IR 05000498/1986010
| ML20199F281 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/13/1986 |
| From: | Constable G, Garrison D, Clay Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199F268 | List: |
| References | |
| 50-498-86-10, 50-499-86-10, NUDOCS 8606240251 | |
| Download: ML20199F281 (13) | |
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s APPENDIX U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-498/86-10 CPS:
CPPR-128 and 129 50-499/86-10 Dockets:
50-498 and 50-499 Licensee:
Houston Lighting & Power Company (HL&P)
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:
April 4 through May 30, 1986 Inspectors:
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'E. 'Johry!lon, Senior Resident Inspector 06t4 Project Section C, Reactor Projects Branch J
l 3l,f7-D,L.Garfison,ResidentInspector, Project 06tf '
Section C, Reactor Projects Branch Other NRC personnel:
J. F. Lara, CO-0P Student Approved:
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G. L. Constab'le, Chief, Project Section C, Dat'e
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Reactor Projects Branch Inspection Summary Inspection Conducted April 4 through May 30, 1986 (Report 50-498/86-10; 50-499/86-10
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Areas Inspected:
Routine, unannounced inspection of licensee action on previous inspection findings, IE Information Notices, concrete activities, allegation followup, inspector identified findings, electrical activities and Deficiency Notices (DN).
8606240251 860618 PDR ADOCK 0500
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1 Results:
Within the scope of this inspection, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- S. Head, Lead Project Compliance Engineer
- C. McIntyre, Site Project Engineer
- T. Jordan, Project QA Manager
- D. R. Keating, Operations QA General Supervisor
- G. B. Rogers, Construction Manager
- E. B. Miller, Deputy QA Manager
- S. M. Dew, Deputy Project Manager
- W. H. Kinsey, Plant Manager
- D. J. Cody, Manager NTD
- . R. J. Daly, Startup Manager Other Personnel Bechtel Power Corporation (Bechtel)
- J. B. Gatewood, Project QA Engineer Ebasco Service, Inc. (Ebasco)
- R. G. Peck, Deputy Project QA Manager
- J. R. Narron, QA Site Supervisor
- W. J. Taylor, Assistant Construction Manager
- Denotes those individuals attending the exit interview conducted on June 2,' 1986.
The NRC inspectors also interviewed other licensee personnel and personnel of Bechtel Power Corporation and Ebasco Service, Inc.
2.
Site Tour The NRC inspectors made several site tours in order to assess construction in progress, general cleanliness and housekeeping activities, condition of equipment, and plant status.
The following areas of the plants were inspected:
mechanical electrical auxiliary buildings, containment buildings, paint shop, fuel building, and essential cooling water structure.
i-No violations or deviations were identified.
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3.
Licensee Action on Previous Inspection Findings (Closed) Violation 8602-01 This item concerned the failure to provide written instructions or procedures in the area of nonconformance reporting. The licensee did not have a method for reporting procedural violations including hold points not verified (missed).
The licensee has amended the required documents to include instructions covering the area of concern.
(Closed) Unresolved Item 8217-05 and 8209-10 This item concerned the exclusion of nuts in a 50.55(e) report pertaining to A-325 bolts. The licensee undertook a program which consisted of complete testing of a valid sample of nuts for applicability in safety-related (SR) systems. This testing proved the integrity of the nuts whether used in SR or non-nuclear safety (NNS) systems. The licensee response and action to clarify this item appears to be adequate.
(Closed) Unresolved Item 8210-01 This item involved the tightening of anchor bolts and the calibration of wrenches. The tightening requirements and calibration frequencies were found to be satisfactory.
(Closed) Unresolved Item 8210-02 This item involved proof load testing of galvanized bolts. The test data has been acquired for all of the SR and NNS bolting and found to be satisfactory.
(Closed) Unresolved Item 8217-04 This item questioned materials used and retrievability of documents on the steam generator lateral support bolts. All bolts, nuts and washers have been verified as being of the correct materials.
(Closed) Open Item 8308-03 This concern involved the locating of Brown & Root training records. All training records have been located and filed except for two which are not available. Bechtel has conducted an independent anchor bolt / embed evaluation program (combining analysis and testing) that provides assurance that the field-fabricated safety-related anchor bolts and embeds meet project requirements. At the point in time of the inspection, no violation or deviation was involved.
