IR 05000498/1986023

Insp Repts 50-498/86-23 & 50-499/86-21 on 860601-0830. Violation Noted:Failure to Follow Storage Requirements & Work Procedures

ML20215F750
Person / Time
Site:	South Texas
Issue date:	09/25/1986
From:	Constable G, Garrison D, Clay Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215F735	List: IR 05000498/1986023 ML20215F731 ML20215F742
References
50-498-86-23, 50-499-86-21, NUDOCS 8610160359
Download: ML20215F750 (16)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/86-23 Construction Permits: CPPR-128 50-499/86-21 CPPR-129 Dockets: 50-498 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: June'l through August 30, 1986 Inspectors: h

. E. Jofinson, Senior Resident Inspector, 9 ff!//

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O Project Section C, Reactor Projects Branch

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h D.'L.~Garrifon, Resident Inspector, Project flW8 D&te/

Section C, Reactor Projects Branch Other NRC personnel: J. F. Lara, CO-0P Student

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E L. CoTistaole, Chief, Project Section C, Date '

N Reactor Projects Branch Inspection Summary Inspection Conducted June 1 through August 30, 1896 (Report 50-498/86-23; 50-499/86-21)

Areas Inspected: Routine, unannounced inspection included site tours, licensee action on previous inspection findings, concrete activities, material control, 8610160359 861008 PDR ADOCK 05000498 G PDR

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reactor coolant pressure boundary hydrostatic test, reactor vessel and internals, mechanical components, safety-related piping and. safety-related pipe support and restraint' system Results: During this inspection two violations'were'. identified (failure to follow storage _ requirements and failure to' follow procedures, paragraphs 1 and 11.d).

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DETAILS

. Persons Contacted Principal Licensee Employees

• Kinsey, Plant Manager

• S. M. Dew, Deputy Project Manager

• J. T. Westermeier, Project Manager

• J. E. Geiger, Manager, Nuclear Assurance

• G. B. Rogers, Construction Manager

• T. J. Jordan, Project QA Manager

• A. C. McIntyre, Principal Engineer

• J. Hughes, Startup

• S. M Scott, Lead Project Compliance Engineer

• S. D. Phillips, Project Compliance Engineer Bechtel Power Corporation (Bechtel)

• R. H. Medina, QA Supervisor

• L. E. Davis, Construction Manager

• L. W. Hurst, Project QA Manager

• W. Humes, Site Project Engineer Ebasco Service, Inc. (Ebasco)

• R. G. Peck, Deputy Quality Site Manager

• R. W. Zaist, Construction Manager

• A. M. Cutrona, Quality Site Manager

• Denotes those individuals attending the exit interview conducted on August 29, 198 The NRC inspectors also interviewed other personnel of HL&P, Bechtel Power Corporation, and Ebasco Service, In . Site Tour The NRC inspectors made several site tours in order to evaluate housekeeping practices, cleanliness, status of the plant, and equipment storage. The areas of the plants inspected were; containment, mechanical electrical auxiliary building, fuel building, diesel generator building, isolation valve cubicles, warehouses, and outlying area No violations or deviations were identifie <

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, Licensee Action on Previous Inspection Findings (Closed)U[resolvedItem 498/8606-04

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This unresolUed item concerned the use of Dow Corning 999. sealant around

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embedded angle for HVAC systems to prevent air-leakage. There were three issues that were not addressed. The first was an instruction of the

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1 method of application of the:Tresco gasket tape and Dow Corning #999

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sealant. The application observed in the field by the NRC inspector was different from that given by the qualification test plan. Second, the ( test plan did not take into-account the back pressure escaping underneath 4 .the embedded angle iron as described in the observation. Third, there-4 were no. test results for revie The. licensee has since decided-to use a qualified product manufactured by

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-Carboline in place of Dow Corning 999 for'this application which has been DBA tested. This product was also tested in the field by the licensee to l . determine if back pressure would be a problem. It appears to be ~

satisfactory, i (Closed) Violation 498/8606-02 This item concerned failure to follow procedures resulting in the incorrect installation of two thimble guide tubes as depicted by approved design drawings Quality control. inspectors approved all of the seal

