IR 05000498/1986022

Insp Repts 50-498/86-22 & 50-499/86-20 on 860721-0919.No Violations or Deviations Noted.Major Areas Inspected:Design Activities,Followup on allegations,licensee-reported Significant Const Deficiencies & Previous Insp Items

ML20214F722
Person / Time
Site:	South Texas
Issue date:	11/13/1986
From:	Constable G, Garrison D, Stewart R, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214F709	List: IR 05000498/1986022 ML20214F706
References
50-498-86-22, 50-499-86-20, NUDOCS 8611250408
Download: ML20214F722 (20)

Text

r

.

. .

APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/86-22 Construction Permits: CPPR-128 50-499/86-20 CPPR-129 Dockets: 50-498 Category: A2 50-499 Licensee: Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 1 Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: July 21 through September 19, 1986 Inspectors: g [n / //Ig/,ft R. TayJor, Reactor Inspector, Project Ddte'

Sectiorf C, Reactor Projects Branch ,

DV ll Id R. C. Stewart, Reactor Inspector, Operations Date Section, Reactor Safety Branch

{ fru HIb<

1.' L. G ison, Resident Inspector, Project Dhre S'cti e C, Reactor Projects Branch Consultants: R. M. Cotapton D. C. Ford E. Y. Martindale C

Approved: , cy -

// [7 T2."c.' Coast 3 Ele, Chief, Project Section C Date /

Reactor Projects Branch 8611250408 861117 0 PDR ADOCK 0500 G

_

.- .- .. . . - - - - . _ .- .

_

~

.. .

i

,

Inspection Summary Inspection Conducted July'21 through September 19,-1986 (Report 50-498/86-22;

,

' 50-499/86-20)

i' Areas Inspected: Routine, unannounced inspection of site design activities;

,

followup on allegations; followup on licensee reported significant construction deficiencies;'and a special announced followup inspection of deficiencies

=

reported by the Construction Appraisal Team Inspection (NRC Inspection

Report 50-498/85-21; 50-499/85-19).

.

Results: Within the areas inspected, no violations or deviations were identified.

i '

i t

4 .

i

?

I

-

,

I f

i

.

9 f

)

, - - - - - , , , ,=---- - _ ,--.,,.--- - , , - . - - , - - - - , -,-. ,. - ---.-- - . . . - . . -

<

. .

DETAILS Persons Contacted Principal Licensee Personnel

• J. H. Goldberg, Group Vice President, Nuclear

• J. T. Westermeir, Project Manager

• J. E. Geiger, Manager, Nuclear Assurance '

• T. J. Jordan, Project Quality Assurance Mansger

• R. Wisenburg, Licensing Manager Bechtel Engineering Corporation

• A.-Zacceria, Project' Manager

• D. R. Quattrociochi, Site Engineering Manager

• L. W. Hurst, Site QA/QC Manager Ebasco Services In *R. W. Zaist, Construction Manager

• A. M. Cutrona, Quality Assurance Manager The NRC inspectors and consultants also interviewed other licensee, Bechtel, and Ebasco personnel during the course ~of this inspectio * Denotes those persons attending the exit interview at the conclusion of the inspectio . Licensee Action on Reported Significant Construction Deficiencies (Closed) Incident Review Committee Item Number 154 This item, initially reported to the NRC by telephone on July 26, 1983 (followup letter dated August 3, 1983), involved a finding that the Unit 1 Reactor Pressure Vessel had: (1) a tilt of the core support barrel flange of approximately .0016 inch per foot of diameter and (2) a waviness'on the same flange amounting to .018 inch peak to valley. Both conditions were beyond the Westinghouse installation tolerances. The vessel manufacturer, Combustion Engineering, and Westinghouse performed analyses which indicated the vessel tilt and flange waviness would not affect vessel stresses or reactor operability in any significant way. The detected tilt i

does not appear to represent any problem with either the installation or quality verification during the original installation in 1979 but rather has occurred because of differential settlement of the reactor buildin The building differential settlement (tilt) is within limits established in the FSAE Chapter 2. The measured building tilt and the measured vessel tilt coincide very closel No assignable cause was identified for the flange waviness. A degree of confusion appears to have existed in

. .

correspondence regarding this item as 'to wh' ether it was reportable or no The licensee's final report on this item dated February 16, 1984, appeared to indicate that the item was reportable while the attachment to the letter stated that no safety or operational problem was identified, in which case the item would not_be considered reportable. The NRC inspector

