ML20100K322

Supplementary Comments Attesting to Validity of Statements of Fact in Sser 9 & Clarifying & Explaining Current Position on Resolution of Allegation A-48.Util Can Safely Operate & Manage Facility.Certificate of Svc Encl

ML20100K322
Person / Time
Site:	Waterford
Issue date:	04/10/1985
From:	Wasserman A LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
CON-#285-492 ALAB-801, OL, NUDOCS 8504120429
Download: ML20100K322 (15)

Text

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.t CE M TCO L3hPC fHE UNITED STATES OF AMERICA 5 APR 11 All :55 NUCLEAR REGULATORY COMMISSION V ~h'  : E T . - . ; ,,,

Before the Atomic Safety and Licensing AppbEl 5 hl card.Es /I!

_.,,,H In the Matter of )

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LOUISIANA POWER & LIGHT COMPANY, ) Docket No. 50-382 OL

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(Waterford Steam Electric Station, )

Unit 3) )

APPLICANT'S SUPPLEMENTARY COMMENTS ALAB-801, NRC (March 22, 1985), addressed the NRC staff's December 21, 1984, Answer to Joint Intervenors' November 8, 1984 motion to reopen the record (" Motion to Re-open").1! The Appeal Board requested the staff to provide an affidavit (or affidavits) attesting to the validity of the statements of fact in Safety Evaluation Report, Supplement 9

("SSER-9'), and asked for " clarification and explanation" of the staff's current position on the resolution of Allegation A-48 described in Safety Evaluation Report, Supplement 7

("SSER-7"). ALAB-801, slip at 18. The Appeal Board provided that Applicant could file supplementary comments on these mat-ters. Id. Applicant's comments are provided herein.

1/ Applicant's Answer was filed on Novmeber 30, 1984, with Errata filed on December 7.

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I. ALAB-801 The Appeal Board's principal concern in ALAB-801 centered on the adequacy of the documentary support provided by the staff for the conclusions in its Answer with respect to Issue 23 in SSER-9 ("SSER-9/ Issue 23"). The Appeal Board noted that the NRC's favorable conclusion on the issue "is not adequately explained" in its Answer, and that the " elaboration necessary to justify" the conclusion had not been provided. Id. at 11-13. As the Appeal Board indicated, Issue 23 had its origins in Allegation A-48,'which was discussed by the staff in SSER-7

("SSER-7/A-48"). Allegation A-48 alleged that there was a breakdown in the QA program between Ebasco and Mercury Company of Norwood, an Ebasco subcontractor. SSER-7 at 96. In Issue 23 of the June 13, 1984 letter to Applicant from Darrell Eisenhut ("Eisenhut Letter"), the staff requested Applicant to address the situation. Applicant responded to this issue in several submissions to the NRC. ALAB-801, slip at 12.2/

As will be dir;ussed more fully below, the NRC staff's resolution of Issue 23 was the culmination of months of strenu-ous review and assessment efforts by both Applicant and staff.

'There is ample support for the conclusions reached by the staff 2/ Attached as LP&L Supplement Exhibit 1, is Applicant's November 21, 1984 submission on the " collective signifi-cance" aspect of Issue 23 (referenced by the Appeal Board in ALAB-801, slip at 12.). This version superseded the version submitted on October 31.

in SSER-9 in the submissions given to the staff by Applicant and as a result of the staff's extensive inspection and evalua-tion activities which continued beyond the initial inspec-tion / review effort. With the adoption of SSER-9 as the staff's response to the Joint Intervenors' Motion to Reopen, and in light of the fact that the staff's conclusions in SSER-9 are well founded, Joint Intervenors' motion must be denied for failing to raise a significant safety issue.3/

II. HISTORY OF THE RESOLUTION OF THE TWENTY-THREE ISSUES In April of 1984, the NRC staff began the task of system-atically assessing and resolving all remaining licensing issues relevant to Waterford 3.$/ SSER-7 at 2. As part of this re-view, the staff organized a Waterford 3 Task Force that con-sisted of about 40 technical specialists ("NRC Task Force").

The NRC Task Force began the process of identifying and as-sessing numerous QA-related allegations involving Waterford 3.

Id. at 3.

The NRC Task Force prepared action plans for each allega-tion. It reviewed construction work packages, personnel 3/ Applicant continues to maintain that Joint Intervenors' motion to reopen is also untimely, including those charges relating to the Eisenhut Letter. See Applicant's Answer to Joint Intervenor's November 8 Motion to Reopen at 7-14.

4/ As noted by Joint Intervenors themselves, the staff had undertaken an " unprecedented inspection effort." Motion to Reopen at 32.

qualifications records, inspection records, and surveillance and audit reports. Id. Allegers were interviewed when possi-ble. Id. at 2. This review in the Spring of 1984 led to the identification of the twenty-three areas of concern that were the subject of the June 13 Eisenhut Letter. As will be dis-cussed more fully below, Applicant immediately began to work on a comprehensive program to respond to the twenty-three issues.

In the meantime, the NRC Task Force continued to work on its review of QA issues. These included allegations (such a A-48) which had previously become part of the twenty-three issues.

Cf. A-33, A-222, A-231, A-232. The NRC Task Force set forth the allegations and their disposition in SSER-7. Those unresolved allegations that pertained to the twenty-three issues were not finally dispositioned in SSER-7. At that time, Applicant had already spent several months of dedicated effort toward resolving the twenty-three concerns. The NRC staff, upon receipt and review of Applicant's responses to the twenty-three issues and associated reports and evaluations, and upon completion of its own efforts, issued SSER-9, in which the allegations relating to the twenty-three issues were resolved.

Thus, although SSER-9 issued only "several months" after SSE'R-7,E! the efforts that had been put into resolving the twenty-three issues had begun almost one-half year before 5/ SSER-7 was issued on October 1, 1984, and SSER-9 was issued on January 11, 1985.

L-SSER-9 was issued.b!

Beginning in the Summer of 1984, Applicant undertook an extensive and comprehensive program to resolve all of the areas of concern identified in the Eisenhut Letter. The program was designed to determine the accuracy of the concerns, to deter-mine the corrective actions necessary or considered desirable, to perform the corrective actions, to provide assurances to LP&L management that the issues were resolved and that the plant is safe to operate, and to provide similar assurances to the NRC. This program is described in the Affidavit of Kenneth W. Cook, attached as LP&L Supplement Exhibit 2.

The program was closely managed by top-level personnel and included direct involvement by the Senior Vice President-Nuclear Operations and the CEO of LP&L. Cook Affida-vit at 2-3. The program was submitted to the NRC staff for re-view and comments, changes were made to reflect these comments, and subsequent changes were incorporated to reflect new 1/ The Appeal Board cited several examples of instances in which the staff had referenced material in the answer that seemingly concluded that the issues raised were of' safety significance. ALAB-801, slip at 8, n.12. Each of these instances constituted the staff's discussion in SSER-7 of allegations related'to one of the twenty-three issues. As with Allegation A-48 underlying issue 23, at the time SSER-7 issued, Applicant was in the'midst of a massive ef-fort responding to the concerns. These issues'(and their underlying allegations) have all been resolved by LP&L.

To'the extent Joint Intervenors' charges have related to these issues, Applicant has specifically addressed them.

With.the adoption of SSER-9 as the staff's response, the staff has concluded that these charges do not raise issues of safety significance.

information and to satisfy additional comments from the staff.

Id. at 3-4.

Reviews were initiated by Applicant to analyze each issue to determine the facts and the specific problems involved with the issue (if any), the root cause that led to the problem or to the perception of a problem, the potential generic implica-tions of the issue, and the safety significance of the problem with respect to fuel load, low power operation, and operation above 5% power. In addition, Applicant determined if correc-tive actions were required (or were desirable on an elective basis) to address both the specific issue and any related ge-neric concerns. Id. at 4. The resolution process also includ-ed a separate review by a special subcommittee of the Appli-cant's Safety Review Committee. Id. at 6-7. All reviews were validated by experienced individuals under a specific Quality Assurance procedure. Id. at 4-5. In parallel with the assess-ment of each issue, Applicant also assessed the collective sig-nificance of the individual issues in order to take steps to avoid recurrence of the types of problems underlying the issues. Id. at 5.

In addition to conducting its own review, Applicant estab-lished an independent task force of outside experts (" Task Force"). The Task Force was chartered to provide an indepen-dent assessment of the adequacy of Applicant's program to re-solve the June 13 issues, to provide an independent validation of Applicant's submissions and conclusions presented to the NRC, and to provide an independent assessment of the safety significance of the issues, the lessons learned, and the col- i lective significance of the issues on the Operational QA Pro-gram. The Task Force' consisted.of highly qualified personnel

'and took steps to insure that it was independent of LP&L. The methods used by the Task Force and its staff to assess Appli-cant's program included independent assessments, statistical sampling plans, interviews of personnel involved with issue resolutions, independent walkdowns and inspections, and inde-pendent reviews of documents and records. Id. at 5-6.

Applicant's extensive review process consumed more than 1,300 man-months of effort, exclusive of the approximately 120 man-months expended by the Task Force and its staff. Only very limited hardware rework was undertaken as a result of the re-view process, and in most cases, the rework was discretionary.

Id. at 7.

The assessments submitted to the NRC staff by Applicant and by the independent Task Force of each of the twenty-three issues provided more than adequate assurance that Waterford 3 i was adequately constructed and can be' operated without undue risk to the public health and safety and environment.

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, III. CONCERNS RELATED TO ISSUE 23 The. Appeal Board identified three aspects of the issue which it requested the staff to address in clarifying and explaining its current position on SSER-7/A-48 and SSER-9/ Issue 23: (1) the degree to which the QA problems described in SSER-7/A-48 were " pervasive"; (2) the basis for concluding that the plant has been " adequately designed, constructed, inspected and tested..."; and (3) the basis for concluding that "LP&L can safely operate and properly manage Waterford 3." ALAB-801, slip at 13. As discussed more fully below, there is ample sup-port for the NRC's conclusions as to each of these elements.

A. The Problem is not Pervasive Following the discovery of QA problems with Mercury in 1982, Ebasco and Applicant took steps to gauge and address ge-neric concerns involving QA. These steps included the mobili-zation of an Ebasco QA Management Team (in July 1982). The Team's action plan required improvement in tracking and timely completion of Significant construction Deficiencies ("SCD's"),

Nonconformance Reports ("NCR's"), Deficiency Notices ("DN's")

and audits, called for increased contractor QA surveillance, reorganization of Ebasco QA auditing functions and organiza-tion, and the establishment of a QA records turnover review system. See Response to Issue 23, attached to Applicant's An-swer to the November 8 motion to reopen as LP&L Exhibit 5, at 23-21. Even though the plan was initiated in response to the problems identified with Mercury, the scope of the plan includ-ed all subcontractors. LP&L Exhibit 5 at 23-22.

Applicant developed its own Task Force in 1982 ("LP&L Task Force") to perform a Quality Records Review and to perform physical verification of construction practices by walkdowns of selected activities. These reviews and walkdowns were per-formed on safety-related work done by 15 subcontractors prior to June 1, 1982, in order to assure that this work complied with the QA program. Id. at 23-23. This review was completed in 1983. Problems on the scale of those that occurred with Mercury were not found. The LP&L Task Force identified some record and system installation deficiences, all of which were subsequently resolved. The NRC staff (in Inspection Report 50-382/84-34) reviewed the work of the LP&L Task Force. The NRC indicated that "[t]he ("LP&L"] Task Force verification ef-fort and findings did contribute to the overall LP&L and NRC assessment of the acceptability of the contractor work and effectiveness of LP&L's QA program." Id. at 23-24.

As part of Applicants' review of the twenty-three issues, Applicant made an extensive effort to determine and evaluate the potential for similar problems with contractors or systems other than those expressly covered by a particular issue. Cook Affidavit at 4. Whenever it was determined that the potential for similar deficiencies existed, Applicant included related contractors, systems, or records within the scope of the issue resolution. Id. This conservative effort to determine project-wide implications provides added assurance that the problem with Mercury was not pervasive throughout Applicants' QA Program.

I

.. As stated by Applicant in its response to Issue 23,

...what deserves emphasis is that a situation such as existed with Mercury has not recurred and furthermore, under the present management philosophy and implementation of quality as-surance, adequate assurance exists that such a situation would be unlikely to recur." LP&L Exhibit 5 at 23-2.

B. The Plant Has Been Safely Constructed Applicant's submissions to the NRC clearly demonstrate that despite the QA problems with Mercury, the plant as-built is safe and has-been adequately inspected.7! As stated by the independent Task Force retained by Applicant to review and in-dependently assess.the twenty-three issues:

The Task Force has concluded that the presently existing safety significance of the 23 issues is minimal. This judgment is based on the follow-ing considerations:

The extensive investigations and corrective ac-tions performed by LP&L; The independent validation of LP&L responses, supporting data, and information sources per-formed by the TFSG; The expenditure of over 1000 man months of ef-fort on these issues over the last several months has not identified any significant rework of plant structures, systems, or components; 7/ Applicant has aggressively addressed QA concerns related to Mercury work at Waterford 3. Cook Affidavit at 8-9.

The latest reinspection effort covered all N1 (class lE) instrumentation lines, and despite this extensive reinspection, only a smell amount of rework was needed, none of which was significant to safety. Id. Applicant has determined that the Mercury work, as-built, is ade-quate to protect the public health and safety. Id.

F

. The substantial additional assurance that sig-nificant discrepancies have been detected pro-vided by (1) the use of an independent contrac-tor (GEO) by LP&L to perform nondestructive examinations, (2) the presence of an authorized

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nuclear inspector, and (3) the overinspections performed by LP&L and EBASCO; and l

The testing performed during plant construction l

and start-up of systems to demonstrate the in-l tegrity and functionability of the safety sys-

! tems.

l Cook Affidavit at 10; Report of the Task Force on Prelicensing l

Issue Assessment Waterford 3 Steam Electric Station, December 1984 at 4, attached as LP&L Supplement Exhibit 3 (not including Appendix B).

The massive effort devoted to the QA problems identified in the Eisenhut Letter resulted in minimal hardware rework.

Cook Affidavit at 7. Most of the hardware rework was discre-tionary. Only two changes were made as a result of potential safety concerns. One was made on a three-foot section of tubing and the second represented a case where the safety sig-nificance was not determined. Id.

In addition to the program activities and verifications discussed above, Applicant performed a comprehensive series of safety reviews which adds further assurance that Waterford 3 can be operated without undue risk to the public health and safety. The safety reviews were conducted in accordance with the criteria of 10 C.F.R. S 50.59 to evaluate the potential im-pact of each of the twenty-three issues on plant systems.8/

8/ The criteria of 10 C.F.R S 50.59(a)(2) include evaluations to determines (i) if the probability of occurrence or the (Continued next page) r

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Cook Affidavit at 11. A program plan covering the review pro-cess was developed and approved by Applicant's management. Id.

at 12. The plan provided for the development of review proce-

- dures, the completion of a safety review checklist by a review team, and the review and approval by a special subcommittee of the Waterford Safety Review Committee. Id. The entire process was audited by'the Independent Safety Engineering Group and the process was also reviewed by the independent Task Force. Id.

The safety reviews have been completed for all systems required to be operable by the Waterford 3 technical specifications for all modes of reactor operation up to and including 100% power operation. Approximately 1400 safety reviews were necessary to

[ . complete the process. Id. These reviews support the conclu-sion reached by the NRC Staff that Waterford 3 can be operated safely.

The Appeal Board stated in Pacific Gas and Electric Company (Diablo Canyon. Nuclear Power Plant, Units 1 and 2),

ALAB-756, 18 NRC 1341, 1345 (1983):

'Although a program of construction quality as-surance is specifically designed to catch con-struction errors, it is unreasonable to expect the program to uncover all errors. In short, perfection in plant construction and the (Continued) consequences of an accident or malfunction of equipment important to safety previously evaluated in the Final Safety Analysis Report ("FSAR") may be increased; or (ii) if a possibility for an accident or malfunction of a dif-farent type than any evaluated previously in the FSAR may be created; or (iii) if the margin of safety as defined in the basis for any technical specification is reduced.

4 facility construction quality assurance program i;s-not a precondition for a license under either the Atomic Energy Act or the Commission's reg-ulations. What is required instead is reason-able assurance that the plant, as built, can and will be operated without endangering the public

. health and safety.

Under this standard, Applicant has provided ample support for the conclusion that Waterford 3 has been properly con-structed and can be operated without endangering the public health and safety.

. C. Applicant Can Safely Operate and Manage Waterford 3 Applicant has undertaken several actions to provide the NRC staff with " reasonable assurance" that it can safely oper-ate and properly manage Waterford 3.

As part of the analysis of " collective significance,"

Applicant developed a list of " lessons learned" from its earli-er QA problems. Cook Affidavit at 13. The lessons learned were actions which, if taken earlier, could have prevented the occurrence of the Applicant's construction QA difficulties.

Applicant evaluated its Operational QA Program in light of the lessons learned. Id. As a follow-up to Applicant's assess-ment, the independent Task Force also performed an independent assessment of the Operational QA Program. The Task Force found that the program was adequate to support plant operation, and made several recommendations. It recommended that a summary QA document be provided to describe the Operational QA Program, that a comprehensive audit of the program should be conducted, and that training on lessons learned from construction QA

. should be factored more extensively into the existing QA pro-gram. Id. at 13-14.

Applicant is adopting these recommendations and is in some areas exceeding them. A comprehensive and detailed summary QA document, called the Nuclear Operations Management Manual (NOMM) has been prepared. The QA training program is being changed to incorporate training on the lessons learned. LP&L has arranged for a comprehensive audit of the Operational QA Program by the Institute of Nuclear Power Operations (with as-sistance from Middle South Services QA). Cook Affidavit at 14-15. Both the QA program modifications and the retraining of Nuclear Operations personnel are expected to be completed shortly. The site activities associated with the audit were completed in early April. Id. at 15.

The purpose of these activities is to assure that as Wa-terford 3 enters its operational phase, the QA problems that arose in conjunction with construction will not be repeated.

Applicant has thus reaffirmed its commitment to assuring that Waterford 3 will be operated safely and in accordance with ap-

[

plicable requirements.

Applicant's extensive and comprehensive responses to the twenty-three issues, its committment to. implement lessons

learned from construction QA into its Operational QA Program, and the independent assessment of the Operational QA Program provides more than adequate assurance that Applicant can safely operate and properly manage Waterford 3.

6 IV. CONCLUSION Waterford 3 has been adequately designed, constructed, in-spected and tested. Applicant has provided ample basis to the NRC to support the staff's conclusion in SSER-9/ Issue 23 that the concerns identified as Issue 23 in the Eisenhut Letter have been resolved. The staff on the basis of Applicant's program efforts and its own extensive investigations and evaluations properly concluded that there is " reasonable assurance" that Applicant can safely operate and manage the Waterford 3 nuclear plant.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By: u- . $ h /--" -

Bruce W. Churchill Alan D. Wasserman 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Counsel for Applicant Dated: April 10, 1985

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c LP&L SUPPLEMET4T EXHIBIT 1 i

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POWE R & LiGH T New cm. manas n 'aaNA 7c$ec e tsc4iess-aace Nu?IsEsM ,

Novenber 21, 1984 ./.M. CAIN President W^,B84-0817 A4.05 s.M tI.q

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Director of Nuclear Reactor Regulation yf g 'S ATTN: Mr. Darrell G. Eisenhut, Director Division of Licensing 2

,- N b N U.S. Nuclear Regulatory Commission l

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Washington, D.C. 20555 '- A* jj

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SUBJECT:

Waterford 3 SES 'k, '

D cy .Q Partial Response to Items / 2 from Waterford Review Team 4/7Q \

REFERENCES:

1) Letter W3B84-0807, J.M. Cain to D.G. Eisenhut, dated October 31, 1984

2) Letter, D.G. Eisenhut to J.M. Cain, dated June 13, 1984

Dear Mr. Eisenhut:

The purpose of this letter is to submit revised responses supplementing Issues 6, 7, 19. 20 and the assessment of Collective Significance. The revision to Issue 6 is provided in accordance with reference 1. The remaining limited revisions reflect information developed since the original submittals and limited technical corrections. The logic and the approaches to resolution of the issues remain unchanged. These revisions have been discussed with your staff.

To facilitate your review, change bars have been provided in the right hand margins of the revised responses to indicate the portions which have been revised. -

The revisions to the responses have been reviewed and verified by LP&L QA in accordance with Procedure QASP 19-13. The designated subcommittee of the Waterford Safety Review Committee also has reviewed the adequacy of the revised responses for resolving the issues raised. The subcommittee scope of responsibility does not include indegendent validation of the facts.

The complete responses to Issues 1 and 10 with respect to QC inspectors will be submitted shortly.

',,n / A m #

lWf2ON

Mr. Darrell G. Eisenhut Page 2 W3B84-0817 November 21, 1984 The Task Force has not yet completed its independent validation of the facts. The Task Force has committed to notifying me and the NRC-immediately should it find significant deviations in the course of its validation. In the event of such notification, LP&L will amend individual responses as may be necessary.

Sincerely,

- JMC:DED:pc1 Attachments cc: (See next page) a 5

9

l

. 1 Fr. Darrell G. Eisenhut, Director Page 3 W3B84-0817 November 21, 1984 cc: Mr. R.S. Leddick Mr. J. Harrison Waterford 3 QA Team Leader Mr. D.E. Dobson Region III 700 Roosevelt Rd.