, plate connections even though two were misconnecte The corrective action taken by the licensee included a reinspection of all j' the incore instrument tubes to ensure they were installed in their correct location on the seal plate. The above discrepancy was corrected by realigning and= rewelding the tubes in the proper locations. Quality control inspectors were reinstructed to perform inspections using only tho

, latest approved engineering design document (Closed) Violation 498/8606-01 This_ item concerned failure to perform work with an approved control

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-document. As a result of an Ebasco Request For Engineering

p Assistance (REA), work on the incore instrumentation system seal plate was performed utilizing a Westinghouse Field Deficiency Report (FDR). This

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, was-in violation of Quality Assurance procedures since a Westinghouse FDR is not an accepted craft work authorizatio The corrective actions taken by the licensee included a review of closed

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. Instrumentation and Control REA's. -These REA's appropriately directed

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construction-to perform work according to approved Bechtel design documents. Craft Supervisors and Field Engineers were reinstructed that p REA's and FDR's must not be used for co.nstruction.

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(Closed)-Violation 498/8317-01 This item concerned the failure to maintain identification and control o structural materials. A paint code was used for maintaining traceability which was not satisfactor The NRC inspector has verified through a reinspection in the warehouse,

-laydown yard, and fabrication shop that the previous methods used for materials control are no longer used. Verification consisted of inspecting cut-up material for. marking, traceability and stamping. The stamping is performed only after complete verification of' mill test

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reports and user tests. All material is stamped with a heat number or

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code depending on its intended us Complete records are maintained for the materials cut-from stock. The NRC inspector also verified this item through review of inspection reports, material logs, user testing and the Material Test Report (MTR). Observation of the. process and documentation was found to be satisfactor No violations or deviations were identifie .

- Concrete Activities ,

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- Containment Dome (Unit 2)

The~NRC' inspector observed the last placement'on Unit 2 Containment dome. Observation indicated that all activities'were conducted as planne No discrepancies or difficulties were observe Core / Pilot Drilling in Concrete ,

Several areas of work in the concrete outer shield wall in the containment were inspected for conformance to the specification, SA010-SS-1000, Revision It was found that the pilot drilling was in accordance with the specificatio t No violations or deviations were identifie , Material Control (Management)

b The NRC inspectors were briefed by HL&P and a Bechtel-representative on t the recent changes in the management of the material control area. Some e changes involved consolidation of personnel positions which resulted in a single organization and included reassignment of responsibilities of

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i various managers. More rigid control of material has been implemented by establishing mini-warehouses closer to the place of work. The main:

warehouse will now only issue a 10-day supply of material to the construction crafts which will help maintain bgtter material control.

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The effectiveness of: this reorganization will be assessed in future

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inspection No violations or deviations were identifie ' Reactor Coolant Pressure Boundary Hydrostatic' Test a .- Procedure Review The NRC inspectors were-concerned about the level.of detail regarding-inspection of welds, both shop and field, that were included in the final documentation of this= test. This concern arose because:the-7 Pressure Test Data Sheet included in' SSP-12, "rroject Generic -

Pressure Test Procedure," allows only for the signature of one constructor inspector and one authorized Nuclear (Code) Inspecto The test plan however, was to have a total of 13 crews composed of a constructor inspector and a code inspector with each crew responsible for a specific area of the overall system. The project issued Interim Change' Notice (ICN) J to Revision 2 of the procedure which included a supplemental sheet to the Test Data Sheet that identified all line segments included within the test boundary. This sheet has places for signoff of each segment observed by each team so as to-properly support the single signature. on the top level record. It was noted that the individual piping welds are not specifically-documented in the test packag Piping ~ isometrics are' referenced which in turn reference spool drawings and thus account for all weld Procedure SSP-2 requires a 100 percent ~" hands-on" examination of the piping on each isometric pipe drawing included in the boundary to observe any leakage or. signs of stress at the test pressur Observations The NRC inspectors observed a portion of' the reactor coolard. pressure boundary hydrostatic test. The; observation by the NRC inspectors-took place when the pressure was.at about 2800 psi. At that point-the inspectors accompanied the test enginee_rs to various areas to  ;

inspect the piping system.' During the inspection the pressure was increased to.3100 psi. There were'no. apparent discrepancies in the reactor-coolant loop except for some leakage in No. 4 pump 0-ring'.

