ML20095A209

NUS Project Plan for Prelicensing Issues Task Force Support Group

ML20095A209
Person / Time
Site:	Waterford
Issue date:	08/14/1984
From:	NUS CORP.
To:
Shared Package
ML20095A195	List: ML20095A192 ML20095A209
References
PROC-840814, NUDOCS 8408210409
Download: ML20095A209 (7)

Text

August 14, 1984

, , Paga 1 of 5' NUS PROJECT PLAN FOR THE PRELICENSING ISSUES TASK FORCE SUPPORT GROUP 1.0 Project Objectives The principal objective of this project is to provide independent technical support to the Prelicensing Issues Task Force in the conduct of their support for the Louisiana Power & Light Waterford 3 Steam Electric Station proj ect. The purpose of the Task Force is described in the Task -

Force charter (Attachment A). The support provided may be in several "

areas, including performing independent assessments of issues raised in the NRC letter dated June 13, 1984, from Darrell G. Eisenhut to Mr. J. M.

Cain (Attachment B).

2.0 Work Scope 2.1 General The work scope of this project involves two principal aspects as covered in Items 2.2 and 2.3 below. Item 2.2 covers the NUS Support Group's, efforts to assist the Task' Force in carrying out its charter to perform an independent assessment for the LP&L CEO of the LP&L responses to the issues raised in Attachment B. Item 2.3 covers separate efforts by the NUS Support Group to provide inspections, validations, and other types of assistance as requested by LP&L on items not covered in the Task Force charter.

See Section 2.3 below for further definition of this area.

The NUS Support Group's paramount objective is to ensure the independence of the Task Force's overall effort. Open and full discussions with LP&L and its contractors for purposes of obtaining a full understanding of the issues, proposed LP&L responses, and other information are encouraged. However, the validation efforts and recommendations to the Task Force are to be performed and '

developed independently of LP&L and its contractors. The major

• effort should be directed to enabling the Task Force to respond effectively to the concerns and directions in Attachment B. The effort should be expanded beyond the scope of that expressed in Attachment B where it may be necessary to do so to address the safety significance, generic implications or other broader implications of an issue. All such expansions should be discussed with and approved by the NUS Project Manager. The collective significance of all the issues must also be addressed.

The detailed nature of the work performed may vary as the project work progresses and as more facts become available. This proj ect plan provides general guidance for the conduct of project activities. Based on the scope of a specific task within the project, additional procedures will be prepared as required to adequately control project activities. The activities related to the project can be grouped into seven broad categories as discussed below.

2.2 Initial Review of Issues 2.2.1 The initial activities conducted by NUS personnel will be to review the background on each of the 23 issues to 8408210409 840815 PDR ADOCK 05000302 A PDR

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develop a complete understanding of the situations presented. NUS personnel with the appropriate backgrounds and experience will.be assigned to this task. Activities will be coordinated closely with the Task Force members to assure that the project is proceeding properly. During the activities related to review of the background, close coordination will be maintained with LP&L and other ..

personnel to assure that correct information is used by the .

NUS Support Group in conducting its activities.

2.2.2 Review Specific Issues The reviewers of each of the issues should ensure that the LP&L responses present sufficient logic to enable the Task Force to specifically address the NRC concerns and ,

directions in Attachment B, including their safety

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significance and generic implications of the specific issues. Each one of the issues outlined by the NRC in Attachment B will be assigned to a member of the NUS Support Group to evaluate and determine what courses of

. action should be carried out to validate the logic of the LP&L responses ar.d ensure that all pertinent information related to that issue is brought before the Task Force.

2.2.3 Validation of Specific Issues To develop validation procedures as the work related to reviewing specific issues and the background information related to them progresses, NUS personnel will develop lists of information to be validated independently by the Task Force and the NUS Support Group and the procedures to be used in validating the information. The purpose of this activity is to ensure the Task Force that the information contained in the response to the NRC is correct to the best of NUS knowledge. In addition, the validation procedures will contain elements intended to verify that corrective actions defined by LP&L in the response are properly carried out.

The procedures will be prepared by the NUS personnel familiar with the issue under consideration. All procedures developed that require field inspections will be approved by a qualified and certified NUS Level III inspector. Procedures related to documentation review, validation of responses by EBASCO and LP&L, and other activities will be approved by either NUS Level III inspection personnel, certified lead auditors, or ,

appropriate engineering personnel. All procedures will be approved by the NUS Project Manager or designee. The logic employed in the procedures and the specific items to be validated or evaluated will be coordinated with the Task Force to the degree necessary.

The procedures prepared will be in the format most appropriate to the specific issues, but must contain at least the following information:

Paga 3 of 5

1. Actions to be taken by NUS

2. Details of carrying out these actions

3. Acceptance criteria

4. Reference documents

5. How the results of the validation process will be .'

documented

6. The types of personnel required for conducting the validation activities, including their experience and qualifications 2.2.4 Validate LP&L Responses .

. The procedures developed for validation of the specific issues will be executed by the NUS Task Force Support Group personnel. The Project Manager is responsible for aasuring that the procedures are carried out correctly and as outlined in the approved document. Statistical sampling techniques may be used where appropriate to assist in the validation effort.

