ML20093M574

Forwards Responses to Issues 4 & 9 of 840613 Ltr Re Safety Evaluation Study.Program Plan for Issue 9 Re Welder Certification Revised to Reflect Info Developed Since 841010

ML20093M574
Person / Time
Site:	Waterford
Issue date:	10/19/1984
From:	Cain J LOUISIANA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
W3B84-0801, W3B84-801, NUDOCS 8410230009
Download: ML20093M574 (32)

Text

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l Louisiama e,,-s1-1 2 O W E R & L I G H T! NEWCREANS LOUSANA

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70160 . [SO4] 595-22O4 soag a s J.M. CAIN October 19, 1984 Preside'n t and Chief Executive Officer W3B84-0801 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 W3B84-0495, J.M. Cain to D.G. Eisenhut,

" Revised Program Plan" dated October 10, 1984

Dear Mr. Eisenhut:

The purpose of this letter is to submit Louisiana Power & Light's responses to Issues 4 and 9 as set forth in yoor June 13, 1984 letter (Reference 1).

The response to Issue 4 follows the approach set forth in the Attachment to Reference 2. The Program Plan for Issue 9 (enclosed) has been revised in order to reflect the information developed since October 10, 1984. The response to Issue 9 follows this revised approach. Current assessment of each of the issues is as set forth in the responses.

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

8410230009 841019 PDR ADOCK 05000382 A

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~ Mr.-Darrell G. Eisenhut, Director Page 2 W3B84-0801

-October 19,11984

- The Task Force has indicated by separate correspondence (enclosed) that it is satisfied with the logic of the responses to Issues 4 and 9. However, it.has not yet completed its independent validation of the facts. The Task Force

- has committed lto notifying me and the NRC imme,diately 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.

Si er ,

P.'. Cain

- JMC:DA:pbs Attachments s

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Mr. Darrell' G. Eisenhut, Director Page 3 W3B84-0801 October 19. 1984 cc

.Mr.-R.S. Leddick Mr. J. Harrison Waterford 3 QA Team Leader Mr D.E. Dobson Region III 700 Roosevelt Rd.

Mr. R.F. Burski.

Glen Ellyn, IL 60137 .

Mr. K..W. Cook Mr. J.E. Gagliardo Director of Waterford 3 Task Mr. T.F. Gerrets Force Region IV Mr. A.S. Lockhart 611 Ryan Plaza Suite 1000

+

Arlington, TX 76011 Mr. R.P. Barkhurst Mr. D. Couchman EMr. L.' Cor. stable NUS Corporation USNRC ' - Waterford 3 910 Clopper Road

~Caithersburg, MD 20878 Mt, R.D.. Martin U.S. Nuclear Regulatory Commission Mr. R.L. Ferguson Regior.-IV UNC Nuclear Industries 1 611 Ryan Plaza Suite 1000 719 Jadwin t Arlingtoo,"TX. 76011 Richland, WA 99352

.t f Mr. D. Crutchfield Mr. L.L. Humphreys U.S. Nuclear Regulatory Commission UNC Nuclear Industries Washington, D.C. 20555 825 Jadwin Richland, WA 99352 Mr. G. Knighton, Chlef

. 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. 2. Douglass Mr. D. Thatcher Baltimere Gas & Electric

• Waterford 3 Instrumentation & Control 8013 Ft. 2mallwood Road Leader Baltimore, 10 21726 7920 Norfolk Ave. MS-216 '

Bethesda, MD 20114 Mr. M.K. Yates, Proj ect Manager Ebasco Services , Inc.

Mr. L. Shao Two World Trade Center, 80th Waterford 3 Civil / Structure Team New York, NY 10048

-Leader 5650 Nicholson Ln. Mr. R. Cnristesen, President Rockville, MD Ebasco Services , Inc.

Two World Trade Center New York, NY 10048

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n PROGRAM PLAN ISSUE: 9 DATE: 10/19/84 TITLE:

d Walder Certification

' DESCRIPTION OF ISSUE:

Locate missing documents for instrument cabinet welds and determine if welders were appropriately certified to the i positions they welded. Take appropriate action to assure the quality of the supports if. documentation cannot be located.

LP&L APPROACH TO RESOLUTION:

NCR W3-7549 was generated on 2/1/84 and supplemented on 4/6/84 to resolve this problem.

i A review of Weld Inspection Reports (WIR) was conducted. The review identified no cases where welders did weld out of a

qualified position. However..the documentation was not complete, and it could not be conclusively established that out.

j of position welding never took place. To assure the quality of the supports, 17 of the 18 cabinets were reinspected 3

(welds on cabinet C-2B were inaccessible).

i This reinspection identified some welding deficiencies which were evaluated and found to be acceptable with no rework i required, i

A review was conducted to identify the scope of Jones other welding. The welding identified by this review was arranged

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i into twenty-two work packages. Welding for six of the twenty-two packages were reinspected and found acceptable.

Based on the extensive reinspection and evaluation described above, with no deficiencies identified requiring corrective i action, it is concluded that Jones welding was adequately performed.

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4 WORK _ INSTRUCTIONS AND PROCEDURES EMPLOYED:

! COMPANY- PROCEDURE NUMBER TITLE i

LP&L QASP 19.10 QA. Inspection Structural Steel Weldments QASP 19.13 Response Verification W-SITP-14 Site Inspection and Test Procedure for Welding Inspection (J.A. Jones)

QASP 2.12 QA Section Qualification and Certification of Inspec* ion Personnel ORGANIZATIONS INVOLVED:

ORGANIZATION FUNCTIONS PERFORMED PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS

. Ebasco 1. Scoping of documents where J.A. 1.'The review was carried out.by Construction Engineers

, Jones potentially performed welding. under the supervision of the Resident Civil Engineer.

2. Determination of all specific 2. The review was carried out by Construction Engineers welding performed by J.A. Jones and under the supervision of the Resident Civil Engineer, determination that proper Documentation review was performed by a QA Engineer '

i documentation exists, under the supervision of the Site QA Supervisor.

3. Reinspection of the seven instrument 3. Reinspection of welds was performed under the 4

cabinets where supporting supervision of the Material Applications Engineer.

j documentation could not be located i was performed in accordance with

, the criteria of NCR-W3-7549.

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4. Reinspection of other eleven (11) 4. Same as item 3) above.

instrument cabinet welds in accordance with QASP 19.10.

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5. Engineering evaluation of those 5. Evaluation performed by a Civil Engineer under the j welds where supporting documentation direction of the ESSE Civil Supervisor.

could not be located.

! 6. Engineering evaluation of those 6. Same as item 5) above, welds for the eleven (11) cabinets with all supporting documentation..

