ML20107B687

Forwards Revised Program Plan in Response to Issues 1,6,10 & 20 & Suppl to Issue 13 of NRC .Addl Info Will Be Submitted by 841121

ML20107B687
Person / Time
Site:	Waterford
Issue date:	10/31/1984
From:	Cain J LOUISIANA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
W3B84-0807, W3B84-807, NUDOCS 8411020297
Download: ML20107B687 (173)

Text

LoulSIANA P O W E R & L 1 G H T / NEWCR.EANEU OUSuWA au - emeer m wx em40 70100 O [504}505-2204 Eu?$EsS$

October 31, 1984 J.M. CAIN Presideht 50-3Sk w3334_ogo7 Director of Nuclear Reactor Regulation ATTN:

Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

Waterford 3 SES Partial Response to Items from Waterford Review Team

REFERENCES:

1) Letter, D.G. Eisenhut to J.M. Cain, "Waterford 3 Review," dated June 13, 1984

2) Letter W3P84-3086, J.M. Cain to D.G. Eisenhut,

" Request for Operating License," dated October 31, 1984

Dear Mr. Eisenhut:

The purpose of this letter is to submit LP&L responses to Issues 1, 6, 10 and 20 as set forth in your June 13, 1984 letter (Reference 1).

These responses follow the approaches set forth in the revised Program Plans enclosed with this letter. Also enclosed is a supplement to the response to Issue 13.

The supplement covers unprocessed Mercury NCRs and is provided in accordance with our commitment in the inital response to Issue 13.

In addition we are submitting our assessment of the Collective Significance of the twenty-three issues.

Additional information on these issues will be provided, as indicated in the responses to these issues. We expect to submit the additional information by November 21, 1984. The responses as presently submitted include sufficient information to support safety analyses presented as part of the licensing program plan (Reference 2).

The submittals 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 responses for resolving the issues raised. The subcommittee scope of responsibility does not include independent validation of the facts.

%1 O

A

'Mr. Darrell G. Eisenhut, Director Page 2

~ W3B84-0807 October 31, 1984

~The. Task Force has indicated by separate correspondence (enclosed) that it is satisfied with the logic of.the submittals. -However,'it 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.

We request that you commence actions you deem necessary to lead to the resolution of these individual issues.

ncerely, A

J.M. Cain JMC:DA:pbs Attachments-

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Mr. Darrell:G. Eisenhut,_ Director Page 3 W3B84-0807'-

.0ctober 31, 1984

~

LMr. R 'i LeddickL Mr. J. Harrison cc:

'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. Cooks

.Mr. J.E. Gagliardo Director of Waterford.3 Task Mr. T.F. Gerrets Force 1

Region IV

~Mr. A.S. Lockhart 611 Ryan Plaza Suite 1000 Arlington, TX 76011 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 Regulatc y Commission Mr. R.L.'Ferguson Region.IV UNC Nuclear Industries 611 Ryan Plaza Suite 1000 1200 Jadwin Suite 425

-Arlington, TX. 76011 Richland, WA 99352 LMr.' D.~Crutchfield Mr. L.L. Humphreys

'U.S._ Nuclear Regulatory-Commission UNC Nuclear Industries i ashington,' D.C. 20555 1200 Jadwin, Suite 425 W

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 JLeader=

-Baltimore, MD 21226 7920 Norfolk-Ave. MS-216-Bethesda, MD 20114 Mr. 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.

lMr. R. Christesen, President Rockville, MD'~

Ebasco Services, Inc.

Two World Trade Center New York, NY 10048

. - ~. ~

_ -,_ _ _... L.

tNUS Cta-e-GFiATION NUS-W3-A745 October 31, 1984 Mr. J. M. Cain President and Chief Executive Officer Louisiana Power and Light Company 317 Barrone Street New Orleans, Louisiana 70160

Reference:

1.

Letter from D. G. Eisenhut, Director, Division of Licensing, USNRC to J. M. Cain, President and Chief Executive Officer, LP&L, Waterford 3 Review, June 13, 1984 2.

Letter from D. M. Crutchfield, Assistant Director for Safety Assessment, Division of Licensing, USNRC to J. M. Cain, President and Chief Executive Officer, LP&L, Missing or Voided Mercury Company NCR's, September 19, 1984

Dear Mr. Cain:

We understand that you plan to submit LP&L responses to the NRC covering Issues 1, 6, 10 and 20 identified in reference 1.

We also understand that you plan to

~

submit a supplement to Issue 13 which addresses the NRC request in reference 2, for additional information on missing or voided Mercury Company NCR's.

In ad-dition we understand you are submitting your assessment of the Collective Signi-ficance of the twenty-three issues identified in references 1 and 2.-

The hsk Force has no objection to this course of action. We have studied these issues and find the logic stated in the LP&L responses to be adequate. You should note that the Task Force has not yet completed its independent validation of the facts presented in the responses. We will notify you and the NRC immedi-ately if we find significant deviations in the course of our continuing validation effort. Of course, as you know, our work on all 23 issues and their collective significance is continuing. As of this date we have submitted formal reports on eight of the issues.

Sincerely,

/0 f

M&

-p Robert L. Ferguson V

Chairman UNC Nuclear Industries b

- e r

/r U

Larry L. Humphreys President UNC Operations Division LLH/cn cc Qj A Halkburton Company

s PROGRAM PLAN ISSUE:

1 DATE:

10/31/84

-TITLE:

In:pection Personnel Issues 7

!~

DESCRIPTION OF ISSUE:

Vsrify the proper certification of site QA/QC personnel or requalify the work performed by these personnel.

LP&L APPROACH TO RESOLUTION:

A verification program has been established to review the professional credentials of 100% of_the site QA/QC personnel, including supervisors and managers who performed safety related functions at Waterford III during its construction.. The diccussions that Sollows applies to all contractors except J. A. Jones, Fegles, and GEO (CMT), which' are addressed in Issues 10 and 20.

Criteria for certification or qualification of QA/QC personnel will be based on ANSI N45.2.6-1973 and i

SNT-TC-1A for QC inspection personnel and contractor QA program requirements for QA personnel. Priority has been placed i

on dispositioning of potential deficiencies _for contractors required to support safety evaluations on systems required 5

for fuel load.

In addition, background investigations will be performed for personnel in all groups. If certification of an individual can not be verified appropriate site nonconformance documentation will be initiated to document evaluation of safety significance and corrective actions, including reinspections of work performed as necessary.

For Ebasco, LP&L and other site construction related Q4/QC. personnel,r,emaining on site, a reverification of proper 4

qualification is being accomplished in accordance with ANSI-N45.2.6-1973.

LP&L operations Quality Control personnel i

will be reverified in accordance with ANSI N-45.2.6-1978 as committed to;in FSAR section 17.2.

Quality Control functions currently being undertaken as part of the inspections,in progress are being. performed by personnel reverified j

as qualified under ANSI-N45.2.6-1973.

WORK INSTRUCTIONS AND PROCEDURES EMPLOYED:

l COMPANY PROCEDURE NUMBER TITLE

)

Ebzaco QAI No. 32 Instructions for Verifications of QA/QC Personnel Qualifications LP&L QASP 19.12 Review of Contractor QA/QC Personnel Qualification Verification V

QASP 19.13 Response Validation 1-1 e

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ORGANIZATIONS' INVOLVED:

')

ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS

.Ebs2co.

.l.

Verification Education / Experience 1.; Training Requirements to QAl-32.

of QA/QC personnel (ex6ept LP&L and Ebasco).

2.

,a.

Review program requirements of 2.

Ebasco's Quality Resources Training Manual-1 (QRTM-1) all contractors, review and delineates the requirements for qualifying records collect data (except LP&L and reviewer. QAI-14, Training and Qualification Ebasco) and identify inspectors Requirements.for Quality Assurance Records Personnel" whose qualifications are not endorses QRTM-1 and requires all reviewers have verifiable against ANSI training on procedures they are reviewing to.

For N45.2.6-1973, SNT-TC-1A and QA qualification / certification files, training Program requirements for QA requirements are QAl-32 and ANSI N45.2.6.

personnel.

b. Determine, to the extent feasible,. inspections performed by personnel whose qualifications are not verifiable.

c. Disposition quality documentation generated by,LP&L in item 5 below.

LP&L 1.

Audit Ebasco's implementation of 1.

a. Indoctrination / training to LP&L and Ebasco QAI-32.

procedures, ANSI N45.2.6-1973 and 1978, ANSI 1

N45.2.'23-78, SNT-TC-1A-75, and interpretations.

1 l

b. Orientation as to task objective, organizations, and associated responsibilities and duties.

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c. OJT for three days to assure knowledge, understanding, and. proficiency demonstration.

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ORGANIZATIONS INVOLVED: CONT'D ORGANIZATION FUNCTIONS PERFORMED PERSONNFL QUALIFICATION / TRAINING REQUIREMENTS LP&L (Continued)

'd Individuals selected have inspection related experience and/or were involved in the training / certification or review of inspection personnel.

e. Personnel involved in this process have not worked for Ebasco or.any of the contractors under review.

2. Review all LP&L and Ebasco as well

2. Same as item (1).

-as those verified by Ebasco.

3. Sample Education / Experience

3. Same as items (1).

verification of contractors performed by Ebasco.

4. Perform final management

4. Review Board-Three senior LP&L QA personnel qualified to determination of the qualifications ANSI N45.2.23 (1978).

of individuals who are potentially unqualified.

5. Initiate suitable quality

5. LP&L, lead auditor who is qualified. to ANSI N45.2.23 documentation in cases where (1978).

inspections were performed by personnel where qualification could not be verified.

6. Make final determination on

6. LP&L QA and Project Management dispositioning of quality documentation mentioned in 4. &bove by Ebasco.

7. Validate response per QASP 19.13 to

7. Validation will be performed under the direct assure positive statements of fact supervision of the LP&L lead auditor who is qualified to are substantiated.

ANSI N45.2.23 (1978).

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. ORGANIZATIONS INVOLVED: CONT'D

., ORGANIZATION

- FUNCTIONS PERFORMED.

PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS Th20philus, Inc.

- 1.IThe purpose of the'Theophilus, Inc. ' 1. Previous ' experience with regard to performing regulatory '

assessment was to provide a totally inspections in the area of inspection and testing' independent evaluation of the personnel.

Previous qualification to-ANSI-qualification of inspectors

,N45.2.23-1978.

m determined to be potentially.not

. qualified by the LP&L Review Group and potentially qualified by the v

LP&L Review. Board.

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ATTACHMENTS:

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Flow Chart - Icapector Qualification Review 3

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ATTAC11 MENT 1 FLOW CHART'-INSPECTOR QUALIFICATION REVIEW LP&L Review LP&L Revicw Board Theophilus, Inc.

Group Determinations Determinations Review Final Results Qualified Qualified J L 4

Administrative M

Qualified

Background

4 Deficiency Only I

I Verification (Qualified)

File Herger t.

V Not Inspector Files Qualified Reviewed From 4

Qualified Ebasco & LP&L V

Potentially Qualified Not Not Qualified 7

Qualified r

3 r 4

Not CAR Indeterminate 4

(Considered Not Qualified y

Written &

Qualified)

Dispositioned Not M

Qualified 1-5 e

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g PROGRAM PLAN w

ISSUE:

6 DATE:

'10/31/84 tTITLE:-

Diepositioning of Non-conformance and Discrepancy Reports DESCRIPTION OF ISSUE:

Some_Ebasco mnd Mercury.NCRs and Ebasco DRs were. questionably dispositioned and LP&L shall propose a program'to assure all NCRs and DRs-are appropriately upgraded, adequately.dispositioned and corrective action completed and that any problems detected are corrected.

LP&L APPROACH TO RESOLUTION:

First, the specific Ebasco and Mercury NCRs'and Ebasco DRs cited by the NRC will be evaluated for proper disposition, itplementation of' corrective action, appropriate. documentation, and proper closure. To date, though some minor deficiencies have been identified, no. physical rework has-been required.

Secend, a program review of Ebasco NCRs closed prior to February, 1984 was started by LP&L in February, 1984 to assess tha validity of the disposition. the review for reportability per 10CFR50.55(e) or 10CFR21, and proper closure.

Approximately 115 of the more'than 7100 NCRs reviewed have been identified as having deficiencies in the above attributes. These are being evaluated. The deficiencies that have thus far been evaluated have no safety' significance.-

Third, an indepth ver'ification has been conducted by LP,&L on a rando,m sample of 124 of the above noted potentially deficient Ebasco NCRs to assure that the hardware and/or software corrective action had been completed. This included an evaluation of documentation for the required corrective action. Approximately forty-five NCRs were identified as having minor deficiencies. The deficiencies that have thus far been evaluated have no safety significance.

Fourth, an additional set of approximately 530 Ebasco NCRs. closed since February, 1984 have been reviewed by LP&L for proper disposition, adequate' documentation to support the required' corrective action, requir&d software changes completed and proper closure. To date, one deficiency has been identified that involves physical rework. This daticiency has been evaluated and has no safety significance.

Fifth, a review of Mercury NCR's will be performed as follows: a) A sample of NCRs that were dispositioned rework / repair or reject for reportability per 10CFR50.55(e), b) NCR.dispositioned Use-As-Is to assure they were upgraded to Ebasco NCRs, c) a random sample of sixty-five (65) NCRs that were dispositioned rework / repair for proper disposition, adequate documentation of corrective actions required, and proper closure.

Finally, a random sample of 230 Mercury and 230 T-B DRs have-been reviewed to verify proper closure.

6-1 m.

WORK INSTRUCTIONS.AND PROCEDURES EMPLOYED:-

COMPANY PROCEDURE NUMBER TITLE Ebc2co

.QAI-33

" Instruction for Reporting Deficiency Rcport. Sheets LP&L QASP 19.13 Response Validation WI-L-6.1 Nonconformance Report Review ORGANIZATIONS INVOLVED:

ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS Ebtsco

-1)

Review of NCRs cited in concern

1) The review was performed by QA Engineers under the supervision of the Lead QA Engineer.

2) Review of DRs cited.in Concern

2) The review was performed by Engineers under the.

supervision of the QAIRG QA Engineer.

~

3) Review random sample of Mercury 3)

Same as item 2.

and'T-B DRs.

4) Review random sample of Mercury

.4)

The review was performed by QA Document Reviewers under NCRs.

the supervision of the EC-QA Manager.

LP&L

1) LP&L-QA engineers performed a

1) Review conducted by the LP&L lead auditor who is review of Ebasco dispositioned qualified to ANSI N45.2.23-1978.

NCR's in accordance with Work Instruction "Non-Conformance Report Review".

This review. included:

1) Performing and documenting' special reviews of specified NCR's.

2) Documenting and processing potential deficiencies through resolution and closure, and

3) Field verification of selected NCR's.

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, ORGANIZATIONS INVOLVED:

(Continued)

ORGANIZATION

. FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS-

. Val'dation was performed-under the direct supervision

2) Validation per QASP.19.13 will 2) t i

consist of but not limited to thel

..of'the LP&L lead auditor who is qualified to ANSI following:

N45.2.23-1978..

Validate'that Ebasco reviewed the nonconforming conditions and

.provided justification where necessary for.the dispositioning of the NCR.

3) Verify that objective ewidence

3) 'Same as Item 2.

exists to support statements of fact made in the response.

ATTACHMENTS:

1) Process Flow Chart - Nonconformance teport Review

2) Process Flow Chart - Specific NCR Review 3)

Process Flow Chart - Mercury NCR Review

4) Process Flow Chart - Review of DRS G

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ATTACHMENT 1 PROCESS FLOW CHART LP&L NON-CONFORMANCE REPORT REVIEW i

The LP&L QA Representative (or his designee) performs a closure review per Work Instruction 6.1 of assigned'NCR's and documents the evaluation.

Potential ~ deficiencies are forwarded to EBasco QA for further evaluation or corrective action.

l-Ebasco performs. a review and re-opens NCR if necessary,_and initiates corrective action to_close valid deficiencies or explains why the _NCR disposition is satisf actory as-is.

LP&L QA Representative re-evaluates the results of Ebasco disposition a'nd documents the' review accordingly.

Field verification of randomly' selected NCR's was performed by LP&L QA and documented

• accordingly.

2 C

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J ATTACHMENT 2

-PROCESS FLOW CHART-

-SPECIFIC NCR REVIEW REVIEW NCRs IDENTIFIED BY CONCERN FOR TROPER DISPOSITIONING AND SPECIFIC CONCERNS RAISED BY THE NRC r

DETERMINE IF ANY OF THE END

-ATTRIBUTES'ARE VALID NO REVIEW NCRs ARE DEFtCIENT YES DETERMINE IF THE VALID

,END ATTRIBUTE (S) HAS SAFETY NO REVIEW SIGNIFICANCE YES 4

V l

DISPOSITION AND RESOLUTION 0F SAFETY SIGNIFICANCE j

sr END REVIEW e

9 6-5

=-

ATTACHMENT 3 PROCESS FLOW CHART-MERCURY NCR REVIEW DEVELOP LISTING OF MERCURY NCRs WHICH WERE NOT UPGRADED TO EBASCO NCRs sr YES DETERMINE IF NCR WAS NON-SAFETY-

-NO

,r

'r DETERMINE IF MERCURY NCR DETERMINE IF MERCURY END YES WAS PROPERLY PROCESSED NCR WAS DISPOSITIONED NO END 4

REVIEW PER~ MERCURY PROCEDURE AS " ACCEPT-AS-IS" REVIEW

'SP-664 IN EFFECT AT TIME OF NCR ISSUANCE YES a

INCLUDING SUPPORTING DOCUMENTATION AND HARDWARE VERIFICATION NO r

EVALUATE FOR CONCURRENCE WITH " ACCEPT-AS-IS" YES_

END DISPOSITION REVIEW NO 3r UPGRADE TO A CIWA/NCR AND PROCESS AS SUCH

,r END REVIEW o

6-6

7-ATTACHMENT 4 PROCESS FLOW CHART-REVIEW OF DRs IDENTIFY DRe CITED BY CONCERN

+

. REVIEW DRs FOR SPECIFIC CONCERNS RAISED BY NRC 4

DETERMINE IF ANY NO END OF THE DRs ARE REVIEW DEFICIENT YES n

DETERMINE IF THE 9

DEFICIENCY HAS NO END SAFETY SIGNIFICANCE

?

REVIEW YES DISPOSITION AND RESOLUTION OF SAFETY SIGNIFICANCE

+

END REVIEW k-O e

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a PROGRAM PLAN ISSUE:

10' DATE:-

'10/31/84' TITLE:

In pector Qualification (J.A. Jones and Fegles)

DESCRIPTION OF ISSUE:

i

.Varify the proper certification of QA/QC personnel and'evaluateithe impact of any deficiencies found.

~

LP&L APPROACH TO RESOLUTION:

A varification program has been' established to review the professional credentials of 100% of the site QA/QC personnel

' fcr J.A. Jones and Fegles, including supervisors and managers who performed safety related functions at Waterford III

-during its construction. Criteria for certification or qualification of QA/QC personnel will be based on ANSI i

N45.2.6-1973 and SNT-TC-1A for QC inspection personnel and-construction QA program requirements for-QA personnel.

i' In addition,. background investigations have been performed for all.QA/QC personnel.

If qualification on an individual cannot be verified, appropriate site nonconformance-documentation will be initiated to document evaluation of safety i

significance and corrective actions, including reinspection of work performed as necessary.

WORK INSTRUCTIONS AND PROCEDURES EMPLOYED:

COMPANY

. PROCEDURE NUMBER TITLE s

Ebasco QAI No. 32 Instructions for Verifications of QA/QC Personnel-Qualifications.

l l

LP&L QASP 19.12 Review of. Contractor QA/QC Personnel Qualification

- Verification.

l QASP 19.13

. Response Validation

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ORGANIZATIONS INVOLVED:

CRGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS Ebs co-(1) Verify Education / Experience of' (1) Training Requirements to'QAI-32.

QA/QC personnel.

(2) a.

Review program requirements of (2)

Ebasco's Quality Resources Training Manual-1-(QRTM-1)

J.A. Jones and.Fegles, and delineates the requirements for. qualifying records a

identify inspectors whose reviewer.-_QAI-14 " Training'and Qualification-qualifications are not Requirements for-Quality Assurance Records Personnel" verifiable.against ANSI endorses QRTM-1 and requires all reviewers have N45.2.6-1973, SNT-TC-1A and QA training on procedures they are' reviewing to.

For program requirements for QA qualification / certification files training personnel.

requirements are QAI-32 and ANSI N45.2.6.

b.

Determine, to the extent l-feasible, inspections i

performed by personnel whose qualifications are not l

verifiable, i~

c.

Disposition Quality i

Documentation generated by LP&L in item-(5) below.

LP&L (1) Audit Ebasco's implementation"on (1) (a)' indoctrination / training to LP&L and Ebasco j

QAI-32.

procedures, ANSI N45.2.6-1973 and 1978, ANSI N45.2.23-78, SNT-TC-1A-75 and interpretations.

2 i

j (b) Orientation as to task objectives, organizations, j

and' associated responsibilities and duties.

(c) OJT for three days to assure knowledge, understanding, and proficiency demonstration.

1 (d)

Individuals selected have inspection related j

and/or were involved in the training / certification-

)

or review.

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ORGANIZATIONS INVOLVED:

(Continued)

ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREME}'TS (1) (e) _ Personnel involved in this process.have not worked for Ebasco, J.A. Jones, or Fegles.

(2) Review all those verified by (2)

See Item 1 above.

Ebasco.

(3) Sample Education / Experience (3)

See Item 1 above.

verification of J.A. Jones and Fegles performed by Ebasco.

(4) Perform final management (4). Review Board --Three Senior LP&L QA personnel determination of the qualified to ANSI N45.2.23 (1978).-

qualifications of individuals who are potentially unqualified.

3 (5)

Initiate suitable quality (5) LP&L lead auditor who is qualified to ANSI N45.2.23 documentation in cases where (1978).

inspections were performed by personnel where qualifications I

could not be verified.

(6) Make final determination on (6) LP&L,QA and Project Management.

dispositioning of quality documentation mentioned in (4) above by Ebasco.

(7) Validate response per QASP 19.13. (7) Validation will be performed under the direct to assure positive statements of supervision of the LP&L ledd auditor who is qualified fact are substantiated.

to ANSI N45.2.23 (1978).

Throphilus, Inc.

(1) The purpose of the Theophilus, (1) Previous experience with regard to performing Inc. assessment was to provide a regulatory inspections in the area of inspection and totally independent evaluation of

. testing personne). Previous qualification to ANSI the qualification of inspectors N45.2.23-1978.

determined to be potentially not qualified by the LP&L Review Group and potentially qualified by the LP&L Review Board.

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• ATTACHMENT I FLOW CHART-INSPECTOR QUALIFICATION REVIEW LP&L Review LP&L Review Board Theophilus, Inc.-

Group Determinations Determinations Review Final Results Qualified Qualified A

4 Administrative i Qualified

Background

4 Deficiency Only L

r Verification (Q alified)

File Merger V

Not Inspector Files Qualified Reviewed From f

Qualified Ebasco & LP&L V

Potentially Qualified Not Not Qualified Qualified r

r qr Indeterminate Not CAR 4

(Considered Not Qualified g

Written &

Qualified)

Dispositioned Not M

Qualified 10-5

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PROGRAM PLAN ISSUE:

20 DATE:

10/31/84 d

TITLE:

Construction Materials Testing (CMT) Personnel Qualification Records.

DESCRIPTION OF ISSUE:.

Varify the proper certification of construction materials testing personnel.

LP&L APPROACH TO RESOLUTION:

CEO has been contacted to assist in providing. additional background information or justification for qualification of QA/QC personnel identified as part of NCR W3-F7-Il6.

A vsrification program has been established to review the. professional. credentials of 100% of the GEO CMT site QA/QC pareonnel, including supervisors and managers who performed safety related functions at Waterford III during its construction. Criteria for certifications or qualification of QA/QC personnel will be based on ANSI N45.2.6-1973 and SNT-TC-1A for QC inspection personnel and construction QA program requirements for QA personnel.

In addition background investigations will be performed for personnel in all groups.

If qualification of an individual cen not be verified, appropriate site nonconformance documentation will be initiated to document evaluation of safety significance and corrective actions, including reinspection of work performed as necessary.

For GEO QC Inspectors remaining on site, a reverification is being completed of proper qualification in accordance with ANSI-N45.2.6-1973.

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L WORK INSTRUCTIONS AND PROCEDURES EMPLOYED:

COMPANY

-PROCEDURE NUMBER TITLE' Ebsaco QAl No. 32 Instructions for Verifications of QA/QC Personnel j

Qualifications.

l LP&L QASP 19.12 Review of Contractor QA/QC Personnel Qualification i

Verification.

1 i

QASP 19.13 Response Validation ORGANIZATIONS INVOLVED:

ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS Ebn co

1) Verify Education / Experience of QA/

1) Training requirements to QAI-32..

4 QC personnel.

I 2a) Review program. requirements of GEO,

2) Ebasco's Quality Resources Training' Manual-1 (QRTM-1) review and collect data and delineates the requirements for qualifying records i

j identify inspectors whose reviewer. QAI-14 " Training and Qualification 1

qualifications are not verifiable Requirements for Quality Assurance Records Personnel"

)

against ANSI N45.2.6-1973.

endorses QRTM-1 and requires all reviewers have training j

SNT-TC-1A and QA program on procedures they are reviewing to.

For qualification /

l requirements for QA personnel.,

certification filed training requirements are QAI-32 and ANSI F45.2.6.

d b) Determine, to the extent feasible, inspections' performed by personnel whose qualifications are not verifiable.

c) Disposition quality documentation j

. generated by LP&L in item (5) l below.

i j

LP&L

1) Audit Ebasco's implementation of

1) (a) Indoctrination / training to LP&L & Ebasco QAI-32.

procedures, ANSI N45.2.6-1973 & 1978, ANSI N45.2.23 -

j 78 SNT-TC-1A-75 & interpretations.

i (b) Orientation as to ta,_ objectives, organizations, and associated responsibilities and duties.

i 20-2 e

7

.s.

'h.

.~ -

ORGANIZATIONS. INVOLVED: (CONT'D)

'(RGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS'

^

LP&L

. Cont'd-(c) OJT for three days to assure knowledge, understanding, and proficiency demonstration.

(d) Individuals selected have inspection related and/or were involved in the training / certification or review of inspection personnel types.

(e) Personnel involved in this process have not worked for Ebasco or GEO.

2) Review all'those verified by

2) See Item 1 above.

Ebasco.

3) Sample Education / Experience

3) See Item 1 above.

verification of GEO performed.by Ebasco.

.4) Perform final management

4) Review Board - Three Senior LP&L QA personnel' qualified determination of the qualifications to ANSI N45.2.23 (1978).

of individuals who are potentially unqualified.

5) Initiate suitabic quality

5) LP&L' Lead Auditor who is qualified to ANSI N45.2.23-documentation in cases where (1978).

inspections were performed by personnel where qualifications could not be verified.-

6) Make final determination on

6) LP&L QA and Project Management.

dispositioning of quality documentation mentioned in 4) above by Ebasco.

7) Validate response per QASP 19.13 to 7) Validation will be performed under the direct assure positive statements of fact supervision of the LP&L Lead Auditor who is qualified to are substantiated.

ANSI N45.2.23 (1978).

20-3

_Si..

ORGANIZATIONS. INVOLVED:.(CONT'D)

ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS.

Th:ophilus, Inc.

1. The purpose of the Theophilus, Inc.-

1. Previous experience with regard to performing regulatory, assessment was to provide a totally inspections in the area of inspection and testing' independent evaluation of the

' personnel.

Previous qualification ANSI N45.2.23-1978.

qualification of inspectors determined to be potentially not qualified by the LP&L Review Group and potentially qualified by the i

LP&L Review Board.

ATTACHMENTS:

1. Flow Charr.- Inspector Qualification Review 1

l t

e 4

I i

4 20-4 i

o

_9 9.

ho 9

ATTACHMENT 1 FLOW CHART-INSPECTOR QUALIFICATION REVIEW'

~

LP&L Review LP&L Review Board Theophilus, Inc.

