IR 05000498/1984012
| ML20138J149 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/09/1985 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Oprea G HOUSTON LIGHTING & POWER CO. |
| References | |
| OL-A-078, OL-A-78, NUDOCS 8510290269 | |
| Download: ML20138J149 (14) | |
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Action Dockets: 50-498/84-12 I " 7- , ,, ~. . ,' . gg 50-499/84-12 ; . E, . ,-
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-m E P Houston Lighting & Power Company g ATTN: G. W. Oprea, J I Executive Vice President P. O. Box 1700 FUa 5400 NLD/RMS Houston, Texas 77001 Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program by Messers. D. P. Tomlinson, D. R. Carpenter, and L. E. Ellershaw of this office during the period Augusc 1 - September 30,1984, of activities authorized by NRC Construction Permits CPPR-128 and 129 for the South Texas Project, Units 1 and 2, and to the discussion of our findings with members of your staff at the conclusion of the inspectio ,
Areas examined during the inspection included a review of previously identified inspection findings, site tours, IE Bulletin followup, and allegation followu Within these areas, the inspection consisted of selective examination of proce-dures and representative records, interviews with personnel, and observations ~
by the NRC inspectors. These findings are documented in the enclosed inspection repor Within the scope of the inspection, no violations or deviations were identifie One unresolved item is identified in paragraph 4 of the enclosed inspection repor We have also examined actions you have taken with regard to previously identi-fied inspectiort findings. The status of these items is identified in paragraph 3 of the enc osed inspection repor buCLIAR 4tCULaf08Y COMMl5160N i
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t Houston Lighting & Power Company -2-Should you have any questions concerning this inspection, we will be pleased to discuss them with yo '
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w H. Jo nson sChief R act r Project Branch 1
Enclosure:
1. Appendix - NRC Inspection Report 50-498/84-12 50-499/84-12
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REGION IV F4RC Inspection Report: 50-498/84-12 50-499/84-12 Dockets: 50-498; 50-499 Construction Permits: CPPR-128 CPPR-129 Licensee: Houston Lighting 4 Power Company P. O. 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 1 - September 30, 1984 Inspectors : a eCr/) v/ PV
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( , 2, 3, nd f /
.( x rpenter,' Resident Inspector Ahr Date (pa . 2, 6. and 7)
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L. E. Ellershaw, Reactor inspector
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(pars. 2, 4, 6, and 7)
Approved: -
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au , Chief. Projec't Section A Date eac r Project Section 1
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Inspection Summary Inspection Conducted: August 1 - September 30, 1984 (Report 50-498/84-121 50-499/84-121 Areas Inspectedt Routine, announced inspection of previously identified Inspection findings; site tours; IE Bulletin followup; and allegation followu The impaction involved 282 inspector-hours onsite by three
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NRC inspector Results_:
Within the areas inspected, no violations or deviations were identifie l
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3-l OETAILS Persons Contacted Principal Licensee Egloyees_
- D. Bednarczyk, Project QA Supervisor-Civil / Structural D. Bonhner, Project QA Supervisor-Electrical
- J. Estella, Supervisor, Quality Systems J. Goldberg, Vice President, Nuclear Engineering and Construction 5. Hubbard, Senior QA Specialist
- T. Jordan, Project QA Manager
- D. Keating, Project QA General Supervisor G. Oprea. Executive Vice President J. Willia-s , Site Manager C. Wright, Project QA Supervisor-Mechanical /NDE Other Personnel Bechtel Power Corporation (Bechtel)
J. Downs Deputy Mana.ger of Construction
- L. Hurst, Project QA Manager
- A. Priest, Project Manager of Construction
- R. Miller, Deputy Pro. ject QA Manager Ebasco Services . Inc. (Ebascol J. Crnich, Construction Manager R. Cummings, QA Site Supervisor R. Grippardi. QC Site Supervisor
- C. Hawn, Quality Program Site Manager F. Miller, Welding Construction Superintendent J. Thompson, Site Manager
- Denotes those individuals attending one or more management meetings during the inspection perio . Site Tours Routine tours of the site were conducted by the NRC inspector observing housekeeping activities; general cleanliness; protection and preservation of equipment and material; personnel access control; and plant status as follows: Units 1 and 2 Reactor containment Buildings, Mechanical-Electrical Auxiliary Buildings. Fuel Handling Buildings, and Diesel Generator Building <
-4- Si te Storage' areas, including the warehouses , laydown areas , and the welding fabrication sho With regard to the above areas, the NRC inspector r afired the following: Safety-related and storage areas wen. W U- mal tions of
