IR 05000498/1980024
| ML19351E838 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/05/1980 |
| From: | Crossman W, Randy Hall, Hubacek W, Tapia J, Tomlinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351E832 | List: |
| References | |
| 50-498-80-24, 50-499-80-24, NUDOCS 8012190416 | |
| Download: ML19351E838 (19) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-498/80-24; 50-499/80-24 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name:
South Texas Project, Units 1 and 2 Inspection At:
South Texas Project, Matagorda County, Texas Inspection Conducted:
August 18-22, September 2-5, and September 16-19, 1980
_4 he jl.b Bo Inspectors:
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J.I.Tapia,h/leactBr Inspgor, Engineering Support Date Section
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. P. Tomlinson, Reactor Inspector, Engineering Support Uate Section Other Accompanying Personnel:
W. G. Hubacek, Reactor Inspector, Projects Section W. A. Crossman, Chief, Projects Section Approved:
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N f/9 W. A. Crossman, Chief, Projects Section Date s
// 3 R. E. Hall, Chief, Engineering Support Section
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Inspection Summarv:
Inspection on August 18-22, September 2-5, and September 16-19, 1980 (Report No. 50-498/80-24; 50-499/80-24)
Areas Inspected: Routine, unannounced follow-up inspection of construction activities including observation of work and review of records pertaining to responses to the NRC Inspection Report No. 50-498/79-19; 50-499/79-19 findings and the responses to the Show Cause Order issued by the NRC.
The inspec-
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tion involved one hundred and thirty two inspector-hours by two NRC inspectors.
Results: No items of noncompliance or deviations were identified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- R. A. Frazar, Manager, Quality Assurance
- D. G. Barker, Project Manager
- J. W. Briskin, Project Manager, Operations
- L. K. English, Site Manager
- T. J. Jordan, Supervisor, Quality Systems
- R. A. Carvel, Project QA Supervisor
- L. D. Wilson, Project QA Supervisor
- J. W. Soward, QC Supervisor S. K. Hubbard, Sr. QA Specialist G. Steinmann, Civil Engineer Other Personnel G. R. Murphy, Concrete Verification Program Leader, Brown & Root (B&R)
- R. H. Leasburg, Site Manager, B&R
- W. J. Friedrich, Project QA Manager, Management Analysis Corp. (MAC)
- G. R. Purdy, Manager, Quality Engineering, B&R
- D. J. Harris, Manager, Quality Engineering, MAC
- V. Cech, QA Engineer, B&R
- R. W. Bass, Audit Section Manager, B&R
- F. G. Miller, Senior Welding Engineer, B&R
- M. D. Muscente, Welding Project Manager, B&R J. Ruud, Supervisor, Civil Quality Engineering, MAC M. Boorady, General Foreman, Construction Engineering Consultants (CEC)
J. L. Sullivan, QA Training Coordinator, B&R M. L. Carlton, Site QC Manager, Pittsburgh Testing Laboratory The IE inspectors also interviewed other licensee and contractor personnel including members of the engineering and QA/QC staffs.
- Denotes those attending the exit interview on September 5,1980.
- Denotes those attending the exit interview on September 19, 1980.
2.
Licensee Action on Previous Inspection Findings During this inspection, certain corrective actions described in the Houston Lighting and Power Company (HL&P) letter to the NRC, dated May 23, 1980, were inspected.
The letter was in response to the items of noncompliance resulting from the special investigation reported in Investigation Report No. 50-498/79-19; 50-499/79-19. This inspection is a continuation of the follow-up activities initiated during inspections No. 50-498/80-17; 50-499/80-17 and No. 50-498/80-19; 50-499/g0-19, and specifically addresses those items related to Category I structural
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backfill, concrete, welding and nondestructive examination.
These items are identified as infractions No. 7, 8, 10, lle, 12, 13 and 21 in Appendix A and infraction No. 22 in Appendix B to the NRC letter to
'HL&P, dated April 30, 1980.
In addition, thirteen unresolved items from Investigation Report No. 50-498/79-19; 50-499/79-19 were also reviewed.
In the discussion below, the track numbers from IE Investigation Report No. 50-498/79-19; 50-499/79-19 are indicated In addition, noncompliance items identified in Inspection Reports No. 50-498/79-15; 50-499/79-15, 50-498/79-20; 50-499/79-20 and 50-498/
80-01; 50-499/80-01 were also reviewed.
(Closed) Infraction (50-498/79-19-10; 50-499/79-19-10):
Ineffective Corrective Action to Resolve Previously Identified Concrete Placement Deficiencies. During inspection No. 50-498/80-19; 50-499/80-19, the IE inspector reviewed corrective actions initiated in response to the subject item of noncompliance. Those corrective actions addressed improper consolidation and excessive lift thickness, concrete place-ment planning, inadequate lighting, QC inspector " hold work" authority, and associated training to the new procedure which prescribes the methods and requirements for all activities involved with concrete construction. The licensee had committed, in the response to the infraction, to provide additional QC preplacement inspector staffing.