2.2.5 Report Results of Evaluation and Validation Effort Upon completion of the evaluation and validation efforts, the results oill be documented for transmittal to the Task Force. During the course of the evaluation and validation efforts, any unusual findings or concerns that arise will be brought to the attention of the Project Manager and, if appropriate, the Task Force. In addition, any concerns raised will be discussed with LP&L personnel to help ensure ,

that the correct documents are available for the work effort and to obtain any additional documented information j required as the work proceeds.

2.2.6 Inspection Support During the course of the evaluation and validation activities carried out by the NUS Support Group, it will be necessary to perform some inspections of field installations. These inspections will be carried out by personnel certified as quality assurance inspectors in accordance with ANSI N45.2.6-1973. The ins'pecting personnel will be certified as Level I, II, or III as appropriate under the requirements of ANSI N45.2.6-1973.

The data gathered by the inspectors will be interpreted by NUS personnel certified as Level III inspectors or by appropriate engineering personnel. All inspections will be carried out in accordance with procedures reviewed and approved by the NUS Project Manager or his designee.

2.3 NUS Support to LF&L for Activities Not Related to Prelicensing Issues

. Pegs 4'of 5 During the course of the activities in support of Waterford 3, LP&L may request that NUS provide inspection or other support to assist in the LP&L efforts related to resolving NRC concerns other than those addressed in Attachment B, such as inspections related to NRC construction appraisal team (CAT) activities. NUS personnel may be used in this capacity if approved by the Task Force and the NUS Project Manager. During these l j  ;

situations, NUS inspection personnel will perform .!

inspections in accordance with LP&L-prepared procedures #

which have been reviewed by Support Group personnel and which have been remodified as necessary to ensure that they are suitable for use in fulfilling the requested function ,

and which have been approved by the NUS Project Manager. i I

Personnel assigned to such work shall be under the direction of the NUS Project Manager. In no case shall the ,

HTS Project Manager assign NUS inspection personnel to

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assist LP&L in any situation that could cause a conflict of interest and jeopardize the independence of the NUS Support Group.

3.0 Project Organization 3.1 Prelicensing Issues Task Force

-. Attachment A to this project plan depicts the relationship of the Prelicensing Issues Task Force and LP&L management. Attachment C hereto shows the relationship between the Task Force and the Task Force Support Group. The Task Force has final responsibility and authority for directing the actions of the Prelicensing Issues Task Force Support Group and will remain cognizant of the activities

. carried out by the Support Group to ensure that they are in accor-dance with the requirements of the Task Force. -

3.2 Project Manager The Project Manager for the Prelicensing Issues Task Force Support Group is Mr. Peter V. Judd. Mr. Judd , as Proj ect Manager, l's responsible for being the primary interface with the Task Force and with NUS personnel assigned to the project at the site and at other

, locations. Mr. Judd will call upon the personnel resources l of NUS Corporation as required to obtain personnel for assignment to the project. -

3.3 NUS Staff NUS personnel vill be assigned to specific tasks related to the functions the Task Force charter based on their experience and qualifications , as previously discussed. The personnel assigned to review issues and develop validation procedures will have back-grounds and experience commensurate with the assignment that they are given. Similarly, personnel assigned to documentation reviews will have appropriate backgrounds for performing these activities.

Attachment D shows the relationship between the Project Manager and

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Support Group personnel. The NUS Personnel Department routinely conducts verification of the credentials for NUS employees. They have reviewed their files to provide assurance that personnel assigned to the project do in f act have the background, creden-tials, and experience outlined in their resumes; this information will be updated appropriately as new people are added to the proj ect . Personnel assigned to inspection activities will be certified as Level I, II, or III inspectors in accordance with ANSI N45.2.6-1973. .

4.0 Project Procedures 4.1 Activities performed by NUS personnel in addressing the 23 issues shall be prescribed in procedures as defined herein.

4.1.1 The initial review of LP&L's 23 responses is performed by NUS personnel, with appropriate backgrounds and experience, to develop an understanding of each of the issues and to determine LP&L's logic approach in response to the NRC directions. This review, consisting of preliminary evaluations into such areas as site control of records, personnel interviews, and utility / contractors implementing procedures is conducted to provide the necessary background information required to form the basis for validation and inspection ef. forts.

The results of this review will be documented in a summary, which delineates LP&L's logic approach, describes additional logic steps identified by NUS, and presents recommended actions (LP&L and NUS) needed to resolve the individual issue. This summary wall be submitted to the

. Task Fcree. Formalized procedures are not required and are not considered necessary to control the aforementioned

. activities. .

4.1.2 Detailed validation procedures shal.'. be prepared, approved, and issued to NUS staff personnel performing independent validation activities. These procedures shall consist of documentation review procedures and inspection procedures.

, Documentation review procedures shall be written to ensure l the independence of the effort, shall prescribe the attributes requiring validation, and shall include checklists / tables, as required, to document and/or acquire objective evideuce.

I Inspection p:ocedures shall be generated to provide (1) the quantitative and qualitative criteria necessary to perform j the inspection and (2) checklists / tables as required to l document and/or acquire objective evidence.

4.1.3 NUS personnal performing validation activities ruch as document reviews or field inspection shall receive training in the specific requirements of the validation activities.