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trash, refuse, and debri Work areas were clean and orde^ Tools, equipment, and materi J <W nM d to pdb proper storage
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locations when no longer in r, Some areas requiring additional a% ...c; Mlative to housekeeping and cleanliness were pointed out to the licensee. Thesa areas were attended to within a reasonable time and the NRC inspector had no further questions concerning site tour . Licensee Action on previous Inspection Findings (Closed) Unresolved Item (498/499-8316-03) Failure to Identify Required Standards: Possible Nonconforming Installation._ During a review of the requirements placed on subcontractors providing material and services for South Texas Project (STP), the NRC inspector noted that the American Institute for Steel Construction (AISC) specification for the bolting of high strength materials had not been directly invoked. In particular he was concerned with the AISC prohibition on the reuse or retorquing of galvanized A-325 bolts. This was considered to be an unresolved item pending further review.
! A further review revealed that the contractor in question, Bostrum-Bergen, was awarded the contract to supply various steel parts and assemblies on July 30,1976. At this time the document in effect was the 7th Edition of the AISC specification for bolting. The prohibition on the reuse or re-torquing of galvanized A-325 botting material first appeared in the AISC 8th Edition, issued in 1980. This ban was introduced to avoid the question-
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able tightening that could result when bolts with relatively rough thread surfaces are subjected to successive cycles of forceful torquing. Although the prohibition on retorquing was not specifically invoked, it.was included in the ordering data by referenc The galvanized bolts as well as all other bolts furnished by this suppiter were tot shop assembled and tightened as permanent bolted connection Therefore, the galvanized bolts were not subject to tightening on the part j
of the supplier. The subsequent onsite torquing and use of these bolts does I not appear to violate the AISC specification or present a potential deficiency within the suppliers scope of operation This item is close __ _ .
-5-Failure to Meet Record Retention
[c C1 a ui rementssed)._ Violation (498/499-8216-01)During a myiew of quality a licensee's site Quality Assurance (QA) records storage room, the NRC inspector noted that records were being removed from metal fileIfcabinets open and were being stored in binders and folders on open shelvin storage is utilized, the storage room, including the door, must have a 4-hour fire rating. The NRC inspector also noted that the exterior walls of the site record storage room were pierced by ventilation supply and return ducts. This precludes the area from meeting the requirements of National Fire Protection Association (NFPA) 232, " Standard for discrepancy This the Protectionviolated of Records" for a 2-hour or 4-hour fire ratin the licensee's Quality Assurance Program Description (QAPD) Section 1 and ANSI N45.2.9 Section 5.6. In a 2-hour rated fire resisant file room
' storage is allowed provided that the records are stored in fully enclosed metal cabinet Houston Lighting & Power Company (HL&P) nsponded to this violation by agreeing that the QA mcords storage room did not meet the requirements
l of ANSI N45.2.9 with respect to a 4 hour-fin rating. HL&P did not egree that the records were stomd improperly with respect to the open shelving. Prior to the ksuance of this violation HL&P requested from the American Society of Mechanical Engineers (ASME) a clarification of the term " loose records" and a determination of what constitutes accept-j able " shelving" and " containers." This clarification was sought for the After reviewing terms as used specifically in ANSI 45.2.9, paragraph the ASME definitions of the terms the NRC inspector agreed that the storage of records in binders and folders on open shelving was not in violation of the intent of ANSI N-45. As corrective action for wall-piercing ventilation ducts HL&P has modifled the record storage structure by the installation of two additional Underwriters Laboratory (UL) listed 3-hour fire dampers installed in series in the ducts. These are combination heating, ventilating, and air condi-tion (HVAC) ducts. This modification has now afforded the records storage room with the equivalent protection of a NFPA Class A 4-hour rated facilit HL&P forwarded drawings and a description of the modifications to American Nuclear Insurers for evaluation. The American Nuclear Insurers response to this request, dated December 21, 1982, acknowledged receipt of the
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information and stated that the facility was found acceptable for insurance purposes as a 4-hour fire rated facility, subject to final inspectio ,
Following his review of the corrective action taken and a tour of the records storage room, the NRC inspector had no further question This item is close(.