Group Determinations Determinations Review Final Results 1

Qualified Qualified 4 k Administrative d

Qualified

Background

g Deficiency Only y

Verification v

(Qualified)

File Merger V

Not inspector Files Qualified Reviewed From 4

Qualified l

Ebasco & LP&L i

9F I

Potentially Qualified Not d

Not Qualified I

Qualified U

j Indeterminate Not CAR 4

(Considered Not 4 Qualified g

Written &

1 l

Qualified)

-k Dispositioned Not j

M Qualified j

20-5 4

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't

-RESPONSE

- ITEM NO:'

-, 1= -

' TITLE:

-Inspection Personnel Issues

~

NRC DESCRIPTION OF CONCERN:

.: As 'a partf of ' the -NRC1 staff's. review,- the credentials of quality assurance and

- quality. control inspectors were - examined.

Included in this ef fort - were the

-verification 7of-previous _' job experience and qualifications and certification of spersonnel as inspectors.

The followiAg items were found.

(1)1 'NRC reviewed inspector certifications for 37 cf 100 Mercury QC inspectors, including T certifications for all. Level III - personnel.

Twelve inspector certifications 7 were found questionable - due-to insufficient education or experience.--

=(2) ~ The certification records of 38 Tompkins-Beckwith (T-B) LQC inspectors were selected ' at random and reviewed. ' Fourteen inspector certifications were found questionable ~due to insufficient education or experience' 1(3) ' A. 30% sample by the staff of inspector certifications of '. the Mercury QC -

work force. revealed!that no' verification of past employment.was documented.

'A: sample by.the staff:of inspector certifications of the Tompkins-Beckwith-

.QC work force produced similar-results.

The? safety significance of these findings is that ; unqualified -inspectors may c

have -- inspected safety-related systems, thereby rendering ~ 'erification of the v

.. quality of-t.hese systems indeterminant. LP&L shalli (1) verify _the professional s credentials.. of 100% of _ the ' site..QA/QC.- personner, - including supervisors - and.

~

managers, -(2) reinspect 'the work performed by inspectors found unqualified, and -

(3) verify the, proper certification of - the remaining site QA/QC personnel to ANSI N45.2.6-1973.

DISCUSSION:

.e JA'. verification program was' implemented to review the professional credentials of 100% 'f'the. site QA/QC personnel who may have performed safety-related functions o

at Waterford.3, concentrating on inspection personnel and including supervisors,

' managers'and remaining QA/QC personnel.

Thisverificationprogramincluded.theQA/QCpersonnelofalh.siteorganizations

.which_ performed safety related functions.

Personne'l from-the following organizations will be addressed in this response:

(1) -LP&L (9) Gulf Engineering

-(2) Ebasco-(10) Mercury Company of Norwood (3)--American Bridge, (11) Nisco (4)' B&B Insulation ~

(12) Nooter (5) Chicago Bridge & Iron (13) Sline (6) Combustion Engineering (14) Tompkins-Beckwith (7) Fischbach and Moore

.(15) Waldinger l-(8): CEO-(NDE)

L i

1-1 f -. -

A

p y

~

The r:cp;n ca to Iseuna No. - 10 cnd 20 discuas inepsetor qualifications for-Fegles, GEO (CMT) and J.A. Jones QA/QC personnel.

The program, which is being performed under the overall - direction of LP&L, consists of three. major elements:

,a Collection and verification of. personnel data.

Evaluation.of qualifications against-specified standards.

o-Dispositioning of deficiencies resulting from cases where inspections o

and tests were conducted by personnel whose qualifications against the

< appropriate standards could not be confirmed.

Collection and Verification of Personnel Data

'Most~of.the contractors which performed safety related work on Waterford 3 have demobilized.

Personnel data was collected from various sources, including site files, contractor home office files, personal contact with individuals or supervisors and through a background verification program.

Personnel ' data for LP&L QA/QC personnel was compiled under the supervision of LP&L. Personnel data for Ebasco QA/QC personnel and that of the QA/QC personnel of other site contractors was compiled under the supervision of Ebasco.

,y Efforts : vere made to -verify the education and work experience of 100% of the

site QA/Q personnel by researching Waterford 3 contractor. records and by contacting schools, former employers and others.

The background verification

~

' effort for site subcontractor personnel was a joint 'LP&L/Ebasco effort.

LP&L.

. performed the verification of the backgrounds of its own empl'oyees and of Ebasco employees...Ebasco personnel were used to some extent in.this effort under overall LP&L control. LP&L also audited and sampled the background verification performed by Ebasco. While the success rate of this effort was good, there were cases where confirmatory information was not obtainable.

In such cases, the judgement of the LP&L Review Board, es described below, was used to rule on the reliability of the available information.

Evaluation of Qualifications to Specified Standards QA/QC personnel data were evaluated in order to classify individuals as either i

having verified qualifications or not.

Training, education'and work experience were the qualifications of primary concern.

These qualifications were verified against the following criteria:

(1)

Inspectors - ANSI N45.2.6-1973 (2) NDE Personnel - ANST SNT-TC-1A 1968 or 1975, as appropriate.

(3) Other QA/QC Personnel - QA Program requirements (4) Operational QC Personnel - Regulatory Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) 1-2

Initici - qunlificctica datarmint.tions for Ebuco cnd LP&L QA/QC parsonnsl wara performed by an LP&L review group.

Initial qualification determinations for QA/QC personnel of other contractors were performed first by Ebasco and then separately by the LP&L review group.

In order to control the consistency of these determinations, approved procedures were utilized. Determinations related primarily to balancing education, experience and training factors.

The LP&L review group qualification determinations were rendered in two categories:

" qualified" and "potentially not qualified".

"Potentially not qualified" determinations were referred to an LP&L Review Board comprised of senior LP&L QA personnel. The Review Board determinations were further reviewed by a consultant very familiar with inspector qualification and related standards.

This process resulted in a final determination for all QA/QC personnel as either " qualified" or " unqualified".

In addition to the redundant reviews indicated above, LP&L has specifically requested the-NUS/UNC Pre-Licensing Issues Task Force to verify the qualifications to applicable standards of all LP&L QA/QC personnel and to sample Ebasco QA/QC personnel.

The qualification review process is described in QASP 19.12 and QAI-32.

The following points further clarify the process:

1.

The meaning of the term " unqualified" must be amplified.

In some cases determinations were made that,. based on verified

data, individuals' backgrounds did not warrant qualification to ANSI N45.2.6-1973.

In other cases, however, individuals were considered

" unqualified" as an expedient in reaching resolution to the concern.

This occurred in cases in which:

a.

Research of records, inquiries to past employees, contact with schools and verification of training' received was either not possible or could not be concluded in a reasonable period of time.

b.

Apparent discrepancies existed between background information provided by some individuals and that obtained in the verification process, and resolution could not be achieved on a a

timely basis.

Minor discrepancies were' excused;

however, significant discrepancies generally rendered any other 1

significant but unverified data as suspect.

2.

In the process

used, being judged as

" unqualified" to ANSI N45.2.6-1973 did not automatically render the individual's work as invalid.

For example, an individual may not' have the education and experience qualifications for all inspection work, yet be fully competent through specific training or other means to perform the particular tasks assigned to him, which might have been very simple and repetitive in nature.

Such an individual potentially satisfies ANSI requirements,,which ultimately require that an individual's qualifications be sufficient to provide reasonable assurance that the individual can competently perform a particular task.

Whether or not the individual is technically qualified, the individuals' work can be deemed valid.

1-3

m -

-3..

During _ the construction - period, some contractors made undocumented

-judgements with respect to the need for eye examinations for

.' inspection personnel.

Such judgements were based on the level of visual, acuity _ or - color perception required to achieve competent inspections.

Such judgements_ were also made as part of the 7 verification program and disposition process and will be documented.

It is noted that such judgements are specifically suggested in ANSI N45.2.6-1978. This factor was not deemed disqualifying.

4.

Some individuals were classified as inspectors but performed no safety related inspections.

To the extent such individuals were identified, they were excluded from the overall inspector popula' tion.

Disposition of Deficiencies For' each contractor which performed safety related work, the LP&L Review Board compiled a list of " unqualified" inspector personnel, and Corrective Action Requests (CAR)- were written to-formally track and disposition potential deficiencies.

Disposition of such documents may require research into inspections performed by individuals, further research into an individual's background, reinspection, engineering evaluation, analysis of previous reinspections or proof tests (NDE, hydrostatic -tests), statistical analyses or rework in order to assure acceptability of the plant components inspected by the personnel. in question.

Determination of the method of dispositioning is on a case:by case basis.

For ' most contractors who performed safety related work, the disposition of deficiencies generally has not-required a large degree of reinspection.

In the case of Mercury, substantial reinspection was initiated, particularly the N1

. instrumentation. tubing installation.

The N1 instrumentation has been found acceptable nwith no significant - rework identified.

In other isolated cases,

-reinspection-was-also deemed appropriate.

To

date, such reinspected

. installations have been found acceptable and no rework has been required.

Included in ' Attachment

1. are the verification program results for Mercury, Tompkins-Beckwith, NISCO, GEO (NDE), American Bridge, Chicago Bridge & Iron and Combustion-Engineering QC inspectors and explanations of how resultant deficiencies were resolved.

Limited background verificatiori efforts remain for these contractors' personnel.

Should completion of the verification cause a change in the results, the response will be amended accordingly.

Supplements to this. response for the remaining contractor personnel, including QA personnel for all contractors, will be provided as they are completed.

Remaining Site QA/QC Personnel a

The qualifications of personnel currently performing QA/QC functions on site are being verified under the verification program.

o e

1-4

1 CAUSE:

ANSI N45.2.6-1973 allows substitution for education and experience levels by noting that "... education and experience requirements specified for the various levels should not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a particular task."

Waterford 3 contractors, to varying degrees, employed such substitutions in certifying the qualifications of their QA/QC parsonnel.

However, the verification program revealed that verification of background data was not adequate or documented, documentation of the justificaticn for substitution was sometimes not provided or lacked depth, and/or was not always totally in accord with contractor procedures or the ANSI Standards, as currently interpreted.

GENERIC IMPLICATIONS:

This issue has been treated generically.

The scope of the verification program included 100% of the QA/QC personnel of all site contractors who performed safety related work.

With regard to future work, qualification and certification of inspectors (including hTE personnel) will be administered through strict ccmpliance with LP&L Nuclear Operations Procedures which meet the requirements of Regulatory Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) and SNT-TC-1A-1975, as applicable.

SAFETY SIGNIFICANCE:

-The results, to date, of the effort employed in responding to this issue further confirm the many other methods (including independent (ANI, etc.) inspection, nondestructive

testing, prerequisite /preoperations/ integrated

testing, and special analyses) employed at Waterford 3 to gain adequate confidence that the Waterford 3 systems, structures, and components will perform satisfactorily in service.

Satisfactory disposition of corrective action documentation, generated as a result of. the verification program, will provide adequate assurance that the installed structures, systems and components will perform satisfactorily in service.

L CORRECTIVE ACTION PLAN / SCHEDULE:

Actions required to disposition corrective action documentation generated as a result of the verification program are in progress.

To date, no items of safety significance have been identified.

Priority attention has been given to completion and dispositioning of QC (inspector) issues, since actual inspections have a more direct bearing on the quality of the constructed plant.

Non-inspector personnel qualification issues, and the inspectors for the remaining contractors, will be addressed in supplements to this response.

It is currently anticipated that the dispositions of QA/QC personnel qualification issues will be completed by November 21, 1984.

ATTACHMENTS:

Verification Program Results and Disposition of Deficiencies, by Contractor.

REFERENCES:

1.

QASP U.12, Review of Contractor QA/QC Personnel Qualification Verification 2.

QAI-32, Instructions for Verification of QA/QC Personnel Qualifications 1-5

ATTACHMENT 1

]

SITE ORGANIZATIONS WHICH PERFORMED SAFETY RELATED WORK

• INDEX A.

LP&L B.

Ebasco C.-

American Bridge D.

B&B Insulation E.

Chicago Bridge & Iron F.

, Combustion Engineering G.

Fischbach and Moore H.-

GEO (NDE)

I.

Gulf Engineering J.

Mercury Company of Norwood K.

Nisco L.

Nooter M.

Sline N..

Tompkins - Beckwith 0.

Waldinger.

8 S.

• Fegles, CEO (CMT) and J.A. Jones are included in Items No. 10 and 20.

o 9

1-6

T.

c

' ATTACHMENT'1 A.

'LP&L

. 1..

On-Site Dates: April 1975 to.present 3

22 Scope of' Work:

Owner 3.1 -Scope of Inspection:

. a.

c Construction Phase' - Reinspection of selheted construction activities..

b.

Startup Phase - Inspection of designated startup activities.

c..

Operations Phase - Inspection during:

1)

Maintenance 2)-

Modifications 3)'

Repair 4)

Material Receiving 5)

Storage Activities' 4..

QA Program Requirements:

a.~

INSPECTORS 1)

Construction Phase a)

ANSI.N45.2.6 - 1973

~

-b)

-QASP 2.12 "QA Section: Qualification and Certification of Inspection Personnel"

~

2).

Startup Phase a)

ANSI N45.2.6 - 1978(Regulatory Guide 1.58,

~

Revision 1, Sep.tember'.1980) 3).

Operations Phase-a)-

ANSI N45.2.6 - 1978(Regulatory Guide 1.58 Revision 1, September 1980) b)'

QI-010-001 " Inspector Qualification" b.

AUDITORS-s

'4 1)

Construction Phase a)

' ANSI N45.2.23 - 1978(Used as guide only)

+

b)

QASP 2.3 " Qualification and Certification of Audit Personnel" s

2),

Startup Phase a)

ANSI N45.2.23 - 1978(Regulatory Guide 1.146-1980) b)

QASP 2.3 " Qualification and Certification of Audit Personnel" 3).

Operations Phase a)

ANSI N45.2.23 - 1978(Regulatory Guide 1.146-1980) b)

QASP 2.3 " Qualification and Certification of Audit Personnel"

- 5.

' Inspector Qualification and Dispositioning of Deficiencies:

i (In Progress) i A-1 t

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= -- w w y,,-,,-

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. ATTACHMENT 1

.B.

~EBASCO O

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April 1972 to present.

-e 6

1.-

-On-Site Dates:

j 2.'.

3 cope of Work:

i 4

Architect / Engineer' 3

-a.

-b.-

Construction Management-4

-c.

Installation and Construction

-3.

Scope of Inspection:

.a.

Receiving Inspection b.

Surveillance of Contractor activities

-c.

Inspection of Ebasco installation and constructicn (all disciplines)

E.

Independe'nt QC inspection of construction activities through d

1977.

i4.

'QA Program Requirements / Contractual Commitments:

a. -

QAE Personnel Basic Site ~ Orientation or QA and Safety Orientation b..

Quality Management / Supervisors i Basic Site Orientation,or RA and

' ~

Safety Orientation.

.c.

. QA Auditors - Ebasco Procedure QA G.3, "Qualif'ication of.QA Audit Personnel". Qualification requirements are based on_ education, nuclear.

experience, related Engineering, or ' manufacturing exparience and professional credentials.

~d.

- QA Records Reviewers '- Ebasco Procedure QAI-14. "Iraining "and Qualification Requirements for Quality Assurance Records Personnel". Qualification requirements are high school' graduate or G.E.D., QA Indoctrination, procedural. training,' and on-the-job training.

e.

' Nondestructive Testing Personnel - SNT-TC-1A and Ebasco Procedure NDE-1, "Ebasco Service Incorporated Procedure for Trdining, Examination, and

~

~

Certification of Nondestructive Examination Personnel".

QC Personnel -- ANSI N45.2.6,- 1973 and Sasco Procedure ASP-I-3,

" Indoctrination and Training"..

r tor Qualification and Dispositinning of Deficiencies:

S

ss) s 4R G

8 x

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3 B-1

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TT

[-

i-ATTACHMENT 1

-C.

AMERICAN BRIDGE 1.:.On-Site Dates: March 1977 to May 1980 2.

Scope of Work:

- Erection.of main and miscellaneous structural steel in the following areas; reactor building, ' reactor auxiliary building, fuel handling building, cooling tower area, turbine generator ' area, circulating water system and construction trestle.

3.-

Scope of Inspection:

l a.

Receiving inspection (upon aeceipt from Ebasco warehouse).

b.

= Fit-up, in-process, and final - visual inspection of welds on structural steel.

Inspection of high strength bolting, including torque inspection.

c.

d.-

Inspection of installation of expansion type concrete anchors.

Calibration.of inspection and testing equipment.

e.

f.

Housekeeping inspection.

. 4.

,A Program Requirements / Contractual Commitments:

Q a.

QA Personnel except Auditors - ANSI N45.2.6 and Procedure 14. " Personnel Training and Qualification".

b.

QA Auditors - ANSI N45.2.23, Quality Assura'nce Manual Section 1.18 and Procedure 8 " Audit Procedure".

c.

QC Inspectors - ANSI N45.2.6 and Procedure 14 " Personnel Training and Qualification".

5.

. Inspector Qualification and Dispositioning of Deficiencies:

'All American. Bridge QC inspectors are determined to have been qualified.

.v m

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t 3 ATTACHMENT 1 D.

B&B INSULATION L

1.

On-Site Dates: April 1982 to Present 2.

Scope of Work:

. Installation of penetration, radiation shields, fire stops, and air a.

seals.

b.-

Installation of ventilation equipment providing ventilation for curing pe'etration seal materials, n

c.

Installation of flexible boot seals.

d.

Seal internal conduit seals.

e.

Drill holes in flange of EVAC penetration for sealing material.

f.

Installation'of protective envelop for cable tray, conduit, cable airdrop and junction boxes.

3.

' Scope of Inspection:

a.

Material Receiving Inspection b..

Inspection performed on Electrical Cable Tray and Conduits are as follows: ;

1.

Penetration Seals Inspection

. 2.~

Cable Tray Wrap Inspection 3.

Fire Protection-Inspection 4.

QA Program Requirements / Contractual Commitments:

a..

QA Personnel - No procedural requirements for qualification.

b. :

QC Inspectors - B&B Procedure QCP-0010 "Certificarion of Inspection and

~

Examination Personnel", which meets the intent of ANSI N45.2.6.

i 5.

Inspector Qualification and Dispositioning of Deficiencies:

(In Progress) 4 O

e o

D-1

ATTACHMENT 1 E.

CHICAGO BRIDGE & IRON

~ 1.

On-Site Dates: June 1976 to April 1978 2.

Scope of' Work:

a.

Erect Steel Containment Vessel complete with all appurtenances, equipment hatches, personnel locks and penetrations.

b.

Post-weld heat treat Steel Contaiament Vessel. -

c.

Test Steel Containment Vessel.

d..

Purchase Order includes applicable NDE.

e.-

Purchase Order, also covers design, fabrication, delivery, and handling of Steel Containment Vessel.

3.

Ccope of Inspection:

a.

Receiving inspection.

b.

Visual inspection of welds; fit-up, in-process, and final weld.

c.

Perform and evaluate NDE of welds (MT or LP and RT, as applicable).

d.

Dimensional inspection.

Witness and evaluate site testing within CB&I work scope.,

e.

f.-

Assure calibration of jobsite M&TE ci.s performed within CB&I work scope.

g.

. Test of Steel Containment Vessel includes Soap Bubble Tests.

Overhead Pressure Test, Leak Plate Tests (including personnel

. locks) and operational testing.

4.

QA Program Requirements / Contractual Commitments:

a.

QA Personnel - CBI Procedure TIP-1, " Training Indoctrination and Qualification Program". This procedure references CBI's QA manual Appendii-C for auditors and Appendix J for NDE-personnel.

NDE personnel are certified to SNT-TC-1A requirements.

b.

QC Personnel - CBI Procedure TIP-1, " Training Indoctrination and Qualification Program".

5.

Inspector Qualification and Dispositioning of Deficiencies:

All Chicago Bridge &. Iron QC Inspectors are determined to have been

(

-qualified.

~

e I

[

E-1 k

I

_a

ATTACHMENT 1 F.

COMBUSTION ENGINEERING 1.

On-Site Dates: March 1982 to January 1984 2.

Scope of Work:

a.

Provide Reactor Vessel Internals ir:stallation assistance.

.L.

Perform related work.

c.

.Related work includes installation procedures, technical direction, MFR., services and drawings, provide QA personnel, alignment meets requirements of C-E reactor vessel internals installation manual.

3.

Scope of Inspection:

a.

Work by contractor subject to inspection and testing by Owners Testing Lab.-

b.

Administrative functions by contractors.

4.

QA Program Requirements / Contractual Comnitments:

All QA/QC Personnel - Training to CE Avery Division QA Program, a.

Standards, Specifications,

Codes, QA responsibilities and documentation.

b '.

QA Auditors - Orientation and training, examination, on-the-j ob training, and maintain proficiency through active participation.

c.

Records Control Personnel QC Software

training, time requirements are based on level of certification.

d.

Inspector Personnel Visual Inspection SNT-TC-1A and Dimensional and Mechanical ANSI N45.2.6.

5Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

Inspector Qualification and Dispositioning of Deficiencies:

All* Combustion Engineering QC inspectors are determined to have been qualified.

F-1

-..,---,n,

ATTACHMENT 1-G.

FISCHBACH AND MOORE 1.

On-Site Dates: May 1977_ to December 1983 2.

Scope of Work:

Installed safety and non-safety equipment,~ accessories, raceways, a.

cable and non-vendor furnished interconnection between equipment, t

connections to all equipment, accessories and devices.

b.

Installed seismic and non-seismic conduit, traf'and box supports (AWS D1.1)..

c.

Installed expansion anchors and bolting of structural steel.

3.

Scope of Inspections:

a.

Material Receiving inspection, b.

Support fit-up and final visual inspection.

c.

. Inspection of installation of equipment.

d.

Inspection of' routing and connection of trays and conduit.

'a.

Inspection of routing and termination of cable.

f. -

Inspection for proper bolting (Torque and tension testing).

g..

Megger/ continuity testing of cable and equipment.

4.

.QA' Program Requirements / Contractual-Commitments:

n.

QA Personnel - 10CFR50 Appendix B and ANSI N45'.2.

-b.

QA Auditors Personnel Documented' experience of previous b.

auditing, orientation, and ' training' in QA program, procedures, and activities to be audited.

c.

Inspector Personnel ANSI N45.2.6 and Fischoach & Moore Procedure QAP-101W3, " Personnel Qualification and Certification".

l

'5.

Inspector Qualification and Dispositioning of Deficiencies:

(In Progress)

[

t b

6 I

e G-1

m ATTACHMENT 1 H.

GEO (NDE) 1.

On-Site Dates: May 1977 to Present 2.

Scope of Work:

a.

Performance of Nondestructive examination of items and welds designated by the Client.

b.

Process and evaluate test results.

c.

Prepare reports.

d.

Identify defects.

3.

Scope of Inspection:

a.

Nondestructive examination methods include but are not limited to: Radiography, Magnetic Particle, Ultrasonic, Liquid Penetrant, and Lead Detection.

b.

Client has. final acceptance or rejection of welds.

Although leak detection was included in G2,0 scope of work, GE0 c.

was not required to perform any tests.

4.

QA Program Requirements / Contractual Commitments:

a.

QA. Personnel except Auditors - No Procedural requirements for qualification.

b.

QA Auditors - GEO Procedure 5.2, " Qualification and Certification of Audit

+

Personnel" which references ANSI N45.2.23.

c.

Nondestructive Examination Personnel - SNT-TC-1A and GEO Procedure GEO-2.3,

" Qualification and Certification of NDE Personnel".

5.

Inspector Qualification and Dispositioning of Deficiencies:

The verification program identified one (1) _ GEO (NDE) individual who performed radiography tasks and whose qualifications were determined l:

as - not meeting the requirements of SNT-TC-1A.

Corrective Action Report EQA84-14 was initiated to track the disposition of this deficiency.

It has been determined that the individual in question performed only field radiography work and was not involved in interpretation of radiographs. Had field radiographs by this individual been defective, this would have been obvious and would have b'een detected during the interpretation of the radiography, which was performed by personnel whose qualifications in accordance with SNT-TC-1A have been verified.

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ATTACHMENT 1 I.

GULF ENGINEERING.

-1.

On-Sita Dates: January 1977 to November 1983 2.-

-Scope of Work:

a.

Install ASME III Safety Class I, II, III, and Non-safety related (B31.1) equipment tank, pressure vessels,.etc.

b.

Install ASME III Class III piping systems.

c.

. Install Seismic Class I supports.

d.

Hydrostatic / Pneumatic ~ testing on all systems erected.

3.

. Scope of Inspection:

a.-

Material Receiving Inspection.

b.

Fit-Up and Final Visual for structural welds, c.

Fit-Up and Final Visual for pipe velds.

d..

Insulation Resistance Testing Inspection - PR-9.2.

e.

-Grouting Inspection PR-ll.l.

14.

QA Program Requirements / Contractual Comnitrants:

a.

QA Personnel with exception of-Auditors - Gulf Engineering QA-Manual Section 20, Indoctrination and Training, Gulf Procedures PR 17.0 and 20.0,

" Indoctrination and Training".

~

-b.

QA. Auditors - ANSI N45.2.23 and Gulf Procedure PR 18.0, " Auditing".

c.

QC Inspectors -. ANSI N45.2.6 and the Gulf Prog' ram requirements listed in-(a).

15.

' Inspector Qualification and Dispositioning of Deficiencies:

'(In Progress) 4

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'1 ATTACHMENT 1-J. MERCURY COMPANY OF NORWOOD 1.

On-Site Dates: September 1978 to November 1983 2.-

Scope of Work:

a.

Intall ASME III P2 and P3 local instrument racks, cabinets, and tubing systems.

b.

Install seismic Class I supports and tubetrack.

c.

Install non-seismic /non-safety instrument air system.

d.

Install non-seismic supports.

e.-

Hydrostatic or air test all tubing erected.

3.

Scope of Inspection:

a.

_ Receiving Inspection b.-

Dimensional Inspection c.-

Structural Inspections d.

Pressure Test Performance e.-

Welding Inspection f.

Piping and Tubing Inspection

1. ?

g.

. Installed Equipment Inspection

~ 4.

QA Program Requirements / Contractual Commitments:

a.

- QA Engineering Personnel - Mercury Procedure QCP-3070, " Personnel Indoctrination and Training".~

b.

Quality Managers / Supervisors - Mercury Procedure QCP-3070, " Personnel Indoctrination and Training".

.c.-

Quality Assurcnce Auditors - Mercury Procedure QCP-3060, Qualification of- "QA Program Audit Personnel" which satisfies the requirements of ANSI N-45.2.23.

d.

QA JRecords Reviewers Mercury procedure QCP-3070,

" Personnel Indoctrination and Training".

e.

' Nondestructive Testing Personnel - Mercury employed no NDE personnel, i

-f.

($

Personnel ANSI N45.2.,6 and Mercury Procedure QCP-3050,

" Qualification of Inspection, Examination and Test Personnel".

~,

5..

Inspector Qualification and Dispositioning of Deficiencies:

^

Using conservative standards as defined in the basic response, preliminary results ~ indic' ate that a significant number of Mer'cury inspectors did not fully meet the ' criteria of ANSI N45.2.6-1973.

The final resu';s of the review of Mercury inspector qualifications will be provided in a supplemental response. Corrective Action Request EQA84-15 was initiated to track the disposition of this deficiency.

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Disp:citien of CAR EQA84-15 in bassd upon tha extsnaive rainspections of Mercury work against established installation criteria and upon extensive testing and engineering evaluation of the as-built installations.

Based on these factors, LP&L has a high degree of confidence in the ability of the installation within the scope of Mercury's responsibility to perform its intended safety functions m'd support safe plant operation.

In light of the extensive verification, this conclusion is justified even if a substantial number of Mercury inspectors do not satisfy qualification requirements.

Attachment No. J-1 provides a matrix of inspection and NDE tests performed as part of the in-process installation activities in Mercury's work scope.

