IR 05000498/1981001
| ML19347E837 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/20/1981 |
| From: | Crossman W, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19347E836 | List: |
| References | |
| 50-498-81-01, 50-498-81-1, 50-499-81-01, 50-499-81-1, NUDOCS 8105130475 | |
| Download: ML19347E837 (18) | |
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l U. S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-498/81-01; 50-499/81-01 Category A2 Docket No. 50-498; 50-499 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, Matagurda, Texas Inspection conducted: January 1981 Inspecto -
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,; H.'s. Phillips, Resicent Reactor Inspector Date Projects Section No. 3 Approved:
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W. A. Crossman, Chief, Projects Section No. 3 Dats Inscection Summary:
Insoection of January 1981 (Recort No. 50-498/81-01; 50-499/81-01)
Areas Insoectec:
Routine, announcea inspection by tne Resicent Reactor Inspector (RRI) included follow up inspections relative to noncomp iances, unresolved items, open allegations, Show Cause Order items, and storage /
maintenance of equipment; storage and handling of reactor coolant loop and safety-related piping; and holding of safety-related piping.
This inspec-tion involved seventy-five inspector-hours by one NRC inspector.
Results: Of the three major areas inspected, no violations or deviations were icentified in two areas. One violatien was identified in one area (violation - failure to follow procedures for storage and maintenance of equipment paragrachs 4 and 7).
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OETAILS 1.
Persons Contacted Principal Licensee Employees
"G. W. Oprea, Executive Vice President
- J. H. Golcberg, Vice President, Nuclear Engineering and Construction
"R. A. Frazar, Quality Assurance Manager
- L. K. English, Project Manager
- R. A. Carvel, Project QA Supervisor (Civil / Structural)
T. J. Jordan, Supervisor Quality Systems
- 0. W. Bohner, Project QA Supervisor (Electrical /I and C)
- L. D. Wilson, Project QA Supervisor (Mechanical)
O. Powell, construction Engineer G. W. Jaunaul, Construction Area Supervisor Management Analysis Company (MAC)
- R. L. Hand, General QA Supervisor for Houston Lighting & Power (HL&P)
W. J. Friedrich, QA Manager for Brown and Root (B&R)
O. J. Harris, Quality Engineering Manager for B&R
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Westinchouse
- W. C. Leslie, Westinghouse Site Manager Brown and Root Inc. (B&R)
- J. McIntyre, Assistant Project Manager
- F. W. Rothermel, PPM / System Engineer Manager J. E. Adkins, Receiving, Storage, Maintenance QC Supervisor D. Lehr, B&R Area Engineer
- F. G. Miller, Chief Welding Engineer M. Hogg, Staff Engineer V. English, Support Supervisor J. Alford, Craft General Foreman
- J. Wood, Maintenance Foreman W. Norris, Lead Millwright S. McCollough, Millwright The RRI also interviewed other licensee and Brown & Root employees during the inspection period including both craft labor and QA/QC personnel.
- Denotes those persons with whom the RRI held on-site management meetings during the inspection period.
2.
Licensee Action on Show Cause Order, Aoril 30, 1980 The RRI reviewed Show Cause Order,Section V.A., Items 1,2,3,5,6,7, 8, 9 and 10 and determined that action had been taken or was sufficiently comolete to allow the RRI to recommend the resumption of placement of safety-related complex concrete on a limited basis.
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The RRI continued the follow-up inspection relative to Show Cause Order,
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Items 1 and 6 as follows:
a.
(0 pen) Show Cause Order, Item V.A.(1): Management Consultant Review.
HL&P Management of Program to Control All Aspects of the South Texas Project; Revision of Organizational Responsibilities to Control the Design, Procurement and Construction Activities of the Licensee's Prime Contractor, Brown & Root, Inc. (B&R), and HL&P Overall Responsibility for QA/QC Program.
The RRI reviewed oojective evidence relative to commitments listed in the licensee's letter ST-HL-AE-533, dated September 18,1980, and closed the following it, ems:
Item Basis for Closing A4 HL&P Procedure PSQP-A8, Revision 1, January 5,1981, describes the evaluation of data for trends.
A5 PSQP-A9, Revision 0 issued September 26, 1980, and sign-in sheets for training were reviewed.