Mr. R.F. Burski Glen Ellyn, IL 60137 Mr. K.W. Cook Mr. J.E. Gagliardo

, Director of Waterford 3 Task Mr. T.F. Garrets Force Region IV Mr. A.S. Lockhart 611 Ryan Plaza Suite 1000 ,

Arlington, TX 76011 i Mr. R.P. Barkhurst Mr. D. Couchman Mr. L. Constable NUS Corporation USNRC - Waterford_3 910 Clopper Road Gaithersburg, MD 20878 Mr. R.D. Martin U.S. Nuclear Rege.latory Commission Mr. R.L. Ferguson Region IV UNC Nuclear Industries 611 Rycn Plaza Su:ite 1000 1200 Jadwin, Suite 425 Arlington, TX 76011 Richland, WA 99352.

Mr. D. Crutchfield Mr. L.L. Humphreys U.S. Nuclear Regulatory Commission UNC Nuclear Industries Washington, D.C. 20555 1200 Jadwin, Suite 425 Richland, WA 99352 Mr. G. Knighton, Chief Licensing Branch No. 3 Mr. G. Charnoff Division of Licensing Shaw, Pittman, Potts &

Washington, D.C. 20555 Trowbridge 1800 M. St. N.W.

, Mr. M. Peranich Washington, D.C. 20555 Waterford 3 Investigation and Evaluation' Inquiry Report Team Dr. J. Hendrie Leader 50 Bellport. Lane 4340 E.W. Hwy. MS-EWS-358 Bellport, NY 11713 Bethesda, MD 20114 Mr. R. Douglass Mr. D. Thatcher Baltimore Gas & Electric Waterford 3 Instrumentation & Control 8013 Ft. Smallwood Road Leader Baltimore, MD 21226

.7920 Norfolk Ave. MS-216 Bethesda, MD 20114 Pr. M.K. Yates, Project Manager Ebasco Services, Inc.

Mr. L. Shao Two World Trade Center, 80th Waterford 3 Civil / Structure Team New York, NY 10048 Leader 5650 Nicholson Ln. Mr. R. Christesen. President Pockville, MD Fhasco Services, .nc.

Two World Trade Center New York, NY 10048

ITDi: COLLECTIVE SIGNIFICANCE (REVISION 1)

PURPOSE:

In response to the twenty-three issues identified in the NRC letter of June 13, 1984, LP&L has provided - the NRC with a program plan describing the ongoing activities to resolve the NRC's concerns. The twenty-three responses developed in accordance with that program plan have addressed the specific NRC concerns.

As part of that effort, the findings of each issue were evaluated to determine the "cause" and " generic implications". That evaluation process was conducted

'in a manner. that allowed commonalities between the various issues to be considered and factored into the generic implications of one or more issues, where appropriate.

The purpose of this assessment of collective significance is to evaluate the overall significance of the findings from the twenty-three evaluations to achieve the following objectives:

Identify and assess the significance to safety and to the construction program of the findings from the evaluations of the twenty-three issues.

Identify actions that could have prevented occurrence of the twenty-three issues and thereby identify the lessons learned which, if implemented, would provide reasonable assurance that such deficiencies would be precluded from occurring in the future.

Review the LP&L operational phase Quality Assurance Program to determine whether the lessons learned are reflected in the Prog' ram or whether additional modifications to the Program are warranted.

The conclusions that have been reached in this assessment of collective significance are discussed in the following sections. The principal conclusions are as follows:

j_

In response to Issue 23, "QA Program Breakdown Between Ebasco and '.

t Mercury", LP&L committed to further address areas needing improvement i

in the QA program in this assessment of the collective significance of the 23 issues. Having completed the assessment, and in consideration ,

of problems related to Mercury in many of the other issues, it is apparent that programmatically the corrective action was not sufficiently thorough. Thus the partial breakdown acknowledged in j 1982 with respect to Mercury was not totally corrected. However, overall site performance improved, particularly with respect to the quality of installed hardware, and there was no escalation into an overall breakdown of the QA program.

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The 23 issues have been thoroughly analyzed. The process has involved more . than 1000 man-months of effort, exclusive of over 100 man-months  !

expended by the NUS Task Force Support Group. The results, reflecting -

the general quality of the QA program and of the construction work itself, provide a high degree of confidence that the structures, systems and components as constructed are adequate to protect the public health and safety during operation. Only very limited hardware rework has been undertaken as a result of the twenty-three concerns, and in several cases this rework has been discretionary.

The lessons learned from the twenty-three concerns provide a  !

reasonable basis to determine whether the operational phase of th e Quality Assurance Program adequately addresses the problems which occurred during construction.

The assessment of the operational phase Quality Assurance Program has provided reasonable assurance that the program is adequate to preclude similar problems.

This process, though extensive, clearly has been valuable to LP&L. The process has identified areas for improvement in the LP&L QA program and has reconfirmed the safety of the as-built plant.

This discussion of collective significance is divided into the following three parts:

1. Assessment of Construction Program and Safety Significance

2. Identification of Lessons Learned

3. Operational Phase QA Program Assessment ASSESSMENT OF CONSTRUCTION PROGRAM AND SAFETY SIGNIFICANCE To assess the safety significance of the 23 issues to the as-built plant, .the issues have been categorized according to the effort needed to resolve the concern (See Table 1). Four categories have been created as follows:

Mercury: Those issues involving resolution of work within the scope of Mercury's ef fort. With the exception of Issue 23, all. are also discussed in the following three categories.

Software: Those issues involving records reviews or limited action such as clarification / correlation of records, engineering evaluation, record analysis, or procedural changes.

Inspection / Evaluation: Those issues involving reinspections and engineering evaluations for resolution.

Hardware: Those issues involving physical rework to address the findings.

The significance to the construction program in terms of whether weaknesses have been corrected and the nature of the weakness is treated on a case by case basis. -

1. Mercury Work:

~

Ten of the 23 issues dealt in varying degrees of specificity with the Mercury program. Issue 23 "QA Program Breakdown between Ebasco and Mercury" dealt expressly with the effectiveness of the corrective action program undertaken by LP&L as a result of the problems identified in the Mercury program in 1982. Additional questions as to the effectiveness of the QA review of Mercury work are included in the following NRC concerns:

Issue Title 1 Inspection Personnel Issues 2 Missing N1 Instrument Line Documentation 3 Instrumentation Expansion Loop Separation 4 Lower Tier Corrective Actions 6 Dispositioning of Nonconformance & Discrepancy Reports 13 Missing NCRs 14 J.A. Jones Speed Letters and EIRs 17 QC Verification of Expansion Anchor Characteristics 22 Walder Qualifications (Mercury) & Filler Material Control (Site Wide)

Analysis of these concerns shows (a) improvement in, but continuing problems with, the control of Mercury efforts during construction, and (b) ultimate success in assuring the adequacy of the work within the Mercury scope.

Improvements in the control of Mercury work are detailed in response to Issue 23. These include a June 1982 LP&L order for Mercury to cease safety related installations until there had been extensive Mercury organizational

changes, additional staffing to address quality inspections / reviews, i

training to provide the guidance / direction needed for quality results, and the establishment of an Ebasco Management team to provide support and management oversight of the Mercury program. Subsequent improvements in control over Mercury included both ongoing administrative and quality program changes, and gradual reductions in the Mercury scope until a full demobilization by November 1983. A review of the post June 1982 work demonstrated a significant improvement in both the quality of installations and the quality of documentation.

Notwithstanding improvements in the Mercury program, problems continued.

Most importantly, generic implications of identified problems were not sufficiently addressed. Had they been, many of the problems identified by the NRC would have been identified by LP&L. For example, a significant l number of QC inspectors hired by Mercury as part of the 1982 corrective action were apparently not sufficiently qualified to ANSI N45.2.6-1973, and this was not discovered in the QA process. As an indication of the ongoing problem, Mercury did not process NCR-888 to address concerns that QC l personnel were not properly qualified. This action could have then l resulted in a more effective corrective action to address the Mercury

j. concerns as well as early identification of the issues found in Issues 1, 10 and 20.

i l l .

i While there were continuing problems with control of Mercury, the as-built condition of Mercury work, as determined by LP&L is adequate to assure the _

public health and safsty. This is demonstrated by reverification and testing activities both as a part of the Mercury corrective action program established in 1982 and as a part of the responses to the twenty three issues. The reverification activities encompass all types of. Mercury safety-related work. (See Responses to Issue 1 and Issue 23) As shown in the response to Issue 1, an extensive reinspection of all N1 instrument lines resulted in a small amount of rework, most of which was elective and none of which was significant to safety.

2. Software:

The resolution of six of the twenty-three identified issues was achieved through actions limited to such tasks as reconciliation / correlation of records, records analysis, records reviews, statistical analysis, engineering analyses, etc. Collectively, the evaluations of these concerns indicate that the past actions to address weaknesses in plant records had shortcomings but that these did not result in problems implying inadequacies in plant hardware.

In responding to Issue 5 " Vendor Documentation - Conditional Releases", a review was performed of the material receiving and control systems as well as other areas with a potential for a similar situation (i.e. concerns noted on Release for Shipment Forms, Ebasco Home Office controlled NCR's, and material received under manufacture, deliver and erect type contracts).

It was determined that the problems were limited to the absence of the formal tracking required by existing procedures for conditional certifications in Combustion Engineering documentation packages. There was an undetected violation of procedures but based on a review of CE purchase orders, it was concluded that there would have been no safety consequences if the deficiency had remained uncorrected.

Issues 7 " Backfill Soil Densities" and 11 "Cadwalding" involved analyses of records. For Issue 7, records correlation had not been completed because some were in the Ebasco vaults and some had not yet been obtained from the contractor who, it should be noted, was still onsite and active. The correlation, review and analysis demonstrated that there was . good work control, that specification requirements were generally exceeded, and that the backfill was adequate to perform its design function. In Issue 11, the quant.ity of data did not allow ready analysis to demonstrate the attributes desi: ed. Therefore, LP&L transcribed cadwald data ento computer storage to

' _ demonstrate compliance with Regulatory Guide 1.10 and specification sampling frequencies. The review identified three minor discrepancies not identified in the prior NCR and these were evaluated and found to be

, acceptable.

Issue 8 " Visual Examination of Shop Welds During Hydrostatic Testing", was the result of a checklist that only identified field welds. This concern had. been previously identified in. June 1983 and dispositioned to demonstrate the adequacy of the visual examination of shop welds and the lack of any safety impact. The review gives no indication of deficiencies. _

J

3 The records reviews for Issue 13 " Missing NCR's" included site NCR's, Ebasco Home Office NCR's, and Mercury NCR's and demonstrates that, although a documentation was not readily available to answer some of the concerns, -

there was no loss of control over NCR's that would currently imply open -

questions about the acceptability of installed safety systems. The cause  ;

of most of the concerns related to Ebasco NCR's was identified as a change _

in record keeping in 1979, a temporary practice that allowed NCR numbers to -_

be issued prior to the NCR being written, and the use of a preassigned block of NCR numbers. The review of Mercury NCR's concluded that there was j one missing NCR which did not represent an unresolved condition, one _

superceeded NCR, and three NCR's which had not been processed by Mercury. --

These three NCR's, one of which is covered by Issue 1, have now been resolved. The cause was Mercury's improper application of their own s procedures.

{

Issue 16 " Surveys and Exic Interviews of QA Personnel" involved an LP&L initiative for obtaining employee feedback on potential safety concerns.

The shortcomings of the initial program have been addressed. The exit n

interview program has been completely restructured and is providing a very _J useful service in obtaining feedback on individual's concerns. Feedback g received prior to the restructuring is being reanalyzed and concerns are l being closed through an orderly closure process. .

3. Inspection / Evaluation: 1 Nine of the twenty three issues were resolved by reinspections, engineering -

evaluation, statistical sampling, or similar efforts but required no

, changes to the plant hardware. An evaluation of these concerns leads to a -

conclusion there were weaknesses in plant records but these weaknesses have -

now been addressed and do not represent a potential hardware deficiency.

x Three of the Issues, 1 " Inspection Personnel Issues", 10 " Inspector _

Qualification - J.A. Jones & Fegles", and 20 " Construction Material Testing (CMT) Personnel Qualification Records" involved a review of professional -

credential and education / employment checks on 100% of the site QA/QC personnel involved in safety related activities. In this review, QA/QC conservative and standardized personnel have been classified using acceptance criteria as " qualified" and " unqualified". These -

classifications were reviewed and finalized by an LP&L Review Board of -

senior QA personnel with the assistance of contractor and consultant r support. For " unqualified" inspector personnel, Corrective Action Requests _

were written to formally track and disposition potential deficiencies. For '

Mercury, substantial reinspection was initiated, particularly for the N1 -

tubing installation, and rework is covered in the next section. For most -

contractors reviewed under Issues 1 and 10, the disposition of deficiencies ,

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has not required reinspection. In the case of Issue 20, an engineering evaluation of the work of CMT personnel has established that questions a about personnel qualifications have not rendered the work indeterninate.

There have been many other methods (e.g. ANI, NDE, prerequisite l ^

preoperations/ integrated testing, overinspections, etc.) which provide assurance that quality has been built into the plant. There have been no )

safety significant hardware changes found and this provides positive -

evidence as to the adequacy of the overall construction program. -

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Issue 4, " Lower Tier Corrective Actions Are Not Being Upgraded to NCR's" required an extensive effort to . review document packages, based on a .

statistical sample, to ascertain whether they had been properly upgraded to NCRs, whether the disposition was adequate, and whether proper reporting per 10CFR50.55(e) and 10CFR21 had occurred. The review identified minor weaknesses in the construction program in following procedural criteria for lower tier documents with regard to voiding and upgrading to NCR's. While it does indicate a deficiency in the construction program, it does not indicate that there was a loss of control over non-conforming materials, parts, or components. This conclusion is supported by the results of a statistically justified sampling program.

The resolution of Issue 9 " Welder Certification" identified adequate welder certification but found that the records for seven instrument cabinets were incomplace or missing. The adequacy of the welding performed by J.A. Jones has been reviewed. In cases where welding deficiencies were identified, '

the welds were dispositioned to be acceptable as is. The missing or l

incomplete documentation identifies a loss of control in records management but the acceptable dispositioning of the welds and the results of the complete review of the J. A. Jones welding scope demonstrates the overall adequacy of the J.A. Jones welding.

A sampling program of the information request documentation used by l

contractors was undertaken in order to resolve Issue 14 "J.A. Jones Speed Letters .and EIRs". In the case of approximately one third of the contractors, instances were identified where design changes were made by information requests without appropriate documentation. This was determined by taking a minimum 10% random sample of each contractors information requests (for fif ty or less such documents, there was a total review) and expanding that sample by 10% increments wherever there was a violation of design control. Approximately 5% of the total IR's evaluated (approximately 6000) involved design control but no rework was required except for that being conducted within the scope of SCD-78 (American Bridge Welding Deficiencies). It was concluded that the lack of control exercised l over these contractors was a deficiency in controlling records in L accordance with the construction program procedures. There are no l remaining open issues.

l The response to Issue 17 "QC Verification of Expansion Anchor Characteristics" recognizes a shortcoming in not specifically delineating l all characteristics on an inspection checklist although the necessary characteristics were listed elsewhere. The expansion anchors were the subject of several different corrective action prograus as part of the i

overall effort to verify the adequacy of Mercury's work. These corrective actions previously addressed the NRC concern except for several technical questions which have been resolved. A 100% reinspection of Mercury N1 instrument installations has been completed and provides further evidence of expension anchor adequacy. The shortcomings in the original inspection checklist are considered a procedural deficiency in the construction progrsa, but a current lack of safety significance was demonstraced.

I

Issue 18 " Documentation of Walkdowns of Non-Safety Related Equipment" resulted from the documentation by exception practices used during previous plant "two over one" walkdowns. To resolve this concern, a detailed reinspection under a formal engineering procedure was performed of the instrument air system and two plant areas to provide additional confidence in the original design and walkdowns. This reinspection found no deficiencies and supported a conclusion that the construction program was adequate and there are no unresolved safety deficiencies.

The resolution of Issue 21 "LP&L QA Construction System Status and Transfer  ;

Reviews" involved demonstrating adequate control of comments and open items  !

- in the system transfer and testing process. As a result ,of extensiv e efforts on this matter, including confirmatory field verification of three j items, it was determined that no significant comments or open items were l untracked and that there was no impact on testing or system operation. I l

There were two separate issues in Issue 22 " Welder Qualification (Mercury) and Filler Material Control (Site wide)". The first, welder qualifications, was resolved by a thorough review of welder documentation and we1. der qualification. No significant deficiencies were identified and those minor deficiencies identified were properly dispositioned. Concerns over weld filler metal controls were addressed by a review which showed site practices to be unclear with regard to ambiguities between various ,

code requirements. Further, justification of several past corrective l

! actions was provided where there had been deviations from the site )

procedure. In both cases, the evaluation demonstrated that, although there were deficiencies in procedural clarity and the control of site practices, no unresolved safety issues exist.

4. Hardware:

- Seven of the twenty-three issues involved hardware changes in addition to inspections, evaluations or other software activities to resolve the concerns. A review of these concerns has shown that, if lef t uncorrected, two of the reworked items presented a potential safety concern. Of these two, one was related to rework on a three foot section of tubing and the second represented a case where the safety significance was not determined.

It has been concluded that while construction program deficiencies existed these did not warrant an implication that the corrective action system as currently implemented was inadequate to provide assurance that the plant is safely constructed.

The N1 instrumentation walkdown initiated in response to Issue 1,

" Inspection Personnel Issues" has identified deficiencias that, if left uncorrected, would not have effected the safety of plant operations. The conclusions on Mercury correction actions were discussed earlier.

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, A lack of documentation consistent with 10CFR50 Appendix B requirements for local mounted instruments installed to ANSI B31.1 was evaluated in Issue 2 -

" Missing N1 Instrument Line Documentation". In responding to the concern, 18 installatic,ns were identified as having documentation . insufficient to meet the objective requirements of Appendix B. Based on documentation reviewed, the as-built installations were considered capable of performing their intended functions. Nevertheless, a decision was made to rework the installations to standardize compliance with ASME code requirements. This t records deficiency in the construction program was found to have resulted in no safety significant deficiencies. The rework was performed as part of a conservative corrective action.

Issue 3'" Instrumentation Expansion Loop Separation" identified a procedural implementation deficiency in the construction program occurring when 2 insufficient attention was given by Mercury personnel to specified ins tallation separation criteria. Reinspections of those installations identified by the NRC as well as installations where tubing lines were run in proximity to each other resulted in the identification of additional deviations to the separation criteria. With the exception of one-three foot section of tube track all were found acceptable "as-is". The

.necessary rework has been completed. It was concluded that this was a deficiency in the Mercury corrective action but was of limited safety significance because of the isolated nature of the rework.

Issue 6 "Dispositioning of Nonconformance and Discrepancy Reports" identified specific Ebasco and Mercury NCRs and Ebasco DRs in ~which the NRC had concerns relative to dispositioning, lack of supporting documentation,

, accomplishment of. related rework and sufficiency of engineering i justification of dispositions. A review of these Waterford 3 records was

! conducted and no condition was found which, were it to have remained uncorrected would have adversely affected the safety of operations of Waterford 3. LP&L had previously initiated a program in February 1984 to address Ebasco NCRs. This -program was expanded to encompass the NRC request and is nearly complete. While some discrepancies were noted and several reinspections performed, rework was performed in only a few cases.

- . The most significant amount of rework occurred as a result of the findings

-in Issue 12 " Main Steam 11ne Framing Restraints". In this case it was found that additional rework was identified from the review of American - Bridge information requests and the incomplete scoping for open Significant Construction Deficiency 78. Rework was required to replace the framing l bcits where documentation was not available and bolt identification could '

net be readily verified. Upon identification of the concern a conservative management decision was made to replace the bolts in lieu of attempting to test or. sample test the bolts in question to determine their usability.

Thus no determination ' was made regarding the safety significance of the existing condition. A rescoping of other significant open SCD's has been conducted to address potential concerns related to scoping practices.

Deficiencies were corrected and no further safety concerns remain in this area.

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Issue 15 " Welding of "D" Level Material Inside Containment" resulted in a reinspection of the most significant "D" level welds. The findings identify a deficiency in the construction program because no record keeping

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requirements were specified in the CB&I QA program for these type welds.

The reinspection of welds identified weld deficiencies that were evaluated to be. acceptable "as is" and a number of are strikes that required rework (grinding) to demonstrate that no damage to base metal had occurred. It was concluded that the construction program weakness created no significant safety concerns and raised no unresolved implications with regard to the adequacy of the "as-built" plant.

Issue 19 " Water In Basemat Instrumentation Conduit" was evaluated by a walkdown to identify areas of seepage and potential direct paths for ground water. As a result of this walkdown a piezometer standpipe will be pressure grouted prior to fuel load to limit further seepage. This rework was identified even though the evaluation showed that there was no potential for flooding the auxiliary basemat. It was concluded that no construction program deficiencies or safety concerns exist.

4.