Overall the test was, satisfactor ~

No violations or-deviations were identifie . Reactor Vessel and Internals , QA Review (Procedures)

The NRC inspectors reviewed site' procedures'and held discussions with construction personnel to ensure that NSSS vendor requirements for the protection of the reactor vessel and internals were adequately-being' addresse The following procedures were reviewe . .

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Westinghouse Process Specification 597760 - Cleanliness

' Requirements During Storage, Construction, Erection, and Startup-Activities of Nuclear Power Systems

SSP-52, Revision 1 - Installation, Assembly and Disassembly of Permanent Mechanical Plant' Equipment

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QCP-13.1, Revision 7 - Storage and Maintenance Inspection / Verification-

CSP-12, Revision 5 - General Instructions For Housekeeping During Construction -

Westinghouse Specification 597760 defined the degree of cleanliness required throughout storage, construction, and startup activities of .

nuclear' power system It is intended to serve as guidance for the

. contractor so as to adequately protect equipment, including the reactor vessel'and internals, and to' prevent the presence of foreign matter which could affect the operation of such equipmen SSP-52 provides-instructions for the installation, assembly, disassembly, and inspection of mechanical equipment. This procedure described the methods used to document work activities pertaining to,

'or in the surrounding area of, the reactor vessel and internal Work packages are used to compile necessary documents needed for the work activities. These packages consist of installation travelers which provide a step by step outline of the work activity to be-performed. . Precautions to be-taken during such activities to prevent damage or contamination of the vessel and internals are~also noted on-travelers. Wcrk:p'ackages are routed to the Westinghouse office for concurrence prior to~ initiating work activity.

, Procedures QCP-13.1 and CSP-12 establish housekeeping and maintenance

programs to assure that the quality of equipment is not degraded due to housekeeping _ practices or work activities. These procedures

. describe housekeeping and inspection requirements to prevent damage '

to permanent equipment. Discussions with construction personnel indicated that they were familiar with the above procedures.

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i Work Observation

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The NRC inspector made several observations pertaining to th protection of Unit 1 and Unit 2 reactor ve'ssel and internal ~

Adequate preventive measures were implemented to prevent the entry of foreign objects into.the open vessel.~ Visual observation indicated

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that the area around the-reactor vessel was clean and dry.

1 Protective covers were in place to prevent dust accumulation.

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The NRC inspector observed startup personnel installing and torqueing closure stud bolts on the assembled reactor pressure vessel in

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i Unit 1. This activity was performed in preparation for primary hydrostatic testin The inspector observed that external stud threads were properly lubricated prior to being inserted into the stud hole. The studs were lifted and lowered into place by the radial arm hoist assemblies. Bolt-up procedure for hydrostatic testing was a three phase procedure with an adjusting phase to bring elongation for all studs into the desired tolerance range. For the hydrostatic test, the nominal stud elongation was 0.098 i .002 inches as required by Plant Maintenance Procedure OPMP04-RX-001 Discussions with startup personnel indicated they had a clear understanding of operations procedures and their required dutie Appropriate procedures were available in the work package and in us c. Records Review The NRC inspector reviewed Westinghouse Construction Services Group records to verify the completeness of all work traveler packages pertaining to work perrormed on the reactor vesse The inspector examined several work traveler packages pertaining to the assembly of the reactor vessel upper internals and other related work activities associated with the reactor vessel. The packages reviewed were:

. T-TGX-003 . T-TGX-015

. T-TGX-005 . T-TGX-048

. T-TGX-006 . T-TGX-077

. T-TGX-007 . T-TGX-080 These work traveler packages included step by step instructions for the work activities. Required inspection hold points were signed off and associated field change / design change documents were referenced in the package The NRC inspector reviewed the qualification records of the personnel ,

involved in-performing the work activities. These records indicated '

that personnel were adequately trained and qualified to perform their assigned dutie No violations or deviations were identifie _ . _ . __

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- Mechanical' Components -

a, . Fuel Transfer Canal ,

.An inspection of the fuel _ transfer canal..was performed:in order to assess the condition-and status-of the. assembly. All~ parts. visible

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were inspected'in the_ fuel building'and containment. It was observed

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that the safety-related portions of the assembly, including the tube,.

bellows, sleeve, and closures and attached components were in i accordance with the drawings.