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(Closed) Unresolved Item 8313-02 This item of concern was that zinc plated A-490 bolts were being used.
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has been established that no zinc plated A-490 bolts are in the STP design and/or being used.
(Closed) Unresolved Item 8320-06 This item concerned loads to expansion anchors set in concrete vs. grout, and required engineering calculations to prove design.
The design and recalculation provide data that indicate the adequacy of using grout to set bolts.
l (Closed) Unresolved Item 8320-07 This item concerned the replacement of anchor bolts with 1" Kwik Bolts.
It has been verified that drilled and grouted anchor bolts (Fy = 36KSI)
were used in lieu of 1" Kwik bolts.
Except as noted, no violations or deviations were identified in this area l
of the inspection.
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Licensee Identified Items 50.55(e)
(Closed) IRC #126 This discrepancy concerned six Essential Cooling Water (ECW) strainer backwash discharge lines which were inadvertently classified as NNS lines and were built as such.
A second backwash line in each of the six units (Safety Class 3/ Seismic Category I) have been installed. Also, operating procedures and the FSAR have been undated to reflect the re-analyzed-rebuilt system.
This item is considered closed.
(Closed) IRC #165 This item concerned the specifying of passive Auxiliary Feedwater valves when active valves were required.
In an SSE event, the passive valves could not perform in a containment isolation mode. Qualified valves have been purchased to replace the old ones. These are listed in Table 3.9-1.2,
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Active Valves in the FSAR page 3.9-88e.
This item is considered closed.
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5.
Allegation Followup
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l (Closed) Allegation 4-85-A-096 (Coatings Application)
Details (Part 1)
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On September 18, 1985, at approximately 8:00 a.m., an individual expressed his concerns about coatings applications and personnel problems to the
resident inspector and a regional inspector.
It was alleged that small areas of coating repairs and touch-ups were
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allowed to be performed without QC coverage.
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The specification defines a small area as being an area of 30 contiguous
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square inches or less.
j Sumary u
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Discussions and interviews with Bechtel engineers, craft painters and Ebasco coatings QC inspectors indicated that small areas of coatings repairs and touch-ups of less than 30 contiguous square inches are
allowed. This is not against site procedures and specifications. The intent of allowing 30 square inches as stated in the FSAR, is not to j
exceed approximately 25-50% of the surface area.
If it exceeds the j
majority of the surface area, it should be reworked in accordance with STP quality site safety procedures / specifications with QC inspections.
Interviews with QC, craft painters, and engineers indicated that the intent has been followed. Also, Bechtel is making a statement by way of a i
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change to the specification to clarify the intent. This allegation was substantiated; however, the intent has not been violated.
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Details (Part 2)
i It was alleged that HVAC duct was prime-coated without proper surface preparation; stitch welds were not properly cleaned; and HVAC duct pieces that had been sandblasted, primed, and allowed to remain unprotected in the coatings yard had become exposed to the elements causing rusting, which had not been removed before additional coatings application.
Summary Discussions with Ebasco Field Engineers, painters, and QC indicated the following:
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Carbon Steel HVAC is sandblasted in the paint yard prior to installation.
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When stitch welds are added to HVAC after installation, the welds are inspected by welding QC before any coatings are' applied. This inspection would require that the flux be removed.
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- t (3) When HVAC duct pieces show evidence of rust spots caused by outside
t storage, the pieces are spot blasted or sweep blasted before any
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further coatings application.
This allegation was not substantiated by the NRC inspector.
Details (Part 3)
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It was alleged that two sections of an orbital bridge crane (Polar Crane)
from Unit 2 were not adequately protected during nearby sandblasting and painting operations. Also, protection was not provided for the machinery
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on these sections. Observation by the NRC inspector indicated that the orbital bridge crane had been reworked and top-coated.
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Summary Interviews with personnel involved indicated that the orbital bridge crane sections were not adequately protected. A DN had been initiated and appropriate corrective action was taken. The foreman stated that he personally sweep-blasted all the parts of the orbital bridge sections.
The NRC inspector examined the sections for possible damage to any
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machinery parts. The polar crane is not functional safety-related and must only stay in place in a seismic event. There was no apparent damage i
and all openings were masked for protection. This allegation was substantiated, but corrective action had been initiated and completed.
l Conclusion Based on the investigation by the NRC inspector, the allegations that were substantiated were identified and appropriate corrective action was taken.