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A10 Upper level management has participated in all A18 phases of the project during the past months as documented in meeting minutes in Brown & Root corresponjence, dated August 1, 1980, September 4, 1980, October 29, 1980, and November 12, 1980.
i A13 The following courses have been conducted for the QA/QC Management Team, which also included the participation of Construction and Engineering Management:
Subject Date Management Seminar, PEJS-710-BT September 19-20, 1980 Oasis Mctor Inn, Bay City, Texas
j Philip Crosby Associates, Inc.
September 15, 1980
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Quality College September 22, 1980 Winter Park, Florida October 6, 1980 October 27, 1980 Novemcer 10, 1980
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Quality Improvement Program September 22-23, 1980
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South Texas Project Site A126 Data Analysis Summary, performed by Brown & Root Inc.,
was documented in correspondence SQA-4327, dated November 25, 1980.
This analysis was an eva'.uation of nonconformance for trends in order for such non-conformances and root causes to be corrected.
Such periodic reviews will continue during the life of the project.
H1 The documents reviewed and listed in A10 above showed a distributica to all key managers. A monthly QA Report, documented in correspondence ST-HS-HL-01383, dated October 9,1980, from HL&P Site QA Management to top HL&P Management.
H4 Review of B&R minutes of monthly Project QA Meeting, M5 dated August 1, 1980, September 24, 1980, and November 12, 1980, showed reports being forwarded to the operating committee and board.
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H11 Review of graphical presentation attached to HL&P letter (ST-HL-AE-568), dated October 31, 1980.
This graph shows staffing from 1980 - 1986.
M6 The HL&P letter (ST-HL-AE-533), dated September 18, 1980, Item No. M6 named the committee and showed the commitment to be complete.
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(0 pen) Show Cause Order, Item V.A.(6): The Licensee Shall Develop a Her* Effective System to Provide for the Identification and Correction of the Root Causes of the Nonconformances Which Occur.
The RRI reviewed commitments listed in the previously referenced letter (ST-HL-AE-533) and closed the following items:
A126 &
Reference the basis for closing Item A125 previously A127 listed in their report for Show Cause Order Item V.A.(1).
A151 HL&P letter ST-HS-00603, dated October 14, 1980, and B&R letter SQA-4327, dated November 25, 1980 transmitted trend analysis reports to HL&P Quality System and Audit groups.
H29 B&R letters, minutes of QA meetings, dated August 1, 1980, August 12, 1980, September 4, 1980, November 12, 1980, gave the status of nonconformances. audit deficiencies, and corrective action reports.
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Licensee Action on Previous Inspection Findings
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(Closed) Open Allegation (50-498/79-19-04):
Vertical Cracks in Structural Steel Clips in the Boron Injection Room of RCB, Unit 1 Elevation 36'.
HL&P had investigated this item by locating the area described above and inspecting the clips.
Inspection revealed that the clips had defects and the condition has been identified in B','own and Root Nonconformance Report No. S C 4522, dated August 13, 1980.
The RRI reviewed this report to assure that the nonconformance was identified and controlled in accordance with the B&R QA program.
The defect will be repaired in accordance with routine repair procedures.
The allegation was substantiated.
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The RRI had no further questions on this item.
(0 pen) Allegation (50-498/79-19-05):
Pipe Sleeve Weld Defect 1/4" Deep at Az. 300 Degrees, Elevation 8' in RCS, Unit 1 Near Work Panel 15.
HL&P investigated this allegation by locating and inspecting.the area described above. Visual inspection of the area and review of drawings showed that there were no pipe sleeves in this area.
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The RRI visually inspected the area and observed that there were no pipe sleeves where welding had taken place.
However, the RRI observed that a pipe run passed through the wall at the alleged location and requested inspection records and nondestructive examination of welds in the general vicinity of piping run 2C 361P-SI-1205-KB2 (Revision 2).
This item will be reviewed after the examinations are mane.
(Closed) Open Allegation (50-498/79-19-06; 50-499/79-19-06):
Classification of the Containment Polar Crane.
This allegation was based on the alleger's premise that the equipment should be classified as safety-related. An IE inspector explained that the STP FSAR Table 3.2.A-1, page 3.2-22 did not require the equipment to be safety-related.
