IR 05000498/1980030
| ML19340E459 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/02/1980 |
| From: | Crossman W, Gilbert L, Randy Hall, Hubacek W, Tapia J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19340E452 | List: |
| References | |
| 50-498-80-30, 50-499-80-30, NUDOCS 8101140556 | |
| Download: ML19340E459 (8) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION h'
0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No.
50-498/80-30; 50-499/80-30 Docket No. 50-498; 50-499 Category A2 Licensee:
Houston Lighting and Power Company
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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: October 21-24 and 27-31, 1980 Inspectors: Mv',.M/%ds
/5/.2/iO W. G. Hubacek, Reactor Inspector, Projects Section Date (Paragraphs 1, 3 & 6)
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h J. I.7apia, Reactor Inspector, Engineering Support Ohte Section (Paragraph 2)
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di L. D.Tailbert, Reactor Inspector, Engineering Support Odtd
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Section (Paragraphs 4 & 5)
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l Other Accompanying Personnel:
W. A. Crossman, Chief, Projects Section W. B. Jones, Engineering Aide (Co-op)
Approved:
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/D W. A. Crossman, Chief, Projects Section Date
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1 R. E. Hall, Chief, Engineering Support Section Dats 810114 0 h
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Inspection Summary:
Insoection on October 21-24, and 27-31, 1980 (Report No. 50-498/80-30; 50-499/80-30)
Areas Insoected:
Routine, announced inspection of construction activities including items of noncompliance, unresolved items, and Show Cause Order items.
The inspection involved one hundred and fourteen inspector-hours by three NRC inspectors.
Results:
No violations or deviations were identified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- R. A. Frazar, Manager, Quality Assurance
- L. D. Wilson, Project QA Supervisor
- L. K. English, Site Manager
- I.
P. Morrcw, Construction Superintendent
- R. A. Carvel, Project QA Supervisor
- R.
Deutschman, QA Systems Other Personnel D. Muscente, Welding Project Manager, Brown & Root (B&R)
- R. Hand, Project QA General Supervisor, Management Analysis Company (MAC)
F. Miller, Project Welding Engineer, B&R L. Weigel, Level III Inspector, U. S. Testing The IE inspectors also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs.
- Denotes those attending the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Infraction (50-498/79-19-18; 50-50-499/79-19-18):
Failure to Complete Backfill Compaction In Accordance With a Qualified Procedure.
Brown & Root Technical Reference Document (TRD) No. 3A700GP002, Revision B, " Test Program for Compaction of Category I Structural Backfill," dated September 29, 1980, was reviewed during this inspection.
This TRD revision documents the completed test fill program and includes a synopsis of pre-vious test fills and of the unrestricted lift qualification program.
The latter program was required by the backfill specification to demon-strate, in the first twenty in place density tests, that satisfactory densities could be achieved prior to proceeding with full scale backfill placement in Category I areas.
The specification requirement was used as the basis for documenting the adequacy of the construction procedure.
The complete TRD report has also been reviewed by the Independent Review Committee and the conclusions have been incorporated in the licensee's response to the Show Cause Order.
The response to Show Cause Order Items V.A.(2)(a) and V.A.(2)(e) were reviewed during Inspection No.
50-498/80-24; 50-499/80-24, and specifically address the test fill program which established the in place density testing criteria and the use of 18 inch loose lifts.
Based on the review of these Show Cause Order responses and of the TRD, this item of noncompliance is closed.
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(Closed) Infraction (50-198/79-19-11; 50-499/79-19-11):
Failure To Inspect Reinforcing Steel For Loose Rebar Prior To Concrete Placement.
The licensee's response to this item of noncompliance was previously reviewed during Inspection No. 50-498/80-24; 50-499/80-24.
The item remained open pending the review of the finalized engineering analysis formulated during the.t inspection.
The analysis was reviewed during this inspection.
It showed that the ties were not capable of moving beyond the 12 inch spacing because of horizontal reinforcing steel and that the maximum allowable spacing of ties, according to the ACI Code, was 24 inches as compared to 12 inches provided.
This analysis there-fore indicates that, for the a;tual shear load requirement, twice as many ties are provided as are necessary.
The analysis shows that the integrity and strength of the Diesel Generator Building flat has not been degraded by the lack of shear tie wiring.
Based on the review performed by the IE inspector during this inspection, the item is considered closed.
(Closed) Unresolved Item (50-498/79-19-09; 50-499/79-19-09):
Need For Additional Controls In Procedures Addressing Prepour, Construction, and Curing of Concrete.
During this inspection, the IE inspector reviewed those sections of Brown & Root Procedure No. A040KPCCP-25, which provide clarifying and quantifying acceptance criteria in response to the observations made by the NRC during Investigation No. 50-498/79-19; 50-499/79-19.