Conclusions:

The twenty three issues have been assessed and corrective actions have been or are being taken to correct deficiencies found. The safety significance of ongoing activities and completed activities is being assessed for each of the plant systems required by technical specifications to be operable during the various operational modes. Those safety evaluations needed to support any phase of operation will be a prerequisite to LP&L requests for a license to operate in that phase.

The responses to the 23 issues, when assessed together, lead to two generic conclusions: (a) The QA program during the construction phase continued to have shortcomings, but with current corrective action the objectives and criteria of the construction program have now been met. The deficiencies fell primarily into the categories of records management and control of corrective actions. (b) The overall adequacy of the plant in the areas of the 23 issues is confirmed by the extensive re-evaluations and reinspections conducted in response to the 23 issues and by the minimal rework required as a result of the concerns. The plant as-built can be operated without undue risk to public health and safety.

e IDENTIFICATION OF LESSONS LEARNED

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Lessons learned were developed from the twenty-three issues for the purpose of evaluating the ability of the operational phase Quality Assurance Program to preclude the mistakes made during construction. . These lessons learned are intended to define the types of actions which could have been taken to avoid the safety impacts that were identified. Table 2 presents the lessons learned as well as a bri'ef description of the manner in which the operational phase Quality Assurance Program addresses the lessons learned. This approach allows definition of the actions needed to anticipate problems. The need to identify emerging _ QC problems in a timely manner and to take effective and timely corrective actions is also recognized. The next section provides a more complete description of the operational phase QA program to supplement the lessons learned table and to describe the management oversight, trending and corrective action programs that allow for prompt identification and action on problems.

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TABLE 1 ACTIVITIES REQUIRED TO RESOLVE THE TWENTY THREE ISSUES Inspection / (1) -

Concern Software Evaluation Hardware

-1 D

2. D 3 L

( 4 X 5 X 6 D 7 X 8 X 9 X 10 X 1

11 X 12 - PS 13 X 14 X 15 D l.

16 X 17 X 18 X 19 D 20- X

.21 X 22 X NCTIES:

(1) The safety significance of the hardware impacts has been indicated by a "D" where hardware changes were discretionary or in accordance with good practices, a "PS" where the safety significance was not fully ..

evaluated, and an "L" where there was safety significance if lef t uncorrected but the significance was limited because of the isolated nature or limited extent of the deficiency.

TABLE 2 OPEkATIONAL READINESS ASSESSMENT-PAST FUTURE Actions Which Could Have Prevented Occurrence Issue (Lessons Learned) Reflection in Operational QA Program 1 .This concern could have been avoided if a During the operations phase, LP&L and contractor inspection uniform and conservative standard had been personnel will be certified to ANSI N45.2.6-1978 and imposed for judging QA/QC personnel. Regulatory Guide 1.58 Rev. 1. Prior to certification a qualifications and for documentation.of those background investigation must be satisfactorily completed.

qualifications. documenting a candidate's education and employment experience as described in Section II.D.

2 Recognize that quality records required by Documentation (objective evidence of acceptance) requirements 10CFR50 Appendix B sometimes exceed the record during normal operations are defined in drawings, keeping requirements of industry codes. The specifications, and procedures. Review of specified concern could have been avoided if the documentation requirements associated with station contractors had been required to supply the modifications is an integral part of the operations phase proper documentation. design process. This review assures the appropriateness and completeness of required documentation. The Station Modification process is described in Section II.H.

3 This concern, which dealt with field run Under the operations phase QA Program field run items will be installations, could have been avoided by minimized and controlled by procedure. The Station increased training of design / installation / Modification Package (SMP) process includes a checklist of inspection personnel in order to increase generic criteria to be addressed. Additionally, the Detailed their understanding of generic criteria and Construction Package will contain necessary acceptance their ability to recognize deficiencies. criteria to direct the installer and inspector (see Section ll.H).

4 The basic causes of this concern (which are During the operations phase a uniform program for quality . .

not felt to be unique to Waterford 3) relate deficiency identification and resolution will be employed.

to the large number of specialty type quality The Condition Identification and Work Authorization (CIWA) contractors employed during the construction will be the primary means of identification and phase, coupled with laterent design / implementation of corrective action at Waterford 3. The i

construction interface problems associated quality deficiency mechanisms utilized by LP&L are described i

with parallel design and construction. The in detail in Sections II.B.I.a-c.

, problems in this issue accruing from the above situation could have been avoided had a more definitive and standardized quality deficiency program been developed and implemented.

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TABLE 2

. OPERATIONAL READINESS ASSESSMENT PAST FUTURE Actions Which Could Have Prevented Occurrence-Issue (Lessons Learned) Reflection in Operational QA Program 5 The concern could have been avoided if it had Any quality related material received on site with been recognized that while CE handled conditional certification is tracked in accordance with the certifications differently than other vendors procedures for Discrepancy Notices as described in Section that did not eliminate the requirement to II.B.1.b.

track conditional certifications in order to ensure closure.

6 a. Some of the concerns could have been a. Under the operations phase QA Program, in order to provide avoided by recognizing the need to have a standardization, hardware deficiencies will be identified more uniform process (LP&L, Ebasco, and through use of the LP&L CIWA (plant identified) or DN contractors) for the disposition and (receipt inspection identified) as noted in Section resolution of deficiencies. II.C.3.

b. Some of the concerns could have been b. All quality related deficiencies identified during the

{ avoided by establishment of a routine operations phase undergo verification review of the 1 process for additional verification corrective action and disposition prior to closing out the

! (including field verification) of the deficiency. The deficiency identification and resolution j resolution to assess the adequacy of mechanisms are described in detail in Sections II.B.I.a-f.

dispositioins and ccrrective actions. More As part of the semi-annual audit of the corrective action

emphasis should have been placed on a QA process, the QA Program will include a field verificati'on l management overview designed to distinguish audit of the CIWA closure process. In addition, Operations I

generic trends and root causes of QA utilizes a QA Trending Programs to identify adverse deficiencies from isolated significant quality tresids and generic quality problems as described occurrences or repetitious occurrences of in Section 11.B.I.u.

less significance. .

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c. Given the need for more consistent c. During the operations phase, the Quality Assurance Section engineering judgement, some concerns could holds monthly training sessions. Lessons learned or

have been avoided by the use in training of corrective actions as a result of quality deficiencies or l specific disposition of past problems. undesirable programmatic trends identified at Waterford 3 l will be reviewed during these sessions as described in l

Section 11.E.2. Additionally, the QA Section will prepare, for distribution to plant staff performing quality related work, similar briefing material as a feedback mechanism for current quality concerns.

TABLE 2 OPERATIONAL READINESS ASSESSMENT 1 PAST FUTURE Actions Which Could Have Prevented Occurrence

+

In+ue (Lessons Learned) Reflection in Operational QA Program i

i

! d. Recognize the need for ready retrieval / d. Records are processed upon completion of the activity and 4

control of records. This would be assisted verified complete by cognizant supervisory personnel. All by processing records as the work is Quality records during the operations phase are maintained completed through all required revieus, by LP&L's Project Files. Documents are stored and cross-l resolutions of comments, and necessary indexed to facilitate timely retrieval. Records verification and then vaulting the records. management is further described in Section II.I. The

, This approach would have avoided some of current programs of record management at Waterford 3 are

, the concerns that arose because of records under review by LP&L management to ensure proper

retrievability, discipline and optimum utility exists. This review is a

expected to be complete, and any necessary programmatic changes will be initiated by November 30, 1984.

?

7 This concern could have been avoided if, as Records are processed upon completion of the activity and i work was completed, records were retrieved verified complete by cognizant supervisory personnel. Quality I from the contractor, processed through the records during the operations phase are maintained by LP&L's required reviews, any necessary verification Project Files. Records management is further described in

completed and then vaulted. Section 11.1.

$ 8 Shop welds, the subject of this concern, were , N/A hydrostatically tested and inspected and, therefore, no deficiency exists.

9 This concern could have been avoided if, as During the operations phase, any change in scope of the work was completed, records were verified as contractor's reuponsibilities would initiate an LP&L review l complete against the scope of work. of the applicable portions of the contractor's QA program -

i similarly to what is required for a new contract. Such I

review would include document generation requirements.

Section II.G further discusses the review of contractor QA programs.

10 This concern could have been avoided if a During the operations phase, LP&L and contractor inspection uniform and conservative standard had been personnel will be certified to ANSI N45.2.6-1978 and

, imposed for judging QA/QC personnel Regulatory Guide 1.58 Rev. 1. Prior to certification a qualifications and for documentation of those background investigation must be satisfactorily completed qualifications. documenting a candidate's education and employment experience as described in Section 11.D. .

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TABLE 2

. OPERATIONAL READINESS ASSESSMENT PAST FUTURE Actions Which Could Have Prevented Occurrence Issue (Lessons Learned) Reflection in Operational QA Program 11 This concern could have been avoided if, in This concern relates to bulk construction and is not addition to in-process analysis conducted, a applicable to the operations phase.

means to track the completion and correlation of data / records needed to verify compliance with specifications had been implemented.

12 This concern could have been avoided if it had Multiple levels of pre- and post- implementation review of been recognized that scoping of complex corrective actions occur during the operations phase.

corrective actions (e.g. multiple contractors, Corrective action must be implemented and tracked through one complex drawings, and construction of the deficiency. identification mechanisms described in interferences) required commensurate care in Sections II.B.I.a-e. Broad scope and complex corrective assuring that the scoping of the corrective actions will be cause for development of a Special Procedure action is accurate and tracked to assure as described in QP-005-001, " Instructions Procedures and completion. Drawings", in order to control scoping and interfaces, and to establish a tracking mechanism to ensure completion and closure.

13 Some concerns could have been avoided through The operations phase QA Program provides for different means the use of a rigidly controlled tracking from the construction phase to identify, track, and resolve system to control special purpose hardware quality problems. Jhe quality deficiency identification deficiency documents that have characteristics mechanisms, all of which provide for a controlled tracking such as: multiple interfaces; require system, are discussed in Sections II.B.1.a-e.

tracking during processing; and/or are needed to control quality related questions in a timely manner. .

14 This concern could have been avoided if Plant modifications during the operations phase are procedures regarding information requests had accomplished through the Station Modification Program (SHP) been standardized and controlled. The described in Section II.H. . Work is directed by the Detailed procedures should have been the subject of Construction Package (DCP) assembled under the Program. For training to ensure a proper understanding and cases where work cannot be done in accordance with the DCP, awareness of the procedure and limitations of changes may be allowed only upon approval of a change to the the IR instrument. Audits could have been Station Modification Package or, for minor changes, through more comprehensive to assure that the program approval of a Detailed Construction Package Change (DCPC).

and procedures were being properly followed. All work documentation, including DCPCs, is included in the CIWA post. implementation review described in Section II.B.I.a. as well as the SMP closure review described in.

Section II.H.

o-TABLE 2 OPERATIONAL READINESS ASSESSHENT PAST FUTURE Actions Which could Have' Prevented Occurrence Icrue (Lessons Learned) Reflection in Operational QA Program

) '

15 The concern could have been avoided if Documentation (objective evidence of acceptance) requirements contractors had been required to ensure during normal operations are well defined in drawings, adequate inspection documentation for specifications and procedures. Review of specified Seismic Category 1 work outside the ASME Code documentation requirements. associated with station jurisdictional boundaries. modifications is an integral part of the operations phase design process. This review assures the appropriateness and

complete..ess of-required documentation. The Station j Modification process is described in Section II.H.

16 This concern could have been avoided if the Th'e LP&L Quality Team has been constituted to allow any program had been auditable, if more formal individual to expresa quality concerns on a confidential

training had been provided to the basis, and be assured of (1) investigation of the concern,

, interviewers, and if more detailed followup (2) substantiation of the concerns and (3) correction of the had occurred. concern. The Quality Team program is described in detail in Section 11.A.ll.

17 The concern might have been avoided if, during The FSAR and the LP&L QA Manual require that inspection the preparation of construction / inspection procedures, instructions and checklists contain acceptance ,

! , procedures, more care was taken to explicitly and rejection criteria. Prior to implementation, there is an  !

i list the characteristics necessary to ensure appropriate review to assure that necessary acceptance

) . proper verification of installation in the criteria are adequately transposed from'the design disclosure inspection sections and checklists. documents to the inspection procedures, instructions and checklists.

18 The two-over-one problems uncovered in the Under the operations phase QA Program the Station previous inspections were documented on an Modification Package process includes a checklist of all i exception basis. The concern over the generic criteria to be addressed during the design and

( adequacy of those inspections could have been verification stage. This process is described in Section j avoided by a requirement to ensure adequate II.H.

I and more auditable documentation of the l inspections.

19 There is no path for groundwater to flow in N/A sufficient quantity to flood the auxiliary building basement and, therefore, no de.ficiency exists. i .

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TABLE 2 4

OPERATIONAL READINESS ASSESSHENT PAST MITURE Actions Which could Have Prevented Occurrence.

Issue (Lessons Learned) Reflection in Operational QA Program i

i i 20 This concern could have been avoided if a During the operations phase. LP&L and contractor inspection i uniform and conservative standard had been personnel will be certified to ANSI M45.2.6-1978 and i imposed for judging QA/QC personnel Regulatory Cuide 1.58 Rev.1. ' Prior to certification a .

i qualifications and for documentation of those background investigation must be satisfactorily completed i qualifications, documenting a candidate's education and employment experience as described in Section ll.D.

21 During the system transfer and testing During the operations phase LP&L will retain control and

, process, Waterford 3 had several groups with responsibility for new and existing systems. No system

generally discrete responsibilities for transfer outside of LP&L will occur.

identifyin.g end resolving quality related j issues. This resulted in the achievement of

optimum hardware quality however full j' understanding of the day-to-day coordination between those groups of the open items and 1

their status could have been enhanced by

] better documentation and training on that process.

22 4 Concere could have been avoided if records a. As a result of this issue. LP&L is evaluating the Waterford had readily allowed the hierarchy of welder 3 welding program to identify areas of potential position and process qualifications to be improvement. As part of this evaluation, welder records demonstrated for audits and verification will be configured to readily allow the hierarchy of .

of compliance with requirements. welder position and procesa qualifications to be demonstrated,

b. Recognizing the need to provide clear b. Deviations from applicable codes and standards may not be justification when there are apparent taken under the operations phase QA Program unless conflicts with code requirements could have evaluated in accordance with 10CFR50.59.

avoided this concern.

TABLE 2 GPERATIONAL READINESS ASSESSMENT PAST FUTURE Actions Which Could Have Prevented Occurrence Issue (Lessons Learned) Reflection in Operational QA Program 23 a. This concern could have been avoided by a. LP&L retains and exercises responsibility for the recognizing that delegation to Ebasco of operational phase QA Program. The QA Program of the routine QA auditing overview of Mercury contractors / vendors performing work for Waterford 3 during without adequate LP&L involvement inhibited the operations phase must meet all applicable requirements the timely recognition by LP&L of quality of the LP&L QA Program (see Section II.C). The problems. Engineering and Systems Development QA Croup conducts audits and surveys of off-site contractors, vendors, and quality related suppliers. The Operations QA and Plant Quality Groups conduct on-site audits and surveillances of quality related activities as described in Sections II.F.1 and II.F.2.

b. More emphasis should have been placed on a b. Operations QA utilizes a QA Trending Program to identify QA management overview designed to adverse quality trends and generic quality problems. This distinguish generic problem trends and root is discussed in detail in Section II.B.2.a. The yearly causes of audit findings from isolated audits schedule is approved by the full Safety Review occurrences. Committee (SRC). Operations QA audits are reviewed by an SRC Subcommittee and results reported to the full SRC as described in Section II.A.I.

c. Staffing levels should have been higher. c. During the operations phase LP&L retains direct control of its QA Program. This resulted in a significant increase in staffing over that employed by LP&L Construction QA.

The current staffing levels of selected Waterford 3 groups including the operations phase QA organization is .

described in Section II.C.

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OPERATIONAL PHASE QA PROGRAM ASSESSMLNT r

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TABLE OF CONTENTS SECTION PAGE I. QA Program Overview 1 A. Organization 1 B. QA Program Scope 2 C. . Quality Training 2 D. Inspection / Audits 3 E. Corrective Action Implementation and Verification 3 II. Selected Aspects of the Operations QA Program 3 A. Management Oversight 4

1. Safety Review Committee 4

2. Yearly Management Audits of the QA Program 5

3. QA Trending Prograa Quarterly Reports 5

4. Quality Assurance Program Status Summaries 6 l 5. Plant Operations Review Committee 6

!. 6. Quality Inspection Activities Status Reports 6 l 7. Licensee Event Reports 7

8. Availability Improvement Program Reports 7

9. Independent Safety Engineering Group 7

10. Operations Assessment and Information Dissamination Group 8

11. Quality Team 8 B. Quality Deficiency Identification and Resolution 10

1. Isolated Quality Deficiencies 10 ,

.a. CIWAs 10

b. DNs 12

c. QNs 13

d. CARS 13

, e. AFRs 14

! f. NRC Inspection Reports 15 i

! 2. Generic Quality Deficiencies 16

a. QA Trending Program 16

b. Availability Improvement Program 18

. c. Hardware Trending 19 C. Staffing 20 D. Certification of Inspection Personnel 21

TABLE OF CONTENTS SECTION PAGE E. Quality Assurance Indoctrination and Training 21

1. Plant Staff Quality Related Training 21

2. Quality Assurance Section Training 22

3. Contractor Training 23 F. Audit / Review Programs 24

1. Nuclear Operations QA Audit / Monitoring Programs 24

a. Audit Program 24

b. Monitoring Program 25

2. Plant Quality Group Review and Verification Process 25

a. Plant Quality Inspection Reports 25

b. Hold Points 26

c. Quality Instructions- 27

d. Plant Quality Surveillance 29

e. Stop Work 29 G. Control of Contractor Quality Related Activities 29

1. Evaluation of Supplier's Quality Assurance Program 29

2. . Conduct of Contractor Quality Assurance Audits 30 3

3. Deficiency Reporting by Contractors 31 H. Station Modification Program 31

. I. Records 33 e

e

OPERATIONAL PHASE QA PROGRAM ASSESSMENT .

The individual responses and the prior discussions in this analysis of

" collective significance" establish that, with respect to the 23 issues, the plant as-built is adequate to assure public health and safety during operation.

At the same time, the review identified various areas in which the construction phase QA Program could have been improved. While the construction phase is essentially complete, the operations phase will shortly commence. In this light, it is appropriate to review the Waterford 3 operations phase QA Program with a focus on the lessons learned from the 23 issues.

LP&L has established a comprehensive program for quality assurance during the operating phase of Waterford 3. The Nuclear Operations Quality Assurance Program is applied to activities affecting the quality of those items which prevent or mitigate the consequences of postulated accidents which could cause undue risk to public health and safety. Those activities include plant operation, maintenance, repair, modification and refueling.

The QA Program is described in Chapter 17.2 of the Waterford FSAR and in the

, Quality Assurance Manual.Section I of this assessment provides an overview of the QA Program, not a detailed discussion. In Section II selected aspects of c the QA Program will be covered in detail in counterpoint to the issues raised in

! the 23 NRC concerns.

I. QA Program Overviev A. Organization

?

! LP&L retains and exercises responsibility for the QA Program at

[- Waterford 3. The Senior Vice President Nuclear Operations, who reports to the President of LP&L, is responsible for defining quality assurance

-policy. Reporting to him are the Plant Manager-Nuclear, Nuclear l Services Manager, Project Manager-Nuclear, Corporate Quality Assurance l Manager, and the Safety Review Committee (the members of which are

appointed by the Senior Vice President Nuclear Operations). The corporate organization for implementation of the QA Program is shown in Figure 17.2-1 of the FSAR.

l While quality is a concern of all Nuclear Operations personnel, the Quality Assurance and Plant Quality Groups within Nuclear Operations deserve special mention. The Quality Assurance (QA)' organization is responsible for developing, coordinating, and assuring implementation of the LP&L QA Program. Although most quality related activities are performed by personnel outside the QA organization, an overview of the j performance of these activities relative to QA Program compliance is

[ accomplished by QA personnel through reviews and audits.

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i QA is divided into two groups. The Engineering and Systems ~

Development QA Group conducts surveys and audits of contractors and vendors, maintains the Qualified Suppliers List, reviews procurenant ,

packages, and conducts surveillance of quality related-suppliers. The I Nuclear Operations QA Group assures that the QA Program at the site is '

, being effectively implemented.

Operations QA is a relatively new organization. It became a functional quality management to'ol with its first audit in January, 1982 of the system turnover process. In fact, it was as a direct result of this audit.that the problem with Mercury (Issue #23) was-first identified and

, reported to the NRC. Its responsibilities include the audit, aonitoring, review and quality trending programs for Waterford 3.

l

- The Plant Quality Department reports to the Plant Manager-Nuclear. l This Department has direct responsibility to implement the  ;

- requirements of the QA Program related to onsite-initiated activities  !

< including review, inspection, verification and surveillance

! requirements.

B. QA Program Scope As described in the LP&L QA Manual, the QA Program is applied to l all quality related areas of plant operation. For safety-related items, all applicable portions of the QA Program (i.e. Appendix B) criteria are applied. The QA Manual also provides.a separate section of Special Scope QA Policies, defining application of selected 10CFR50 Appendix B criteria as necessary. Currently, such areas as fire protection, radiological environmental monitoring, the Availability Improvement Program, computer software, radiation protection and emergency preparedness are covered as special scope policies. Special scope policies will be issued to cover additional areas such as security and radioactive waste management.