Nota 6 on page 3.2-29, Ammendment 2 (October 9,1978), states in part, "Our.ng and after a seismic event, the component and it's supports are designed to retain structural integrity and prevent collapse and damage to 3 fety-rele+.ed equipment and structures. Operability need not be retained."
The RRI contacted the NRR Project Manager at NRC Headquarters to determine if this matter of changing the FSAR classification should be pursued by NRR.
The present classification is correct, therefore, this matter is closed.
This allegation was substantiated, however, the classification will remain nonsafety-related/ seismic.
The RRI had no further questions on this matter.
(Closed) Open Allegation (50-498/79-19-07; 50-499/79-19-07):
Storage of Electrical / Mechanical Penetrations and Lack of Understanding by Warehouse Electricians of Megger Tests on Motors. The RRI visually inspected or
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observed the storage of electri:al and mechanical penetrations. The penetrations were stored in accordance with ANSI N45.2.2 and Brown & Root Procedure GCP 35, Revision 0, dated August 28, 1979.
The electricians were retrained in soggering equipment on August 25, 1980.
The above actions were documented in B&R Memo No. ST-BC-HS-03528, dated August 25, 1980.
Minor maintenance problems were experienced relative to' maintaining the nitrogen blanket on electrical penetrations.
The pressures on some penetrations were decaying at a faster rate than desired, however, there was no evidence to show that the condition was detrimental to the pene-trations. As a precautionary measure, the frequency of inspection of nitrogen pressure was changed from monthly to weekly.
Maintenance personnel were interviewed and they stated that they knew of no other detrimental conditions. NCR No..SN-G1-4786 described a nonconformance condition on mechanical penetrations.
In this instance, the minimum level of storage required by ANSI N45.2.2 is Level "D"; however, B&R TRD A710G002-C
required Level "B" which exceeds the minimum requirement.
This allegation was substantiated in part, in that, thare were some minor discrepancies that were iv.entified and documented, however, they were not deleterious to the equipment and had been corrected. The allegation.
that electricians did not understand megger testing could not bt sub-
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stantiated, however, all had received. training in megger testing.
The RRI had no further questions on this matter.
(Closed) Noncompliance (50-498/78-16; 50-499/78-16):
Failure to Inspect Storage and Maintenance In Accordance With Procedures.
B&R Procedure MCP-3, Revision 3, dated August 4, 1978, paragraph 3.1.2.2 and Appendix "C,"
paragraphs II.a. through d. required 100% surveillance of maintenance on Class IE equipment by QC personnel.
This procedure was not being followed.
Brown & Root Procedure GCP-35, Revision 3, dated February 21, 1980, now l
requires verification of in process maintenance and storage instructions and QC is now required to perform ESMI implementation verification on a minimum of 50 items par week.
This requirement has been exceeded during
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the last several months since QC was performing 100% verification to assure that the system was operating properly.
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(Closed) Unresolved Item (50-498/78-18):
Storage of Charging Pumps and a Positive Displacement Pump in Mechanical Electrical Auxiliary Builuing (MEAB) No. 1.
During an inspection conducted December 19-22, 1978, the IE inspector found these pumps and electrical motors to be stored in an area where excessive ceacrete curing water caused excessive humidity.
Protection of this equipment under these conditions appeared to be marginal. The l
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f IE inspector considered this item unresolved since the licensee had issued Brown & Root a memo to correct similar conditions.
The RRI inspected and observed this equipment on January 29, 1981, after reviewing procedures and the quality history regarding storage and
maintenance.
This satter is upgraded to a violation.
See paragraph 5 of this report for details.
(Closed) Varesolved Item (50-498/79-13; 50-499/79-13):
ESMI Ca-ds for High Head Safety Injection Pump No. 3 and Pump Motor Had Switched Equipment Numbers on the Respective Cards. During an investigation conducted on August 6-10, 1979, the IE inspector identified the condition described above and considered this item unresolved since HL&P site discrepancy memo (50M) M-051 identified a similar discrepancy.
The licensee on January 30, 1981, verified that the equipment numbers now
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match the proper ESMI cards. The RRI reviewed objective evidence (ESMI cards) and determined that corrections were made.