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1 ORGANIZATIONS INVOLVED: (CONT'D) i

' ORGANIZATION FUNCTIONS PERFORMED , PERSONNEL QUALIFICATION / TRAINING REQUIREMENTS LP&L 1. Validation per QASP 19.13 by LP&L QA 1. Validation will be performed under the' direct will consist of, but not be. limited supervision of the LP&L lead. auditor who is qualified to, the following: to ANSI N45.2.23 (1978).

a) Review of supporting

> calculations.

b) Review of all weld inspection i reports for J.A. Jones structural steel on instrument cabinets.

.specifically addressed by response.

. c) Verify that objective evidence exists to support statements of 4

fact made in the response. ,

) 2. LP&L supervised inspection of welds 2. Qualification / Certification was accomplished in j in accordance with QASP 19.10. accordance with ANSI N45.2.6(1973).

ATTACHMENTS:

] 1. Process Flow Chart - Review of J.A. Jones Welds and Welding Documentation i

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ATTACHMENT 1 PROCESS FLOW CHART - REVIEW OF J. A. JONES WELDS AND WELDING DOCUMENTATION Locate Welding Documentation

't Determine if any welder welded Yes

• Generate an Ebasco out of a qualified position > NCR and process as such No v

Determine if welding was done Yes by another contractor or welds _ End Review are non-safety No v

Determine if documentation Yes is complete (Note 1) y End Review No t

Inspect welds in accordance with Criteria of NCR-W3-7549 or QASP 19.10 8F Engineering Evaluation

• None of the welder documentation reached this point.

Note 1: While documentation was found in order for 11 instrument cabinets, these welds will also be reinspected.

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t NUSCQ;e-GAATON

[ ?detueaceve.$asa q NUS-W3-A737 October 17, 1984

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Mr. J. M. Cain President and Chief Executive Officer Louisiana Power and Light Company 317 Barrone Street New Orleans, Louisiana 70160

Reference:

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

Dear Mr. Cain:

We understand that you plan to submit LP&L responses to the NRC covering Issues 4 and 9 of the referenced letter.

The Task 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 complet'ed its independent validation of the facts presented in the responses. We will notify you and the NRC immediately 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 :ollective significance is continuing and will culminate in a formal report to you.

Sincerely, I

a ' d 8'au'l Levine Vice President and Group Executive Consulting Group, NUS

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Larry L. $umphreys Ih President i ,

UNC Operations Division .

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k- ~ 2A M n Robert L. FergQ on Chairman UNC Nuclear Industries SL/en p

@ A Halbburton Company

RESPONSE

ITEM NO.: 4 TITLE: Lower Tier Corrective Actions Are Not Being Upgraded to NCRs NRC DESCRIPTION OF CONCERN:

The staff reviewed the Corrective Action system to verify if lower tier corrective action documents were _being properly upgraded to NCRs as required by

.1'O CFR Part 50, Appendix B Criteria XV and XVI. Specifically the staff looked at a number of Field Change Requests (FCRs), Design Change Notices (DCNs), and Engineering Deficiency Notices (EDNs) selected from printouts of safety-related equipment and systems document issuance logs. The selected documents were reviewed for content and basis for issuance (i.e. before the fact design change or after the fact nonconformance). Finally a walkdown was performed to verify proper identification and change control completion. In addition Tompkins-Beckwith (T-B) Discrepanev Notices (DNs) were reviewed.

As a result of its review the staff found the following issues.

a. Field Change Requests - Sixty-three FCRs and 21 revisions to FCRs were evaluated._ It appears as though 35 should have been NCRs and another 4 reflected conditions that may have warranted an NCR. The list below provides examples of FCRs that should have been NCRs.

F-MP-1818 F-AS-1631 F-AS-3698 F-E-3089 F-AS-3648 F-MP-2138 F-AS-2338 F-MP-2151 F-MP-1434 F-E-2288

b. Design Change Notices - Fourteen DCNs and 5 revisions to DCNs were reviewed. It appears as though 4 of those should have been upgraded to NCRs. Listed below are examples of these.

DCN-703 and Revision 1 DCN-IC-478 DCN-ME-30 DCN-E-790 It appears as though the problems identified in DCN-703 are related to FCR-MP-2138 and may have been reportable under 10 CFR Parts 21 or

• 50.55(e).

c. Engineering Discrepancy Notices (EDNs) - Seventy-six EDNs were reviewed for proper identification and control. Of those 76, it appears as though 51 of those should have been NCRs. Examples of these l_ are listed below.

EDN-EC-1476 EDN-EC-1548

[ EDN-EC-1502 l

EDN-EC-1479 ~

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i In additioa during .the review, another 35 were " voided" with no action taken. "The voiding action was performed by c clerk. Examples of voided EDNs are as follows: 1 EDN-EC-0630 EDN-EC-1175 EDN-EC-Il76 EDN-EC-1140

d. Tompkins-Beckwith - The staff reviewed a sample of the handling of information requests and Discrepancy Notices by Ebasco. As a result of that review it appeared that a number of these items should have been upgraded to NCRs. Examples of these are listed below.

W-6519 W-5755 W-6183 W-742 W-6322 W-5917 W-3656* W-381 W-1876 W-5824*

W-4112 W-5047 W-5692 W-5416 W-6243 W-5916 W-6349 W-2105 W-728* W-4968*

W-4648 W-4969*

The asterisked (*) items all related to incorrect heat numbers being entered incorrectly or clerical errors being made on rod slips.

In summary, the staff found that the QA program requirements for nonconformance identification, control and proper action do not appear to have been complied with.

LP&L shall review all FCRs, DCNs, EDNs, and T-B DNs to assure that proper corrective action was taken, including an adequate review by QA. This action shall include the steps required by 10 CFR 50, Appendix B, Criterion KVI, Corrective Action, and for Construction Deficiency Reporting, 50.55(e) . Also included in this review shall be the examination of improper voiding of all other design changes or discrepancies notices that affected safety-related systems or that were misclassified as non-safety related.

DISCUSSION:

To confirm that the requirements of 10CFR 50 Appendix B, Criteria III, XV and XVI and 10CFR50.55(e)/10CFR21, as applicable to FCRs, DCNs, EDNs and T-B DNs, were met, LP&L has taken the following actions:

A review of the FCR's/DCN's and lower tier documents identified by the NRC has been performed to determine if the conditions described should have been processed as an NCR. Any determined to have warranted such processing were then reviewed for safety significance under the reportability criteria of 10CFR50.55(e) and 10CFR21.

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A similar review was performed on a sample of approximately 900 lower tier documents and FCR's/DCN's.

The~ voided EDNs identified by the NRC were reviewed to ensure that proper actions had been taken or that voiding was proper. An additional sample of 49 voided EDNs was reviewed in the same manner.

A sample of over 160 EDNs were reviewed to determine if the proper safety classification had been assigned.

. All 145 Mechanical (M) and Welding (W) voided T-B DNs were reviewed to ensure that proper actions had been taken or that voiding was proper.