_ concurs in the latter position. This item is considered close (Closed) Incident Review Committee Item No. 174 This item related to a finding that an unqualified and undocumented weld had been made on each of four underground pipe segments associated with the auxiliary feedwater system installed in Unit 2 and later confirmed to have also occurred during the installation of similar lines in Unit This item was initially reported as a potential 10 CFR 50.55(e) item on December 2, 1983, and confirmed as formally reportable by letter dated December 29, 1983. Further review by the licensee also indicated that because the error occurred as the result of incomplete engineering on the part of Brown & Root, the item should also be reported as an item falling-under 10 CFR 21 which was done by letter dated January 20, 198 The welds involved in the finding were of an electrical cable associated with the cathodic protection system _to the pipe segments using a form of the Cadweld syste This welding system is a high heat process and when used in this form, provides a high copper bearing deposit. The basis of the concern was that the combination of high heat and high copper rendered the stainless steel pipe as potentially unfit for use in a safety-related syste It was determined that the best course of action would be to abandon the installed segments of pipe since they were in part buried under the foundation. floor slab of the IVC building. New pipe segments utilizing an entirely new routing were installed and subsequently buried. During this review, the NRC inspector verified that the new piping had been completely installed but also noted that the buried segments of the piping had been electrically insulated at both ends by special flanges and thus were not connected to the station grounding system. There was no evidence that the catho'Jic protection system grounding cables had been reconnected to the insulated segments of the pipe which could render the pipe subject to corrosive galvanic attack. The licensee subsequently provided information that indeed the cathodic protection cables had not been installed as required by the design but that the pipe had been wrapped and coated with materials that would significantly reduce the possibility of galvanic attack even in the absence of the grounding cable As a further measure, the buried pipe segments have been connected to the station ground system by removing the insulating materials in the flanges at the supply tank end of pipes which then connects the pipe to the tank's liner and hence to the station grounding system. Cathodic protection systems such as that installed at the South Texas Project are commonly installed to protect buried conductive materials at most large industrial facilities to avoid expense maintenance. These systems are, however, not considered to be safety-related in their nuclear power station

. , .. _

9 %

applications and hence the failure to install the grounding cables after installation of the new piping does not violate any NRC requirement. The licensee has investigated the reason behind the failure and found that the construction personnel responsible for piping installation failed to communicate with the electrical personnel responsible for installation of the cable Construction procedures have been revised to reduce the possibility of such an event occurring in the future. The NRC inspector considers that the licensee's actions have been appropriate to the circumstances and in the absence of any jeopardy to'an engineered safety feature, this matter is considered close . Licensee Actions on Previously Identified Inspection Findings The item numbers and titles which follow are those provided in NRC Region IV letter to the licensee dated September 24, 198 (0 pen) 85-21-01 Electrical Separation The inspector verified that program controls and specific criteria have been delineated in Standard Site Procedures SSP-45 and SSP-58. liowever, implementation of engineering and quality assurance walkdowns have not yet occurred. Consequently, evaluation of corrective action in this area could not be accomplishe (Closed) 85-21-02 Redundant Raceway Support The NRC inspector verified that FSAR Change No. 779 was issued to appropriately reflect the intent of Table 3. Additionally, recently completed engineering walkdowns have determined that no supports of this type will be affected by missile impac (Closed) 85-21-03 Conduit Support Spacing The NRC inspector verified that HL&P nonconformance report CE-03207 had been issued to document and correct this condition. The engineering disposition of "use-as-is" was approved based on the lower seismic '

accelerations expected in the building which this component was installe (Closed) 85-21-05 Traveler Documentation Errors Standard Deficiency Report E-361 was issued by the licensee to correct this condition. Evaluation initiated by this document indicates that the errors identified were the result of mistakes by one individual. Trainirg-and evaluation of all his work has occurred. Corrections to affected document packages have been mad (Closed) 85-21-06 Tray Support Bolts The NRC inspector verified that nonconformance report CE-03229 was issued to document and correct this condition. The support ceficiencies

. .

-

identified were corrected in accordance with the requirements of QCP-10.30. Deficiencies in this area were considered isolated by the NRC inspecto (0 pen) 85-21-07 Cable Separation at Equipment Entrance During review of this issue, the NRC inspector noted that recently issued design criteria which allows for physical separation of only (1") between exposed Class 1E cable and non-1E cables in conduit, does not have appropriate technical justification. The resolutions of SER open item 9 and site specific test are required before further evaluation of this item can be accomplishe (Closed) 85-21-08 Cable Separation Inside Equipment Nonconformance report SE-03233 was issued to document and correct this condition. Physical inspection of the Class 1E switchgear cubicle indicates that appropriate barriers, and conduits have been installe (Closed) 85-21-09 Conductor Spacing and Derating The NRC inspector verified that Nonconformance Report CE-03211 had been issued to document this condition, and that specific cable deficiencies identified during CAT had been reworked to meet requirement Inspection of future installations will be accomplished by the licensee during area walkdown (Closed) 85-21-10 Cable Tray Softeners The licensee issued Nonconformance Report CE-03210 to document this condition. Physical inspection verified that edge guards have now been installed, and that site procedure QCP-10.32 has been revised to require verification of this item during area walkdown (Closed) 85-21-11 Cable Protection at Floor Openings Nonconformance Report CE-3310 was issued to document and correct this condition. Physical inspection verified that Silicone Extrusions have been installed at the areas in question. Inspection of previously installed cables, revealed no areas of damag (Closed) 85-21-12 Coiled Cable Protection Nonconformance Report CE-03310 was issued to document this deficienc A review of construction activity indicates that this condition has been corrected and that current construction activity is closely monitored by