(Clesed) Unresolved Item (50-498/79-19-02; 50-499/79-19-02):
Licensee is Correcting Problems Found in the Resolution of Old NCRs on Storage /
Maintena,ce. During the NRC investigation conducted from November 19, 1979, to February 7, 1980, an IE inspector followed up on Allegation No. 9A described in Investigation Report No. 79-19. The IE inspector found that the licensee's and contractor's system had identified the problems described in the allegttion and was in the process of taking corrective action; however, the action was not complete. Therefore, the IE inspector left the item open pending final action and NRC review of the action.
The RRI reviewed Corrective Action Reports (CARS) No. 5-139, S-149 and S-157A and confirmed that the licensee had required B&R to take corrective action.
A large file documenting corrective actions relative to HL&P Concern Memo (CM-064) and Site Discrepancy Memo (SDM-051) was also reviewed.
The RRI performed routine and follow up inspection during November and December 1980 and January 1981 and determined the in place storage of equipment was not adequate.
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This item is upgraded to a violation since in-place storage has been a continuing problem from Decemoer 1978 until the present.
(See paragraph 5 of this report)
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(Closed) Unresol'ved Item '(50-498/79-22): MEAB 1 Centrifugal Charging Pump 1A and Electric Motor Heavily Contaminated with Sanoblast Grit and Dust.
During an NRC inspection conducted December 11-14,_1979, the above con-dition was identified to the licensee.
The IE inspector was informed
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that this condition had been identified on a B&R ESMI Verification Report, dated November 29, 1979, and immediate steps would be taken to correct the inadequate storage conditions.
On January 29, 1981, the RRI inspected the subject pumps in MEA 81.
The area where the pumps were stored still had a large amount of sandblast grit and dust.
Thi? item is upgraded to a violation, see paragraph 5 of this report.
(Closed) Unresolved Item (50-498/80-10-01; 50-499/80-15-01): Essential Cooling Pump Motors Did Not Have Current Applied to Windings.
During a routine inspection in May 1980, the RRI observed that power to the subject motors had been disconnected.
Three subsequent inspections were made of this area since that date and no further problems were found relative to power to electrical motors.
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(Closed) Unresolved Item (50-498/80-33-01):
Sandblast Grit and Dust in the Reactor Vessel, Loop Piping, Reactor Internals and Access Control to this Equipment. The RRI identified this condition on approximataly November 19, 1980, and discussed the conditions with licensee site representatives on that date. The PRI further discussed the unresolved
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item with licensee representatives on approximately December 19, 1980, aad advised that the unresolved item would be included in the NRC Inspection Report No. 80-33, which described the November and December 1980 inspection findings.
In a meeting held on January 7, 1981, the RRI was informed that the conditions described above were acceptable for this stage of construction.
This item was upgraded to a violation on January 23, 1981, see para-graph 4.b.
4.
Storage and Maintenance of Eouicment - Reactor Containment Building No. 1 a.
Background Unsatisfactory conditions relative to storage and maintenance of safety-related equipment have been identified during NRC inspections conducted from December 19-22, 1978, to January 1, 1981.
The licensee informed the IE inspector that an HL&P memo had been issued to Brown & Rect, Inc. on December 19, 1978, to take action relative to in place storage requirements for equipment and assure that requirements were implemented.
The licensee subsequently upgraded the memo to a Concern Memo (CM-064) on December 29, 1978, and then CM-064 was up-graded to a Site Discrepancy Memo (SCM-MOSI) on August 7, 1979.
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The Concern Memo (CM-064) documented the NRC inspector's unresolved item relative to the inadequate protection of equipment in MEAB, Unit 1 and subsequently the licensee determined that storage pro-taction recommended by the vendor was not consistently maintained; and additionally, maintenance information for the positive displace-ment pump was not on the maintenance card.
Site Discrepancy Memo SDM-MOSI was opened as a result of unsatis-factory corrective action on the part of Brown & Root, Inc. At that time the licansee considered the problem to be generic.
Eleven letters or memos followed and documented partially adequate responses, extensions and inadequate corrective action until finally Corrective Action Report No. S-157 was issued on November 7,1979.
It was closed out in B&R correspondence (BC-25991), dated April 15, 1980. HL&P correspondence (ST-HS-BC-01809), dated June 16, 1980, closed out the B&R memo (SDM-MOSI) which had identified a generic problem in B&R storage and maintenance.