[t-This componentLhas not been completely finished, hydrostatic tested, or final. inspected. The bellows protection and other work is yet to j= be complete ,

The drawings and specifications used are' listed below:

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Westinghouse Drawing 1209E54 & 1217E32 general Bechtel Drawing 3F26-95-3020, Revision 7 - details-

'Bechtel Drawing ~ 3C26-9S.1515, Revision 2 - details

Bechtel Drawing 3C01-9S-1548,' Revision 4 - details

PDM Drawing 329, 311, E7 - layout i Bechtel Specification 4F269SS0008, Revision 5 - tube

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Bechtel Specification 9E199ES1009, Revision 2 - conduit j Pathway Inc. Drawing D3-2693 & D2-2693 - bellows i Kerotest "Y" Valve

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. An inspection of a Kerotest ASME class 1 valve, serial'No. DAP6-2, in-

the chemical'and volume control system was performed in order to l- access the adequacy of the installation. This valve.is a motor operated valve'between the reactor cross-under piping and the excess

[ letdown heat exchanger. This valve was observed to be welded to'the

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piping at an' excessive angle from horizontal.

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! In coordination with the ANI, the NRC inspector.and Ebasco level III i ' radiographer reviewed the radiographs, process sheets, and data

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-packag The valve was welded at 5 degrees from horizontal which is-2 degrees aoove permissible; a Field Change Notice had been generated which approved the deviation.

. ~It was concluded that the valve to pipe welding was in accordance-with the ASME cod Inspection of Disassembled Valve

An inspection of the internals of a kerotest metal diaphragm valve

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was made'with the licensee in order to assess the possibility of internal damage during a water hammer event.

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The valve inspected was one of two' motor. controlled 2-inch diameter-safety injection valves involved in'a water hammer situation in which~ ' _

 - a 2-inch diameter pipe was fractured down stream of the valves. This item was previously reported in NRC Inspection Report 50-498/499-06, paragraph ' -
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The body internal surfaces, disc; assembly and motor drive were found

 . to be in satisfactory condition with minor evidence of wea No violations or' deviations were identifie , . Safety Related Piping-Piping Orientation / Configuration

An; inspection of the configuration of the main steam line in the "C" , isolation valve cubicle was performed to Drawing 2G396PMS646, sheet 8, Revision 5. No discrepancies were noted concerning this aspec Two socket welds on the main steam piping were also inspected and the traveler packages were' retrieved from the vault and reviewed. It was determined that the welders were qualified to the correct procedure for'the welding performed. .The field welds examined were 30MS-100-3-GA2-FW11323, 11324, and FW007 made by. welders with codes PYC, FKS,_FGE, and PB . No violations or deviations were identifie . Structural Steel and Supports Steam Generator Structural Bolts The bolting for the. steam generator and reactor coolant pump vertical

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o columns _at elevatio~.. - 11 feet (floor) and + 16 feet:(ceiling) were

 ' inspected to verify conformance to the drawings for torque. Through review of the. documentation, the NRC inspector determined that the bolting had been inspected for location and torque'(3000 Ft-lbs) and was'in accordance-with the Specification 2C26-95-1001, Revision 0 and '
 ' 2C26-95- 1003, Revision Semi-Automatic Refueling Machine An inspection of the structural bolting on the refueling machine was performed in order to verify that the correct bolting materials were being used. . The' inspection focused on the bridge trolley and t

overhead structural frame / hoist. The inspection was performed to the

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Refueling Machine Technical Manual Volume'1, Revision _ - - _ - -

