IR 05000498/1986003

Insp Repts 50-498/86-03 & 50-499/86-03 on 860113-0725.No Violation or Deviation Noted.Major Areas Inspected:Review of Litigation Records,Followup on Significant Const Deficiencies & IE Info Notices & Quality Class Insp Program

ML20206S819
Person / Time
Site:	South Texas
Issue date:	08/28/1986
From:	Constable G, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206S815	List: IR 05000498/1986003 ML20206S811
References
50-498-86-03, 50-498-86-3, 50-499-86-03, 50-499-86-3, IEIN-83-20, NUDOCS 8609220382
Download: ML20206S819 (14)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMISSION ' J  ; i REGION IV

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NRC Inspection Report: 50-498/86-03- Construction Permits: CPPR-12 /86-03 CPPR-129

          .1 Dockets: 50-498        'l-50-499  -

Licensee: _ Houston Lighting & Power Company (HL&P) P. O. Box 1700-Houston, Texas 77001

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Facility Name: South Texas Project, Units.1 and 2

 ' Inspection At: South--Texas Project, Matagorda County, Texas Bechtel. Power. Corporation, Houston, Texas
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Houston Lighting & Power Company, Houston, Texas s,

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Inspection Conducted: January 13 through July 25,e 198 >

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R G. Taylor} Project Inspector _

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- L. Cons 1.RJe, Chief, Project Section C,  Dat'e 7 '

Reactor Projects Branch i

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Inspection Sumary ' ' Inspection Conducted January 13 through July 25, 1986 (Report 50-498/86-03; !. 50-499/86-03) [ Areas Inspected: Routine, announced inspection of licensee action on previous !

 - inspection findings; followup on allegations; review of litigation records;

, followup on significant construction deficiencies;.IE Information Notices; mechanical containment penetrations; and Quality Class 7 inspection program Results: No violations or deviations were identified.

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_.; , . DETAILS . 4

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Principal Licensee Employees ,

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 *J. Westermeir, Project' Manager     ,
 *T. Jordan, Project QA Manager
 *C McIntrye, Project Engineer
 *S. Head, Compliance Engineering, Supervisor
 *M. Wisenburg, Manager Licensing     s  ,

, The NRC inspector also interviewed other personnel of Bechtel Poweh Corporation, EBASCO Services Inc., and the license . Licensee Action on Previon Inspection Findings , The following item, refer to paragraphs of NRC NUREG-0943 which was a special NRC inspection report of the Quadrex Corporation Report on Design Review of Brown & Root Engineering Work for the South Texas Projec Appendix A of the report listed a number of items that the special inspection team recommended further followup when more information became available. NRC Inspection Report 50-498/84-11;'50-499/84-11 discussed the findings regarding many of the items designated by Appendix A to be the responsibility of Region IV. This report discusses the findings on the balance of the items in the Region IV scop (Closed)Quadrexparagraph4.2.2.1(e): Quadrex paragraph 4.2.2.1(e) expressed a concern that computer generated design calculations were not subject to the same level of control as manually generated design calculations. NRC Inspection Report 50-498;499/84-11 documented NRC , review of a substantial number of calculation and verification packages and found compliance with Bechtel Engineering Department Procedure 4.37 titled, " Design Calculations." The NRC inspector reviewed the above procedure, including change notices 7 through 11, and found the procedure provided the same controls to both manual'and computer generated calculations. No additional calculation packages were reviewed. This item is considered closed.

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 (Closed) Quadrex paragraphs 4.1.2.4(v) and 4.6.4.4(f): These Quadrex paragraphs expressed concerns with Brown & Root's staffing continuity fer performing seismic evaluation and for considering valve performance qualification requirements. The NRC inspector reviewed Bechtel Design Criteria document 4E019NQ1009 " Equipment Qualification," Revision 5 dated September 12, 1985, and Project Engineering Directive 015 Revision 4 dated March 5, 1986. The former document provides technical criteria for seismic, environmental, and operability evaluations. The latter document provides the administrative and interface controls to implement the former
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  -document. The NRC inspector determined that these items should be closed .

since Brown and Root is no longer involved with the STP site, the Bechtel documents appear to be adequate and the area. of equipment qualificatio'n -is now subject to stringent review by the NRC under 10 CFR 50.49:and' continued,' separate followup via these Quadrex items would be redundan These items are, therefore, considered closed. '