The items identified in NRC reports from December 20, 1978, througn January 1,1981, were reviewed and inspected by the RRI for corrective
action as described in paragraph 3 of this report.
During an exit meeting held on January 23, 1981, the licensee was informed that all
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open unresolved items pertaining to storage and maintenance would be reviewed to determine if a generic problem ramains and to close out items where satisfactory results were found.
Subsequently, unresolved matters 78-18; 79-19-02, 79-22 and 80-33-01 were upgraded to violations as a result of the findings described in paragraphs 4 and 5.
b.
Reactor Pressure Vessel (RPV), RPV Internals Main Coolant loop (MCL)
Piping and MCL Pumo Volutes Jn approximately November 19, 1980, the RRI identified unsatisfactory storage conditions in the RPV, MCL piping and in areas where the internals were separately stored.
Licensee representatives were informed that the RPV, MCL piping (upper and lower) and the internals had fine sandblast grit and/or dust inside.
Also, the RRI informed the licensee that access was not controlled since the RRI was able to enter the vessel onchallenged and without shoe covers.
The licensee was informed on November 19 and Decemoer 19, 1980, that these matters would be documented as unresolved items in NRC Report No. 50-498/
80-33; 50-499/80-33.
On January 7, 1981, the RRI was advised that the HL&P QA Manager of the South Texas Project and the Westinghouse Site Manager considered the previously described conditions to be acceptable and he was advised that they wanted to meet with him. Durirg the meeting that was held the same day, the Westinghouse Manager stated that the conditions were totally acceptable, commensurate with the status of construction.
The licensee was advised by the Westinghouse Manager to do nothing, but since it is the licensee's vessel, they could do as they wished. He further aavised that the vessel was.ot in a storage condition.
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RRI stated that '.no vessel had been stored in place since being placed in Unit 1 Containment. Also, the RRI pointed out that little or no work had been performed inside the vessel or
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loop since welding had ceased in early 1980 continuing through December 1980. On January 12, IS81, the RRI informec the HL&P Manager QA STP that protecting the vessal from sandblast dust or grit and access control to the vessel are required per ANSI N45.2.2, paragraphs 2.7.4 and 6.2.1, respectively.
The RRI again stated that the in place storage was inadequate.
On January 21, 1981, the RRI and the RRI's supervisor met with the HL&P QA Manager, Project Manager and Discipline Project QA Supervisor to discuss the conditions. HL&P representatives stated at this time that access control would be improved; however, dust was not considered a problem.
On January 22, 1981, the RRI and the RRI's supervisor performed a follow-up inspection and found that the area around the top circumference of the vessel' had not been sealed with Griffolyn.
The area was open and allowed dust, grit and rodents to enter.
Access to the internals was not controlled as stated at the previous days meeting. At a meeting, the HL&P Manager STP
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was advised of these conditions. He stated the vessel would be sealed and access would be controlled.
On January 23, 1981, the RRI performed ancther follow-up inspection at 8:30 a.m. and found tnat the vessel had been sealed but sev2ral holes in the old covering, about one foot in diameter retained at approximately 9:30 a.m.
The RRI advised the HL&P QA Manager that ur ~esolved Item No. 50-498/80-33-01 had been upgraded to a violation.
Reactor coolant pump casings lA,18,1C and ID are in place and welded to loop piping which is connected to the reactor vessel.
These casings had plywood protective covers, however, one-half or three quarter inch gaps between the plywood covers and machined surfaces allowed sandblast grit and dust to enter the casings and loop. This equipment was not sealed well enough to meet Level "0" storage requirements.
The RRI subsequently performed a follow-up inspection and found that the reactor vessel, piping loop and reactor coolant pump casings have now been properly sealed.
The protection of thimble storage guides and racks meets Level "D" storage requirements.
This reactor vessel head was adequately protected to Level "0" storage requireinents and access was controlled.
The failure to adequately protect equipment stored in place and to adequately control access as described above and as required by B&R Procedure GCP-35, Revision 3 (February 21, 1980), para-graphs 3.2.1, ano 3.5.4 is a violation of 10 CFR Part 50, Appendix B, Criterion V.