In the discussion that follows, the results of these actions as well as a description of the size and type of sample reviewed will be presented. An overview of the lower. tier reporting system as well as the processing of DCNs and:FCRs is provided as Appendix A. The discussion together with the appendix demonstrates that, although interpretive errors allowed a small percentage of conditions that should have been dispositioned on an NCR to be processed on another document, adequate procedural quality safeguards existed such that high confidence exists that conditions of safety significance received the proper evaluation and reportability review. Of the documents reviewed none met the criteria for reportability of 10CFR50.55(e) or 10CFR21. In addition, no plant hardware' changes were' required as a result of this review.

I. REVIEN OF LOWER TIER DOCUMENTS AND FCRs/DCNs IDENTIFIED BY THE NRC In addition to those items specifically cited in the NRC DESCRIPTION OF CONCERN, the NRC subsequently provided a list to LP&L of uncited lower tier

' documents and FCRs/DCNs which the NRC identified as potentially warranting processing as an NCR.

A review of these documents was performed by Ebasco to determine if any warranted processing as an NCR, and if so, whether the condition described

~ met the criteria for safety significance and reportability in accordance with 10CFR50.55(e)~and 10CFR21.

In addition, a joint committee, headed by LP&L (two LP&L and two Ebasco engineers) conducted an-indepth evaluation of the 121 documents identified by the NRC. This committee determined how many documents warranted processing as an NCR; reviewed all documents pursuant to 10CFR50.55(e) and 10CFR21; and ~ determined how many FCRs/DCNs had been appropriately preceeded by a-construction field document. These field documents were then reviewed to ensure that they were being used to identify in-process constructability -

problems and not "after the fact" deficiencies.

The committee identified the following two items which required retesting or reverification:

FCR-MP-2151 - This FCR was developed to add a one inch isolation valve upstream of a damaged regulator valve during RCS hydrostatic testing.

' These valves are located in a branch line (sample line) off of the pressurizer surge line. Our review indicated that the regulator valve was subsequently repaired. However no documentation was available to substantiate that six welds on line 2RC3/4-051A/B-2 had been hydrostatically tested.

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-s On October 2,1984 Ebasco initiated Condition Identification and Work

, Authorization (CIWA) - 19024 to test.the welds. On October 4, 1984,

'all welds were hydrostatically tested and confirmed to be acceptable.

EDN-EC-1595 - Satisfactory documentation could not be located to show proper closure of.this EDN. The EDN required specific QC signoffs for wiring' modifications performed within the Process Analog Control (PAC) system panels CP-42 and 49.

Since some of the individual signoffs were not done initially, the EDN required that LP&L perform a QC check on the terminations. On

-September 25, 1984 two CIWAs~were developed to perform the specific wiring verifications and to ovaluate any noted discrepancies. After verification of all terminations, and by utilizing referenced DCNs to determine subsequent changes, all wiring was confirmed to be correct.

The following are the overall results of the reviews for documents questioned by the NRC:

Of the 36 identified FCRs, six (6) were judged to have warranted

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processing via an NCR; none was judged to meet the criteria for reportability per 10CFR50 55(e) and 10CFR21.

Of the seven (7) identified DCNs, none were judged to have warranted processing via an NCR; none'was judged to meet the criteria for reportability per 10CFR50.55(e) and 10CFR21.

Of the 55 identified EDNs, two (2)'were judged to have warranted processing via an NCR; none was judged to meet the criteria for l reportability per 10CFR50.55(e) and 10CFR21.

Of the 23 identified T-B DNs, two (2) were judged to have warranted processing via an NCR; none was -judged to meet the criteria for reportability per 10CFR50.55(e) and 10CFR21.

Of the 43 design documents (36 FCRs and-7 DCNs) reviewed, 40 should have appropriately been preceeded by a. lead field document. Of these, seven (7) either did not have a lead field document or the field document identified a conconformance instead of a constructability  ;

problem.' Two of these 7 design documents were non-safety related.

Details of the evaluation of the cited examples are contained in Attachments 1 and 2.

.i II. RANDOM SAMPLE OF LOWER TIER DOCUMENTS AND FCRs/DCNs A' sample size of approximately 900 documents was initially reviewed by Ebasco from a-total population of approximately 32,000 documents. Except for the fact'that only documents pertaining to safety-related components,  !

structures or systems were chosen, the sample was random.

The objectives of the review were to:

Determine if the condition described on the document should have been processed as an NCR, and 4 __~_ _ . . - _ _ _ _ _ . , _ , . . _ .~ _ . _ .- _ ._.. ._. _ _ _ _ . _ _ . . . _ _ . _ . _

LIf s'o, did.the condition meet the criteria for safety significance and reportability.as defined in 10CFR50.55(e) and 10CFR21.

The review was conducted by experieuced engineers familiar with the

.Waterford-3 design. The initial evaluation was checked by another reviewer. If it was judged that the condition should have been upgraded to an NCR,LEbasco> Licensing and QA performed a review for safety significance

and reportability.- These results were further reviewed by two committee

. representatives (LP&L committee chairman and an Ebasco representative).

Of the total documents reviewed, it was' judged that 39 (4%) should have

,1been processed as an NCR. However, the disposition for these 39 documents was,'in all cases adequately evaluated and documented. Additionally, none of the document-described conditions were considered to meet the criteria for safety significance and reportability in accordance with 10CFR50.55(e) and 10CFR21.

III.' REVIEW OF VOIDED DOCUMENTS

.To' address the apparent NRC concern that improper voiding of documents may Lhave caused the identified conditions to go unresolved, LP&L and Ebasco conducted a sample review of EDNs and a total review of T-B "M" and "W" DNs. In addition, LP&L identified that' voiding of EDNs was never

~ procedurally ' allowed and voiding of T-B DN's was only allowed af ter August, 1981.

LP&L reviewed'53 of a total of 222 voided EDNs. These documents are '

identified in Attachment 3. The review indicated that the EDNs were voided because either they were not an actual deficiency or were subsequently resolved by_other means. Based on the review of the 53 voided documents, there is a confidence level of 95% that_95% of the unsampled voided EDNs contained no safety significant issues.

A total-of 145 "M" and "W" T-B DNs were voided. Of this total,-13 were voided because they were found to be non-safety relaced and required no

'further review. . Sixteen of the DNs had been voided because they were upgraded to NCRs. The balance of voided DNs (116) were voided for one of the following reasons:

1) The review concluded that no discrepancy existed.

2)- Misinterpretation of procedures by inspectors.

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3) Premature inspection of in process work. *

, '4) Duplication of lost DNs where original was later found.

5) Code Case acceptance.

! Voiding of design changes (DCNs, FCRs) does not represent a safety issue in a

that final: plant configuration must be in accordance with final design specifications and drawings. If a potential design change was voided, the change was not implemented and the design configuration must still be in accordance with the latest revision of the drawings.

