. ~ e0 '$n ? i 6 O e I I N '3 4 f
m w;gg s -g _.-.s: 13 y. 2.;A% u,,.. m ugg.g y,u, f a ,,,,,- - w p ,,w-- - wwpu-y ?. A e e s _I i ,l. v.g q. jb, .k .[. { ~ ,,N 1:4 7" P90CRAll PLAN 89I) T ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APP 90 ACE TO RESOLUTION WERENT ASSESSBRENT f
- 5. Vendor Documentattoa #
The concern relates to Recorde associated with CE material and equipment The existence of Candittenal ~ Conditional Releases whether shortcomings in were re-reviewed and Conditional Certificattoos Certificattoms on CE equipment contractor's . identified. An seassement of the poteattel for reflected incomplete Purchase k documentation, the entotence of other manufacturing open itene Orders, not hardenare or software particularly Combustion not being tracked in the Master Tracking Systes deficiencies. ' ', 3 Engineering's, which (MTS) was conducted. It led to the conclusion eststed at the time the that the potential for a similar situation estated No items of safety significance have
- material was supplied have only la areas where problems are identified off-been found thus far on the other been corrected.
site relating to material to be shipped to the three areas of concern. atte. As a result of this concern the following g 'k areas are being evaluated: Concerns noted by vendor QA Reps on Release for shipment forms. ~ ~ ' NCRs controlled by Ebasco's Home Office g* + Material received at the ette under asaufacture. a deliver and erect type contracts. To date 8 of 14 CE Conditional Certifications have been changed to unconditional. The remaining 6 will have Unconditional Certifications by 9/15/84 The issues that required resolution deal with tech-f alcal manuals and have no effect on equipment operation. The review conducted on the other three areas of potential concern is nearing completion. I e Y ~ * .4-e e i7 j V, s.' ' d ',,- { - _ ' N. w.4 e " o' 's of
VyMJ7AC L'A %m ' t,- 2 -- ' - '. ;.c.,. ' a. m g. ' % & A.4,.,a "...(.. -e-' " ~ ' ' ' U. i ht A h.W i s + 4 t PROCRAM FLAN 4 ISSUE & TITLE DESCRIPTION OF TSSUE LP&L APPROACH TO RESOLUTTON CURRENT ASSESSMENT 6. Disposittening of Sona Ebasco and Marcury First, the in-place program for handling of lower To date none of the potentially Non-conformance and NCRs and Ebasco DRs were tier documents such as DRs will be discussed. deticient NCRs that have been Discrepancy Reports questionably reviewed and evaluated have safety dispositioned and 1ESL Second, the specific NCRs and DRs cited by the NRC significance. shall propose a program have been evaluated for proper designation, to assure all NCRs and disposition, and implementation of corrective action A final determination of safety DRs are appropriately under the existing quality program. Six of the significance will be made upon h[h upgraded, adequately fifty NCRs were determined to not have been completion of the evaluations of dispositioned and adequately dispositioned and are under evaluation. potentially deficient NCRs and the corrective action field verification. coupleted and that any Third, a program, review of Ebasco NCRs was started prohlama detected are by LP&L in January, 1984 to assess the validity of corracted. the dia' position, the corrective action taken, the completeness of the documentation, and their proper ~'l closure. Approximately 460(62) of the more than 7700 NCRs reviewed have been identified as having ~ potential deficiencies in the above attributes. These are being evaluated. The deficiencies that have thus far been evaluated have no safety significance. Fourth, a field verification will be conducted on a ~ random sample of 122 (over 252) of the potentially deficient Ebasco NCRs to ensure that the hardware and/or software corrective action has been completed. Fir. ally, the Mercury NCR's and Ebasco DR's cited by the NRC have been reviewed against the attributes mentioned in the concern. Information from this review is p rrently being evaluated. = 1 Ie (.< I a
4 Znt '-.. w. UK.4w,4 ,a L... .%._u- ,c_ m m _._, _-w--- ou_ % g. _ -. m j m .o. c< f l v pBOGRAff Pt.All I Issut a TITLE DESCRIpT10lf op ISSUE Lp6L Appanaru to agS0tET10N CURREIIT ASSESSMBIT a 7. Backfill Soil Conduct a review of all A review of backfill records (i.e. backfill soil The soit density is in compliance Densities soil packages for density laboratory test data and taspection with specification requirements. i, + completeness and reports) wee lattiated to determine completenese technical adequacy, and technical adequacy. A three stage progree for Where records are the evaluatica of soil backfill densities was missing or technical toplemented to (a) locate all backfill soil data. problems are defined. (b) review the test records for completeness and i" take corrective action. utilise these for the constructica of relative density overlay plots, and (c) evaluate docuesacation and overlays for complian e with
- f specification requirassato.