, craft and inspection personnel to assure that future cable installations will not be adversely affecte .

, .-, -~- --,

r

. .

(Closed) 85-21-13 Cable in Contact with Equipment The licensee has issued Nonconformance Report SE-03241 to document this condition. The cable in question had been reworked and examined for damag Physical inspection indicates that an edge protector has been applied to the battery rack to assure that future damage will not occu (Closed) 85-21-14 Broken Terminal Block The NRC inspector verified that an approved terminal block.was ordered and installed to replace the origina Nonconformance Report SE-03222 was issued to document this conditio (Closed) 85-21-15 Cable Terminations Nonconformance Report SE-03258 was issued to document this conditio Although the installed configuration of this termination did not reflect the design detail specified in paragraph-13.9.1 of the specification, additional information supplied by the licensee indicates that the applicable vendor drawing reverses phases (L1) and (L3) top to bottom and thus matches the as-installed configuration. Phase rotation is allowed based on the note following paragraph 13.9.1 of the specificatio (Closed) 85-21-16 Bend Radius Nonconformance Report CE-03205 was written to document ',his conditio Cables identified during the CAT inspection have been reworked, and physical inspection verified an acceptable configuratio (Closed) 85-21-17 Termination Process The review of relevant inspection records and termination activities indicates that in process inspection of terminations is occurring as procedurally required. The deficiency identified during the CAT inspection existed due to a delay in records sign off. Training has been provided to inspection personnel to emphasize the importance of accurate records annotation (Closed) 85-21-21 Equipment Weld Configuration The NRC inspector verified that the licensee had issued Nonconformance Report SE-03325 to document and correct this condition. As part of the generic deficiency identified in the Region IV N3tice of Violation 86-04-01, equipment mounting configurations were completely reinspected tay the licensee. Based upon engineering evaluation, one of the two distribution panels identified by CAT exhibited sufficient weld to e be dispositiened "use-as-is," while panel 39B was reworked to conform with the requirements of the latest design documen '

.

, .

(Closed) 85-21-22 Solder Connection in Battery Chargers Startup Work Request SWR-01757 was issued to track this -ite Special solder was ordered, applied, and inspected in accordance with the requirements of the vendors' instruction manual. Physical inspection of battery chargers ElBil-2 and ElCll-2 confirmed that corrective actions have been accomplishe (Closed) 85-21-23 Equipment Identification Nonconformance Report BE-03300 and Deficiency Report E-0632 were issued to document this conditio Physical inspection verified that proper identification tags have been installe (Closed) 85-21-45 Incorrect Code Data Report This item concerned two 8-inch check valve One valve package was deficient in that the certification of welding for the valve was not dated. Westinghouse has submitted a corrected certificate. The other valve documentation was deficient in that the bonnet material was indicated to be forged material when it was actually hot rolled and annealed plate. The documentation for this valve has been corrected by Westinghouse and resubmitted to the license Both items were documented by the licensee on nonconformance reporting document The corrective action appears to be satisfactor (Closed) 85-21-46 Lack of Documentation for Equipment to Establish Bolting Traceability This item involved 18 document packages that were not retrieved for the NRC CAT inspector to review during the inspection. Since the inspection, all of the documents requested have been assembled, the requirements for bolting extracted and compared to the CAT findings. The followup review indicates that the problem areas have been adequately researched and deficiencies noted on nonconformance documents and corrective action taken. The NRC CAT inspector followed the work and status of these items during the reinspection progra (Closed) 85-21-27 No Calculations on Sizing Skewed Welds (Closed) 85-21-56 Inadequate Engineering Evaluations of Supports The first of the above items, based on additional information obtained during the inspection from NRC IE Headquarters, dealt with a concern on who and how the loss of load carrying capacity was treated for skewed welds with an intersecting angle ranging between 30 and 60 degrees. The concern is caused by the impossibility of fusing the base metals at the point of intersection with any standard weld rod size. The codes (ASME and AWS) require an increase in the minimum calculated weld size at a ratio dependent on the intersection angle. Memoranda made available to