The type of training given in each instance shall be documented.

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P O W E R & LI G H T ! ecm.r.um.s-m% n:nso e p --

MIOCLE SOUTH UTiuT;ES SYSTEM J.M. CAIN June 20, 1984 President and Chief Executive Officer I-W3B84-0445 Mr. Saul Levine .

NUS Corporation 910 clopper Road -

Gaithersburg, Maryland 20878 Mr. Robert L. Ferguson , ,

UNC Nuclear Industries, Inc. -

1200 Jadvin, Seite 425 Richland, Washington 99352

{

i Mr. Larry L. Humphries l UNC Nuclear Industries, Inc.

l P.O. Box 490 1 Richland, Washington 99352 l

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SUBJECT:

Pre--Licensing Issue Assessment Task Force t'harter .

REFERENCE:

-Discussions in the,0ffices of Shaw, Pitt=an, Potts & Trowbridge,- Washington, D.C. , June 13, 1984

Dear Messrs:

Levine, Ferguson and Humphries:

Pursuant to discussions in the referenced meet g, this for=alizes agree =ents reached between us as to the charter of the subject Task Force.

The roles of UNC and NUS will be to act as a task force in providing assessment and advice in responding to the NRC letter of June 13, 1984 It is i=portant to emphasize that both UNC and NUS will mai= .ain sufficient indqpendence in order to provide to me as Chief Executive Officer of LP&L an independent pro-fessional assessment regarding the functions listed below. Your assessments vill be formalized and sent to the Director of the Office of Nuclear Reactor Operations at the same time they are provided to me.

L 9 The Program Plan and implementation schedule requested ir.

the NRC letter, e The adequacy of responses and resolutions (including validation of data and sources, as cypropriate) of the l matters set out in the NRC letter.

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6 - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _

.', ,'::e- :.cens:.n; .ssue Assessr.en:

.sg. .

.. Task Force Charter Juns 20, 1984 i

e The safety significance of the matters liste'd in the NRC letter with respect to:

- Fuel load and testing up to 5% power

- Operation above SI power o

e The adequacy of the past QA/QC program in light of the  ;.

matters listed in the NRC letter, and the resolution of such matters.

4 Recommend institutional or programmatic changes that are deemed appropriate during plant operation in light of the lessona learned as a result of the matters set forth in the NRC letter, and the LP&L responses hereto.

• The fellowing abbrieviated organization chart is provided to clearly depict that the Task Torce is to. have access to and interface with all necessary elements of the Waterford' staff but is to report directly to me. -

President &

Chief Executive Officer (LP&L)

(J.'Cain)

Task Force T~

Senior Vice Brasident - '

Nuclear Operations (LP&L)

(M. Leddick)

.. . Safety Review

______________ Co=mittee i

l I Quality Assurance Proj ect Manager (LP&L)-----Plant Manager (LP&L)

Manager (LP&L) (D. Dobson) (R. Barkhurst)

(T. Garrets) 8 8

i i Ebasco & Staff LP&L & Staff Reporting Interface Very tru y yours, l

J.M. Cain JMC:DED:pb cc: G. Charnof f, R.S. Leddick, D.E. Dobson

yp>'*c%jog UNITED STATES y_ ,( p, NUCLEAR REGULATORY COMMISSION E WASHINGTON, D. C. 20555 -

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. June 13, 1984 Docket No. 50-382

• i Mr. J. M. Cain President & Chief Executive Officer

• Louisiana Power and Light Company 1 317 Baronne Street New Orleans, Louisiana 70160

SUBJECT:

WATERFORD 3 REVIEW On April 2, 1984, the staff began a. intensive review effort largely ~

conducted onsite, designed to complete those issues necessary for the staff to reach its licensing decisien on Waterford Unit 3. These issues covered a number of areas including allegations of improper construction practices at the facility. As we indicated to you. the staff would promptly notify you of issues that :ould potentially affect the safe operation of the plant. -

We have recently. identified the items listed in the enclosure that have, potential safety implications for which we require additional information. .

It should be noted that they are being provided to your before the NRC staff publication of its SSER which will document its assessment of the significance of these and all of the other issues examined. The issues in the enclosure represent an extensive staff audit of information related to the plant. -

As a result, you are requested to propose a program and schedule for a

detailed and thorough assessment of the concerns. This program plan and implementation schedule will be evaluated by the staff before consideration of issuance of an operating license for Waterford 3. This progran pian should include and address the cause of each of these potential problems identified; the generic implications and the root cause of the concern on

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Mr. J. M. Cain 2- June 13, 1984 '

e other safety-related systems, programs or areas; and the collective significance of these deficiencies. Your program plan should i'nclude the proposed LP&L action to assure that such problems will be precluded from .#

occurring in the future. .

. . Sincerely, M[

p.f M

DarrellG.Eis@ hut, Director  ;.

Division of Licensing .

Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page e

, N O

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t Mr. J. M. Cain - 3- June 13, 1984 Mr. R. S. Leddick

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Vice President - Nuclear Operations Louisiana Power & Light Company 142 Delarende Street- .