It was determined that a complete set of soils test data exista at the site, and that the field ,y and laboratory testing and insite relative deastty' "'T of the class A backflli were la compliance with . :p specificatica requirements. ,1 A review for completeness of the rematader of the s soil package data for attributes other than ?. density, which includes all inspection reports, is presently being performed. f IO a 1 t' e a e e a Y a i.g ,4 a
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.a u _ .u.. n.a. -w~ - <-wey y . ~.-->m, m - ~ w I t .9, e i i 1 I s. l 4 s PROGRAM FIAH g. ISSUE & TITLE DESCRIPTION OF ISSUE tp&L Arpt0 ACE TO RESOLUTION CURRENT ASSESSMENT I S. Tieuel Eneminetton Document inspectione Shop welde were taspected and accepted during No deficiency estate, of Shop Welde during of shop welde during hydrostatic teste by en Authertsed Nuclear M Hydrostatic Testing hydro tests or other-Inspector. vlee verify such' inspection. The ASM N-5 cede data reporte eles caafirmed that there wee taspectica of shop welds. The methodology of the field hydreetatic teste provided additional assurance that shop welde were inspected. W't. .[ 1 ) ~ n 't. Ii V ,4-u ^ zp: p I '~ (. ) i e ' t + m i. 4
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a m w. ~... ac '-2 _ w m2. m n.... n.. : - ~.w s...L .w-A~.-~.-4-..' 't.an.~.3........ s 6 1 \\ e i I 1 FROGRAM PLAN ISSUE & TITLE DESCRIPTION OF ISSUE LFAL APPROACH TO RESOLUTION CURRENT ASSESSMENT 9. Walder Certification Locate missing documents NCR W3-7549 was generated on 2/1/84 to track this All welding evaluated to date has for instrument cabinet problem. No documentation was found on three of been found acceptable. A final welds and determine if the eighteen cabinets and partial documentation determination of safety significance welders were appro-found on four. All seven were reinspected and will be made upon completion of the priately certified. founJ acceptable after evaluation by Engineering. review. Take appropriate action to assure the quality As a result of the missing documentation, e cf the supports if review is being performed to determine other $g A documentation cannot miscellaneous cases where J.A. Jones performed 7 be located, welding. Documentation for the welding identified will be reviewed. ? no 98 m E 4 n
C p'a. s w. 4 aw M % A. 'a.s % +co.. - ~. - ~ - * ^ - N " 'TC4R M - 3- --- i I d F90 CRAM FLAN TSSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT
- 10. Inspector Quali-Verify the proper certi-A verification program has been estab11shed to To Be Determined fication (J. A.
fication of QA/QC review the professional credentials of 100% of the Jones and Fegles) personnel and evaluate site QA/QC personnel for J.A. Jones and Feglas. in-the impact of any ciuding supervisors and managers. Crataria for deficiencies found. certification or qualification of QA/QC personnel will be based on QA program requirements and [ contractual commitments. y %s The adequacy of credentials to support f certifications and qualificationa la being reviewed. Criteria have been established to sort personnel files into 3 groups: l A. Qualifications deemed adequate l B. Inadequata documentation to perform evalsation ~ C. Qualifications questionable a i Other site flies will then be researched, and J.A. Jones and Fegles contacted for personnel in groups B and C to verify their acceptability. In addition, background investigations will be performed for a sample of personnel in all groups. If certificattom of an individual cannot be justified, he will be placed in a fourth group designated group D (Qualification inadequate). g Appropriate site nonconformance documentation will be initiated to document evaluation of safety significance and corrective actions, including reinspection of work performed as necessary. g~ s- =
_u,J..:. l:mu-- - '--p'm; 1 - = .2 n;w. m _,,,,My . % w,.. m --- - - ~ w a v._ u L tLu a. a t o. 4 g f c, ISSUE 8 TIT 1.E BESCRIPTION OF ISSUE 12&L Ap 10 RESOLUTTON CURRENT ASSESSMENT
- 11. Cadwelding Provide the cadweld The cadweld recorde have been transcribed onto Based on the previous disposition of data for the project la -
compu'ter data storage. This tactudes the placement NCR W3-6234, there is no reason to such a form that it can area. cadweld number. cadwelder. bar size, bar anticipate any significant be readily compared to position. visual test. productica test, sister deficiency. j the testing criteria test. cadwelder qualification dates and used for the Waterford taspector amas and qualification dates. 3 project with data broken down by various In this form the cadweld data can be called up by 4 categorise. Provide any of these attributes to expedite review for S data on welder quali-specificacios compliance or other reason. Aloe. ,I ) fication and requali-physical location of cadwelde may them be readily g fication tacludtag obtataed by reference to the concrete placement 6. dates. lif t diagrams which locate the placements. W 7 i Prior revieve have already been accomplished ""~T [ under NCR W3-4234 (opened 5/16/S3) and + 1 seacomforming conditions resolved. A re-evaluatica i< is betas conducted now that the cadweld data to is { a more systematic, auditable forant. ~ [ [ i i I T I i e, p., ,t [ .A , - f-4 e,' (,, 8 ...u..
y.m.-%: w A.- , w hsii 2,Ja.c..ea m a,, <.. ; ;_o s _ 2,%w ;m, ,g. y ) ' f c i e
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g i g pm TSSUE & TITLE DESCRIPTICII 0F ISSUE 1F&L APPROACE TO RESOLUTION CUnmarr ASSES $2NT v.