(Closed) Violation (498/499-8202-01) Failure to ReportWhile Desion or_
conducting fonstruction Deficiencies Within the Required Tim in investigation at STP, the NRC inspector noted an apparent Thisviolation regula-of the timely reporting requirements of 10 CFR 50.55(e).
tion recuires that the holder of a construction permit notify the appropriate NRC Regional Office, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery, of any i - - - - - _ _ _ _
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deficiency found in design or construction, which, if uncorrected,
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could adversely affect the safety of plant operation l
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Contrary to this, two deficiencies were found by the applicant on or about November 1980 and January 1981, respectively, but were not reported tc the NRC Region IV Office within the required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The original notification for each was received on May 8,1981, after a delay of approximately 4 months. This ' violation and the two specific examples are detailed in Investigation Report 498/499-820 The licensee agreed that there was a failure to report one of the items but determined that the second was not reportable pursuant to
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! 10 CFR 50.55(e). This actual significance of the second item did not becore apparent until the detailed findings of the Quadrex Report became available on May 7,1981. HL&P formally notified the NRC Region IV Office or. May 8,1981, the day following their receipt of the informa-tion necessary to fully evaluate the reportabilit ,
As a result of this violation the deficiency riporting procedures have been revised and employees have been retrained in order to reduce the potential for a failum to comply with these reporting requirement Procedure PEP-4.01 was rewritten and reissued as PLP-02, " Reporting Design ar.t Construction Deficiencies to the NRC," dated May 18, 198 PLP-02 no. clearly state the requirements for reporting and change the lead risponsibility for initial notification of all deficiencies
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solely te the Team Leader, Nuclear Licensing. It also rumoved the distincticn between site and home office handling of deficiencies and clarified the role of engineering in the evaluation proces The NRC ir.spector has reviewed procedure PLP-02 and subsequent revisions to deterr'ne its adequacy and clarity. The NRC inspector made a random selectior. of eight deficiency notifications received subsequent to this violatior, and verified that each had been promptly reported. Three of these wars originally reported as "potentially reportable" items and were lata , determined to be reportable. Following these reviews the NRC inspe-tor had no further question This ita. is close (Closed) '_%esolved Item (498/499-8209 04). Structural plates and Bars and :lat Washers for Reactor Coo _lant System (RCS) Support The NRC tr.spector noted an apparent conflict between the requirements
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of the ST.: FSAR and the Brown and Root (B&R) specifications for materials used in the RCS supports. The conflict in requirements was l identified when FSAR Section 3.8. 3.6 .5 .1 was compared to B&R Specification 1C11955015E/DCN dated June 2,1977. The STP FSAR specified that materials for RCS supports, structural plates, shapes and bars art to be ASTM A588 corrosion resistant, high strength, low alloy steel. The FSAR, in the same section, also specified that flat washers were to be quenched and tem-
- pered caroon steel. B&R Specification IC11955035E/DCN dated June 2,1977, however, specifies the use of ASTM A36 material for thicknesses greater
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the B&R_ specification allows the use of ASTM A36 material for use as flat washers .