  (Closed) Quadrex paragraph 4.4.2.1(c): This' item expre'ssed a concern by'

the Quadrex reviewers that Brown & Root had not properly, examined lthe , reactor containment building for possible locations of hydrogen gas concentrations following a design basis accident. Itlw'as'also'noted Brown & Root had used an allowable hydrogen gas. concentration'in the* , battery rooms higher than recommend by the NRC.. By review of HVAC,and building drawing, Bechtel has-established that there are no areas,in the containment. building that would allow hydrogen to locally concentrat Bechtel calculation package 3V-11-0-M6-5143 indicates that greatest hydrogen gas concentration in any of the battery rooms will be 0.4 percent of volume, well below the maximum of 2 percent recommended by the NR This Quadrex item is considered close .

  (Closed) Quadrex paragraph 4.1.2.4(r): This item expressed a concern that the Brown & Root methodology for analysis of the load capacities
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of walls in various buildings might not be sufficiently rigorou Bechtel had committed to perform a review of the designs as part of the standard design evaluation process. The NRC inspector was informed that all scheduled calculations had been completed except for the Mechanical-Electrical Auxiliary Building which was 50-60 percent complet , The NRC inspector selected the calculation package for the fuel handling building as typical of the design process. This. calculation package, C-8010' Revision 1, was reviewed and found to be thorough in its treatment of seismic loading of the walls in the building. The methodology being used appeared to be consistent with the requirements of ACI-318-71 and the NRC Standard Review Plan. This item is considered close (Closed) Quadrex paragraph 4.3.2.1(m): This item addressed a concern that the Brown & Root methodology for assessing the manual operability of-various items of equipment in a post-accident environment appeared inadequate. The NRC has provided' guidance and requirements addressing this concern via item II.B.2 of NUREG-0737. The licensee has responded via amendment 45 to Section 7A of the FSAR. Bechtel has developed and implemented Project Engineering Directive 011. "ALARA Directive" which also requires a design review to assure operability and maintainability of l systems and components under all operational conditions for. compliance to i 10 CFR 20. Since both the NUREG 0737 and ALARA confonnance are subject of - I ongoing NRC inspection and review culminating prior to operating licensee i issuance, no further examination of this Quadrex item is considered

necessary and the item is, therefore, considered closed.

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  (0 pen)Quadrexparagraph4.1.2.3(m): This Quadrex item contains two

, essentially separate concerns. Concern a. was relative to the interface l between Brown & Root engineering and vendors in regard to equipment l ! L . - - - - - . - _ _. . - . . - - . . . - . - - - -

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seismic qualification while concern b. involved a perceived problem with-the Brown & Root review of the selection of materials and welding processes. The NRC inspector detennined that concern a. should be closed for the same reason noted above relative to paragraph 4.1.2.4(v) and , 4.6.4.4(f) above. Based on the Quadrex report and on-NUREG 0948, it ' appears the primary Quadrex specific concern was in the selection of materials for the spent fuel pool liners and that~ the materials actually used were not adequately reviewed by Brown & Root' engineering for compliance to requirements. The NRC inspector was provided with' documentation that indicated the vendor prepared certified material test- ~ reports and welding procedures had been reviewed by~Bech'tel and'had been found acceptable. TheBechtelworkpackage(EN-619)Talso,scommitted to' ' performing a visual inspection of the pool l liners as part of the - resolution of this item. . The NRC inspector reviewed a report of a speciill inspection of the liner by personnel of the Materials and Quality Services organization of Bechtel National, Inc. The report indicates that.they : found no evidence of cracking or detrimental heavy oxide in.the area of ' J interest. This Quadrex item is considered close c 1 s , Followup on Allegations (Closed) Allegation 4-86-A-025 (inadequate training and supervisory overview) On March 7,1986, the NRC Headquarters Duty Officer heceived'a telephone call from the alleger. The alleger indicated.that: (1)hewas laid off his job as an -inspector with EBASCO because of a personality conflict, (2) he had received no training regarding his required paperwork and that interpretation of QC procedures was left up to the individual inspector, and (3) the supervisors did not conduct surveillances in the field and did not adequately check paperwork prior to sending it to the vault.