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A sample which included a majority of the bolting was inspected and determined to be ASTM-A-307 and A-32 No violations or deviations were identifie . fafety-Related P!pe Support and Restraint Systems Procedures / Specification Review The NRC inspector reviewed Procedure SSP-9, " Pipe Support Installation," Revision 4, and Specification SL340JS1002, " Pipe < - Support Field Fabrication ar.d Installation," Revision 10, pertaining _ to pipe supports and restraint systems. The procedure is the combination of QC and construction work procedures. It was found that adequate technical acceptance criteria has been implemented in both specification and procedure. However, one case was identified where the procedure could be enhanced in the area of spring hanger inspections. Review of the inspection forms for spring hangers revealed that there are no inspection attributes except for verification of the spring hanger model number. There were no inspection attributes to verify travel stops or cold and hot settings. After the review, the NRC inspector was informed by the licensee that procedures will be developed for final balancing of th system to verify cold and hot settings. Field Change Request (FCR) BJ-1126 was initiated to assure that travel stops are verified by QC upon final acceptance. Review of procedure / specification by the NRC inspector indicated the following: Manufacturer's instruction are used and incorporated with work procedures Procedure / Specification have been reviewed and approved as required Procedure and Specification both address small bore and large bore pipe supports

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Controls have been established to ensure that the type and classification of supports systems comply with approved design drawings and specification Fabrication / installation requirements have been incorporated into both the specification and procedure Overall suffic % nt technical criteria for installations and fabrications have been implemented into both the specification and procedur +,

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  .12 Observation of Work and Work Activities Personnel Interviews Interviews and discussions with Quality Control (QC) and Quality Assurance (QA) personnel indicated the following:
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Personnel were knowledgeable of technical criteria and QA commitment Personnel engaged in the installation of safety-related pipe supports and restraints appear to have adequate training to perform special processes contained in inspection procedure Manufacturers instructions and installation requirements are used in conjunction with site prncedure Interviews with these personnel indicated that QC has sufficient

. knowledge to adequately perform their duties in the pipe support are p Installation Activities    W
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The NRC inspectors observed and examined QC accepted pipe supports and restraints in two systems (Main Steam and Residual Heat Removal).

During this examination the NRC inspectors observed attributes such as: Support type and classification

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Location and orientation as given by design drawings Components free from corrosion or deterioration Dimensional requirements and pipe support clearances

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Bolts, nuts, clamps, washers, locking devices, and fasteners are tight and secure Correct material and size Connecting joints, moving parts are free from foreign material Weld acceptability and size During this inspection the NRC inspectors identified four discrepancies as listed below: Support No. RH-1303-HL5005: jam nut loose

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    ;.. Supports No. MS1150-HL5003 and MS1148-HL5003: bottomed out due to removal of travel stops and temporaiy supports Support No. MS1148-HL5003: Welder.ID identified on the hardware but was not documented on the AWS welding checklist Support No. RH1205-HL5013: WF 6X15 bent and the spring can on
'the eastside was loose (not carrying any load)

Discrepancies Nos.1 and 4 were' isolated case NCR's were initiated by the licensee for Nos. 1 and Discrepancy No. 3 will remain as an open item because the licensee had previously identified a similar deficiency and has documented it on Standard Deficiency Report (SDR) No. H-338R. The NRC inspectors will close this item upon a review of the licensee corrective action and response to SDR H-338 (0 pen Item 498/8623-01) I Discrepancy No. 2 was observed during the examination of the Main Steam line in the Isolation Valve Cubicle. It.was observed that Support Nos. MS1150-HL5003 and MS1148-HL6003 were bottomed ou Investigation by the licensee indicated that these supports were bottomed out due to unauthorized removal of travel stops and temporary supports. This is an apparent violation. The licensee reported that they were able to identify additional supports that were also bottomed out. Several things led to the cause of the apparent violation as listed below: Travel stops and temporary hangers were removed without authorization from engineering. Five of seven spring cans

verified were discrepant and are as follows: Hanger Stop Inspected _ Requirement RH1303-HL5005 out out RH1205-HL5013 in in MS1106-HL5002 in out M51050-HL5003 in out MS1148-HL5003 in out M51003-HL5018 out in MS1001-HL5013 out in

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Field engineering had not checked ard verified that the travel stops were replaced after Hydrostatic testing was complet During this review there was some concern about additional stresses placed on the 14S line due to removal of these temporary support .