- 12. Maim Steamline Complete the document-SCD 70 wee resolved and subsequently reopened upea All corrective actica has base Frasios Restraints aston for all discovery that taspections la the steam generator compiered in accordance with the connections la the fraziog were act complete. NCE-W3-7736 was 1seued to criteria stated la the SCB 73 I
staae generator framlag. track resolution of the deficiency. A 1001 QC Docummatation Fackage. k retaspectica of steam generator frastas connections ) as well as a review of the American Bridge work- } scope against the scope of SCD 73 retaapections wee j P performed. l ~ This verified that only steam generator framf ag ] connections were omitted from the original scope of SCD 78. All corrective actice has been completed. . s 9 4 't n 4 g i b 4 l I ee / t I s 9 9 9 .g e Y r. a
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-x .....w&-a.. M L..k a. ... m -- -. u - e "- -s M ,- d - + p %N ISSUE & TITLE DESCRIPTION OF ISSUE LP&L AFFROACM TO RES01.UT10N CURRENT ASSESSMENT L3. Missing NCRs LF6L shall obtata The concera specifically stated that there were 10 As a result of the review, all NCRs the alasing NCR's. NCR numbers misstag *f rom the QA vault and card not on file la the QA vault were explata why these NCR'a indes file. This is correct and is due to the fact either found. located or probably not were not maintained la that all of these NCRs were voided or cancelled tasued. the filing system review prior to 1semance as indicated la the manual log them for proper voiding, that was maintained at that time. The purpose of the and assure that when an card fades file is to locate NCRs which are actually = tenue is raised to an on file in the vault, not those that were voided or NCR. it is property filed never issued. for tracking and closure. Nowever. la response to the NRC's general statement i that "Others were also noted to be missing from the l Ebasco QA Tault".1.P&L has l '4 l
- Reviewed for accountability a!! Ebssco Site and New l
Tork Office tassed closed or voided NCRa for ~ I;- accomatability (8200 total NCRs). i
- Provided substantiating evidence on those NCR4 l
indicated as void in the logs.
- Frovided substantiating evidence that NCR numbers in the sequence indicated act to have been assigned d'
to an NCR is correct. a. l L-k m I g
nKra M L*: - m m = m ---w..a.. a.r m... m x x ..:s... m m.. u .:..... m a w;mmm w ~ m y m - r, I - l 4 ,g e i l 2 issue a TITLE DESCRIPTicu or issut 1.F&L APP 906CE 10 RESoufficW CURREWy ASSESSMENT i 14. J. A. Jamee Speed Dortag the Ibasco Q& Firet. a review has been conducted of corroependence No problems of esfety significance t letters and EIts review of J. A. Jones between J. A. Jones and h ea via Speed lettere and were found la the J.A. Jones speed 1sttere and eag-ElBa. Second, corteependence which conveyed desiga correspondence. The review of other Saeertag Saformattom changes to J. A. Jones without reference to contractors is nearing complettom and i requeste. eeveral items follow-up actica to formalise the chaeges use no problems of safety significance i that could affect plant conducted to determine safety significance. have been found to date. aatety were acted. i Based on its sample of Of appronia tely 1100 J.A. Jones documents reviewed. these actione, the staff 271 appear to coevey destga changes. These 271 have does not espect that any been evaluated and researched om a case-by-case .y of these items will basta and deterstaed to be acceptable as is aves sigatticaatly affect thr.am they represent a procedere violation. No C plant safety. safety problees have been identified., 1 Nevertheless, the app- ..y 11 cant should complete Third, a maatama of 101 of engineertag saformation g the actions identified requests generated by other safety-related T la these reviews and contractors was sampled to determine if they need teaues raised shall be destga changes conveyed by such taformal documents.
- d resolved promptly.
The sample size was espanded depending on the reanics of the tattial review. Fourth, any design changea identified are betag reviewed for safety significance. The initial review of the other safety related contractors has been completed. No safety related problems have been identified to date. Addittomat sampling te belas performed on three contractore. i y 4 I + f
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... _ -. - _ _, ~,,. _ _ _ _ _ _.. _ _ _ _ _. - _. _. ~_ .__m______-.__ ..___.__m.____., _--m,_ i i 1 i ) i P90 CRAM F1AN J ISSUE & TIT 1.E DESCRIPTION OF ISSUE 1.FAL APP 90ACM 70 RESOLUTION CURRElff ASSESSIENT i l
- 15. Welding of "D" level 1.ocate the documentation The CB4144 manual requirements for documentattom preliminary results from the ongstag Material laside for "D" level material of fit-up and final weld taspections do not apply.
inspectica tedicate that the "D" g, I Containment welding and verify the per their manual, to "D" material welds. This material welds are acceptable. A i adequacy or the Jocumentation is therefore not available for all final determinattom of safety l informattom or perform a "D" material welds. eigatficance will be made upoa material analysis and completion of the reinspection. 1 MDE work, or gework The "D" mate:ial welds were performed by the l I the welds. same welders and taspected by the same weldtag l 1 supervisors and to the same standards as the 6 ) rest of the CB41 work for which documentation is provided. Considering this, and the quality i 1 of CB&1 work on this project. it la not expected i i l that any quality problem ent sts with "D" material welds. f.p6L will, however, in accordance with j g g a formal Q4 procedures h t f T
- Strip paint off of a 5% sample of "D" material welds fwa which no documentation is available and provide full visual inspection.