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Based on the above reviews, LP&L believes that the voiding of these

~ documents does not represent a significant safety issue.

'IV. REVIEW FOR PROPER SAFETY CLASSIFICATION The NRC also regtested that LP&L evaluate the document types in the concern to assure that non-safety related discrepancies / changes were not misclassified. As.t.oted on Figure 1, correct DCN/FCR classification was reviewed and accepted by Construction Engineering and Design Engineering. ~

These reviews provided adequate assurances that design documents were classified properly.

The TB-DN procedure did not differentiate between safety and non-safety related. All DNs were procedurally required to be reviewed by QA for upgraling.

13Hi processing was slightly different. Non-safety discrepancies did not normally receive QA review. For this reason LP&L has sampled 163 out of the approximately 1200 non-safety related EDNs to determine if: 1) they were classified correctly and 2) if they were misclassified, was the discrepancy a significant safety problem. The results of the sample showed that none of EDNs were misclassified. On that basis, there is a confidence level of 95% that 98% of the total non-safety related EDN population was classified correctly. Based on this sample LP&L believes that no further

review is warranted.

CAUSE:

The causelof the concern was due to the utilization of seve'ral specialty contractors with individual QA programs. The corrective action sections of these programs did not standardize the definition and use of'NCR. This lack of standardization caused a minor number of interpretive errors to be made.

Interpretive errors led to processing a small percentage of conditions on a

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lower tier document or FCR/DCN that should have more appropriately been

.dispositioned on an NCR.

GENERIC IMPLICATIONS:

The potential generic implications of this concern were-that significant conditions adverse to quality and safety may not have been properly evaluated, corrected, and reported in accordance with Criteria XVI of Appe Ibc B to 10CFR50 and 10CFR50.55e/10CFR21.

'The review; conducted has provided LP&L with a high level of conf dance that such

• conditions have been processed properly.

CORRECTIVE ACTION PLAN / SCHEDULE:  !

LP&L feels that no further action is necessary for items that should have been

.. upgraded to NCRs. Our review has shown that the dispositions and corrective actions defined on lower tier acuments were adequately evaluated and properly documented.

With respect to procedural violations identified during the review, LP&L is ,

highly confident that present programs as implemented by Nuclear Operations l 4-6

t should preclude recurrence. ' Since the operation phase will not utilize the number of subcontractors required during the construction phase, the QA program

- will be inherently less complex. As. presently structured, the operations QA program is designed to implement.the requirements of 10CFR50, Appendix B, Criteria.III, XV, and XVI. The approved QA program is outlined in chapter 17.2 of.the FSAR and implemented by well defined procedures and management controls.

In addition. Nuclear Operations and Nuclear Services have implemented programs to meet the legal reporting requirements defined in 10CFR parts 20, 21, 50, 70 and

95. LP&L will provide a more in depth discussion of the overall QA program in the submittal that discusses the collective significance of the 23 NRC items of concern.-

SAFETY SIGNIFICANCE:

The reviews describ'ed above reached the following conclusions:

No conditions were found which required physical plant changes.

No lower tier or design documents (FCRs/DCNs) that were judged to warrant processing as an NCR described conditions which, if lef t uncorrected, would adversely affect plant safety.

The dispositions and corrective actions defined on the lower tier documents that should have been upgraded to NCRs were conservative and correct. Upgrading the documents would not have changed the dispositions or corrective actions.

The cample of lower tier documents discussed in Section II was random and consisted of.over 900 documents out of a total of approximately 32,000. The basic concern relates to the ability of the hardware to  !

perform its intended safety function. For statistical purposes, l therefore, a defect is defined as an instance in which, as a result of 1 the review, a hardware deficiency was identified which, if lef t )

uncorrected, would adversely affect safety. No such defects were found and on that basis there is a confidence level of 95% that 98% of the total population neither describe conditions that have safety significance nor meet the reportability criteria of 10CFR50.55(e) and 10CFR21.

LP&L therefore believes that this concern has been adequately addressed and should not be considered a constraint to fuel load or power operation.

ATTACHMENTS:

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1) DCNs/FCRs Cited by NRC

2) Evaluation of T-B DNs and EDNs

'3) Voided EDNs Appendix A: Overview of Lower Tier Documenting Reporting System and Processing of FCRs/DCNs.

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ATTACKHENT 1 DCNs/FCRs CITED BY NRC FCR/DCN NO. RESOLUTION / COMMENTS FCR-MP-1818 This FCR and NCR W3-3897 were written within one day of each other. TB-182 (NCR) initiated W3-3897. The FCR provided dimensional information for the NCR disposition of " replace". Drawings G-204-S7 provides evidence of FCR implementation.

This item is not considered reportable.

FCR-AS-3698 This field change was generated to revise plate and bolts to accomodate as-built condition.

DN-SQ-0924 was d veloped which subsequently caused CEIR-090 to be written. CEIR-090 we.s submitted and caused development of FCR-3698. The item is not considered reportable.

FCR-AS-3648 Several design and corrective action documents were associated with this support. Support deficiencies were initially identified by an NCR.

This NCR appears to have been closed prema'turely, however subsequent design documents corrected the conditions. FCR-AS-3648 was issued to accomodate the "as built" condition developed by the previously written NCR and design documents. The item is not considered reportable.

FCR-AS-2338 .No NCR was genernted. Based on definition, an NCR should have been generated since a prefabricated piece of structural steel was shop released and incorrect. This item is not considered reportable.

FCR'MP-1434 Two TB-irs (4559, 5356) properly identified and documented the incorrect installation of the Dravo spool piece. The installation error is significant due to the piping segments safety function and should have been written as an NCR prior to shipment of the piping assembly.

Additionally the spool, as initially installed, caused further fit up problems which had to be corrected to affect proper piping alignment. The disposition for the irs is conservative and properly documented on the FCR. The item is significant but not reportable since construction controls were in place to prevent the improperly installed spool from going uncorrected.

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ATTACHMENT 1

'DCNs/FCRs CITED BY NRC (Continued)

-FCR/DCN NO. RESOLUTION / COMMENTS FCR-AS-1631^ Original cracks were repaired via NCR W3-1548.

Continued attempts at the repairs required by W3-1548 still resulted in cracked weld. FCR AS-6131 was generated to allow alternate

, configuration to eliminate cracking at this joint.

This item-is not considered reportable.

-FCR-E-3089 An NCR was written on this matter. NCR-5371

. revealed that the enclosures for reactor coolant pump speed sensor amplifiers had been replaced.

Apparently heavy corrosion had been noted.

Stainless enclosures were substituted for carbon steel. Subsequently, Ebasco performed an unauthorized modification which negated the NEMA

. Type III requirements for a weather proof enclosure. The FCR was generated to document the enclosure change and gasket replacement.