Since a stop-work order was in existence for all complex concrete placements, the implementation of this commitment was not reviewed during inspection No. 50-498/80-19; 50-499/80-19. The infraction there-fore remained open pending verification of increased QC staffing following the resumption of complex concrete placement.
During this inspection, the licensee submitted a supplemental response to clarify certain state-ments in the original response and expand on others based on discussions held during the exit interview for Inspection Report No. 50-498/80-19; 50-499/80-19.
The supplemental response clarifies.the licensee's original
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' commitment to increase the QC staff by stating that the original commitment l
was meant to refer to a relative increase in QC involvement in preplacement activities based on increased levels of concrete ccustruction activity
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and was not meant to refer to an increase in the absolute number of qualified preplacement inspectors.
The submitted clarification and the previously reviewed corrective actions taken to assure QC preplacement inspector effectiveness resolve the item of noncompliance. The adequacy of concrete preplacement and placement activities will receive continuing assessment in the course of subsequent inspections.
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This item is closed.
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(0 pen): Infraction (50-498/79-19-11; 50-499/79-19-11):
Failure to Inspect Reinforcing Steel for Loose Rebar Prior to Concrete Placement.
The licensee's response to this infraction referred to the corrective
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actions taken in response to Item No. 50-498/79-19-10; 50-499/79-19-10.
In addition, the licensee committed to provide an engineering assessment of the effect of the unwired shear ties observed in the Unit 1 Diesel Generator basement placement.
During this inspection, discussions were held with the Concrete Verification Program Task Leader, at his request, to identify an appropriate method of performing the engineering analysis.
It was agreed that for purposes of analyzing loose shear ties, a very conservative analysis would be to disregard every other shear tie.
This infraction vill remain open pending review of the finalized engineer-ing analysis.
(Closed) Infraction (50-498/79-19-16; 50-499/79-19-16):
Failure to Follow Procedures with Regard to Qualification of Civil and Concrete QC Inspectors.
A review of the qualification and certification of all civil QC personnel was conducted by the licensee representative.
This review included verification of information contained in job application records with previous employers and schools.
The review effort was addressed by the IE inspectors during inspection No. 50-498/80-04; 50-499/80-04. As of September 12, 1980, the licensee now has twenty-three retrained and qualified concrete QC inspectors.
Brown & Root Power Division Procedure No. DLO35, Revision 0, " Procedure for Verifica-tion of Education and Experience," was issued May 21, 1980, for the purpose of outlining the process to be followed for verification of a new employee's educational background and prior job experience.
In addition to reviewing the new procedure, the IE inspector randomly selected one QC inspector's file and verified that the three years of college education listed on B&R form PD1410, " Certification Record,"
had been verified by receipt of an official transcript from the listed college. The completed form, " Requesting Verification of Previous Employment," was also reviewed and found to document the employee's stated previous employment.
The licensee representative's review of all Civil QC personnel and substantiating documentation to Procedure No. DLO35 resolve the item of noncompliance.
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Ihis item is closed.
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(Closed) Infraction (50-498/79-19-03; 50-499/79-19-03):
Failure to l
Take Corrective Action when Cadwelders Needed Requalification.
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this inspection, the licensee submitted a supplemental response to clarify certain statements in the original response and expand on others
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based on discussions held during the exit interview for inspection No. 50-498/80-19; 50-499/80-19. The supplemental response addresses paragraph B.4 of the initial response, " corrective steps which will l
be taken to avoid future items of noncompliance."
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This paragraph originally did not address how QC inspectors would be empowered to stop work in progress until observed discrepancies are resolved. Quality Construction Procedure "o. A040KPCCP-25 authorizes the QC inspector to stop work in progress until nonconforming con-ditions are resolved by a Project Site Engineering representative.
In addition, this precedure requires that all such conditions and sub-sequent engineering dispositions be documented on nonconformance reports (NCRs).
In order to assure that individual inspectors are made aware of dispositions to NCRs which they originate, the NCR reporting procedure will be revised to include feedback mechanisms which will make inspectors aware of dispositions to all NCRs.
This specific infraction, " Failure to Take Corrective Action When Cadwelders Needed Requalification," resulted from Allegation No. 10A of Inspection Report No. 50-498/79-19; 50-499/79-19.
The allegation concerned the substantiated fact that five Cadwelders were permitted to continue working when a QC inspector had identified the fact that all five Cadwelders were not qualified to continue working without requalification according to specification requirements.
When two of fifteen Cadweld splices are found visually unacceptable by QC inspectors, requalification of the Cadwelder is required by Specification No. 2A010CS028-G/DCN/5-2-79,
" Concrete Construction." The allegation arose because Cadwelders were permitted to continue making production splices after two unacceptable splices within a unit of fifteen consecutive splices had been identified by QC inspectors.