O e J .-

-

both the NRC CAT personnel and the NRC inspector stated that the compensation was a design engineering function and was included within the

~

required weld size indicated on engineered drawing The NRC CAT inspector originating the first concern and primarily responsible for the physical inspection of welds apparently then referred the above information to another NRC CAT inspector responsible for inspecting design activities for verification of the above responses. The latter inspector then found that a third party design review organization had challenged the site engineer's documented calculational basis for all skewed welds, including both acute and obtuse angle welds. The resolution to the challenge was a commitment to review all calculations for such welds. Documentation provided to the NRC inspector indicated the review has been completed and that the third party engineering organization has accepted the results of the revie The NRC inspector had no further questions regarding these items and both are considered close (Closed) 85-21-42 No Marking on Fasteners Approved by Specification This item concerned a weakness in the area of electrical fasteners whereby the national standard marking was deleted from the specification without consideration for contro Since the CAT findings were identified, the licensee has established a program of positive control of unmarked fasteners including the stamping of codes after verification of material An NRC inspection (50-498/86-12; 50-499/86-12) conducted after the CAT inspection has verified through 60 random samples of bolting that the correct grade of materials for ASTM A307 is being controlled. Procedures have also been revised to reflect the more positive control of material issued to the craft.

I (Closed) 85-21-43 Lack of Traceability Verification This item concerned weakness in programs to verify that proper bolting was used, especially in larger skid mounted equipment, both mechanical and electrica The licensee established a comprehensive program for the verification of bolting, including reinspection, which has been completed. Procedural changes have been made to preclude inadvertant use of improper bolting through the correct issue of bolting for specific wor (Closed) 85-21-44 Lack of Code Data Report

.

'

This item concerned the Unit I radwaste holdup tank and reactor internals disconnecting device data packages which could not be located for revie The radwaste holdup tank document package consisting or requirements in

,

'

purchase order 35-1197-4015 have since been reviewed. It was determined that the tank is an atmospheric type built to the requirements of American

. .

Petroleum Institute (API) standard 650; the verification to purchase order and specification requirements was a certificate of compliance. The code ,

data package for the reactor internals disconnecting device was received on site in mid-November of 198 This package has been reviewed and is determined to be satisfactor (Closed) 85-21-30 Deficiencies Revealed in Radiographic Interpretation This item included four welds; three on the essential cooling water system and one on the containment spray system as follows: EW 1202 FW 0027R2 - This weld evidenced thinning on the final

'

radiograph. An ultrasonic thickness (UT) measurement was conducted (report 040) subsequent to the radiograph report that indicated full weld thickness. Follov. ng the CAT assessment, a new ultrasonic thickness examination was conducted (report 2286). This report indicated thicknesses that were representative of those observed on the radiograph and were acceptable. It was concluded that the UT report 040 was inadvertantly conducted on a nearby weld and appears to be an isolated cas EW 1205 FW 14 had a linear indication adjacent to a repair are The original radiographic report did not report its natur Subsequent to the CAT assessment, a Bechtel Level III inspector reviewed the film and concluded that the indication was slag and that it meets the requirements of ASME Code. The CAT inspector re-reviewed the film and agrees with this conclusio EW 2205 FW 0009 had a penetrameter shim extending into the area of interest contrary to ASME Code requirements. Subsequent to the CAT assessment, the Bechtel Level III inspector reviewed the film and concluded that he was able to interpret this area. The CAT inspector re-reviewed the film and agrees with this conclusion. This deficiency is considered an isolated situation based upon the earlier CAT inspectio CS 2007 FW 0006 had a linear indication and two rounded indications in the adjoining vendor seam weld. The linear indication had been rejected and repaired. However, the two rounded indications had not been properly addressed on the ' radiographic report. It was the CAT inspector's judgement that they were indicative of microbiological induced corrosion (MIC). A followup investigation of this concern was conducted by the CAT inspector and Bechtel during this inspection. This investigation included the review of 19 welds on the containment spray rings in Unit 1 and Unit Many of the reviewed welds displayed rounded indications similar in nature and location to those observed in the subject weld. There were no reportable linear indications observed in the adjoining seam welds; in addition, it was construction practice to place punch marks

F

. .

