ML20127G461

Requests Eg&G to Develop Sampling Plan for NRC to Followup on QC Inspector Qualification Issues.Requests That D Ross Chair Effort & Ensure Development of Sound Plan in Time for 841001 Effort

ML20127G461
Person / Time
Site:	Waterford
Issue date:	09/13/1984
From:	Harrison J NRC - WATERFORD 3 TASK FORCE
To:	Kobichek L EG&G, INC.
Shared Package
ML20127B509	List: ML20127B505 ML20127C256 ML20127C319 ML20127C332 ML20127C625 ML20127F837 ML20127F896 ML20127F924 ML20127F948 ML20127F991 ML20127G128 ML20127G172 ML20127G206 ML20127G409 ML20127G439 ML20127G461 ML20127G486
References
FOIA-85-123 NUDOCS 8506250451
Download: ML20127G461 (15)

Text

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ATTACHMENT 3 0 f800, UNITED STATES

1. g NUCLEAR REGULATORY COMMISSION

• g REGION 111 o

3 j 799 ROOSEVELT ROAO

• GLEN ELLYN, ILLINOl5 601 M of September 13, 1984

$' MEMORANDUM FOR: Larry Kobichek, EG&G FROM: J. J. Harrison, USNRC - Waterford TASK Force

SUBJECT:

SAMPLING PLAN FOR WATERFORD TASK FORCE This letter is to document my request for EG&G to develop a sampling plan for the NRC to use at Waterford to follow up on the QC Inspector qualification issues. As we discussed on our telephone call, on September 13, 1984, I am requesting that Dave Ross be allowed to chair this effort and ensure

- - development of sound plan in time for my review and NRC to use during our Waterford effort beginning on October 1, 1984. Please provide Dave with the assistance he may need from a statistician to allow this plan to be sound and provide the basis to meet attachment 1. Dave has copies of the total number that need to fill in the blank on the attachment.

If I can be of assistance, please feel free to contact me (FTS-388-5635).

J. J. Harrison s

%h B506250451 850411 PDR FOIA

, BERNABE85-123 PDR

ATTACHMENT 1 NRC Sampling Plan to Verify Inspector Qualifications:

Attributes: ,

1. 95% Confidence / Reliability Level

2. The lots to be sampled:

a. T-8/ Mercury QC - Population

b. Other QC Inspectors - Population - proportion total sample size to each contractor by total QC Inspectors.

~

c. Other: QA Personnel for all - Population - proportion total sample to number of QA personnel.

3. Develop a random number basis for QA/QC personnel selection.

van!Nd f

a WATERFORD STEAM ELECTRIC STATION, UNIT No. 3 ,

ERRATA TO THE SAFETY EVALUATION REPORT SUPPLEMENT No. 9 -- NUREG-0787

, .- Appendix J, Section 2 Page 5 The first line of Item 11 should read, "The NRC Office of Investigations currently has twelver.open investigations of alleged wrongdoing."

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1. Introduction S ' '33-1 On October 1, 1984, the NRC staff issued Supplement 7 to the Waterford Unit 3 Safety Evaluation Report (SER) which provided the results to date of the staff's evaluation of approximately 350 allegations and concerns relating to poor construction practices at the Waterford 3 facility as well as the status of the operating license application review. As discussed in Supplement 7, the NRC's Executive Director for Operations, in order to assure that items needing resolution prior to staff consideration of an operating license were promptly addressed, directed complete management responsibility to the Office of Nuclear Reactor Regulation.

The principal areas needing resolution included: (1)completionand documentation of the review of the Final Safety Analysis Report (FSAR);

(2) response to the motion before the NRC Atomic Safety and Licensing Appeal Board to reopen the hearing because of cracks in the concrete basemat;(3) mptth*n. WC:

..J allegations. ns. edw

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Subsequent to the issuance of SSER J. a motion was filed by the Joint Intervenors to" reopen the hearing based on three contentions dealin with Moddhin (

Quality Assurance,Managemeat integrity,and the NRC staff effort dea ing A/

with allegations.'