New Orleans, Louisiana 70174 W. Malcolm Stevenson, Esq. Regional Administrator - Region IV Monroe & Leman U. S. Nuclear Regulatory Commission 1432 Whitney Building 611 Ryan Plaza Drive New Orleans, Louisiana 70130 Suite 1000 -

Arlington, Texas 76012 --

Mr. E. Blake .

Shaw, Pittman, Potts and Trowbridge Carole H. Burstein, Esq.

1800 M Street, NW 445 Walnut Street Washington, DC 20036 New Orleans, Louisiana 70118 Mr. Gary L. .Groesch 2257 Bayou Road New Orleans, Louisiana 70119 ,

,- Mr. F. J. Drummond "

', Project Manager - Nuclear

.'. Louisia*na Power and Light Company 142 Delarende Street New Orleans, Louisiana 70174 Mr. K. W. Cook . .

Nuclear Support and Licensing Manager Louisiana Power & Light Company -

'.42 Delarende Street New Orleans, Louisiana 70174 .

Luke-Fontana, Esq.

824 Esplanade Avenue -

New Orleans, Louisiana 70116 Stephen M. Irving, Esq.

535 North 6th Street -

Baton Rouge, Lcuisiana 70802 Resident Inspector /Waterford NPS ~

P. O. Box 822 -

Killona, Louisiana 70066 Mr. Jack Fager -

Miccle South Services, Inc. -

P. O. Box 61000 -

New Orleans, Louisiana 70161 .

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ENCLOSURE .

r POTENTIAL SAFETY IMPLICATIONS

1. Inspection Personnel Issues ,

As a part of the NRC staff's review, the credentials of quality a assurance and quality control inspectors were examined. Included in .,

this effort were the verification of previous job experience and qualifications and certification of personnel as inspectors.

The following items were found: - - - -

(1) HRC reviewed inspector certifications for 37 of the 100 Mercury QC inspectors, including certifications for all Level III personnel. 7 Twelve inspector certifications were found questionable due to insufficient education or experience. ,

(2) The certification records of 38 Tompkins-Beckwith (T-B) QC inspectors were selected at random and reviewed. Fourteen

' inspector certifications were found questionable dut to insufficient education or experience.

(3) A 30% samole by the staff of inspector certifications of the f - 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 have inspected safety-related systems, thereby rendering verification of the quality of these systems indeterminant. LP&L shall: (1) verify the professional credentials of 100". of the site QA/QC personnel, -

including supervisors and managers, (2) reinspect the work performed by inspectors found unqualified, and (3) verify the prcper certification of the remaining site QA/QC personnel to ANSI N45.2.6-1973.

2. Missino N1 Instrument Line Documentation  :

The staff examined the documentation concerning installation of safety-related N1 instrument lines. Part of that review dealt with the situaticn where there is a change of design classificaticn for systems.

As a result of the staff review it was determined that ccmunications between LP&L and Ebasco prompted a revision to be written by Ebasco to an LP&L drawing to clarify the " class break" for N1 instrument lines. The revision imposed ASME Class requirements for all installations between the process piping and the instruments for instrument lines installed after April 7, 1982. Prior to the revision a class break was defined to show the location where ASME class stopped and ANSI B31.1 applied.

Although ANSI S31.1 does not relate to records retention,10 CFR 50 _

Appendix 3 does require special process controls, traceability, installation and inspection records. Therefore, for locally mounted N1 instruments, even though they were installed prior to April 7,1982, .

c these records could not be located. Examples of the instruments lines with no supporting installation and inspection records for zones classified as ANSI B31.1 are LT-SI-0305B; LT-SI-0305D; PS-CH-0224X; PS-CH-0224Y and PS-CH-0224Z. 1 Examples of the type of deficient data are weld reports, welder identification, weld filler material, base material and weld inspection results.

The NRC staff concluded that based upon the lack of quality records, for _

instrumentation installation to 831.1 the requirements of 10 CFR 50, -

Appendix.B and the related other QA program elements may not have been complied with.

The lack of documentation to demonstrate the quality of installation of these safety related lines calls into question the acceptability of these installed components.

LP&L shall; (1) Provide the missing documentation required by 10 CFR 50 Appendix B for the B31.1 instrumentation for local mounted instruments;

/ (2) Review other design changes and documentation for all safety-related, N1 instrumentation systems to assure all system installations were properly documented and inspected; and (3) If the documentation cannot be located, action must be taken to assure affected portions of safety-related system comply with NRC requirements.

3. Instrumentation Exoansion Loco Seoaration As a part of its review of NCRs the staff identified a concern in NCR' W3-7702. This NCR was written as a result of Mercury OCR Package 1782.

Drawing 172-L-012-C Revision 4 had a handwritten note on it identifying two lines DPR-RC-9116 SMS (HP) and DPT-RC-9115 -SMA-(-HP-) where-the-separation criteria had been violated. The violation occurs where these instrument lines from different trains leave the tube tracks and form an ~.

expansion loop before returning to the continuation of the tube track.

Lack of separation could result in failure of redundant lines that could prevent a safety function.

LP&L shall correct the separation criteria violation found in System 52A. They shall also provide a program for review of other safety-related systems for separation criteria violations and take the necessary corrective actions.