This review is a continuation of the reviews performed during Inspections No. 50-498/80-19; 50-499/80-19 and 50-498/80-24; 50-499/80-24 of Infraction No. 50-498/79-19-10; 50-499/79-19-10,
" Ineffective Corrective Action to Resolve Previously Identified Concrete Placement Deficiencies." The closure of the infraction and the review performed during this inspection, incorporate and resolve the issues originally generated in this unresolved item.
This item is closed.
(Cic3ed) Unresolved Item (50-498/79-19-15; 50-499/79-19-15):
Apparent Conflict of Personnel Qualification Requirements for Concrete Inspectors.
The subject unresolved item identified a commitment to NRC Regulatory Guide 1.58.
NRC Regulatory Guide 1.58 endorses, with amplification, the requirements of American National Standards Institute Standard N45.2.6 and American Society of Non-Destructive Testing Recommended Practice SNT-TC-1A, for the training and certification of inspection personnel.
The commitment was identified in the STP PSAR, Appendix A, Question 411.70 response.
Further review of PSAR commitments, during this inspection, disclosed that concrete quality control personnel were specifically required to conform to the requirements of ASME III, Div. 2/AC1-359-draft, issued for trial use and comment in 1973, including subsequent addenda 1 through 6.
This commitment is contained in the following STP PSAR Sections:
3.8.1.6.1.5; 3.8.3.6.1.5; 3.8.4.2.3; and 3.8.4.6.
The apparent conflict of personnel qualification requirements for concrete inspectors stems from a failure to review those PSAR sections specifically concerned with concrete.
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Notwithstanding the experience requirements of the two standards,
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for personnel certified to the requirements of ANSI N45.2.6., training and examination may be used as an alternative to the specified education and experience requirements.
This in essence means that, since train-ing and examination are required by ASME III, Div. 2, the certifications of concrete inspection personnel provide less latitude as compared to the certifications of personnel performing inspections in accordance with ANSI N45.2.6.
The apparent conflict is therefore resolved.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-58; 50-499/79-19-58):
Basis for Specification Requirement for Backfill Lift Thickness of 18 Inches.
The subject of this unresolved item is an integral part of Infraction No.
50-498/79-19-18; 50-499/79-19-18, " Failure to Complete Backfill Compaction In Accordance With A Qualified Procedure." The actions taken by the licensee in response to the infraction serve to address the issue originally generated.
These actions have resulted in closure of the infraction and therefore resolve this item.
This item is closed.
3.
Licensee Action On Show Cause Order Items (0 pen) Show Cause Order Item 7, "The licensee shall develop and implement a more effective system to provide for the control of field changes in order to assess the impact of the design changes on the design."
Brown and Root has issued revised procedures which describe the new STP field design change program the licensee committed to develop and implement in their July 28, 1980, response to the NRC Show Cause Order.
The title and scope of each procedure are as follows:
Quality Construction Procedure A040KGPCP-21, " Field Change Requests /
l Temporary Change Notice," Rev. 11, September 30, 1980.
The pro-
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cedure describes site construction activities directly involved in the initiation and control of Field Change Requests (FCR).
The procedure deals with changes to or deviations from design documents
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originated and/or approved by Houston Engineering or provides documented clarification of specification or Code requirements.
Engineering Procedure STP-0C-023-L, " Engineering Procedure for
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Processing Field Change Requests," Rev. L, October 1, 1980.
The procedure establishes requirements for the evaluation, disposition, and tracking of FCRs that are received by Site Engineering from STP construction or the client.
The procedure also applies to all FCRs that are forwarded to Houston Engineering by Site Engineer-ing.
Engineering Procedure STP-DC-028-8, " Engineering Procedure For Design Change Control," Rev. B, October 1, 1980.
The procedure establishes requirements for design change control including initiation and
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documentation of design changes, their review and approval, and the distribution and computer tracking of approved d2 sign changes.
The procedure applies to changes made to the STP design (as it is defined by drawings except those revised to the next revision level), specifi-cations, System Design Descriptions, and Technical Reference Documents.
Engineering Procedure STP-0C-029-B, " Engineering Procedure For Change Review Board Activities," Rev. 8, October 1, 1980.
The procedure establishes the organizational structures, functional responsibilities, and level of authority of the Change Review Board (CRB) whose primary responsibility is to assure that safety-related design changes result-ing from site activities are properly reviewed and the impact of the changes on the design have been assessed.
The IE inspector reviewed the above procedures for compliance with commitments in the licensee's response to the Show Cause Order, however, implementation of the procedures was not reviewed during this inspection.
The IE inspector observed that Brown & Root QA Manual, Section 3.0 and QA Procedure ST-QAP-3.2 will require revision to address the field design change program described in the above procedures.