- Reinspect another 5% sample of "D" material welds without stripping paint.
+ I The results of this reinspectica vill determine i if there is a need to espand the sample size. [ To address the NaC's specific concerns. Ebasco has evaluated the containment spray piping weld - 4ttachments. All containment spray piping veld e attachments were installed and documented by } Tompkins-seckwith except for two. The results se far demonstrate that failure of these two welds e d will not preclude the piping f rom performing its f design basis function. Ebasco is presently 1 finalizing the analysis by redistributing the loads 3 to other supports under the assumption that the two 1 "D" level attachments do not exist. I s I + J u I W 4 4 4 I l 1 i h l
i l I PaocsAM PLAN ISSUE a TITLE DESCRIPT1018 OF ISSUE 17tL APPROAOi TO RESOLUTION CURRENT ASSESSMENT 16. Surveys and Exit LF&L should develop and LP&L has e4 cured the services of Quality Technology Reviews to date have not identified Interviews of QA implement a formal program Company (qtC) to implement an enhanced program to safety concerns not already Personaal for handling issues raised conduct emit laterviews of personnel departtag the identified. by individuals. One of site. QTC will aise review the interviews conducted the first tasks to be to date to assess whether the corrective actions dealt with by the program for Elie concerns identified thereon are l shou!J be the review of appropriate. Procedures have been approved which I the responses previously assure management involvement. l provi. tad to the QA survey i and during the exit interviews.
- \\
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-_ ~._ I i etOCRAM FLAN issue & TITLE DESCRIPTION OF ISSUE LP&L APP 90acM TO RESOLUTION CURRENT ASSESSMENT I t,
- 17. QC Verificatice of The Nec le concerned The review of this matter tadicates that six of the The review of Mercury Q& records Espaaston Anchor whether there was seven cited QC reviews were made as required by the conducted by Ehasco prior to !J&L Characteristics suf ficient QC verifica-drawings which were referenced on the taspectica turnover, the resultant field tica of the character-forms. This was substaattated by a thorough review verifications, and the directicas t
latics necessary to of Mercury quality records. LF4L will prepara a provided by the documents referenced ensure proper installa-resposee discusatag the tacorporatica of drawings la the Mercury Espansica Anchor j j tion of concrete into the procekere. training of Mercury persommel, procedure provide assurance that QC i expaaston anchors the QC review and substantiatica of records and verification was adequate. [ installed by Mercury. evaluatica of the cause of the problem. I i The seventh attribute cited by the NRC is spacing ? betweeg anchor and embedded plate. The response j will ref er to Ebasco design drawings,which allow anchor plates to overlap and be welded to embedded M l plates. It will also provide the results of ea S anaylsis* performed on worst case situations of f f Mercury anchor plates butting up agatast embedded i i l plates of different stres which demonstrates that I the anchor and embedded plates are still capable of withstanding the original design loads. f Based ce the above discussion and our review, no I additional retaspectica la believed necessary. t i No revision is necessary to procedure SP-666 since this procedure is no longer in use at the site. \\' i ? l l i i 4 k n.
_ ~ -.. m.__.. _ _. _ t' ~ { I t I paOCaAM M e tsser a TITtt nascarrTms or issur 1.rst. Arreonas to mascLarios cumanrf ASSESSMENT j
- 18. Documentation of Documentation should be Decumentattaa actasting to the scope, conduct and The destga and construction of
) Wikdowns of Non-provided that clearly results of the walkdowns will be provided. hterford-3 considered interactices Safety Belated shows what equipment was of non-metemic Mechaatcal, Equipment reviewed dortag the The response to thia issue will also establish that Electrical. MVAC, Civil and ! l walkdowns and on what in our opinion. the destga sad tastallation Instrumentation equipment with bases it was concluded adequately censidered the ef fects of interactions of safety-related equipment. that the tastallation non-seismic wgth safety-related systems during as was acceptable. SSE. The walkdown verified that such interactions do not constitute a safety concera. t ~ g e L e 1 l ,r 1 i V 1 l i 1
_-m ) \\ t 6 l c-PROCRAM PIAN ) TSSUE & TIT 1.E DESCRIPTION OF TSSUE LF&L APyR0ACM TO RESOLUTION CURRENT ASSES $8ENT r
- 19. Water la Basemat Review all conduit that A walkdown was performed which identified 28 places There was never a path for ground e
Instrumentation penetrates the basemat where wetness due to seepage from conduits was found water to flow in sufficient quantity Conduit and terminates above the and 12 places where evidence of past leaking from to flood the aus111ary building f top of the basemat to conduits was found. Neither the present slow basement, even before the seals were assure that these seepage thru some of the seals nor the seepage that lastalled and before the temporary poteattal direct access would result from a gross failure of the seats conduits were grouted. The floor paths of water are presents a flooding hazard. The decistoa to replace drata and sump. pump system was more
- i properly sealed.