C. Quality Training

- Training is fundamental to quality. As a result, indoctrination and training programs are established for Nuclear Operations personnel performing quality related activities. The programs are designed to ensure that personnel are knowledgeable in quality assurance procedures / requirements and have the necessary proficiency to implement the requirements. The Quality Assurance Section assists with the development and conduct of quality assurance indoctrination and training with the Corporate Quality Assurance Manager reviewing and concurring with the program content.

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D. Inspection / Audits Monitoring of quality program implementation is performed through

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inspection and surveillances during operation, maintenance, modification, repair, material receiving, and storage activities.

Maintenance and modification instruction, and work plans are reviewed by Plant Quality personnel to assure the inclusion of inspection requirements and to' verify that methods and acceptance criteria are defined. Inspections are performed by qualified Plant Quality personnel. For quality related activities (e.g. surveillance testing) where direct inspection is not utilized, the Plant -Quality Group

,' surveil the activities in accordance with established procedures.

Audits are conducted by the Quality Assurance Section to provide a comprehensive independent verification and evaluation of quality related procedures and activities. Additional audits are performed as required to verify and evaluate supplier and contractor Quality Assurance Programs, procedures, activities, and interf ace controls.

E. Corrective Action Implementation and Verification For deficiencies identified by plant staff or identified during the inspection / audit process, multiple means exist to implement corrective action. For each means of deficiency identification there exists a process to implement, track', and verify as complete the appropriate corrective 5

action. Furthermore, through various trending programs the generic significance of individual deficiencias taken as a whole is identified, assessed and corrective action implemented. Such trending programs exist for the areas of programmatic, systematic and hardware deficiencies.

II .~ Selected ' Aspects of the Operations QA Program The 23 NRC issues have dealt with possible quality problems during the construction phase of Waterford 3. During the review of these issues LP&L has identified various lessons learned that. . in retrospect, would have led to changes in the construction QA Program. It is natural, therefore, 'to examine-the operational phase QA Program for Waterford 3 in light of the construction phase lessons learned. The discussions which follow are i

, intended to amplify on selected aspects of the operational phase QA Program which reflect incorporation of the major lessons learned from the construction phase. It should be noted that the Operations QA Program was developed independently of the construction QA Program in order to meet the needs of an operating plant. With minor exceptions, the Operations QA Program was not changed as a result of the lessons learned from the 23 NRC concerns, but rather anticipated and already encompassed those areas of concern.

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The following discussions are divided into nine major areas:

A. Management Oversight -

B. Quality Deficiency Identification and Resolution C. S taffing i D. Certification of Inspection Personnel I E. Quality Assurance Indoctrination and Training F. Audit / Review Programs G. Control of Contractor Quality-Related Activities H. Station Modification Program I. Records A. Management Oversight Maintaining a high level of quality at an operating nuclear power plant requires continuous management involvement in the QA Program.

LP&L management has structured the operational QA Program to ensure management oversight and control of all aspects of quality at Waterford 3.

The Plant Manager, reporting directly to the Senior Vice President Nuclear Operations, is responsible for the primary implementation of

. quality related measures during the operation activities at Waterford

3. The Senior Vice President Nuclear Operations, the Plant Manager, and other utility executives employ a number of management tools to implement'and validate the operational QA Program.

1. Safety Review Committee The Waterford 3 Safety Review Committee (SRC), of which the Plant Manager is a member, reports directly to the Senior Vice President Nuclear Operations through monthly reports of SRC activities. It is primarily responsible for the management level overview of the operation of the Waterford 3 plant to assure that the plant is operated in accordance with the Technical Specifications and to review significant safety issues.

One of the key functions of the SRC is to review the audit program as defined by the plant Technical Specifications. At Waterford 3 the SRC has established a subcommittee responsible for reviewing all QA audits specified by the Technical Specifications as well as reviewing any special audit or additional audits performed by the QA organization. The SRC Charter requires a minimum of quarterly reviews of the results of the audits performed. As a matter of practice, the audit subcommittee generally has review meetings scheduled concurrent with the monthly meetings of the full SRC. These subcommittee meetings include a review of the results of .all audits performed since the last subcommittee meeting. Significant issues raised in these audits are brought to the attention of the full SRC.

In addition to reviewf ug the individual audits and their findings, the subeqe%ctre reviews the schedule of audits as prepared by the Le*' :1oas QA Group to assure that it is in --

conformance 2v1 .hr :equirements of the Technical Specificati<a4 A:,3 f. ensure that audits are being conducted on a timely basxs in auctedance with that schedule.

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v Because the SRC is concerned with an overview of plant operation, and identification and review of significant safety .

issues, the SRC review of the operational QA audits serves to provide an additional review of root cause, generic

( implications, and safety significance of the findings in those

@ audits. In addition, the SRC receives regular reports by the Corporate Quality Assurance Manager of significant issues and

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occurrences in the QA area. The combination of an overview of the QA program and the QA audit findings provides an opportunity to assess the quality of the audits in determining and evaluating QA issues at a management level.

C i 2. Yearly Management Audits of the QA Program Audits of the Quality Assurance Program are conducted as s specified in the QA Manual, Chapter 18.7, and in the FSAR, g Section 17.2. These audits are currently scheduled in g accordance with QA procedure QASP 18.12.

F Management audits are conducted by an independent audit team from the Middle South Services Quality Assurance group. Members of the audic team are qualified to appropriate standards. The

review topics cover all activities associated with the administration and execution of LP&L's QA Program. Findings are reported to the Senior Vice-President level and assigned to the i appropriate LP&L QA managers for corrective action. Findings

- are tracked using approved procedures and forms. Audit findings

are reviewed for underlying causes to determine corrective

action to prevant recurrence. Those deficiencies requiring long term action to correct, or which have the potential for

( recurrence, are reinspected in follow-on management audits to

determine the effectiveness in addressing identified problems.

s It is anticipated that the yearly management audit of the QA Program will be an effective management tool in assessing and

maintaining the adequacy and effectiveness of the operations phase QA Program,

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3. QA Trending Program Quarterly Reports

! The Operations QA Group administers a QA Trending Program

[ intended to identify adverse programmatic quality trends and j initiate corrective action. While other mechanisms exist to j identify and correct individual quality concerns, the QA 1 Trending Program will allow management a tool to identify I underlying " common mode" sources of quality deficiencies. The QA h Trending Program is described in detail in Section II.B.2.a.

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Trend analysis reports will be issued quarterly by the Corporate QA Manager to the Safety Review Committee and the Senior Vice .

President Nuclear Operations. It is expected that the QA Trending Program will prove a valuable senior management tool for assessing and controlling the level of quality at Waterford 3.

4. Quality Assurance Program Status Summaries Summaries of QA Program activities at Waterford 3 are provided to the Senior Vice President Nuclear' Operations on a weekly and monthly basis, a) Weekly Report - provides a status as of the last day of the week reviewed for various QA Program subjects of interest which include Audits & Reviews, NRC Site Activities, and QA Training. These reports are posted in all QA office locations.

b) Monthly Report - presented to the Chief Executive Officer

, and Senior Vice President Nuclear Operations during the monthly Program Review meeting. It provides a summary of site-related QA activities similar to the weekly report and includes statistical studies where applicable.

5. Plant Operations Review Committee The function of the Plant Operaticas Review Committee (PORC) is to advise the Plant Manager on all matters related to nuclear safety. In fulfilling this function the PORC reviews, among others, plant procedures that affect the public health and safety, proposed hardware modifications that affect nuclear safety and all reportable events. The PORC provides the Plant Manager, prior to implementation, with written recommendations and 10CFR50.59 safety evaluations with respect to the acceptability of procedural and hardware changes. The minutes of each PORC meeting, documenting the results of all PORC activities performed under the provisions of the Technical Specifications, are provided to the Plant Manager, Senior Vice President Nuclear Operations, and the Safety Review Committee.

6. Quality Inspection Activities Status Reports The Plant Quality Department will provide quarterly reports to the Plant Manager-Nuclear. Included in the reporting is an analysis of quality trends with respect to deficiencies identified during processing of Discrepancy Notices, Quality Notices, and Plant Quality Department reviews / inspections of CIWAs, procedures and procurement documents. Reporting in this area has recently commenced. The frequency, format, and categories reported in the Quality Inspection Activities Status Reports are expected to change to fulfill the needs of the Plant .

Manager in detecting adverse trends in quality related activities on site.

7. Licensee Event Reports LP&L has established a permanent onsite Event Evaluation Committee (EEC) for the purpose of coordinating the evaluation, reporting and closure of corrective actions associated with i reportable events described in 10CFR50.73. The EEC is responsible to the Plant Operations Review Committee (PORC) and the Plant Manager.

Any individual identifying a reactor trip, transient, safety L related equipment failure or malfunction, radiological event, l -security event, violation of a technical specification, or other

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events deemed to be potentially reportable, are responsible for initiating a potential reportable event (PRE) report. Following any necessary innaediate corrective actions and/or modifications, the EEC ensures that a prompt, thorough PRE investigation is

conducted. During the investigation, the cause of the event is

(_ identified and corrective action initiated to prevent recurrence.

i Generally, corrective action is documented and tracked via one of l the deficiency identification mechanisms discussed in Section II.B.1.a-e. In addition to the standard closure verification processes, the EEC independently tracks and confirms adequacy of corrective action.

The EEC provides the PORC with a report of the completed i investigation and recommendations. Following PORC review the Plant Manager is responsible for approving disposition of PRES as Licensee Event Reports for transmittal to the NRC.

8. Availability Imprcvement Program Reports The Availability Improvement Program (AIP) is currently under development by LP&L for implementation during the operations L phase at Waterford 3. Quality related problems, as described L later in this submittal, will be periodically reported to senior management. Whereas the QA Trending Program will provide management input as to adverse programmatic trends, the AIP will provide adverse trend information on the system / hardware level.

9. Independent Safety Engineering Group I.

I~ One of the functions of the Independent Safety Engineering Group (ISEG) is to prepara and conduct independent reviews of plant activities which may result in recommendations to plant staff and corporate management. These recommendations include corrective actions such as procedure revisions, equipment modifications and additional training necessary for improving overall quality assurance and plant safety.- Evaluations of plant operations, maintenance and modification are documented through ISEG reports.

, These reports, as well as any action item resulting from them are l logged by the ISEG group for purposes of tracking and resolution.

To keep management appraised of ISEG activities, an ISEG Monthly Summary is provided to the Senior Vice President Nuclear '

Operations and the Engineering and Nuclear Safety Manager listing evaluations performed that month and areas of ongoing review.

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10. Operations Assessment and Information Dissemination Group The Operations Assessment and Information Dissemination Group (OA&ID) is responsible to the Nuclear Safety Supervisor for screening, evaluating, and disseminating operational experience information. A significant management overvisw function that the OA&ID group will provide is the detailed evaluation of selected LP&L Licensee Event Reports (LERs). This evaluation will explore generic implications or special aspects of the event'which are outside the scope of normal LER evaluation and review. Periodic status reports will be provided to management.

11. Quality Team The LP&L Quality Team offers concerned individuals the opportunity to voice quality concerns on a confidential basis.

Reporting directly to the Senior Vice President Nuclear Operations, the Quality Team has been empowered with the authority to conduct investigations of any quality concerns brought to their attention; investigate instances of intimidation and harassment of individuals providing information to the Quality Team; and maintain strict independence and confidentiality. Following preparatory work the Quality Team was staffed and began full operation at the beginning of August, 1984.

The Team acquires quality concern information through the following methods:

a. Local and toll free hotline telephones are established to receive quality concern calls. The numbers are published widely to project personnel. Quality Team personnel man the phones during working hours, while calls are recorded at other times.

b. All personnel terminating employment from Waterford 3 exit through Quality Team headquarters. Personnel are afforded the opportunity to express quality concerns on a confidential basis. Any individuals who terminate employment off site or during other than working hours are sent a letter requesting any quality concerns they may have.

c. All Waterford 3 personnel can " walk in" the Quality Team headquarters at any time to discuss quality concerns.

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d. Concerns received by the Quality Team from sources external to Waterford 3 are documented and processed in the same manner as internal concerns.

, e. The Quality Team is re-evaluating all interviews conducted l prior to the present Team configuration (see NRC Concern

1. 16). ..

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Regardless of how the quality concern was identified, each is addressed in the same manner. An initial review is conducted ~

for reportability and safety significance requiring immediate corrective action. An Investigative Plan, intended to resolve each concern identified, is then developed and a Quality Team investigator assigned for completion. Once the investigative actions are completed and the concern is resolved all documentation is retained as an auditable file. The specific procedural steps are contained in QASP 19.11. " Quality Team Operating Procedure".

Substantiated quality concerns are documented for corrective action and verification on a Quality Team Deficiency Report (QTDR). The QTDR is very similar in form and handling to the Corrective Action Report (CAR) discussed in Section II.B.1.d.

The Quality Team reviews the results of implementing the QTDR findings and, where the corrective action is unsatisfactory and/or attempts at resolution have been unacceptable, the Quality Team notifies the Senior Vice President Nuclear Operations by letter requesting resolution and action (s) to prevent recurrence. Final reports for all concerns are directed to the Senior Vice President Nuclear Operations with copies to appropriate senior managers.

The Qualit r Team is committed to investigate concerns in a manner that focuses on determining root cause and complete implementation of corrective action. To support root cause determination the Quality Team maintains a trending program categorized by type of quality concern (e.g. unqualified personnel, inadequate training) and means of identification (e.g. hotline, " walk-in"). The basic elements of the trending program center around data retrievability and sorting to suit management needs. The key attributes are:

a. Concern categorization and coding

b. Statistical data gathering-

, c. Evaluation and analysis.

I The Senior Vice President Nuclear Operations, and other j- appropriate senior management, are provided with timely Quality l Team information to assist in their assessment of the status of l the QA Program. -The Quality Team transmits, among others, the l following reports:

a. Weekly Status Report of the Quality Team Program

. Activities

b. Quality Team Monthly Status Report

c. Quality Team Deficiency Trends Status Report (weekly) y ee t

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. I B. Quality Deficiency Identification and Resolution -

In maintaining and improving quality a comprehensive program must exist to identify and correct quality deficiencies. Two components are important for successful implementation of such a program.

First, sufficient means and opportunity should be available to identify and correct individual quality concerns as they occur.

Secondly, a capability should exist to assess the identified

. deficiencies as a whole to determine whether they are isolated occurrences or due to underlying common causes. The LP&L QA Program incorporates provisions for both components of quality deficiency identification.

1. Isolated Quality Deficiencies LPEL employs a hierarchical system for identification of individual quality deficiencies. At the first level of the hierarchy it is intended that adverse quality conditions will be identified by plant staff using CIWAs (Condition Identification and Work Authorization), DNs (Discrepancy Notices) and QNs (Quality Notices). The second level of detection includes CARS (Corrective Action Request) and AFRs (Audit Finding Reports) issued by the Operations QA Group during monitoring and audits.

Finally, at the third level are NRC Inspection Reports.

Upon identification of the quality problem, specific action is necessary for effective resolution: 1) cause is identified either explicitly or _ as part of the trending program, 2) appropriate corrective action is implemented, 3) a means of tracking the deficiency and corrective action (s) to completion is available, and 4) verification of completion and effectiveness of corrective action is documented. These steps are included for the deficiency identification mechanisms at Waterford 3 and are described in the discussions which follow,

a. CIWAs PURPOSE: The Condition Identification and Work Authorization (CIWA) is the primary vehicle through which abnormal plant conditions are identified, evaluated and corrected,' as well as the means for taplementing routine maintenance.

ORIGINATION: If, during the course of inspection, testing or operacica, a condition adverse to quality is identified by any Watarford 3 personnel, it is required that a CIWA be generated. Routine maintenance must also be performed via a CIWA.

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CORRECTIVE ACTION IMPLEMENTATION: Except in cases requiring immediate attention, corrective maintenance may not commence ~

without a processed CIWA in accordance with UNT-5-002. Any maintenance or adverse quality condition involving the basic power plant is forwarded to the Control Room Supervisor (CRS)/Shif t Supervisor (SS) for review. The CIWA is then forwarded to Planning and Scheduling Department (P&S) for evaluation, dispositioning and work planning. CIWAs.are evaluated as nonconformances when the adverse quality condition is determined to be a departure from specified requirements and, (1) is not the result of normal wear or, (2) is not a secondary effect due to failure of another component, or (3) is not identified as a routine part of the work process and will be corrected as a continuing part of the work process, or (4) is dispositioned as " repair" or "use-es-is", or (5) is a suspected generic problem. If the CIWA is dispositioned as " repair" or "use-as-is", it must obtain concurrence from Plant Engineering. Plant Engineering performs a technical evaluation in such cases (including a Safety Evaluation, if necessary) to determine cause and corrective action and documents the results on the CIWA. If a design change is necessary, a Station Modification Request number is entered on the CIWA. When the CIWA has been dispositioned, a copy is forwarded to o On-Site Licensing for a 10CFR21 evaluation.

The CIWA is then processed as a work package by the appropriate discipline. The CIWA work package is reviewed and approved prior to commencement of work by the responsible Maintenance Supervisor and Plant Quality Group

, (for quality related work packages) to ensure inclusion of accurate and complete work instructions and/or inspection

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! Hold Points. Subsequent changes which change the scope of l

work or acceptance criteria are reviewed by the same review i organizations.

Upon completion of work, the responsible department Supervisor reviews the work package-for completeness and forwards the CIWA work package to P&S for closure on the MIS (Master Tracking System). The MTS identifies all archived and active CIWAs at the plant site. Tight administrative controls are instituted to assure proper input and extraction of data to/from the MTS.

CORRECTIVE ACTION VERIFICATION: Post closure review by the Plant Quality Group and Plant Engineering consists of an overall review of the adeq"acy of the CIWA and corrective action. All CIWAs identified as Non-Conformance are periodically analyzed by Operations QA for adverse quality l trends. The Nuclear Safety Section of the Project Management Department also provides an independent review of ~

non-conformances, dispositions, and close-outs.

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b. DNs PURPOSE: The Discrepancy Notice (DN) is the mechanism -

through which discrepancies are identified during receipt inspections of quality related parts, material, and components by LP&L Plant Quality personnel at Waterford 3.

ORIGINATION: Upon receipt of quality related items, Stores personnel notify the Plant Quality Group and initiate a Material Receipt Inspection Report. For those items specified in the procurement package as requiring tailored or Special Receipt Instructions, a "Special Receipt Instruction Sheet" will be initiated by Plant Quality personnel. The inspector examines incoming materials in accordance with approved inspection instructions. In the event a discrepancy is identified during the inspection, a DN is issued by Plant Quality which maintains a log and status of all DNs. The DN is also forwarded to Licensing for 10CFR21 evaluation.

CORRECTIVE ACTION IMPLEMENTATION: A " hold tag" is attached to the discrepant item (s) inspected which is then placed in a segregated area. A Material Review Board (MRB) exists to ensure proper disposition of discrepant material.

Representatives to the MR3, which is chaired by the Plant Quality Manager, include personnel from Maintenance, Plant Engineering and Purchasing. Upon completion of review and concurrence with the final disposition, members of the MR3 sign and date the DN. If the discrepancy can be corrected after installation, the item may be released for installation on a " Conditional Release" (CR) basis subsequent to approval of the " Request for Conditional Release" (RCR). Once the RCR is approved and granted, the CR is sequentially numbered and logged in the CR Log and stated.as such on the CR cag and the RCR. The " hold tag" will be removed from the item in exchange for a "CR tag".

The original RCR stays with the DN and a copy is attached to the CIWA with special instructions (limitations) for installation. Conditionally released items may not be placed in-service until the DN is satisfactorily closed.

Closure of the CR is a pre-condition for closure of the DN.

In those cases where a design change was nscessary to close the CR, a Plant Engineering representative has joint approval responsibility.

CORRECTIVE ACTION VERIFICATION: The Plant Quality Manager is ultimately responsible for approval of DNs through inspection / reinspection, as applicable. DNs are periodically analyzed by the Operations QA Group for quality trends. The Nuclear Safety Section of the Project Management Department will also provide an independent review of non-conformances (DNs), dispositions, and -

close-outs.

c. QNs

. PURPOSE: Conditions adverse to quality which are due to a lack of, or a breakdown in, administrative controls are documented with a Quality Notice (QN). This document identifies non-conformances indicating a breakdown or I substantial departure from required procedures or instructions to the extent that a loss of control is evident.

ORIGINATION: Any Waterford 3 employee may initiate a QN and request a sequential number from Plant Quality who maintains the log and status of each QN. Within 30 days of the identification of a QN, the responsible department is required to report the actions taken or proposed to cover the following:

a)- the cause of the condition,

-b) correction of the conditions identified, c) action to prevent recurrence, and d) schedule of implementation.