Allegation No. 10A was found to be an instance of lack of management support to the QC inspectors.
The specification requirement for requalification is based on South Texas Project Final Safety Analysis Report (STP FSAR), paragraphs 3.8.1.6.3 and 3.8.3.6.3.
These paragraphs are the subject of a proposed amendment to the FSAR commitment. This amendment will be addressed by the NRC licensing review group.
Since the QC inspectors have been empowered to stop work when non-conforming cocditions arise and since the requested deviation from the FSAR is now a subject of NRC licensing, the subject of the item of noncompliance is resolved.
This item is closed.
(Closed) Infraction (50-498/79-15-A; 50-499/79-15-A):
Failure to Follow Concrete Consolidation Procedure. During Concrete Placement
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No. CS2-W7, the Resident Reactor Inspector observed one of seven vibrator personnel not vibrating the concrete properly, in that, the vibrator did not penetrate completely through the upper layer and at least six inches into the next lower plastic layer. The area of concern was revibrated at the direction of the QC inspector.
In response to this infraction, B&R requires all vibrator operators to be retrained every ninety days. This training incorporates the require-ments contained in Procedure No. A040KPCCP-25 and American Concrete Institute recommendations.
Quarterly retraining to concrete consolida-tion procedures addresses the item of noncompliance.
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This item is closed.
(Closed) Deficiency (50-498/79-20-A; 50-499/79-20-A): Failure to Maintain an Unrestricted Vertical Drop of Concrete.
Paragraph 8.6.7.9 of Quality / Concrete Construction Procedure No. A040KPCCP-25 has been issued to require that tremies be used to control vertical drop when-ever segregation is possible.
As of September 12, 1980, 9,564 man-hours have been spent in retraining all personnel in the new procedure (see Inspection Report No. 50-498/80-19; 50-499/80-19). This training involved video tapes, class lectures, and on the job training.
The possibility of concrete segregation due to interrupted free fall was specifically addressed.
QC inspectors have been instructed to ensure an arrangement of concreting equipment which will result in a quality concrete placement. Since the observed placement revealed no signs of segregation and since the QC inspectors are now retrained to avoid recurrence, the deficiency is resolved.
This item is closed.
(Closed) Infraction (50-498/80-01-A; 50-499/80-01-A): Failure to Follow Test Procedure.
On February 7,1980, the Resident Reactor Inspector determined that approximately 60 psi of water pressure was accidently applied to a void area behind the Unit 2 Reactor Containment Building liner plate. This application of pressure was inadvertently applied during initiation of Procedure No. 2C801CQ002-C," Shell Lift 15 Investigation and Repair Criteria, RCB-1."
The resulting damage con-sisted of a 10x14 foot section of liner plate bulged approximately 4-5 inches toward the center of the containment.
The overpressuriza-tion can be attributed to the fact that the pressue monitoring gauge was located approximately twenty feet above the injection point on the liner. The procedure has been modified to require that the pressure gauge be within ten feet in elevation of the injection point.
In addition, a pressure gauge and shut-off valve are now required at the point of injection.
Direct communication between the pump and the control skid will now assure adequate control of injection pressure.
Implemen-tation of the procedural modifications will adequately address the subject noncompliance.
This item is closed.
(Closed) Infraction (50-498/79-19-34; 50-499/79-19-34): Failure to Control Welding as a Special Process. The IE inspector reviewed B&R Welding Procedures MECP-2 (Rev. 8), MECP-4 (Rev. 10) and MECP-12 (Rev. 1) and verified that each had been revised to include require-ments for maintaining cleanliness during the welding process.
It is stated in all three procedures that the weld area shall be kept clean of dirt, grease, dust and other potentially_ deleterious contaminants.
Also included are environmental controls to provide protection against-rain, snow, wind and airborne particles.
A training session for all welders and welding supervisors instructing them in these procedural changes was conducted on February 15, 1980. All welders will be
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reinstructed prior to the resumption of safety-related welding.
Welding technicians will monitor future activities and report any infractions to the chief welding engineer or Quality Control.
This item is closed.
(Closed) Infraction (50-498/79-19-39c; 50-499/79-19-39c):
Failure to Control Liquid Penetrant Examinations.
It has been determined by B&R that this was an isolated case wherein a liquid penetrant inspector did not properly follow procedures. As a result of this, all NDE personnel have been retrained in the requirements of the inspection procedures with emphasis placed on the importance of adhering to these requirements.
This training was followed by a re-examination and recertification of all liquid penetrant inspection personnel.
Inspection Procedure ST-NDEP 4.1 has also been revised (Revision 9) incorporating a notation that during all reinspections performed, acceptable indications and nonrelevant indica-tions will be included on the inspection report form PD-1505 in the space marked " sketch and remarks."
This item is closed.
(Closed) Infraction (50-498/79-19-41; 50-499/79-19-41):
Failure to Follow Procedures in that a Procedure was Used After an Expiration Date.