The plant contains 24 sensor amplifiers. 16 are considered safety related since they feed safety channels for the Core Protection Calculator (CPC).

However, failure of the amplifiers signal due to environmental effects would-cause a reactor trip, but not . prevent a trip. Therefore the stated condition does not represent a significant

. deficiency that could adversely affect the safe operation of ' the plant.

FCR-MP-2138- This item was identified by NCR-W3-4739. In DCN-MP-703 addition several CIWAs were generated to implement corrective actions. The cause of the cracking was due to overtorquing of ~ the valves to limit RCS leakage prior-to hydrostatic testing.- The valves were replaced and tested satisfactorily. Although this deficiency is not considered reportable it '

was noted that the NCR was inadequately evaluated '1 during the time of occurrence. ,

1

-The condition was evaluated with only one failure noted. After the addition of 13 valves to the NCR the condition was not immediately re-evaluated by Ebasco. During our' review Ebasco Engineering and LP&L Engineering concluded that the condition was not reportable pursuant to 10CFR50.55(e) and 10CFR21.

4-9

ATTACHMENT 1 DCNs/FCRs CITED BY NRC (Continued)

FCR/DCN NO. RESOLUTION / COMMENTS FCR-MP-2151 The FCR added a manual valve upstream of a damaged regulating valve to facilitate cold hydro testing.

Documentation was available to document repair of the regulating valve; however no documentation was available to substantiate the hydrotesting of six welds in line 2RC3/4-051A/B-2. Subsequently, the line was hydrotested successfully. A more detailed explanation of this FCR is contained in the body of the response. This item is not considered reportable.

FCR-2288 This FCR was written in response to RFI-4143 which requested additional cable pull clarification.

These cables are non-safety. This item is not

, considered reportable.

DCN-IC-478 This DCN involved retagging of instruments in the warehouse based on an inventory survey. Subsequent to the inventory survey, a DN was generated to document discrepant tag numbers based on a revised EMDRAC drawing. The DN (MC-3188) was dispositioned to change the tag numbers based on procedure ASP-IV-54, a DCN was not necessary. The tags have been changed and the DN is closed. QA documentation reflects revised tag numbers. This item is not considered reportable.

DCN-E-790 This DCN was written as a result of CIWA 820056 which revealed a disparity between design documents. This circuitry is not safety-related.

This item is not considered reportable.

DCN-ME-30 R1 This DCN was generated to document the as-built condition reflected in DCN-IC-1415 RI.

DCN-IC-1415 R1 revised the model number for the ASCO solenoid from NP 831664E to NP 831665E. The difference between these two types of solenoids is that the 665E model has an explosion proof and watertight enclosure while the 664E model only has a watertight enclosure. Both models are environmentally and seismically qualified. The change represents an upgrade based on ME-30 requirements. This item is not considered reportable.

4-10

9

a j

• r ATTACHMENT'1 DCNs/FCRs CITED BY,NRC

(Continue'd)

The'DCNs/FCRs cited by the NRC were evaluated individually in this attachment.

In'2 cases an NCR should have been written to document the discrepancy based on definition. However, there is no safety, significance with respect to.10CFR50.55 1(e)/21. In other cases, a corrective action:. document had been previously

written, the item was nonsafety-related or"the condition was identified on a pre. approved design documenc.

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i' ATTACHMENT 2 )

EVALUATION OF T-B DNs AND EDNs i W-381' -

' Welds painted prior to visual examination and dispositioned by I

Ebasco letter. The welds are not safety-related.

i

- W-728 -

Hold Point for ANI bypassed. Jut additional LP examination was

. ,. subsequently performed with ANI present. Discrepant condition brought back to requirements by additional testing.

W-742 -

. Electric power off for an unknown time (weld rod ovens).

Disposition by T-B welding engineer assured that rod would be held at correct temperature for required time prior to issuance.

Discrepant condition brought back to requirements. (Response to Concern 22 addressed this issue).  !

- W-1876 -. Post Weld Heat Treatment not verified for FW5R1 by QC. Records c were subsequently generated by involved craft per disposition, s.

' W-2105 -

Bypassed ANI hold for fit-up inspection. Four additional reviews i..- -

were procedurally required including the ANI review of completed

' /. ;*Y( 11008 & 11009 forms for acceptability. l 1

W-4112 -

Coupling installed not in conformance with MP-488RI. DCN MP-488 required'the addition of 6000f couplings to an MSIV Bypass line.- Apparently 3000f couplings were~ incorrectly installed.

.U This DN documented and identified the problem and requested design information. 3000f couplings were subsequently documented via redline procedures and was approved and the DCN and DN closed.

Incorrect weld procedure used. Weld procedure which was used was W-5047'- -

metallurgically compatible. The disposition was conservative and correct.

7 W-5416 -

Two DNs and NCR 4010 were affiliated with this deficiency. The DN listed several welds that were deficient due to documentation  ;

problems. The problems were identified as part of the DN-T-2474, NCR-4010 support walkdown program. (NCR-4010 was upgraded and  ;

reported as SCD-60 which is still open).

. W-5692- -

No RT performed on base metal repair area. The DN was initiated  !

-to identify the t.ed for RT instead of visual and PT examination

• specified on 2 previous DNs. This condition should have been 1 written as an NCR. However, the DN disposition was conservative and not considered reportable.

W-6183 -

These DNs identified that flanges were torqued at values outside

-W-6322 'of the. calibrated torque wrench range. However, specific torque W-6519 values are not' required by Code. These flanges were checked for

+

leakage as part of system hydrostatic testing and were

, acceptable.

I 4-12

m

~

ATTACHMENT 2-EVALUATION OF T-B DNs AND EDNs (Continued)

W-6243 -

A non-conservative interpass temperature of 600*F versus 350*F was specified on a weld rec'ord. Due to the type of weld involved (Bimetallic), the process involved and the documented welder training, neither interpass temperature would have been expected to be exceeded.

W-6349 -

Gap between lug and pipe clamp unacceptable per FCR 1553.

Cap was evaluated by_Ebasco per NCR 4010-program and accepted.

W-3656,4648 - These DNs indicated clerical errors in transcribing heat numbers 4968,4869 or filler material on to QA documentation. Based on evaluation 5755,5824 of material dispursed by rod room, the justification for 5916,5917 maintaining the position that a clerical error existed appears well documented and logical. The error both individually and collectively, is not considered safety significant.

EDN-EC-1479 -. Material' documentation on a hanger was unavailable on the four snubbers. A supplement to the purchase order was developed to require QC review of the documentation. The snubbers were released after documentation requirements were resolved.

EDN-EC-1476 -- Root pass LP was not performed. Final UT inspection was performed which volumetrically accepted the weld. This item did '

not represent an AWS code violation.