The various reinspection, test and engineering verification activities are also tabulated in relation to the impacted Mercury installations.

~

Attachment No. J-2 is a description of several of the verification activities additionally considered in this assessment.

Attachment No. J-3 is an assessment of safety significance with respect to the findings identified in the N1 installation reinspections recently completed by LP&L.

The figure contained in-Attachment J-4 represents Mercury's work scope pictorially for the categories of installations described above.

Mercury's construction activities which are affected by QC inspector qualifications have been categorized as follows:

A.

N1 Installations N1 installation include tubing, instrumentation and related hardware which perform a function required to mitigate the consequences of a design basis accident and allow the operator to safely shut'down the plant.

B..

N2 Installation N2 installations include tubing, instrumentation and related hardware required ~ to maintain pressure boundary integrity that do not perform a direct plant safety function.

~

~

C.

Seismic Category I Instrumentation Supports, Tube Track, and Instrumentation Stands These installations are required to withstand a safe shutdown earthquake and thus assure the integrity of N1 and N2 installations.

D.

Primary Sampling Piping and Related Supports / Restraints These installatiens consist of Seismic Category 1 pipe supports and ASME Class 2 piping.

J-2

-~.

Verification activities independent of the -initial in-process inspections are discussed in relation to each category of Mercury installation.

' A. -

'N1' Instrumentation-Due to. its ~ importance to safe ~ plant : operations, N1 instrumentation has undergone the most extensive re-verifications of any Mercury installation category. These' verification activities are summarized as follows:

1. -

Reinspections Reinspections peJformed in relation to N1 instrumentation include the Efollowing:.

a.,

N1 Reinspection Program-As a' result the LP&L Review of NRC Issue No. I regsrding Mercury

-QC qualifications, LP&L deemed it prudent to undertake a further extensive reinspection of Mercury work.

Accordingly, LP&L procedure QASP 19.15 was established to reinspect the sensing lines and associated hardware. (e.g. tube track, support, etc.)

for the N1-instrument installations, which perform a

safety-related function and provide a pressure boundary.

The reinspection is, complete and no. discrepancies impacting plant safety; were found.

This reinspection covered most of the installation. attributes which are subject to in-process QC inspections.

Certain attributes such as anchor bolt torquing and weld fitup inspection were not included since reverification cannot be performed without-destroying existing installations.

Such attributes,

however, were' subjected to many in-process inspections and subsequent documentation reviews as is evidenced

_by the numerous NCRs which were dispositioned in these ' areas.

The ' adequacy of Mercury anchor bolt installations was further

. later verified by Ebasco based on the corrective action' required to close NCR 5864.

This NCR required tension test verification of:108 Mercury installed anchor bolts.

An ' evaluation of the reinspection findings was performed for safety ' significance.

The evaluation results and inspection findings are discussed in detail in Attachment J-3.'

It has been concluded ' that, while deviations from established installation criteria were identified, none were, judged to be safety significant.

Further, in relation to. the quantity of items

~

reinspected, the number of identified O screpancies is small.

b.

LP&L QA Inspection of Redundant N1 Instrumentation Impulse Lines for Mechanical Separation This reinspection was performed under direct LP&L supervision in accordance with LP&L Procedure-QASP 19.9.

The inspection required the reverification of mechanical separation requirements for redundant N1 instrumentation installations.

As a result of this program, 2 out of 82 instrument installations inspected were reworked to assure proper mechanical separation.

J-3

4-4 c.

. SCD 57 Correction Action ~ Program This reinspectioni effort commenced.

in

July, 1982, and subsequently involved the reinspection of all N1 and N2 instrumentation installed in full or in part prior to July 1982.

- Although these reinspections may have been performed by some of g

jthe QC inspectors whose credentials are currently suspect, this is mitigated by the fact that Ebasco Engineering participated in the tubing -installation walkdowns.

LP&L QA and Startup also participated in many of the walkdowns.

d.

-Selective Reinspection-Programs Impacting N1 Ittstallation

~Various reinspection programs were initiated by LP&L and Ebasco QA.in relation to. established review programs in the 1982-1983 time frame..These reinspections impacted N1 Instrumentation, and are described as follows:

1)

Ebasco QA Records-Review Program Reinspections During the records review process a limited number of reinspections.were performed in order to reverify specific attributes-related to tubing-installations.

Refer to Attachment.No. J-2'for more detail.

11).LP&L QA Turnover Status Review

- A. ' limited number of field ' verifications were conducted by LP&L QA as part of a system' turnover status review.

These field ' verifications establf.shed a satisfactory level of confidence that.the as-installed conditions were reflective of the - approved installation details.

Refer to Attachment-

~ No.-J-2 for more detail.

2.s Testing.

L

-Various NDE' and l testing programs have been implemented.which provide z

additional assurance with respe.ct to the adequacy of N1 installations.

These programs are summarized as follows:

o a.

Presst e Boundary Tests In ' general, -NI and ASME Class 2 and '3 tubing installacions were integrity tested in accordance with code requirements.

Certain N1 HVAC installations were exempted from integrity testing.

In addition to Mercury QC inspectors ASME integrity tests were

-witnessed by Ebasco, LP&L Startup and QC personnel, and in the case of Class 2 installation, the Mercury WI representative..

b.-

- Non-Destructive Testing i

N1 ASME ~ Class 2 installations welds were subjected to liquid penetrant itests which were performed by an independent r

- contractor (GEO).

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Hot Functional Preoperational Testing During Pre-Core Hot Functional Testing, N1 instrumentation was placed in service under normal; plant operating conditions.

The integrity of these installations was verified under thermal growth and pressure conditions by LP&L.

Instrumentation loop functionality under plant startup and. normal process flow

, conditions was -also verified.

These same systems will again be tested during Post Core Hot Functional Testing, prior to initial criticality.

B.

N2' Installations N2 installations were subjected to many of the came reverification programs. The major LP&L programs which did not involve N2 installations are tha N1 instrumentation reinspection conducted by LP&L (Item A.I.a) and the LP&L QA inspection of redundant NL instrumentation for Mechanical Separation (Item A.l.b).

LThe most noteworthy reverification efforts with respect to N2 installations

' involve the SCD 57 ~ corrective action programs and pre-core hot functional testing programs. The comprehensiveness of these two programs citigate the

-consequences resulting from the QC inspection qualification concerns.

Attachment No. J-3 discusses the justification for not extending the reinspection program conducted under QASP 19.15 (Item A.l.a) to include N2 installation.

-C.

. Seismic Category I Supports, Tube Track and Instrumentation Stands As has been the case. with N1 and N2 installation, Seismic Category I supports, tubetrack and instrumentation stahds have been subjected to various reinspections and verification programs.

The most notable are discussed below.

1.

The -N1 reinspections conducted by LP&L under ~ procedure QASP 19.15

-included reinspections of Seismic Category I supports installed in N1 instrument loops.

Attributes _ inspected. included support location, weld size. and workmanship, anchor bolt embeddient, spacing, and

~

correctness of' hardware installations (i.e.-nut, bolts, washer, etc.).

Approximately 1600 supports were inspected under the program.

l 2.

The Ebasco QA Records Review Program Reinspection

'n 1982-1983 involved The-QC reinspection conducted by Ebasco i

approximately 35% of all Mercury installed instrumentation seismic supports.'

These reinspections. verified support configuration, locations and weld size.

Partial inspection for only certain r.

- attributes (i.e. support type or veld size, etc.) were also conducted.

In addition to Seismic Category I supports, the QA Records review resulted in the full reinspection of 100% of the Seismic Category I instrument stands installed by Mercury and approximately 67% of the l

tube track installation including hardware and welds.

Anchor bolt embedment sud torque were reverified in 896 instances. More detail L

-with respect to the impact of the Ebasco QA records review on Seismic Category I hardware is provided in Attachment No. J-2.

3-5

.D.

Primary Sampling Piping and Related Supports / Restraints This portion of' Mercury work has been reverified in several ways.

These

.'are summarized as follows:

1.-

Reinspection a.

Piping fillet welds were reinspected under SCD 62 which involved

-identification and repair of undersized fillet welds not meeting

. ASME ' Code requirements.

Although. reinspections may have been done by soma - of the same QC inspectors whose credentials are currently - under question. the. impact of their involvement is minimized since at least 2-inspectors looked at each veld, b.

All the Primary Sampling Supports / Restraints were reinspected by Ebasco QC during the QA records review process.

'c.

Both the piping an'd supports / restraints were verified by Ebasco ESSE as part of the 79-14 program.-

d.-

Primary Sampling Supports / Restraint. were reinspected by LP&L QA as part of the QASP-19.7 pipe hanger inspection program..

o 2.-

Testing

~

~

a.

'ASME Code Hydros of Primary Sampling Piping ASME Code hydros were witnesse'd by the Mercury ANI, LP&L Startup and Ebasco Engineering'.

~

b.

Non-Destructive Testing s

Since the primary sample tubing is ASME Class-2, all fillet welds

~

were liquid penetrant tested by GEO.

.c.

Hot Functional Testing (HFT)

During Pre-Core HFT, the P.rimary Sampling System was subjected to normal operating pressure and. temperature conditions.

Formal verification of-the adequacy of installation was documented under the thermal monitoring program. conducted during HFT.

Similar postcore testing will be performed.

L The extent of reinspection testing and engineering verifications conducted in relation to the Mercury installed Primary Sampling System' is so comprehensive that the impact of QC' inspector qualifications is insignificant with respect to plant safety.

SUMMARY

AND CONCLUSIONS ~

e In ' each ' installation category, several reverifica..on and testing activities have. been performed which did not involve Mercury QC inspectors.

When reinspection activities were performed by Mercury QC inspectors, credit is taken in this assessment dua to either of two' factors:

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1.

1he Mercury - QC inspector was. accompanied ' by eithsr an LP&L or Ebasco

. representative or both (eg. SCD 57 walkdowns, hydros, etc.)

2.

-The reinspection was a duplication of previous reinspections, and thus the-

. impact of inspector qualification to ANSI N45.2.6-1973 is minimized.

In conclusion, the extent to which Mercury installations were reverified by either. testing, reinspection or engineering verification, substantially independent of the Mercury QC inspection proc ~ess, provides sufficient confidence that safety related instrumentation has been properly installed.

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ATTACIO1ENT J-1

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ATTACHMENT J-l I&C' PRIMART WELD

'QC INSPECTION

.ASME CODE INTEC. DOCUMENT REVIEW COMPONENT CLASS OTY. INVOLVED - CONFICURATION PERFORMED

INSPECTION.

NDE TEST MERC.ESASCO LPL OTHER Tubing P2N I.

'51 Travelera 1/8" Socket

1. Cleanliness.

Indep.' exam.

Indep. 100% 1001 1001 152

1) SCD 57.

(Approx.)

Weld

2. Companent Verified by Eemper Exam.

2) QASP-19.15 -

+

3. HT Component No.

Insurance By CEO

3) QASP-19.9

. Verified Record Liq.

4. HT & Type Filler Review Penet.

Metal (100%)

(1002)

5. Fit-Up Physical

6. Final Inspection

7. Welder ID (Approx 22)

8. Weld No.

9. Mechanical Separation.

Tubing P2N2 35 Travelere 1/8" Socket' l. Cleactiness Indep. exam.

Indep. 1001 1001 100%

'52

1) SCD 57 1

(Approx.)

Weld

2. Component Verified by Eemper.

Exam.

3.HTComponentjo.

Insurance By CEO Verified Record Liq.

4. HT & Type Filler Review Penet.

Hatal (100%)

(100Z)

5. Fit-Up Physical

6. Final Inspection

7. Walder ID (Approx 22)

8. Weld No.

Tubing P3NI 189 Travelers I/8" Socket

1. Clean 11nese 1002 -1001 100I 15% 1) QASP-19.15 (Approx.)

Weld

2. Component Verified With

2) QASP-19.9

3. HT Component No.

Except

3) SCD 57 Verified of

4. HT & Type Filler HVAC Metal

5. Fit-Up

6. Final

7. Welder ID

8. Weld No.

9. Hechanical Separation w

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4 ATTACHMENT J-l I&C PRIMART WEI.D' QC INSPECTION ASME CODE-

'INTEC. DOC 11 MENT REVIEW COMPONENT CLASS QFT. INVOLVED CONFICURATION PERPORMED INSPECTION NDE TEST MERC.EBASCO LPL OTHER Tubing P3N2 95 Travelers 1/8" Socket

1. Cleanliness 100% -100% 100% 15% 1) SCD 57 (Approx.)

Weld

2. Component Verified With

3. HT Component No.

Except-Verified of'

4. HT & Type Filler HVAC Metal-

5. Fit-Up

6. Final

7. Walder ID

8. Weld No.

P3 Sample P2 10 Drawings 1/4" Socket 1.' Clean 11 ness Indep. Exam.

Indep. 100Z 100% 1001 15I

1) SCD 62 Pipe Weld

2. Component Verified By Keeper Exas

2) SCD 57

3. HT Component Nog Insurance By CEO Verified Record Liq.

4. HT & Type Filler Review Penet.

Metal (1002)

(100%)

5. Fit-Up Physical

6. Final Inspection

7. Welder ID (Approx 22)

8. Weld No.

i Strong Back P3N1 7 Tanks 1/4" Socket

1. Cleanliness 100Z 1001 100I 151

!) SCD 57 Piping for Weld-

2. Component Verified Lovel

2) QASP-19.15

3. HT Component No.

Switches

3) QASP-19.9 Verified

4. HT & Type Fille,r Metal

5. Fit-Up

6. Final

7. Welder ID

8. Weld No.

9. Mechanical Separation, Tubetrack Seismic 650 Fillet I ) 67Z Under QAI-23 CL I (Approx.)

100% 10Z I

2) QASP 19.15 (NI Only)

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ATTACHMENT J-I D

T E.C FRINART WELD QC INSPECTION ASNE CODE INTEC. DOCUMENT REVIEW.

COMPONENT CLASS QTY. INVOLVED CONFICURATION PERFORMED INSPECTION NDE TEST MERC.BBASCO LPL OTHER Tubing &

Seismic

$100 Fillet

1. Cleanliness-751 100I 10E

1) 352 Under QAl-23 Tubetrack CL 1 (Approx.)

2. Component Verified

2) QASP-19/15 (N! Only)~

Supports

3. Heat No. Component' Verified-

4. HT & Type Fillet Metal

5. Fit-Up

6. Welder ID 1

7. Weld No, e

i

8. Final l

Bergen-Seismic 310 Fillet

1. Cleanlicess Not 1001 101

!) Ebasco QC 1001 reinspection Faterson CL I (Approx.)

2. Ccaponent Veritted Comp.

2) 79-14 Walkdown Supports

3. HT No. & Type A

3) QASP-19.7 Filler Metal

=

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4. Welder ID

5. Weld No.

6. Fit-Up

7. Final

~

i Instrument Seismic 200 Fillet

l. Cleanliness Not 100% 10%

1) 1001 Under QAl-23 Stands CL I (Approx.)

2. Component verified Comp.

2) QASP-19.15 (N1 Only)

3. HT No. OF Component Verified

4. HT & Type Filler Metal

5. Welder ID

6. Weld No.

7. Fit-Up

8. Final 0

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ATTACHMENT NO. J-2 VERIFICATION OF THE ' ACCEPTABILITY OF MERCURY INSTALLATIONS Since the Stop Work. Order on. Mercury-safety related activities was issued in LJuly' 1982, Mercury installed : systems have been heavily scrutinized by LP&L and Ebasco. The Mercury installations have also been subjected to NRC field review.

Additionally, Kemper Insurance participated in the ASME Section III N-Stamp application process and, as such, was required to witness hydrostatic testing of

'all ASME Safety Class 2 installations.

The fol15 wing 1s a brief discussion of some of the significa t LP&L and Ebasco

~

verification activities with respect to Mercury installations.

A direct result of the Stop Work Order, was the initiation in July 1982 of 1.

joint Mercury 'and Ebasco walkdowns of instrumentation installations on a

+

p

' startup ' system basis.

LP&L QA and Startup were involved in the initial phases of the program. Walkdown results were documented on punch lists and evaluated for nonconforming conditions and establishment of corrective

- action..The walkdowns were conducted in two phases.

The first phase consisted primarily.of tubing along with the associated tubetrack and clamps. The.second phase, which commenced in. January 1983, consisted of a walkdown of supports.-- The walkdowns resulted.in the generation of a large G

4

number of NCRs and rework. Attachments 2, 3 and 3F of the response to NRC

-Issue 23 discuss the significance of the NCRs.

2.

In addition ~ to LP&L -QA participation in the corrective action walkdowns -

discussed - above, LP&L QA performed a status review at the time of system turnover'in accordance with the requirements of LP&L Procedure'QASP 17.5.

This review consisted of a minimum 10% review of the documentation, and a random field sampling of hardware versus as-built drawings.- Portions of the Mercury installation for the following startup systems were field verified:

18-3, 25-9, 36-1, 36-3, 39, 43A, 43B, 43E, 43H, 43J, 46A, 46B, 46C, 46D,.46E, 46H, 52A-1, 52A-2, 52B, 52C, 53A, 55A,56A, 58, 59, 60A,.60B, 60C, 66, 713, 73 and 76.

'As a result.of these reviews, LP&L was able to conclude that the as-built conditions generally reflected the system drawings, and that no significant hardware deficiencies were encountered.

3..

Ebasco-conducted various other field vari?ication' activities relative to Mercury installations. These are summarized as follows:

~

a.

As ' ~ part of the - closure of SCD 57, Ebasco QA initiated a corrective-action supplement which consisted in part of a sample field inspection of various attribgtes related to Mercury installations.

This

~ inspection took place in February, 1984.

J-12

b.-

. Ebasco Engineering conducted a plant walkdown in order to identify and correct miscellaneous hardware deficiencies which normally result from ongoing construction activities.

This walkdown was conducted in accordance with Ebasco Procedure ASP-IV-141 and included all safety related areas of the plant.

Deficiencies, along with QA/QC verification of corrective action on safety related items, were documented on punch' lists.

The program was established in support of the area closecut and. transfer process, which took place in March, 1984 through May, 1984.

This walkdown provided another level of assurance on the Mercury installations.

c.

Since August 1982, the Ebasco QA Surveillance Group. has conducted 48 documented surveillances of Mercury hardware and documentation.

Any findings were resolved and, when necessary, NCRs.were initiated to evaluate potentially significant discrepancies. The activities of the Ebasco QA _ Surveillance Group are discussed in greater detail in to the response to NRC Issue 23.

Generally, this. in-l process surveillance program provided another means of monitoring Mercury activities, thus ensuring the adequacy of the installations.

4..

-The most significant activity, aside from the corrective action walkdown discussed in Item 1,

involved the Ebasco QA records review of Mercury documentation.

This ' review was necessary dtge to the demobilization of Mercury in August.of 1983 without the comple, tion of the Mercury records.

M review. The review commenced in November, 1983 and was completed in March, 1984.

A group of 46.QA reviewers, inspectors, supervisors and clerical staff was assembled for this effort.

The review was conducted in--

.accordance with QA instruction QAI-23.

As deficient or missing documents were identified, QC inspectors were dispatched

.to reverify the installations. As a result, approximately 67% of tube track installations were reinspected; approximately 35% of Seismic Category 1 supports were reinspected; and approximately 24% of the Mercury installed. anchors were reverified for proper torque.

Attachment SA to the response to NRC Issue 23 provides a summary of the review and reinspection scope resulting from the Ebasco QA records. review.

Available records indicate that an insignificant amount of rework resulted from the reinspection process.

2 I

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J-13 l~

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SUMMARY

OF THE EBASCO QA RECORDS REVIEW I.

The following ~ is a summary of the work scope related to the Mercury documentation review conducted by Ebasco QA.

Further, a summary of field

{

- QC verifications resulting from the review process is provided in Section i

' II.

A.

Tubing Installations Records Review ASME Section ASME Section Review Scope III-Class 2-III-Class 3 Total Number of Systems _

13 36 49 Number of Mercury Travelers (OCRs) 86 284 370 Number of Instruments 150 835 985 B.

Seismic Category I Support, Tube Track, and Other Miscellaneous Harduare Installations Review Scope Quantity Tube Track Supports 5142 Primary Sample Line Pipe Supports 314-Tube Track Installations 665 Instrument Stands 184 Bulk Fabricated Supports / Fittings /

Anchor Pi '.es 7230 (Approx.)

Instrument Mounts 267 II.

QA reinspections were initiated in order to resolve documentation

-deficiencies identified in the review process. A aummary of reinspections

~

istas follows:

A.

Tubing Installations o

Reinspections were initiated to verify the following:

Attributo.

Quantity Heat Number 30 Material' Identification 15 Walder's I.D.

11 Tube Slope 4

Verify Repair of Damaged Tubing 7

Wall Thickness 2

Defective Weld 1

Instrument Installation 3

TOTAL 73 (Note 1) l J-14 s

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- - - - - -. - ~. ~.

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Supports / Tube Track and other miscellaneous-Seismic Category 1

installations.

Reinspections were initiated to verify the following:

Attribute Quantity Support Configuration, Location & Welds 2058 Tube Track 514 Instrument Stands 211 Torque Verification of Anchor Bolts Including Prcper Embedment and Thread Engagement

• 896 Support Tyne Only 159 Final Visual of Support Weld Only 88 Pipe Support Configurat!.on 77 Miscellaneous Attributes (Ht. No., Welder I.D.,

Etc.)

216 TOTAL 4219 (Note 1)

As a result of these reinspections, a total of 113 NCRs and 1035 Discrepancy Notices were dispositioned.

P NOTE 1: Some duplication of reinspection or unsuccessful inspection is included in these numbers.

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ATTACHMENT J-3

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4 ATTACHMENT NO.~J-3~

SUMMARY

OF MERCURY REIF"PECTIONS RESULTING FROM NRC ISSUE NO. 1

'As a result. L of the _ LP&L _ review of' NRC Issue No.

I regarding Mercury. QC

qualifications,.LP&L deemed.it -prudent ~ _to undertake a-further. extensive reinspection of( Mercury. work.

Accordingly, LP&L procedure QASP19.15 was established to _. reinspect the ' sensing' lines and associated hardware (e.g. tube

.. track,. support,. etc.) for the N1 ' instrument installations, which perform ~ a

. sakry-related function and provide a pressure boundary.

The reinspection is

.. complete and no discrepancies impacting plant safety were.found.

The discrepancies were' sorted into the following nine-categories for evaluation:

A. -

Overspan on tubing B.-

Missing hardware (e.g. missing nuts, bolts, lockwashers, tube clamps)

~

- C.

Incorrect.tubeclanp type (2D,3D)

D.

Insufficient weld on support

- E.-

Incorrectly assembled hardware, track, support, etc.

F.

. Undersized tubing weld G.

Anchor bolt embsdment H.

Anchor bolt spacing g

I.-

Arc strike / grind mark on weld

. I Table 1 summarizes the number of' findings in each category.

The purpose of this attachment is to discuss the ramifications of the identified

- conditions Lwith respect to plant safety and to discuss the need for further reinspections.

Category A - Overspan on Tubing The most significant overspanned conditions found during the reinspection were

~ analyzed under design loading conditions and-detemined to be within ASME code allowable: stresses. The 15 cases identified as rework items involved minor relocation of. clamps and were reworked rather than submitted for complete engineering _ evaluation. It ' was judged, however, that there was no safety significance with the respect _to the as found. conditions in this category.

Category B - Missing Hardware Missing hardware was further broken down into two categories:

l-a) Missing lockwashers 1

b) Missing tube clamps, missing nut or bolt for tube clamp assemblies, and tube track support or track splice connections.

- M' issing :lockwashers pose -'a concern in that ' the nut is more likely to loosen under : seismic conditions..

Since the nuts were found to be tight in these

-instances, the bolts should not loosen under short term seismic conditions.

J-17 i.

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Induced. vibration in~ tubetrack/ tubing installations due to plant normal ioperating ' conditions is minimal, and should not cause loosening of the

-connection.

With respect to the missing tube clamp hardware, such cases were treated as an

'overspan condition for evaluation.

Stress analysis evaluation of the identified

discrepancies concluded that the as-found condition would not result in overstressing the tubing under design' loading conditions.

tu'etrack hardware likewise results in an overspanned condition.

Missing _

b The resultant, deflections would not result in failure of the tubing pressure

_ boundary under design loading conditions.

In. summary, none of the ~ missing. hardware items degrade the overall system integrity and thus do. not preclude the system from performing its intended safety function.

However, missing hardwarc items were reworked in accordance d

with installation requirements.

Category C - Incorrect Tube Clamp (2D & 3D) 4 The as-found conditions can be broken down further as follows:

1.

Two dimensional (2D) clamps used in lieu of a three dimensional (3D) clamp.

s.

2.

Three dimensional clamp used in lieu of a two dimensional clamp.

The_first condition represents no. safety significance in that a 3D clamp simply

~

provides axial restraint as well as lateral and vertical ~ restraint.

Axial restraint is also achieved by clamps installed on the tubing as it changes

' direction.

(That _is, tube clamps in a tube run 'on a perpendicular plane of direction to the run to be restrained will provide restraint to that run).

~The condition in which a 3D clamp is used in ~ lieu of a 2D clamp may pose a

_ cencern in that axial thermal growth would be restricted..The only case where this condition may pose a problem is when there is a straight run of tubing between two 3D clamps coupled with high maximum operating system temperatures.

Only two such cases were noted out ~ of the 68 total clamp discrepancies.

Approximately 2600 tube clamps were. inspected.

The probability that these lines would. fail is low, since restricted growth due to cyclical thermal loading of the tube in itself would not cause.a pressure boundary failure.. Frequent -cyclical thermal loading is not anticipated en Waterford since it is_LP&L's policy to backfill instrumentation legs rather than

' blowdown the line.

In the unlikely event of a tube failure for the two identified instrument. loops (had the cases not been corrected), the failure would not have been of safety significance.

Category D - Insufficient Weld,On Support The two identified conditions _ in this category were evaluated and found to be acceptable as ~ installed, under design loading conditions.

Thus, no item of safety significance was identified in this category.

J-18

m

- Category E - Incorrectly Assembled Hardware The 49-identified conditions consisted primarily of loose bolts. Many instances involved.one - loose nut in a four bolt tube track splice assembly.

In such

- instances one bolt alone would be sufficient.

- In instances of loot,e tube track to support bolts or tube clamp bolts, the loose nut and bolt assembly provided some clamping action, ensuring no overspan condition existed that would degrade the overall system integrity under design conditions.- The instances of L this condition occurring are isolated throughout all.the-reinspected installations, which further reduces the impact on individual system integrity.

Category F - Undersize Tubing Welds

- Twenty-Five undersized welds were identified. Thirteen were acceptable based on a previous analysis (refer ~ to NCR-W3-5850).

The remaining 12 welds were repaired to meet - ASME code requirements.

However, in LP&L's judgement, had these undersized conditions gone undetected, the structural integrity of the weld to perform under design loading conditions would not have been compromised.

Also, hydrotests performed on non-atmospheric installations provide further evidence relative to the adequacy of the weld.

Given that only 12 out of the approximately 4800 welds sinspected were found to.be undersized, LP&L believes that additional. reinspection is not justified.. None of these conditions represent an iten of safety significance even though repairs were required based on ASME code requirements.

Category G - Anchor Bolt Embedments Three of the identified conditions in this category were reworked to be consistent with installation criteria required.

These were later analyzed and

-it was found that rework was not required and none of these conditions posed a concern relative to safety significance.

' Category H - Anchor Eolt Spacing Violations

.The as-found conditions in this category were evaluated and determined to be acceptable as-is under design loading con'ditions.

Therefore, no item of safety

'?

significance was noted.

Category I - Arc Strikes & Grind Marks Arc strikes or grind marks were identified on base metal pressure boundaries or at a weld.

When buffed and measured, the as-found' conditions were determined not to exceed established minimum wall' thickness criteria or minimum weld size

- requirements. Thus no condition of safety significance was noted nor were any repairs required.