The document in question was not a procedure but an interim change written to provide immediate guidance pending the issuance of a pro-cedure revision. Revision 9 of ST-NDEP 4.1 was approved and issued
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STP QAP 6.1 (Revision ~0) and GCP-1 were both revised on July 15, 1980, and interim changes have been eliminated by their exclusion from these documents.
All interim changes'have been recalled and future changes will now be made via procedure revisions or other approved methods.
This item is closed.
(Closed) Infraction (50-498/79-19-38; 50-499/79-19-38):
Failure to Control Design Changes in Root Openings and Weld Dimensions. On Janua ry 16, 1980, a letter was issued by Welding Engineering altering root openings and weld dimensions of welds on ASME, Section NF hangers.
These changes were not " essential variables" and the Procedure Qualifica-tion Record (PQR) was not revised. This is in-accordance with the ASME Boiler and Pressure Vessel Code, 1974 edition with Addenda through Winter 1975.
The letter did not have an expiration date for the changes nor did it list specific welds effected by these changes.
As a result of this infraction, MCEP-3'and MCEP-4 have been revised to require all-changes to be made by procedure revision with the approval-of Welding.
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Engineering and Quality Assurance.
This item is closed.
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(Closed) Infraction (50-498/79-19-32; 499/79-19-32):
Failure to Follow ASME B&PV Code Per 10 CFR 50.55a for Radiography Qualification Technique.
Radiography of welds utilizing a film-side penetrameter is allowed by the ASME B&PV Code only in cases where the part configuration prevents hand-placing of the penetrameter on the source-side.
It has been common practice to radiograph welders' test pipe assemblies using the film-side technique even though no such configuration restriction exits.
All radiographers have been retrained in the proper placement of penetrameters and in the limited uses of the film-side technique.
In accordance with restart commitments, all ASME welds made to date will be reinspected as part of the program to assure that quality welds have been produced regardless of errors in the qualification method. All future welder test coupons subjected to radiographic examination will be shot using a source-side penetrameter when possible.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-57; 50-499/79-19-57): NRC Told of Voids in Concrete with no Definite Close Out or Resolution. The subject unresolved item resulted from Allegation No. 17A of Inspection Report No. 50-498/79-19; 50-499/79-19.
During investigation No. 50-498/
80-26; 50-499/80-26, the IE inspector, accompanied by the IE investigator, interviewed the individual initiating Allegation No. 17A.
During the interview process, the IE inspector asked the individual if his concerns addressed to the investigative staff of Report No. 50-498/79-19; 50/499/
79-19 had been adequately addressed in subsequently issued or reviewed NRC Inspection Reports. The individual was shown the section of Report No. 50-498/79-19; 50-499/79-19 which documented his concerns. The individual stated that, subsequent to his allegation, he became aware of the NRC inspection results addressing the concrete void problem.
The individual stated that his concerns were resolved.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-12; 50-499/79-19-12):
Concrete Transit Trucks Standing or in Transit Without Agitation.
During investi-gation No. 50-498 79-19; 50-499/79-19, the IE inspectors observed loaded concrete trucks in transit and standing by at the pump with the agitating drum idle. The concrete at the South Texas Project is batched in a central plant and then transported via transit mixer not more than one-half mile to point of placement.
Since the concrete is subject to visual examination at the point of truck discharge and since the distance traveled in transit is over smooth roads and for a short distance, the transit trucks are not required by specification or by any industry standard to serve as concrete batch mixing apparatus when a central plant is used.
Only when water is added at the pumping station does the transit mixer become a concrete batch mixer.
Pittsburg Testing Laboratory form BP-1, Revision 4, " Concrete Test Load Ticket," is used j
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to document the amount of water added and the revolutions added.
A minimum number of revolutions are required after water tempering of the original batch mix.
Since the observed conditions involved transit trucks which had not been tempered with water, no violation of applicable criteria occurred.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-13; 50-499/79-19-13): Final Inspections on Completed Placements not Adequately Controlled and Up-to-Date.
This item involved the failure to provide a means to readily identify whether inspection of concrete surfaces for defects had been performed in accordance with Procedure No. CCP-8.
During this inspec-tion, the IE inspector reviewed the recently issued " Civil QC Inspection Repair Card Log" which is now used as a tracking mechanism to determine the final inspection status of each concrete placement.
The log is also used to track the status of repairs to concrete surfaces utilizing Inspection Repair Cards.
This tracking system serves to resolve the item.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-19; 50-499/79-19-19):
Compaction of Upper Part of Last Lift. This item was addressed in Inspection Report No. 50-498/80-17; 50-499/80-17 as a part of infraction No. 50-498/
79-19-21; 50-499/79-19-21. The licensee response to the NRC Show Cause Crder, Section (2)(d) addresses the performance of the top layer of backfill immediately below mat foundations during postulated earthquake loading conditions.