c The Headquarters Duty Officer referred the above allegations to Region IV l personnel who, in turn, recontacted the alleger. The alleger then stated that he had already reported his concerns to the EBASCO headquarters in NewYorkandthathealsodesiredtoadviseHL&P(thelicensee)ofhis allegations. He indicated that he had no objections to being contacted by the STP Safeteam personnel. The alleger was advised during the contact with the Region IV person that he could report his layoff and the reason

  .for the layoff to the Department of Labor for review and investigation if

, he chose since the NRC had no immediate' jurisdiction.

l . ! In a letter dated April 21, 1986, Region IV referred allegations (2).and (3) to the licensee for investigation by their Safeteam in accordance with the alleger's wishes ard NRC policy. The licensee responded with a letter dated June 2,1986, stating that their investigation had revealed that the alleger had not attended any of three scheduled classroom training sessions regarding one specific procedure that the alleger had informed the Safeteam was the core problem. The licensee stated that a review of quality data for a period prior to and after implementation of the new procedure, which was a consolidation of other long used procedures,

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revealed no_ discernable differences in the~ deficiency rates. The licensee

  'did find that improvements could be made in-the training program that-would make it more. meaningful. In~ regard to the third allegation, the
 . ' licensee stated that.while there was no procedural requirement for-supervisory surveillances or for paperwork. reviews, other than for
  . completeness, an informal program in the surveillance' area had been; implemented in March 1986b as a response to the NRC construction' appraisal
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  -team inspection. The. licensee stated that they had found that there were; no safety concerns uncovered during their' investigation'of these allegations.

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 , The NRC1 inspector reviewed both a preliminary and final Safeteam-investigation report concerning these allegations and'had the benefit of -

discussions with the'Safeteam investigators involved. The investigators found_that the alleger had, in fact, missed the scheduled. training class

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  ;on the site procedure involved,'in part, through_his own fault and, in part,-be'cause of his work day assignments. The investigators.also found that there was no provi'sion in the training program.that would-identify ~.

personnel Who had missed scheduled. training and provide them with the necessary-training. The investigators also found that some of the training given was,'in part, inadequate since the instructors were in some cases ill prepared to' answer questions from the trainees. Based upon a-survey of a significant number of inspectors, the investigators found tha percent of the inspection personnel felt the' training given was

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adequate while 44 percent felt that it wasninadequate. The survey also indicated that training in procedures, other than the one of concern, was generally' considered adequate by the inspectors. Since the training given the alleger had only been to' complete reading assignments of revisions to the procedure after-the initial procedure training and that the alleger had not received any formal classroom training, the allegation was considered substantiated by the Safetea Regarding the allegation concerning supervisory surveillance, the Safeteam found that while there was no procedural or program requirement for^such surveillance, the EBASCO QC group had. initiated such an activity. The Safeteam also found that the various supervisors were not consistent with each other in their approach to or thoroughness in conducting the surveillances. The investigators found that-the surveillance program is under review by quality management both in EBASCO and Bechte Based upon the absence of any written program requirement for the surveillances, the investigators concluded that the allegation was not substantiate Regarding.the allegation relative to the inadequacy of supervisory review of records prior to sending them to the vault, the investigators found

 . that the supervisory reviews were only for correctness and completeness in the view of the supervisors. This view was confirmed by' review of the applicable site procedure.~ The investigators also found that the licensee's QA group had found problems with the supervisory review, apparently independent of the investigation, and was requiring some as yet unidentified corrective action. Based upon the licensee's QA concern, the Safeteam concluded that the allegation was substantiate .,

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s D -6-Based upon the interview with the investigators, the NRC inspector concluded that the , investigation by the Safeteam had been thorough. The NRC inspector also~ agreed with the investigators conclusions as to whether the allegations were substantiated or not with one exception.' In the allegation concerning the lack of supervisory field surveillance of their subordinates, the conclusion was that the allegation was unsubstantiated because of no procedural requirement. The report indicates that there was an informal supervisory surveillance program albeit inconsistently and apparently infrequently implemented. The NRC inspector concluded this allegation was also substantiated. The NRC inspector also concluded that there are limited safety implications inherent in the allegations on the basis that if the training given inspectors was inadequate and supervisory overview was poorly applied, it could indicate that inspectors performance could be less than desired which, in turn, could lead to deficient installations. In the absence of any known situation of deficient quality