CORRECTIVE ACTION VERIFICATION: The Plant Quality Group is responsible for verification of corrective actions committed to in the 30-day response supplied by the affected discipline (s). The Licensing Group reviews QNs for reportability under 10CFR21. QNs are periodically analyzed by che Operations QA Group for quality trends. The Onsite Safety Review Subgroup of the Project Management Department provides an independent review of non-conformances, dispositions and close-outs.

d. CARS PURPOSE: The purpose of a Corrective Action Request (CAR) is to provide a mechanism through which the Operations QA Group can document deficiencies based on monitcring of plant activities or conditions, and present such findings to the affected Manager for a timely and effective resolution of the concern.

ORIGINATION: A CAR originates as the result of monitoring or observation of a quality affecting activity or condition which could be detrimental to the safe operation of the plant and/or safety of personnel. QA personnel assess the cause and significance of the deficiency to determine if an immediate corrective action is required. Where such a determination is made, a "Stop Work Order" may be initiated, or other steps taken for immediate implementation. The CAR includes a description of the identified deficiency, and a requirement that corrective action, underlying cause and action to preclude recurrence be documented by the responding organization. -

CORRECTIVE ACTION DiPLEMENTATION: The delivery date of the I CAR to the affected organization is the start of the 30-day- -

period during which the cognizant group must resolve the deficiency, or define steps to be taken to effect resolution and provide a schedule for completion.

CORRECTIVE ACTION VERIFICATION: If the resolution and corrective action are considered acceptable, the QA Representative indicates so on the CAR and recosamends approval and closecut of the CAR. The original CAR is given t to the applicable QA Supervisor for final approval and filing. If the resolution and corrective action are not considered applicable, the cognizant Group Head will be so informed and a schedule arranged for satisfactory disposition. The action taken will be filed in the Open CAR File. 'If corrective action and the schedule for resolution are acceptable, but such action has not yet been taken, the QA Representative may accept the proposed resolution on the original CAR and maintain it in the Open CAR File. After satisfactory resolution and closecut,.as attested to by the

. applicable QA Supervisor's signature, the original CAR will i be maintained.

e. AFRs PURPOSE: The Audit Finding Report (AFR) is the Operations ,

QA mechanism for documenting deficiencies identified during  !

audits of organizations performing quality related ,

activities at Waterford 3. These AFRs are then forwarded to appropriate levels of management.

ORIGINATION: An audit is structured around a checklist prepared by the auditor and concurred with by the supervisor. The checklist is used during the audit to compare the audited organization's mode of operation against procedures, standards and other documents which govern its domain of operation.

CORRECTIVE ACTION IMPLEMENTATION: The audited organization is required to complete the following actions upon receipt of the audit report:

a) Review and investigate the condition described in each audit-finding, I b) Schedule appropriate immediate corrective action to correct the deficiency and to prevent recurrence, and c) Respond to all findings within (30) days after acknowledging the audit finding. The response must clearly state the corrective action implemented and/or the scheduled date targeted for the completion.

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' CORRECTIVE ACTION VERIFICATION: The QA Audit Supervisor -

l assures that corrective action is being accomplished in a -

timely manner by maintaining a tracking system of all -

unresolved items. The Lead Auditor confirms through -

g personal observation or verification, that corrective action .g is accomplished as scheduled. The verification review also  ;

assures that the corrective action is adequately identified 1

' and implemented for each finding, including considerations i

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, a) Similar conditions

( b) Corrections as to cause

_ c) Software aspects ,

Hardware aspects A d) e) Schedule i

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f) Completeness 3

E g f. NRC Inspection Reports  :

ORIGINATION: These reports are transmitted to LP&L by the 2 NRC Region IV office. A summary of NRC inspected areas of kh operations, maintenance, administrative controls, and  ;;

license activities are contained therein and may identify r=

open items, unresolved items, and/or Violations / Deviations.

E CORRECTIVE ACTION IMPLEMENTATION: The Nuclear Services A k Manager and the Nuclear Support and Licensing Manager are 22 responsible for the coordination of reviews and preparation h

of responses to NRC Inspection Reports. This task is }

{ performed by the Onsite Licensing Unit of the Licensing ][

Section. 5 -

The specific task is performed by the Licensing Engineer _

(LE) through the development of a Licensing Action Plan s

(LAP). This plan may necessitate input from other J t departments and is transmitted to them through the use of a

Licensing Information Request (LIR) form. The LIR is --

responded to and cortified by the respective departments :l via the Task Review And Certification (TRAC) form. The response is reviewed by the LE for consistency with the E g LAP, LP&L commitments, completeness and the FSAR. Inspection $

F Report responses are reviewed by the Plant Manager, 4 Licensing Manager, and the Nuclear Support and Licensing  ;;

Manager prior to transmittal to the NRC.

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CORRECTIVE ACTION VERIFICATION: This is accomplished jl through receipt of signed off TRAC forms from responsible 4 departments as well as a confirmatory review by the LE.

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[ LIRs are tracked from inception through completion by the LE i via the computerized Licensing Comnitment Tracking System. 9

- Responses to the NRC pertaining to Inspection Reports and 4 10CFR21 are further validated by the Operations QA group via j

_ QASP 19.13 prior co transmittal to the NRC.. --

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2. Generic Quality Deficiencies

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There may be cases where correcting individual quality deficiencies is insufficient to assure overall quality. Such

' cases occur where there are underlying causes common to more than one deficiency. Therefore, LP&L has established programs to provide timely identification and correction for such generic deficiencies. The following three sections will discuss the QA Trending Program, the Availability Improvement Program, and Hardware Trending.

a. QA Trending Program Recognizing the need for early identification and correction of generic quality problems the Operations QA Group initiated a Quality Trending Program in May, 1984 with the publication of procedure QASP 16.1.

Data Reduction The Operations QA Group collects and analyzes quality data for the purpose of identifying adverse trends. Responsible organizations initiate corrective action for Waterford 3 programmatic deficiencies.

Documents to be incorporated into the trend analysis include, but are not limited to:

CIWAa (Condition Identification and Work

• Authorizations)

QNs (Quality Notices)

DNs (Discrepancy Notices)

AFRs (Audit Finding Reports)

CARS (Corrective Action Reports)

NRC Inspection Reports i

e For each document the assigned QA representative will L

review and identify any deficiency in the effectiveness of the QA Program. The identified deficiency will then be

, categorized according to the following scheme:

Equipment Control Training and Qualification

Design Control Maintenance and Modification Control Procedure Adherence i Plant Records Management

! Control of Purchased Materials and Services Identification and Control of Materials, Parts and l Components b

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Control of Special Processes Inspection _

Test Control Control of Measurement and Test Equipment Surveillance Testing and Inspection Schedule Plant Security Corrective Action As experience is gained in the trending program, categories will be added and deleted as necessary.

Trend Analysis The Operations QA representative will evaluate the trend reports to determine if a possible adverse trend exists based on the following:

a. A significant increase in the number of occurrences of a specific adverse condition category is noted as compared to the previous reporting period,

b. A continuing and significant rise in the overall trend of adverse conditions for a responsible organization over the last three months is noted.

Further investigation to confirm possible adverse trends may be indicated and accomplished by monitoring the specific activity or program in question.

Corrective Action Corrective action will generally be in the form of issuance of a Corrective Action Request (CAR) to the Manager of the responsible organization. Future trending reports will be used (in addition to standard QA confirmatory actions) to verify the adequacy of the corrective actions.

Reporting The trend analysis report will be issued on a quarterly basis in the form of. graphs and sununary reports (including l

summaries of CARS and corrective actions) to the Safety Review Committee and to the Senior Vice President Nuclear Operations through the Corporate QA Manager. The reports will be formatted in a manner to facilitate the l identification of trends in programmatic deficiencies.

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4 Management Overview i The trending program provides a valuable senior management tool for assessing the effectiveness of the quality program at Waterford 3. -Trends whose root cause may lie in the areas of staffing, corporate philosophy, management deficiencies, and the like, can most appropriately be resolved through the Senior Vice President Nuclear Operations following' his quarterly review of the trending reports.  ;

Current Status The trending program has been recently initiated at Waterford 3 with the first quarterly report to the Senior Vice President issued in October,1984.

b. Availability Improvement Program The Availability Improvement Program (AIP) for Waterford 3 will be implemented to improve overall plant reliability.

In so doing, quality related problems will be identified to management and corrective action implemented on a system / component level. . While the QA Trending Program will identify generic programmatic deficiencies, it is expected that problems identified by the AIP v111 be predominately in the hardware area.

The AIP centers around a computerized model of the Waterford 3 plant. The plant will be divided into generic functions, which will be further subdivided into subfunctions, equipment systems, and, finally, equipment items. The model database will be regularly updated to L reflect actual plant' performance data, enabling the calculation of reliability / availability for any

' hierarchical level of the computer model. Availability goals will be set initially based upon industry performance of similar plants. As the AIP proceeds, and the database is extended, plant-specific availability goals will be utilized.

When an unusual characteristic affecting some measurement of availability is identified, or a problem is recommended for investigation, a Unit Availability Investigation (UAI) will be undertaken. The UAI will focus on a group, or individual piece, of hardware as appropriate. A root cause analysis will be performed to determine the reasons for

. abnormal performance. The analysis may make use of plant personnel interviews, vendor interviews, consultant interviews,. investigation of environmental conditions, special testing, etc.

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Upon determination of the root cause of the problem, corrective action will be implemented as necessary and tracked to completion. Verification of ef fectiveness of the corrective action will be evidenced through improved availability performance under the AIP.

. Periodic reports of the results of the AIP will be provided to Nuclear Operations management, including the Senior Vice-President Nuclear Operations. Such reports will

identify adverse availability trends, the root cause of i such trends, corrective action taken, and confirmation of effectiveness of the corrective action.

As with any trending program, an operational database is required prior to effective implementation of the AIP.

LP&L expects the AIP to be fully implemented within two years.

c. Hardware Trending l

l The purpose of the Maintenance History System (MHS) is to

, identify potential improvements in the preventive maintenance program, to suggest improvements to corrective maintenance procedures, to identify equipment requiring

, upgrade, and to provide a tool for assessing adequacy of spare part inventory levels. After completion of a plant modification, repair or maintenance, a MHS form is filled out on the affected component describing the nature of the work performed. The MHS form is attached to the CIWA before routing for closure review. These forms are used for data entry into the MHS computer system. The MHS data base is currently under extensive review to update and verify accuracy and adequacy of input data. This data base will provide a complete preventive and corrective maintenance 7

history of all plant system components. This will enable LP&L managers to detect equipment trends in systems under P their control. Once operating time is accumulated on plant systems the Plant Maintenance Superintendent will select key systems to review the frequency and scope of preventive maintenance for changes as necessary to improve system j operability.

Pump and valve testing performed under the requirements of the ASME Boiler and Pressure Vessel Code is another source of trending information. A list of Section XI tests performed on safety related equipment under this Code for which data must be recorded to identify failure trends has been established at Waterford 3. This 14.se includes such ,

equipment as the Emergency Diesel Generator, Charging Pump, Containment Spray Pump, Reactor Coolant System (RCS) Pumps, RCS Instrumentation, MSIVs and containment isolation boundary valves. This trend information will provida plant management with advance notice sufficient to take the -

necessary corrective actions to prevent failure of such equipment vital to nuclear safety.

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In programs of this magnitude it is inevitable that changes -

will be necessary. As LP&L gains more experience in quality trending, program refinements will be made to support the

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program purpose of identifying adverse quality trends. It is also important to note that the effectiveness of any trending program is a direct function of its database. The identification of trends requires a detailed previous history. By initiating the trending program at this time LP&L expects it to become a useful management tool going into commercial operation.

C. Staffing The organization, staffing levels and personnel qualifications for Waterford 3 are described in Chapter 13.1 of the FSAR. Staffing of key areas of plant operations and quality include:

Authorized Actual Level Staff Staffing Level as of 9/84 Plant Operations and Maintenance 211 -191 Plant Technical Services 96 92 Plant Training 31 28 Plant Quality 13 13 Quality Assurance 46 42 The operations phase QA organization is divided into two main groups -

Nuclear Operations QA and Engineering / System Development QA sach of which is further subdivided into 3 sections. QA staffing for the operations phase is detailed below:

d Authorized Staff Staffing Level Nuclear Operations QA Manager 1

- QA Audits 9

- QA Support 6

- QA Analysis 9

- Total 25 Engineering / System Development QA Manager 1

- Audit / Surveillance 5

- System Development 7

, Engineering / Procurement 4

- Total 17 QA Management 4 t ..

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D. Certification of Inspection Personnel _

Inspection personnel during the operations phase of Waterford 3 including those provided by contractors are certified in accordance with QI-10-001, " Qualifications of Inspection Personnel".

Certification for Level I, II and III qualifications is done in accordance with ANSI N45.2.6-1978, and Regulatory Guide 1.58 Rev. 1.

Prior to certification a background investigation must be satisfactorily completed verifying a candidate's education and employment experience. Recertification is performed every two years.

E. Quality Assurance Indoctrination and Training

1. Plant Staff Quality Related Training ,

An indoctrination and training program has been established for the Nuclear Operations Department personnel performing quality related activities. It is designed to ensure that personnel involved are knowledgeable in quality assurance procedures / requirements as well as the overall functional responsibilities in the plant, and have the necessary proficiency to implement the requirements. The scope, objective, and method of implementing the indoctrination and training program are documented in procedures developed by the Training Department. The Quality Assurance Training and Indoctrination Program requires that:

a) Personnel responsible for performing activities that affect quality are instructed on the purpose, scope, and implementation of quality related manuals, instructions, and procedures; b) Personnel performing activities that affect quality are trained and qualified in the principles, techniques, and requirements of the activity being performed; c) Proficiency and requalification of personnel performing activities requiring certification are maintained by retraining, re-examination, and/or racertification on a periodic basis; d) Proficiency tests be given to those personnel performing and verifying activities affecting quality, and acceptance criteria developed to determine if individuals are properly trained and qualified; e) Certificates of qualification clearly delineate (1) the specific functions personnel are qualified to perform and (2) the criteria used to qualify personnel in each function; and 4

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f) Documentation concerning training and qualification -

programs which describes the content, who attended, and resulta of tests as required by the training program are maintained.

2. Quality Assurance-Section Training QA Procedure QASP 2.10 directs the development, implementation and documentation of the QA Section training program to reasonably assure that LP&L QA personnel have sufficient knowledge and experience to perfcra assigned tasks at Waterford

3. Training is implemented throuth:

Completion of a QA required reading list; Formal classroom training (onsite and offsite) in specific topical and procedural areas to enable and enhance performance and effectiveness; Performance of on-the-job training assignments by individuals at their supervisor's discretion where formal courses cannot provide the level of training necessary for a particular quality related task; Special training where unique skills are needed for performance of specific functions such as monitoring of NDE, welding and fire protection; Periodic training such as the monthly QA Section training sessions or group sessions on an as-needed basis where changes, revisions or new requirements from LP&L QA Program documents, regulatory codes and standards are brought to r the attention of QA personnel. Lessons learned or l

corrective actionis as a result of quality deficiencies or undesirable programmatic trends identified at Waterford 3 and other nuclear generating facilities will be reviewed during these sessions.

The Quality Assurance Section Training Committee was forme,d on 12/16/83 to review the goals, objectives, effectiveness, and implementation of the training program for the Quality .usurance Section. It is composed of supervisory members from Engineering / Systems Development, Nuclear Operations, and Nuclear Construction QA Groups to act as a steering committee to provide management with an overview for evaluating the effectiveness and future direction of the QA Training Program.

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l An evaluation of the 1983 QA Training Program by this "ad hoc" '

group stressed three areas of concern for additional improvement:

presentation and preparation of training lessons, attendance, and attitude and participation during training. As part of an effort to remain innovative and improve the skills of QA personnel two new training formats emphasizing professional development and corporate awareness were introduced. Under professional development, college professors and outside consultants provide instruction in stress management, leadership, oral communication, technical writing, time management, problem solving and negotiating skills. To enhance corporate awareness, representatives .from various organizations within LP&L and the Middle South System will occasionally present their group's workscope to provide better understanding among QA personnel of company operations.

The success achieved by the Quality Assurance Section in meeting

, their training goals is evidenced in a Good Practica noted by INPO during a recent corporate assistance visit (December 1983).

l While evaluating senior corporate management attention and support of programs for developing experienced, trained, and qualified personnel required for the operation and support of Waterford 3. INPO stated in Good Practice 2.5A-1:

i "An excellent continuing professional training program has been developed for the Nuclear Operations Quality Assurance Group. This program is intended to enhance the inspecting, interviewing, and general management skills of QA personnel and has been well received by QA personnel."

3. Contractor Training i Contractors supplying quality related services to LP&L for which they conduct their own quality inspection and surveillance L functions, are responsible for training their inspection j personnel and documenting their qualifications under their own QA progress. These programs must meet or exceed the requirements of

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l LP&L's QA Program, including training, before such vendors can be placed on the Qualified Suppliers List and enter into contract agreements with LP&L. QA program assessments of QSL vendors are made through Annual Evaluations and Triennial Audits (refer to Section II.G.1). Additionally, whenever contract personnel are

r. performing quality related work onsite, implementation audits of vendor activities are conducted by Operations QA personnel l (refer to Section II.G.3).

i Contract personnel who perfora quality related work under LP&L's QA Program must be trained in accordance with LP&L Procedures.

LP&L managers directly supervising ..se personnel are

. responsible for ensuring they receive the proper QA tra.4 aing.

Contract personnel performing inspection and monitoring functions '

are periodically evaluated by LP&L. Evaluation documentation is retained in individual training files in LP&L Project Files.

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F. Audit / Review Programs

1. Nuclear Operations QA Audit / Monitoring Programs

a. Audit Program As part of its charter to assure that the QA Program at Waterford 3 is adequate and being effectively implemented, the Operations QA Group administers an audit program of on-site quality related activities.

The QA Audit Supervisor, within the Operations QA Group, '

maintains a yearly audit schedule. Audit subject and frequency are based upon 10CFR50 Appendix B, the LP&L QA

, Manual, Technical Specification 6.5.2.8, Regulatory Guide 1.33 Rev. 2-1978,' paragraph C.4, and Regulatory Guide 1.144. Rev.-1980, paragraph C.3. These documents establish minimum requirements which are generally exceeded. For instance, whereas the Technical Specifications require audits of Appendix B criteria to be conducted at least once per 24 months, such audits are presently scheduled on a yearly basis.

The annual audit schedule is updated every six months to incorporate any changes since the previously issued schedule. For example, when an unscheduled audit is performed it is added to the schedule as a record of the

, audit having been performed.

In revising the schedule, the QA Audit Supervisor considers

the need for redirection of auditing efforts in response to problems identified as a result of the audit program, regulatory inspection findings, Site QA Revievs Safety Review Committee direction, etc. Regularly scheduled audits are supplemented by scheduling additional audits for reasons

,F such as:

a. Significant changes are made in functional areas of the QA Program such as significant reorganization or

procedure revisions;

b. A systematic, independent assessment of program effectiveness is considered necessary; or

c. Verification of implementation of required corrective action is necessary.

The Corrective Action Audit, which is performed twice i annually, includes items of noncompliance previously identified to the NRC between the two preceding Corrective Action Audits. Those items are also included within the audit ' checklist of the Corrective Action Audit conducted ..

one year later to ensure that the corrective action for

i. those items remains in compliance with commitments made to i the NRC.

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The overall scheduling and audit of unit activities is -

performed under the management cognizance of the Safety Review Committee (SRC) as previously described in Section II.A.L. In addition to periodic reports of audit activities from the SRC, the Senior Vice President Nuclear Operations receives the audit reports within 30 days of completion of the audit by Operations QA.

The audit process is described in detail in QA Procedure QASP 18.10 " Conduct of On-Site Internal and External Nuclear Operations Quality Assurance Audits".

b. Monitoring Program Monitoring of plant activities is carried out by the Operations QA Group in order to provide additional observation of various aspects of plant quality related activities.

Monitoring may be initiated for a variety of reasons. For example, the QA Trending Program may identify an adverse quality trend; audit personnel may note a potential quality problem area outside the scope of their audit; or, during the course of review of CIWAs or procurement documents, QA personnel may identify areas of questionable quality.

Deficiencies identified during monitoring activities are documented through the use of a Corrective Action Report (CAR). The origination, tracking and verification of corrective actions for CARS has been previously described in Section II.B.L.d. The overall monitoring process is covered in QA Procedure QASP 18.9 " Conduct of Nuclear Operations Quality Assurance Monitoring of Quality Activities".

2. Plant Quality Group Review and Verification Process The Plant Quality Group has responsibility to review and verify implementation of the quality requirements related to Waterford 3 on-site activities.

a. Plant Quality Inspection Quality inspections are performed at designated inspection Hold Points. Quality and Technical Reviews are performed by the responsible department head and Plant Quality Group on all quality related maintenance, modification and testing procedures and work p.ackages. This review ensures that the procedure or work package addresses applicabia NRC requirements Technical Specifications, applicable quality requirements and couaitments made to the NRC. As a result of these reviews, Hold Points are designated in the "

procedure / work package, during which a Plant Quality Inspector:

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1) Ensures necessary test and inspection equipment is _

properly calibrated before use,

2) Checks that the procedure is applicable to the work being performed.