No further action is needed. This allegation is considered closed.
(Closed) Allegation 4-86-A-002 Concrete Pour Packages Details A person called the NRC Regional Office to report that the review of concrete pour packages being performed by Bechtel has indicated that certain documents are not. included in the packages. These items are listed on punchlists and are not being resolved.
Summary
Prior to the implementation of Standard Site Procedure (SSP) 56, dated February 3,1986, several procedures governed the packaging of documents.
As problem areas were noted, the records were returned to the records
group and were worked off as data became available. The past and current procedure and pour files include a matrix of required documents. When the matrix in each folder is complete, a computer listing is updated to
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indicate the status and the package is sent to the vault.
If a problem is noted by a reviewing group, it is tracked on a Records Deviation Report in accordance to SSP 56.
This allegation was not substantiated.
Conclusion Each pour folder includes a listing of all documents required for closure of the file.
No evidence was found to indicate that all documents were not accounted for.
The Technical Adequacy Review Program (TARP) is responsible for records completeness.
This allegation is considered closed.
(Closed) Allegation 4-85-A-008 (Rehire of employee, altered steel pipe heat numbers, falsification of welder's certification)
Details An anonymous caller contacted the NRC office and alleged that he had the name and job of a once-released employee who had been improperly rehired.
He stated that this employee had once been caught cheating to keep his welder's certification current.
He resigned due to this, was rehired in another capacity, and fired from that job.
He was rehired in another position for the same company.
This was felt to be against site employment policy.
It was also alleged that this individual, when in an earlier supervisory position, had told the alleger to affix altered heat numbers to pieces of steel pipe which had none.
The alleger remained anonymous.
Summary i
This allegation was turned over to the site Safeteam to investigate.
Their findings substantiated the allegation of attempting to falsify his welders certification.
However, through discussion and interviews with management of HL&P, the investigation indicated that the supervisor in question did not actually commit the act of falsification of his welder certification since he was never certified.
It was not substantiated that he told the alleger to affix altered heat numbers to pieces of steel pipe.
Conclusion It is true that the supervisor was rehired, but not in a supervisory position.
The Labor Stabilization Agreement gives management of the Constructor and Owner an opportunity to discuss and decide whether an employee can return to work.
In this case, they felt that the employee's
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past record warranted another opportunity.
It was managements decision to rehire the employee. This was based on the site employment policy and the Stabilization Agreement.
This allegation is considered closed.
6.
Licensee Commitments To The Technical Evaluation of Anchor Bolts The licensee, in a letter to the NRC dated March 30, 1984 (ST-HL-AE-1075),
committed to performing seven separate tasks, each of which was designed to provide additional information to the validity of the previously reviewed " Technical Evaluation of Anchor Bolts." This report evaluated NRC concerns in the area of civil bolting materials. The following lists the commitment and NRC review comments.
(Closed)
1.
"A verification of the heat treated condition and accurate hardness of installed anchor bolt heats of A193.B7 material which exhibited apparent high or variable hardness ranges in earlier tests by portable hardness test equipment."
It appears that the sampling which indicated high hardness was due to improper surface preparation in the field. The laboratory analysis indicates that the affected materials meet the requirements of ASTM-A-193-B7. The NRC inspector reviewed the Report on the evaluation in the licensees response letter to the NRC (ST-HL-AE-1111) pages 8-38 of 161 and concludes that the materiel in question is correct.
(Closed)
2.
"A demonstration, if possible by direct non-destructive testing, that there is a high probability that A193.B7 rods have not been welded to significant safety-related embeds."
This program was to verify the acceptability of welding ASTM-A-193-B7 to ASTM-A-36 plate and tested to destruction. The 30 samples tested failed at tensile strengths which exceed that required of ASTM-A-36. The study in this area is reported in the licensee letter and report to the NRC (ST-HL-AE-1176), approximately 75 pages. The NRC inspector reviewed the report of the tests and concludes that the program was adequate to establish the integrity of the welding of A-193-B7 bar to A-36 plate.
(Closed)
3.
"A review by HL&P of Brown & Root, Ebasco and Bechtel NCR's pertaining to the anchor bolt / embed evaluation to verify appropriate disposition."