4 Lower Tier Corrective Actions Are Not Beina Uoaraded to NCRs The staff reviewed the Corrective Action system to verify if Icwer tier -

corrective action documents were being properly upgraded to NCRs as _

required by 10 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 .

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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 Finally a walkdown was performed to verify proper wk nonconformance).

identification and chan In addition )

Tompkins-Beckwith (T-B)ge control completion. Discrepancy Notices (DNs) w As a result of its review the staff.found that the following issue,s.

a. Field Change Requests - Sixty-three FCRs and 21 revisions to FCRs were evaluated. It appears as though 35 should have' been NCRs and 7 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-M?-1434 F-E-2288

b. Design Change Notices - Fourteen DCNs and 5 revisicns 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-1C-478 DCN-ME-30 DCN-E-790 It appears as though the problems identified in DCN-703 are related td FCR-MP-2138 and may have been reportable under 10 CFR Parts 21 or 50.55(e).

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

EDN-EC-1476 '

EDN-E-1548 EDN-EC-1502 EDN-EC-1479 In addition during the review, another 35 were " voided" with no action taken. The voiding action was performed by a clerk.

Examples of voided EDNs are as follows: -

EDN-EC-0630 _

EDN-EC-1175 EDN-EC-1176 EDN-EC-1140 .

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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. .

c 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 sunnary, the staff found that the QA program requirements for nonconformance identification, centrol and proper action do not appes:- to have been complied with. .

LP&L shall review all FCRs, DCNs EDNs, and T-B DNs to assure that nrocer corrective action was taken, including an adequate review by QA. Th S '

action shall include the steps required by 10 CFR 50, Appendix B,

. Criterion XVI, 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.

! 5. Vendor Documentation - Conditional Releases  :

b As a part of the staff review of the QA program, the staff evaluated the

, :Ebasco vendor QA program. In assessing this program, the staff

! specifically looked at the receipt inspection program and the conditional release system. -

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l- As a result of its evaluation, the staff found certain~ deficiencies with l the handling of conditional certification of equipment (C of E) for

( Combustion Engineering supplied equipment. For example, one conditional

! C of E for the reactor vessel and internals was issued because as-built l ' drawings, material certifications, and the fabrication plans had not been l- forwarded when the equipment was delivered to LP&L in 1976. The missing -

l documents were sent to Ebasco scmetime in 1978, according to the Ebasco -

l quality records supervisor, but were apparently lost prior to being placed in the Ebasco document control system. The conditional

certification of equipment was found when a check of all files was made in April or May 1984. The missing documents have been requested from CE, and a deficiency report was issued and placed on a master deficiency g list. This problem has existed since July 20, 1976. .

- The safety significance of this is that problems with the vendor QA records could affect installed safety related equipment. LP&L shall examine their records and determine.lf all conditional certifications of equipment have been identified, reviewed, and promptly resolved.

6. Dispositioninc of Nonconformance and Discrecancy Reports The staff' condo:ted a review of Ebasco nonconformance reports (NCRs) randomly ' selected from the Ebasco QA vault and the NCR tracking system.

The selected N Rs were reviewed for content, compliance with procedures, accuracy, comp:ateness of the disposition and final closure. Of the NCRs reviewed it c the staff's judgement tr.at a::croximately one third contained questic sie dispositions. Other NCRs were found still open.

The implied safe.; significance is that improperly dispositioned NCRs or '

lack,,of NCR cleic ceuld place the quality of installation in question.

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For example, Ebas: NCR W3-5564 identiff'es ihat welds were oainted before the final weld in: action was performed. The NCR was closed out with a letter stating th: the final inspection will be performad to inspect only for underr' 3 and lack of weld material where installation drawing calls for wel>. raterial. No paint was to ce removed therefore the inspector could not inspect for welding defects'.

l The NCRs revieweo bf the staff dealt with a wide variety of issues. The j following is a list of example Ebasco NCRs that the staff feels contain j questionable dispositions or exceeded clcsure time requirements.

l Ebasco W3 NCRs .

NCR-7139 NCR-7177 NCR-3912 NCR-7182 NCR-5563 NCR-7181 NCR-7184 NCR-6159 NCR-6723 NRC-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 .'CR-7170 NCR-7140 NCR-5565 l The staff also found similar type problems related to Mercury NCRs in i that the dispositions were questionable; supporting documentation could not be located; rework appears to have not been accomolished; NCRs were _

not processed; a sufficient basis was not provided; and closure basis was inadequate. -

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6-The following NCRs fall into these categories:

Mercury NCRs 180 420 528 568 625 1 255 429 540 591 656 268 438 554 594 658 363 487 560 595 380 491 565 614 Additionally during this review the staff found problems with Ebasco discrepancy reports (DRs) in that it appears some DRs should have been ..*

elevated to NCRs; closure references were incorrect or inappropriate; closure 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 categcries:

Ebasco DRs Related to Turnover Packaoes

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. 02-CS-1C-27 B0-1C-1143

- - 4 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 CH-1C-342 CC-1C-6 Th'e staff concludes that some Ebasco and Mercury NCRs and Ebasco DRs were questionably dispositioned and that LP&L shall (1) Propose a .

program 'that assures that all NCRs and ors are appropriately upgraded and adequately dispositioned and corrective action completed, and (2) correct any problem detected.