EDN-EC-1548 - Small nicks on cable jacket. The condition was corrected by repairing the cable to design / installation criteria.

,EDN-EC-1502 - An EDN should nce have been issued. Conduit installed through other penetrations was allowed per design drawings (B-288) as long as cable identification was maintained.

Conclusions:

LP&L's evaluation of the cited EDNs/DNs indicates that one case, by definition, should have been upgraded to an NCR. In this case, evaluation was performed by the appropriate groups including the quality assurance organization. The DN that should have been upgraded is not considered safety significant.

1 l

4-13 1

w ___ _ _ _ . . _ _ . _ . _ _ - . _ . - ~ ~ - - - - - ~ - - . - - . - - - - - - - - - . - - - - - - - - - - -

1 ATTACHMENT 3

, VOIDED EDNs

-53 voided EDNs were reviewed

-. of the 53,.17 were written against safety equipment EDN NO. ' DESCRIPTION RESOLUTION

• l

' EC-0630 -Inadequate-drainage at The EDN identified a non-safety /

-35 (RAB).- non-seismic plumbing problem.

Further action was required to correct drainage problems '

throughout the plant. This action was accomplished by a contractor in late 1983 and early 1984 under the CIWA program.

EC-1149. Potential Damaged Tubing. The EDN was voided because the tubing damage was previously i

addressed and closed out on EC-1136.

EC-1431 Unable to. Locate SF-83-4-5. The Service Fot.x was subsequently located.

EC-1104 Scale Change on Recorder A scale change was identified by JR-RC-005/006. .CIWA 832097 and corrected by DCN-ICP-540.

EC11392 HPSI-Pump on Lower Guard. The coupling guard bolts (non-safety) on HPSI pumps were not completely snugged down. Potential

, Problem Report #244 was transmitted to LP&L. The PPR was closed by LP&L via CIWA 18006.

EC-1393 Valve Stem Protector Valve stem protector lengthened.

- 2SI-V1544B4. No discrepancy exists.

EC-1175- Maierial On Hold. Problem addressed in EDN-1175 as it

, pertains to proper control, storage and segregation of permanent plant

material was resolved on

, DN-MC-5223.

EC-1176 _ QC Vol.-AG WQC.1. DN-1176 identified a potential l warehouse inspection problem.

Warehouse inspection forms were y retrieved which indicated inspection.

EC-1347 - Conduit. Installation CP-6. DCN-E-1024 was developed to implement the installation change.

t 4

4-14

ATTACHMENT 3

-(Continued) ,

.EDN-NO. DESCRIPTION RESOLUTION

• EC-1350 Box 31008-SB & 31009-NAB FCR-E-3253 was issued.to correct

-are not installed per the installation.

DCN-E-1100. '

EC-917 - Hilti Belt for valve 2SI- Based on field inspection, no V804A/B pulling out of discrepancy exists.

concrete.

-EC-1140 ! Operators interchanged for Potential Problem Report 0245 was 3FW-V6074 & 6CD-V343. submitted to LP&L. Operators were not interchanged, tag _on operator must be changed based on Pacific Valve Inc. Electric Motor Operating Testing Report dated 12/20/79.

This report identified operator S/R 240727 as belonging to tag 3FW-V607A. Valve 3FW-B605B does not have operator. Limitorque motor operator for 6CD-V343 must also be corrected. The PPR was closed by LP&L via CIWA 10055.

I EC-1205~ Exposed Hilti and Core Based on field inspection, no Hole 762. anchor plates existed in the described area. Discrepancy invalid.

EC-1110 Foundations for Fans E-22 Based on. field inspection, no A&B. discrepancy exists.

EC-0584 Cable' Reel number change. NCR-2833 was generated. The DN should have been closed.

EC-1502 Conduit Installations As noted on Attachment 2, the conduit installation was allowed per B-288 drawings.

EC-1802 Tubetrack Identified that several short Ell '

shaped cantilevers existed on tubetrack. FCR-ICP-654 was subsequently issued to define the engineering disposition.

All voided EDNs (cited).were evaluated in this attachment. In no case was an NCR required that was not generated. None of the problems identified in the EDNs have any safety significance as defined in 10CFR50.55(e) or 10CFR21.

4-15 j

A

L 4 .-

APPENDIX A TO CONCERN NO. 4 OVERVIEW OF LOWER TIER DOCUMENT REPORTING SYSTEM AND PROCESSING OF FCRs/DCNs During the initial designLand construction phase LP&L established and implemented'an approved QA program to evaluate discrepant and nonconforming conditions.- This program was implemented throughout the construction phase of the project. ~In addition, Corporate procedures required that-

- individuals within the various_ organizations report all discrepant conditions for proper evaluation, including 10CFR50.55e and 10CFR21 (Ebasco Procedure N-23) consideration.

lThe lower tier reporting system contributed to plant safety in that it allowed engineering, QA personnel and management to properly focus on issues of,safetyfsignificance, evaluate'their generic implications and trend performance. In the final analysis, however, judgement and

' interpretation was made on many conditions that came close to meeting the criteria-for processing as an NCR.

Our review has demonstrated that based on a strict interpretatior. of the definition of nonconformance, such judgements were not always appropriate.

lit has also shown, however, that the program requirements which delineate the identification, processing and review guidelines for these lower tier documents as well as for DCNs and FCRs provided adequate safeguards such that significant ' safety problems received the review, evaluation and management visibility required by. Criteria- XVI of Appendix B to 10CFR50.

DN, EDN Processing and' Review Deviations from design criteria and specifications were generated from

_ Engineering /QC inspections, whether by Ebasco or other contractor personnel. Ebasco/ Contractor procedures require that these conditions be identified-by discrepancy notices (e.'g. EDNs and T-B DNs). Discrepancy notices, by procedures, were evaluated and dispositioned within the contractor's organization by Construction or QC.

In-ecch case (D'N, EDN), the responsible QA organization was required by

- procedure to review the recommended disposition to ascertain if the DN, EDN should have been upgraded to an NCR. If an NCR was written, the DN/EDN was closed. .If QA agreed that.the concern could be addressed properly on a DN, it was processed for corrective action and verification.

The' processing and review of contractor DNs and Ebasco EDNs was very similar to-the processing of NCRs with respect to evaluating organizations and review.. Procedures clearly identif,ied the appropriate evaluating

. organizations and formed an integral part of LP&L's Quality Program.

Identification, control, and proper action, with respect to deviations

, design and installation requirements, were controlled by these procedures.

(Attachment A-1) summarizes this processing and review cycle. Attachment A-2 summarizes these procedures with the responsible organizations for the

-processing and review-of these documents.