J-19 0

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SUMMARY

AND CONCLUSIONS Conditions that have.been designated for rework were done so generally to meet code requirements and - to satisfy specific installation criteria.

Had. these conditions been left uncorrected, in LP&L's judgement, they would not have impacted the. overall ability of the system to function under design loading conditions. :Turther, the limited number of discrepancies found in each category as compared to the total number of -items inspected does not justify further reinspection of Mercury installations.

This is further substantiated by the

- fact thet most of the rework performed involved minor hardware discrepancies (i.e. categories B, C and E).

All Mercury N1 instrument tubing installations were reinspected.

Reinspection of N2 instrumentation, which is only safety related with respect to its pressure boundary integrity function, is not warranted.

As noted, significant pressure boundary concerns were not identified in the N1 instrumentation reinspection.

Only 12 out of 4,800 welds were repaired, and these repairs were due to code requirements, and.not as a result of a degraded pressure boundary

. integrity condition.

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TABLE 1

SUMMARY

BY DISCREPANCY TYPE v^

- VIOLATION:

APPROXIMATE TOTAL DISCREPANCIES

. TOTAL NUMBER OF ACCEPTED CODE TOTAL ITEMS IDENTIFIED

• REWORK ITEMS AS IS INSPECTED **

CITED ACTUAL

A.

10,500 ft.

55

'21 15 6

.B.

.5.500 -

75 67 67 0

C-2,600 68 68 68 0

D-3,~700 15 2

0 2

E 5,500 60 49 49 0

F 4,800-25 12 12 0

G 3,600 40 3

3 0

H 3,600 88 42 0-42

'I.

10,500 ft.

7

-7 0

7 TOTAL 430 274 221 53 QASP19.15 contained basic design criteria that had to be inspected against.

This. procedure did not' account for previous dnalysis, unique installation details ' or certain ' criteria identified-in the installation details notes section. The actual number of discrepancies reflect the valid violations from

~ the specified detailed design criteria.

Estimate based on typical installation of 10,500 linear ft. of> tubing with accessories.

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ATTACHMINT 1 i

4 K.

NISCO

~1.-

-On-Site Dates: -August 1978 to October 1983 2.

Scope of Work:

a.

' Installation of Reactor Coolant Pumps.

b.-

Installation and final setting. of reactor vessel and.(2) steam generators.

c.

. Installation of Reactor Vessel head.

'd.

Installation and assembly of fuel handling system.

' Fabrication and installation of seismic Class I supporcs.

e.-

f.

Installation of pool seal ring / rolling missile shield.

g.

Perform hydrostatic testing on all systems installed.

h.;

Perform insulation resistance testing ou electrical equipment.

.i.

Assembly and installation of CEDM system magnetic jack assemblies.

3..

Scope of Inspection:

a.

Material Receiving Inspection.

'b.

Inspection of fit-up and final welds.

ci Inspection of Proper Bolting (Torque and Tension).

-d..

Installed Equipment Inspection.

's e.

Hydrostatic Testing Inspection.

f.

Insulation Resistance Testing Inspection.

.4.

QA Program Requirements / Contractual Commitments:

Quality Personnel (including Auditors, QC Insp'ectors, and QA Surveillance

-a..

Personnel) - Nisco's f contract - required all personnel to receive indoctrination and. technical training.

b.

QA Auditors - Nisco Procedure ES-116-3, " Qualification Certification of-Audit Personnel" required completion of self study courses, on-the-job training, and oral or written examinations.

.c.

~QC Inspectors /QA Surveillance Personnel - ANSI N45.2.6, Nisco Procedure ES-116-2, " Qualification and Certification of Inspection Personnel", and

-Nisco Procedure ES-117, " Inspection, Testing, and Examination Persennel Training Procedure"..

~5.

Inspector-Qualification'and Dispositioning of Deficiencies:

i l-

, The - verification ' program identified one (1) NISCO QC inspector who performed Level II inspections for approximat,ely.5 months and whose qualifications were determined as not meeting the requirements of ANSI

[.

N45.2.6-1973-for Level II - during that period of time.

Corrective Action Report EQA-84-4 was initiated to track the disposition of this deficiency.

L The Level II qualifications of the identified individual had been questioned in 1980 in a finding resulting from an LP&L audit of NISCO (LP&L Audit NO.-80-25).: Corrective action taken by ' NISCO to resolve I

that finding was accomplished. shortly after the LP&L audit and included removal of the Level II certification for the individual and E

reinspection of the installations which he had inspected as a Level II l

inspector.

The quality of the construction activities inspected by L

the 1 individual in question wap further confirmed by acceptable NDE reports.- See NISCO Letter, dated July 16, 1980, attached.

K-1 2, a,

I 0

ATTACHMENT K-1 o

e G

L e

Wh

?

e e

3 K-2

8*S?S

>Y NUCLEAR INSTALLATION SERVICES COMPANY-

).

P. O. Box 425 NITRO. WEST VIRGINI A 25143 s.

(300 7554101 TWX 710 938-1696 July 16,1980 EBASCO Services, Inc.

P. O. Box 70 Killona, LA 70066 Attention: Mr. L. A. Stinson Manager Site Quality Program 2

Subject:

Louisiana Power and Light Company Waterford Steam Electric Station

~

1980 - 1165 MW Installation - Unit #3 Contract W3-NY-18 Inspector Certification - K. J. Rogers t

l

Dear Mr. Stinson:

The Level II Certification of our _K. J. Rogers has been questioned as a result of a recent NRC inspection and L.P.&L. Audit No. 80-25. We have previously expressed our opinion on this subject, referencing the approved procedure (ES-ll6-2) in use at the time of original certification (dated.2/11/80);

however, we do realize that Mr. Rogers' experience falls short of the recommended experience provided in ANSI N45.2.6, and that required by our revised Certification Procedures.

In light of this information we are at this time formally withdrawing these Level II certifications.

Mr. Rogers will continue to function as a Level I~ Inspector, as he has done since this ' problem was id:ntified, until such time that he reaches the degree of experience required by cur ES-ll6-2 for Level II Certification.

Wn have reviewed work previously performed by Mr. Rogers and have determined this work to be acceptable. The following pages show a list of items inspected by.this individual, as well as a porresponding list of acceptable NDE reports.as

.provided by the Site NDE Subcontractor.

v - - -

f\\

s.

<[

Insp;ctor Certification c;

K.J. Rogers j

_/

July 16,1980 ir Page Two TYPE ITEM INSPECTION NDE REPORT 1.

CEDM UPPER SEAL WELDS:

Location No.

PCS No.

7 461

• Visual PT-3381 3

457 Visual "PT-3381 4

458 Visual PT-3381 12 466 Visual PT-3381 48 502 ~

Visual PT-3402 28 482 Visual PT-3402 80 534 Visual PT-3402 65 51 9 Visual

.PT-3402 41 495 Visual PT-3402 23 477 Visual PT-3402 18 472 Visual PT-3415 11 -

465 Visual PT-3415 19 473 Visual PT-3415 s

20 474 Visual -

PT-3415 36 490 Visual PT-3468 60 51 4 Visual PT-3421

.1^

76 530 Visual PT-3421 59 513 Visual PT-3421 42 496 Visual PT-3421 PT-3447 34 488 Visual 27 481 Visual PT-3447 i

35 489 Visual PT-3447 43 497 Visual PT-3447 56

e510 Visual PT-3447 l

68 522 Visual PT-3447 91 545 Visual PT-3447 PT-3447 77 F31 Visual i.

66 520 Visual PT-3447 54 508 Visual PT-3496 47 501 Visual PT-3496 55 509 Visual PT-3496 67 5 21 Visual PT-3496 79 533 Visual PT-3496 88 542 Visual PT-3496 l

86 540 Visual PT-3496 l

78 532 Visual PT-3496 i

87 541 Visual PT-3496

• Visual inspection of final weld surface.

1 0

l l

'j.*

A

,e'gESS Inspector certification

~

D,i K.J. Rogers d i July 16, 1980 Page Three TYPE I-ITEM INSPECTION NDE REPORT

2) PIPE WELDS Location No.

PCS No.

P13W1 238 Visual PT-3759 Final Weld NISCO-025F(RT)

P7W1 228 Visual MT-ll24

~

Final Weld NISCO-018M(RT)

The acceptable condition attested to on the above NDE reports provides sufficient evidence that the inspection work was not detrirental to the final condition of the iters.

Level I' Inspection Certification in several areas will be provided to the site upon a

completion of a.'eview by our current Level III Examiner.

~~

4 Sincerely,

/

Of LM N

)

Robert P. Larkin Manager Qaality Assurance r.j cc:

F. R. Howard E, Beebe - J3015 J. Moore G. Sementi

~

e 8

).

0 nw e

ATTACHMENT 1 L.

N00TER 1.

On-Site Dates: July 1976 to December 1981 2.

Scope of Work:

Fabricate and Erect a._ -Refueling Water Pool Liner b.-

Condensate Storage Pool Liner c.

Reactor Building Canal Liner including Floor Embedments, Floor and Wall Embedments, and Refueling Cavity Seal Bed-Plate

.d.

Spent Fuel Storage Pool Liner e.

Spent Fuel Cask Storage Pool Liner f.

Refueling Canal Liner g.

Spent Fuel Cask Decontamination Area Liner h.

Decontamination Room Liner 3.

Scope of-Inspection:

c a.

Receiving Inspection b.'

Radiographic c.

Magnetic Particle d.

Ultrasonic e.

Liquid Penetrant f.

Leak Detection (Vacuum Box Testing) g.

Calibration of Test Equipment h.

Final Visual Weld Inspection 4.

QA Program Requirements / Contractual Commitments:

a.

Quality. Assurance Engineer (includes Auditors) - No requirements for qualification.

b.

Quality Assurance..

(includes Record Reviewers) - No Technicians requirements for qualification.

c.

Quality Assurance Management / Supervisors - No requirements for qualification.

d.

Field Inspectors - Nooter Procedure SP-18, " Qualification of Inspectors",

field requirements rie High School education or prior experience in manufacturing and construction, natural or corrected near distance acuity.

Such that they are capable of reading the'J-l letters on the standard l

Jueger test chart and color vision evaluated for personnel performing color, l'

sensitive evaluations.

In addition, prior to performing inspection, the inspectors are briefed on job requirements.

e..

Nondestructive Examination Personnel - SNT-TC-1A and Nooter Procedure NDE-13, " Nondestructive Examination Personnel Qualificat3cn and Certification".

5.

Inspector Qualification _and Dispositioning of Deficiencies:

(In Progress)

L,1 L

c:

ATTACHMENT 1 M.

SLINE

'1.

On-Site Dates: December 1977 to August 1984

.- 2.

Scope of Work:

a. '

Application of Service Level I, Level II Coatings and. Balance of

~

Plant Equipment and Structure.

-3.

Scope of Inspection:

' Surface Preparation Inspection a.

b.

Product Selection Inspection c.

Paint'-and Protective Coating Application Inspection.

d.. Workmanship-Inspection e.

Receiving and Issuing Material Inspections

-f.

Calibration Inspections 4.

'QA Program Requirements / Contractual Commitments:

'a.

QA Personnel except QA. Manager '- No. procedural requirements for

~#

qualification.

b..

QA Manager - Sline Procedure W3-1, " Certification and Qualification of Inspectors", which requires QA Manager to be a Level III.

c.

Inspector ; Personnel - Sline Procedure W3-1, " Certification and

. y

. Qualification of Inspectors".

5.

Inspector Qualification and Dispcsitioning of Deficiencies:

(In Progress)

S 9

en e

C 0

M,1

1-

~

ATTACHMENT 1

- N. TOMPKINS - BECKWITH (T-B)

.1).'

5On-Site-Dates: June 1977 to June 1984

~

22.

Scope of Work:

. a.

- PIPING.-

1.

Ineta11ation of ASME III Safety Class I, II, III, and Non-Safety

-related_(B31.1) Process Piping Systems' 2.

Installation of Pipe Flange Bolts.

'3.

System. Hydrostatic Testing, i

' b.-

- HANGERS' 1.

. Installation of associated Seismic and Non-Seismic Pipe Hangers / Supports'(AWS D1.1.or ASME Section NF).

. 2.

Installation of Pipe, Rupture and Whip Restraints including

structural steel, U-bolts, restraining plates, spacers and shims

for' piping systems installed by T-B.

3.

, Installation of expansion anchor _ bolts for systems installed by 1-B.

[3.

Scope'of Inspection:

~ 2 a.- - PIPING 1.

Fit-up and-final visual ~ inspection.

2.

Inspection of pipe flange bolts.

- 3.

Hydrostatic-testing.

r b.-

HANGERS / RESTRAINTS

, 1.

Fit-up and final visual inspection.

- 2.

-Inspection of high strength bolting.

3.

Inspection of expansion anchor bolts.

Lc.

GENERAL-1._

- Material-Receiving inspection.

4.

QA Program Requirements / Contractual Commitments:

=

9?

L a.'

Quality Assurance Auditors - T-B Procedure TBP-8, _ " Quality Assurance Audits", requirements shall have or be given appropriate training or orientation to develop their competence for performing ~ required audits.-

^

b.

Quality Control -Inspector /QA Surveillance ANSI N45.2.6 and T-B Procedure TBP-4, '" Indoctrination,' Training, and Certification of QA/QC Personnel".-

5. -

Inspector Qual'ification and Dispositioning'of Deficiencies:

Using conservative standards as defined in the basic response, 16 of the

' 147. ' T-B ' inspectors did not ~ fully meet the criteria of ANSI 45.2.6-1973.

.Further, there has : been' a significant amount of required and elective overinspections, reinspections, ~ tests and reviews conducted by T&B, Ebasco,

LP&L and

others.- These are displayed on the attached Tables I & II.

Brief

. explanations, keyed to the tables, are:

N-l~

git 6 9

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9 1+Vt'*

m y,-

,-egyhy--wp ew.+-=y+---ew-g+g--e www T'-#-'9'"1F iP'

%'+48F'*"'"W-'*W--'

T*t*'wW'W"7#-~-""'W-"'M-4F--&1*W'WW=f*'t

• m'T9W"*8'VWT'W W'M 7 9C4""'T

PIPING AND PENETRATIONS (1)

T-B contracted Hartford Steam Boiler, Inc., to provide third party

' Authorized. Nuclear-Inspection-se rvices.-

The Authorized Nuclear

~ Inspectors..(ANI) inspected in-process and completed work on a sample basis to independently assure compliance to the ASME Code.

These inspections. were performed on items and processes that were also

[

. inspected by.T-B QC personnel.

~ (2)

T-B inspectors only performed visual examinations of welds. All other lNon-Destructive Examination (NDE) was independently performed by

- Peabody /GEO Testing..'GEO NDE included radiography, liquid penetrant, imagnetic particle ~and ultrasonic testing.

, ~ (3) :A11. radiographs were independent 1y' reviewed by a qualified Ebasco Examiner.

(4) Independent Preservice Inspection (PSI) of piping, ' pipe welds, and pipe: ' supports.. per ASME Section XI requirements was performed by Virginia Corporation under contract to. LP&L.

This inspection consisted of both visual examination and. ultrasonic. testing of critical-safety related installations previously. installed and inspected'by T-B. personnel.

(5) All ~ safety-related piping - systems - were hydrostatically tested to

~

assure system integrity.

In addition to T-B QC personnel, these tests

- were witnessed by the T-B ANI (Hartford), Ebasco Start-Up personnel, LP&L Start-Up personnel, and the LP&L ANI (Factory Mutual - witnessed Class'3).

(6) All piping documentation was reviewed by T-B and Ebasco QA personnel.

On.a sampling basis, LP&L QA personnel teviewed a minimum of 10% of this documentation.

The LP&L - QA documentation review included field verification of approximately 3% of the. installed hardware of small bore piping.

(7). The Pre-Core Hot Functional Test has' been performed and this test

. verified the integrity' of the pipe welds under pressure and thermal loading based on simulated actual plant conditions:

(8). Verification - of piping configuration was accomplished as part of Ebasco Engineering IE Bulletin 79-14. program.

The.' Pre-Core Hot

. Functional thermal monitoring program further established the adequacy of.the as-built piping configuration to function'as designed.

SEISMIC PIPE SUPPORTS

- (9) Ebasco :' Engineering has performed a field verification of Seismic Category I-support /rgstraints which consisted of the following:

. Support / restraint location and functionality (IE Bulletin 79-14).

a.

b..-

.-Completeness of hardware installation

~(10) Support / Restraint functionality was verified during the Pre-Core Hot Punctional Thermal Monitoring Test program.

e N-2

-.. -. 2

t

/

.(11). As s ' result of Significant Construction Deficiency No. 60 (NCR-4010),

T-B QC-inspectors reinspected over 4500 safety-related_ pipe supports.

1

((12) Ebasco.QA has performed 'a detailed as-built inspection of over 200 highly: stressed hangers.

(13) LP&L QA has ' inspected 3500 hangers in accordance with procedure QASP

- 19. 7..

(14)-LP&L contracted Helmut

Thielsch, a

noted metallurgist, to independently review the support / restraint assembly structural welds.

In his report he concluded that even those welds that were considered

~

marginal in. appearance, exceeded. load carry.. requirements by a considerable amount.

Further, he judged the structural welds to be comparable to other nuclear power plants.

(15) The LP&L Piping Verification Group. is responsible for the following

activities to be performed during Phase III testing program:

y a.-

Monitor mechanical snubbers for cold / hot settings b.

Monitor-spring hangers (except 2" & under non-seismic /non-safety)

-.for cold / hot settings.

Ec.

To clear -the deficiencies found. during the pre-core hot ft.nctional testing - a portion ~ of safety class (high. energy) piping will be monitored for thermal expansion.

(16) All' hanger documentation.was reviewed by T-B and Ebasco QA personnel.

On a sampling basis, LP&L QA personnel reviewed a' minimum of 10% of this documentation. The LP&L QA documentar. ion review included a-field verification of approximately 3% of the ihstalled hardware.

- The above reviews and inapections contirm the overall acceptability of the

' work performed by Tompkins-Beckwith..

Therefore, there is adequate assurance that the safety related piping and supports will satisfactorily l'

perform their intended functions and no further construction-related inspections or tests are warranted.

6 e

e e

L L

N-3 i

I e

.s

- PIPING Tanss kins-Beclarith T-B Scose of brk Overinspectness, hennasections and Mstkdeums ASPE CODE QuaNTITT. PRIMARY WEta CODE req'D QC INSPECTION QlDE -

C00901ENT Q. ASS INVOLVED CONrIQ RATION IDE hRW3 BY T-b INSPECT 10N ISE

' RADuncease PRESERV12 NVDROSTATIC D0QsENEATION REVIElf j

REVILW INSTECTION a r,a sa T-5

=== IJEL OlWR ASE III 54 teos Circumfereettal VT, RT, Mr_

(1)

(2)

(3)

(4)

(3)

(6)

(6)

(6)

(7)

1. Dimenstanal Third Party

?^_,

Ebass >

Independent 1004 1004 1004 104 Not Class 1 Walds or LP Verificatten

- hartford enamtmation 1004 laspectica.

Inspected by (Otta.)

Punctional

2. ramp ~=nt &

Steam Doller by CEO Testing by Wir 1sta

1) I-B

. Tests Wld b.

RT, NT, LP Corp.

Inspertore Veritted

2) T-B AN1-(s).

3. Cleanliness Nortford IE tulletta

4. Fit-Up.

3) Ebasco 79-14 Program S. Purse (14 0 )

1 SE*KE*UP

6. Preheat 4).1761.

7. laterpass Start-Up P1,1mg

8. Purge Das large Pemoved Bors

9. Intera. Root Pass Insp.

10. Wider Stamp, Wald & Iso leo

11. Final Y1sual

12. FWHI Accep-tance (1)

(2)

(3)

(4)

(3)

(t)

(6)

(6)

ASPE III 245 Isos circunferential VT Same as above Same as GO Testtag b eco Same as above Same as above 2004 1004 104 Class 2 W1de PT above BT 1004 (Nin.) -

(2)

(3)

(6)

(6)

(e)

ASE 111 472 laos Circumferential VI and NE Same as above N. A.

GEO Testing N. A.

N. A.

Same as above - 1004 1004 104.

Class 3 -

W1ds or IP ttt,17 (escept no (Min.)

T-R AN1)

(1)

(2)

(3)

(4)

(3)

(6J (6)

(t)

(T)

ASPE 111 2 face Circumfereattat VT

1. Dimensiceal Same as CEO Testing Ebasco 1" and above Same as above 1004 1004 104 2600 anchet Class 1 Walda RT Verificattoo above RI 1004 Same as above (Min.)

weise rein-

2. ra Paaamt &

Independent 34 Field spected under Wald $10.

Inspection by Verified SCD-28 (Sck-

. 3. Cleanlinese Virgiata Corp.

4. rte-up

-160)

S. Preheat

6. Interpase

7. W1 der Stamp, W14 & Iso llo Ptytag

a. Final Visual Saa11 Bore (1)

(2)

(5)

(6)

(6)

(6) 1 ASPE III 14 lace Socket Helde VI and NE Same as above Same sa CEO Testing N. A.

N. A.

Same as above 1004 1004 104 Class 2 er If above Mf, IJ (Min.)

34 Field.

3 Verified (3)

(6)

(6)

(6)

ASE 111 47 1 sos Socket W ide VT Same as above M. A.

N. A.

N. A.

N. A.

Same as above 1004 1004 104 Clast 3 1

(

(eacept no (Min.)

I*S ANI) 34 Field Verified (1)

(2)

(3)

(4)

(3)

(t)

(6)

(6) caar==st ASIE 111 150 Isos Circumfereat*at VI Essentially third Party CEO Testing Ebasco independent Overpressuri-1004 1004 104 4

Pome.'s Subsec.

Walda RT same as

- Martford RI 1004 Inspection by sation Tests (Nin.)

sec large bare piping ASE III, Steam Boiler Virginia Corp.

piping Class 2 ASE III i

Class 2

.9

.,p,

=*

Y\\ o- - -

n

.a 4

s SETSMIC PTPE dtIPPORTS Templas-tecknatch Scape cf Work Overtrapecetans. Retnasecticos, and hikdonne (ODE Q NAftITY. PRIE RT WEIA CODE REQ'D

. QC INSPECT!0It OtNER DOCUISIffAT10N REVIEW.

CO90NENT CLASS INUULVED CEIKIC4!kATIGI IIPE PgnPna gD l@E IIBSPECTifWS)/RFVirel$

M I-s x-a ty) tae)

(263 gle; Setssic AWS 81.1 6800

. Fillet Welding ' TT

- 1. Dimenetenal vertiteetion VT,

- Ebesco Emotesertag Field Vertiteation 2004 ' 1004-'104 Mangers M III

2. Fit-up and Flaan of h ids fle)

(esta.)

NF

3. heterial Traceability

- Thermal Ilmattertag Te:t Program -

(0:111o4 (11)

' 34 h ter only)

- NCR 4010 inspections (SCD No. 60)

Field (12)

Verification

- Ebeace As-built tospectiana of a

over 200 Nighly Stressed Neapers l

(Q&I No. 20)

(13) -

- LP&L 04 Inspection of 3500 hangers (QASP 19.7)

(14)

• leald Study by Metallurgist Nelmut Thielsch (15)

= LP6L Piptog Vertiteetion Group

\\'

W 9

O 9

3 p+

9 t

• Q

• 9

,9

ATTACHKENT 1

)

C.

WALDINGER l

11.

On-Site Dates: April 1977 to June 1979

2.,

Scope of Worki Install HVAC duct, duct accessories, and supports.

a..

b..

Install HVAC equipment.

Perform pre-operation, balancing, and functional testing of HVAC systems, c.

d..

Install plant stack.

e.

Install duct insulation.

f.

NDE'by others.

.g.

Waldinger's contract calls for furnishing and fabrication of ductwork, accessories, and supports; as well as installation.

~h.

Includes safety-related and/or seismic and non-safety related/non-seismic.,

11.

Leak and pressure testing of HVAC systems performed by Coastal Air Balance (W3-FB-19) with.TWC QC witness.

-3.

Scope of Inspection:

-a.

-Receiving Inspection.

b.

Inspection.of on-site fabrication.

~#

. Inspection of installation of drilled-in concrete expansion anchors.

c.

d.

Inspection _of duct-duct connections.

e.

Fit-up and final visual inspection of structural welds.

'f.

' Inspection of equipment setting (including bolt-torquing).

g.

Witness leak and pressure tests.

4.

QA Program Requirements / Contractual Commitments:-

QA Personnel - ANSI N45.2.6 paragraph 3.1 per Waldinger's QA Manual.

a.

b.

QA Auditors Waldinger Procedure SQCP-18.1-1, " Audit" which is compatible with ANSI N45.2.23.

c.

QC Inspectors - ANSI N45.2.6 and Waldinger Procedure SQCP-2.1-1,

" Qualification-of Inspection, Examination, and s

Testing Personnel".

5.

Inspector-Qualification and Dispositioning of Deficiencies:

(In. Progress).

p k

04 o

., - - n - -,,

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

y 7 -x g

q _y

RESPONSE

iIT'EM NO.:

'6 p

TITI.E:

.Dispositioning of Non'conformance and Discrepancy Reports

~NRC DESCRIPTION OF CONCERN:

The ' staff conducted a review of ' Ebasco ' nonconformance reports (NCRs) - randomly selected from : the Ebasco QA vault - and the NCR tracking _ system.

The selected

. NCRs ; were.- reviewed for content,. compliance "with procedures,

accuracy,

-comple.teness of-the disposition and final closure.- Of the NCRs reviewed it'is the staff's. judgement that approximately one third contained questionable

-- dispositions. Other NCRs were found,still open.

The implied safety significance is that' improperly dispositioned NCRs or lack of

_ :NCR closure could place the quality of installation in question.

For example, Ebasco NCR-W3-5564 identifies that ' welds were painted ' before the final weld ;; inspection was performed.

The NCR -' was closed out with a Dietter stating' that-the final inspection will be performed tc inspect-only for undersizing_and lack of weld material'where installation drawing calls for veld material.' No paint was to be removed therefore the inspector could not inspect

-for. welding defects.

s The.NCRs reviewed by the. staff. dealt with a wide _ variety of issues.

The folicwing is-a = list of, example Ebasco NCRs - that - the. staf f faels contain questionable dispositions or exceeded closure time requirements.

Ebasco W3 NCRs NCR-7139 'NCR-7177 NCR-3912 NCR-7182 NCR-5563 NCR-7181 NCR-7184 NCR-6159 NCR-6723 NCR-3919

-NCR-7547 NCR-6221 NCR-1650 NCR-6511 NCR-6623 NCR-4219 NCR-5586 NCR-7432 NCR-7180 NCR-4137 NCR-6165 NCR-4088 NCR-7099 NCR-6786 NCR-6597 NCR-7533 NCR-7179 NCR-7140 NCR-5565 The ; staff 'also found similar type: problems related to Mercury NCRs in that the dispositions were questionable; supporting documentation could not be located; rework 1 appears to have 'not been accomplished; NCRs were not processed; a Tsufficient basis was not provided; and closure basis was inadequate.

4

The foll'owing'NCRs fall into these categories:

Mercury NCRs t

180 420 528 568 625

'255 429 540 591 656 268 438 554 594 658 363 487 560 595 380' 491 565 614 o

Fh l:(

6-1 L

7

Addition 211y during.this'raview the staff found problems with Ebasco discrapancy

= reports - (DRs) in that it~ appears come DRs should have been elevated to NCRs:

closure-references were incorrect or inappropriate; clecure action was improper; documentation was ' inaccurate; closure was via a DR, should have been an NCR; disposition failed-- to-address the discrepancy; -and the disposition of "use-as-is" had insufficient basis.