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arising that is directly connected to the allegations, the NRC inspector can only conclude that no NRC requirements have been violate This allegation is close (Closed) Allegation 4-85-A-061 (pipe design specifications) The NRC received allegations, first by telephone in May 1985, which.was followed up by a letter in February 1986, to the effect that piping design specifications were being misused and that piping in the Primary Process Sampling System (PPS) could be overstressed in terms of ASME code _ allowables. The NRC inspector utilized the following documents ~during the course of his review of the allegation. The marked *.was specifically referenced by the alleger in his lette . a.* Criteria for Piping Design, SL01PS004, Revision 7 ,

     ' Criteria for Piping Design, SLO 1PS004, Revisioq,9 { Piping and Instrumentation Diagram, Primary ~ Sampling System, 5Z329Z00045, Revision 2 Design Criteria for Process Sarr.pling System, 5Z329Z1017, Revision 3 Specification for Process Sampling System, 9Z329Z0110, Revision 5 Primary Sampling System Isometric Drawing, SM369PPS285, Revision 1 Primary Sampling System Isometric Drawing, 2C369PPS485, Revision 4 Penetration M85 and M86, drawing 802185, Revision 3 ASME Code, Section III, Subsection NC-1974 Piping Minimum Wall Thickness Calculation 2L010PC5208, dated August 5, 1986

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 :The allegation indicated that sheets UB'and UD-of reference a. showed tha't -

7 pipe: sizes-ranging from 1/2 to 24 inches could be used in the PPS which7

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has a pressure-rating of 2485 psig at a temperature of 650*F. 'The alleger stated that his. calculations' indicated that any pipe over 1 inch would be overstressed at these pressure / temperature combination The NRC-

 : inspector made calculations in accordance with reference'i. whic confirmed.the.allegers statement. The alleger l implied that he believed piping larger than 1 inch had been used in the-PPS, particularly in-containment penetration area.. References c.-through h. indicated,
,  however, that all piping is 1 inch in size except for extensive use of    ,

tubing specified to be 3/8 inch by '.065 inch wall thicknes # The NRC inspector also found that reference b., a more current?. version of the' document referenced by the alleger, no longer indicated that class UB \ , pipe-would be used in the applicable portion of the PPS. Based on V c

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 ; reference j., references c., g., and b. have now all been revised to   e M require the use of BB pipe. The effect of these changes has been to.'   - w" change the piping from 1 inch schedule 40.(UB)' pipe to liinch" schedule s -

160 (BB) pipe. . Discussions with design engineering personn'el }evealed x that even though the schedule 40 pipe was acceptable for the .- .( , pressure / temperature combination, there was so-little margini'only aboutt

  .001 inch in wall thickness, that if the site used dot impression stamping for traceability marking of the pipe, there would not,be. sufficient wall ' i'"  ,
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already schedule 160, using the same size and-schedule onlboth sides;of s the penetration would somewhat facilitate field-installationi ,< .

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allowed by pipe class sheets UB and UD would be operating well-beyond the ' allowables of ANSI B16.5. The NRC inspector verified by review'of references c. and g. that no flanges of any pressure rating:are utilized in the PP The alleger further appeared concerned that reference a'.'f(or b.)'was being used as the primary vehicle to communicate design requirements relative to piping. The NRC inspector found that this reference is one of two middle level design documents utilized. The top level document for the PPS is the Westinghouse NSSS design criteria. The next lower level would be of ,

 ~the calculation type documents, one of which was reference j. The two middle level documents were references a. and c. The final output document for site use would be reference f. (or g.) and a bill of materials for fabrication. The only possible application of reference ,

in the field would be where the engineer in preparing the isometric drawings and bill of material might specify a particular pipe schedule and material by one of pipe class sheets such as BB. Each of the sheets is  ; organized to deal with a full range of pipe sizes of one scheadle and of  ; one type of material such SA-312 stainless steel pipe. Thus, in the class of BB, the engineer would be specifying the use of a given size of pipe as displayed on the face of the isometric, of schedule 160 and that the i

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stainless stee By way of perspective, the pipe involved in each of the four process lines of the PPS working at the pressure / temperature combination of1 concern.is about 13 feet in each run of which 5 feet are a part of flued-head forged penetration. The balance of each run is made up of the tubing previously mentioned and amount to 70-80 percent of the total of each ru The concerns expressed by the alleger were not substantiated by the_ NRC , inspecto C .