4-16

' The attachments demonstrate that whether a condition was originally-documentedias a DN or EDN, as opposed to an NCR, it received a quality review. Such a review effectively acted as a " safety net" for conditions with safety significance. Although occasional interpretive errors were made, the probability of conditions with safety significance not being processed on the appropriate level document was very low. Similarities in the review cycle are as follows:

Condition identified by QC or inspection group Dispositioned by Construction, ESSE or QC QA supervisor or designee determined, by an interpretation of definition, if upgrading was required.

.QA/QC signature required / Engineering Inspector Signature Verification of disposition by. inspection (EDN - Engineering Inspector /QC, DN-QC) .

FCR/DCN PROCESSING AND REVIEW

- Changes to design were generally initiated from three areas; information and new regulations received from regulatory agencies, field requests, and

. in-house design reviews which included vendor information received which was incorporated into design drawings and specifications. In house reviews and regulatory information were evaluated and directly transcribed onto a DCN or YCR. Field information was typically received via contractor documents such as an Information Request (IR) or a Request For Information (RFI). These requests were "in process" construction documents which provided the contractor with a documented system to request clarification, '

detailed information, or to advise the engineer of constructability problems.

' DCNs and FCRs were used to advise the field of engineering approved changes

. to Ebasco design. These documents, when issued, carried the same impact and importance as design specifications and drawings. They were not considered " lower tier" documents. As discussed below, they received a level of review commensurate with the design change. They were not used in lieu of DNs, EDNs or NCRs for documenting and dispositioning design discrepancies. Utilization of DCNs/FCRs minimized original drawing revisions and were used as an interim modification until design drawings  :

are "as-built".

It was the responsibility of the Lead Discipline Engineer to determine if the' changes had a safety impact as defined in Ebasco Engineering Procedure E-69 entitled " Design Change Notice - Field Change Request". As defined in E 69, major and minor changes which affect safety-related aspects of the plant were processed, reviewed and documented in accordance with Topical Report ETR-1001, Section QA-I-4, Dasign Control (see Figure A-1).

Processing of FCRs initiated by Construction included review and

. acceptance by Engineering. As in the case of DCNs, Engineering was

-responsible to verify that the change did not affect safety related aspects of the equipment / system. If the change affected safety, it was processed as defined in QA-I-4.

L 4-17

.- - . . ~ . - _ _ - . ._. , _ _ . _ _ _ . - _ _ _ _ _ ._..___,_,_._ _ _ .__ _ _ ._

m No documented review of DCNs/FCRs was requireI for 10CFR50.55e or 10CFR21 applicability. However, Engineering was responsible to meet the requirements of Ebasco Procedure N-23 " Reporting a Defect /Noncompliancy to the NRC". This procedure required each employee to consider the effect of deviations to design and procedures-and to report these types of deficiencies for evaluation as potentially significant deficiencies. The supervisor responsibilities required contact with QA for this preliminary evaluation. This procedure, by requiring QA input, made it similar to processing DNs/EDNs. Attachments A-1 and A-2 detail the processing and review cycle for DCNs and FCRs. Based on our review, there were cases where a DCN/FCR described a condition that warranted processing an NCR.

However, none of these cases were considered safety significant with respect to 10CFR50.55e/21.

4-18

ATTACHMENT A-1 MATRIX FOR PROCES3ING AND REVIEW OF NONCONFORMANCES (NCRs)

DISCREPANCIES (DNs)

ENGINEERING DISCREPANCIES (EDNs)

DESIGN CHANGE NOTICES (DCNs)

AND FIELD CHANGE REQUESTS (FCRs)

GENERATED BY DISPOSITIONED REVIEWED BY QA VERIFICATION OF INSPECTION PERSONNEL BY CONSTRUCTION (EBASCO OR CORRECTIVE ACTION DOCUMENT (QC OR ENGR) OR QC CONTRACTOR) BY QA/QC PROCEDURE REFERENCE DN (Eb rco) Yes Yes Yes (Note 1) Yes WQC-150 DN (Contractor- Yes Yes Yes (Note 1) Yes TB Procedure TBP-12 Typical)

DN (Contractor- Yes '

+ Yes Yes (Note 1) Yes Gulf Procedure PR 15.0 Typical)

EDN Yes Yes Yes (Note 1) Yes or Engineering ASP-IV-70 Inspector NCR Yes Yes (or ESSE) Yes Yes ASP-III-7 DCN No Yes As Req'd. by N/A Engineering Procedure E-69 Procedure FCR No Yes As Req'd. by N/A Engineering Procedure E-69 Procedure IOTE 1: Review by QA for Upgrading to NCR 4-19 -

FIG URE 1 DCN/FCE PROCESSING PER ENGINEERING PROCEDURE E-69 .

.FCE PEOCESSING DCN PROCESSING CHANGE REQUEST CHANGE REQUEST GENERATED . = GENERATED BY BY CONSTRUCTRW = ENGINEERING (LDE)

' h '

CCN GENERATED ASAEESULTOF DECISION ON M40g02 MINOR DECIS/CN ON MA<JOR/ MINOR FCRAFFECTING MA</0R / MINOR BYCONSTRUCTION SAFETY SYENGINEERING BASED ON E-69 BASED ON E-69

. DEF/NITION DEFINIT /0//

MAJORGR MMR MAJOR ~ U U 'CHAMGE AFFECTNG- _

U MINOR y SAFETY y p,gy CHANGE CHANGE RECOMMENDED a PROCESSED IN AfflTjNG l DISPOSITION ACCORDANCE BYCONSTRUCTION WITH ETR-/00I y,pog l CHANGE  :

U U yMTAFFECTING

' SAFETY REVIEWED BY APPROPRIATE '

SRE / PROJ ENGINEERING SUPER. g REVIEWS U -

REVIEWED jp iog og pg S/GNED OFF BY DEC/ DES THAT BYLDE, PE $

l.DE4 PE cy)Nagspogia SUPERV/S/NG \

BE MAJOROf ENGINEER MINOR CHANGE

• y AFFECTING SAFETY y CHANGE IS

. EXECUTED TRANSMITTED TO CONSTRUCTIONFOR IMPLEMENTATION U

CHANGE IS EXECUTED 4

l l

l l

RESPONSE l ITEK NO. : 9

. ' TITLE:  ; Welder Certification NRC DESCRIPTION OF CONCERNi The. staff reviewed the records for the installation of the supports for certain of!the instrumentation cabinets in the Reactor Containment Building (RCB). The i-review included an examination of procurement records for the support material, l weld rod control documents, welder certification records and QC inspection records.

. Based on th e staff review, it appears that documentation is missing on a number of support welds and it is not clear that the welders were certified for all of the weld positions used. Thus, the quality of the supports for the instrument

,- Lcabinets are'indeterminant.