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apparent violation of NRC. requirements. (498/8623-02)

 . d .~ Storage of Pipe Hanger Components The NRC inspectors, using Bechtel Specification 5A300GS1002,'" Storage Requirements for STPEGS Safety Related Engineered Equipment,"

inspected the laydown and staging area west of Unit No. 2. .It was-found that most ASME Section III pipe supports manufactured by NPS

 .had been adequately protected during storage including application of a rust preventative, however, some have not been protected and have deteriorated to the point'of not being serviceable in that the paddle end bearings and threaded portions were seized due to excessive rusting. Also some bearings were noted to have been pushed out of the bearing recess. These items are required to be in level D storage ~. . . i.e.', protection from the elements and physical damag This condition was discussed with and observed by the licensee
 . material control manager. This is an apparent violatio (499/8621-01) Traceability of Materials for Pipe Supports A, verification of the traceability of materials was performed in the warehouse, yard and fabrication shop as follows:
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  .A 4X10X2 foot plate was observed being cut for user testing in the-laydown yard. The heat number was marked on the plate and the warehouse personnel produced the mill _ test report on reques A 4X10X1 1/2 foot plate was observed in the yard and was tagged;
  'a heat number was also stamped on the end. When the inspector ,

requ'ested the verification data for this plate the warehouse-personnel produced a package ~ verifying the code, the material receiving report,-the user test data, and the MTR numbe In the fabrication' shop the NRC inspector witnessed the stamping of cut-up shim plates. The Ebasco QC inspector produced the inspection report for the items which verified the stamping and traceabilit * Also, in the fabrication shop the QC inspector produced the inspection' report,' cross reference. heat code, and the material test report for an item asked for by the NRC inspecto No violations or. deviations were identified in this are _

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    . Welder' Qualifications 1
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The following is a listing of welders making field weld on pipe

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supports. 'Each welder was verified as being qualified to the-proper ; procedure when the field weld was mad _ Support N Welders ID ' Field Welds

 'MS1148-HL5003 EGH, PKK, PCU  ' l- 6 MS1106-HL5002  PJK  1-4 MS1001-HL5011  PJK  OA MS1001-HL5012- PJK  OA MS1001-HL5010  PJK-  0A MS1001-HL5014 PJK,1EA :  1-10 !

MS1001-HL5013 - PHH, PJK', PNK -9, 12,-17, 21, 23,

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    '27-29 MS1150-HL5003 -PCU ~  1-2 MS1004-HL5002  PKI  3-4 6 MS1003-HL5015  PTD  OA MS1003-HL5016  PT A MS1003-HL5018 PHH, PMX 7, 8, 11, 12, 13, 17 RH1303-HL5004  PLI  1-2 RH1306-HL5003 FID, PYR, FHG  1-3 RH1306-HL5001 PSX,~ PBZ, FG RH1303-HL5005  PGB  1-3 RH1303-HL5002- PKX, PFE  1-3 0-1
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RH1205-RR0004 PTK RH1205-RR0005 PTF 1-3 RH1205-HL5011 PIF 1-5 RH1205-HL5014 PJU, PZY, PDT, FDH, FHR A-D & 1-6 RH1205-HL5013 PRS, PGB 1-4 Pipe - 30" MS1003-GA2 PYC 11323 30" MS1003-GA2 FKS 11324 30" MS1003-GA2 FGE, PBI 0078 No violations or deviations were identified in this are Records The NRC inspectors reviewed the record packages of the pipe supp' orts and restraints they examined in the field. The records were reviewed to determine if the type and' classification of pipe ~ support or

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restraint complies with the appropriate design / installation drawing;- location, spacing and. critical clearances meet licensee's ; specifications and have been verified by QC; required scope of QA/QC !

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 . inspections were met; weld identification / location corresponds to respective weld card, drawing, and other welding. documentation, if records were~ complete, easily retrievable, and legibl ...,
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One discrepancy was identified in the weld documentation. The welder's ID wr.s identified on the hardware but did not appear on the AWS checklist for making the welds. The licensee had identified a similar deficiency which is documented on SDR No. 338R. This deficiency will remain as an open item pending the response and corrective action by the licensee to SDR No. 338R. This is also discussed in paragraph 11.c abov It was found that the work had been performed to the latest revision of the drawings and/or approved change request No violations or deviations were identified in this area. Apparent violations of NRC requirements are identified in 11.c and 11.d abov . Exit Interview The NRC inspector met with licensee representatives (denoted in paragraph 1) on August 29, 1986, and summarized the scope and findings of the inspectio I

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