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This allegation is close ' l -

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4. Inspection of Litigation Review Program ' x

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The licensee, by letter dated August 30, 1985, forwarded a document titled

" South Texas Project Litigation Review Program," for review and comment by NRC Region IV. The purpose of the program was to review a substantial volume of records that were generated in the course.of the litigation to identify any safety issues that might not have been othemise identifie Any such issues identified by the review rising to the level of 10 CTR 50.55(e) would be reported to the NRC. The program referenced above was divided into two stages. Stage one was an initial screening to eliminate any documents from stage two review that were unlikely to contain any technical information. Stage two was the review by S. Levy, Inc. personnel of the documents containing technical information for safety issues. The NRC inspection of stage two has been documented in NRC Inspection Report 50-498/85-23;50-499/85-20. The inspection discussed hcrein was for the purpose of evaluating the licensee's implementation of stage one. The NRC inspector initially interviewed the attorney and the engineer who had performed the stage one screening for the most part. A second attorney-engineer team had performed a small part of the initial review subject to a reverification by the first team. The second team performed the reverification overview when the first team was the primary reviewer. The NRC inspector reviewed the informal procedure utilized by these teams for conducting and documenting the review .

The procedure required that for each document reviewed, the initial review team would generate a summary document describing the reason a record did not require S. Levy, Inc. review and was signed by the team. The overview team also signed the summary to denote their concurrence. The NRC inspector examined these records pertaining to each of the documents reviewed during this inspectio The NRC inspector selected documents from each of the three categories of documents filed with the court during the litigation. In the category titled " Expert Witnesses" the inspector reviewed: Trend Analysis of Brown & Root Deficiency Nonconformance Reports

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  -9- Damages to STP Report of Project Management and Project Controls In the category of depositions, the NRC inspector reviewed the depositions taken of two high ranking officers of Brown & Root, two high ranking officers of NUS Corporation (an engineering consultant to Brown & Root)

and an engineer employed by Central Power and Light who had an involvement in the early phases of STP. In the category of interrogatories, the inspector selected for review only the. responses by Brown & Root (B&R) to ' the interrogatories directed to B&R by the other parties on the basis that only B&R could reasonably have the technical information pertinent to stage two. This group of 56 interrogatories were summary reviewed to verify that most had been sent to S. Levy, Inc. The 13 fully excluded interrogatories were completely reviewed. Some questions and answers in eight additional interrogatories were partially excluded with all exclusions again fully reviewed by the inspecto Based on the sample described above of the documents excluded in whole or in part from the S. Levy, Inc. review by stage one screening teams, the NRC inspector concluded that stage one teams had been conservative in the performance of their review It is considered unlikely that any documents, or portions thereof, were improperly excluded from the stage two revie No violations or deviations were identifie . Followup on Licensee Reported Significant Construction Deficiencies (10 CFR 50.SS(e))

(Closed) Incident Review Committee Item No.'23 This item, originally reported to the NRC on October 25, 1979, related to findings during a design review that a weld in the containment recirculation sump penetrations could be overstressed under certain loading combinations and could cause safety systems to malfunction. The original designer, B&R, redesigned the sump to pipe connection and that design was implemented as reported to the NRC in May 1980. When Bechtel Power Corporation assumed design responsibilities from B&R, a reassessment of the entire sump and isolation valve enclosure system indicated that there would be serious future maintenance and inspection problems with the then inplace installatio A redesign was undertaken and implemented which obviated both the original issue and subs'equently discovered potential maintenance problem. The present design is described in Chapter 6.2 of the FSAR. The NRC inspector'had no further questions and this item is considered close (Closed) Incident Review Committee Item No. 170 This item involved a finding during a stress analysis of containment penetration assemblies M85 and M86. It was found that the fillet welded connections between the carbon steel penetration header plate and the penetration pipe passing through the plate could be overstressed in

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operation due to temperature cyclir.g. A second problem was also identified wherein the concrete of the containment wall surrounding these penetrations could be heated above ASME code allowables by heat radiating from the pipe. The solution to the first problem was to. redesign penetration assemblies. The redesign utilizes a flued-head forged single unit system where there are no bimetallic welds at points of high temperature cycling. The second problem was corrected by'providing forced flow cooling air to the interior of the penetration to remove the excess heat. By review of design drawings for the penetration assemblies and the HVAC system, the NRC inspector determined that the changes have been implemented and had no further question (Closed) Incident Review Committee Item No. 204 '