Dr. H. Bolton Seed, a member of the South Texas Project Independent Review Committee, analytically determined the factor cf safety against liquefaction for a four inch layer of backfill at forty-five perc ut of relative density and a layer four to-ten inches deep at a relative density of sixty percent.
The minimum factor of safety against liquefaction was determined. to be 1.85.
The fact thet the top layer of backfill placement is subject to additional roller passes according to the construction procedure indicates that the relative density of the top lift is higher than that assumed in the analysis.
This' fact is also based on the statistical results which show mean relative densities of the layer from four to ten inches deep for Units 1 and 2 of ninety-eight and ninety-four percent, respectively.
In addition, the top four inches of backfill is subject to the cementatious effect of the mortar in the six inch mud slab which is applied directly on the upper backfill lift.
The high confining stress resulting from the building load will also serve against the buildup of excessive pore pressures. These factors resolve this item.
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This item is closed.
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(Closed) Unresolved Item (50-498/79-19-20; 50-499/19-20):
Excessive Number of Roller Passes.
The NRC observations of excessive overlap were based on the test fill program attempted in February.
This test was performed without a procedure addressing maximum permissible roller overlap.
Revisions to Construction Procedure No. CCP-2 in August 1980 specify maximum roller overlap criteria.
The test fill program was subsequently performed in adherence to the requirements during the period of June through July 1980.
Observations by IE inspectors, during the July test fill development, confirmed the proper use of the compaction equipment.
This retesting resolves the matter.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-26; 50-499/79-19-26): Discrepancies in Minimum and Maxinum Densities of Backfill Used Versus Those Reported in the SAR for Liquefaction Analysis. The licensee response to the NRC Show Cause Order, Section (2)(b) addresses the compliance of the backfill material placed with the design basis material characteristics described in Sectiou 2.5.4.8.3 of the STP FSAR.
The backfill material placed originates from the same geologic formation and has the same gradation and particle shape characteristics as the material used in the determination of the cyclic loading characteristics. The backfill material listed in the STP FSAR had a minimum dry density of 93.5 pounds per cubic foot (pcf) and a maximum dry density of 128.1 pcf.
The values observed during NRC Investigation No. 50-499/79-19; 50-499/
79-19 were 105.3 pcf for minimum dry density and 123.6 pcf for maximum dry density. Computation of 80% re:stive density for both sets of minimum and maximum. dry density values results in values of 119.27 pcf and 119.45 pcf, respectively. This shows that the dry density weights at 80% relative density are approximately identical.
This value is the j
weight to which dynamic test specimens were compacted in the design phase
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liquefaction analysis.
For the dry density weight at 80% relative density used, the liquefaction analysis showed factor of safety greater than l
2.5 against initial liquefaction, and greater than 3.5 for liquefaction j
at + 10% strain.
The variation, in minimum and maximum dry densities noted in NRC investigation No. 50-498/79-19; 50-499/79-19, can be attributed
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to subtle changes in the gradation and coefficient of uniformity which l
have occurred over the four years of structural backfill placement.
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Since this change has been shown to not significantly affect the material's l
engineering properties with respect to liquefaction, the liquefaction i
analysis performed for the design and presented in the FSAR is considered l
valid and applicable to the backfill material placed.
I This item is closed.
(Closed) Unresolved Item (50-498/79-19-29; 50-499/79-19-29): Attempt to Correlate Standard Penetration Values to Those From Oversized Blunt Spoon and Nonconforming Hammer. During NRC inspection No. 50-498/80-17; 50-499/80-17, infractions No. 50-498/79-19-27; 50-499/79-19-27 and 50-498/79-19-28; 50-499/79-19-28 were addressed by the IE inspector.
These infractions involved, respectively, the apparent use of a hammer
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weight and a split barrel spoon not in strict compliance with ASTM D-1586, " Penetration Test and Split-Barrel Sampling of Soils." Both infractions have been closed out (also see Inspection Report No. 50-498/
80-19; 50-499/80-19).
The hammer weight in question was found to be two pounds heavier than the ASTM specified weight of 140 pounds.
This weight was considered a minor variation which would result in a conserva-tive test result, if in fact, any effect were noticed.
The dimensional difference between the Terzaghi spoon used and the spoon specified by ASTM D-1586 was determined as having no effect on the penetration test results. The calculations supporting the determination are the subject of this unresolved item (50-498/79-19-29; 50-499/79-19-29) and were made available to the IE inspector during this inspection.
The mathematical analysis of the force required to drive'the different spoon configurations was reviewed.
The results of the analysis show that the small difference in spoon configuration is not a significant factor in the blow count determinations of the borings made in the STP structural backfill.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-30; 50-499/79-19-30):
Boring 204, Loose Material Near Base of Unit 2 Foundation Mat.
Woodward-Clyde Consultants have completed a comprehensive study of the density of back-fill in Units 1 and 2.
The IE inspector reviewed the report submitted to Brown & Root by Woodward-Clyde.