~

'The following DRs fall'into these categories:

Ebasco DRs Related to Turnover Packaces lQ2-CS-IC-27 BD-1C-1143

_Q2/3-FW/1C-851 Q1-RC-LWS-RC-2 Q2-SI-1C-89 LW3-RC-29 QMC-APO-P47E

-~Q2-LW3-SI-10F/E

'C(W)-1C-342-CC-1C-6

The? staff - concludes that ~ some. Ebasco and Mercury NCRs and Ebasco DRs were

, questionably -.dispositioned' and that LP&L shall (1) Propose a program that assuresL that all NCRs and' DRs' are ' appropriately upgraded and adequately

. dispositioned ' and corrective action completed, and (2) correct any problem deected.

DISCUSSION:

' LP&LOinitiated a program, beginning in February 1984, to review Ebasco site

) Nonconformance - Reports (NCRs) to verify the ' ef fectiveness of the Waterford 3 deficiency reporting / disposition programs during construction.

That program consisted of a review of Ebasco site NCRs closed prior to initiation of the program' ' (approximately - 7100).,

Each Ebasco site NCR was reviewed and independently assessed by LP&L to-determine if:

~

o The disposition addressed the described discrepancy;

' The NCR was reviewed for reportability 10CFR50.55(e) and 10CFR21; o

and o

The NCR;had received the appropriate signatures.

j This response. discusses and presents suc: mary results of the original review and

~a significantly. expanded program addressing dispositioned NCRs/DRs (voided and administratively closed NCRs are addressed in the response to. Issue 13).

This program provides adequate confidence that the overall construction deficiency

-reporting / disposition system was effectively implemented.

Corrective action as-n asult. of the expanded review is also discussed.

Discussion of the. issue is structured nlong the lines ' of the major elements of the expanded ' program as follows:

I.

. Review of the specific nonconformance reports and deficiency reports identified by the-NRC..

II.

Review of Ebasco Nonconformance Reports III. Review of Mercury Nonconformance Reports IV.

Review of Ebasco' Deficiency Reports.

L 6-2

.y p

Three general conclusions have resulted to' date from the original and e:cpanded reviews, as follows:

[

1.

No additional condition was identified in these reviews which, were it to have remained uncorrected, would have affected adversely the safety of operations of Waterford 3.

I[

2.

Corrective action required as a result of the reviews involved correction of documentation deficiencies, reinspection or engineering

^

evaluation and only limited. hardware rework.

-3.

Due to the structure of the filing system, systematic review of the Waterford -3 construction deficiency documentation is difficult, but is achievable.

I.

Review of the Specific NCRs and DRs identified bv the NRC The Ebasco and Mercury NCRs and the Ebasco DRs identified by the NRC were first reviewed by Ebasco Quality Assurance Engineers.

The NCRs and DRs were reviewed for proper disposition, corrective action completion, appropriate documentation, and proper closure.

Upon completion of Ebasco's review and. required corrective actions, LP&L QA reviewed the NCRs and corrective actions taken by Ebasco, and sampled the Ebasco review of DRs.

The review of NRC identified Ebasco and Mercury NCRs and Ebasco DRs was

.scoped as follows:

A.

Ebasco Nonconformance Reports Thirty Ebasco NCRs are identified by the NRC in this issue.

In addition,.seven Ebasco NCRs related to this issue are specifically identified in Supplement 7 to the Safety Evaluation Report (SSER)*

which was issued on October 1, 1984. summarizes the results of the review of NRC identified Ebasco NCRs to date.

B.

Mercury Nonconformance Reports Twenty-three Mercury NCRs are identified by the NRC in this issue. An additional fifteen Mercury NCRs related to this issue are specifically identified in the SSER. summarizes the results of the review of NRC identified Mercury NCRs to date.

C.

Ebasco Deficiency Reports Ten Ebasco DRs are identified by the NRC in this issue. An additional three Ebasco DRs related to this issue are specific 411y identified in the SSER.

Limited documentation deficienciei were identified and corrected, none of which were safety significaut.

NUREG 0787 (SER Supplement 7 - September 1984) 6-3 4

I

Tha ravi w for sefety significance of the NRC _ identified documenta has Men completed.

LP&L estimates that the detailed review and closure effort of Ebasco and Mercury NCRs and Ebasco DRs idcntified by the NRC in this issue as well as those identified in the SSER is approximately 75% complete.

LP&L estimates that this review will be completed by November 15, 1984.

While QA prcgram procedural deficiencies existed, no safety significant deficiencies have been identified.

II.

Review of Ebasco Nonconformance Reports The review of Ebasco site Nonconformance Reports enccmpassed approximately 98%. of the site NCR numbers issued by Ebasco during the construction of

.Waterford 3.

The review consisted of several elements, each with its own particular level of review.

Figure 6-1 depicts the elements of Ebasco NCR review process in the form of a flow diagram, in order to facilitate understanding of the process.

FIGURE 6-1 REVIEW OF EBASCO NCRs NCR'S ISSUED 8Y ESASCO

~ 7,800 NCR'S I

I I

I INIT8AL LPSL REVIEW OETA4.ED LPSL REVI EW NCR'S CLOSED PRIOR NC R 'S CLOSED TO 2/04 AFTER 2/84 A T,100 NCR' S S32 NC R' S POTENTIALLY POTE Nil A LLY DEFICIENT D E Fif*l E N T SAflSFACTORT.

E8ASCO REVIEW S AflSFACTORY 3rA 6663 NCR'S m 437 NCR'S

& RESPONSES

. Tl NCR'S

,v 46l NCR"3 7

~ Sot NCR' S I

I

__j LPSL R E V I,E W 500 NCRS a

NTAILED SAsePLE REVO S ATIS FA CTO R Y CEFICIENT. PRC9R AW OEFICIENCIES.144 NCR' S yr ev 362 NC R'S SAFETY SIGNIFICANT CEFIC.ENoES.O NCR'S 124 NCR*S y

SATISFACTORY CEFICIENT. P ROGR AM DEFICIENCIES - 33 NCR'S SAFETY Si O NIFIC ANT DEFICIENCIES - 0 NCR'S 6-4

. - ~

s

}--

x 7

The follhwing paragraphs ' discuss the individual elements of the review of Ebasco cNCRs:

A'. _

LP&L OA Review of.Ebasco NCRs closed prior to February 1984 1.

Initial Review In1 February 1984,- LP&L QA initiated a review of Ebasco NCRs. This review was undertaken to verify, by way of a Work Instruction, that:

.a.

The disposition addressed the described discrepancy; b.

'The NCR was reviewed for reportability_ under 10CFR50.55(e) and 10CFR21; and

~

c.

The NCR had received the appropriate signatures.

'Approximately 7100 Ebasco NCRs were reviewed and 437 potentially deficient NCRs were identified. Upon completio'n of the evaluation, it was determined

_that 122 NCRs were deficient in disposition, corrective action, software or closure, or combinations thereof.

Corrective action required as a result of this review involved only limited hardware rework and correction of documentation deficiencies.

Seventy-two of the NCRs were considered.potentially deficient for lack of

' documented ' evidence that they had been reviewed for reportability per 10CFR50.55(c) or 10CFR21.

Subsequent documented reviews of these NCRs determined that none were reportable.

2.-

Detailed Review LP&L selected 124 (approximately 28%) of the potentially deficient NCRs identified in ~ the initial review for an in-depth review.

This review included hardware verification for rework / repair, software verification for updating :as-built-drawings and specifications-and evaluation of documentation for the required corrective actions and retrievability of documentation.

As a result of this detailed review, 33 NCRs were found to be deficient, and seven CIWAs were initiated to address the deficiencies.

None of these deficiencies met the criterion for sefety significance.

Corrective action for~ 30 of the deficient-NCRs involved correction of documentation deficiencies, reinspection or engineering evaluation.

For the remaining three, limited. discretionary rework is being performed.

B.' '

Detailed LP&L OA Review of Ebasco NCRs closed after February 1984

.Ebasco NCRs closed after February 1984 were reviewed as a separate group by

.LP&L QA.

Review of these NCRs was in-depth and was for the purpose of verifying proper disposition,. adequate documentation to support the

-required corrective action, required software changes completed and proper closure.

Five hundred thirty two (532) NCRs were reviewed with 71 NCRs requiring resolution of comments.

Of those 71 NCRs, 24 were determined to have valid deficiencies.

Corrective action for 22 of the deficient NCRs involved correction of documentation deficiencies, reinspection or engineering. evaluation.

For the remaining tuo, limited discretionary rework is being performed.

6-5

m

. Cs

'Eb "co NCR Closura Tim 711nwa

-With respect to'the NRCl concern regarding timeliness of Ebasco NCR closure, Ebasco.~ procedure ASP-III-7,

" Processing o f.

Nonconformance",- required completionL of corrective action within twenty (20) days of receipt of the

--dispositioned NCR.

If ' the verification of corrective action was not completed within the allotted twenty days, a written request for extension was to be filed with the Ebasco Quality Assurance Department for approval.

~

The twenty day time period did not begin until rhe nonconformance report had been.dispositioned and evaluated by the appropriate departments.

The twenty ' day-requirement was for administrative control only and did not adversely affect' the quality of Waterford 3.

In December, 1983, Ebasco procedure' ASP-III-7 was revised to delete this requirement.

All' Ebasco NCRs' closed as of approximately the end of September, 1984 (Approximately '98% -of the - Ebasco NCRs issued) were subjected to an LP&L review as described above.

While program deficiencies existed, and minor rework was required, no' safety significant deficiencies have been identified.

III. Mercury Nonconformance Reports

' Mercury dispositioned approximately.3700 Mercury NCRs.

Of

these, approximately 1700 were upgraded to Ebasco NCRs ano, as such, were reviewed as Ebasco NCRs (See Section II of this response).

The remaining Mercury NCRs were reviewed as.follows:

~A.'

Mercury NCRs - dispositioned "Use-As-Is" were reviewed to assure that

'they were upgraded to Ebasco NCRs, as required.

As a result of this review, 31 NCRs were deemed to require upgrading to Ebasco NCRs.

The NCRs are now identified on Ebasco NCRs, and were processed under the Ebasco NCR program.

B.

Approximately 1850 Mercury NCRs were dispositioned " rework / repair" or "rej ect. "

In most cases, when Mercury designated a deficiency to be corrected by " repair", it was, in fact, a " rework."

For example, in

.dispositioning rej ected welds, Mercury - would specify the veld be

" repaired" in accordance with procedures to meet the design requirements.

This is actually a '.' rework" ' disposition.

Mercury procedures did state that deviations from original design or technical specification outside the tolerances allowed was a " repair".

Mercury procedures required nonconformances meeting this criteria to be upgraded to Ebasco NCRs so that these deviations would be reviewed and approved by Ebasco.

p 6-6

y s

ii A rando.n sample of 66 Mercury NCRs from. those dispositioned " rework /

repair" was selected for review.

These NCRs were reviewed for proper disposition, adequate documentation of corrective actions required and proper closure.

LP&L QA reviewed each sampled Mercury NCR in accordance-with QASP 19.17.

Deficiencies ware corrected and documented. None were found to be of safety.signiricance.

C.

Seven hundred twenty five (725) of the 1850 Mercury NCRs dispositioned

" rework / repair" and " reject" were reviewed by Ebasco for reportability per 10CFR50.55(e). None of the NCRr were determined to b.: reportable.

LP&L.QA selected a random sample of 64 of these NCRs for a reportability review and the Ebasco conclusions were confirmed.

D.

Mercury documented material conditionally released from Ebasco on Material Receiving Reports (MRR) and assigned Mercury NCR numbers to each such MRR in accordance with Mercury Procedure SP664.

Approximately 120 Mercury NCRs of this type were identified by Ebasco.

LP&L reviewed the Mercury files and, although the conditional releases appeared to have been properly handled, there were instances where supporting information (Ebasco NCRs, DNs) was neither referenced nor included-in the documentation package.

The supporting informa;:fon is available and will be either included or referenced, in the NCR packages, as appropriate.

This review of dispositioned Mercury NCRs is essentially complete.

While program deficiencies existed, no safety significant deficiencies have been identified.

The results. of these sample reviews establish a 95% confidence

. level that at least 95% of the total population of Mercury NCRs do not contain unreported conditions reportable under 10CFR50.55(e) or 10CFR21.

IV.

Review'of Ebasco Deficiency Reports The Ebasco QAIRC review of contractors records required that deficiencies be documented on Deficiency Reports in accordance with QAI-9, " Review and Handling of Construction Installation (DRs) Records".

A random sample of DRs generated as result of the review of Mercury and Tompkins-Beckwith records was reviewed for proper closure.

For each contractor, 230 QAI 9.2 Deficiency Report Sheets were selected and reviewed as follows:

A.

The review of Deficiency Reports on Tompkins-Beckwith included 115 Deficiency Report Sheets on piping and one hundred fif teen QAI 9.2 Deficiency Report Sheets on seismic hangers and supports.

These QAI 9.2 Deficiency Report Sheets included approximately 856 DRs.

This review identified 12 DRs which required engineering evaluation and concurrence.

Although minor deficiencies, such as missing references, signatures or dates were identified, the DR closures were satisfactory.

B.

The review of the 230 Mercury QAI 9.2 Deficiency Report Sheets was divided equally among P-2 and P-3 tubing, and tube track supports.

These QAl 9.2 Deficiency Report Sheets included approximately 1173 DRs.

The review identified 31 DRs which required engineering evaluation.

The engineering evaluations are in progress.

Although minor deficiencies, such as missing references, signatures or dates were identified, the DR closures uere satisfactory.

6-7

p 3

q y

LP&L '.QA performed audits of the Ebasco review.

These audits included random samples of the Mercury. and Tompkins-Beckwith -DRs reviewed by Ebasco.. While documentation deficiencies-existed,.no safety ~ significant deficiencies, or

. deficiencies requiring rework,!have been identified.

CAUS r' -

The f review - program. verified that deficiencies were - generally processed in accordance with the site procedures.

However, those procedures did'not provide adequately _ -specific. -guidelines for. the

' implementation cf procedural

-requirements which led - to excessive need for judgements and interpretations.

. Thisf program weakness led to the inconsistencies in handling deficiencies at LWaterford-3 which have been identified by LP&L.and the NRC.

GENERIC IMPLICATIONS The : review. program -encompassed approximately 98% of the Ebasco NCRs and

' statistically, justified samples of Mercury NCRs and Ebasco DRs. The results of an in-depth-review and verification of a conservative sample of NCRs and DRs has provided adequate confidence'that the deficiency system did not allow conditions in dispositioned NCRs/DRs to remain unreported per 10CFR50.55(e) and 10CFR21.

SAFETY SIGNIFICANCE LP&L has p'erformed ~ a review of major elements of the construction deficiency reporting / disposition system.

The results of this review indicate that, in general, ~ the systes was effectively implemented.- The procedures contained the basic: requirements for documenting and controlling deficient conditions.

The

deficiencies identified. during the review of nonconformances are considered minor'in nature and were generally. resolved with the addition of documentation f or further evaluation.

The items dispositioned as rework were based on good engineering practice or management conservatism rather than-on safety

~ significance.. There is no recognized reason that this issue should constrain fuel load or power operation.

r CORRECTIVE ACTION PLAN / SCHEDULE The remaining reviews and corrective actions are expected to be completed prior to November 15, 1984.

~

6-8

p -

ATTACFMENTS:

'l.

. Ebasco Nonconformance Reports Identified by the NRC.

2.

Mercury Nonconformance Reports Identified by the NRC.

REFERENCES None.

6-9 m

{

c ATTACHMENT 1-w EBASCO NONCONFORMANCE REPORTS IDENTIFIED BY THE NRC LTheS following is ~ a - l'ist of ' EBASCO Nonconformance Reports - (NCRs) identified by.

the NRC in Issue No. 6 and. in Supplement 7 to the Safety Evaluation Report

.(SSER). - The list. identifies the NRC Concerns.with each NCR _ and the Resolution or Corrective-Action taken to date.

The list also summarizes. any additional concerns identified as - a result of the LP&L Review and the Resolution or-Corrective - Action; taken to date.

It should be noted that dispositioned NCRs were reviewed for reportability under 10CFR50.55(e) and 10CFR21 and none were found to beLreportable.-

NOTE:

-This is an incremental submittal.

Resolution to those NCRs identified by the NRC.in Issue Number 6 but for which there is no explanation herein are under final review by LPSL.

It is planned to have those

-reviews completed by November. 10, 1984.

- A.

Ebasco NCRs' Identified in Issue No. 6

1. - -NCR W3-1650 2..

NCR W3-3912

'3.

NCR W3-3919 4.

~NCR W3-4088 (Mercury 491)

-(a) NRC CONCERNS

'There was no description attached to the NCR to verify that corrective ac' ion was accomplished or completed.

t RESOLUTION OR CORRECTIVE ACTION 1.

Found and attached a copy of LP&L CIWA 828372, which was issued to perform the corrective action for NCR-W3-4088,

2.

Found and attached a Mercury QC report which verifies adequate completion of corrective action.

3.

Found and attached a Mercury veld data report for the replacement welds.

'4.-

Found and attached a copy of drawing 100-T-035-A, which-reflects the' replacement welds described in #3 above.

.(b) LP&L IDENTIFIED CONCERNS 1.

Inadequate '.'use-as-is" justification provided by engineering, for discrepant items B, C, & G on NCR attachment #1.

2..

Drawing 100-T-035-A showing the affected instrument line was not attached to the NCR.

3.

Supporting veld data documentation was not attached to the NCR.

L 1

6-10

ATTACHMENT l'

- 4.

NCR W3-4088 (Mercury 491) (Continued)

~ RESOLUTION OR CORRECTIVE ACTION

'1..

Obtained and attached additional ESSE evaluctions to the~NCR.

2.

Obtained and attached copy of drawing 100-T-035A to the NCR.

3..

Obtained and attached a copy of Mercury's weld data report for

.the~ replacement welds.

.5.

.NCR W3-4137 (Mercury #420):

(a) NRC CONCERNS

'1.

Improper-NCR closure and reopening.

~2.

Incorrect. reporting system (DN in lieu of.NCR).

RESOLUTION OR CORRECTIVE ACTION 1.

NCR-W3-4137 was ' reopened and processed ' in accordance with

~' applicable' procedures.

(b) ' LP&L IDENTIFIED CONCERNS

-1.

NCR corrective action did not adequately correct the discrepancies.

2.

DN-SQ-1991 was not properly processed in accordance with the

. applicable procedures.

RESOLUTION OR CORRECTIVE ACTION 1.

Deficiency was reinspected.

ESSE evaluated the condition accept-as-is.

2.

Drawing was. revised.

3.

Corrective action for violation of Procedure WQC-150(DN in lieu of NCR) cannot be accomplished since subject procedure 4

has been'retirel.

6.

-NCR W3-4219 7.

NCR W3-5563 (a)_'NRC CONCERNS

1. -

Inspections signed off by an unqualified inspector.

.2.

Inspaction Reports co-signed by Level II inspector 3 years and 5 months later.

RESOLUTION OR CORRECTIVE ACTIONS NCR reopened and CIWA written to re-inspect Fuel Handling Building (FHB) Crane.

6-11

7.y

. m,

/

,.s 1

-ATTACHMENT 1 l7.

'NCR W3-5563 (C'ontinued)-

y (b)- LP&L IDENTIFIED CONCERNS' Same:as above.

RESOLUTION OR CORRECTIVE ACTION

'Same as above.

'8.

NCR W3-5564'

(a) NRC CONCERNS Disposition of NCR for inspection through paint is unacceptable, due to 1 saint precludes adequate visual inspection of the velds.

RESOLUTION OR CORRECTIVE ACTION '

Downgrading.of FHB stairways from - Seismic Class 'I to Seismic Class II eliminates the requirements for visual inspection.

'(b) LP&L IDENTIFIED CONCERNS' 1.

No - QC verification signature on the sketches provided in attachment'#23 of the NCR.

2.

Insufficient ESSE evaluation for downgrading Seismic Class I stairs in the FHB, to Seismic Class II.

RESOLUTION Ok CORRECTIVE ACTION 1.

Ebasco QC performed' and documented a verification of the items identified in the stairwell on NCR attachment #23, and attached the'results to the NCR as attachment #24.

.2.

~ ESSE _ Electricali and HVAC reviewed the information in NCR attachments

1. 23~ and

1. 24, and deternined them to be non-safety..

9.

NCR W3-5565

'(a) NRC CONCERNS

't.

The qualification of the QC inspector who performed the inspection ~of reviewing of the FHB Crane.

2.

.The documentation of the reinspection was not attached to the NCR as directed by the NCR.

'RESOLUTICN OR CORRECTIVE ACTION 1.

The - FHB crane was turned over to LP&L with subsequent testing and reinspection performed by LP&L on 1/29/83 per their procedure SPO-40-002.

2.

The testing-and inspection data performed by LP&L has been a

attached to the NCR.

6-12

m

%._p

-ATTACHMENT 1

'9.-

NCR W3-5565'(Continued)

?

L.

-(b): LP&L IDENTIFIED CONCERNS

~

Noncenformance~was reopened on April.26, 1984 to add attachment-1A.-and. closed the same ' day without documented evidence that-the p:;

investigation as' required in the-attachment was actually

C performed.

i RESOLUTION OR CORRECTIVE ACTION h

' Attachment.5 has b'een added to the NCR to reference LP&L test e

procedure SPO-40-002 which documented the final functional testing 'of the subject crane.

10.-

NCR W3-5586 11..

'NCR t!3-6159' 12.

NCR W3-6165 (a) NRC CONCERNS 1.

There is no indication of measures taken to preclude recurrence.

RESOLUTION OR CORRECTIVE ACTION 0

1.

- A ' review :of - Filler Metal Requisitions and T&B time sheets indicates that welder R-7 not R-1 made the veld -concerned, and'R-1 was'not-employed during the time the weld was made,

,^

. therefore, measures taken;to preclude recurrence were not necessary.

.e 5

=(b) LP&L~ IDENTIFIED CONCERNS F

1.

Documented. verification that welder - R-1 was not on site should be included.

RESOLUTION'0R CORRECTIVE ACTION l.-

Review attached to NCR indicating R-1 not on site during the jy time period weld.~was made.

n k

i 6-13 C

, m ATTACHMENT 1 13.

NCR W3-6221' d

(a).NRC CONCERNS

1'. '

Weld control records signed off by Level I Inspector.

l

.2.

. Letter of designation based on revision of Q. A. Manual not if effect at the.timefof letter issuance.

RESOLUTION OR CORRECTIVE ACTION

'nspectors experience,- education, and 1.

LP&L QA' evaluated i

training and determined the inspector -was ' qualified to-perform.the d.signated activities.

(b) LP&L IDENTIFIED CONCERNS Same'as above.

RESOLUTION OR CORRECTIVE ' ACTION Same'as above.'

.14.

NCR W3-6511

(a) NRC CONCERNS 1.

The NCR only addressed the. fact that the - maximum gap was violated, should have included undersize weld; lack of fusion; are strikes and undercut.

2.

There are no records of rework or reinspection.

RESOLUTION OR' CORRECTIVE ACTION i :

1.

Support was reinspected by Ebasco QC and as-built data supplied to ESSE.

2.

. ESSE accepted support "as-is "

3.

-Documentation posted to Mercury installation package to assure-update to as-built installation documentation.

F.

--(b),

LP&L IDENTIFIED CONCERNS Same as above.

RESOLUTION OR CORRECTIVE ACTION Same as above.

15 ',

~ NCR W3-6597 (Mercury #2870) 16.

NCR'W3-6623 17.

NCR W3-6723 18.

NCR W3-6786 6-14 E

~w

?

ATTACHMENT 1-r:

19.~

NCR W3-7099 s

-(a) ;NRC CONCERNS 1.-

No documentation to adequately support the NCR Disposition.

' RESOLUTION OR CORRECTIVE ACTION

-1.

- Stress calculations utilized as a basis for disposition have been attached'to the NCR.

' (b) - LP&L -IDENTIFIED CONCERNS.

1.

Cracks in heat affected zone of cabinets 48A & 3.

-2.

Smallerithan design embed plates.

3.

. Flare bevel in lieu of fillet welds.

RESOLUTION OR CORRECTIVE ACTION 1.

Cracks - accepted by ESSE.

it.

Embed. plates are the correct size; cabinet 48A requires a split 4"x4"x3/8 TS(which leaves-3" wide exposure) and cabinet'48B required a 4" wide plate.

3.

. Flare bevels, fillets and lengths accepted by ESSE.

20.

NCR W3-7139 l'

-(a) NRC CONCERNS QC data in NCR was incorrect for 2 of'3 radiation monitors.

RESOLUTION OR CORRECTIVE ACTION NCR re-opened _and letter of clarification and inspection report added to NCR.

(b) LP&L IDENTIFIED CONCERNS F&M Inspection Report IR303-71-624 contains only. sheet 1 of 3 and

'does not include a list of the discrepant' supports.

RESOLUTION OR CORRECTIVE ACTION 1 Sheets 2 and 3 of Inspection Report added.

6-15

y in

~

-ATTACHMENT 1 v7 w

x.

R'W3-7140-

.D i(a) NRC CONCERNS-

'None were. listed in the. allegations-associated with this issue in-Supplement'7.to-the. Safety. Evaluation Report.(SSER).

(b)_~LP&L IDENTIFIED CONCERNS i

-1.

-Traceability of rework materials.

? RESOLUTION OR' CORRECTIVE ACTION

1.

' Rework- ' consis ted of additional welding only, filler metal.

requisition form enclosed in documentation of NCR.

22.

NCR W3-7177

-e

23. NCR W3-7179

-(a) -NRC CONCERN

- None ~ were -identified 'in, the ' allegations associated with this issue in Supplement 7 - to the Safety Evaluation Report (SSER).

None were identified in the LP&L review.

24b -NCR W3-7180

'(a) NRC CONCERNS-F&M: procedure -QC-309 violated ANSI - N45.2 Section 13, because it-Ldid not require the tension = tester - serial #, pressure' gage # or calibration date to be recorded..

RESOLUTION'OR CORRECTIVE ACTION

~

ANSI-N45.2, Section(131does not require the recording of serial numbers or, calibration. dates on test reports.

However, during.

the time frame-involved there were only two '(2) pressure gauges that were utilized 'sitewide.(QC ' 4.2.1 & QC. 4. 2. 2).

These gauges

.were maintained ' under Ebasco's M&TE procedure WQC-4.

Copies of the. calibration records lare' attached to NCR-W3-7184.

25.

NCR W3-7181 uw

-(a)- NRC CONCERNS F&M procedure QC-309 violated ANSI N45.2 Section 13,' because l't J

did not require the tension tester serial number, pressure' gage #

or. calibration date to-be recorded.

6-16

fu f

f ATTACHMENT'l 25.

NCR W3-7181 (Continued)

RESOLUTION OR CORRECTIVE ACTION ANSI N45.2, Section 13 does not require the recording of serial

1. 's or calibration dates 'on test reports.

However, during the time frame involved there were only two (2) pressure gauges that were utilized sitewide (QC 4.2.1 - & QC 4.2.2).

These

~

gauges were maintained under Ebasco's M&TE procedure WQC-4.

. Copies of the calibration records are attached to NCR-W3-7184.

~

.26.-

NCR W3-7182 27.

NCR W3-7184

28..NCR W3-7432 (a) NRC CONCERNS

-1.

Concrete pre-placement & post-placement documentation could not be matched.

2.

No specific references were used for voiding the NCR.

3.

QA Engineer approved the Recommended Disposition and then voided the NCR.

RESOLUTION OR CORRECTIVE ACTION 1.

NCR-W3-7431 R1 addressed curing violations. NCR-W3-7435

. addressed the placement documentation.

2.

Late entry added to NCR-W3-7432 referencing NCRs W3 7431.R1

&.W3-7435.

'3.

No t.

a procedural violation per ASP-III-7, Rev. -5.

The recommended disposition was approved-11/23/83; NCR was voided 1/16/84.

29.

NCR W3-7533 30.

NCR W3-7547

-B.

Ebasco NCRs Identified in Suoplement 7 to the SSER The following Ebasco NCRs were identified by the NRC in Supplement 7 to the Safety Evaluation Report published October 1,

1984.

The review of these NCRs is scheduled to be completed by November 15, 1984.