7. Backfill Soil Densities The staff fcund that records are missing for the in-place density test of backfill in Area 5 (first 5' starting at Elevation -41.25'). These documents are important because the seismic response of the plant is a function of the soil densities.

LP&L shall (1) Conduct a review of all soil packages for completeness and technical adequacy and locate all records and provide closure on technical questions, or (2) conduct a review of all soil packages for completeness and technical adequacy and where soil volumes cannot be verified by records as meeting criteria, perform and document actual soil conditions by utilizing penetration tests or other methods, or -

(3) Justify by analysis that the soil volumes with missing records, or _

technical problems as defined after the records review, are not critical in the structural capability of the plant under seismic loads.

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8. Visual Examination of Shoo Welds During Hydrostatic Testing s

The staff's review of hydrostatic tests conducted by Tompkins-Beckwith .

(T-B) for their installed ASME Class 1 and Class 2 pipi.,q systems found r

~~ a lack of proof of the visual inspection of all shop welds during the tests. Inspection of all welds for leakage is required by the ASME Code and is essential to ensure the structural integrity of the piping system.

LP&L shall provide documented evTdeWe" that shop welds were indeed' inspected during the hydro tests. If the appropriate inspection documents do not exist or cannot be located, LP&L shall submit a  ;

statement attesting to shop weld inspection by the responsible personnel of LP&L or Ebasco who had witnessed the hydro tests.

9. Welder Certification The staff reviewed the records for the installation of the supports for certain of the instrumentation cabinets in the Reactor Containment Building (RCB). The review included an examination of procurement records for the support material, weld rod control documents, welder ~

certification records, and QC inspection records.,

Based' on the staff review it appears that documentation is missing on the support welds.snd 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 cabinets are indeterminant.

LP&L shall attempt to locate the missing documeitts 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.

10. Inscector Qualifications (J. A. Jones and Fegles) ~~ ~~ ~

The NRC staff reviewed the cualification and certifications of QC inspectors in the civil / structural area. The review included the qualifications of four Eb:sco inspectors, 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 r indeterminant. -

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, 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

,5 the qualification requirements, the licensee shall then review the records to determine the inspections made by the unqualified individuals and provide a statement on the impact of the deficiencies noted on the safety of the project.

11. Cadwelding The staff reviewed the Cadweld activities related to the deficiencies identified in .NCR-W3-623a. The staff is concerned that the applicant has provided~only limited data (in other than the raw form) to the NRC on the statistics of the Cadweld testing program conducted during construction.

The data provided stated that for the. base mat 3,673 splices were made with 81 tests of 60,750 run, showing

- 107,051 an average strength of 95,397 psi with a range psi. For the entire project the applicant has stated that 14,293 splices were made of which 591 were tested with 5 of those failing to meet tensile requirements.

It is noted that the above NCR has been reopened as a result of the CAT inspection and all issues have not

/ been resolved.

LP&L shall provide the Caldweld data for the project in such a form that it can be readily compared to the acceptance criteria used for the Waterford 3 project. This will require breaking dcwn the Cadweld data by building or structural element such as the bese mat, NPIS walls that are not part of RAB or FHB, containment interior structures etc.

Additionally, the data should be broken down by test program type (production or sister), bar size, bar position and cadwelder. Data .

shall be provided in each category on total splices made, visual rejects, production tests and failures, and sister tests and failures.

Data shall also be provided on welder qualification and requalification

' including dates. ~

Based on discussions with LP&L representatives the NRC staff has been informed that efforts in this area are underway, but this information is needed for staff review.

12. Main Steamline Framing Restraints As part of the NRC staff's review, the installation and inspection of the main steamline framing restraints above the steam generators was

• examined to determine if the as-built drawings reflect the actual installation. The NRC staff found no problems with as-built conditions, but found that-several bolted connections had not been inspected -

(or documented) for the framing. The failure to perform (or document) the inspections render the quality of these framing restraints as indeterminant.

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Based on discussions with LP&L representatives the staff was i.nformed that the subject inspections are in progress. LP&L shall complete the inspections of the restraints and make the documentation of such er inspections available to the staff. .

13. Missing NCRs During the NRC's review of Ebascc's NCR Processing System the card index file of NCRs was examined and thE staff noted that there 'are missi'ng reports in the consecutively numbered NCRs. Specifically.W3-27, 814, 859, 981, 1053, 1102, 1109, 1228, 1349, and 1438 are missing from your ..

card index file.. Others were also noted to be missing from the Ebasco

• QA vault; LP&L shall (1) obtain the missing NCRs, explain why these NCRs were not maintained in the filing system, review them for proper voiding, and (2) assure that when an issue is raised to an NCR, it is then properly filed for tracking and closure.

14. J. A. Jones Soeed Letters and EIRs

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DuringtheEbascoQAreviewofJ.A.Jone speed letters and engineering

- information requests, several items that could affect plant safety were noted. Based on its sample of these actions, the staff does not expect that any of these items will significantly affect plant safety.

Nevertheless, the applicant should complete the actions identified in these reviews and issues raised shall be resolved promptly.