the seals will be based strictly on operational and than adequate to baadle the quantity f malatenance considerations. Any replacement seals of water which entered the building will consist of a listas density silicone elastomer duttag constructica and is adequata which has the capability to stop the seepage. to handle the much reduced quantity i ! presently observed. Temporary conduits which enter the basemat from i outside. and which once allowed passage of ground water la quantifies that required periodic pumpias. have now all been pressure groeted and their { 4 temporary blockout pits filled with concrete and no i S longer serve as a leak path for ground water. Two piezometers still la use utilize one riser which will be sealed with a light density silicone elastomer. The standpipe of one piezameter no looger la use will be pressure grouted. II \\ I l f b i i l 6 l l I 1
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l I i l >: l l l pROCEAtt PIAN l l l ISSUE & TITLE DESCRIPTION Op ISSUE IP&L Appenam 10 kgSOLUTION CURREttr ASSESSDENT . i
- 20. Construction Terify the proper GEO has been contacted to assist la providias The tattial evaluation of this k
teater141a Testing certification of congt-additicaal hochground taformation or justification concera tedicated "no safety (Off) personnel ruction materials teattag for certificattom of QA/QC personnel identified significance" based on evaluation ofr t* i qualificattaa personant. as part of NCR fW3-FF-116. nonconformance report N3-F7-116. We 9 Records. are agata reviewing the A verificatica program has been established to qualifications of QA/QC personnel on + review the profeestonal credentials of 100% of the the noncomformance report and others CBD CNE assa QA/qC personnel. including empervisors to reconfirm our initial evaluation. and assagers. Criteria for certification or f gealificacima of QA/QC personnel will be based os l Q& progree seguirements and GE0's contractual f, e requirassets. i f The adegency of credentials to support ~ ~. } certificatione and qualifications is betag reviewed. I Criteria has been established to sort personnel ~ files into 3 groups. ob A. Qua11ticatione deemed adequate. I p
- 3. Inadegmate h eation to perform evaluation, j
C. Qualifications questionable i i Other site files will than be researched. and CEO I contacted for paraceaal in groupo 5 and C to verify + l thstr acceptability. In addittoa. background tuvestigations will be performed for a sample of pessoamel ta all groups. If certification'of an j, individual can not be justified, he will be placed L to a fourth group designated Group D (Qualification Sandequate).. Appropriate site nonconformance documentatica will be initiated to document l evaluattaa of safety significance and corrective actions inclading reinspectica of worlt performed as necessary. For CEO QC Inspectors remaintag on site. a reverification is being completed of proper i certification ta accordance with AN51-B45.2.6-1973. I W i I i 1 { i
- - -... ~.- -. - - - - _. ~ ~ - _ - _ -. _ =. ~ _. -,. _ ? 1,,. i t t . e I i i (- i .l t t + P90 CRAM PLAN I ? ISSUE & TITLE DESCRIPTI(35 OF ISSUE LP&L AFFPnAN TO RESOLUTICII CURRENT ASSESSIENT 21,1.F&L Constructica A concera exists over A review of transfer correspondence on the A review of 100% of { Systen States and whether comatruction systems which were the cause of this concern turnover /tramafer correspondence t Transfer Seviews. deficiencies were has been performed. A review has also been showed no addittomal correspondesce properly closed out conducted to verify that deficiencies la was outstandtag beyond that } or identified during transferred systems had no tapact on testing. previously identified. Deficiencies the process of identified ca the outstandtag l transferring systems A review was also conducted of hardware and soft-correspondence (13 SUS) have been from conatsuctica to were comments generated during status and trans-reviewed by IJ8L start-up/ plant operations. for of safety-related systems, operations and it was determined l that there was no impact on teattag. 6, 4 s e I i ! i t j i l l I t l I i i l ? i t r
1 4 L .I i I e i PROcRAM PtJus + ISSUE a TITLE DESCRIPTION OP ISSUE LP&L APPROAOI TO RESOLUTION CURRgNf ASSESSMENT
- 22. Welder Qualification Verify welder qualif-The welder documentation is available which All we1 Jets were found to be properly 1
(Mercury) and Filler cationa or assure the demonstrates that the welders were properly qualifted. NCR-W3-7724 addressed and Material Control qua11ty of all welds, qualifted. resolved qualification sheet errors (Site Wide) for 3 welders (clerical errors which l l Provide engineering just-The response summarizes the site requirements for were committed after the welders left i ification for the allow-handling of welding electrodes and demonstrates that site). y ance of "rebake" temper. ASME code requirements are mest and that AWS D1.1 i i, atures and holding times code requirements. through a documented deviation to Code requirements for receiving thac dif fer from the the holding ovea temperature, are also met. shipping, storage and issuing and 1 requirements of the ASME control of welding electrodes were + and AWS Codes, met. s 4 4 The only deviation from esplicit code i requirements was a documented - A reduction in specified holding oven f 84 temperatures. t 84 ilI' l i i 1 1 i s I, 4 4 k i 1 4 i I t I 4 i a t h e i
i 1 r 1 + I t l I i PROGRAM Pt.AN i ISSUE & TIT 1.E DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION CURRENT ASSESSMENT 3 0
- 23. QA Program Breakdown LP&L shall provide an First. LP&L is conducting a thorough review of the To date the specific issues involve f