-W3-6514

. 3-5974 W3-5973 W

W3-3941 W3-4593 W3-6719

.W3-5819 6-17

n ATTACHMENT 2 MERCURY NONCONFORMANCE REPORTS IDENTIFIED BY THE NRC

~

The following is a list of Mercury Nonconformance ' Reports.(NCRs) _ identified by.

the ~ NRC in Issue No. 6 and in - Supplement

7. to the Safety Evaluation Report (SSER).

The' list identifies the NRC concerns with each NCR and the Resolution or. Corrective Action taken to date.

The list also summarizes any additional ~

-~ concerns - identified as a - result of the LP&L Review and the Resolution or

. Corrective. Action to'date.

It should be noted that dispositioned Mercury NCRs

- were reviewed - for reportability under.10CFR50'.55(e) ' and 10CFR21 and none were found to be reportable.

NOTE:

This is an incremental submittal.

Resolution to those NCRs identified by.the h1C in Issue Number 6 but for. which there is no explanation.

~herein are under final review by LP&L..

It is planned to have those reviews completed by November 10, 1984.

A.

' Mercury NCRs Identified in Issue No. 6 1.-

NCR-180 (Ebasco NCR W3-6839) 2.

NCR-255~

(a) NRC CONCERNS-None were identified in the allegations associated with this issue in Supplement 7 to the~ Safety Evaluation Report (SSER).

(b) LP&L IDENTIFIED CONCERNS The documentation of the corrective action was nct available for eight of the fourteen supports requiring retorque.

RESOLUTION Ok CORRECTIVE ACTION w

The supports identified as having misplaced documentation were reinspected.

This action ' has been completed. with acceptable results and attached within the NCR package.

3.

Mercury NCR-268

'(a) NRC CONCERNS None were listed in the allegations. associated with this issue in

g Supplement 7 to the Safety Evaluation Report (SSER).

6-18 m

1; ATTACHMENT 2 3.

Mercury NCR-268 (Continued)

(b) Lp&L IDENTIFIED CCNCERNS 1.

This NCR is not a rework as stated, it is a "use-as-is" since as-built information is to be redlined.

2.

Should have been up-graded to an Ebasco NCR.

-3.

No obj ective evidence Ebasco Engineering has approved the as-built conditions.

4.

All deficiencies. identified in the description are not addressed in the disposition completed section of the NCR.

5.

There is not' objective evidence to indicate that all existing field conditions have been incorporated into the redline drawing.

6.

NCR was written 1/26/82 and closed 12/22/82.

Training-records supplied for corrective action are dated 11/29/82 (due to updated revision of five procedures released this date) and 6/17/84 (due to Ebasco audit) there is no evidence of timely retraining of personnel per disposition of NCR.

RESOLUTION OR CORRECTIVE ACTION 1.

The NCR represents a procedural violation for failure to redline the drawing prior to the installation of the supports.

There was no physical rework due to the actual installation being acceptable.

This NCR was written as an in-process deficiency due to the~ inspector's findings during walkdown inspection.

2.

The _ NCR was not used to accept a deviation from design requirements, thus, did not require upgrading to an Ebasco NCR.

3.

As-built conditions were in accordance with Ebasco guidelinea provided to Mercury in the specifications and

' drawings.

4.

The deficiencies identified were addressed by redlining the drawing and requiring the training to address the procedural violation.

5.

Copy of the drawing is attached.

6.

No specific training records could be located for this NCR.

However, as a result of SCD #57, all Mercury personnel were retrained. This training addressed redlining.

4.

NCR-363 (a) NRC CONCERNS An Authorized Nuclear Inspector (ANI) review was not performed for installation of strongback support lugs to ASME process pipe.

RESOLUTION OR CORRECTIVE ACTION ASME process pipe is class 3 and does not require ANI review.

6-19 I

Y' i

ATTACHMENT'2 4.-

NCR-363 R

-~(b)_'LP&L' IDENTIFIED CONCERNS b ;e 1.-

' Mercury lNCRshouldhavebeenupgradedtoanEbascoNCR.

-2.

Mercury Project Engineer did not verify similar installation for like conditions.

{

' RESOLUTION OR CORRECTIVE ACTION 11 ESSE approved the~ existing condition by issuance of an DCN.

-2.

'Ebasco QA reviewed similar installations -and - the review results were placed with the Mercury NCR File.

5.

NCR-380 (Ebasco NCR-W3-4015)

~ (a) ' NRC CONCERNS None were identified in the ' allegations associated with this issue in Supplement 7 to the Safety Evaluation Report (SSER).

'(b) LP&L IDENTIFIED CONCERNS 1.

Three sets of weld data records for support 664-70 are attached to - the NCR.

Unable to determine which record is being used as a basis for acceptability.

-2.

Mercury documentation cannot be found for welding performed by welder M-229.

RESOLUTION OR CORRECTIVE ACTION 1.-

NCR-W3-4015 was revised to NCR-W3-4015 R1 for clarification of this discrepancy.

-2.

Research by Ebasco revealed that welder M-229 was qualified to perform the welding on the anchor: plates.

6.

NCR-420 (Ebasco NCR W3-4137)

L7.

NCR-429 (Ebasco NCR W3-3965)

(a) NRC CONCERNS None were - identified in the allegations associated with this issue in Supplement 7 to the Safety ' Evaluation Report - (SSER).

None were identified in the LP&L review.

8.

NCR-438-(Ebasco NCR W3-4013) 9.

NCR-487 (Ebasco NCR W3-4044) 6-20

r m

k- '-

=

ATTACHMENT 2 10.; NCR-491'(Ebasco NCR W3-4088)-

.11.

MERCURT NCR-528 ' (Ebasco NCR W3-4824)

(a' 'NR'C CONCERNS

~None were identified in the allegations associated with this Lissue in-Supplement 7 to the Safety Evaluation Report (SSER).

(b) LP&L-IDENTIFIED CONCERNS I1.

No statement-or documentation was attached to the NCR to resolve traceability of heat #M2245.

2.

- Disposition of NCR fails' to state whether the correct ID#

was etched on the plate.

13.

No documentation was attached to the NCR to verify corrective action take..

RESOLUTION OR CORRECTIVE ACTION-1&3 Attached a copy of MRR-77-11206 to NCR, indicating heat code MZ-245 (M2245), and associated supplier C of C.

~ 2.

-Field verified heat number 7428779 on anchor plate.

12.

NCR-540

-(a) 'NRC CONCERNS None were identified in the allegations associated with this issue in Supplement 7 to the Safety Evaluation Report (SS ER). -

'(b) LP&L IDENTIFIED CONCERNS 1.

' Documentation not attached to NCR for' replacement of support locator'#31.

2.

Documentation not attached to NCR for replacement of tubing that had cold' spring.

RESOLUTION OR CORRECTIVE ACTION 1.

Mercury documentation was attached to NCR for replacement of support locator.#31 with an acceptable support locator #33.

-2.

Mercury documentation was attached to NCR for replacement of tubing with cold spring.

13.

NCR-554 (a). NRC CONCERNS No documented evidence of corrective action for hanger deficiencies identified during walkdown.

6-21

P

-

,4 K.

ue nt

• ~~

~ ATTACHMENT 2 (13.

NCR-554 (Continued).

RESOLUTION OR CORRECTIVE ACTION-

' Documentation ' search and re-inspection established rework was accomplished.

(b) -LP&L IDENTIFIED CONCERNS

. 1.

No welding documentation for repair of supports.

- 2.

No inspection documentation for repair of supports.

3.

Inadequate documentation of corrective action to correct elongated holes in tube track.

RESOLUTION OR CORRECTIVE ACTION

~

1 and 2.

Documentation search and reinspection established 4

rework was accomplished.

-3. Reinspection established rework was accomplished.

114. NCR-560-(Ebasco NCR W3-5428)

15. NCR-565 (Ebasco NCR W3-4730)

See Mercury NCR W3-568.

16.

NCR-W3-568 (Ebasco NCR-W3-4730)

17. -NCR-W3-591 (Ebasco NCR-W3-4206)'

(a) NRC CONCERNS None were identified in the - allegations associated with this issue in Supplement 7 to the Safety Evaluation Report (SSER).

(b) LP&L IDENTIFIED CONCERNS 1.

The analysis conducted for this NCR was not attached, including ESSE concurrence.

RESOLUTION OR CORRECTIVE ACTION 1.

Calculations were performed by ESSE to substantiate analysis described in NCR. Analysis was attached to the NCR.

6-22

y,_

~-(.

ATTACHMENT 2-18.

NCR-W3-594' (Ebasco NCR-W3-5557)-

(a)..NRC CONCERNS None were -identified in the : allegations associated with this issue' in-Supplement 7 to :the Safety Evaluation Report (SSER).

[(b) 'LP&L IDENTIFIED CONCERNS No docunentation that drawing has been redlined.

RESOLUTION OR-CORRECTIVE ACTION Support.in question. is. a typical - detail and therefore not red lined. Deviation 'isi referenced appropriately in OCR package.

119. NCR-W3-595-(Ebasco NCR-W3-4197)-

l(a) NRC CONCERNS--

None were. identified in the allegations associated with this issue in Supplement 7 to the Safety Evaluation Report (SSER).

-(b)- LP&L IDENTIFIED CONCERNS-

'l'.

Several supports installed which are. not per an approved installation detail.

RESOLUTION OR CORRECTIVE ACTION 1.'.

Description of ' NCR incorrectly written as locator ' "5" was

-actually installed as locator "23".

2.

The anchor' plate installation for locator "23" is acceptable

. per. the' general notes section of the B-430 series detail drawings.

3.

' Attachments to NCR were made : tom clarify installation details.

20.

NCR-614 (Ebasco NCR W3-4219) 21.

NCR W3-625 (Ebasco NCR-W3-5282)

(a) NRC CONCERNS None weye identified in the allegations associated with this

. issue in-Supplement 7 to the Safety Evaluation Report (SSER).

r 6-23

W k

ATTACILMENT ~ 2

'21..NCR W3-625 (Ebasco'NCR-W3-5282 l

'(b)

LP&L-IDENTIFIED CONCERNS 1..

One weld sign--off L for two. welds.

2.

-Reason for voiding installation and location information.

RESOLUTION OR CORRECTIVE ACTION-r

- 1. :

Inspection reports ! identify velder of both joints.

2.

.Information voided due to redline'#6.

22.

NC'l-W3-656 (Ebasco - NCR-W3-4303)

23.. MERCURY NCR-658 (a) NRC CONCERNS No documentation was attached to the NCR as objective evidence for corrective action taken.

RESOLUTION -OR CORRECTIVE ACTION 1.

.A field verification by EBASCO revealed that corrective

' action per the NCR disposition had been properly performed.

2.

Found and attached to the NCR, a Mercury anchor ' inspection report for retorquing of.Hilti bolts.

(b) -LP&L IDENTIFIED CONCERNS No documentation was attached to the NCR as objective evidence for corrective action taken.

RESOLUTION OR CORRECTIVE ACTION 1..

Ebasco field verification revealed that corrective action-per the NCR recommended disposition had-been properly performed (see Ebasco General Inspection report SW-913).

2.

.Found and attached to the NCR, a Mercury anchor inspection report for retorquing of Hilti bolts.

B.

-Mercury NCRs Identified in Supplement 7 to the SSER

.The following Mercury NCRs were identified by. the NRC in Supplement 7 to the Safety Evaluation Report. (SSER) published October 1, 1984.

The review of these NCRs is scheduled to be completed by November 15, 1984.

NCR-313 NCR--674 NCR-888 NCR-322 NCR-675 NCR-889 NCR-337 NCR-676 NCR-2234 NCR-572 NCR-677 NCR-3149 NCR-673 NCR-678 NCR-1830/806 Mercury NCRs 888 and 889 were determined to have been administrative 1y closed and accordingly are addressed in the response to Issue 13.

6-24

y, Q-}

ir b

h

RESPONSE

~ ITEMTN0'. : 10 TTITLE:

Inspector Oualification (J.A. Jones and Fegles)

'NRC' DESCRIPTION OF CONCERN:

.The NRC,scaffLreviewed the qualification and certifications of QC inspectors in the civil / structural area.

The review included the qualifications of four Ebasco insp'ectors, five J.A. Jones inspectors, and eight Fegles inspectors. The inspector qualifications were compared against the requirements of ANSI N45.2.6 and the contractor's procedures.

.The staff found that four of the five J.A. Jones inspectors'and two of the eight Fegles inspectors failed to meet. the applicable certification requirements

-related to relevant experience.

Since these inspectors were involved in the inspection.of safety-related activities, the fact that they may not have been qualified to perform such inspections, renders the quality of the inspected construction activities as indeterminant.

~LP&L shall review all inspector qualifications and certifications for J.A. Jones

.and Fegles against the project requirements and provide the information in such a' form that -each requirement is clearly shown to have been met by each inspector. -If an inspector is found to not meet the qualification requirements, the licensee 'shall then review ~ the records to determine the inspections made

- by the unqualified findividuals and provide a statement. on the impact of the

deficiencies noted on the safety of the project.

DISCUSSION:

A.verificatioa program was implemented to review the professional credentials of

-100% of the site QA/QC personnel who may have performed' safety-related functions

~

at'Waterford23, including supervisors, managers and remaining QA/QC personnel.

The-responses to Issues No.

I and 20 discuss inspector qualifications for

~Waterford 3 contractors other than J.A. Jones and Fegles.

The program, which is being performed under the overall. direction of LP&L,

, consists of ^ three major elements:

.o Collection and verification of personnel data.

o Evaluation of qualifications against specified standards.

.o-

' Dispositioning of deficiencies resulting from cases where inspections and tests.were conducted by personnel whose qualifications against the

. appropriate standards could not be confirmed.

10-1

f$ _

x Collection and Verification of Personnel Data Per'sonnel idata were J collected from' various sources, including site files, fcontractor home. office files, personal contact with individuals or supervisors and through a background verification program.

Efforts were mada to verify the education and work experience of 100% of the J.A.

Jones and Fegles QA/QC personnel by resea.ching Waterford 3 contractor records and by contacting schools, former' employers and others.

The background verification effort for J.A. Jones and Fegles per;onnel was a joint LP&L/Ebasco effort. Uhile the success rate of this effort was good, there were cases where confirmatory information was not obtainable.

In such cases, the judgement of the LP&L Review Board, as described below, was used to rule on the reliability

-of.the available information.

Evaluation of Qualifications to Specified Standards QA/QC personnel data were evaluated in order to classify individuals as either having verified qualifications or not.

Training, education and work experience were the qualifications of primary concern.

These qualifications were verified against the following criteria:

(1)

Inspectors - ANSI N45.2.6-1973 (2) Other QA/QC Personnel - QA Program requirements Initial qualification determinations for J. A. Jones and Fegles QA/QC personnel were performed first by Ebasco and then separately by an LP&L review group.

In order-to control'the consistency of these determinations, approved procedures were utilized.

Determinations related primarily to ' balancing education, experience and training factors.

The LP&L review group qualification determinations were rendered in two categories:

" qualified" and "potentially not qualified".

"Potentially not qualified" determinations were referred to an LP&L Review Board comprised of senior LP&L QA personnel. The Review Board determinations were further reviewed by a contracted individual very. familiar with inspector qualification and related standards. This process resulted in a final determination for all QA/QC personnel as either " qualified", or " unqualified".

The qualification review process is described in QASP 19.12 and QAI-32.

The following points further clarify the process:

1.

The meaning of the term " unqualified" must be amplified.

In some cases determinations were made

that, basad on verified

data, individuals' backgrounds did not warrant qualification to ANSI N45.2.6-1973.

In other cases, however, individuals were considered "unqualifiad" as an expedient in reaching resolution to the concern.

This occurred in' cases in which:

10-2 c

g.

37 d

a

7.... _

s g

W?

t y

s

~

a.

)Research of records,' inquiries to'past employers and employees,-

contact with ^ schools and verification 'of training received was y

J 1either. not possible or. could not be concluded in a ' reasonable

period of. time..

,=

'b.-

Apparent discrepancies existed between-background information provided by some individuals and that obtained in the verification _ process,.and resolution could not be achieved on a l

_ timely basis.-

Minor. discrepancies were' excused; however,.

E 1significant

.' discrepancies -. generally

-rendered any other significant but unverified data as. suspect.

h 2. -

In thex process used.- being judged' as

" unqualified" to ANSI J

N45.2.6-1973 did 'not automatically render the individual's work as invalid. -For example, an individual may not have the education and experience ~ qualifications for all -inspection ' work', yet be~ fully

, competent through specific training or. other. means to perform the particular tasks'. assigned to bim, which migh.t have been very simple' and repetitive in nature.. Juch an individual potentially -satisfies

^

ANSI.. requirements, which ultimately require that an individual's i

qualifications.be sufficient to provide reasonable assurance that the individual'can competently perform a particular task.

Whether or not

.the ~ individual is technically -qualified, the individual's work can be

~ deemed valid..

' 3 ~.

During, the ~ construction period, some contractors made undocumented judgements with respect. to the need for-cye-examinations for-

-inspection personnel.

Such judgements were based on the level 'of r

. visual acuity or-color - perception required to achieve competent.

[

1 inspections.

. Such judgements -were also made-as part

.of, the-

-W verification program and. disposition process and.will be documented.

I It is noted that _ such judgements :are specifically suggested in ANSI -

N45.2.6-1978. This factor was not deemed disqualifying.

Disposition of Deficienc'ies i

.For J.A.. Jones : and Fegles, the LP&L' Review-Bo.ard compiled a list of

" unqualified" -inspector personnel and Corrective Action Requests (CAR) were

, written ' to ' formally track and disposition potential deficiencies.

Limited

[

background. verification ef forts remain for - 'J.

A.

Jones and Fegles personnel.

Should _ completion of the verification cause a change in the results, the response will be amended.accordingly.

i A~

10-3 I

I

Included in Attachment 1 are the verification program results for J.A. Jones and regles.

lor J.A.

Jones, CAR EQA84-22 identified 25 QC personnel who performed inspections while not meeting the requirements of ANSI N45.2.6-1973.

The construction activities inspected by the identified J. A.

Jones personnel with respect to the Common Foundation Basemat and Engineered Backfill were inspected by qualified ' Ebasco inspectors.

Accordingly, inspection by the J.A.

Jones personnel does not render the quality of the inspected construction activities as indeterminate.

Adequacy or the inspected construction activities was independently confirmed by qualified inspectors.

J.A.

Jones inspector qualification deficiencies in areas other than the Common Foundation Basemat and Engineered Backfill will be addressed in a supplemental response.

For Fegles, CAR EQA84-20 identified three QC personnel who performed inspections while not meeting the requirements of ANSI N45.2.6-1973.

The three individuals performed preplacement inspections on a limited scope of slip form operations.

Duplicate preplacement inspections were performed by qualified Ebasco QC inspectors. Accordingly, inspection by the Fegles personnel does not render the quality of the inspected construction activities as indeterminate.

Adequacy of the inspected construction activities was independently confirmed by qualified inspectors.

CAUSE:

ANSI N45.2.6-1973 allows substitution ior education and experience levels by noting that "... education and experience requirements specified for the various levels should not be treated as absoluta when other factors provide reasonable assurance that a person can competently perform a particular task."

J.A. Jones and Fegles, to varying degrees, employed such substitutions in certifying the qualifications of their QA/QC personnel.

However, the verification program revealed that verification of background data was not adequate or documented, documentation of the justification for substitution was sometimes not provided or lacked depth, and/or was not always totally in accord with J.A. Jones /Fegles procedures or the ANSI standards, as currently interpreted.

GENERIC IMPLICATIONS:

This issue has been created generically.

In response to this Issue and Issues 1 and-20, the verification program included 1007 of the QA/QC personnel of all site contractors who performed safety related work.

With regard to future work, qualification and certification of inspectors (including NDE personnel) will be administered through strict compliance with LP&L Nuclear Operations Procedures which meet the requirements of Regulatory Guide 1.58 Rev. 1 (ANSI N45.2.6-1978) and SNT-TC-1A-1975, as applicable.

SAFETY SIGNIFICANCE:

Satisfactory disposition of CAR #EQA84-16 (J.A. Jones) and CAR #EQA84-7 (Fegles) will provide adequate assurance that the installations by J. A. Jones and Fegles will perform satisfactorily in service.

10-4

4 CORRECTIVE ACTION PLAN / SCHEDULE:

Corrective' actions required to ' disposition CAR EQAS4-22 (J.A. Jones) are in

.. progress.- The CAR EQA84-20: (Fegles) corrective action has been satisfactorily completed:Jas described. in' Attachment

~1.

To date, no items of safety

[n significance have been identified.

It is ' currently anticipated that the dispositionc of. QA/QC personnel qualification issues will be completed by

November. 21~,1984. -

t ATTACHMENTS:

- 1.

.Results of Verification Program for J.A. Jones and Fegles.

REFERENCES:

- 1...

QASP 19.12, Review of Contractor QA/QC Personnel Qualification Verification 2.

~QAI-32 Instructions for Verification of QA/QC Personnel Qualifications r

10-5

b e

+:b ATTACHMENT 1 A.

J.A. JONES 1.

On-Site Dates: October 1975 to March 1981

-2.

Scope of Work:

a.

Concrete Construction b.

Concrete Masonry c.

Concrete Reinforcing Steel d.

Dewatering and Excavation e.

Waterproofing f.

Waterstops g.

Mechanical Splicing of Reinforcing Steel h.

Filter and Backfill 1.

Structural Steel 3.

Scope of Inspections:

a.

Material Receiving Inspection b.

Site Fabrication Assembly & Installation Inspections c.

Structural Inspections d.

Civil Inspections 4.

QA Program Requirements / Contractual Commitment:

a.

QA/QC Personnel, except Auditors, ANSI N45.2.6 and Manual TR-1,

" Training / Certification Program",

Procedure POP-N-505,

" Qualification / Certification of Persennel" and Procedure P0P-N-702, " Personnel Training / Qualification /Cortification".

b.

Q.A..

Auditors ANSI N-45.2.23 and Manual TR-1,

" Training / Certification Program",

and Procedure P0P-N-505,

" Qualification / Certification of Personnel" and Procedure P0P-N-702, " Personnel Training / Qualification / Certification".

5.-

Inspector Qualification and Dispositioning of Deficiencies:

The Verification Program identified 55 J.A.

Jones personnel who performed inspections and whose qualifications were determined as not meeting the requirements of ANSI N45.2.6-1973.

Corrective Action Requeat EQA84-22 was initiated to track the disposition of this deficiency.

A-1 L

i I

A review of the work of the identified J.A. Jones inspectors has been completed with respect to the Comon Foundation Basemat, including cadwelds.

This review also included the identification of overinspection performed by qualified Ebasco inspectors who inspected the construction of the Co=on Foundation Basemat.

Where an inspection activity was performed by an identified J.A. Jones inspector, the qualifications of the Ebasco inspector who performed the overinspection of the same activity was checked.

In this manner it was demonstrated that each of the Common Foundation Basemat placements were inspected by one or more qualified inspectors.

The reinforcing bar cadwelds which were inspected by J.A. Jones have also been addressed in the response to NRC Concern No. 11 for the entire NPIS. The cadwelds are deemed acceptable.

The structural backfill inspections performed by J.A.

Jones were overinspected by qualified Ebasco inspectors, in

addition, statistical studies were performed which deconstrate the consistency of the work.

The clan shell Filter Blanket quality was addressed in NCR-W3-5997 including-addressing the uncertified J.A.

Jones inspectors.

The Blanket was found acceptable.

Accordingly, inspection by the J.A.

Jones personnel does not render the quality of the inspected construction activities as indeterminate.

Adequacy of the inspected construction activities was independently confirmed by qualified inspectors.

J.A. Jones inspector qualification deficiencies in areas other than the Comon Foundation Basemat and Engineered Backfill will be addressed in a supplemental response.

Completion of the review of the work of the concrete inspectors on the balance of the J.A.

Jones construction activities is expected by November 9.

This report will be supplemented at tha t time to reflect the findings of that review.

A-2

m

-c T

Jh, g

e 1

s

.i

+

3

.. e

' ATTACHMENT'1 B. 1FEGLES'

..m

.l.'Lon-Site Dates: December:1975 to Augustfl976 (Shield Wall).

1 February 1979 to February 1980'(Dome) 2.

Scope ~of Work:- '

i s-a.;

Designing, furnishing,' fabricating,' erecting and dismantling' slip Eforms for ' shield wall construction and conventional formwork and cF'

supports'for dome construction.

- b.

, Handling, placing and. fastening reinforcing steel.-

c..

Detail reinforcing steel for shield wall slip: form construction..

d.

- Handling, placing and setting ' to.line and grade all items to be

~

embedded in-the shield wall and in,the dome.

e.

-Forming for blockouts - in~ shield Lwall, installing waterstop, removing-forms and patching voids or honeycomb areas.

s

}q f.--

Placing, finishing and -curing ' concrete. by the slip form method 7

.for the shield wall and the dome by conventional 2-stage construction.

l l

-3.

, Scope of Inspections:

=

a.

Material ~ receiving inspection b.

Form erection inspection

[

Placement area preparation inspection 4

c d.,

Concrete placement inspection-

e.. Concrete: finishing and curing inspection f.-

. Concrete repair inspection g.

Pome form decentering= inspection h.-

Reinforcing steel placement inspection 4.; 3QA Program Recuirements/ Contractual Commitments:-

s Fegles - Shield Wall-CSnstruction: December 1975 to August 1976-a.-

-QA/QC Personnel.except Auditors ANSI N45.2.6 and Fegles Procedure QAP-303,

" Quality Assurance Plan" and QAP-303 Supplement #2, "Pe: sonnel Qualifications".

b.

-QA Auditors - QA auditor must be a Corporate QA Manager.

g

?

-Fegles - Dome Construction: February 1979 to February 1980 a.-

QA/QC Personnel except Auditors ANSI N45.2.6 and Fegles Procedura-QAP-303.21, " Qualification of Inspection Personnel".

b.

QA L Auditors - QA Auditor must be a Corporate QA Manager (Level III).:

^

L B-1 s

Y

g-.

4

5.-

Inspector cualification and Dispositioning of Deficiencies:

The Verification Program identified three Fegles QC personnel (out of the original seven. (7) identified on CAR EQA84-20). who performed

, quality. inspections and whose : qualifications twere determined as not meeting the requirements. of ANSI. N45. 2.6-1973.

Corrective Action

' Request EQA84-20 was initiated to track the disposition of this deficiency.-

Ebasco QA has determined that these three Fegles QC personnel were involved. only with the slip form operations (placement series G-511)

..f rom April. to May of 1976.

The three Fegles QC inspectors only perfomed preplacement inspections. These inspections were documented on the ^preplacement checklist.

Further_ research concluded that

.;although these three individuals did perform inspections, qualified Ebasco QC inspectors performed 100%

duplicate proplacement

-inspections.

Accordingly,' ' inspection by the Fegles personnel does not render the quality of the inspected construction activities as indeterminate..

Adequacy ~ of the inspected ' construction activities was independently confirmed by qualified inspectors.

B-2

SUPPLEMENT TO THE RESPONSE TO CONCER14 NO. 13 SUBMITTED SEPTEMBER 4, 1984 DISCUSSION:

As committed to in the Corrective Action Plan / Schedule portion of the response to Concern No. 13, a review of Mercury NCRs has been performed by LP&L QA in accordance with procedure QASP 19.17 to determine whether any were improperly voided or administrative 1y closed.

Also, an accountability of Mercury NCRs was performed to reconcile whether a Mercury NCR document was issued / processed for each given number issded by Mercury Company.

This was accomplished by both a review of the Mercury NCR log and a review of the Mercury NCR documents to assure that the specific categories of NCRs questioned by the NRC within the SSER 7 were obtained.

The results of the review performed on the voided and " administratively closed" NCRs has determined that, except as noted below, they were appropriately processed and closed.

Cases were found where the documentation

• to support closure was referenced, but not in the Mercury NCR file. This documentation is being retrieved from the appropriate files reviewed by LP&L QA and placed into the Mercury NCR files.