15. Welding of "D" Level Material Inside Containment The staff reviewed the welding of "D", level material for containment attachments. The containment spray system structural component welds were chosen for specific detailed review. The welds on the containment spray piping supports were checked for weld rod traceability and welder ~

identification and certification. The applicant was unable to produce the documentation sought for the staff review.

The applicant shall (1) locate the documentation and verify the adequacy of the information, or- (2) perform a material analysis and NDE work, or (3) rework the welds. The staff shall be promptly informed of the applicant's approach and the documentation shall be made available for staff review.

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16. Surveys and Exit Interviews of OA Personnel In a memorandum dated January 3, 1984, R. S. Leddick, LP&L Vice President for Nuclear Operations, directed that the LP&L Quality 1 Assurance (QA) personnel conduct interviews of the on-site contractor QA personnel to elicit any concerns the contractor staff may have regarding the quality of construction of Waterford Unit 3. That memorandum also indicated that exit inteviews would be similarly conducted with the contractor personnel prior to their leaving the Waterford 3 project. A total of 407 such interviews were' conducted ,

beginning in January 1984 Individual responses were sent to the -

specific employee (s) who raised the con ern.

Exit interviews with the contractor QA employees (resigned, transferred, or terminated) began on January 15,196. . A ccmpilation of the concerns raised during those interviews were fory ~ fed for followup on May 22, 1984.

The NRC staff reviewed all of the questier re forms and responses to the questions identified by.the L 9L QA et 'f. In some cases, the S'RC .

review identified additional potential 1.5 as, beyond those identified by LP&L, and responses that did net addru the intent of the concerns.

Nevertheless, the staff found that the ma,i -ity'of the concerns raised are being or have been addressed as part o all of the other NRC review efforts associated with Waterford 3.

As a result of the staff review, it is .: evident that the survey and exit interviews have been vigorously p . sued by LP&L to investigate tfie issues raised for safety significance, root cause, and generic implications. For example, the exit interviews began in January and .

are continuing. Hcwever, the process of re,' ewing the content of those interviews did not begin until late May 1984 For some of the interviews, additional information should have been obtained from the person interviewed but the interviewers did not indicate on the fom whether or not they sought additional Scts. Finally for a number of -

areas, issues or potential problems wer? acknowledged but it is not clear that any followup action occurrec.

The NRC staff is concerned that the LP5L program to investigate issues does not promptly and thorcughly examine tne specific areas and the programmatic implications of them. Other successful programs have utilized independently staffed groups to assess 2ach issue raised and formally report to senior utility management on their findings and recommended corrective actions. These elements are not evident in the LP&L process. As a result, LP&L should develop and implement a formal program for handling issues raised by individuals. One of the first tasks to be dealt with by the program should be the review of the -

responses previously provided to the QA nrvey and during the exit .,

interviews. -

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• 17. OC Verification of Expansion Anchor Characteristics A review of Mercury Construction Procedure SP-666, Revision 8, ,

" Drilled-In Expansion Type Anchors in Concrete for Category I c Structures," revealed that it does not require QC verification of many characteristics necessary to ensure proper installation of concrete expansion anchors. These characteristics include:

Spacing between adjacent anchors .

Spacing between an anchor and the edge of a concrete surface ,

- Spacing between an anchor and an embedded plate

• Minimum anchor embedment depth

- Grouting of unused / abandoned holes in the concrete Mounting plate size Size of holes in mounting plates and hole distance from plate edges Although most of the above characteristics are addressed in Section 6.1

" installation," they are not included within Section 6.2 " Inspection,"'

as items requiring QC verification. In addition, QC Inspection os port Form 277A, Rev. May 1982, " Equipment Installation (Anchors)," does not lift these attributes as inspection points.

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Therefore, Procedure SP'666 should be revised to include all necessary inspection attributes, and a reinspection program should be initiated.

This program should be of sufficient size and scope to indicate wnether these concrete anchors, in general, are able to perform their intended function. Detailed results should be made available to the NF.C staff for review.

18. Documentation of Walkdowns of Non-Safety Related Ecuioment A review of the design and evaluation of the non-safety instrument air piping, tubing, and their supports indicated that the general reccmmendations of Regulatory Guide 1.29, " Seismic Design Classification" -

were considered. This non-safety equipment is installed in areas with safety related equipment, such as the containment and auxiliary building areas. From the information provided relative to this system, it is apparent that the potential for system failure was considered in the design.

Also a number of procedures and controls were implemented to further assure that these non-safety related components would not affect safety related equipment. However, the followup documentation of the final walkdowns did not list the reviewed equipment in detail and'therefore it could not be concluded that the instrument air piping and tubing (and their supports) had been adequately addressed regarding potential -

physical damage to safety-related equipment. _

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Therefore, documentation should be provided that clearly shows, what equipment was reviewed during the walkdowns and on what bases it was concluded that the installation was acceptable.

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19. Water in Basemat Instrumentation Conduit In examining the safety significance of the allegations, the NRC staff performed system walkdowns as a means of verifying the as-built conditions. During one of those walkdowns, the staff noted that there was water in an electrical conduit that penetrated the basemat. If the seals in that conduit should fail there is a potential direct path for ,

ground water to flood the auxiliary building basement. LP&L should review a.11 conduit that penetrates the basemat and terminates above the top of the basemat to assure that these potential direct access paths of water are properly sealed.