between Ebasco and assessment of the overall corrective actions associated with the 1982 NRC inadequate or inconsistent closure Mercury. QA program and determine enforcement actions and civil penalty to determine documentation, and not hardware i cause of the breakdown, the adequacy of follow-up related to corrective impacting concerns. Thus far the together with corrective action commitments. review indicates that there saa no I action to prevent open itema af fecting plant safety. recurrence. This overall second.12&L is conducting a thorough review of its assessment is necessary QA audit program which has beta in af fact since July to provide assurance that 1982. Particular attention will be placed on audits the QA program can relsted to Mercury activities. This review will i function adequately when loclude an evaluation of the methods used for l, the plant proceeds into determining cause of identified problems and the t operation, systems used to assure effective follow-up and continued compliance with corrective action 4 g tearsitynts. l Third. LP&L is performing an overall assessment of the LP&L QA construction program based een the g results of the above reviews to idevitify lessons i learned and to determine if any improvements are i required to assure adequacy of future oper.tlonal j QA program activities. The above actions are ongoing. Based on efforts to date. It is believed that LP&L can demonstrate that the extensive management and quality. assurance actions taken by 1E&L. Ebasco and Mercury sub-sequent to June. 1982, were appropriate; that most of the problems identified were part of the corrective actions on work previously done and are not indicative of continued inferior performance; and that the partial program breakdown did not 3
- persist, j
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= l OUISIANA P O W E R & LI G HT ! Nawcruwam =uw an - s -
- o..e-m so e com om M100LE SOUTH UTiuTIES SYSTUA J.M. CA!N President and June 20, 1984 Chief Executive otticer W3B84-0445 Mr. Saul Levine NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878 Mr. Robert 1. Ferguson UNC Nuclear Industries, Inc.
1200 Jadvin, Suite 425 Richland, Washington 99352 Mr. Larry L. Humphries UNC Nuclear Industries, Inc. P.,0. Box 490 Richland, Washington 99352 SU3 JECT: Pre-Licensing Issue Assessment Task Force Charter
REFERENCE:
Discussions in the Offices of Shaw, Pitt=an, Potts&Trowbridge[ Washington,D.C., June 13, 1984
Dear Messrs:
Levine, Ferguson and Humphries: Pursuant to discussicus in the referenced meet g, this for=alizes agreements reached between us as to the charter of the subject Task Force. The roles of UNC and NUS will be to act as a task force in providing assessment and advice in responding to the NRC letter of June 13, 1984 It is i=portant to e=phasize that both UNC and NUS will maintain sufficient independence in order to provide to me as Chief Executive Officer of LP&L an independent pro-fessional assessment regarding the functions listed below. Your assessments will be formalized and sent to the Director of the Office of Nuclear Reactor Operations at the same time they are provided to me. 6 The Program Plan and implementation schedule requested in the NRC letter. 8 The adequacy of responses and resolurions (including validation of data and sources, as t.ppropriate) of the matters set cut in the NRC letter. j I i m
4.-
- e-ucans:.ng issue Assassnen:
Fage ; Task Forco Charter Juna 20, 1984 e The safety significance of the matters listed in the NRC letter with respect to: - Fuel load and testing up to 5% power - Operation above 5% power e The adequacy of the past QA/QC program in light of the matters listed in the NRC letter, and the resolution of such matters. 4 Recommend institutional or prograc:=atic changes that are deemed appropriate during plant operation in light of the lessons learned as a result of the matters set forth in the NRC letter, and the LP&L responses hereto. The following abbreviated organization chart is provided to clearly depict that the Task Torce is to.have access to and interface with all necessary elements of the Waterford ' staff but is to report directly to me. President & Chief Executive Officer (LP&L) (J. Cain) Task Force I denior Vice Bresident - I Nuclear Operations (LP&L) (M. Leddick) Safety Review ______________ Co=mittee t i I Quality Assurance --- Project Manager (LP&L)- -Plant Manager (LP&L) Manager (LP&L) (D. Dobson) (R. Barkhurst) (T. Garrets) il i f l I Ebasco & Staff LP&L & Staff Reporting Interface Very t y yours, J M. Cain JMC:DED:pb cc: G. Charnoff, R.S. Leddick, D.E. Dobson i
PROCtan FLAN CURRENT ASSESSMENT OF SAFETY SICNIFICANCE / e ISSPE & TITLE DESCRIPT1C3 0F ISSUE LPSL APPROACll TO RESOLUTION NONE FL TO 5% 5% JUSTIFICATION 1. Inspection Personnel Verify the proper cert-The professional credentials of 100% of the site lasues fication of site QA/QC QA/QC personnel, including supervisors and managers personnel or requalify will be verified. Acceptance criteria for certifi-the work performed by cation or qualification of Q4/QC personnel will be these personnel. researched from Contractors' contractual commit-ments, and QA program requirements. A task force has been established to review the adequacy of credentials to support cert-ifications and qualifications. Acceptance criteria has been established to sort personnel files into 3 groups: A. Qualifications deemed adequate B. Inadequate documentation to perform evaluation C. Qualifications questionable. Task team members will then research other site files, contact contractors, and/or initiate back-ground investigations for personnel in groups B and C to verify their acceptability. If they are unable to justify certification of an individual he will be placed in group D (Qualification inadequate). Appropriate site nonconformance documentation will be initiated to document DRAFT evaluation of safety significance, and corrective actions including re-inspections of work performed as necessary. JULY 17, 1984 For QC inspectors remaining on site, a reverifi-cation of proper certification has been accom-plished in accordance with ANSI-N45s2.6-1973. Quality control functions currently being under-taken as part of other programs will be performed by personnel reverified as qualified under ANSI-N45.2.6-1973.