3) Performs inspection in accordance with the work procedure,

4) Reinspects items found unacceptable during previous inspection, t

5) Documents the results on the work instructions, attached data sheets or Quality Inspection Report, and

6) Writes or directs a CIWA be written to correct an unacceptable condition unless the item can be reworked.

i Completed work packages /CIWAs are reviewed by the Plant Quality Group to ensure that inspections / verifications were properly performed and documented. In the unlikely case that an inspection required by an established Hold Point is missed or not documented, then. a Quality Notice (QN) is initiated. The work package will remain incomplete until the QN is verified as closed by rescheduling and completing the inspection, or producing valid documentation of the

! inspection, or obtaining approval to delete the Hold Point.

1. b. Hold Points Inspection Hold Points are required whenever there is a reasonah Le possibility that an undetected deviation could occur that affects plant safety. In determining probability for an undetected deviation, post-maintenance testibility, complexity, criticality, and uniqueness of the work being performed are considered. Information concerning Inspection Hold Points is obtained from related design drawings, specifications, codes, standards and controlled documents.

i The following are exsaples of activities which would normally require Inspection Hold Points:

1) Activities which could affect the integrity of the ,

reactor coolant pressure boundary of safety / quality related components (e.g., installation and/or setting of pipe or component hangers; bolt-up and torquing of closure studs; installation of locking devices; welding, including fit-up and welding / welder qualifications; heat treatment; and hydrostatic testing.) ,

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2) Nondestructive examination.

3) Cleanliness and foreign material exclusion, including cleanliness of components with tight clearance, such as control rod drive mechanism internals and major pump seals, and system or component closure following maintenance.

4) Characteristics of electrical components or circuits such as cable routing, splicing, lugging and potting, tightness of connections, and penetrations and fire stop installation which cannot be verified by post-maintenance and/or modification testing.

5) Characteristics of materials or components, such as surface finish, hardness, dimensions, leveling, alignment, torque, and clearance when such characteristics are critical to safety and when they will not be verified La subsequent tests or inspections.

c. Quality Instructions Quality Instructions (QIs) are provided for those quality related activities of the Plant Quality organization outside of maintenance, modification and testing procedures / work packages that require quality inspection / review. Some of the key instructions are:

1) Quality Review of Procurement Documents - The Quality Reviewer (QR), as designated by the Plant Quality Manager, conducts a quality review of purchase and contract requisitions which include: Local Emergency Orders, Spara Parts Equivalency Reports, Major Changes, Major Exceptions and Transfer Requests. The QR verifies during his review dhat the procurement document:

a) Meets the guidelines of the Purchase Requisition Quality Review Guide, b) Has a review by the Requirements Engineer to ensure the technical requirements are included and meet or exceed previously imposed specifications, c) Contains applicable references, d) Contains a statement concerning vendor requirements,10CFR50 Appendix B requirements, QA Program requirements, 10CFR21 Reporting, Right of Access and Nonconformance Reporting, and c

e) Confirms that the recommended vendor is on the ~

Qualified Suppliers List.

Reviews which result in comments are documented on a Purchase Requisition Review Comments sheet and tracked on the Outstanding Plant Quality Review Comments Sheet until resolved.

2) Materials Receipt Inspecti'on - Quality related materials received on site are controlled through the use of a Materials Receipt Inspection Report (MRIR) initiated by Plant Stores personnel. A plant Quality Inspector will verify on the MRIR that:

a) Identification and markings are in accordance with codes, specifications, purchase orders and drawings, b) The manufacturer documented fabrication and testing requirements, c) Protective covers and seals are in place, d) Coatings and preservatives meet specifications, e) Dessicants are in place and unsaturated, f) No physical damage exists,

3) Cleanliness has been maintained, and h) Other checks including weld preparations, workmanship, insulation resistance checks and dimensional checks have been conducted as appropriate.

Items passing review are affixed with a RELEASE tag.

Discrepant items are identified with HOLD tags.

Discrepancies are documented by Discrepancy Notices which are logged and tracked by the Plant Quality Group until resolved or dispositioned by the Material Review Board (MRB) as described in Section II.B.I.b.

3) Material Storage Inspection - This instruction provides Quality Inspectors with detailed procedures for verifying proper classification, packing, storage, cleanliness and segregation of materials received.

4) Cleanliness Inspections - This instruction provides for cleanliness verification of materials, equipment and components as required by work package ~

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instructions.

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5) Housekeeping Inspections - This instruction provides -

for the use of Quality Inspection checklists to verify prescribed standards of cleanliness in various plant areas for the purposes of personnel safety, morale, contamination- ation control, fire prevention and 4

degradation of plant operability. Discrepancies are noted on the Quality Inspection Checklists and tracked and resolved through the Inspection 4 Comments / Resolution Sheet.

d. Plant Quality Surveillances In addition to Quality Inspections, Quality Surve111ances provide for observations of quality related activities.

These surveys are documented on Quality Surveillance Report

(QSR) forms. When deficiencies are noted during the Surveillance, a QN shall be written requiring corrective action. Plant Quality Surveillances provide sampling of a portion of station activities, whereas Quality Inspections provide for checks of specific quality affecting activities.

j e. Stop Work The Plant Manager or Plant Quality Manager may issue verbal stop work orders (SW0s) to halt unsatisfactory work and to

. control the processing, delivery, or installation of

nonconforming material at Waterford 3. A verbal SWO is followed up v1th a written SWO which is documented on an SWO form, and logged for tracking. Notification of the SWO is made to the Senior Vice President Nuclear Operations, r

Corporate QA Manager, Safety Review Committee, Control Room Supervisor, individual company involved, Plant Manager,

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applicable department supervisor, and the Plant Operations Review Committee. When the deficiency is corrected, or sufficient steps have been taken to ensure-that further i noncompliance will not occur, a Stop Work Order Release (SWOR) form is issued by the Plant Quality Manager to allov ,

. work to resume. A SWOR form notes the corrective action taken'and the reason for release.

G. Control of Contractor Quality Related Activities

1. Evaluation of Supplier's Quality Assurance Program Suppliers providing safety related material or services must be on the LP&L Qualified Suppliers List (QSL). Before a vendor can be placed on the QSL, that vendor must be evaluated for acceptability by the LP&L Engineering / Systems Development QA Group.

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q j An initial evaluation of a prospective contractor is performed by reviewing the contractor's: , ,

a. Current quality assurance program manual, procedures and records; b.

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, Capability to conduct quality activities as revealed _

through examination of the facilities for performing such work and ability of the supplier's personnel;

c. Past performance based on experience that LP&L and other users have gained using identical or similar products and services.

Based on results of the above evaluation process, a supplier is classified:

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a. Acceptable - no questions / concerns were raised during evaluation, or questions / concerns have either been resolved

' or have an insignificant impact on the item / service to be provided.

b. Unacceptable - the supplier's program doesn't meet

procurement document requirements, or is not adequately

'- implemented and review questions not satisfactorily

addressed / resolved.

c. Conditionally Acceptable - only certain portions of a supplier's program are acceptable and purchase activities are limited to restrictions as imposed by the Engineering / System Development QA Group and noted on the QSL and are to be reflected in procurement documents. Full acceptability will be based on satisfactory supplier resolution of questions / concerns.

Once a contractor is on the QSL, a documented evaluation of the supplier will be performed annually and kept in that vendor's

' file.

While an audit is not necessary for a satisfactory annual evaluation, an audit must be performed every three years for a

vendor to remain on the QSL.

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2. Conduct of Contractor Quality Assurance Audits t

a. Off-Site QA Audits The Engineering / Systems Development group is responsible for ensuring all QSL listed contractors' offsite activities are audited to requirements of 10CFR50 Appendix B and LP&L's QA Program. Either they themselves will audit these contractors, or a vendor audit group will be contracted ,

which has'been qualified to LP&L's QA Program to conduct i these audits. Audits will be conducted triennially per NRC Regulatory Guide 1.44.

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b. On Site Auditing and Monitoring of Contractors The Nuclear Operations Quality Assurance Manager directs -

audits of those organizations not witFin LP&L chat are performing quality-related services at Waterford 3. These type of contractor audits are designated as "On-Site External Audits" and are conducted as previously described in Section II.F.1.a.

Periodic monitoring of on-site contractor activities is done through the use of Monitoring Reports as assigned by the QA Analysis Supervisor under the Operations QA program previously described in Section II.F.1.b.

3. Deficiency Reporting by Contractors All vendor personnel performing on-site quality inspections of their company's work under LP&L's QA Progran are required to report deficiencies identified for inclusion on a CIWA. This includes deficiencies discovered outside the scope of work being

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performed. A CIWA, which documents a deficiency and its corrective action / rework, is approved and tracked by LP&L management as described in Section II.B.I.a. Corrective action verification is provided by post closure review of the CIWA by the Plant Quality Group.

H. Station Modification Program The purpose of the Station Modification program is to provide a j mechanism through which design modifications to Waterford 3 are controlled and tracked. The Station Modification Package serves as a comprehensive, stand alone design change document which has undergone the appropriate interdisciplinary reviews. The process assures that no changes are made to the plant structures, systems and components which may introduce an unreviewed safety question per the criteria delineated in 10CFR50.59.

Any individual with the concurrence of the department head may request a design modification. Reasons for the change could include enhancement of the plant structures, systems, or components as a result of engineering preference, regulatory requirements, licensing commitments, ALARA Human Engineering Design considerations, etc.

Upon management approval of the request, a Station Modification Package (SNP) is assembled and receives appropriate interdisciplinary review. During the course of the design and review process checklists are used to ensure that, among other things, generic criteria such as separation, failure effects, fire protection, etc., are taken into account. The LP&L Quality Assurance Progrsa requires that documentation' appropriate to satisfy 10CFR50 Appendix B will be generated and retained.

t Typical SMP Contents include:

1. Suanary Functional Description

2. List of Attachments a) Purchase Orders / Requisitions b) Recommended Spare Parts c) New or Revised Drawings / Description Documents / Tech Manuals / Equipment Specification / System Description d) Vendor Information e) Design Calculations / Analyses f) Work Procedures

3. List of References

4. Bill of Material

5. Installation Instructions

6. Examinations (e.g. NDE requirements, PSI /ISI surveillance requirements)

7. Testing (including acceptance criteria)

8. Nuclear Safety Evaluation checklist (10CTR50.59 review)

Modification is performed via the Condition Identification and Work Authorization (CIWA) process described in Section II.B.1.a. Detailed Construction Packages (DCPs) are preparid for work activities.

Pertinent design and reference information (e.g. isometric drawings, engineering instructions, code type testing requirements, installation procedures) is included in the DCP as well as instructions for implementation documentation. Acceptance criteria / tests / checks are developed and included as part of the DCP prior to implementation.

With the exception of minor changes, alterations (or field changes) to the DCP may not be made without approval of a revision to the SNP.

For minor changes, the Action Engineer may authorize a Detailed Construction Package Change (DCPC) in which case a detailed description of dhe change is documented prior to Laplementation of the change. All DCPC documentation is retained as part of the work package and subject to post-implementation review.

Verification of implementation is first performed by.the Station Coordinator and the Action Engineer who had the responsibility for developing the package. The Action Engineer assures that all work was accomplished according to the SMP and that acceptance criteria are met. Control Room controlled drawings are redlined to reflect .

the change. The Action Engineer then initiates a Modification l Project Closmout Review form, and forwards it to the SH Coordinator

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i 'd (SMC). The SMC forwards a Work Completion Notice to all af fected -

disciplines so that appropriate documents are revised. Completed Document Update Forms are returned to the SMC to certify that all affected drawings, procedures, programs, and/or training plans have been revised and approved. A'. this time the CIWA is closed and the SM Closeout Review form initiated and sent to the Systems Engineering Department Head for review and approval of the Modification Project Closure Review form. See Section II.I.3 for quality review and storage of SMPs.

l I. Records

1. Project Files Project Files is the focal point for storage and maintenance'of uncontrolled records and documents. The filing system used is a computerized document retrieval system. Completed records forwarded to Project Files are indexed on the computer, then microfilmed and stored by Film Access Number. This number indicates the roll and frame number of a particular document or its hard copy location. Records are thus effectively filed under document number, record type, date, title, vendor, subject, equipment number, etc. , allowing a user to retrieve documents in a timely manner.

Records processed by Project Files are received under a standard transmittal form which lists the contents forwarded. The records transmitted are inspected to ensure that all of the

! records on the transmittal form are present, complete, and validated. .If the records are complete and agree with the

. transmittal form, then the form is signed by the package reviewer, filed, and a copy sent to the originator.

Unlimited access to Project Files is granted only to personnel

-assigned to the Project Files Group. This minimizes the possibility of lost / misplaced records by personnel who have not been indoctrinated in the proper procedures for control of documents. The Project Files Supervisor may authori:e temporary access when individual requirements cannot be handled by the Project Flies personnel. QA records may be accessed by request for work / review, but may only be reviewed in designated controlled are,as.

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2. -Document Control Document Control is the organization responsible for processing controlled documents such as approved drawings, specifications, technical manuals, FSARs, SMPs and some procedures. This process includes receiving, recording, distributing, updating and retrieval of those documents affecting quality to ensure only the latest applicable revision is used for operation and maintenance at Waterford 3. Controlled issue is maintained by the use of transmittal forms which must be signed and returned  !

by assigned copy holders on established distribution lists.

Direct access to files maintained by the Document Control is l

limited to group personnel and their supervisors.

3. Records Quality Review Quality-related Station Modification Packages (SMPs) are reviewed by the Operations QA group before final closura and transmittal to Project Files. A Quality Reviewer (QR) completes a QA Review Checklist on the SMP to ensure that records establishing proper review and other necessary records are retained. The QR review scope ensures that documents required

.by the SMP index and controlling procedures are included, proper j_ review and approval is indicated on the records, applicable i codes and quality standards are identified, test and inspection requirements are documented, and safety evaluation and design verification is performed.

Comments from this review are tracked and closed out on a standard Procedura Review Comments sheet, ensuring completeness 1

of the SMP. The Checklist, comments sheet and any additional records generated by the QR's review are filed for storage.

Similarly, quality related documents generated by the Plant Quality and' Quality Assurance groups in the performance of their duties are reviewed and retained in Project Files. These records include audit reports, nonconformance reports, receipt inspection reports, CIWAs, QNs, DNs, Stop Work Orders, QC surveillances, QC Inspector certification, hold tags, conditional release tags, various NDE documents, calibration records, and NDE personnel qualification and training records.

l l (NOTE: Some aspects of Records Quality Review, particularly records storage, are not yet fully implemented due to their recent adoption by Waterford 3.)

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4. Status During the construction phase, records management was primarily handled by the architect / engineer. As a result, although current records are handled and processed as described above, there remains a backlog of construction phase records to process through the LP&L Records System. Additionally, to assure l continued high quality in records storage and retrieval, LP&L 1

. management is evaluating the current records management process l for Waterford 3 to identify any areas needing improvement. It 1s expected that appropriate recommendations of this evaluation I will be initiated by November 30, 1984, l l

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t LP&L SUPPLEMENT EXHIBIT 2 d

THE UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

'Before'the Atomic Safety and Licensing Appeal Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY, ) Docket No. 50-382 OL

)

(Waterford Steam Electric Station, )

Unit 3) )

. AFFIDAVIT OF KENNETH W. COOK j

The undersigned, being duly sworn, deposes.and says:

I My name is Kenneth W. Cook. My address is 142 Delorande Street, New Orleans, Louisiana 70174. I am Nuclear Support &

Licensing Manager for Louisiana Power & Light Company. In this position I am responsible for licensing activities for Wa-terford 3, interfacing with state and federal regulatory agen-cies and for providing technical support for the plant staff in

-the areas of Radiation. Control, Nuclear Engineering, Fuels Man-F agement, Chemistry and Radiochemistry. A copy of my profes-

. sional qualifications is attached.

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The Atomic Safety and Licensing Appeal Board Memorandum

-and Order (ALAB-801) of March 22, 1985 calls for additional information from the NRC staff and LP&L. The concerns that the s

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F Board asked the staff to address dealt principally with the basis for the staff's conclusion that, in light of QA allega-tions, Waterford 3 can be operated without undue risk to the public health and safety. In this statement, my intent is to cover the investigative efforts, extensive multi-level reviews performed, corrective actions taken, and further activities planned and in process which provide the assurance, required by LP&L Management, that Waterford 3 can indeed be operated safely.

LP&L undertook an extensive and comprehensive program to resolve all of the areas of concern identified by the special NRC Waterford 3 Task Force.b! The purposes of the program were to determine the accuracy of the concerns, to determine the corrective actions necessary or considered desirable, to per-form the corrective actions, to provide assurances to LP&L man-l agement that the issues were resolved and the plant is safe to i

operate, and to provide similar assurances to the NRC.

The program was closely managed by top-level LP&L person-nel. The LP&L Project Manager-Nuclear was assigned responsi-bility for management of the overall program. The Project i

1/ Letter to J. Cain (LP&L) from D. Eisenhut (NRC) (June 13, 1984) (" June 13th letter).

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Manager-Nuclear, the Nuclear Support and Licensing Manager, the Quality Assurance Manager, the Engineering and Nuclear Safety Manager and a representative of the Plant Manager-Nuclear com-prised the LP&L Response Review Team. The team's composition of LP&L's top nuclear experienced managers reflected the com-mitment to provide adequate resources to resolve the concerns raised expeditiously and thoroughly. The team had access to and the support of the required LP&L and contractor managers and staffs on a priority basis. The Project Manager-Nuclear re-ported directly to the Senior Vice President-Nuclear Opera-tions, who in turn reported directly to the CEO of LP&L. Both the Senior Vice President-Nuclear Operations and the CEO were directly and actively involved in the management of the pro-gram.

The program for addressing the twenty-three issues raised in the June 13 letter consisted of a description of the organi-zational' structures set up to resolve and/or review resolution of issues as well as detailed plans covering the approach to be followed in resolving each issue. An initial draft of the pro-gram and plans was sent to the NRC staff for review and com-ments. These comments were incorporated into a finalized ver-sion, the program was again submitted, and subsequent changes were incorporated as necessary to reflect new information and

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- j satisfy additional comments from the staff during the lengthy ,

review process.

LP&L analyzed each issue to determine the facts and the specific problems involved with the issue (if any), the root cause that led to the problem or to the perception of a prob-lem, the potential generic implications of the issue, and the safety significance of the problem with respect to fuel load, low power operation, and operation above 5% power. In addi-tion, LP&L determined if corrective actions were required (or were desirable on an elective basis) to address both the spe-cific issue and any related generic concerns. The potential for similar problems or deficiencies with contractors or sys-tems, other than those expressly covered by the particular issue, was examined extensively. A conservative approach was taken in that related systems, records, or other contractors were reviewed and included within the scope of the issue reso-lution whenever it was determined that the potential for simi-lar deficiencies existed.

LP&L established a formal Quality Assurance procedure for detailed validation by the LP&L Quality Assurance organization of all information provided in response to each issue. The validation process was accomplished by individuals with exten-sive experience and the vast majority of the validation efforts i .

were performed by former NRC inspectors who are well qualified to perform such validations. In parallel with the plans in place for resolution of each issue, LP&L assessed the collec-tive significance of the individual issues (" collective signif-icance") and recommended institutional or programmatic changes that would be appropriate to avoid recurrence of the types of j problems underlying the issues.

i In addition to conducting its own review, LP&L established an independent task force of outside experts (" Task Force").

.The Task. Force was chartered to provide an independent assess-ment of the adequacy of LP&L's program to resolve the June 13 l

issues, to provide an independent validation of LP&L's submis-sions and conclusions presented to the NRC, and to provide an

-independent assessment of the safety significance of the issues,'the lessons learned, and the collective significance of

.the issues on the Operational QA Program. The Task Force took steps to insure that it was independent of LP&L, reported di-Irectly to the CEO of LP&L, and transmitted its reports simulta-neously to the NRC and the CEO of LP&L. The Task Force was comprised of three well known corporate officials, highly re-t spected w_ hin the nuclear industry. The chairman was Mr. R.L.

I Ferguson, Chairman of UNC Nuclear Industries. The other mem-b'ers were Mr. L.L.-Humphreys, President UNC Nuclear Industries

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

. 1 and Mr. Saul Levine, Vice President and Group Executive NUS Corporation.E! The Task Force principals were supported by the I Task Force Support Group (TFSG) consisting of a number of per-sonnel from NUS Corporation. The size and makeup of the TFSG varied throughout the review process.and was controlled by the Task Force. The qualifications of the TFSG personnel were pro-

.vided to the NRC~for.their examination as part of their review process. The on-site reviews, assessments and inspections were performed in large part by the TFSG under the direction of the Task Force principals. The methods used by the Task Force to assess LP&L's program included independent assessments, statis-tical sampling plans, interviews of personnel involved with issue resolution, independent walkdowns and inspections and in-dependent reviews'of documents and records.

The resolution process also included a separate review by a special subcommittee of the LP&L Safety Review Committee

("SRC"). The SRC is the corporate level review board specified by the Waterford 3 Technical Specifications to provide an overview of plant operation. The SRC Chairman reports directly 2/ Mr. Levine died on October 18, 1984. Based upon the de-gree of completion of the Task Force effort a decision was made not to replace him but to complete the effort with the two remaining members.

to the Senior Vice President-Nuclear Operations on committee activities. The special subcommittee consisted of the LP&L Nu-clear Support and Licensing Manager (SRC chairman and subcom-f mittee chairman), the LP&L Engineering and Nuclear Safety Man-ger, Mr. R.M. Douglass, Manager of Quality Assurance for Baltimore Gas and Electric Company and Mr. J.M. Hendrie, Con-sulting Engineer (former Chairman of the NRC). The responses to each of-the twenty-three issues as well.as the assessment of .

collective significance were reviewed with particular emphasis on the safety significance of the issues and potential impact on-plant operation.