20. Construction Materials Testino (CMT) Personnel Ous11fication Records The Inquiry Team effort included a review of the disposition of the generic problem identified during the LP&L Task Force verification relative to GE0 Construction Testing (GEO) documentatien for personnel qualifications in the area of.CMT.

The utility should conduct a review of supporting documentation for GE0 corrective action stated in Attachment 6 of NCR W3-F7-116 (Ebasco W3-6487). This review should focus on the identification of CMT personnel placed 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.

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21. LP&L OA Construction System Status and Transfer Reviews ,

The Inquiry Team assessment of the Ebasco QA disposition of LP&L QA Construction documentation and walk-through hardware findings for a sample of the sixty-seven systems transferred to LP&L operations resulted in NRC questions on the adequacy of Ebasco and LP&L QA Construction disposition of those findings. As a result of the NRC

questions LP&L and Ebasco QA initiated a review to ensure that all

= LP&L QA Construction findings were adequately dispositioned. Ebasco QA had identified 15 systems or subsystems (Nos. 18-3, 36-1, 36-3, 438, 4389, 46C, 46E, 46H, 55A, 59, 69B, 7182, 72A, and 91E) where the LP&L findings may not have been properly dispositioned during the transfer of these systems to LP&L operations. _

s Based on the above, LP&L is requested to complete the review of all significant LP&L status and transfer review findings, such as undersized.,.

welds and other hardware walk-through and documentation findings. This r' .

review should ensure that these findings have been properly closed out or e identified to LP&L operations for their closecut. For any LP&L open findings not properly identified on the status or transfer letters to LP&L operations, LP&L should determine whether this condition adversely affected the testing conducted for-those systems. -

22. Welder Qualifications (Mercury) and Filler Material Control (Site Wide) ..,

The staff reviewed inprocess weld records for the installation of instrumentation systems by Mercury Company. Systems reviewed included Reactor Coolant, Safety Injection, Component Cooling Water, Main Steam, Main Feed, and Charging Water. The staff selected welders frcm these records and reviewed their qualifications to the welding process used during the time frame of actual welding.

Based on the staff's review it appears that some Mercury welders were not qualified. Problems included: welders not qualified to the

~ correct welding procedure; welders qualified for a specific process, even though they were not tested for that process; and actual dates on qualification records appeared questionable, the welder may have welded .

prior to being tested. The staff concludes that there are questions relative to the Mercury welder qualification status.

A1,so during this review the staff evaluated the' controls being used to control filler material. The staff found that the requirements for .

"rebaking" of low hydrogen electrodes did not meet the requirenent of the ASME and AWS Codes. The Codes require low hydregen electrodes to be rebaked at temperatures of 450* to 800*F for two hours. The site practice for all site contractors was to rebake at 200*F fot_ eight_.._ . . . . _ . _

hours. Justification for this Code deviation has not been provided by LP&L . -

LP&L shall (1) Attempt to locate the missinc documentation and determine if the welders were properly qualified, or {2) If the documentation to support proper qualification cannot be located, LP&L shalj propose a program to assure the quality of all welds performed by questionably qualified welders.

LP&L shall also provide engineering justification for the allowance of "rebake" temperatures and holding times that differ from the requirements of the ASME and AWS Codes.

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23. 0A Procram Breakdown Between Ebasco and Mercury The staff review included evaluation of the implementation of the QA .

programs of LP&L, Ebasco, and Mercury. The staff performed a followup on the previous 1982 NRC review that resulted in NRC enforcement actica and a civil penalty. The most recent staff review indicated that LP&L, Ebasco, and Mercury did not followup on the corrective action commitments made to the NRC.

Additionally LP&L, Ebasco, and Mercury failed to audit th'e entire QA program as required (LP&L only performed one-third of their scheduled audits for a five year period). The audits that were conducted identified some problems, however the required corrective actions were not completed. Management audits, performed by outside consultants, identified problems and concerns that LP&L also failed to take corrective action on.

The results of the NRC task force effort' indicate that an overall breakdown of the QA program. occurred. Most prcblems identified by the

' NRC had been previously identified by the QA programs of LP&L, Ebasco, and Mercury. But the failure to determine root cause and the lack of corrective action allowed the problem to persist.

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LP&L shall provide an assessment of the overall QA program and determine the cause of the breakdown, together with corrective action to prevent recurrence. This overall assessment is necessary to provir a

, assurance that the QA program can function ace,quately wnen the plant proceeds into operations. .

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., PRELICENSING ISSUE TASK FORCE SUPPORT GROUP ORGANIZATION ATTACHMENT D PROJECT MANAE M Peter V. Judd

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l FIELD INSPECTION TEAM MANAGER- ISSUE REVIEWERS

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Mark Vislay

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FIELD INSPECTORS DOCUMENT REVIEWERS

• This p5sition originally filled by B. Naft until the arrival of P. V. Judd on site, July 11, 1984.

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• e PRELICENSING ISSUE TASK FORCE SUPPORT GROUP ORGANIZATION ATTACHMENT C PRELICENSING ISSUE TASK FORCE .

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