The response to this item stated that it is not a requirement that the F5AR reflect all materials and processes used on the project. It is the
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' intent of the project that the FSAR identify only the basic materials and l processes used. The response stated that an SAR change notice had been initiated to clarify this position and to identify the basic materials and processes which are being use The NRC inspector reviewed Section 3.8 of the STP FSAR and found that Revision 40 incorporated several approved changes. The material to be used for RCS supports is now clearly stated as ASTM A588. Section 3.8.3,6.4.1 has also been changed to allow the use of either quenched and tempered carthon steel or ASTM A36 material for flat washers used in the RCS support The NRC inspector had no further questions following his review of SAR Revision 4 l This item is close (Closed) Un esolved Item'(498/499-8322-04) 88R Calibration and Control of Gaces and Other Inspection and Test Tools Reautring Calibratio During a review of records in the calibration laboratory, the NRC inspector reviewed a number of recalibration records where the calibration status of the equipment, as received for recalibration, was not recorded, precluding determination that the equipment was l
within calibration when returned. The identification numbers of seven gages and/or tools were listed as examples. This item was considered as unresolved pending further review of calibration l
procedures and implementatio The NRC inspector reviewed the calibration records of the specific
tools and gages listed in the inspection. This review revealed
that six of the seven itens were "Go-No-Go" thread ring gages and the seventh was a crimping tool. Instrument Engineering l Instruction IEI-42 did not require an entry in the " Data as Received" l
l and " Data After" sections of the calibration record since these data sections are not applicable to ring gages. The seventh item, a l crimping tool, was placed in a " hold" status on May 14, 1980, and has l
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never been issued for use. In these instances the calibration lab was correct in not entering data in the "as received" sections.
l This item is closed.
l (Closed) Unresolved Item (498/499-8213-04) Records . During a review f of records and procedures, the NRC inspector determined that the procedure " Quality Assurance Records" had been written and approved but the implementing procedure for administration of the Ebasco
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Records Office was still being progressed through the review cycle j
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prior to issuance. An Ebasco staff member stated that interior guidance would be provided to personnel handling records until the procedure is fully implemented (end of September 1982). Because of the small number of documents being processed at the time of this inspection, the response was acceptable to the NRC inspector, pending _
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his further review following the procedure issuanc The NRC inspector has reviewed QAI-016. " Control of Site Quality Records",
as issued for use on September 13, 1982. Based upon the issuance and implementation of this procedure within the specified time, the NRC inspector had no further question This item is close . IE Bulletin Followup -
The NRC inspector rtviewed the available documentation pertaining to the IE Bulletin (IEB) listed below, to assure that the Itcensee management had ,
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received the bulletin, that a review for applicability was performed, and, if applicable, that the required actions had been taken; i.e., conducting an evaluation to demonstrate that the materials were suitable for intended
service, or replacing discrepant materials with materials which have been
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manufactured in full compliance with Section III of the ASME Code and the applicable procurement specification requirement IEB 83-06 Nonconforming Material Supplied by Tube-Line Corporation Facilities at Long Island City, New York; Houston, Texas; and Carol Stream, I Illinoi IEB 83-06, dated July 22, 1983, was received by HL&P, and an investigation was conducted by them and their architect-engineer, Bechte With respect to IEB 83-06, HL&P provided a final response to the NRC in a letter dated April 30, 1984. This response stated, in part ". . . we have not identified any Tube-line material that has been supplied to the STp for use in safety-related systems. . . we reviewed the STP purchasing for safety-related pipe fittings and flanges of the type supplied by Tube-Line and identified 35 vendors that could have supplied Tube-Line material to the project. . . Each of the 35 vendors was then provided with the project's purchase order listings and asked to identify any Tube-Line ASME Code Section III material furnished to the project. All 35 vendors have responded, stating that no Tube-Line ASME Code Section III material for use in safety-related systems had been supplied to the STP."