The process of review of the twenty-three issues was esti-mated to have consumed more than 1,300 man-months of effort, exclusive of approximately 120 man-months-expended-by the Task Force.and the TFSG. Corrective actions were generally complet-i ed prior to submittal of a final response to the NRC.1! Only very limited hardware rework was undertaken as a result of the twenty-three concerns, and in most cases this was discretionary

' (in accordance with good practices).d! LP&L is currently i

! 3/. Actions outstanding at the time of submittal were placed

[ on a tracking system to assure completion.

I 1/ Only two changes were made as a result of potential safety concerns. One was made on a three-foot section of tubing and the second represented a case where the safety signif-icance was not determined.

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verifying that all corrective actions, including hardware re-work, have been completed.

In addition to the efforts of LP&L, its contractors, the Task Force, the Task Force Support Group, and the Safety Review Committee to resolve the twenty-three issues, the NRC staff was very active in reviewing and dispositioning of the twenty-three issues and other allegations. In addition to its initial ef-fort in the Spring of 1984, the NRC Task Force remained heavily involved with the resolution of the twenty-three issues through periodic on-site review visits and by review of program plans and responses to issues submitted by LP&L.

The resolutions of the twenty-three issues, including evaluations of root cause, safety significance and generic im-plications, are contained in the individual submittals to the NRC staff. The Board has addressed in particular in ALAB-801 interest in the issues of the Mercury QA program (Issue 23) and the pervasiveness of the QA deficiencies (Collective Signifi-cance).

LP&L aggressively addressed the QA concerns related to Mercury that were first raised in 1982. As detailed in LP&L's response to issue 23, these actions included extensive person-nel changes within the Mercury organization, retraining of Mer-cury personnel, joint Ebasco and Mercury walkdowns, initiation

{.

of-a review of Mercury records by Ebasco QA, and reinspection of a large-portion of Mercury installations. In response to the-twenty-three issues, LP&L conducted an extensive reinspection-of all N1 (Class lE) instrumentation lines which

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resulted in only a small amount of rework, most of which was elective and none of which was significant to safety. As a re-sult of these. actions, LP&L'has determined that the Mercury work, as-built, is adequate to protect the public health and safety.

LP&L separately assessed the collective significance of the twenty-three issues. LP&L concluded:

The responses to the 23 issues, when assessed together, lead to two generic conclusions: (a) The QA program during the construction phase continued to have shortcomings,.but with_ current corrective. action the objectives and criteria of the construction program have now been met. The deficiencies fell primarily into the categories of records management and control of corrective actions. (b) The overall adequacy of the plant in the areas of the 23 issues is confirmed by the extensive re-evaluations and reinspections conducted in response to the 23 issues and by the minimal rework required is a result of the concerns. The plant as-built can be operated without undue risk to public health and safety.

The Task Force found the LP&L program to be adequate, found that LP&L "has made a conscientious and aggressive ef-

- fort" to' address NRC concerns, found no " substantive technical or factual deficiencies" in LP&L's responses, and found that

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i the corrective actions undertaken by LP&L were " adequate to re-solve the 23 NRC concerns." As stated by the Task Force, j The Task Force has concluded that the presently existing safety significance.of the 23'NRC issues is minimal. This

' judgment is based on the following considerations:

The extensive investigations and corrective actions performed by LP&L; The independent validation of LP&L responses, supporting data, and information sources performed by the TFSG; The expenditure of over 1000 man months of effort on these. issues over the last several months has not identified any significant rework.of plant structures, systems, or components; The substantial additional assurance that significant discrepancies-have been detected provided by (1) the use of an independent contractor (GEO) by LP&L to perform nondestructive examinations, (2) the presence of an authorized nuclear inspector, and (3) the overinspections performed by LP&L and EBASCO; and The. testing performed during plant construction and start-up of. systems to demonstrate the integrity and functionability of the safety systems.

'The analysis of collective significance led LP&L to develop a list of lessons learned from its earlier QA problems.

This list contains actions which could have prevented occur-rence of the problems and are reflected in the current Opera-tional QA Program. LP&L has also initiated modification of the 4

training program and. retraining of_Waterford personnel on the lessons learned from the resolution of the twenty-three issues.

k-It is, therefore, extremely unlikely that problems such as those experienced during the construction program would occur during plant operation.

LP&L provided still another level of review following the completion of a majority of the issue resolution process de-scribed above. This process involved performing a series of safety reviews using the criteria of 10 C.F.R S 50.59 to evalu-ate the potential impact of the twenty-three issues on plant systems. A number of teams were established to perform the re-views with each team consisting of an individual (Quality As-surance, Project' Engineering or Nuclear Licensing) thoroughly familiar with the details, status and/or resolution of one of the twenty-three issues and an individual cognizant of the plant systems, their operation and technical specification requirements. These systems specialists were from plant oper-ations organizations and included Shift Supervisors, Control Room Supervisors, and Shift Technical Advisors.

The Technical Specifications were reviewed in detail and

. listings were developed by the Plant Operations Superintendent which contained the plant systems required to be operable by the Technical Specifications for each plant mode or condition (i.e., Fuel load, Initial Criticality, Low Power (<5%) and Power Ascension (>5%).

A program plan covering the safety review process was developed and approved by LP&L management. A Plant Operating Manual procedure was developed to define a safety review check-list. The safety review process included completion of the safety review checklist by the review team, approval of the Plant Manager or Nuclear Support and Licensing Manager, review I

and approval by the Plant Operations Review Committee (PORC) and review and approval by the special subcommittee of the Wa-terford Safety Review Committee (SRC). The coordination and handling of the review process was provided by the Nuclear As-

.surance organization of Middle South Services. The entire pro-cess was audited by the Independent Safety Engineering Group (ISEG), the organization designated by the Waterford 3 Techni-cal Specifications to improve plant safety by providing inde-pendent verification of plant activities, including design and operational information. Auditable files on the process were gathered by the Nuclear Licensing organization. This process was also reviewed by the independent Task Force.

The-safety reviews have been completed for all systems re-quired to be operable by the technical specifications for all modes of reactor operation up to and including 100% power oper-ation for each of the twenty-three issues. Approximately 1400 safety reviews were necessary to complete the process. This extensive effort provides LP&L with additional confidence that

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Waterford 3 can be operated without undue risk to the public health and safety. I 1

The'LP&L efforts to review, analyze, take corrective ac-tion and review the impact of the issues on plant systems pro-vided considerable assurance the plant was constructed cor-rectly, properly documented and safe to operate. Significant efforts have also been expended, by LP&L and others, to assure that the Operational QA Program does not suffer from similar deficiencies as those identified, and corrected, in the course of the review of the twenty-three issues.

LP&L's assessment of the collective significance of the twenty-three issues included an identification of lessons learned, an overall assessment of the operational phase QA pro-

-gram, and an assessment of the operational phase QA program in light of the lessons learned. As a follow-up to LP&L's as-sessment of the Operational QA Program, the Task Force also performed an independent assessment of the program (TFSG limit-ed Scope Audit of LP&L Operational Quality Assurance Program, December 4, 1984). The Task Force found that:

The overall content of the Operational QA program is judged adequate to' support plant operation.

The Task Force did recommend that a summary QA document be prepored to provide a comprehensive description of the program, a definition of responsibilities and interfaces, and guidance on where to locate QA information. Additionally, the Task Force recommended that a comprehensive audit of the Operational QA program be conducted and that training on lessons learned from construction QA be factored more extensively into the ex-isting QA program.

As in resolution of the twenty-three issues, LP&L has taken a vigorous and comprehensive approach to the Task Force recommendations (included by the NRC staff as low-power and full-power license conditions). LP&L has gone beyond the Task Force recommendation to develop a summary level document and has developed and approved a Nuclear Operations Management Man-ual (NOMM). This manual establishes the overall goal of the Nuclear Operations Department, denominates the hierarchy of documents covered by the NOMM, illustrates the organizational structure and responsibilities of organizations, provides a Quality Requirements Matrix and contains Nuclear Safety Quality Policies, Special Scope Quality Policies and Management Stan-dards. Also in response to the Task Force's recommendations LP&L has initiated changes in the training program to incorpo-rate training on the lessons learned from the assessment of the collective significance of the twenty-three issues. Both pro-gram modifications and retraining of nuclear operations personnel are expected to be completed shortly.

.4 LP&LLhas arranged for a comprehensive audit of the Opera-tional QA Program by the Institute of Nuclear Power Operations

' (INPO) with assistance from Middle South Services (MSS) Quality Assurance. - This special assistance" visit by INPO will exam-ine the extent to which lessons learned have been incorporated into the Operational QA Program as well as assess the overall effectiveness of the program in preparation for commercial operation. MSS QA will supplement the INPO efforts by auditing the program for compliance with regulatory requirements. The INPO visit was initiated on April 1, 1985 and site activities were completed by April 4, 1985.

LP&L, through approval of the NOMM by the senior manage-ment, has reaffirmed its commitment to excellence and has man-dated compliance with the requirements and commitments contained.therein, including the Operational QA Program. The l

extensive review of the twenty-three issues, the completeness of corrective actions, the performance of safety reviews on all technical-specification systems, and the assessments and audits of the Operational QA program collectively provide assurance that LP&L can operate the Waterford 3 plant in a safe manner and in so doing will not endanger the public health and safety.

I, Kenneth W. Cook, being' duly sworn hereby depose and state that I have prepared and read the foregoing affidavit, i

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and that it is true and correct to the best of my knowledge and belief.

Kenneth W. Cook y //pci/

Sworn to and subscribed before me this /c day of Mesch, 1985.

A w .l'at bs-e< n/

Notary Public My Commission expires: V-Se-it

9 1 Resume of KENNETH W. COOK EDUCATIONAL ~ BACKGROUND I oL  : University of Wyoming B.S. in Mechanical Engineering-(with honors) - 1 Nuclear Option (1960-1964) '

o- University of California, Berkeley M.S. in Mechanical Engineering (1967-1968) o . General l Electric Advanced Engineering Courses (1965-1968) o- Numerous General Electric Sponsored Management &

Engineering Courses & Seminars l

I

' PROFESSIONAL LICENSE  !

Registered Professional Nuclear Engineer - California PROFESSIONAL LEVEL EXPERIENCE LOUISIANA POWER & LIGHT COMPANY (1983 - Present)

-Nuclear Support & Licensing Manager (9/83 - Present)

Responsible for managing the LP&L Nuclear Licensing and Nuclear

' Support organizations which-are responsible for licensing activities ufor Waterford.3, interfacing with state and federal regulatory agencies and for providing technical support to the. plant staff in the areas of Radiation Control, Nuclear Engineering, Fuels Management, Chemistry.and Radiochemistry.

WASHINGTON PUBLIC POWER SUPPLY SYSTEM (1980 - 1983)

Licensing Project Manager (4/80 - 9/83)

' Licensing Manager for two nuclear power plants (one plant terminated tin 1982); responsible for obtaining operating license and resolution 4 of. licensing issues with the NRC. . Direct efforts of Architect / Engineer, Nuclear Steam _ Supply System (NSSS) vendor, Project Technical staff, Operations staff and outside consulting agencies in preparing submittals

. Lto NRC and other regulatory agencies. Develop licensing strategies, schedules, resource commitments and manage implementation of programs through licensing department staff.

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GENERAL ELECTRIC COMPANY (1964 - 1980)

Senior Licensing Engineer (6/79 - 3/80)

L Program Manager for resolution of licensing issues associated with twenty-two (22) operating Boiling Water Reactors (BWR's).

Responsibilities included development of licensing action plans, coordination of technical resolution and resolution of issues with NRC.

Senior Licensing Engineer (5/77 - 5/79)

Program Manager for generic. licensing issues involving transient analyses for GE Boiling Water Reactors (BWR's). Programs included

= licensing of one-dimensional transient analysis model including development of licensing action plans, establishment of licensing basis, coordination of review with NRC and negotiation of licensing basis.

Senior Engineer (6/75 - 5/77)

Clinch River Breeder Reactor Project (CRBRP) cognizant engineer and program manager for safety of intermediate Heat Transport System (IHTS), Steam Generator Auxiliary Heat Removal System (SGAHRS), large sodium pumps and several analytical tasks including sodium fire, radiological and core disassembly analyses.

Engineer 1 (12/71 .6/75) l Established safety design guidelines and~ performed safety conformance reviews for GE scope of supply on CRBRP. Coordinated GE input to CRBRP.PSAR.

Directed safety analysis tasks relating to CRBRP Primary and Intermediate Systems ' sodium fires and structural evaluation of reactor vessel and internals during a core disassembly accident.

l Performed studies of Radioactive Waste Management System and Containment System requirements, Refueling Accident Analysis Study,-Refueling System Flow Chart and Safety Assurance Diagrams for the GE Demonstration Plant design.

Directed adaptation of Argonne National Laboratory developed REXCO computer code for use in GE evaluations of Hypothetical Core Disassembly Accident (HCDA) effects on the reactor internals and reactor vessel. -Updated national LMFBR Program Plan in areas of ,

Safety and Control Rod Assemblies.

Engineer 1 (1/73 - 9/73) Special Assignment Provided consultation and performance of analytical tasks relating  ;

to new concept in Boiling Water Reactor containment design. l

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Engineer II (3/68 - 12/71)

Performed transient neutronic and thermal-hydraulic analyses in support of the SEFOR follow-on program and developed Design Safety Criteria for usage in the program. Developed an outline of Technical Specifications for the Demo Plant PSAR. Initiated and directed analysis of pipe break accidents within the primary system for the Demo Plant.

Developed a computer model for evaluation of the detailed fluid velocity distribution for interior and corner fuel pins in an LMFBR fuel bundle. I Engineer (10/67 - 3/68)

Attended University of California at Berkeley as part of GE j Advanced Engineering Course to obtain Masters Degree.

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Engineer (6/64 - 10/67) l Developed detailed design, test plans and test operation plans for LMFBR fuel assembly water flow tests. Developed LMFBR test requirements for core fuel assembly thermal-hydraulics. Developed criteria and analytical models for evaluation of LMFBR fuel pin spacer assemblies.

Performed core thermal-hydraulic evaluations and prepared fuel test specifications for Superheat Reactor test fuel under irradiation at the EVESR superheat reactor test facility.

Prepared Core Design and Plant Data Sheets for Boiling Water Reactor (BWR) proposals.

Developed experimental plans and designed test facilities and test aection for BWR spacer pressure drops and feasibility study for UNISEAL for Superheat Reactor applications.

Reviewed design of BWR control rod drives and modified design to

, reduce cos t of manufacture. Developed detailed cost breakdown of drive manufacturing process.

PHILLIPS PETROLEUM COMPANY (1963)

Nuclear Engineer (6/63 - 9/63)

Participated in fuel Development Program for the Advanced Test Reactor. Set up corrosion test loop and monitored fuel test specimens.

ID LP&L SUPPLEMENT EXHIBIT 3 l

I REPORT OF THE TASK FORCE ON PRELICENSING ISSUE ASSESSMENT )

WATERFORD-1 STEAM ELECTRIC STATION Prepared for J. M. Cain President and Chief Executive Officer Louisiana Power & Light Company by Task Force Principals:

Larry L. Humphreys, UNC Operations Division Robert L. Ferguson, UNC Nuclear Industries December 1984

t S

TABLE OF CONTENTS FOREWORD

SUMMARY

AND CONCLUSIONS I. INTRODUCTION II. -PURPOSE AND SCOPE III. OVERALL ASSESSMENT OF LP&L RESPONSES AND CORRECTIVE ACTIONS IV. TASK FORCE AND SUPPORT GROUP OPERATION V. FINDINGS AND RECOMMENDATIONS REFERENCES APPENDICES A. TASK FORCE CHARTER B.- ASSESSMENTS OF INDIVIDUAL LP&L RESPONSES

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FOREWORD Task Force member Saul Levine, Vice President and Group Executive, NUS Corporition, died on October 18, 1984. Mr. Levine's contributions to this Task Force, and indeed to the entire nuclear power community, were substantial and

, irreplaceable. We are all diminished as a result of his passing.' Because much of the work of the Task Force was already completed when Mr. Levine died, a decision was made not to replace him, but rather to complete the effort with the two remaining Task Force members.

4 4

REPORT OF THE TASK FORCE ON PRELICENSING ISSUES WATERFORD 3 STEAM ELECTRIC STATION

SUMMARY

AND CONCLUSIONS The Waterford 3 Prelicensing-Issues Task Force and its Support Group performed extensive auditing, validation, and inspection in its assessment of LP&L's responses to the 23 issues raised :bs the NRC letter to LP&L of June 13, 1984.

As a result of these activities, the Task Force has concluded that none of the 23 issues ' pose any constraint to fuel load. Further, no major constraints to initial 1 criticality or power escalation have been identified; paragraph III.C discusses minor items that should be resolved prior to these evolutions.

While the Task Force's activities hare confirmed the basic soundness of the physical-plant in the areas investigated, a number of software deficiencies were noted in the quality assurance program. For the most part, the problems noted were due to management deficiencies during construction in the implementa-tion of the program. The LP&L responses to the NRC have recognized nearly all of these deficiencies, and the lessons learned have been identified. The lessons learned from these construction phase problems have been partially transferred to the Operational QA Program at the procedural level..

- The Task Force concludes that a summary document defining and describing the entire (NL program and its internal interfaces should be prepared. The Task

' Force also believes that the QA training program should specifically address the QA problems experienced during construction and their applicability to the operational phase.

Finally, the Task Force recommends active and aggressive management involvement to assure that outstanding commitments are completed promptly and to assure that the Operational QA Program fully incorporates the lessons learned at all t- levels and units of the plant organization.

I. INTRODUCTION On April 2, 1984, the NRC staff began an intensive review effort, largely

. conducted on site, to identify those issues that needed to be addressed in order for the staff.to reach a licensing decision on Waterford 3. The

, -review effort was broad in scope and included consideration of l allegations of improper construction practices at the facility.

. As a result of this review, the NRC staff identified 23 issues that had L potentia 1' safety significance and for which additional informatioy was required. These issues were transmitted to LP&L in an NRC letter dated j June 13, 1984. The letter requested LP&L to propose a program and j schedule for a detailed and thorough assessment of the 23 issues l

identified and noted that the program plan and implementation schedule s

,-,n .-r . - ---- - - - - ~ ~ - - . . , . . , . - ..n... --,.- , , _- . , ,-- , , , , ,-e -.m- , - - - - -

Pcgs 2 of 9 would be evaluated by the NRC staff before consideration of issuance of I an operating license.for Waterford 3. The NRC staff instructed LP&L to address in the' program plan (1) the cause of each of the potential

problems identified; (2) the root cause of the problem and the generic implications for other safety-related systems, programs, or areas; (3).the Collective Significance of the deficiencies; and (4) the proposed

LP&L actions to preclude such problems in the future.

In response to the NRC letter,-LP&L assigned internal responsibilities for. addressing each of the 23 issues of concern and retained the services i of three senior industry executives to serve as a task force to (1) pro-

[ vide advice in responding to the NRC letter and (2) provide an indepen-dent assessment of the LP&L' responses. The charter gnd organizational

! reporting of the Task Force is contained in a letter from J. M. Cain, President and CEO of LP&L, to the three Task Force principals, dated June 20, 1984 (Appendix A). The letter also specifies that the report of

.the Task Force is to be sent to the.NRC at the same time it is sent to the President.and CEO of Louisiana Power and Light Company.

II. PURPOSE AND SCOPE The purpose of this report is to document the independent assessment made by the Prelicensing Issue Assessment Task Force of the adequacy of the LP&L responses to, and resolutions of, the 23 issues identified in the

-Reference 1 NRC letter to LP&L.

L In accordance with its charter, the Task Force reports herein our assessments of the following:

o Th'e LP&L program plan and implementation schedule,Section III.A, o The overall adequacy of the responses and resolutions,Section III.B.

o. The safety. significance of the NRC issues,Section III.C.

o. The adequacy of the past LP&L QA/QC program in light of the NRC issues and their resolutionsSection III.D, and i

.o 1 Recommendations concerning institutional or programmatic changes

[- deemed appropriate for the future in light of the lessons learned,

! Section V.B.

This report also includes a description of how the Task Force and the

. Task Force Support Group (TFSG) performed their review,' validation, and assessment functions,Section IV; and a summary of Task Force findings on the key issues,'Section V.A.

III..- OVERALL ASSESSMENT OF LP&L RESPONSES AND CORRECTIVE ACTIONS A. . Program. Plan and Implementation Schedule TheTask}ForceprovidgditsassessmentoftheProgramPlanst.d Schedule in a letter to LP&L President and CEO, J. M. Cain, on

Pcgs 3 of 9

? ' July 26, 1984. This letter followed several substantive interactions of the Task Force and LP&L on drafts of the plan and expressed its judgments that the plan (1) accurately represented LP&L's plans for resolving the issues and (2) should, when imple-mented, lead to satisfactory resolution of the issues. The Task

. . Force ~1etter noted that changes to the reviewed program plan could be expected as additional information became available and as the-

"j work f LP&L and the Task Force proceeded. The detailed program K

plan5was not reviewed in detail and assessed by the' Task Force because we did not consider this assessment necessary. An interim report on the status of validation activities as of October 31,-

1984, was provided in Reference 6.