Also, the review has shown that all but two of the Mercury NCRs can be accounted for and that two NCRs were incorrectly administracively closed and one was not processed. details the processing / resolution of these five NCRs.

In addition, this supplement provides within Attachment 2 some further clarification as to the processing / resolution of NCR-W3-859 and NCR-W3-981, submitted in the response to Concern No. 13.

There is' no change to the previously stated Cause, Generic Implications Safety Significance and Corrective Action Plan / Schedule.

An addition to the CAUSE as stated in the initial response is:

In the case of Mercury, two NCRs were found to be missing, however investigation revealed these were isolated instances and there was no lack of resolution of the underlying problems.

Mercury failed to process three other NCRs.

An addition to GENERIC IMPLICATIONS as stated in the initial response is:

This isssue has been approached generically. The review has encompassed Mercury voided and administratively cicsed NCRs and all identifiable missing and unprocessed Mercury NCRs.

ATTACHMENTS:

1.

Mercury NCRs that are missing or were never processed.

2.

Discussion of site NCRs W3-859 and W3-981.

REFERENCES:

None 13-12

fI ATTACHMENT 1 MERCURY NCRs THAT ARE MISSING OR WERE NEVER PROCESSED Mercury NCR-2685 The description provided in the NCR Log indicates that this NCR was written against _0CR 1029, instrument number DPI/DPS-HV 5009A, Drawing No. 853-L-183-A to identify "no-fit up date" as the nonconforming condition.

-Since the description noted in the log was not specific as to what item (s) did not have a fit-up date, four areas were considered.

Tnese areas are the following:

1)

Tubing -

The tubing on the noted drawing is ANSI B31.1 and therefore no documented inspection would be required.

2)

Instrument Stand - The instrument stand is installed per Instrument Installations Detail B430 - X14 which is a non-seismic stand and therefore no documented inspection would be required.

3)

Tube Track -

The tube track on the drawing is seismic but no fit-up inspections were required.

4)

Seismic Supports - There were 19 seismic supports on the subject drawing.

These supports required a documented fit-up inspection.

After reviewing the documentation for all 19 supports, it was determined that only one Support Locator (No.

12) was missing a fit-up inspection date on the

" Support Inspection Report" form (262-1).

Further search revealed that the " Support Inspcetion Report" form shows a

late entry of the fit up inspection date for Support Locator No. 12 made by the same person who initiated the NCR.

It is deduced that the same individual identified the nonconformies condition and then corrected it.

As a result of this investigation, LP&L concludes that the condition identified by the missing NCR was corrected and documeatation is available to show resolution.

Mercury NCR-2242 The Mercury NCR Log entry for this NCR was crossed out by the log keeper noting that the NCR was written in error and that the number was never used.

It was found that at about the same time two more entries were made against the same OCR number, the same drawing number and the same instrument that were noted against NCR-2242.

The new entries were NCR-2264 and NCR-2285.

NCR-2285 was closed with the notation that the same problem was tracked via NCR-2264.

13-13 e

Mercurv NCR-2242 Cont'd)

From the description provided in the NCR Log, the same instrument was identified on all three ' NCRs and it was resolved under NCR-2264.

Since the NCR. Log does not describe the specific nonconforming condition, further research was perfor=ed to determine if any situation existed which may have gone unaddressed.

'A review of Mercury QC inspection reports (Form 211) of the same period revealed that three different -QC inspectors noted the same condition during three different walkdowns and recommended that NCRs be issued to correct the discrepancy.

Furthermore, a Form 211 was found which records that an inspection was performed that verified the correction of the discrepancy and thus the closure of NCRs 2264, 2285 and 2242.

As a result of this investigatlon, LP&L concludes that the condition identified by the missing NCR was corrected.

Mercerv NCRs that were never Processed Three nonconformances that were issued but were incorrectly administratively closed or not processed by Mercury Q.A.

Department were NCR-888 dated 9-19-82, 889 dated 9-19-82 and 2734 dated 3/10/84. Mercury should have processed these NCRs; subsequent actions have resolved the deficiencies contained therein. The rationale by Mercury for not processing the NCRs and the resolution by Ebasco to the NCR concerns are provided below:

NCR-888 This NCR-was generically written stating the several Q.C. personnel have been certified. to Level II without documented evidence of qualification requirements.

At the time Mercury's management response was that the NCR was not processed based on "1) initiator not a Mercury employee at time of writing

2) QCP-3110 paragtaph 1.4 references QCP-3040 which does not apply to W-3 3)

ANSI N45.2.6 provisions incorporated by QCP-3050 as approved.

All Mercurf Company QC techs are trained and tested per QCP-3050 prior to performing inspections or tests."

Ebasco's current review of the above document determined that: a) The initiator was terminated on the same date the NCR was initiated. b) Recently a review of all Mercury's quality assurance / quality inspection personnel has been undertaken for adherence to procedural and ANSI requirements relative to qualification /

certification status.

The concern as stated in the NCR and reinspection is addressed - and resolved by the in-depth qualification / verification review being accomplished under Concern No. 1.

NCR-889 This NCR was generically written noting a change to actual field installation versus Mercury's Q.C.

support installation documentation.

Mercury's Support Verification Croup and Mercury's Documentation Review Group had identified numerous deficiencies relative to hanger installation traceability.

At the time Mercury's management response to this NCR was that the NCR was not processed based on: "1) Initiator not a Mercury Company employee at time of writing.

2) The situation has already been identified by LP&L Audits, Ebasco Audits, Mercury Company Audits and case-by-case NCR's.

There is insufficient information to process an NCR of this description.

Mercury Company has established a program to investigate, evaluate and report on these conditions with LP&L and Ebasco Q.A. concurrence."

13-14

'NCR-889 (Cont'd)

Ebasco's current review of the above document determined that: a) The initiator was terminated on the same date the NCR was initiated.

b) Since the time this NCR was initiated, numerous efforts have been undertaken to verify that as-built field conditions do in fact reflect the Mercury as-built drawings:

1)

Ebasco Q.C. verification of supports per procedure ECRRI-3.

A total of 1852 supports were inspected for configuration, dimensions, location, amount of weldcent.

2)

LP&L Construction Q. A. walkdown during the status review of turnover of systems. This consisted of 114 instrument supports.

3)

All N1 (approximately 1600) supports were inspected and documented in accordance with LP&L procedure QASP-19.15.

4)

Mercury NCR-3578 was upgraded to Ebasco NCR-W3-6512 which generically addressed traceability of Mercury supports.

Based on the above efforts and the resulting documentation, the concern stated on the NCR is considered to be resolved.

NCR-2734 Maximun lengths 4" x 3" x 1/4" angle were exceeded on supports 8-000-H-013N, 17-000-H-008N,18-000 -H-013N by 1",

2" and 4" respectively.

Mercury failed to process this NCR.

Ebasco initiated CIWA 018917 to evaluate the cited problem.

Ebasco (ESSE) has evaluated the condition and found it to be acceptable.

LP&L has concurred with ESSE evaluation.

13-15

ATTACHME'.'T 2 DISCUSSION OF SITE FCRs W3-859 and W3-981 NCR-W3-859 The NCR' log entry for NCR-W3-859 indicates " Erection of Plant Process Piping" under subject and-it gives a void date only. The Ebasco Site QA transmittal log has no entry _ relative to this NCR and a search of files in the Site QA records vault and other locations, did not locate the subject NCR.

A review of-documentation pertaining to Ebasco QA audit and surveillance activities _ relevant to the timeframe and general subject of the entry was

-performed.

It was determined that Ebasco Site QA had performed an audit of the piping contractor's site welding program which identified four findings.

There is a possibility that these findings were presented to Ebasco Site QA Management for evaluation and an entry in the log made to obtain an NCR number.

Subsequently, it was probably decided that the findings should be identified in the audit report and not the NCR and the entry in the log was voided.

As a result of this investigation, LP&L concludes that NCR-W3-859 was never issued.

NCR-W3-981 The NCR log entry for NCR-W3-981 shows a July 18, 1978 date of preparation and includes a specific heat number, type and size of welding electrode. The Ebasco Site QA transmittal log has no entry relative to this NCR and a search of files in the Site QA records vault and other locations, did not locate it.

A review of documentation in file, applicable to the subject welding electrodes heat number revealed that the manufacturer of these electrodes had submitted a corrected _ certified material test report for that heat number.

Apparently, Ebasco Site QA had anticipated.that an NCR would be necessary to identify deficiencies in the original certified material test report that was submitted with the welding electrodes and a NCR log entry was made.

However, the receipt of the corrected certified material test report resolved the deficiency and the entry was voided..

As a result of this investigation, LP&L concludes that NCR-W3-981 was never issued.

13-16

JCY

~

r

RESPONSE

-ITEM NO: 20

. TITLE:

Construction Materials Testine (CMT) Personnel Oualification Records NRC DESCRIPTION OF CONCERN:

.The Inquiry. Team effort included a review of the disposition of the generic problem, identified during the LP&L Task Force verification relative to GEO Construction Testing (CEO) documentat' n for personnel qualifications in the area of CMT.

The utility should conduct a review of supporting documentation for GEO corrective action stated in Attachment 6 of NCR W3-F7-116 (Ebasco W3-6487).

This1 review should focus on the identification of CMT personnel placcd in GEO Categories 1, 2, or 3 who were apparently qualified solely on written statements by other individuals attesting to the individuals training and qualifications.

For such - individuals,. the applicant should pursue any new information or evaluations which could provide further assurance in support of the actual past work, experience and training referenced by the written statements.

DISCUSSION:

, As requested by the staff, LP&L has pursued and obtained additional information on the GEO individuals perfo rming inspections and tests as will be explained in the sections of this response entitled " Collection and Verification of

- Personnel Data" and " Disposition of Deficiencies". - Also, evaluations have been

'made of work performed by GEO personnel as briefly cutlined herein.

A verification program was implemented to review the professional credentials of 100% of the site QA/QC personnel who may have performed safety-related functions at Waterford 3, including supervisors, managers and remaining QA/QC personnel.

Assessment of the qualifications of all CEO Construction Material Testing (CMT)

. personnel, including those identified in Attachment 6 of Ebasco NCR W3-6497 (the NRC reference to Ebasco NCR W3-6487 is apparently a typographical error), was a part of that verification program.

The responses to Issues No. I and 10 discuss inspector qualifications for other Waterford 3 contractor personnel.

The program, which is being performed under the overall direction of LP&L, consists of three major elements:

o Collection and verification of personnel data.

o' Evaluation of qualifications against specified standards.

o-

.Dispositioning of deficiencies resulting from cases where inspections, tests or data collection vore conducted by personnel whose qualifications against the appropriato standards could not be confirmed.

20-1

y

'Cnll'etion nr.d V rificati*n of Personnni Data Personnel data were collected from various sources, including site files, contractor home office files, personal contact with individuals or supervisors and a thorough background verification program.

Efforts were made to verify the education and work experience of 100*: of the GE0-CMT QA/QC personnel by researching Waterford 3 GEO-CMT records and by contacting schools, former employers and others.

While the success rate of the background verification effort for GEO-CMT was good, there were cases whero confirmatory information was not obtainable.

In such cases, the judgement of the LP&L Review Board, as described below, was used to rule on the reliability of the available information.

Evaluation of Oualifications to Specified Standards QA/QC personnel data were evaluated in order to classify individuals as either having verified qualifications or not.

Training, education and work experience were the qualifications of primary concern.

These qualifications were verified against the following criteria (1)

Inspectors - ANSI N45.2.6-1973 (2) Other QA/QC Personnel - QA Program requirements Initial qualification determinations for CEO-CMT personnel woro performed first by Ebasco and a separately by an LP&L review grcup.

In order to control the i

these determinations, approved procedures were utilized.

consistency Determinations related primarily to balancing education, experience and training factors.

Th'a LP&L review group qualification decorminations were rendered -in two categories:

" qualified" and "potentially not qualified".

"Potentially not qualified" datorminations were referred to an LP&L Review Board compriaod of senior LP&L QA personnel. The Review Board determinations wore further rosiewed by a consultant very familiar with inspector qualification and related standards.

This process resulted in a final determination for all QA/QC personnel as either " qualified", or " unqualified".

The qualification review process is described in QASP 19.12 and QAI-32.

The following points further clarify the process 1.

The meaning of the term " unqualified" must be amplified.

In some cases determinations were made that.

based on verified

dats, individuals' backgrounds did not warrant qualification to ANSI N45.2.6-1973.

In other cases, however, individuals were considered

" unqualified" as an expedient in reaching resolution to the concern.

This occurred in casos in which:

a.

Rosearch of records, inquiries to past employers and employees contact with schools and verification of training rocoived was either not possible or could not be concluded in a reasonable period of time.

20-2 s

I b.

' App:rcnt discr:p:ncico cxiettd b:tw n b:ckgrcund informrtion f

.provided by some individu.ls and that obtained in the verification process, and resolution could not be achieved on a timely basis.

Minor discrepancies wete excused;

however, significant discrepancias generally rondered any other significant but unverified data as suspect.

2.

In the process used, being judgod as " unqualified" to ANSI N43.2.6-1973 did not. automatically render the individual's work as invalid.

For example, an individual may not have the education and experience qualifications for all inspection work. yet be fully competent through specific training to perform the particular tasks assigned to him. which might have been very simpio and repetitive in nature.

Such an individual potentially satisfies ANSI requiromonts, which ultimately require that an individual's qualifications be sufficient to provida reasonable assurance that the individual can competently perform e particular task.

Whether or not the individual is technically qualified, the individual's work :an be deo nod valid.

3.

During the constructim period, CEO made undocumented judgoments with respect to t'ho need for eye examinations for inspection personnel.

Such judgements were based on the lovel of visual acuity or color perception required to achiavo competent inspections. Such judgoments were also made as part of the verification program and disposition process and will be documented.

It is noted that such judgoments are specifically suggestod in ANSI N45.2.6-1978.

This f actor was not deemed disqualifying.

4.

Some individuals were classified as inspectors but performed no safety related inspections and were otherwise not involved in quality related work.

To the extent such individuals were identified, they wero excluded from the overall inspector population.

Disposition of Deficiencios For thoJo individuals found " unqualified" the LP&t. review board initiated Corrective Action Roquest (CAR) EQA84-11 to formally disposition the identified deficiencies.

Ebasco 11G-W3-6497 will be rooponed to reflect the disposition of that CAR.

Disposition of CAR EQA84-11 was acconplished by 3 methods as follows:

1)

Ansessment of Kay CMT ennes and of nkilin required to perform those tents.

The key tests were as follows:

a)

Concreto - The anost inportant test is the final cylindor break tost as this test servos to confirm the stre.ngth of the concreto actually placed in tha structure.

Other testa on concrotu are generally either performed na monsures to avoid subsequent replacement of sub-specification concreto or woro performed in collecting the concreto for sn1 preparing of the toot cylinders.

The break test requires minimal skill in sotting up and starting a compression device which compressos a pro-molded cylindor to failure.

A largo gauge records the force required which is casily translated into the data required.

20-3

P,..

Further confidence in the quality of the as-built material is provided by the fact that improper operator action would tend to degrade test

results, i.e.,

improper testing would cause the concrete to appear less strong than it actually is.

j b)

Soils - The most important test is the field density test as it measures whether the backfill material has been compacted to specific requirements.

The field portion of the work, which was performed by the technician, - consisted of digging a small _ hole and placing the removed soil in an airtight container, positioning a rubber balloon apparatus over the hole, inflating the balloon to a predetermined p

pressure and reading a volume indicator scale.

Further, confidence in the quality of the as-built material is provided.by the quantity of tests conducted.

As stated in the engineering report supporting the response to issue 7,

to insure control of backfill placement approximately three times as many field density tests were conducted as required by the technical specifications.

c)

Cadwelds - There was only one test on cadwelds conducted by GEO-CMI and that was the break test.

This test is as simple as the concrete break test. The test specimens are secured in a tension device, tension is applied and the failure strength is read from a gauge and recorded.

The review indicates all cadweld tests were conducted by personnel qualified to ANSI 45.2.6 (73)

It has bem determined that only minimal training would be required for an unskilled individual to become proficient in performing the above tests.

A single demonstration coupled with minimal practice under proper supervision is sufficient. GEO has formally confirmed that " Prior to being assigned to production work, all personnel were trained to pctform the work required."

On the basis of the above, though not strictly qualified to ANSI N45.2.6-1973, individuals could be considered competent to perform the technician or data collection-type functions described.

2)

Ouality of Testing Performed by Personnel in Question A detailed analysis was conducted of inspection / testing performed by a L.

large sample of Level I personnel in question.

This sample is felt to include the most. significant exposure in terms of potential for inferior inspection / testing.

Level II and III personnel either performing or directly supervising the performance of the tests described above should be

-competent to perform such functions.

20-4 u

o 3.

Engineerine Evaluation J A statistical analysis was conducted, using industry standard techniques, to evaluate test. results for concrete. and the class A back#ill (Reference 3).

In the case L of-concrete both the overall and within-test coefficients of variation demonstrated excellent control of the product which would not.be the case had

.the. tests'not been well, conducted.

Backfill test results also demonstrate good consistency..This evaluation verifies the overall adequacy of the work of all levels, Levels (I, II and III) of GEO-CMT QC personnel.

~

As stated before.. all cadweld tests. were conducted by personnel considered qualified.

CAUSE:

Implementation-of ANSI N45.2.6-1973 allows substitution for education and experience levels by noting that "... education and experience requirements specified : for tho' various levels should not be treated as absolute when other factors provide reasonable assurance that a person can competently perform a

.particular" task."

GEO and its predecessor organizations issued certifications of qualifications for testing personnel under successive programs which employed such substitutions. and which became more detailed and batter documented with time. The program in place since 1978 generally parallels the ANSI Standard for

-inspector _ certification.

However, the verification program revealed that verification of background data was not adequate or documented, documentation of the justification for substitution of other factors for the requisite degree of

. training, education or experience was sometimes not provided, lacked depth, was not totally ~ in accord with. contractor procedures or the ANSI standard, as currently interpreted.

GENERIC ~ IMPLICATIONS:

This. issue has been treated generically.

The scope of the verification program included 100%. of the QA/QC personnel of all site contractors who may have performed safety-related work, including GEO CMT personnel.

'+

With regard: to future work, qualification and certification of inspectors (including NDE personnel) will be administered through strict compliance.with LP&L Nuclear. Operations Procedures which meet the ' requirements of Regulatory

~ Guide 1.58 Rev. 1 (ANSI N45.2.6-1978). and SNT-TC-1A-1975, as applicable.

' SAFETY SIGNIFICANCE:

The results.of the verification program and evaluation of the work performed by

'! unqualified" GEO CMT personnel provides reasonable assurance that the related installations: will perform satisfactorily in service.

There is.no recognized

reason that.this issue should constrain fuel load or power operation.

20-5 C=.

-, ~... _ _

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+

y CORRFCTIVE ACTION PLAN / SCHEDULE:

-On.the basis.'of ReferenceL'3, CAR EQA84-11 hcs been dispositioned.

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REFERENCES:

. I '. -

[QASP19.'12,ReviewmfContractorQA/QCPersonnelQualificationVerification.

-2.-

QAI-32,' Instructions for Verification of QA/QC Personnel-Qualifications

3. --. Engineering Evaluation uf Report on the Review and Analysis of the work of-GE0'-' Construction Material Testing.-

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COLLECTIVE SIGNIFICANCE PURPOSE:

In respense 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 la 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 purpcce 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 te 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 i=plemented, wculd provide reasonabla assurance that such deficiencies would be precluded from occurring in che future.

Review. the LP&L operational phase Qu'ality Assurance Program to determine'whether the lessons learned are reflected.in the Progrcm 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:

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

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

~

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 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. s

,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 E 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 the

-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 followc:

~

Mercury: Those issues involving resolution of work within' the. scope of Mercury's effort.

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 phys'ical rework to address the findings.

iTheisignificance 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..

p-t 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 ef fectiveness of the co rrective action program. undertaken by LP&L as a result of the problems identified in the Mercury program in 1982.

Additional questions as to the of fectiveness of the QA review of Mercury work are included in the following NRC concerns:

Issue Title 1

Inspaction 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.

Welder Qualifications (Mercury) & Filler Material Control (Site Wide)

Analysis of these concerns shows (a) improvement in, but continuing problems with, the control of Mercury ef forts 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, 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 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 personnel were not properly qualified.

This action could have then resulted in a more effective corrective action to address the Mercury concerns as well as early identification of the issues found in Issues 1, 10 and 20. La m

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. (2 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 U

Lpublic -' health' and safety.

This is demonstrated by. reverification and-i testing activ1 ties both _ asj a-part of-the Mercury corrective action program.

L establishedi in11982_ and as a part _of1 the responses to the twenty three.

4

-issues.

. Thel-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.. r_einspection of all N1 instrument-

. lines"resultedlin c small. amount of rework, most of which _ was elective and

~

none 'of Wh'ich 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 Eshortcomings.but. that these -did not result in problems implying

inadequa'ies-in plant-hardware.

c 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 similarisituation (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).

L

-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 Cadwelding" 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'b_ackfill was adequate to perform its design function.

In Issue 11, the

~

.~_

' quantity of data did not allow ready analysis to demonstrate the attributes-

?

~ desired. Therefore, LP&L transcribed cadweld data onto computer storage to -

demonstrate. compliance -with Regulatory Guide 1.10 and specification tsampling frequencies.

The(review identified three minor discrepancies not Lidentified.in : the prior - NCR and these were evaluated and found to. be acceptable..

Issue;8 " Visual Examination of Shop Welds During Hydrostatic Testing",-was ithe result of a ch'eklist that only identified field welds.

This concern L

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< had 1 been : ~ previously identified in. June 1983 and dispositioned to rdemonstrate the adequacy - of the visual examination of shop welds and the

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lack of!any safety impact. The review gives no indication of deficiencies.

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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 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 ta the NCR being written, and the use of a preassigned block of NCR numbers. The review of Mercury NCR's concluded that there was 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 procedures.

Issue 16 " Surveys and Exit 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 interview program has been completely restructured and is providing a very useful service in obtaining feedback on individual's concerns.

Feedback received prior to the restructuring is being reanalyzed and concerns are being closed through an orderly closure process.

3.

Inspection / Evaluation:

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.

Three of tl e 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 personnel have been classified using conservative and standardized acceptance criteria as

" qualified" and

" unqualified".

These classifications were reviewed and finalized by an LPSL-Review Board of senior QA personnel and subsequently by a consultant very familiar with inspector qualifications and related standards.

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 has not required reinspection.

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

For corrective actions not yet completed, there have been nany other methods (e.g. ANI, NDE, prerequisite preoperations/ integrated testing, overinspections, etc.)

which provide assurance that quality has been built into the plant.

To date, there have been no safety significant hardware changes found and this provides positive evidence as to the adequacy of the overall construction program. L

h Issue'4, "Lcwer Tier Corrective Actions Are Not Being Upgraded to NCR's"

. required an extensive effort to review document packages, based en 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 cccurred.

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

'iti does -indicate. a deficiency in the construction program, it does not indicate ' ' that there was a loss of control over non-conforming materials, ports, 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 incomplete 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 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

. 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 e

._ determined by taking a minimum -10% random sample of each contractors information requests _(for fifty or less such documents, there was a total review) and expanding that sample by 10% increments wherever there was a violation of' design control.

Apprcximately 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 over these contractors was a deficiency in controlling records in accordance -with the construction program procedures.

There are no remaining open issues.

The response to Issue 17 "QC Verification of Expansion Anchor Characteristics" recognizes a shortcoming in not specifically delineating all characteristics on an inspection checklist although the necessary characteristics were listed elsewhere.

The expansion anchors were the subject of several different corrective action programs as part of the 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 expansion anchor adequacy. The shortcomings in the original inspection 1 checklist are considered a procedural deficiency in the construction program, but a current lack of safety significance was demonstrated. c

r

. Issue ~ 18 - Documentation. of Walkdowns of. Non-Safety Eelated Equipment" resulted from.the documentation by exception practices used during previous

~

t plant "two lover one" valkdowns.

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 walkdcwns.

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 extensive efforts.on this matter,' including confirmatory field verification of three items, it.was determined that no.significant comments or open items were

untracked and that there was no impact on testing or system operation.

There were two separate issues in Issue 22 "Wolder Qualification (Mercury) and. Filler ' Material _

Control (Site wide)".

The

first, welder qualifications, was resolved by a thorough. review of welder documentation and welder-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 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 left uncorrected, two of - the reworked items presented a potential safety concern.

Of thess

.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 'El instrumentation walkdown initiated in response to Issue 1,

" Inspection Personnel. Issues" has_ identified ' deficiencies that, if left

' uncorrected, would not have ef fected the safety of plant operations.

The conclusions on Mercury-correction actions were discussed earlier.

p u L.

' 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 installations 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 records deficiency in the' construction program was four ' 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 insufficient attention-was given by Mercury personnel to specified installation 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

-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 enecmpass 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 Steamline 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 bolts where documentation was not available and bolt identification could not.be readily verified. Upon ideatification 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.

_a_

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Issue 15 " Welding of.; "D"- Level l Material Inside Conta'inment" resulted in a

' reinspection of the-most-significant- "D"

_ level welds.

.The. findings identify a deficiency-in-the construction program-because no record keeping Erequirements L were. specified in the CB&I.QA program for these type welds.

.The reinspection of welds identified weld-deficiencies that were evaluated tolbe acceptable "as is" andia number of arc strikes that required rework

' (grinding) ~to demonstrate that no damage to base' metal had occurred.

It o

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 grcund-water.

As a. result of this walkdown a piezameter standpipe will be pressure'greuted prior to fuel load to limit further. seepage. This rework was identified esen 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.

-l

Conclusions:

The twenty - three -issues have been assessed and corrective actions have been orc are : being taken to correct deficiencies found. The safety significance of L ongoing activities andl 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 b

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 1 is confirmed by the extensive re-evaluations and reinspections conducted -in. response to the l23 issues and by the minimal rework - required as a result of the conearns'. The plant as-built can be

~' operated'without undue risk to public health and safety.

IIDENTIFICATION'Op. LESSONS-LEARNED Lessons learned were developed fr'om'the twenty-three issues for the purpose of-evaluating ;the ability 'of the operational phase Quality Assurance Program to b

preclude the mistak'es 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 brief 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.

8 -

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t TABLE.1 ACTIVITIES REQUIRED TO RESOLVE THE TWENTY THREE ISSUES Inspection /-

(1)

-: Concern ;

' Software Evaluation Hardware 1

D e-2

.D 3.

L 4-X

~

5 X-.

6' D

.y y

8.

X

.9 x-

.. l 0 '

'X-11 X

.12; PS 13 X

'14 X-15 D

16-X 4-1' 7 y

18 X~

19' ~

D L20.

X

21

-X

22 X-

-NOTES:

(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 left uncorrected but the-significance was limited because of the isolated nature or limited extent of'the deficiency.

u

_9 TABLE 2 OPERATIONAL READINESS ASSESSMENT PAST FUTURE Actions Which could IInvc l

Prevented Occurrence Icsue.

(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 ll.D.

2 Recognize that quality records required by Documentation (objective evidence af acceptance) requirements 10CFR50 Appendix B sometimes exceed the record during normal operations are defiacd 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 I1.11.

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 II.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 inherent design /

implementation of corrective action at Waterford 3.

The construction interface problems associated quality deficiency mechanisms utilized by LP&L are described 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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OPERATIONAL ~ READINESS ASSESSMENT 4

s PAST' FUTUREi 3-t t

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gy cActions Wliich~Could'Have, Prevented Occurrence-4 Iesue (Lessons Learned)

. Reflection in Operational'QA Program'-

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~The concern'could have:been avoided iffit had.

fAny.qualityJrelated mater'ialirece'ived on site,with..

been recognized that'while CE handled

conditional; certification"is - tracked in 'accordanceTwith the-

~

certifications differently-than.other vendors:

proceduresTfor' Discrepancy. Notices"as,describedfin Section that did not eliminate the1 requirement to.