~~ '~ mai. .u.. v, ,u m s u.4 1, 4 uus e, IS' SUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTIC'1 NONE FL TO 5Z 5Z JUSTIFICATION 2. Mi:-ing N1 Ir.ctruneit V;rify complirAco with LP&L has revievrd c.11 N1 itctrumentation in talled Th2 combination of the Line Documentation NRC requirements for N1 during the period when class breaks were allowed reviews described has instrumentation (prior to April 7. 1982). LP&L has established provided assurance that installations. that documentation exists to verify the adequacy documentation is of the B31.1 portions of N1 Instrumentation available to assure installations. In some cases, additional the quality inspections were performed.* installation of all N1 instruments. The documentation for the ASME portions of the N1 installations were reviewed by the Ebasco Records Review Croup prior to the inspection. DRAFT JULY 17, 1984
PROCRAN PLAN CURRENT ASSESSHENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTIEJ EICE FL TO SR 51 JU STIFICATICO 3. Instrumentation Correct separation NCR-W3-7702 covers the system 52A problema The walkdowa to date Expansion Loop criteria violations and has been dispositioned to remove the represents approximate-Separation found in system 52A and expansion loops in question. ly 20% of the installa-tions to be walked down. provide a program for review of 'other saf ety-NCR-W3-7730 was generated to track the generic related violations and concern. In order to provide some basis for take the necessary determining the scope of our program, a sample corrective actions. of 51 instrument installations were chosen for review in areas of congestion, and walkdowns of these lines were done. Thirteen deficiencies were found out of 276 locations. and were evaluated. None required rework. This provides a high level of confidence A QC verification of all lines where redundant that other design tubing runs in proximity of each other will be cansiderations and performed. An interim response discussing the walkdowns (i.e. pipe resolution of NCR-W3-7702 items and the status rupture / jet impingement of NCR-W3-7730 reinspections will be provided analysis, non-seisnic b' as well as a schedule for completion of the over seismic criteria reinspections. and walkdowns) in combination with the tubing separation criteria has provided adequate protection for the instrument installations. DRAFT JULY 17, 1984
FROGRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION NONE FL TO 5% 51 JUSTIFICATION 4. Lower Tier Corrective LP&L shall review all LP&L has reviewed the lower tier document reporting The current review has Actions Are Not Being FCRs. DCNs. EDNs. and system and verified it was structured in such a demonstrated that there Upgraded to NCRs T-B DNs to assure that manner that procedures. integral to the Quality has been adequate QA/QC proper corrective Program, provided a sound basis for decisions re-involvement in all action was taken, garding the severity level of documents used to lower tier documents including'an adequate report deficiencies. The review specifically with regard to 100rn50 review by QA. This considered QA and QC reviews of engineering / Appendix B corrective corrective action shall construction judgements on deficiencies as it action and non-conform-include the steps relates to the corrective action and noncon-ance requirements. required by 10CFR50 formance requirements of 10 CFR 50 Appendix B This involvement Appendix B. Criterion and the reporting requirements of 10 CFR 50.55(e). ensures that XVI Corrective Action appropriate corrective and for Construction The response vill include an assessment actions, specific and Deficiency Reporting, of all the lower tier documents specifically generic, are identified 50.55(e). Also, cited by the NRC to verify the adequacy of the included in this review proceduralized safeguards in assuring that Our current evaluation shall be the deficiencies with safety significance are of the examples of examination of improper being properly dispositioned and reported. lower tier documents voiding of all other There will also be an assessment of improper cited by the NRC demon-design changes or voiding. strates that although a discrepancy notices small percentage should that affected safety-In addition a randon 2Z sample of FCRs. have been upgraded to related systems or that DCNs. EDNs and T-5 DNs will be formally NCR's under the quality were misclassified as reviewed to determine if any should in f act program in effect, none safety. have been reported as NCRs. Any so judged had aduerse safety will then be reviewed for reportability significance. under 10CFR450.55e and 10CFR21. Thus. LP&L has a high confidence that the sample review will provide additional DRAFT evidence that the projects' system of " checks & balances" JULY 17, 1984 ensures that, despite isolated cases of judgemental or inter-pative errors, all lower tier documents, as well as FCRs and DCNs receive adequate evaluation for safety significance. A