at those locations for alignment purposes. The CAT inspection has concluded that the reported rounded indications are punch mark (Closed) 86-12-17 This item involver two separate issues, Yellowed film on one vendor supplie'd item from Richmond Engineerin The radiographs involved were reviewed by Bechtol Level III inspector. He concluded that the yellowing has not diminshed the required sensitivity as indicated by the penetrameter and were, therefore, interpretable. The CAT inspector agrees with this conclusion and feels that, based on the low number of films involved, this is an isolated cas An accountability program has been initiated to retrieve vendor radiographs. The program is near completion and appears to be adequate. The CAT inspector reviewed three packages of radiographs on component cooling water heat exchangers 3R-201-NHX 101 A, B, These packages were not available during the CAT inspection. No areas of concern were note (Closed) 85-21-28 Undersized Fillets on Steam Generator Lateral Support This finding was documented on Nonconformance Report CH-03036 rather than CS-03201 as indicated in the CAT report. Nonconformance Report CH-03036 has been dispositioned by the engineer "use-as-is" on the basis that loads on the welds are only about 50 percent of allowable loads and are not significently undersized in relation to the amount of over desig (Closed) 85-21-29 Weld on Weld-o-let Undersized Nonconformance Reports HP-03164 and HP-03238 were initiated and dispositioned to add filler metal as required to comply with the desi0n requiremen Since only two weld-o-lets out of 100 inspected by CAT were found to be undersized and these have been corrected, the CAT inspector judged that the licensee's actions have been adequat (Closed) 85-21-31 Design Changes Worked in Field without Proper Authorization CAT noted that electrical support 1-016-H100 had had a design change made by the field personnel without a Modification / Removal Form having been issued and, therefore, the changed work had not been reinspected. The licensee had committed to reinspect this support which has been done. The reinspection showed that the support as modified was acceptable. This was considered to be an isolated situation during the CAT inspectio (Closed) 85-21-33 Structural Steel Welds not per Drawing The beams identified to this item are utilized to provide lateral stability to main floor support beams and are lightly loaded. The small

o

- -

. .

amount of undersize of the welds (typically 1/16 inch) has allowed the engineer to disposition the three Nonconformance Reports written to document the condition as "use-as-is."

(Closed) 85-21-32 Wrong Type Globe Strut Used The globe strut material used on CAT identified supports has been removed and replaced with the correct material. The construction personnel have been reinstructed in the correct application of the double type versus the single type material. For the record, globe strut is a trade name for a commercial construction material consisting of steel sheet formed into an open sided square tube similar to Unistrut. The double type strut consists of two tube sections welded back-to-back whereas a single strut is only one such sectio .

(Closed) 85-21-60 M_ircellaneous Deficiencies in Pine Supports / Restraints Twenty additionM QC accepted safety-related pipe supports / restraints were

'

examined in the field for conformance to design and procedural requirements. See TABLE I for a listing of supports / restraints inspected and observations made. Although several discrepancies were noted, no extensive hardware concerns were identified. With the consideration that additional pipe supports / restraints will be examined by the NRC during subsequent as-built inspections, this item is considered close (Closed) 85-32-61 Pipe to Structure Clearance in Pipe Supports Documentation, including the revised specification (SL340JS1002),

procedures, and drawings were examined. One restraint of this type (RC-1125-HL5010) was examined in the field for conformance to new requirements. The inspector considers that the concern regarding this restraint configuration is now being adequately addressed and controlle This item is considered close (Closed) 85-21-62 Removal of Temporary Supports Procedures for controlling the installation, removal, and reinspection of temporary supports (SSP-16 and specification 4L360JS1000); documentation of the removal of.the supports specified in the CAT report (SWR 1527) and photographs of the removal area were examined. The inspector considers-that current procedures are adequate and this item is close (0 pen) 85-21-64 Control of the Usage of Lubricants Station procedure OPGP03-ZM-0004, Revision 1, " Lubrication Program," and specification 5L209PS1003, Revision 9, " Allowable Con'umable s Material for Use During Construction," appear adequate to assure the use of only approved lubricants on site. However, the technical manual for the RHR pumps specifies the use of FEL-PR0 N1000 anti-seize compound on the fasteners used during pump and seal assembly. The Westinghouse correspondence noted in the CAT report clearly indicates that N1000 is not

. ,

recommended for use in any area of a nuclear system due to stress corrosion cracking effect Existing documentation indicates that FEL-PR0 N1000 was not used on site during pump repair wor However, the use and acceptability of this compound by the vendor during shop assembly and the specification of unacceptable materials in other vendor manuals onsite is unknown. This item remains open pending resolution of these concern (Closed) 85-21-66 HVAC Documentation Discrepancies Seventeen current HVAC construction travelers, revised procedures, personnel retraining records, and applicable Standard Deficiency Reports (SDRs) were examined. This item is considered close (Closed) 85-21-49 Posting of Design Changes on Design Documents The licensee field document control center (FDCC) performed an audit of all electrical drawings in the Unit 1 and Unit 2 reference station The posting problem observed by the CAT was apparently isolated to recently revised electrical drawings at the one statio In addition, the procedure for update posting has been revised wherein each stations' " cookbooks" are returned to the FDCC each Friday and updated by the control center personnel. This updating procedure was verified by the NRC inspector. There was no indication that this matter was a generic problem. This item is considered close (Closed) 85-21-$0 QC Inspection of Design Changes Field change request (FCR) CC-4141, issued September 12, 1984, details the coping of CAT "A" radial and tangential nain frame steel in RCB-1. The QC inspection report (3461F1) and the Nonconformance Report (CC-03133) were both dated October 28, 1985. It appears that the CAT inspector's concern was relative to the time delay between FCR issuances (September 12,1984)

and when the rework inspection was conducted (October 28,1985).