. These and all other areas have been resolved to the staff's satisfaction to allow issuance of a license to Louisiana Power & Licht (LP&L) to operate Waterford Steam Electric Station, Unit No. 3.

In the staff's review of the Waterford 3 FSAR, an SER and eight supplements have been previously published. At this time no safety issues from the FSAR review remain unresolved.

The second item that needed resolution prior to a licensing decision concerned the common foundation, concrete basemat supportidg the safety class structures at Wr.terford. On August 7, 1984 the staff filed its response to a motion to reopen the hearings based.on cracks discovered in the basemet. The staff .

concluded that the observed cracking does not affect the safety of the Waterford facility. On October 2, 1984, the A) peal Board requested additional information on the filigg The staff us. filed its response on December 17, 1984.{5 %st sa @ ddh ionM information includes a discussion of the 7/

allegations concerning the construction of the basemat as resolved in this SSER. ,

! Completion of routine NRC Regional inspection actions was the third area that needed to be finished before a licensing decision could be reached. In memoranda from R. Martin, Region IV to H. Denton, NRR dated December 4, 1984 and from R. Martin, Region IV to D. Eisenhut, NRR dated December 13, 1984, the Pegion IV staff found that based on its inspections, they conclude that construction is complete, preoperational testing has not revealed any significant unresolved problems, and the licensee is ready and, in its ,iudge-ment, competent to operate the Waterford 3 plant. The licensee has sufficient trained and licensed staff to safely operate the Waterford 3 plant and they have no concerns regarding the fitness for duty of the Unit 3 operating staff.

Region IV has no items which would preclude issuance of a low power operating license.

($-Y"Y Waterford SSER 9 Appendix J

The fourth issue involves allegations concerning construction practices. SER No. 7, issued on October 1,1984, resolved many of the 350 technical allegations and concerns the staff had identified beginning in early 1984.

However, as a result of the staff's review, 23 areas of potential safety concern were identified. In a letter to the 4pplicant dated June 13, 1984, Louisiana Power & Light was requested to propose a program and schedule for a detailed and thorough safety assessment of the 23 concerns. LP&L gepppr)ded i to the staff's request by letter dated June 28, 1984. W. / '

After discussions with the staff the plan was revised and impro'ved, and as the uAnt.rA m 'innt reviewed the concerns more closely their program became more detailed and thorough. Revised program plans were submitted by letters of July 27, September 14, 18, and 28, October 10, 19. and 31, November 21, and December 6, 1984. As requested by the staff the program included plans to address root cause, and potential generic implications of each of the 23 concerns.

The : provided the results of their review and the corrective actions taken for each of the concerns by letters dated August 10 and 27, September 4, 14, 18,and 28, October 15, 19, and 31, November 21, and December 6, 1984.

. NRC N ers reviewed the 23 issues identified in/ C letter from \

Mr. Darrell G. Eisenhut to LP&L Mr. J. M. Cain dated _ June 13, 1984. The Lk 5c.

", specifically reviewed LP&L's responses, corruc Le actions, program plan, '

implementing procedures, and results. The 4HilrTa so evaluated the third party assessment, being perfonned by _the NUS Corporatfory, under contract to LP&L to wS944 reviewthgc ,

The NRC 4e8%pmj:tive action process on the 23 issues identified by the NRC.Tfrorts November 1984, with site visits being regularly;cydugegr ugtgpgod. .

In evaluating the corrective actions, the team reviewed the LPAL plan, A b h responses, corrective actions and inspection results. The-4esaT F6Tewed the actions and results taken on examples identified'by the NRC as well as sampling the total populations both within and outside of the licensee's evaluation j process. Where the licensee performed a one hundred g cent review,a ,1grge ~ (

Hw+--'~ '

sample w gas 1so taken. The fiRC sampling process was*

staff t; -_. , a sufficient level of confidence to assure that the licensee had determined: (1) the extent and depth of the problem; (2) safety significance .

and generic implications; (3) adequacy of management controls; (4) adecuacy of corrective action; to correct the problem and = ti r to prevent recurrence; and (5) identified impact on hardware, if any.