The NRC inspector reviewed copies of the available Bechtel letters and the responser, received from 19 vendors. All of the vendors, except one, indicated that they had not provided Tube-Line material to ST The resp 6'nse from Guyon Alloys, Inc. , stated that several items from Tube-
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Line had been furnished to STP; however, the Bechtel purchase orders (PO)
had not required processing in accordance with their quality program and only certificates of compliance were required. It was established that the subject PO's were not for safety-related materia The NRC inspector reviewed 14 documentation packages consisting of PO's, vendor documentation, and receiving inspection reports pertaining to 1
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materials provided by Gulfalloy, Inc., 1 of the 19 vendors. The Gulfalloy, i
l Inc., response letter to Bechtel was dated April 13, 1983, and stated, in parts ", , , Gulfalley has not supplied any matarials either manufactured or i
supplied by Tube-Line for the South Texas Project . . . ."
One of the 14 documentation packages contained a Brown & Root In (the original architect-engineer for STP) P0 to Gulfalloy, Inc.,
No. 35-1197-19432, dated July 18, 1979, for 200 each, 1-1/2", Schedule 40, A-234 WPB, Long Radius, Socket Weld, 900 Elbow l The P0 states, in part, "This is a ' Nuclear Safety-Related' Order
. . . Vendor shall furnish . . . Certified Material Test Reports (CMTRs) For i Each Heat / Lot of Materials Delivered . . . And Evidence Conformance to the i Requirements of ASTM A-234. . . ." Additional documents in the package
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consisted of a CMTR from Tube-Line. Inc., Long Island City, New York, and a i
B&Rreceivinginspectionreport(RIR). The CMTR is dated Ju-ly 20,1979, and shows 200 each,1-1/2", 90o long radius elbows, of A-234 WPB materia B&R's RIR No. 3558 shows that 200 elbows were received on August 6, 1979, accepted and released. Thus, there is an apparent conf 1fet between the data
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contained in the documentation package, the Gulfalloy response to Bechtel, and the HL&P bulletin response to the NRC.
In addition, with respect to the Tube-Line CMTR, the ASTM Material Specifica-i tion A-234 requires that when CMTRs are requested by the purchaser, the manufacturer shall report the results of the chemical analysis, tension test results, and the applicable heat treatment applied to the material and to the test pieces. The Tube-Line CMTR did not address heat treatmen It should also be noted that this documentation package was reviewed for i adequacy by Bechtel on August 16, 1984, and accepted as evidenced by a
Bechtel stamp with number.
! Another concern pertaining to the HL&P/Bechtel evaluation deals with Bechtel's I data accumulation and usage. Prior to the issuance of IEB 83-06 on July 22,
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1983. Bechtel received infonnation about potential 10 CFR Part 21 reports filed with the NRC by Capitol Pipe & Steel Products Company and Babcock &
Wilcox Company on December 6,1982, and January 10, 1983, respectively, ,
dealing with Tube-Line, Long Island City, New York. Subsequently, but still prior to the issuance of the bulletin, Bechtel sent letters to certain vendors (Gulfalloy Corporation, Capitol Pipe & Steel Products Company, McJunkin Corporation, ar.d Guyon Alloys, Inc.) requesting confinnation that no Tube-Line material had been supplied to ST The letters also orovided the PO numbers and referenced only 2-i_nch
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and under oinino material. This_may have_ limited the vendors'
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' review to iust the 2-inch and under piping material on the soecific *e +n P +ha = = === fran th.c. vendnre gpr e M 9 F_urth c
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' dust Tnha line. I nna 1tland city. New York.
I l I This ace'umulated nda11stin data may have been used en ennnart m 1R Ap (
to the NRC. This could conceivably invalidate their response _in retnnn i n- l that creater than 2-inch piping material and tne tube-Line facilitiec Carol Stream. u nnon. anc nouston. ioxas. annear to have not been included ;
in the reviews conducted hy the four Ahnvs listed vendors,
' This is considered an unresolved item (498/8412-01;'499/8412-01). Allegation Followun
_ _ -An allegation was received via telephone by the NRC RegionThe IV Office allegerconcern-
{ ing the QA program of a major supplier of steel to the STP sit stated that Sheffield Steel Corporation was supplying large quantities of structural steel to the STP construction site although the company j
had no quality program to assure that the material shipped confomed l' to the P0 specifications.