During this inspection, the NRC inspector reviewed the document as .

referenced above. The NRC inspector observed that the final dispostion of NCR-CC-03133 is dated November 19, 1985, and evaluated as use-as-i Accessibility to the reworked structural steel members for QA inspection was apparent during the time frame involved (approximately one year).

Relative to this type of work activity, 10 CFR 50, Appendix B, does not prescribe a time limit between the completion of the work activity and the QC inspection, therefore, this matter is considered close . .

(Closed) 85-21-51 (10 CFR 50.55(e)) Traceability of QC Records to Structural Members Inspected The CAT inspectors encountered difficulty in identifying the specific installed steel which had been QC inspecte On September 20, 1985, prior to the CAT inspection, the licensee reported a potential 10 CFR 50.55(e) relative to QC documentation deficiencies i similar to the CAT findin The licensee conducted an in-depth review of this matter, wnich resulted in revision to appropriate procedures, retraining of personnel, defining-

~

mapping requirements for both bolted and welded connections and correction of documentation deficiencies. In a final report dated March 6, 1986, Incident Review Committee (IRC) 268, the licensee concluded that the deficiencies were essentially incomplete QC inspection reports and deficiencies in the mapping process associated with previously installed structural steel. There were no hardware deficiencies identified, therefore, the matter was deemed unreportabl The NRC inspector reviewed IRC 268 and observed that the evaluations and corrective actions initiated provide sufficient documentation and evidence that the matter has been adequately resolved. Both the CAT items noted above and IRC 268 are considered close (Closed) 85-21-54 Conflicting Definitions for Configuration Control Packages The CAT inspector was concerned in that drawings incorporated into multiple configuration control packages (CCPs) prior to the recent upgrade may have been subject to conflicting modification During this inspection, the NRC inspector observed that the Bechtel and EBASCO governing procedure definitions were incorporated in Revision 2, dated August 4, 1986, site standard procedure SSP-37, " Configuration Control Package." In addition, Bechtel engineering design procedure EDP 4.72, " Configuration Control Packages," was revised and issued January 23, 1986, which now mandates that, "All revisions to the CCP or new CCPs shall reflect the required sequencing of work." With regard to CCPs issued prior to the recent CCP upgrade, standard deficiency reports (SDRs) B-179 and B-181 were initiated January 27 and February 5, 1986, respectively, which contain approriate documentation reflecting a re-review of more than 300 CCPs previously issued. Of the total reviewed, nine CCPs required changes to facilitate sequencing and consistenc The NRC inspector concluded that the remedial and corrective actions taken in regard to this concern appear to be sufficient to preclude recurrenc This matter is considered closed.

I .. .

15 Potential Enforcement Actions At the time of this inspection, the licensee had not previded an official response to the Region IV Notice of Violation. Consequently, formal-review of licensee actions taken to resolve CAT identified potential enforcement actions could not be' accomplished. However, a preliminary review of actions taken to date was accomplished by the CAT inspector Results of this review are provided in the following paragraph PEA 1. A "MOV Wiring" (85-21-24)

The inspector selected the following Class 1E valve motor opreators for examinatio A1SIM0V0004A B1SIM0V0004B B1SIM0V0018B CISIM0V0018C C1SIM0V0039C C1RHM0V0060C These valves were examined in detail to assure that the hardware deficiencies identified during the. CAT. inspection had been corrected and that the existing wiring configuration was in accordance with the applicable design document With regard to hardware deficiencies, the inspector observed that the licensee's program appears to have been effective in eliminating this type of deficiency. Each of the MOVs examined exhibited good workmanship and an absence of damage to internal components and wiring. Corrective action in this area was provided through use of CIP 2.2-62, " Construction Inspection Planning for Limitorque Motor Operators," which details specific inspection requirements for acceptance of vendor and field installed M0V component As a result of the original CAT finding, the licensee has developed a Bechtel wiring diagram which provides point-to point wiring information for each M0V. Subsequent design changes are then incorporated into this document to provide " base line" design information. The inspector verified that wiring configurations within each of the MOVs examined conformed with these design detail PEA 3. A " Circuit Breaker Load Side Terminal Extenders" (85-21-19)

Licensee evaluation of this issue concluded that with the exception of two installations, the circuit breaker load side termirral extenders supplied for use at STP were not required. Consequently, the licensee initiated action to remove the extenders and connect field cables directly to circuit breaker terminals. The inspector verified this activity through examination of the following component MCC C1PMMCEC4 Cubicles - DIR, D1L, C31, C4H3, C4H2, C4K1

._

. .