The sstewteam reviewing the responses to the 23 issues and related information was comprised of 30 technical members, many of whom originally participated in April and May 1984 effort. Several other members were supplied from a similar effort recently conducted at the Comanche Peak site. Team members were drawn from NCR's Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research, Office of Inspection and Enforcement, from NRC's Region III and IV Offices and from-the-staff-of-a-Nat4cnah-laboratory, /.Wud mwdhtr;h .

The Task Force also discussed with the NUS Corporation their independent review of the 23 concerns and LP&L's responses to them. NUS developed procedures to validate the infonnation contained in LP&L's responses to the NRC, as well as Waterford SSER 9 Appendix J

verify that corrective actions defined by LP&L in their responses were properly carried out. During the course of NUS's evaluation and validation activities they performed inspections of field installations where necessary.

The NRC has reviewed NUS's evaluations for each of the 23 issues. In some cases recoinnendations were made to LP&L for improving their programs but in each case NUS concluded that the concerns raised by the NRC iave been adequately addressed.

The staff, having reviewed the applicant's responses to the concerns raised and NUS's reports on LP&L's program, concludes that all concerns have been satisfactorally addressed. The staff's evaluations for e,ich of the 23 issue are included in this report. N (A.tes, A -109 , A-lh , A- lW , 4 2.W, A- 2.52. , A-2s's , A-53% -3MJ Also include are evaluations of nine allegations previously identified in

$$ER No. 7 The reviews of these allegations were still in progress when

, ,. : SSER No, was issued. These evaluations, now complete, are presented in this

' report.

The staff completed its review of an issue in Allegation A-19 requiring additional action by LP&L. The NRC staff had identified some issues pertaining to electrical support documentation deficiencies. These deficiencies were identified, trac ted, and resolved on LPAL site Survet.11ance Report W35-84-165.

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These issues were resolved by LP&L and reviewed by the NRC staff and found acceptable.

One allegation, though documented in $$ER No. 7 as being resolved, required additional review. The staff's review of Allegation A-256 in SSER No. 7 indicated that the Waterford 3 paint application for inside the containment.

vessel did not have any documentation concerning certification, painter qualification, quality. control certification, or work activity inspection.

This does not meet Regulatory Guide 1.54, and therefore, paints inside containment are not considered qualified. The staff dispositioned Allegation A-256 as having no safety significance on the basis of LP&L's demonstration of coating adequacy throuch the use of an in-situ design basis, accident (DBA) test. ,

Upon more detailed review, the staff has determined that the demonstrated /

adequacy of coatings inside containment based on thtf particular type of V in-situ test is inconsistent with ANSI N 101.2. The in-situ DBA testing of the coatings inside containment at Waterford was limited to three test locations, which is not considered representative of the containment coating system, nor did it include the effects of radiation, and chemical spray solution. Because of the potential safety significance of failure of these coatings, and in order to gain confidence in the applicant's as-built configuration' of coatings, the staff will require that LP&L perform a plant-specific analysis demonstrating that failure of these coatings will not adversely impact the performance of post-accident fluid systems. This methodology is consistent with that in Revision 1 of SRP Section 6.1.2 (Dectmber 1978), acceptance criterion II.2.c. /.

which permits non-oualified coatings'pf "it can be justified that the debris V will not adversely affect the performance of post-accident fluid systems." A conditinn was placed in the operating license requiring that LP&L submit'the above plant-specific evaluation for staff review and approval one-month after

,issuerce of-the operating-license' p w r fr A m . 19, g6 Waterford SSER 9 Appendix J