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R,esidual Haat Removal (RHR) Pumos On Janaury 26, 1981, the RRI continued tne inspection of equip-ment stored in place in Reactor Building, Unit 1 to determine the effects of the sandblasting operation.
Residual Heat Removal (RHR) pumps IA, 18 and 1C were stored in an area where heavy sandblasting had taken place. The pumps were covered with Griffolyn.
Pumps IA and 1B were not protected in such a a nner that would preclude sandblast grit and dust from getting into the bearings.
Pump 1C could not be inspected because sand was piled outside of the door which was sealed.
The RRI determined that a Nonconformance Report had not been
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written to identify the inadequate protection of this equipment.
This equipment was stored to Level "B" requirements until it was moved to the Reactor Building and stored in place.
The protection now given will not meet Level
"D" requirements for protection against airborne coatamination.
This failure to identify that the RHR pumps were contaminated
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and issue a Nonconformance Report as required by Brown and Root Procedure GCP-35, Revision 3 is a violation of 10 CFR Part 50, Appendix B Criterion V.
d.
Steam Generators The RRI visually inspected the outside appearance of the Steam Generators.
In an interview with the cognizant engineer, it was noted that the nitrogen purge was removed from the shell side (secondary) exposing carbon steel material to atmospheric
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conditions with openings seale<t.
Special equipment was pur-chased to control the environment, however, it had not been connected because Westinghouse did not want to expose the Steam Generators to the present environment.
This matter is an unresolved item pending further review.
(No. 50-498/81-01-04)
e.
Safety Injection System Accumulators and Pressurizer Three Safety Injection System accumulators are stored in place and have a nitrogen blanket.
Protection of this equipment meets Level "0" storage requirements.
This Pressurizer was stored in place and had a nitrogen blanket.
The storage met Level "0" requirements.
No violations or deviations were identified.
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5.
Storace and Maintenance of Equipment - Mechanical / Electrical Auxilf ag Building On January 29, 1981, the RRI inspected the in-place storage cf equipment in Mechanical Electrical Auxiliary Building (MEAB), Unit 1.
Refueling Water Purification Pump (M-0410), Centrifugal Charging Pumps (M-0370),
Baron Recycle and Waste Pumps, Letdown Chiller / Reheat Heat Exchanger (M-0396/0395), Sea 1 water Heat Exchanger (M-0366), Thermal Regenerative Domineralizer Tanks (M-0389 through 0393) Closed Cooling Water Heat Exchangers (M-0570 and M-0571) and Recycle Holdup Tanks (M-0019 and M-0020) were ir.spected.
The nitrogen pressure on one of the Closed Cooling Water Heat Exchangers (M-0571) was noted to be lower than required (actual 1 psi versus tee required 3 psi). There were no covers on the Recycle Holdup Tanks wnile work such as painting was being performed (immediate corrective action was tawn to replace the covers).
These matte.'s are considered unresolved and will be reviewed during future inspections by the RRI.
NRC Report No. 50-498/78-18; 50-499/78-18, inspection conducted December 19-22, 1978, identified inadequate storage of Centrifugal Charging and Positive Displacement Pumps because of exposure to curing water.
NRC Report No.
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50-498/79-22; 50-499/79-22, inspection conducted December 11-14, 1979, identified inadequate storage because sandblast material was contaminating the Centrifugal Charging Pumps.
The RRI found that B&R had initiated an NCR on September 9, 1980, which was almost nine months after the NRC identified the problem.
NCR No. SG-2591 identified this pump as nonconforming and indicated that the condition of moving parts was considered indeterminate. Additionally, the NCR identified the same nonconforming conditions for Chiller Pumps, Reactor Coolant Purification Pumps and Refueling Water Purification Pumps.
The recommended corrective action response was due from the Westinghouse Site Manager by October 30, 1980. The Westinghouse Site QA Manager responded to the Material Review Board with corrective action on January 29, 1981.
A follow-up inspection on January 19, 1981, revealed that Centrifugal Charging Pumps still were not properly protected since sandblast grit and dust were in the storage area. The Charging Pump area was covered with a Kelly Closure and the roof was damaged, but was covered with Gri f folyn. This means that the pumps have either been rotated without removing the sandblast grit and dust or they have not been rotated Lecause the NCR was not initiated or dispositioned in a timely manner.