MCC A1PMMCEA4 Cubicles - 4F3L, 4J2L, A4H2, 4CIL, 4E1L MCC 81PMMCEB4 Cubicles - C3R, C2L, B2L, B2R, B4H3 The inspector also verified that the installation which required the use of the supplied terminal extenders had been adequately protected through use of heat shrink tubing to prevent phase-to phase short circuit PEA 6.A " Instrumentation" (85-21-25)

Deficiencies in this area were determined _to be the result of errors by one inspector. Limited instrumentation had been completed at the time of the CAT inspection. Consequently, the reinspection of all instrumentation systems by the licensee has provided reasonable assurance that these systems conform with requirement PEA 1.6 "Mislocated Annubar Flow Probes (85-21-59) (86-21-182)

Applicable Nonconformance Reports, Deficiency Evaluation Report, related correspondence and documentation were reviewed. The inspector bad no concerns with the physical corrective actions taken on this matte PEA 6.b " Undersized Schedule 160 Socket Welds (85-21-58) (86-12-02)

Applicable Nonconformance Reports surveillances reports, revised procedures and other correspondence were reviewed. All schedule 160 socket welds had been reinspected and repaired as required. A sampling program of schedule 40 and 80 socket welds had been performe The inspector had no concerns with the physical corrective actions taken on this matte PEA 6.c Improper Fasteners in Lugged Wafter Valves (85-21-57) (86-12-03)

Applicable Nonconformance Reports, DER, SDR, and revised site procedures were examine The construction inspection planning procedure and findings for verifying proper capscrew lengths were reviewed. All valves installed with capscrews had been identified, all capscrews had been ultrasonically examined and evaluated for proper length and replacements made where necessary. The inspector had no concerns with the physical

'

corrective action taken on this matte PEA 6.d HVAC Equipment Deficiencies (85-21-63) (86-12-04)

Subsequent to the CAT inspection, the licensee reinspected five additional pieces of installed HVAC mechanical equipment. A number of discrepancies were identified on one of these items. From a review of inspection records for this item and the CAT identified discrepancies, the licensee

,

_ _

. .

-

_

,

_,

concluded'the one inspector-(now no longer on site) was responsible for the inadequate ' inspection Ho' sever', a review of these records by the NRC CAT inspection revealed.that inspection attri6utes with discrepant conditions had bien accepted by st leasttfour other QC inspectors. This involved two pieces of equipment in the original CAT sample:and the one deficient item in the licensee's followup sampl '

This inspector considers that the reinspection sample by the licergee was too small and the. determination that all of the problems were attributable to one QC inspector and n6t7 indicative of program waaknesses was in erro ~

, , --

s ,

PEA 6.d " Reactor Water Make Up Tank Foundation (85-21-63) (86-12-04)

'

, f Engineering chlculations indicated the tank was acceptable as-is'.' . Revised'

site procedures and training of personnel should preclude recurrences of this type of deficiency. The inspector dad no further concerns on this matte <

a Followup on Allegations (Closed) Allegation 4-86-A-059 ~ '

This allegation was received by NRC Region IV as an attachment t% a

'

~

complaint filed with the Departmcnt of labor in March 1986 wherein the complainant was a-former employee of ESASCO at ST The' complainant-stated that he believed that he was terminated for reporting damaging actions that were taking place'to the Unit 1 polar crane rather than the reason stated byaEbasco which was that he had refused to sign an employee ~

consent form allowing testing under the licensee!s drug and alcohol 1 testing program. By letter dated April 24, 1986, the Department of Labor notified the ccmplainant that the 00L investigation had found that the Ebasco-stated reason was, valid. _The purposs'of th.is foll(fsup was to determine the nature and extent of any possibie damage to the polar cran The NRC inspector found that some dama;e had occurred to one of the wh;els of the crane and was occasioned by using the craps to bump and :nove' the orbital service platorm which rides the,scme rail as the crane. Based upon a'n intbrview with a field engineer and review of documentation, it was learned that an engineered coupl,ing between the polar crane and the orbital service platform had broken because the design did not allow for differential movement betwden the crane and the platform during movemen The breakage was reported'on a Request for Engineering Assistance on June 1, 1985. In response, a new design was developed by the crane manufacturer and was issued as an ap' proved Field Change Request on June 27, 1985. On December 31, 1985, a Maintenance Deficiency Report was issued by permanent plant maintenance superdsion stating that the rim on oni polai' crane wheel had been damaged by. bumping into the orbital service '

,

platform. Disposition to the report, also' issued.on December 31, 1985, -

was for construction to stop the practice and reinstruct the operattrs on use of the two component The NRC inspector was informed tnat - '

construction then used a length of angle iron and a "ccme-along" to separate the two components and yet tie thent together such that the crane s

r"7

-, #

.?