The area of Boring 204 was extensively addressed. Twenty additional borings were taken in the adjacent area.
The report submitted to Brown & Root will subsequently be reissued by Houston Lighting & Power Company in response to Section VA (2)(d) of the Show Cause Order.
This response will provide information to address the adequacy of all existing backfill material.
The subject of Boring 204 will be specifically addressed in the response.
This item is closed.
(Closed) Unresolved Item (50-498/80-04; 50-499/80-04):
Inco rporation j
of Punch List Activity into a Procedure.
During this inspection, the
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IE inspector reviewed Brown & Root Quality Construction Procedure No.
A040KCCP-25, Revison 0, Section 8.4, " Concrete Pour Card Sequence."
This section requires a " Construction Pre-Pour Inprocess Inspection Checklist," (CPPIIC) to be issued and attached to the Concrete Pour Card.
In addition, the procedure requires that the final signature l
on the Concrete Pour Card be that of the Brown & Root Civil Quality l
Control Superintendent. This signature will provide evidence that all items identified on the CPPIIC have been satisfactorily completed, reinspected if required, and verified by signature of the QC inspector.
This section of the procedure serves to resolve the item.
This item is closed.
(Closed) Unresolved Item (50-498/80-17; 50-499/80-17):
Procedure for Sampling Top Layer of Backfill. The IE inspector reviewed the change i
to the structural backfill specification effected by Document Change
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No. 3YO69YS029-F/DCN/7-23-80.
This change provides criteria for testing of backfill top lifts immediately below foundations.
Pittsburg Testing Laboratory (PTL) Field Change Request and Approval No. PT-FCR-049 was also reviewed.
This revision to the PTL procedure for backfill testing incorporates the B&R specification criteria.
These criteria are based on detailed studies performed by the Independent Review Committee
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and conservatively satisfy the unresolved item.
See closure of Unresolved Item 50-498/79-19-19; 50-499/79-19-19 in this report for details of the analysis performed by the committee.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-31; 50-499/79-19-31):
Details of Welder Qualification Procedures - Work Stoppage; Root Gap and Backing Ring in Question.
The details of the welder qualification procedure involved the moving of a test pipe during the process of welding the joint.
The pipe was in the 2-G position which required the axis of the pipe to be vertical and the weld deposited circumferentially in the horizontal direction. The configuration and arrangement of the welding booths allowed reasonable access only to 180 of the circumferential weld.
The welder was depositing one-half of the weld metal, rotating the test assembly one-half turn and completing the weld pass.
AShE B&PV Code,Section IX specifically states that the test assembly shall not be rotated during welding.
By one interpretation of the events, this could be called a violation as the pipe was rotated after the welding process had begun.
Another interpretation is that no weld metal was being deposited at the time the pipe was moved and this did not constitute rotation during welding.
The welding test booths and coupon fixtures have since been modified to allow the welder 360 access to weld the test coupon and prevent any rotation once the pieces have been positioned.
Welders have also been instructed that movement of the test plates or test pipes will immediately disqualify that test assembly.
The qualification test observed by the IE inspector was invalidated and discarded.
Because of the Show Cause Order, all welders will be required to requalify for the various techniques and positions to be used.
In the past, test assemblies have been tack welded together to assure that root gaps were uniform and within prescribed tolerences.
An assembly jig has now been constructed and will be used for the fit-up and pre-weld tacking of all test assemblies to assure correctness and uniformity in all test root gaps.
All future test assemblies, whether being evaluated by radiography or bend testing, will have the backing strips removed prior to being taken from the welder qualification test area. This will assure that no test assembly will be radiographed with the backing strip in place.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-40; 50-499/79-19-40): Test Reports of Liquid Penetrant Examinations not Adequate.
No serialization
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of inspection reports is required, provided that the item being examined is fully identified and the report is traceable to that item, as is the case at South Texas.
Procedue ST-NDEP-4.1 has been rewritten as Revision No. 9 and provisions have been included in paragraph 4.4.(e) to record all results of the inspection including relevant and nonrelevant indica-tions, surface conditioning, re-examinations, temperature of material, etc.
This and other procedural changes nave been emphasized during the requali-fication training required for inspector recertification and will continue to be emphasized in all future training.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-42; 50-499/79-19-42):
No Training for QC Personnel in Liquid Penetrant by Fluorescent Materials; Processing and Reading of Radiographs; Visual AWS; Record Keeping.
The items listed were all included in various training courses but were not shown in the training records as separate items.
In training sessions for each inspection method, the record keeping system is presented as an integral part of the inspection.
Inspection Procedure ST-NDEP-3.1 has been rewritten and Revision No. 9 includes inspection requirements and acceptance standards applicable to AWS D1.1.
This has always been included in the visual exam-ination training but not recorded as separate training.