PROCRAM PLAN CURRENT ASSESSMENT OF SAFETT SIGNIFICANCE ISSUE & TITLE DESCRIPTICJ OF ISSUE LP&L APPROACH TO RESOLUTICJ NCTE FL TO 9% 52 JUSTIFICATION 5 Vendor Documentation The concern relates to A problem did exist with formal tracking of The CE records and Conditional Releases whether shortcomings in Combustion Engineering Conditional Certifications other records with the contractor's documen-of Equipment. Records associated with CE material exception of JA Jones tation which existed at and equipment will be re-reviewed and conditional have been reviewed. the time. the material certifications will be identified and promptly To date 8 of was supplied have been resolved. Control of CE material and equipment 14 CE conditional cert-corrected, differs from that of other contractors. In order ifications have been to verify that a similar problem does not exist changed to uncondit-in the case of other contractors, a sample audit of ional. No items other critical purchase orders will be performed. affecting plant safety If the sample audit identifies any other problems have been identified with the handling of contractor afaterial releases, additional reviews will be initiated. in any of the completed reviews and dispo-sitions. DRAFT ~ JULY 17, 1984
PROCRAM PLAN CURRENT ASSESSMENT OF SAFETY SICNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTICJ NONE FL TO 32 52 JUSTIFICATICJ 6 Dispositioning of Some Ebasco and Mercury First, the inplace program for handling of lower To date,(7/16/83), the Non-conformance and NCRs and Ebasco DRs tier documents such as DRs will be discussed. NCRs cited by the NRC Discrepancy Reports were questionably dis-have been evaluated.Six positioned and LP&L Second, the specific NCRs and DRs cited by the of the 50 are being shall propose a program NRC will be evaluated for pr,oper designation, further evaluated. to assure all NCRs and disposition, and implementation of corrective Three impact hardware DRs are appropriately action under the existing Quality program, and two software. The upgraded, adequately balance have been shown dispositioned and Third, a review of all NCRs was started by LP&L to be adequately dispo-corrective action in January to assess the validity of the dis-sitioned. The overall completed and that any position, the corrective action taken, the com-review of NCRs has problems detected are pleteness of the documentation and proper closure been completed with corrected. will be discussed. the exception of approximately 31. This Fourth, a field verification will be conducted on one hundred randomly selected NCRs to ensure the review showed 472 of es the total 7750 NCRs corrective action resolved the nonconformance were questioned. 85% will be discussed. of these deficiencies were documentation If any problems are detected from these steps, a which were non signif-plan of further corrective action will be estab-icant. The balance 11shed. will be closed. Among the 100 randomly selecte'd (from the 472) for field verification, all but three have been assembled into packages containing the necessary information DRA T for field verification. None of the packages ha completed hardware / software verification JULY 17, 1984 and documentation evaluation as'yet.
PROCRAM PLAN CURRENT ASSESSHENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE 1.P&L APPROACH TO RESOLUTION NONE FL TO 51 52 JUSTIFICATION 13. Missing NCRs LP&L shall obtain the LP&L has conducted a review for accountability of LP&L has r> viewed for missing NCR's, explain Ebasco NCR's, accountability all why these NCR's were closed os colded Ebssco not maintained in the Site and New York filing system, review Office issued NCRs. The review concludes them for ' proper voiding, and assure that all are accounted that when an issue is for. Those not main-raised to an NCR. it tained on file in the is properly filed for vault were either tracking and closure. voided or never issued. In summary, sufficient documentation exists to account for all closed and voided NCRs. DRAFT JULY 17, 1984
PROGRAM PLAN CURRENT ASSESSMENT OF SAFETY SICNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTICJ NONE FL TO 51 51 JUSTIFICATION 32. Walder Qualification Verify welder qualif-The missing velder documentation is available All welders were found (Mercury) and Filler cations or assure the which demonstrates that the velders were properly to be properly qualif-Material Control quality of all welds. qualified. f ed. NCR-W3-7724 (Site Wide) addressed and resolved Provide engineering just-Baking /rebaking is not allowed on the site. Site qualifications sheet ification for the allow-procedures for receiving, storage. is.aing and errors for 3 welders ance of "rebake" temper-control of filler material meets the required (clerical errors which stures and holding times codes. were committed after that differ from the the welders left site). requirements of the ASME and AWS Codes. No code deviations exist. 6, 6 DRAFT JULY 17, 1984
O. PROGRAM PLAN CURRENT ASSESSMENT OF SAFETY SIGNIFICANCE ISSUE & TITLE DESCRIPTION OF ISSUE LP&L APPROACH TO RESOLUTION NONE FL TO 52 52 JUSTIFICATION 23. QA Program Breakdown Provide an assessment of LP&L and Ebasco recognize that certain aspects of To date the specific between Ebasco and the overall QA program the respective QA programs were not fully effective. issues involve Mercury. and determine the cause Evaluations are underway in,these areas to inadequate or incon-of the breakdown in the establish cause and corrective action. Lessons sistent closure case of Mercury, together learned from the evaluation will be applied to documentation, and not with the corrective other aspects of the respective programs. hardware impacting action to pravent concerns. The review recurrence. LP&L will review all of the above in light of the indicates that there entire QA program and make an overall assessment are no open items of its adequacy. ~ affecting plant safety. p. .) DRAFT JULY 17, 1984
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