J In NRC report 83-21 it was stated that PO 35-1197-6001 was issued to Amco Steel in 1975 to supply all of the concrete reinforcing steel i Prior to issuing this P0 to be used for the construction of ST a review was made of the Armco Steel Quality Assurance Manual by HL&P l
i personnel. HL&P coments were incorporated into the manual and the I
program was accepted as being in compliance with all applicable requirement When Amco Steel was sold and the name changed to Sheffield Steel, the only
change made to the QA Manual was in the name.
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! The Sheffield Steel QA Manual was reviewed by the NRC inspector and was found to be complete and comprehensive. Personnel responsibilities, l document control, program requirements, personnel qualifications, i
training, audits, nonconfomances, corrective action and vendor requirements are delineated in detail. The NRC inspector also reviewed several of the Sheffield Steel procedures utilized in the testing, storage, and shipping of reinforcing steel and all were found to be in compliance with the QA manual.' The NRC l'nspector reviewed a sample of the test records received for various lots of reinforcing steel. Each contained quantitative results for yield, tensile, elongation, and chemical analysis of each heat
of materia The NRC inspector's review of the QA manual, material test records, and quality engineering evaluation of documentation revealed no conditions onsite to ' ndicate that theBecause Sheffield Steel QA program, as stated, was not of the nature of the allegation, it was being fully implemente forwarded to the NRC Region IV Vendor Inspection Branch for further evalua-tio The NRC Region IV Vendor Inspection Branch conducted an inspection of the Sheffield Steel Corporation facility at Sand Springs, Oklahoma, during the peri'od January 30 - February 3,1984. The report for this inspection l
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- stated that no violations were noted but did identify three nonconfor-mances. A copy of this report was transmitted to HL&P with a request that the three items be acted upon and that records and results of these actions !
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be provided for NRC revie As a result of this request records were presented to the NRC inspector to document the following: On May 11, 1984, HL&P issued a letter to Bechtel requesting that
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specific actions be takcn and answers provided concerning the quality program at Sheffield Stee A joint audit of Sheffield Steel was performed by Bechtel and HL&P during the period May 23-29, 1984, which resulted in ten finding Three stop shipment orders were issued because of these finding On June 1,1984, a Nonconformance Report (NCR) BC-00452 was issue This NCR placed a " Hold" on all questionable reinforcing steel until it could be reinspecte On June 12, 1984, Sheffield Steel reassigned all of their inspectors to the Quality Control (QC) organization rather than production. This was done as a result of the NRC inspection and the finding of the joint audit. On this day Bechtel also removed the stop shipment order based
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upon the results of the reinspection performe On June 18,1984, Bechtel issued a letter to Sheffield Steel listing 13 heat numbers of material which were to be quarantined and pemanently barred from shipment to ST On June 30,1984, a reaudit of Sheffield Steel was conducted by Bechte The results of this reaudit indicated that all previous findings had been adequately addressed and the proper corrective actions taken. Although no additional adverse findings were identified, all of the documentation l
for each future Sheffield Steel shipment will be reviewed by Bechtel i r'eceiving inspection personne Based upon the NRC inspector's review of the audit and inspection findings and of the actions taken, this item appears to have been adequately addressed.
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6. Unresolved Item An unresolved item is a mtter about which more information is required in order to determine whether it is an acceptable item, a violation, or a deviation. One unresolved item is discussed in paragraph 4 of this repor Subjec_t Item Number 498/8412-01; 499/8412-01 Review of Greater Than 2-inch Piping Material (IE Bulletin 83-06) Exit Interviewt Exit interviews were held periodically with licensee management personnel Those attending one or more of the during the course of this inspection. At these meetings , the scope and meetings are denoted in paragraph findings of the inspection were presente ,
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