This item has been reviewed as committed to and is reported in the
" Technical Evaluation of Anchor Bolts and Embedded Rods," section 3.
The NRC inspector reviewed the 20 pages of NCR dispositions versus identified problem and each appears to be satisfactory.
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(Closed)
4.
"A demonstration that the review of Brown & Root procurement by Bechtel/HL&P has been adequate and reasonable and that the potential for future reportable concerns in this area is acceptably small."
The licensees response and programs were reviewed and appear to be satisfactory.
The review is recorded in the licensee letter to the NRC (ST-HL-AE-1111) pages 44, 45, and 50-54 of 161 and specifically items A, B, C, H and L and attachments.
(Closed)
5.
"A demonstration by a thorough and comprehensive
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review of the Brown & Root material control program by HL&P/Bechtel that the potential for future reportable concerns is acceptably small."
The licensees review and reporting of this item is demonstrated in the Technical Evaluation and in (ST-HL-AE-1111) pages 46, 47, and 50-54 of 161 and explanatory attachments.
(Closed)
6.
"A confirmation that CMTR's provided for threaded fasteners and anchor bolts are in accordance with project requirements."
The licensee commitment has been addressed as noted in items 4 and 5, Summary of individual reviews and attachments and are satisfactory.
The licensee's letter to the NRC (ST-HL-AE-1138) addressed items 4, 5, and 7 concerning the 100% review of the Bostrum-Bergen Quality Verification Documentation.
(Closed)
7.
"A determination of the adequacy of the present record control systems to ensure that Brown & Root construction inspection records are used with up-to-date supplements so that j
superseded information in records is not erroneously used to the l
detriment of reactor safety."
The record control has been continuously evaluated for adequacy of records, retrieval, and completeness, the latest of which was an indepth review of concrete pour records.
The inspection program for the site and the traceability of commodities as established in the CAT inspection verified that this area appears to be satisfactory.
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7.
Deficiency Notices The NRC inspector reviewed procedure QCP-15.1, " Identification and Control of Deficiency Notices," and had discussions with various discipline QC inspectors on the method of documenting the deficiencies identified.
i During these interviews with various discipline QC inspectors, it was apparent that there was some misinterpretation by different disciplines on how these deficiencies should be documented.
Paragraph 5.1.1.B of the
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procedure explains how these deficiencies should be documented, however
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the word "may" was interpreted by some disciplines to mean that deficiencies of the type that meet the requirements of paragraph 5.1.1.B do not require documentation on the inspection report or a DN.
It was apparent that clarification was necessary.
This was turned over to HL&P QA to resolve.
HL&P's investigation also indicated that clarification was necessary.
Standard Deficiency Report (SDR) H-275 was initiated documenting the discrepancy.
Corrective steps to prevent recurrence were initiated by the licensee are listed below.
. Interoffice Correspondence STP-QC-1353 was issued to all QC supervisors giving instruction on how discrepancies should be noted.
. SSP-8, Revision 2, dated April 21, 1986, has incorporated the requirements of QCP-15.1.
. Classroom training to SSP-8 is being conducted for all Ebasco Services Inc. Quality Control personnel during which the instructions contained in #STP-QC-1353 are emphasized.
. Additionally, ICN #5 to SSP-8, dated May 19, 1986, has been initiated to further clarify the procedural requirements.
The NRC inspector will monitor this matter during a subsequent inspection.
8.
Concrete Dome Placement Unit 2 The NRC inspector observed the concrete dome placements 2RC-W-205-031 and 2-RC-W-209-033.
Each placement contaiced about 300 cubic yards of concrete.
Observations indicated that proper consolidation and good industry practices were being followed.
The only problem observed was a broken slick line which was immediately repaired and concrete pumping activities resumed as normal during placement 2-RC-W-205-031.
There is one placement left before topping out on the Unit 2 dome.
Records reviewed were legible and complete.
No violations or deviations were identified.
9.
HVAC The NRC inspector observed the use of Carboline Caulking Compound 225 applied to an embedded angle for HVAC systems in the MEAB.
An air pressure leak test was performed to determine if the caulking would prevent leakage of air from the system.
Observation indicated that the Carboline Caulking Compound 225 may resolve the leakage problem around the embed angle.