LP&L shall attempt to locate the missing documents and determine-if the welders were appropriately certified. If the documentation cannot be located, appropriate action must be taken to assure the quality of the cabinet supports. i

' DISCUSSION: .-

The instrument cabinet support steel of concern to the NRC was installed by the J. A.iJones: Construction Company. J. A. Jones' primary construction responsibility was to install reinforcing steel and place concrete. Welding by J. A.' Jones was limited in scope and incidental to their primary responsibility. '

As a result of the specific NRC concern, a thorough review was conducted of the

. documentation ~ associated with welding of the instrument cabinets. Reviews were also conducted to identify the remaining scope of Jones welding and the extent

' of.available documentation. As discussed below, no cases of welding out of position were identified, and the adequacy of Jones welding was confirmed.

A) Reactor Containment Building (RCB) Instrument Cabinets

'In order to determine that no welders welded out of a qualified position, a thorough review was' conducted of Weld Inspection Reports (WIRs) associated with the support steel for the RCB instrument cabinets. This review determined that for'11 of the 18 instrument cabinets, the WIRs indicated the welders were all qualified.

r .

.For the remaining seven cabinets documentation was not complete.

Accordingly, it could not be conclusively established that no welders welded out of a qualified position. To confirm the integrity of the

, welding associated with these seven cabinet supports, a complete reinspection'of'six' cabinet supports (welds on cabinet C-2B were inaccessible) was performed. The results of this inspection are documented in Attachment 9 to NCR 7549. The inspection did document conditions requiring an engineering evaluation. However, the evaluation confirmed the capability of the support steel to perform its safety functions under design conditions including seismic loads required by the FSAR. No rework was required.

9-1

2. . . ,, - , , . - , . . . - _ - - . - - - . - . . . - _ - . . - - . , . - - - . - . _ . . -

Based on the inspection results of the dix cabinets, LP&L elected to reinspect the other 11 cabinets. Conditions requiring engineering evaluation were documented. The evaluations confirmed the as-built condition to be acceptable with no-rework required. Based on partial documentation of welding on cabinet C-2B and the acceptable evaluation of the other 17 cabinets, no further evaluation of C-2B is necessary.

The following summarizes ~the conclusions r'eached from reinspection and '

evaluation of the instrument cabinets.

1 (1) Documentation for inspection of welding on the RCB instrument cabinet supports was not complete.

(2) A review of the available documentation revealed no cases where out-of-position welding occurred. The J. A. Jones weld inspection procedure included instructions for completing WIRs that required a check of the welders certifications, and very few Jones welders were not qualified to all positions. This review has provided reasonable assurance that no J. A. Jones welders performed welding in positions for which they were not qualified.

(3) In any instances where out-of-position welding may have occurred, the complete reinspection and subsequent evaluation of the as-built condition has confirmed its adequacy.

.B)- Other Welding Performed by J. A. Jones To ensure that conclusions reached relative-to the safety of the instrument cabinet supports could be extended to the rest of J. A. Jones welding, a thorough review was conducted to establish the scope of welding and adequacy of documentation. The additional J. A. Jones welding identified by this review consisted of 22 work packages. They were categorized as 1) temporary work or work done for construction convenience, 2) nonsafety-related welding, 3) safety-related or seismic welding. Work performed under categories 1 and 2 were not considered further due to their non-safety applications. For welding identified as safety-related or

' seismic, a documentation review was conducted. This review indicated that L

the available documentation associated with J. A. Jones other welding was as good, and in most cases, better than the' documentation associated with the RCB instrument cabinet supports welding. Documentation for three Field Change Requests (FCRs) (1898,1916 and 1965) has not been located, however, i Work Verification sheets indicating completion of this work provides a high .

level of confidence that the work was adequately performed.

Welding identified as safety related or seismic was also determined to be of a low stress. No applications involving high stress were identified.

The welding performed on the RCB instrument cabinet supports represented l a largo percentage of the J. A. Jones welding. This welding was completely reinspected and analyzed without identification of any required rework.

The acceptable condition of this work, combined with the favorable documentation on additional J. A. Jones welding, substantiates the conclusion that the additional J. A. Jones welding is adequate.

i 9-2

To provide additional confirmation of this conclusion, six of the twenty-two packages determined to be the most important of J. A. Jones additional welding, were selected for inspection. Included in one of chose work packages are the three FCRs for which full documentation has yet to be located. This inspection is documented by L-CIWA-18908, and identified no condition-requiring corrective action.

I CAUSE:

The causefof this situation concerning documentation and quality of work on the RCB instrument cabinet supports is believed to have been a combination of several factors that by themselves had no adverse effects, but as uniquely combined in the instrument cabinet work, resulted in the deficiencies noted by the NRC.- These factors were:

(1) -Limited welding performed by J. A. Jones provided limited opportunity for detecting any adverse condition in the welding program.

-(2) A " Welding Inspection Report" format that did not ensure documentation of inspection on an individual weld basis.

(3) Numerous revisions to the FCRs installing the instrument cabinet support steel. In some cases as many as three separate FCRs were required to complete the installation of steel for a single cabinet.

(4) Frequent modification / removal / reinstallation of support steel as a result of'(3) above.

.(5) Due'to (3) and (4) above, the installation required an inordinate length of time, with different welders involved in small portions of the overall job for each cabinet support.

The WIR used by Jones was, in retrospect, inadequate to deal with this combination of problems confined to these supports. As a result, it has g been concluded that a portion of the welding associated with the instrument

cabinets may not have been inspected, and deficiencies were not documented and corrected.

GENERIC IMPLICATIONS:

Th1s concern has been addressed generically. A review of all welding performed by J.A. Jones was completed. Elements of the Jones program that resulted in problems on the cabinet supports were common to all welding performed by Jones.

However, the unique combination of problems observed on the cabinets was not *

, observed elsewhere.

SAFETY SIGNIFICANCE:

Complete reinspection and engineering evaluation of the welding associated with i

17f of .the 18 RCB cabinets confirmed its capability to adequately perform its

. safety function under design conditions. Review of documentation, determination of the low stresses involved and the selected inspection confirmed the adequacy of the remaining J. A. Jones welding. On this basis, there is no recognized

[ reason that this issue should constrain fuel load or power operation.

9-3

e . -

-CORRECTIVE ACTION PLAN / SCHEDULE:

_ Review and evaluation of the RCB instrument cabinet supports is complete. No

' further corrective action is required.

Identification and documentation review of J. A. Jones additional welding is complete. Six work packages were selected for inspection. No further corrective action.resulted from this inspection.

LP&L considers all corrective action associated with this concern to be completed.

ATTACHMENTS:

None

REFERENCES:

(1) J. A. Jones QA Manual (2) NCR-W3-7549 (3) J.A. Jones Welding Inspection Procedure, W-SITP-14 (4) E. Stanley memo to file dated Au' gust 23, 1984, No. ES-84-08-7 (5) B. Grant /I. Bari memo to J. Houghtaling dated 10/10/84, No.ES-10145-84 9-4