'This item involved a finding that NPSI had supplied rear brackets for snubber assemblies that tended to interfere with the paddles of the snubber. The rear bracket is the trade name for "u" shaped bracket that is fixed to the building or other structure into which the snubber will then be attached such as to allow loads imposed on the-snubber to be transmitted to the building or structur Snubbers are either mechanical or hydraulic devices that can lengthen or shorten at very slow rates but lockup when sudden' loads are applied and thus serve to restrain movement-in seismic or comparable events. The interference was such as to prevent
< design movements of the snubber within the bracket. Incorrect brackets were identified and replaced with acceptable units. Action was also taken to prevent. recurrence by restructuring the source inspection effort at NPS The NRC inspector had no further question No violation's or deviations were identifie . Review of Licensee Actions Regarding IE Notices (Closed) IE Information Notice 83-020: Mechanical Snubber Attachment Interference This notice concerned the interference of snubber rear brackets with snubber paddles similar to that described in paragraph 5 above relative to Incident Review Committee Item 204. Since the licensee had used only brackets suppled by NPSI, the corrective actions taken satisfy the intent of this Notic No violations or deviations were identifie . Inspection of Containment Mechanical Penetrations 1 The NRC inspector selected the following mechanical penetrations for inspection of this area of construction activities, all in Unit h. .
  -11- Equipment Hatch Safety Injection System penetration M-10 Auxiliary Feedwater penetration M-83 Main Feedwater penetration M-5 Containment Spray penetration M-9 Equipment Hatch A review of installation records for this component revealed that it had ,

been field installed into the unit 1 containment liner during the period of May to October 1977, by the Pittsburgh-Des Moines Steel Company (PDM).

A review of NRC inspection reports during the period 1976-77 indicated NRC personnel had reviewed the PDM quality program including welding procedures and welder qualification. These reports indicate that while problems were identified, they were quickly and effectively correcte f.2C Inspection Reports involved are 50-498/76-05, 76-07, 77-04, 77-05, and 77-09. The NRC inspector examined to the extent possible the installed barrel assembly that penetrates tle containment wall for any evidence of damage or mishandling since installation. The important barrel to head sealing surface was found to be adequately protected. The factory fabricated closure door for the hatch was hoisted well above the opening and was not accessible for examination. The NRC inspector reviewed the factory fabrication records for the closure door including certified material test reports and radiographs of five of the welds that were used-to fabricate the dished head and surrounding ring of the door assembl * The materials were either SA-516 Grade 70 or SA-537 Class 1 as required by specification 2C269550006, all revisions through 5. The records reviewed indicated the door had been fabricated in full accordance with the applicable ASME code, Section III, Subsection NE-1971.through the winter 1973 addend Penetration M-10 ,

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This penetration consists of a flued-head type one piece forging of SA-182 F-304 stainless steel. The forging was furnished by National Forge to Gulf & Western Company who finish machined the' forging and performed the nondestructive tests of the component except for the volumetric ultrasonic examination which had been accomplished by National Forge. The NRC inspector examined the certified material test report, the ultrasonic test report and liquid penetrant inspection report. All complied with the ASME Code. The forged component was welded to the penetration sleeve via FW-0041A as shown on isometric 4C69 PSI 472, sheet 7, Revision 5. This and the balance of the field welds to be discussed later were all made under the licensee /EBASCO ASME pipe welding quality progra The NRC inspector examined the radiographs for this weld and found them to comply with code requirement ex .

  -12-Penetration M-83 The penetration is a flued-head forging of SA-350 LF-2 carbon steel with an SA333-6 pipe welded to the outer diameter of the forging which effectively extends the containmeat sleeve. Thc-forging to pipe weld was accomplished by the vendor. The rough forging was furnished by Earle Jorgenson Co. to Gulf & Western for final finish while the pipe was
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furnished by Phoenix Steel. The certified material test reports for both components were found to comply with the Code requirement The radiographs for the factory weld described fully complied tt. requirement The penetration component was welded to the containment sleeve via FW-0021 shown on isometric 2C369PAF402. The radiographs and other welding records were examined and found to be satisfactor Penetration M-5