This matter will remain unresolved pending review of the corrective action by the RRI.
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Storace and Maintenance of Equipment - Warehouse
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The RRI accompanied a maintenance foreman who performed maintenance of equipment selected by the RRI.
The equipment selected was that which was previously identified by HL&P Site QA in a letter, dated March 12, 1980, as improperly maintained. The RRI inspected the following equipment for proper maintencice:
a.
Reactor Make-up Motor Pump Motor, 3R272NPAZO1A, ESMI-M-3088C b.
Auxiliary Lube Oil Pump Motor, WPO 274413, ESMI-M-3088C c.
Regenerative Heat Exchanger, WP0 274472 (maintenance not required)
d.
RHR Pump Motor, WPO 248002, ESMI-E-0742 e.
Butterfly Valve, WP0 299859 (maintenance not required)
No violations or deviations were identified.
7.
Surveillance /Inscection of Equicment Maintenance and Storace -
Reactor Containment Building No. 1 The Brown & Root quality assurance / control, housekeeping and storage maintenance procedures require surveillance / inspection of the above areas and reccrds (ESMI cards). The RRI reviewed QA Examination Check Sheets relative to the RPV and RPV internals Housekeeping Zones.
These sheets documented inspections which showed satisfactory results from October 14, 1980, through January 16, 1981.
These findings do not correlate with the actual conditions previously described.
B&R ESMI Verification Reports document satisfactory storage conditions on RPV/
RPV internals from October 21, 1980, througn January 1981, and these inspections do not correlate with actual conditions previously described.
These verifications are based on the ESMI card data / instructions and this may account for the satisfactory results since these instructions are not entirely adequate. ESMI Verification Report 539 (December 1980),
447 (November 1980), 425 (November 1980) reported satisfactory storage conditions for the RHR pumps.
Inadequate storage conditions have been identified, but have not been corrected.
The RRI reviewed B&R Housekeeping Inspection Report, HIR 42, dated March 28, 1980. This report stated that the interior of the vessel was not well kept, in that, sunflower seed (food), trash (paper) and
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used grinding wheels littered the bottom of the Unit i vessel.
Even though reinspection, performed by B&R on April 18, 1980, documented correction of these conditions, this instance is highlighted to emphasize that access control and material accountability must be improved when work resumes inside the vessel.
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The RRI reviewed Equipment Maintenance and Storage Instruction (ESMI)
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cards to determine if adequate instructions are available for maintenance and inspection personnel. The cards were also reviewed to determine if maintenance was performed.
The following was found:
a.
No instructions were given relative to access control, material accountability or assuring that the RPV (ESMI M-0321C) is pro-tacted from airborne contamination.
The comments on the back of the card on April 17,1980, July 12,1980, and October 9, 1980, indicated a problem with airborne contamination and residue left from penetrant testing, b.
" Westinghouse Recommended Storage Criteria" recommended that RPV internals (ESMI M-0427/M-0428) stored per Level "C" be covered with dust cover which is fire, tear resistant and waterproof. No cover was observed.
The card did not have instructions on it relative to this covering.
Sandblast grit and dust was in this area; therefore, Level
"C" requirements were not met. The card does not state that shoe covers wera required; however, Westinghouse criteria recommended the use of shoe covers.
The note < on the ESMI card indicated dust in the area on July 28, 1980.
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c.
RHR Pumps A, B, and C, (ESMI, M-0344D/03450/03460) storage instructions indicate Level "B" storage is required while in the warehouse; however, once they are stored in place, the instructions state, " protect from detrimental environment."
The notes on the ESMI card for Pump A indicate that Level "B" storage could not be maintained because of sand and water as of July 31, 1975. On August 22, 1979, the notes indicated that the shaft could not be rotated quarterly as required on the card, however, the Westinghouse representative stated that the requirement would be daleted.
Similar notes relative to dirt, shaft rotation occurred on April 17 and 24, 1980, May 22, 1980, and July 17, 1980.
Similar notes were four.d on the ESMI cards for Pumps B and C.
These pumps are not stored in accordance
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with Level "D" requirements.
This failure to develop adequate instructions and procedures that incor-parate vendor maintenance, ANSI N45.2.2 and B&R Procedure GCP-35, Revision 3 (February 21, 1980) requirements for in place storage is a violation of 10 CFR 50, Appendix B, Criterion V.