The applicant has submitted a justification for interim operation of Waterford 3 up to 55 of rated power. The adverse environment for coating failure inside containment, by a break in thewhere sump reactor watersystem coolant is necessary(RCS)., could potentially The probability of an RCSonly be produce break of sufficient size to degrade containment coating is low during the period prior to exceeding 51 power. Moreover, the low levels of decay heat and fission products produced during this period would limit accident sonsequences to low levels in the unlikely event of an RCS break. The applicant has perfonned an analysis employing very conservative assumptions and has demonstrated that three hours following a large break LOCA, whe,n ECCS flow is first required to prevent core uncovery, the flow requirement is less than one- /

half of one percent of one loop of Low Pressure Safety Infisction TJ '), /

-

• approximately 20 gpm. An assumed sump blockage of 905 would still allow g sufficient coolant to the core. (gggAge,g.350)

. Three additional allegations concerning construction of the Waterford 3

-a facility were identified to the staff after the Waterford 3 Task Force had completed its six-week onsite review of t f ap roximately 350 1ations.

The Waterford 3 Task Force reviewed these n t e same manner)t legations discussed in SSER No. 7 were reviewed, and their evaluations are included in this report. .

'/ On November 8. 1984 the Joint Intevenors filed anotheLr motion with the Appeal poard to reopen the hearings. The motion consisted of three contentions concerning the applicant's quality assurance pro 9 ram, the applicant's character integrity and competence, and the NRC s effort to resolve the allegation's and concerns of poor construction practices at Waterford. The staff has reviewed the supporting materials and has not identified anything which would alter its previous conclusions concerning the basemat or the allegations discussed in this $$ER or in $$ER No. . The staff X. respond -

formally to the motion on December 21,1984. (au, Alo, f.)

3. Susunary y i .

Based on its review of the :;;M;;;;'; response and corrective action to the staff's 23 areas of safety concern. its review of the additional allegations -

and contentions not addressed in SSER No. 7. and other related information, the staff makes the following observations and conclusions:

w ig i 1. The WMr;'; program plan for resolving the staff's 23 areas of l potential safety concern was found to contain acceptable corrective action to resolve the safety concerns. .

} 2. The hN program plan also identified acceptable action taken to prevent recurrence in each specific case and as denoted in

! collective significance should be sufficient to ensure that the OA

program breakdown does not recur.

i t l 3. The a.we.AU.pplicant utilfred appropriately qualified individuals to j implement the program plan. .

I

! 4. The implementation of the program plan was completed to the satisfaction of staff.

l f

i. . 44 l Waterford SSER 9 .4 - Appendix J i

tA.  :

5. The third party assessment performed by the,MNC/NUS group provided an(extensive and valuable audit, validation and inspection effort /

/

of the LP8L resperses to the 23 issues raised in the NRC letter to LP&L of June 13, 1984.

6. The nine allegations previously identified in SSER No. 7 were reviewed and found to have no safety significance or gengric implications.

7. The additional allegations that were identified after' the initial

, six-week onsite review were reviewed and found to have no safety significance or generic implications.

8. Allegation A-256 in SSER No. 7 was given additional review. As a result of this review the staff finds that this issue may have an impact on safety. A condition has been placed in the operatin

..- lice.1se requiring acceptable resolution of this issue e mc.;g W%

9 efter-isstrenw vi snw operating-license 0

}

9. Although LP8L did not fully implement their QA program, the impact on hardware was minimal. The plant design is adeouate and the final installed plant systems meet the design requirements. The few hardware deficiencies were reviewed and werg. found to have been satisfactorily corrected.

10. Potential violations of NRC regulations identified by the Task Force have been forwarded to the NRC Office of Inspection and Enforcement and to the Administrator. NRC Reginn IV Office for appropriate action. An escalated enforcement action package has , '

been prepared.

11. The NRC Office of Investigations is currently conducting ;L.7 /

investigations of alleged wrongdoing. 'AJfdttional potential .

violations may result from these investigations.

i Waterford SSER 9 Appendix J