II.B.1.b.

i track' conditional ~ certifications;in order to-ensure closure.

6 a.'Some of the concerns could'have been.

a.Under.the;operationsiphaseQA' Program,;inorder.to1 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 CIMA (plant identified)'or DN-contractors) for the disposition and-(receipt inspection identified) aslnotednin Section; resolution of deficiencies.

'II.G.3.

s

b. Some of the concerns could have been Lb. All-quality related deficiencies identified duringLthe avoided by establishment of a routine operations phase undergo verification review of the process for additional verification

' corrective action.and disposition. prior to closing out. thel (including field verification) of'the deficiency. The deficiency identification and resolution resolution to assess the adequacy of, mechanisms are described in detail in Sections:II.B.I.a-f.

dispositions and corrective 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. verification management overview designed to. distinguish audit of the CIWA' closure process. In' addition, Operations.

generic trends and root causes of.

QA utilizes a QA Trending Programs.to identify; adverse deficiencies from isolated significant.

quality trends and generic quality. problems as described occurrences or repetitious occurrences of in Section II.B.I.a.

less significance,

c. Given the need for more consistent

c. During the operations phase, the Quality Assurance Section.

engineering judgement, some conc' erns 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 specific disposition of past problems.

undesirable programmatic trends. identified.at Waterford 3 will be reviewed during these sessionsLas described 11n Section II.E.2.

Additionally, the QA Section will~

.preparc, for, distribution to plant staff performing quality related work. similar briefing material as a feedback mechanism for current quality concerns.

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' FUTURE.

s Actions Which Could Have Prevented Occurrence.

.lesue' (Lessons Learned)

T Reflection in! Ode' rational QA Program (

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.d. Recognize the need'for ready retrieval /'

d.' Records are processed uponfcompletion'of.'the activ'ity?and control of records. This would be assisted' verifiedicomplete byTeognizant supervisoryLpersonnel. Alli ci by processing records as the' work is.

' Quality records.during the operations phase arefmaintained-c complete'd through all required reviews,-

. by; LP&L's Project Files;' Documents are ' stored f and ' cross-L resolutions of comments, and-necessary:

indexed to facilitate timely retrieval..' Records..

verification and'then vaulting thelrecords.

management is further described In Section II.l.'--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 expected to be complete..and any necessary programmatic changes.will be initiated by November 30, 1984.-

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7 This concern could have been avoided if, as

Records are processed upon completion of the. activity'and work was completed, records were retrieved

' verified complete by cognizant. supervisory personnel.l Quality 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 II.I.

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,.sua During the. operations phase, any. change in scope of the work was completed, records vere verified as contractor's' responsibilities.would initiate an LP&L review complete against the scope of work.

of the applicable portions of theLeontractor's.QA program similarly to what is required for a new: contract.

Such 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'ccrtified to ANSI N45.2.6-1978 and imposed for judging QA/QC personnel-Regulatory Guide 1.58 Rev.. ).

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.

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N" i, OPERATIONAL READINESS' ASSESSMENT --

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- PAST-FUTURE-

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>U 11 This concern.could havelbeen' avoided >1f, in This concern relates'to' bulk construction!andEis?not-addition to' in-process analysiscondu'eted, a.

. applicable to:the: operations phase.:

Emeans to-track'the completioniand< 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 reviewfof.

'been recognized that scoping of complex

. corrective' actions occur-during the, operations 1 phase..

corrective actions'(e.g. multiple 1 contractors, Corrective action must be implemented and. tracked:through ones complex' drawings, Hand construction of.the deficiencyfidentification 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 tor

' establish a tracking mechanism to ensure completion'and; closure.

1 13 Some concerns could have been avoided'through.

The operations phase QA Program provides -for dif ferent 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.... The quality deficiency identification deficiency documents that have characteristics mechanisms,lall of which provide foria controlled tracking such as: multiple interfaces;-require system, are discussed in Sections-II.B.I.a-e.

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

14 This concern could have been sJoided-if Plant modifications during the. operations phare are procedures regarding information requests had accomplished through the Station Modification Program 1(SMP) 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 s

training to ensure a ' proper. understanding and cases where. work'cannot be done in accordance with:the.DCP.-

awareness of the proced,ure 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 11.B.I.a, as.well as the S!!P closure' review described in

. Section 11.11.'

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TABLE 2 OPERATIONAL? READINESS ASSESSMENT.

PAST FUTURES Actions Which Could Have Prevented Occurrence

~~

Issue.

(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 I 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 completeness of required documentation. The Station Modification process is described in Section 11.11.

16 This concern could have been ' avoided if the The LP&L Quality Team has been constituted to allow any program had-been auditable, if more formal individual to express 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 II.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 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 inepection sections and checklists.

documento to the inspection procedures, instructions and checklists.

16 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 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 avoided by a requirement to ensure adequate I 1. 11.

and more auditable documentation of the inspections.

19 There is no path for groundwater to flow in N/A.

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sufficient quantity to flood the auxiliary building basement and, therefore, no deficiency exists.

TABLE 2 OPERATIONAL'RFADINESS ASSESSMENT PAST FUTURE Actions ~ Which Could llave Prevented Occurrence Issue 1 (Lessons Learned)

Reflection in' Operational QA Program 20 This concern could have been avoided if a During tlie operationa phase, LP&L and contractor inspection uniform and conservative standard had beer.

~ personnel will be certified to ANSI N45.2.6-1978 ai,d 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 employmeiit experience as described in Section II.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 systens.

No system.

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

identifying and resolving quality related losues. This resulted in the achievement of

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optimum hardware quality however full understanding of the day-to-day coordination between those groups of the open items and their status could have been enhanced by better documentation and training.on that process.

22

a. Concerns could have been avoided if records

a. As a result of this issue, LP&L is evaluating the Waterford had readily a]Iowed'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 process 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.

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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 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 vork 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 LF&L QA Program (see Section II.G).

The problems.

Engineering and Systems Development (Fi Group 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 deccribed 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 f'ull 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 utafting 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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TABLE OF CONTENTS SECTICN PAGE

_I.-

.QA Program Overview 1

A.

. Organization 1

B.

QA Program Scope 2

12.

-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'0versight 4

' 1.

Safety Review Committee 4

2.:

Yearly Management Audits of the QA Program 5

3.

"QA Trending ProgramfQuarterly Reports 5

4.

15.. ' Quality Assurance Program Status Su=maries 6

Plant Operations 7 Review Committee 6

6..

Quality Inspection. Activities Status Reports 6

7.

Licensee Event. Reports 7

8.

Availability. Improvement Program Reports 7

9.

. Independent Safety Engineering Group-7-

-10.

. Operations Assessment and Information Dissemination 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 2.

Generic Quality Teficiencies 16 a.

lQA Trending Program 16 b.

Availability Improvement Program 18 c.

Hardware Trending 19 C.

Staffing 20

.D.

Certification of Inspection Personnel 21 Le

Q TABLE OF' CONTENTS

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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.

JAudit/ Review Programs 24 1.

. Nuclear Operations QA Audit / Monitoring Programs 24.

a.

-Audit Program 24 b.

Monitoring Program 25

2.

JPlant 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 L2.

. Conduct of Contractor Quality Assurance Audits 30 3.

Deficiencf Reporting by Contractors 31

- H.

Station Modification Program 31 I.

Records 33 m

b.

OPERATIONAL PHASE QA PROGRAM ASSESSMENT The,individualfresponses and the prior discussions in this analysis of

" collective signific'ance" 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, itois appropriate to review the Waterford 3 operations phase QA Program with a focus:on the lessons lea'ued from the 23 issues.

r 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.

..the QA Program will be covered in detail in counterpoint to the issues raised in the 23 NRC concerns.

I.

QA Program Overview 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 Services Manager, Project Manager-Nucleari Corporate Quality Assurance 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.

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 crganization, an overview of the performance of these activities relative to QA Program compliance is accomplished by QA personnel through reviews and audits.

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m QA3s? divided into wo groups. The Engineering and Systems

. Development QA-Group conducts-surveys.and audits of contractors and evendors, maintains'the-Qualified. Suppliers List, reviews procurement.

R L packages,L and conducts : surveillance. of : quality 1related suppliers.

The cNuclear Operations _QA' Group-assures.that'the QA Program-at the site is E eing effectively implemented.

b Operations.QA is a' relatively -new-organization.. It became-a functional

^

quality management' tool: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,

. monitoring, review and. quality. trending programs for Waterford 3.

LThe Plant Quality Department reports-to the Plant Manager-Nuclear.

y This Department has: direct responsibility to implement the requirements of the.QA Program related to onsite-initiated-activities Lincluding review,-inspection.-verification and surveillance requirements.-

B.. !QA' Program ~ Scope s

JAs'describidLin the LP&L QA Manual,~ the-QA Program is' applied to

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all. quality-related areas of plant operation.

For safety-related items, c

Tall applicable portions of the ()A Program (1~.e. Appendix B) criteria are

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applied. The ()A 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 7 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 toicover. additional areas such as security and radioactive waste management.

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- 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-simplement 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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' Monitoring of-quality program implementation 1.

rmed through inspection ~and'surveillances during operation, man.

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modification. repair, material _ receiving, and storage

'rities.

i Maintenance. cad modification instruction, and work plans reviewed by Plant Quality personnel to assure.the inclusion of ins.

-ton requirementstand:to verify that methods and acceptance crit, are

' d efined.' Inspections are performed bysqualified Plant Quality Lpersonnel.. 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 interface 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 action.. Furthermore, through various trending programs the generic

significance of individual deficiencies 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 ot 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 intended to. amplify on selected aspects of the operational phase QA Program which reflect. incorporation of'the major lessons learned irca 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 anLoperating plant. With minor exceptions, the Operations 1QA 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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6

The following discussions are divided into nine major areas:

A.

Management Oversight

-B.

Quality Deficiency Identification and Resolution C.

Staffing D.

Certification of Inspection Personnel E.

Quality Assurance Indoctrination and Training F.

Audit / Review Programs G.

Control of Contractor Quality-Related Activities H.

Station Mcdification 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 managemenc 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 mansures during the operation activities at Waterford 3.

The Senior Vice President Nuclear Operations, c'e Plant Manager, and other ut?'ser executives employ a number of management tools to implement

<d v.' date the operational QA Program.

1.

Safety La :vw 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 organisation. The SRC Charter requires a minimum of quarterly reviews of the resulta 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 reviewing the individual audits and their findings, the subcommittee reviews the schedule of audits as prepared by the Operations QA Group to assure that it is in conformance with the requirements of the Technical Specifications and to ensure that audits are being conducted on a timely basis in accordance with that schedule.

4

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s Because the SRC-is concerned with an overview of plant E

operation, and identification and review of significant safety l

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

' 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 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.

2.

Yearly Management Audits of the QA Program Audits of the Quality Assurance Program are conducted as specified in the QA Manual, Chapter 18.7, and in the FSAR, Section 17.2.

These audits are currently scheduled in accordance with QA procedure QASP 18.12.

Management audits are conducted by an independent audit team from the Middle South Services Quality Assurance group. Members of the' audit 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 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 prevent 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.

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.

3.

QA Trending Program Quarterly Reports The Operations QA Group administers a QA Trending Program intended to identify adverse programmatic quality trends and initiate corrective action.

While other mechanisms exist to identify and correct. individual quality concerns, the QA Trending Program will allow management a tool to identify t

underlying "co= mon mode" sources of quality deficiencies.

The QA 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 Nuc1 car 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 Operations 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 provisiens 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. C:

V

- 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 reportable events described in 10CFR50.73. The EEC is responsible to the' Plant Operations Review Ccmmittee.(PORC) and the Plant Manager.

t Any individual' identifying a reactor trip, transient, safety related equipment failure or malfunction, radiological event, security event, violation of a technical specification, or other events deemed to be potentially reportable, are responsible for initiating a potential reportable event (PRE) report.

Following 1

any necessary immediate 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.

Generally, corrective action is documented and tracked via one of the deficiency identification mechanisms discussed in Section II.B.l.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

-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 Improvement Program Reports

^

The Availability Improvement Program (AIP) is currently under development by LP&L for implementation during the operations phase.at Waterford 3.

Quality related problems, as described later in this submittal, will be periodically reported to senior management.- Whereas'the QA Trending Program will provide managecent input as to adverse programmatic trends, the AIP will b

provide adverse trend.information on the system / hardware level.

1 9.

Independent Safety Engineering Group One of the functions of the Independent Safety Engineering Group (ISEG) is to prepare and conduct-independent reviews of plant t 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. rom them are logged by the ISEG group for purposes of tracking and resolution.

To keep canagement appraised of ISEG activities, an ISEG Monthly Su= mary 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. n

. h -

10... operations Assessment and Information Dissemination Group The Operations Assessment'and Information Dissemination Group (OA&ID) is responsibic:to the Nuclear Safety Supervisor for

-screening,fevaluating, and disseminating operational experience information. :A significant management overview function'that the OA&ID group will' provide.is the detailed evaluation of selected LP&LLLicensee 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.

ill..

Quality Team c _

LThe LP&L Quality Team offers concerned individuals the

-opportunity to voice quality concerr.s 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 ot' individuals providing information tosthe 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 sto 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.

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 prior'to the present Team configuration (see NRC Concern

1. 16).

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.~

ps 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.l.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 Quality 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.

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

a.

Weekly Status Report of the Quality Team Program Activities b.

Quality Team Monthly Status Report c.

Quality Team Deficiency Trends Statre Report (weekly) y m

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4 f B.-:

Quality Deficiency Identification and Resolution 1

~

l Inl maintaining and improving quality ;a comprehensive program must-s (exist to_ identify.and. correct. quality deficiencies. Two components

~

Lare'important_-for successful implementation of such a program.

i.

First', sufficient;means and opportunity should,be available to

~ identifyland correct-individual quality concerns as_they occur.

--Secondly,-al capability should exist to assess the-identified

' deficiencies as'a whole'to~ determine whether they are isolated

'-occurrences or dueEco underlying common causes. The LP&L QA Program l incorporates provisions-for both components of quality deficiency

-identification.

1.1 (Isolated Quality Deficiencies LLP&L 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)

Jissued 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 i

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x necessary for effective resolution:

1)n cause is identified either explicitly or_as part of the trending program, 2)

- appropriate corrective action is implemented,

3) a'means of A

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tracking.the ~ deficiency and corrective ~ action (s) to completion

'is available, andJ '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-U 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 implementing routine maintenance.

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-ORIGINATION:

If, during t*1e course - of inspection, testing or operation,' a. condition adverse to quality is identified by any Waterford 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

.a immediate attention, corrective maintenance may not commence 3>

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 Roem 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.co be a departure from specified

requirements and, (1) is not the. result of. normal wear'or,

(2)iis noteaLsecondary effect'due to failure of~another'

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component, or-(3) is not identified.as a routine part of the work process and will be corrected as a contir.uing part of the work process, or (4) is dispositioned as " repair" or "use-as-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 s

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 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.commenceme'nt of-vork by the responsible Maintenance Supervisor and Plant Quality Group (for quality related work packages) to ensure inclusion of.

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accurate and complete work instructions and/or-inspection Hold Points.

Subsequent changes which change the scope of work or acceptance criteria are reviewed by the same review 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 MTS (Master Tracking System). The MTS identifies all archived and activn 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 adequacy of the CIWA a:M corrective action. All CIWAs identified as Non-Conformance are periodically analyzed by Operations QA for adverse quality

. trends. The Nuclear Safety Section of the Project 7

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 MRB, 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 MRB 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 tag 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 necessary 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.

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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

. 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 follouing:

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 the 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 monitoring 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..

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r CORRECTIVE ACTION' IMPLEMENTATION: The delivery date'of the 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 recommends approval and closeout of the CAR. 'The original CAR is given 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 wil.1 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 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 ofLthe audit report:

a)

Review and investigate the condition described in each audit finding,

.b)

Schedule appropriate immediate corrective action to correct the deficiency and to prevent' recurrence, and c)

Respond to.all findings within (30) days af ter acknowledging the audit finding. The response must clearly state the corrective action implemented and/or the scheduled date targeted for the completion. %

s CORRECTIVE ACTION VERIFICATION: The QA Audit Supervisor 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 personal observation or verification, that corrective action is accomplished as scheduled. The verification review also assures that the corrective action is adequately identified and implemented for each finding, including considerations for:

a)

Similar conditions b)

Corrections as to cause c)

Software aspects d)

Hardware aspects e)

Schedule f)

Completeness f.

NRC Inspection Reports ORIGINATION: These reports are transmitted to LP&L by the NRC Region IV office. A summary of NRC inspected areas of operations, maintenance, administrative controls, and license activities are contained therein and may identify open items, unresolved items, and/or Violations / Deviations.

CORRECTIVE ACTION IMPLEMENTATION: The Nuclear Services Manager and the Nuclear Support and Licensing Manager are responsi' ole for the coordination of reviews and preparation of responses to NRC Inspection Reports. This task is performed by the Onsite Licensing Unit of the Licensing Section.

The specific task is performed by the Licensing Engineer (LE) through the development of a Licensing Action Plan (LAP). This plan may necessitate input from other departments and is transmitted to them through the use of a Licensing Information Request (LIR) form. The LIR is responded to and certified by the respective departments via the Task Review And Certification (TRAC) form. The response is reviewed by the LE for consistency with the LAP, LP&L commitments, completeness and the FSAR. Inspection Report responses are reviewed by the Plant Manager, Licensing Manager, and the Nuclear Support and Licensing Manager prior to transmittal to the NRC.

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

LIRs are tracked from inception through completion by the LE via the computerized Licensing Commitment Tracking System.

Responses to the NRC pertaining to Inspection Reports and 10CFR21 are further validated by the Operations QA group via QASP 19.13 prior to transmittal to the NRC. _ _ _ - - _ _ _ - - _ _ _ _ _ _ _ _

M' 2.

Generic Quality Deficiencies 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 o ganizations initiate corrective action for Waterford 3 programmatic deficiencies.

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

CIWAs (Condition Identification and Work Authorizations)

QNs (Quality Notices)

DNs (Discrepancy Notices)

AFRs (Audit Finding Reports)

CARS (Corrective Action Reports)

NRC Inspection Reports For each dccument the assigned QA representative will 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 Plant Records Management Control of Purchased Materials and Services Identification and Control of Materials, Parts and Components.

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0 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 theJfollowing:

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- 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 organizatio.a.

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 summary reports (including 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 identification of trends in programmatic deficiencies. u o

PT Management Overview 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 will 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 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 measurem'ent 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.

.Upon determination of the root cause of the problem, corrective action will be implemented as necessary and tracked to completion. Verification of effectiveness 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 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 Laplementation of the AIP.

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

c.

Hardware Trending 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 history of all. plant system components. This will enable LP&L managers to detect equipment trends in systems under 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 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 list 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 provide plant management with advance notice sufficient to take the necessary corrective actions to prevent failure of such equipment vital to nuclear safety. s

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'In programs of this magnitude it is inevitable that changea will be necessary.. JAs LP&L gains more experience in quality trending.-program refinements will be made to support the 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.

x 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.

' Staffing LC.

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 28-1 Plant Quality 13 13 i

Quality Assurance-46 42

.The operations phase QA organization is divided into'two main groups -

Nuclear Operations QA and Engineering / System Development QA each of operations phase is detailed below:

~ QA staffing for the which is further subdivided into 3 sections.

Authorized

-Staff Staffing Level Nuclear,0perations 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 --

e D.

Certification of Inspection Personnel Inspection personnel during the operations phase of Waterford 3 including those provided by contractors are certified in accordanca 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 cxperience.

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 t'ae 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 recertificatien 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 delinante (1) the specific functions personnel are qualified to perform and (2) the criteria used to qualify personnel in each function; and f)

. Documentation concerning training and qualification programs which describes the content, who attended, and results of tests as required by the training program are maintained.

,y 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 perform assigned tasks at Waterford 3.

Training is implemented through:

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 whert 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, regulacory codes and standards are brought to the attention of QA personnel. Lessons learned or corrective actions as a result of quality deficiencies or undesirabic programmatic trends identified at Waterford 3 and other nuclear generating facilities will be reviewed during these sessions.

The Quality Assurance Section Training Committee was formed on 12/16/83 to review the goals, objectives, effectiveness, and implementation of the training program for the Quality Assurance 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 ef fectiveness and future direction of the QA Training Program.

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An evaluation of the 1983 QA Training Program by this "ad hoc" groupistressed.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 r

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 Ecompany operations.

The success achieved by the Quality Assurance Section in meeting their training goals is evidenced in a Good Practice noted by 1NPO during a recent corporate assistance visit (December 1983).

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

"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 4

9-and has been well received by QA personnel."

'3.

Contractor Training Contractors supplying quality related services to LP&L for which they conduct.their own quality inspection and surveillance functions, are responsible for training their inspection personnel-and documenting their qualifications under their own QA programs.

These programs must meet or exceed the requirements of LP&L's QA Program, including training, before such vendors can be placed en 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 performing quality related work onsite, implementation audits of vendor activities are conducted by Operations QA personnel (refer to Section II.G.3).

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

LP&L managers directly supervising these personnel are responsible for ensuring they receive the proper QA training.

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. t__

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' Audit / Review Programs' 1..

~ Nuclear' Operations QA Audit / Monitoring Programs a.

zAudit Progran.

LAs 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 Reviews, Safety

-Review Committee direction, etc.. Regularly scheduled audits 7

care supplemented by scheduling additional audits for reasons Lsuch as:

a.

Significant changes are made in functional arecs 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 annually,' includes items of noncompliance previously-identified to.the NRC between the two preceding Corrective Action Audits. Those items are also included within the H

audit-checklist of the Corrective Action Audit conducted one year later to ensure that the corrective action for those items remains in compliance with commitments made to the NRC. i L=

f 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 Opcrations 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 cf 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 perforned 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 packages. This review ensures that the procedure or work package addresses applicable NRC requirements, Technical Specifications, applicable quality requirements and commitments 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: -.

'E 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, 5)

Docucents 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.

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.

b.

Hold Points

-Inspection Hold Points are required whenever there is a reasonable 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.

The following are examples 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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Nondestructive examination.

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Cleanliness and foreign material exclusion,-including cleanliness'.of components with1 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-maintenanceJand/or. modification testing.

~ 5)

Characteristics of materials or components, such as

-surface-finish, hardness, dimensions, leveling.

~ lignment,. torque, and clearance.when such a

characteristics are critical to safety and when they will not be verified-in subsequent tests or

~

' inspections..

c.

Quality Instructions Quality. Instructions (QIs) are provided for those quality.

.related activities of the Plant Quality organization outside lof 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, Spare. Parts Equivalency Reports, Major Changes, Major Exceptions and Transfer Requests. The QR verifies during his review that 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 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 antil resolved.

2)

Materials Receipt Inspection - Quality related materials received on site are controlled through the use of a Msterials 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 manuf acturer 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, g) 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.l.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 instructions.

bm' 5)

-Housekeeping inspections - This instruction provides for the use of Quality Inspection checklists to verify prescribed standards of cleanliness in various plant arena for the purposes of personnel safety, morale, contamination-atien control, fire prevention and degradation of plant operability. Discrepancies are noted on the Quality Inspection Checklists and tracked and resolved through the Inspection 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) forma.

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.

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 with 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, Corporate QA Manager, Safety Review Committee, Control Room Supervisor, individual company involved, Plant Manager, applicable department supervisor, and the Plant Operations Review Committee. When the deficiency is corrected, or sufficient steps have been taken to ensure that further noncompliance will not occur, a Stop Work Order Release (SWOR) form is issued by the Plant Quality Manager to allow work to resume. A SWOR form notes the corrective action taken and the reason for release.

'G.

Control of Contractor Ouality 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. 9

~ _

A

~ An' initial evaluation of ' a prospective contractor is performed

'by reviewing the contractor's:

j Current quality assurance program manual, procedures and a.

i records;

-b.

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:

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.

m

. 2.

Conduct of Contractor Quality Assurance Audits 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 audic group will be contracted which has been qualified to LP&L's QA Program to conduct these audits. Audits will be conducted triennially per NRC Regulatory Guide 1.44..

W 1b.

.On Site Auditing and Monitoring of Contractors

' The Nuclear Operations Quality Assurance Manager directs audits of.those organizations'not within LP&L that are

~

perforning 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 s.

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

. 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.1.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 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 (SMP) 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...ere taken into account.

The LP&L Quality Assurance Program requirea that documentation appropriate to satisfy 10CFR$0 Appendix B will be generated and retained. m ;

V hr Typical SMP Contents. include:

1.

' Summary Functional Description 2.

List of Attachments a)-

Purchase Ordtrs/ Requisitions b)

Recommended Spare Parts c)

New or Revised Drawings / Description Documents / Tech Manuals / Equipment Specification / System Description d)

Vendor Inforection e)

Design Calculations / Analyses f)

Work Procedures 3.

Lis", of References 4.

Bill of Material 5.

Installation Instructions 6.

Examinations (e.g. NDE requirenants, PSI /ISI surveillance requirements) 7.

Testing (including acceptance criteria) 8.

Nuclear Safety Evaluation checklist (10CFR50.59 review)

Modification is perforced via the Condition Identification and Work Authorization (CIWA) process described in Section II.B.1.a. Detailed Construction Packages (DCPs) are prepared 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 SMP.

For minor changes, the Action Engineer may authorize a Detailed Construction Package Change (DCPC) in which case a detailed description of the change is documented prior to implementation 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 Statio.t 1 Coordinator and the Action Engineer who had the responsibility for developing the package. Thn Action Engineer assures that all work was accomplished according to the SMP and that acceptance criteria are met. Contro1~ Room controlled drawings are redlined to reflect the change. Die Action Engineer then initiates a Hodification Project Closecut Review form, and forwardo it to the SM Coordinator

~32-

N R

l (SMC).. The SMC forwards a Work Completion Notice to all affected-

'r-

. disciplines so that appropriate documents are revised. Completed Document Update Forms are returned.to the SMC to certify that all

. af f ected drawinga,. procedures, programs, and/or training plans have s

been revised and approved.

At this time the CIWA is closed and. the SM Closecut Review form initiated and.sent to the Systems Engineering Department Head for review and approval of the Modification Project

-Closure Review form.

See Section 1I.1.3 for. quality review and Jstorage of SMPs.

I.-

Records 1.

Project ~ Files Project Files is the focal point for3 storage and maintenance of uncontrolled records and documents. The filing system used is a ecmputerized 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, subj ect, 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' conten,ts 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

.y been indoctrinated in the proper procedures for control of documents. The Project Files Supervisor may authorize temporary access when individual requirements cannot be handled by the g

Project Files personnel. QA records may be accessed by request for work / review, but' may.only be reviewed in designated

~

controlled areas.

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..o 2.

Dccument Control

All controlled documents such as approved drawings,

. specifications,' procedures, technical manuals, safeguards

'information...FSARs and SMPs are. processed by the Document

-Control. Group. This includes receiving, recording, Edistribution,: 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 standard 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 Group is 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 closure and-transmittal to Project Files. A Quality Reviewer (QR) completes a' QA Review Checklist on the SMP to ensure that reccrds 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 review'and approval is indicated on the records, applicable codes and quality standards are identified, test and inspection requirements are documented, and safety evaluation and design-verification is performed.

~

TComments from~this. review are tracked and closed out on a standard Procedure Review Cocments sheet, ensuring completeness

.of the SMP. The Checklist, comments sheet and any additional-Lx '

records generated by the QR's review are filed for storage.

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'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, CIRAs, QNs, DNs, Stop Work Orders, QC h~

isurveillances, QC Inspector certification, hold tags, conditional release tags, various NDE documents, calibration records, and NDE personnel qualification'and training records.

4.

LStatus.

i

During the construction: phase, records management was primarily

[G, -

handledzby 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 L'

through the LP&L Records System. Additionally, to assure continued'high quality in records storage and retrieval, LP&L b

1 management is evaluating the current records management ~ process i5 Efor-Waterford 3 to identify any. areas needing improvement.

It y~

is expected that appropriate recommen'ations of this evaluation d

will be. initiated by November 30, 1984...

.