HL&P has had problems with the leak test of HVAC systems as reported in previous inspection report 86-06.
They had originally used Dow Corning sealant 999 and 795 which apparently was unsuccessful in stopping the
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leaks. The NRC inspector also reviewed the design basis accident (DBA)
I tests results of Carboline Caulking Compound 225. 'It appears to be an
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adequate product, however, additional evaluation is being done because this product contains about 5% asbestos.
10.
Electrical Activities
a.
Bend Radius and Pull Calculations I
The NRC inspector. inspected two electrical cable conduits to verify
that appropriate procedures were adhered to when cables were pulled through the conduits. Standard Site Procedure (SSP) 27, Revision 1
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and Interim Change Notice 5 require that tension calculations be
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performed on cable pulls when cable lengths exceed those specified in Attachment SSP-27-1 for a particular conduit size with a certain total bend radius. Tension calculations must also be performed when the total bend exceeds 360 degrees. When calculated tensions exceed
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70 percent of the maximum allowed pull tension, a calibrated tension
meter or dynamometer must be used to assure that the maximum allowed tension is not exceeded.
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The NRC inspector examined conduits ERAIXC4CRH001 and ERAIXC4CRS002
which were determined to have a total bend of 450 and 405 degrees, i
respectively. The NRC inspector met with Quality Control (QC)
j inspectors and asked to see the appropriate tension calculations and j
inspection reports. The inspector examined Cable Pulling Calculation CCC0310 and determined that no tension meter was required to be used i
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exceed 70 percent of the maximum allowed tension. QC inspection
reports were reviewed for completeness and were determined.to be
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satisfactory.
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b.
Torque Values For Electrical Raceway Supports t
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The NRC inspector reviewed SSP-28, Revision 2, which specifies the
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minimum torque values of Globe strut bolts allowed in electrical i
raceway supports. The inspector reviewed Measuring and Test Equipment Issue / Record Sheets issued for the torque wrenches that
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were used to torque raceway support strut bolts. These records were
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examined to verify that the strut bolts were being torqued to the minimum required torque value. Review of three torque wrench issue sheets indicated that the correct wrenches were used to torque strut
bolts in the Unit 1 Mechanical Electrical Auxiliary Building and Fuel
Handling Building.
Further review indicated that raceway support
strut bolts were being torqued to at least the minimum required i
torque value, torque wrenches were not used within the lower 20 percent of full range as required by Quality Control Procedure 12.1, Revision 5, nor were they used past the end of-the calibration interval.
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Cable Tray Supports Review by the NRC inspector of the cable tray supports in the three switch gear rooms in the EAB and discussions with electrical QC inspectors indicated some confusion of drawing 0-E-55032 series.
These drawings indicated welded connections to " Existing Steel," and note 13 of drawing 3-E-56-0E-55032 states that " Existing Steel" could be wide flanges, insert plates, channels or plates attached to the decking.
This meant to QC and construction that you could obviously weld a conduit support to any wide-flange member, in this case to cable tray supports in the switch gear rooms.
QC was given direction later from site Engineering that the wide flange members for cable tray supports for the switchgear rooms were not intended to be utilized to support conduit.
This created confusion and also contradicts the criteria of note 13 of 0-E-55032, sheet C.
The NRC inspector had meetings and discussions with HL&P, Bechtel and Ebasco personnel to resolve the issue.
This issue was initially identified by Ebasco electrical QC by a Request For Engineering Assistance (REA) #E-2-86-074.
A response to the REA was initiated.
This response included clarification of " existing steel" and generic relief that will be used for the remaining installations.
This relief will permit the attachment of items identified in DCN #3 to drawing 9-5-37002, Revision 6; DCN #5 to drawing 9-S-37050, Revision 7; and DCN #3 to drawing 9-S-37149, Revision 3, to the cable tray hangers without documentation when the tabulated limits are not exceeded.
The response also included six NCR's for which existing installations will require a review by the Constructor to identify those cases where this generic relief was violated, and these violations will be documented on the NCR's.
The response was reviewed by the NRC inspector and appears to be adequate.
11.
Exit Interview The NR' incnactor met with licensee representatives (denoted in paragraph 1) o.. June 2, 1986, and summarized the scope and findings of the inspection.
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