The processing and reading of radiographs have been presented in training but not thoroughly as this is normally an area attended to by a limited number of specialized inspectors. These items have been included in the recently rewritten radiographic procedure ST-NDEP-2.1, Revision No. 11 and will be stressed more in future training.
Fluorescent penetrant instruction has been included in past training only for familiarization as this method has never been used at South Texas.
Procedure ST-NDEP-4.1, Revision No. 9 has been issued and all mention of fluorescent penetrant has been deleted.
No training is needed if the method is not used.
This item is closed.
3.
Nine Point Corrective Action Program The IE inspector reviewed the status of proposed measures to provide implementation of a nine point corrective action program as outlined in HL&P letter No. ST-HL-AE-401, December 28, 1979.
a.
Action Item No. 4 Qualifications of Brown and Root QA and QC Personnel.
This action item was previously addressed during inspection No. 50-498/
80-04; 50-499/80-04. At that time, the action item was found to have been implemented and the IE inspectors had no further questions.
The action item is also addressed during this inspection as part of infraction No. 50-498/79-19-16; 50-499/79-19-16.
The infraction was closed during this inspection.
This item is closed.
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b.
Action Item No. 5 Procedure Implementation in Regard to Concrete Preplanning and Place-ment Activities.
This action item was previously addressed during inspection No. 50-498/
g 80-04; 50-499/80-04. The item remained open pending revisions to the concrete procedure to include a requirement for check for completion and sign-off of the " punch list" by the QC inspector and to make the " punch list" a part of the Pour Card package. This issue was closed during this inspection by inspection of these pro-cedural requirements.
This item is closed.
c.
Action Item No. 6 Provision of Method of Judging When Reinspection of a Concrete Placement is Necessary.
This action item was previously addressed during inspection No. 50-498/
80-04; 50-499/80-04.
Brown & Root Quality Concrete Construction Procedure No. A040KPCCP-25 now includes a controlled method for judging when reinspection of a concrete placement is necessary prior to sign-off of the Pour Card.
This item is closed.
4.
Thirteen Point Response The IE inspectors reviewed the status of responses, provided by HL&P in letter No. ST-HL-AE-417, February 7,1980, to the matters identified in the NRC exit interview conducted on site on January 24, 1980.
a.
Response No. 1 Failure to Take Corrective Action - Concrete Placement.
The corrective actions taken by the licensee in response to the subsequently issued infraction No. 50-498/79-19-10; 50-499/79-19-10,
" Failure to Take Corrective Action on Improper Vibrator and Concrete Placement Practices," resolve the issues originally generated.
These actions have resulted in closure of the infraction.
This item is closed.
b.
Response No.-3 Failure to Take Corrective Action - Cadwelding The corrective actions taken by the' licensee in response to the subsequently issued infraction No. 50-498/79-19-03; 50-499/79-19-03,
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&
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" Failure to Take Corrective Action When Cadwelders Needed Requalifi-cation," serve to address the issue originally generated.
These actions have resulted in closure of the infraction.
This item is closed.
c.
Response No. 4 Failure to Follow Procedures - Inspector Qualifications The corrective actions taken by the licensee in response to the subsequently issued infraction No. 50-498/79-19-16; 50-499/79-19-16,
" Failure to Follow Procedures With Regard to Qualification of Civil and Concrete QC inspectors," serve to address the issues originally generated. These actions have resulted in closure of the infraction.
This item is closed.
d.
Response No. 5 Inadequate Concrete Inspection The corrective actions taken to date by the licensee in response to the subsequently issued infraction No. 50-498/79-19-11; 50-499/
79-19-11, " Failure to Inspect Reinforcing Steel for Loose Rebar Prior to Concrete Placement," resolve the concern that inadequate preplacement inspections were the cause of the NRC inspectors'
identification of unwired shear ties after QC signoff. The infrac-
,
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tion remains open pending an engineering analysis of the subject placement.
Corrective actions to preclude recurrence have been initiated and therefore resolve the issue.
This item is closed; however, as noted in paragraph 2 above, this subject remains open.
e.
Response No. 6 Failure to Identify a Nonconforming Condition The corrective actions taken by the licensee in respouse to the subsequently issued infraction No. 50-498/79-19-21; 59-499/79-19-21,
" Failure to Take Prompt Corrective Action When Test Apparatus Failed,"
resolve the issue.
The fact that maximum-minimum density tests for backfill were not conducted for approximately two months while the testing machine was broken, does not diminish the validity of the subsequently performed tests on the samples secured during the two month breakdown.
The infraction has been closed.
This item is closed.
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f.
Response No. 7 Inadequate Procedure for Backfill Tests The corrective actions taken by the licensee in response to the j
subsequently issued infraction No. 50-498/79-19-21; 50-499/79-19-21, j
" Failure to Establish Procedures for Systematic Sampling as Part l
of Soil Testing Program," serve to resolve the issues originally l
generated. These actions have resulted in closure of the infrac-tion.
This item is closed.
I g.