8.
Receiving and Storage The RRI reviewed South Texas Project Monthly Site QA Activity Report No. 43, December 1980, and made the following observations:
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Receiving Eighty-thrse inspection reports were generated for receipt inspection activities during this reporting period.
Eighteen of these reports reflected unsatisfactory conditions resulting in fourteen NCRs being issued (all eighteen are covered by these NCRs).
One hundred ninety-one warehouse requisitions were approved for issue to construction.
Present inspection backlog as of December 27, 1980 is nineteen.
b.
Storace Storage and maintenance requirements, as indicated by ESMI cards, were verified on 1,548 items.
Sixty-four unsatisfactory conditions were noted and placed on " suspense hold." Thirty-one of the seventy areas inspected and documented on storage inspection report forms showed unsatisfactory conditions.
No NCRs were generated as a result of unsatisfactory maintenance / storage inspection reports.
Only four percent of the 1,548 items that were inspected for storage and maintenance showed unsatisfactory conditions.
However, forty-four percent of the storage areas inspected were unsatisfactory and no nonconformance report was issued nor was a trend identified.
In view of the RRI inspection findings, it appears that a trend snould have been identified.
These matters will be considered unresolved pending further review by the RRI.
9.
Review of Coen Nonconformance Reports The RRI revitwed the January 27, 1981, computer run which listed all open Nonconformance Reports. As a result of reviewing several Nonconformance Reports in detail, it was found that approximately forty-nine aonconformances, which were controlled by the Brown & Root nonconfonnance system, had been closed out by letters from the Westingnouse Site Manager. The letters stated that the Nonconformance i'
Reports (NCRs) were closed on this Westinghouse equipment because no nonconformance ever existed.
The subject nonconformances dealt with the following equipment:
a.
Computer Cabinet b.
Four-inch Diaphram Actuated Control Valve c.
Reactor Coolant Pumo Internals
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Stena Cenerator
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Reactor Trip Switchgear The above examples appear to be valid nonconformances.
The description of the nonconformance written on the manufactured equipment infers that testing, design criteria and reports should have been completed.
Westinghouse site operations does not have a site QA program / procedure to control nonconformances if they are subsequently identi fied as NCRs.
This ites is unresolved pending further inspection.
10. B&R Maintenance and Storace Organization The RRI reviewed B&R Procedure GCP-35, Revision 3, (FebrJary 21,1980).
Section 3.1 describes responsibilities of the PQA Supervisor, Ware-house Department, Storage and Maintenance (S&M) Department, Area Discipline Superintendent and S&M Technicians.
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The RRI was unable to obtain an up-to-date organization for the site construction organization and has unsuc::essfully attempted to obtain such charts since August 1980.
The only chart available was a February 1980 chart; however, a draft was available which will correct the condition when approved and distributed.
The RRI met with the B&R Assistant Project Manager and the PPM / Systems Engineering Manager to discuss how the organization functions.
The RRI was given an organizational chart, dated October 27, 1980; however, this chart described positions which were not in the Storage and Maintenance Procedure GCP-35, Revision 3, dated February 21, 1980.
The RRI found that GCP-35, Revision 3, dated February 20, 1980, does not describe safety-related functions perforiaed by S&M field technicians.
That is, they perform duties relative to receipt inspection, scheduling maintenance and ESMI records for safety-related equipment.
These matters will be considered unresolved pending a raview by the RRI of an updated organization chart and a description of the duties and responsibilities of storage and maintenance field technicians in the appropriate procedure (GCP-35, Revision 3 (February 1980)).
11. Wsldino of Safety-Related Pioing The RRI visually inspected a compleao +aldn.ent on Component Cooling Water piping, CC-1103-WA3 (Sheet 1) Spoul 1, in MEA 8-1 at elevation 25'.
No violations or deviations were identified.
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12.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violation, or deviations. Six unresolved items disclosed during the inspection are discussed in paragraphs 4, 5, 8, 9 and 10.
13. Manaaement Meetinas The RRI eet with one or more of the persons identified in paragraph 1 on January 7, 9, 15, 19, 20, 21, 23, 27, 28 and 29, 1981, to discuss inspection findings and to discuss licensee actions and positions.
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