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This penetration is also a flued-head single piece forging of SA-350,LF-2 ' material but has no extension pipe attached. Jhe forging was made,by ' National Forge which also performed the ultrasonic examination. Gulf and Western finish machined the forging. It was found after receipt of the component at the site that forging had been furnished oversized at the outside perimeter which connects to the penetration sleeve. Gulf & f Western had failed to remove enough material from the inside to the outer rim of the forging which would create an unacceptable inside' diameter-mismatch at the welded interface to the sleeve. Records indicate the component was returned to the vendor for correctio Radiographs of'the field weld, FW-001 on isometric 2C369PFW433, indicate the. correction was , satisfactor Certified material test reports for the forging material' also indicated compliance with SA-350 requirements ~. Penetration M-9 This penetration is again a single piece flued-head forging of SA-182 F304 stainless steel material as furnished by National Forge who also'per. formed the ultrasonic examination. The component was welded to the' penetration sleeve via FW0053 of isometric 2C369PCS41 The radiographs ~and other records indicate that this weld is in compliance with requirement In addition to the data reviewed as described above, the NRC inspector examined four each mainstream, main feedwater, and auxiliary feedwater penetrations as installed for any indication of damage or mishandlin The field attachment welds had been ground essentially flush with the forging and connecting pipe which facilitates any future inservice inspection. The penetrations did not indicate any evidence of mishandling at any time during the crection process. Examination beyond that described was limited by access to the components necessary for a more detailed inspectio No violations or deviations were identified in this are . _ . - . - . - - - - - . . - -

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3: Based upon discussions with'other NRC' inspectors, this NRC inspector hp p reviewed the quality program instituted by the licensee for what is L described as Quality Class:7. 'In accordance with Bechtel specification N '- '7A050GS1006, Revision 2, this quality class encompasses the quality program' requirements for design, fabrication, installation, and inspection-of:

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1 < . Items a, b, and d, abovelare in response to NRC Branch Technical Positions and/or Regulatory Guides which include quality program requirements of their own and do not reference Appendix B to 10 CFR Part 50. These programs generally do not require implementation of a rigorously documented quality. program and give the licensee considerable latitude, particularily in the area of inspection and process controls. Item c, however, stems from Regulatory Guide 1.29, position C.2. Position C.4.'of' this Regulatory Guide also requires that pertinent requirements of -

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Appendix B be applied to' activities related to Position C.2. The licensee has committed to comply to Regulatory Guide'1.29 without exception. -It-would appear then that the licensee's quality program should comply:with 7

,  Appendix B in che manner that is described in the licensee's'NRC! approved Quality Assurance Program Descriptio The Quality l Assurance: Program
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Descriptionindicateslbywordsandorganizationichartsthat'a1.1inspe'ctib activities under Appendix B will be accomplished'by'qualit I6ntr.01 S * inspection groups independently managed within each~of the.si,te - s contractor The licensee ~is committed'to maintenance'oflan: overview ' . function for all quality activities. Thd:above referenc'ed specification while generahy describing prograin requirements, essentially ;1ea'ves uthei

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methodofimp}ementationuptotheBechtelConstructionManagement. - - organization. ;The Bechtel Project Quality Program Manual,- Appendix C-Part 3 indicates that Construction Manager,1but not Quality Assurance, shall have procedures, instructions and/ specifications ( implementing the inspection aspect of the quality program. Based on discussior.s with licensee personnel, including the Project QA Manager, it has been confirmed that the actual inspection work has been assigned to the constructor's (EBASCO) field engineering force rather than to his QC group. Organizational 1y, these field engineers are an integral part of construction organization and assist the craft superintendents in obtaining installation materials from the warehouse and providing technical;, assistance at the worker level. The program does require that the field engineers document their inspection in much the same way that a QC inspector would have to. The assignment of this inspection activity to , ,

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field engineer is not described in the FSAR or in the Qudlity Assurance'; Program Description. This does not imply'that the licensee is in 'j ' ., noncompliance since Appendix B allows considerable freedom in the/ - structuring of organizations. To avoid confusion the licensee has comitted to clarifying his comitments in this area either by revision to the FSAR or the Quality program Description as appropriat ' 9. Exit Interviews-The NRC inspector met with appropriate licensee representatives several times during the course of this inspection to discuss the findings applicable to each phas The persons denoted in paragraph 1 attended one or more of the meeting J a O I

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