Response No. 8.b i
l l
Failure to Control Special Processes - Liquid Penetrant l
This item, dealing with the evaluation and disposition of liquid
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penetrant examination results, was closed out as infraction No. 50-498/
79-19-39c; 50-499/79-19-39c.
This item is closed.
h.
Response No. 9 Inadequate Protection from Adverse Environmental Conditions --Welding This item, dealing with cleanliness and environmental protection during the welding process, was closed out as infraction No. 50-498/
79-19-34; 50-499/79-19-34.
This item is closed.
i.
Response No. 10 t
l Failure to Meet Requirements of 10 CFR 50.55a(3)
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l This item, dealing with placement of penetrameters on welders'
l qualification test assemblies, was closed out as infraction No. 50-498/
l 79-19-32; 50-499/79-19-32.
This item is closed.
5.
Licensee Response to Show Cause Order The IE inspector reviewed the licensee's response to the Show Cause Order transmitted to HL&P by NRC letter dated April 30, 1980. The following items were addressed:
(Closed) Show Cause Order, Item V.A.(2)(a):
Provide Information to Address the Test Fill Program Which Established the Soil Conditions,
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,
Lift Thickness, Compactive Effort, and Equipment Characteristics Necessary to Develop the Necessary In-Place Densities.
A test fill program was performed by the licensee for the purpose of providing new data to support the field placement criteria previously established.
This test fill program was addressed during NRC inspection No. 50-498/80-12; 50-499/80-12. During this in pection, the IE inspector reviewed the procedure used to perform the test fill program, Technical Reference Document No. 3A700GP002-A, " Test Program for Compaction of Category I Structural Backfill," and the results of the program as documented in the licensee's response.
In addition, Memorandum No. BC-00998-JDG, dated June 16, 1976, documenting the test fill originally used to establish the construction methods and equipment to be used in the placement of Category I structural backfill, was reviewed. This memorandum shows that the density of the lower 18" lift is increased significantly by compaction of the lift above it.
The results of this test fill were used to establish the minimum number of passes required before testing was initiated in the lower lift. This criteria was established as an economic consideration to limit commencement of the in place density tests until it was felt that specification density had been achieved. The criteria chosen was a minimum of 8 passes on an 18" lift before testing commenced.
If density was not reached, additional passes were then added. The adequacy of this construction procedure was verified by the most recent test fill program.
The Expert Committee of Independent Engineers (Dr. H.
Bolton Seed, Professor of Civil Engineerng, University of California; Dr. A. J. Hendron, Jr., Professor of Civil Engineering, University of Illinois; Stanley D. Wilson, P.E., Consulting Engineer) have reviewed the test fill program results and have documented their findings in the " Interim Report to Brown & Root on Adequacy of Category I Structural Backfill." This report is attached, as Exhibit 9, to the licensee's show cause response. The independent committee has concluded that testing of the upper portion of the underlying lift produces conservative results when a minimum of 8 passes is used. The construction procedures used were also judged by the independent committee, " correct to determine the point of starting in-place density testing." Based on the reviews
,
performed during this inspection, the licensee has satisfied the Show
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l Cause Order to provide information to address the test fill program L
used to establish in place density testing criteria.
This item is closed.
I (Closed) Show Cause Order, Item V.A.(2)(b):
Provide Information to Address the Comparison of Materials Tested and Described in Section 2.5.4.8.3 of the FSAR Addressing Liquefaction With Those Used in the Field. The licensee's response was reviewed and found-to resolve the apparent discrepancy in densities of material used in the design with those placed.
The apparent discrepancy was caused by a failure to compute the 80 percent relative density values for purposes of I
comparison.
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Computation of this value, which was used in the liquefaction analysis results in a 0.18 pound difference between the design 80 percent relative dry density and the field 80 percent relative dry density. This issue is further addressed in this report in the closure of Unresolved Item No. 50-498/79-19-26; 50-499/79-19-26.
Based on the IE inspector's review, the liquefaction analysis performed for the design and presented in the FSAR is considered valid and applicable to the backfill material pisced.
This item is closed.
(Closed) Show Cause Order, Item V.A.(2)(e):
Provide Information to Address the Rationale Behind the Use of 18 Inch Loose Lifts Compacted by 8 Passes of the Equipment to Achieve the Required Densities. During this inspection, the IE inspector reviewed the licensee's response to this show cause item. The 8 passes referred to is the minimum required compactive effort prior to in place density testing. The use of this number is based on the test fill program conducted in May 1976 and on recommendations from the vibratory roller manufacturer.
This construction criteria has been verified by the test fill program conducted in June 1980. See the closure of Show Cause Order Item V. A.(2)-
(a) for more detail.
Based on the review performed by the IE inspector during this inspection, the item is considered resolved.
This item is closed.
6.
Exit Meetings Exit meetings with licensee and contractor personnel identified in paragraph I were held on September 5 and 19, 1980.
Findings of the inspection were discussed by the inspectors.
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