<

• cauld moee the platform without bumping. The disposition also stated that

'

maintenance supervision was to arrange to have the damaged wheel examined to determine the extent of the damag A visual and magnetic particle examination was accomplished and documented on July 29, 1986, which found

.'

that the damage was a small chip to one wheel rim that did not extend-

'

further into the wheel. Installation of the redesigned coupling between the components was stated to be scheduled in the near future. Neither the polar crane nor the orbital service platform are considered safety-related but both are designed to not become dislodged and fall during an earthquake. The wheel rims do play a part in that design but since there are eight wheels at each end of the crane and only one has a small chip,

-

the damage is considered insignificant. The technical portion of the allegation is considered substantiated but also appears to have been well documented by persons other than the complainant and at a time period

.

/- somewhat earlier that the complainant indicated in his letter to be the period when he became concerne . Inspection of Site Design Activities The NRC inspector initiated an inspection of site design activities during this inspection period. The NRC inspector interviewed one of the four

-

Bechtel Project Engineers assigned to the Site Engineering Office (SE0).

The four project engineers report to the Site Engineering Manager (SEM).

Each of the project engineers has several engineering discipline groups headed by a lead engineer reporting to them. At the time of this -

inspection, SEO employed over 200 engineers with that number expected to increase in the near future as more design responsibility is shifted from the Bechtel Houston Field Office to the site. Theinterviewedproject engineer stated that the primary task of the SE0 was review and approval of FCRs and review of Field Change Notices (FCNs). Some amount of criginal design work was also being done, particularly in relation to pipe supports. The project engineer provided data to the NRC inspector that o

indicated that from 2000 to 3000 FCRs are processed each month by SE Approximately 60 percent of the FCRs relate to piping and/or piping

,

'

supports with the balance essentially evenly distributed among the other

'

engineering disciplines. The NRC inspector inquired as to the purpose of FCRs versus FCN The NRC inspector was informed that an FCR was tne

, vehicle for documenting a request for change to engineered drawings where s a published design could not be installed within the parameters allowed by specification. The FCN is used to document such changes that are allowed by specification so as to provide as-built information. The NRC inspector was also informed that SE0 designated personnel of the Ebasco field engineering organization may provide initial approval of both documents to allow the work to' continue. Because of the scope of site design activities, further NRC inspection will be required.

.

, h No violations or deviations were identifie . , - -_ ,

, .

.y (

,

' - f

'

. 1

... , ,

,

1 j, i

-

i 19 4 Exit Interview The NRC inspectors and.NRC consultants met with the licensee management .

and their staff at the conclusion of-the inspection to inform them of the

1. '

disposition of the followup on the CAT items. Other findings were discussed with established management representatives during the course'of the inspection.

,

r

i

.

,w ,

r --

,, -- ~ - , - - - - . ~ , a.,---- -,- --n,,- - - - - , - ,,-.---,e- ,- , -, , , ~ ~ .- -- - - - - - ~ ~ ~ - < - - - - -

. . ... . . . . . _ __ ._

-

,. . . -. ..

?

I

-

TABLE I

.

_

Pipe Support / Restraint Inspection Sample Support / Restraint Observations' >

AF-1005-HL 5003- None

-

AF-1054-HL'5003 . None-AF-1054-HL 5008' None AF-1006-HL 5024 None

[ AF-1006-HL 5011 - ' Non ' '

. CC-1111-HL 5002 '

. None-

.

CC-1115-RR 16  : Two each item'14 rotated 90, degrees

. reducing weld lengths CC-1414-HL'5007 - - None-

',. RC-1000-SH 02 Two loose locknuts

' P.C-1003-HL 50071 One missing cotter pin in struct load pin

. RC-1123-HL 5008~ None

RC-1123-HL 5011 None RC-1125-HL 5010 Drafting / design error - no hardware effect RH-2304-HL'5003 None

"

- SI-1105-RR'28- None

. SI-1106-RR 09

'

Strut / pipe clamp removed without

,

documentation

~

SI-2105-RR 40' None SI-2106-RH 064 Nohe SI-2205-HL 5016 None SI-2313-HL'5001- None

. .  ;

,

.

t

,

1 h " -h F P 4 4-- e -+

-wm +1,--4- --->y n- -1- -

g *emem+m-y .yiy emw=p5-w+.w-.m44.ry MT--te.-y%- ws p we = * p-9t-Nt'++=6--ry y-