A licensee representative stated that these revisions are presently in progress.
This matter will remain open pending revision of the QA Manual and procedure ST-QAP-3.2 and comprehensive review by IE of implementation of the field design change program.
(0 pen) Show Cause Order Item 8, "The licensee shall develop and implement a more effective system of record controls."
Brown & Root has prepared new or revised procedures which describe the records control system the licensee committed to develop and implement in their July 28, 1980, response to the NRC Show Cause Order.
The title and scope of each procedure are as follows:
QA Procedure ST-QAP 17.1-1, " Records Control," Rev. 1, August 1, 1980.
The procedure describes the method by which the site QA department processes and controls records at STP including minimum requirements for transmittal, receipt, storage, mainte-nance and retrieval of project records received by or originated within the site QA department.
QA Procedure STP-QAP 10.1, " Inspection Planning and As-Built Veri-fication," Rev. O, approved October 20, 1980, but not issued for use pending completion of training for using personnel.
The pro-cedure describes the QA program requirements for inspection plann-ing and as-built verification requirements including documentation and responsibility for implementation.
QA Instruction ST-QAI-17.1.1, " Instruction for Records Control,"
August 1, 1980.
The procedure establishes methods and details necessary to receive, process and control records after they are transmitted to the QA vault.
It icentifies responsibilities
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and requirements to standardize the internal document flow, account-ability and QA Engineering review and verification. The scope includes activities for processing the current workload and backfit activities to be accomplished during the transitional phase of imple-menting the records control program.
QA Instruction ST-QAI-17.1.2, "QA Document Administration for the QA Vault," August 1,1980.
The procedure delineates administrative activities necessary to support the records control program including microfilming, computer key batching, on-line computer instructions, and the use of the action notice to identify action items for docu-mentation requiring correction or supplement.
The IE inspector reviewed the above procedures for compliance with commit-ments in the licensee's response to the Show Cause Order, however, imple-mentation of the procedures was not reviewed during this inspection.
The IE inspector observed that the procedures do not appear to address ANSI N45.2.9 requirements relative to description of record storage areas and environmental control. A licensee representative stated that these matters had been identified in an audit and were being corrected. The licensee representative also stated that the applicable Brown & Root QA Manual section was being revised to reflect changes in the records control system implementing procedures.
This item will remain open pending revision of the QA manual, incorpora-tion of ANSI N45.2.9 requirements related to description of storage areas and environmental control, and review by IE of implementation of the records control system.
4.
Immediate Action Letter (IAL) Follow Up
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The IE inspector selectively reviewed procedures and personnel qualifi-cations relative to additional production welding of the AWS safety-related structural steel referred to in the IAL dated October 22, 1980.
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The following procedures and personnel qualifications were reviewed:
Procedure Application MECP-2, Rev. 9 Field fabrication and welding of structural steel to AWS D1.1 l
WP-52.08-157, Rev. 5 Prequalified AWS procedures for
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butt welding of Group 1 materials l
using E7018
WP-52.08-230, Rev. 5 Prequalified AWS procedure for fillet wlding of Group 1 materials using.7018 r
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Welder AWS Test AUR E7018,1" Plate, 3G & 4G Positions AXX E7018,1" Plate, 3G & 4G Positions ARW E7018,1" Plate, 3G & 4G Positions In the areas reviewed, the procedures and qualification of personnel
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were consistent with AWS 01.1-1975 and the limits of the IAL.
The IE inspector also interviewed the U. S. Testing certified Level III inspector who was contracted to perform an independent inspection of the AWS Welding Restart Program. The Level III inspector had reviewed and concurred with acceptability of first 339 welds completed on cable tray supports in Room 202 of the Mechanical Electrical Auxiliary Building of Unit 1 (MEAB-1) including documentation of the work for conformance to requirements.
Based on the above, the commitments in the licensee's response to the Show Cause Order have been met.
These commitments included a review by a certified Level III inspector of the quality of welds and documentation related to the resumption of AWS structural welding on cable tray supports in Room 202 of the MEAB-1 showing con-formance with requirements.
Satisfaction of these commitments was required prior to expanding into other plant areas.
No violations or deviations were identified.
5.
ASME Welding Restart Program The IE inspector initiated a review of completed items from the list of show cause commitments applicable to the ASME Welding Restart Program; however, he was informed by the licensee that the documents applicable to the ASME Welding Restart Program were either not finalized or were still in the review cycle.
Review of the ASME Welding Restart Program will be completed during subsequent inspections.
No violations or deviations were identified.
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Exit Interview The IE inspectors met with licensee representatives (denoted in para-graph 1) on October 24 and 31, 1980.
The IE inspectors summarized the purpose and the scope of the inspection and the findings.
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