B. Overall Adequacy of the LP&L Responses The Task Force concludes that LP&L has made a conscientious and aggressive effort to-address the NRC issues. In their written responses to the issues and in the actions taken to resolve the issues, LP&L has attempted to be responsive to both the letter and the spirit of the NRC instructions. LP&L has also been responsive l to the advice of the Task Force.

1 The independent validation of data and sources by the TFSG has not revealed any substantive technical or factual deficiencies in the LP&L' responses. The TFSG validation activities examined the informa-tion base supporting the LP&L responses and involved independent sampling inspections, verifications of engineering analyses, docu-mentation evaluations, and procedure reviews. The Task Force assessments of-the LP&L responses to each of the NRC concerns are provided in Appendix B C. Safety Significance of the NRC Issues The safety significance of the NRC issues was evaluated by the Task L Force, in light of the LP&L responses, both individually and collec-L tively. The assessmants of safety significance for individual

! issues were focused on the stated or implied safety implications in L the'NRC's statement of concern for each issue. These individual assessments are included in the Appendix B Task Force evaluations.

The collective safety significance assessment of the Task Force was L ' based on our judgment of the overall impact of the 23 NRC concerns taken as a group. We examined whether or not the' magnitudes and categories of NRC concerns were indicative of (1) a fundamental

~

breakdown in the LP&L QA/QC program taken in its entirety, l

.(2) generic deficiencies in specific parts of the program or with I specific contractors, or (3) failures in specific limited areas of j

j the. total program.

1 l

Our' findings in these areas can be summarized as follows:

1 o No deficiencies were identified in specific limited areas of the program that could not be related to the generic deficiencies l discussed below;

Pcgm 4 of 9 o Generic deficiencies in QA/QC practices have been identified on the part of EBASCO subcontractor Mercury; and these deficiencies were addressed, but were not corrected by LP&L in a timely manner; other programmatic deficiencies were identified; and o Although LP&L did not maintain enough control over the QA/QC practices of its contractors and subcontractors during construction, a fundamental breakdown of the QA program taken in its entirety did not occur. Better implementation of the QA/QC program would have avoided most of the problems that did occur.

The Task Force has concluded that the presently existing safety significance of the 23 NRC issues is minimal. This judgment is based on the following considerations:

o The extensive investigations and corrective actions performed by LP&L; o The independent validation of LP&L responses, supporting data, and information sources performed by the TFSG; o The expenditure of over 1000 man months of effort on these issues over the last sever 4Q months has not identified any significant rework of plant structures, systems, or components; o The substantial additional assurance that significant discrepancies have been detected provided by (1) the use of an independent contractor (GEO) by LP&L to perform nondestructive examinations, (2) the presence of an authorized nuclear inspec-tor, and (3) the overinspections performed by LP&L and EBASC0; and o The testing performed during plant construction and reart-up of systems to demonstrate the integrity and functionability of the safety systems.

Further, as supported by the Task Force letter to LP&L of August 31, 1984, the plant staff has carried out safety analyses on all systems required for fuel load and hot functional testing, giving special attention to the 23 NRC issges as stated in the LP&L letter to the NRC dated October 31, 1984 Although LP&L has adequately addressed all 23 NRC issues, there are still a few outstanding action items'that should be completed to resolve all issues. Some of these items pose constraints on the plant start-up activities as noted below:

1. Prior to Initial Criticality

a. Complete the analyses of the concerns identified in the initial interview program discussed in Issue 16 and resolve any concerns which have safety significance for critical operations. See Task Force report on Issue 16.

Pegs 5 of 9

b. Complete the safety reviews of plant systems required for criticality, low power testing, and full power operation against each of the 23 NRC issues. SeeAttacgmentBofthe LP&L letter to the NRC dated October 5, 1984

2. Prior to Exceeding 5 Percent Power

a. Resolve any concerns from the initial interview program which have safety significance for operations above 5 percent power. See commitment 1Ln LP&L response to Issue 16.

l b. Schedule an audit by an outside qualified organization of the new interview program, discussed in the LP&L response to Issue 16. See recommendation in Task Force report on Issue 16.

3. Prior to Commercial Operation Schedule an audit by a qualified outside organization of the Operational QA Program. See Task Force report on Issue 23 and Collective Significance.

D. Adequacy of the Past QA/QC Programs in Light of the Issues Identified and Their Resolution The basic Task Force finding on the subject of past quality assurance / quality control programs is that LP&L did not maintain enough control of the QA/QC programs of its contractors and subcon-tractors during construction. As a result of this management deficiency, unacceptable work practices occurred that were not discovered and addressed in a timely manner. The consequences of discovering unacceptable work practices later than might have been expected have, in this case, been more apparent in software issues (e.g., qualifications documentation, inspection procedures, noncon-formance documentations) than in hardware deficiencies. This latter observation reflects the fact that most of the 23 NRC issues are being adequately resolved without significant rework or other hardware modifications.

But at this juncture, it is more important to look ahead than to look back. The LP&L submittal to NRC on Collective Significance, enclosed with the Reference 10 letter, includes an extensive dis-cussion of how the " lessons learned" from the shortcomings of the construction phase QA/QC programs have been reflected in improve-ments in the Operational QA Program. The Task Force observes that

this transfer of lessons learned has been partially achieved in the l Operational QA Program on paper, but notes that continuous and aggressive involvement of upper management will be necessary to ensure effective implementation of the program.

IV. TASK FORCE AND SUPPORT GROUP OPERATIONS The Task Force Charter is given in Refercace 2 and is attached as Appendix A to this report. The TFSG objectives, work scope, organiza-

, tion, and project procedures are described in Reference 11. This section l

L

Page 6 of 9 _;

_s

=

of the report summarizes these functions and also describes the TFSG ]

independence from LP&L, methodologies used, relationships to other parties, and reporting requirements. j

_~_

The basic functions of the Task Force were to provide to the President _;

and CEO of LP&L advice on responding to the NRC issues and an independent P professional assessment of (1) the LP&L responses to, and resolutions of,  %

the NRC issues and (2) the safety significance of the issues. Further, the Task Force was asked to assess the LP&L program plan for resolving  ;

the issues, assess the adequacy of the past LP&L QA/QC program, and

• recommend institutional or programmatic changes deemed appropriate. 9w The basic function of the TFSG was to generate the information required il by the Task Force to make its assessments and to formulate its 4 recommendations. This function involved such tasks as performing  ?

detailed reviews of LP&L responses to the NRC issues, reviewing and validating the supporting data and information cited in the LP&L L responses, and performing independent field inspections of hardware ___

installations. TFSG validations and inspections were performed by q qualified personnel and in accordance with detailed procedures. ,

Independence The independence of the Task Force and the TFSG from LP&L was assured in several ways. NUS Corporation, which supplied one Task Force member and -

the TFSG personnel, prepared a Statement of Non-Conflict of Interest -

documented in Reference 12. This statement examined previous work performed by NUS for LP&L and concluded that "NUS has no conflicts, real or potential, which would limit our objectivity in reviewing proposed 3 LP&L responses to the NRC." The UNC Task Force g mbers and NUS personnel =

assigned to the TFSG signed forms, per procedure , affirming that they e owned no LP&L stock and had no other personal or family ties to LP&L. In a addition, the Task Force reports only to the Chief Executive Officer of ==

LP&L, and not to a line organization. The Tasa Force established its own 5 -

scope of work, within the framework of its charter, and exercised the freedom it was given to apply the numbers and types of personnel needed _

to execute the scope of work. Further, the validation work performed by the TFSG has been documented, and the project files are available to NRC ]

for review. Finally, this final report of the Task Force goes to the NRC 5 at the same time that it goes to the Chief Executive Officer of LP&L.  ;

5w Methodologies j Subject to the overall supervision of the Task Force, the TFSG prepared its own procedures, qualified its own people, and provided training as deemed necessary for the auditing, validation, and inspection functions -

performed. For many issues, statistical sampling and analysis techniques 4 were used in the validation process. The application of these techniques allowed the TFSG to quantitatively determine the fraction of a given sample expected to lie outside stated criteria and the degree of confi- '_

dence in the results. The work of the TFSG has been carefully _

documented, and supporting information for our conclusions is available in the project files. l a

. s j

_ _ . .. . 5

Pcgs 7 of 9 Relationships to other Parties The charter of the Task Force contained two primary elements, namely providing advice to LP&L in responding to the 23 issues described in the NRC letter and providing an independent professional assessment of the technical adequacy of the responses. The organizational independence of

, the Ta'sk Force and its Support Group from LP&L is described above.

However, because of the nature of the work to be performed, it was necessary for the TFSG to work closely with the staffs of LP&L and their construction and engineering contractors. This involved attending LP&L technical meetings and progress meetings, where draft issue responses prepared by LP&L or contractor personnel were discussed in order to obtain a complete understanding of each response. The TFSG also had many contacts with LP&L and its subcontractors in order to locate the documentation required to perform the independent auditing, inspection, and validation functions. Throughout all of these essential information exchanges, the Task Force and the TFSG were cognizant of the need to maintain independence from LP&L in arriving at judgments or conclusions.

A figure included with the charter of the Task Force (Appendix A) deline-ates both the interfacing requirements and the reporting requirements for the Task Force.

Reporting Requirements As noted earlier, the Task Force reports only to the Chief Executive Officer of LP&L, and our final repo:t.is transmitted simultaneously to the CEO of LP&L and to NRC. Initially, the Task Force planned to submit a single final report at the conclusion of its work. However, as the project progressed, it was decided to adopt a phased reporting process in support of the phased licensing reviews being carried out by NRC.

Therefore, the Appendix B Task Force evaluations of the individual issues were transmitted to the LP&L CEO and to NRC as they were completed and are appended hereto in the interest of compiling a single comprehensive document.

Individual Task Force assessment reports on 19 of the LP&L responses to the 23 issues were submitted prior to the issuance of this report as noted below:

Issue Task Force Transmittal Letter 2 NUS -W3-A735 Dated October 12, 1984 5, 8, 11 NUS-W3-A736 Dated October 19, 1984 3, 7, 12, 19 NUS-W3-A742 Dated October 26, 1984 9, 13, 15, 21, 22 NUS-W3-A746 Dated November 2, 1984 16, 17 NUS-W3-A756 Dated November 16, 1984 7 NUS-W3-A757 Dated November 19, 1984 14 NUS-W3-A758 Dated November 26, 1984 18 NUS-W3-A759 Dated November 28, 1984 20 NUS-W3-A760 Dated November 30, 1984 The individual Task Force assessment reports on the remaining LP&L responses, to Issues 1, 4, 10, 23 and Collective Significance, are included with this report. It should also be noted that Revision 1 to 9

Pegs 8 of 9

-the Task Force assessment report on Issue 8 is included with this report.

The change made in this revision is limited to a single editorial correc-tion which does not in any way alter the substance of the report.

Supplements or revisions- to the LP&L responses to Issues 6, 7, and 19

-were completed by LP&L and submitted to the NRC after the Task Force reports had been submitted on these -specific LP&L responses. The TFSG has-reviewed the changes made by LP&L to the original responses. The

-Task' Force has concluded that the previously submitted reports on these responses require no revisions.

-V. FINDINGS AND RECOMMENDATIONS A. ' Findings

1. Adequacy of the LP&L Program Plan and Schedule The LP&L program plan accurately represented the plans of LP&L for resolving the issues. Implementation of the plan has led to satisfactory resolution of the issues, subject only to completion of the actions identified in paragraph III.C above.

2. Adequacy of the LP&L Written Responses LP&L has made a conscientious and aggressive effort to address the NRC concerns, has attempted to be responsive to both the-

-letter and the spirit of the NRC instructions, and has been responsive to the advice of the Task Force. The TFSG valida-tions have not revealed any substantive technical or factual

deficiencies in the LP&L responses to the NRC issues.

3. Adequacy of the LP&L Corrective Actions The Task Force and the TFSG, in performing their advisory and validation functions, had many interactions with LP&L and its contractors on the subject of the adequacy of LP&L corrective actions. As a result of these interactions, the LP&L responses, the independent TFSG inspections and evaluations, and the judgment of the Task Force, the Task Force concludes that the actions completed or in progress.by LP&L are adequate to resolve the 23 NRC concerns.

4 Safety Significance The presently existing collective safety significance of the 23 NRC issues, in light of the LP&L responses and the TFSG validations, is minimal.

5. Adequacy of LP&L QA/QC Program There is evidence that the transfer of lessons learned from the construction phase QA/QC deficiencies to improve the Operational QA Program has been partially achieved at the procedural level.

The overall content of the Operational QA Program is judged adequate to support plant operation.

i e

Pcgo 9 of 9 B. Recommendations

1. Lessons learned from the construction phase QA/QC shortcomings have been partially transferred to the Operational QA Program at the procedural level; management involvement in the Operational QA Program should be continuous and aggressive to assure program effectiveness *in practice. To provide further assurance that needed improvements are identified and incorporated in a timely manner, a comprehensive audit of the Operational QA Program should be conducted as soon as possible, but prior to commercial operation ,

at the latest.

2. A summary QA document should be prepared to provide a comprehensive description of the Operational QA Program, the definition of responsibilities and interfaces, and guidance on where to find information on QA matters at all levels of concern.

This should be completed prior to the audit recommended in paragraph B.1 above.

3. Programmatic controls should be strengthened to assure that all appropriate personnel receive necessary QA training in a timely manner on the basic concepts of quality and quality assurance.

-The existing QA training program should be supplemented to incorporate specific discussion of QA problems experienced during construction and how this experience applies to operational activities.

4. Each of.the suggestions in the TFSG Limited Scope Audit Report of LP&L Operational QA Program (see Issue 23 and Collective Significance) should be addressed.

5. Corrective actions related to the 23 NRC issues, as identified in the LP&L responses, that are still in progress should be aggressively pursued by LP&L management for proper and timely closeout.

.s REFERENCES

1. USNRC letter from D. G. Eisenhut, Director, Division of Licensing, ONRR, USNRC to J. M. Cain, President and CEO, LP&L, Docket 50-382, Waterford 3 Review, June 13, 1984.

-2.. LP&L Letter W3B84-0445 from J. M. Cain, President and CEO, LP&L, to Mr. Saul Levine, NUS Corporation; Mr. Robert L. Ferguson, UNC Nuclear Industries, Inc.; and Mr. Larry L. Humphreys, UNC Nuclear _ Industries, Inc.; Prelicensing Issue Assessment Task Force Charter, June 20, 1984.

3. LP&L Letter W3B84-0459 from J. M. Cain, President and CEO, LP&L, to D. G.

Eisenhut, Director, Division of Licensing, ONRR, USNRC, Waterford 3 SES Revised Program Plan, July 27, 1984.

4. Task Force Letter CG-SL-19-84 to J. M. Cain, President and CEO, LP&L, Task Force Review of Waterford 3 SES Revised Program Plan, July 26, 1984.

5. LP&L Letter W3B84-0495 from J. M. Cain, President and CEO, LP&L .to D. G.

Eisenhut, Director, Division of Licensing, ONRR, USNRC, Waterford 3 SES Revised Program Plan, October 10, 1984.

6. Task Force Letter NUS-W3-A744 to J. M. Cain, President and CEO, LP&L, October 31, 1984.

7- Task Force Letter NUS-W3-0014, to J. M. Cain, President and CEO, LP&L, August 31, 1984.

8. LP&L Letter W3A4-0133 from J. M. Cain, President and CEO, LP&L, to D. G.

Eisenhut, Director, Division of Licensing, ONRR, USNRC, October 31, 1984.

9. LP&L Letter W3*84-3086 from J. M. Cain, President and CEO, LP&L, to D. G.

Eisenhut, Director, Division of Licensing, ONRR, USNRC, Waterford 3 SES

. Request for Operating Licensing, October 5, 1984.

10. LP&L Letter W3B84-0807 from J. M. Cain, President and CEO, LP&L, to D. G.

Eisenhut, Director, Division of Licensing, ONRR, USNRC, Waterford 3 SES

' Partial Response to Items from Waterford Review Team, October 31, 1984.

11. Task Force Support Group Letter NUS-W3-A706 from P. V. Judd, Project Manager, TFSG, to D. Crutchfield, USNRC, August 15, 1984.

12. NUS Corporation Letter R0-84-060 from D. L. Couchman, Senior Vice President, Regional Operations, to J. M. Cain, President and Chief Executive Officer LP&L, June 21, 1984.

13. NUS-W3-GP-2, Procedure for Assuring Independence of the Prelicensing Task Force Support-Group, August 15, 1984.

I

h APPENDIX A LP&L Letter W3B84-0445 from J. M. Cain, President and CEO, LP&L, to Mr. Saul Levine, NUS Corporation; Mr. Robert L. Ferguson, UNC Nuclear Industries, Inc.;

and Mr. Larry L. Humphreys, UNC Nuclear Industries, Inc.; Prelicensing Issue Assessment Task Force Charter, June 20, 1984

. S LOUISIANA 47 - s - . .e..o - o POWER & LIGHT ! e: cautAML u:veAN4 vosso e p-M100LE SOUTH UT1uTIES SYSTEM J.M. CAIN June 20, 1984 President and Chief Executive Officer W3B84-0445 Mr. Saul Levine NUS Corporation 910 Clopper Road -

Caithersburg, 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 j Richland, Washington 99352 i

SUBJECT:

Pre-Licensing Issue Assessment task Force Charter i

REFERENCE:

Discussions in the Offices of Shaw, Pite=an, l Potts & Trowbridge, Washington, D.C. , June 13, 1984

Dear Messrt:

Levine, Ferguson and Humphries:

Pursuant to discussions in the referenced meeting, this for=alizes agreements j 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 l and advice in responding to the NRC letter of June 13, 1984 It is important I 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 Of fice of Nuclear Reactor Operations at the same time they are provided to me.

9 The Program Plan and implementation schedule requested in the NRC letter.

e The adequacy of responses and resolutions (including ,

validation of data and sources, as appropriate) of the matters set out in the NRC letter.

g -Juna 20, 1984 o

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 G The adequacy of the past QA/QC program in light of the matters listed in the NRC letter, and the resolution of such matters.

6 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 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 Waterford staff but is to report directly to me.

President &

Chief Executive Officer (LP&L)

(J. Cain)

Task Force Senior Vice President -

Nuclear Operations (LP&L)

- (M. Leddick)

?

Safety Review

______________ Committee 1

l l Quality Assurance ------Proj ect Manager (LP&L)-------Plant Manager (LP&L)

Manager (LP&L)' (D. Dobson) (R. Barkhurst)

(T. Garrets) i e 1 Ebasco & Staff LP&L & Staff Reporting

-- - Interface Very t y yours, J M. Cain JMC:DD:ph , .

cc: G. Charnoff, R.S. Leddick, D.E. Dobson

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

,_ ,,e-.- - -,- -, --..,-___ --_

h; '

L.

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3k

$ ' 08';H E TED

.UShMC UNITED STATES OF AMERICA 'B5 APR 11 All ;55 NUCLEAR REGULATORY COMMISSION

- Before the Atomic Safety and Licensing ApNdf.'Bohr'd.t iAin

~

"BN h'CS

' In the Matter of. )

)

=-

LOUISIANA POWER & LIGHT COMPANY ) Docket No.-50-382 OL

)

(Waterford Steam Electric Station, )

- Unit -3) )

~ CERTIFICATE OF SERVICE

. This.is to certify that copies of the foregoing " Applicant's Supplementary Comments" were served, by deposit in the United States mail, first class, postage prepaid, to all those on the attached Service List, except those marked with an asterisk were served by. hand delivery this 10th day of-April, 1985

,,, y

. & % ;- lJ If..ls c . ..

Alan D. Wasserman

- Dated: April'10,'1985 hane ei is umg sgemi smuse inugn gisi igi

i UNITED STATES OF AltERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 OL

)

(Waterford Steam Electric )

Station, Unit 3) )

SERVICE LIST

• Christine N. Kohl Sheldon J. Wolfe

. Administrative Judge Administrative Judge Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. -20555 Washington, D.C. 20555

• W. Reed Johnson Harry Foreman Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission Director, Center for Population Washington, D.C. 20555 Studies Box 395, Mayo

• Howard.A. Wilber University of Minnesota Administrative Judge Minneapolis, MN 55455 Atomic Safety and Licensing Appeal Board Walter H. Jordan U.S. Nuclear Regulatory Commission

. Administrative Judge Washington,. D.C. 20555 Atomic Safety and Licensing Board

• Sherwin E. Turk, Esquire 881 West Outer Drive Office of the Executive Oak Ridge, TN 37830 Legal Director U.S. Nuclear Regulatory Commission Docketing & Service Section (3)

Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

LP&L SOrvica List-ASLAB

( Page Two Mr. Gary Groesch

-2257 Bayou Road New Orleans, LA 70119 Carole H. Burstein, Esq.

445. Walnut Street New Orleans, LA 70118

• Lynne Bernabei, Esq.

Government Accountability Project 1555 Connecticut Avenue, N.W.

Suite 202 Washington, DC 20009 i

l 9

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