IR 05000498/1986039

Insp Repts 50-498/86-39 & 50-499/86-39 on 860825-29.Major Areas Inspected:Adequacy of Corrective Actions Associated W/Engineering Assurance Program Tasks 85-1,85-2 & 85-3 & Status of Prior Comments & Concerns

ML20215D204
Person / Time
Site:	South Texas
Issue date:	12/11/1986
From:	Imbro E, Parkhill R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20215D202	List: IR 05000498/1986039 ML20215D199
References
50-498-86-39, 50-499-86-39, NUDOCS 8612160264
Download: ML20215D204 (18)

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US NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT Division of Quality Assurance, Vendor, and Technical Training Center Programs Report Nos.: 50-498/86-39,50-499/86-39 Docket Nos.: , 50-498, 50-499 Licensee: -

Nouston Lighting and Power Company Facility Name: South Texas Project, Unit 1 Inspection At: Bechtel Energy Corp, Houston, Texas Inspection Conducted: August 25 to 29, 1986 Inspection Team Members:

Team Leader: R. Parkhill, Inspection Specialist, IE Mechanical Systems: T. De10aixo, Consultant, WESTEC Services Electrical Power: S. Athavale, Electrical Engineer, IE Controls: E. Dunlap, Consultant, WESTEC Services *

Civil / Structural; A. Unsal, Consultant, Marstead Engineering

• E. Imbro, Section Chief, Quality Assurance Branch IE Prepared by: g Ronald Parkhill Inspection Specialist, IE Team Leader Approved by:

b f hl-t4 12f/Ch'$

Eugene V. Imbro, Chief Licensing Section Quality Assurance Branch

• Attended exit meeting 0612160264 R61211 PDR ADOCK 050g 0

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80UTN TEXA8 PROJECT - UNIT 1

. INSPECTION OF AUDIT RESULTS: TASES 85-1, 85-2, AND 85-3 August 25, 1986 Through August 29, 1986 1.. Bacharound on March 1, 1984, representatives of Mouston Lighting and Power Company (ML&P) presented to the NRC the details of the Engineering Assurance Program (EAP) being conducted on the South Teams Project (STP). As a result of this meeting and additional information provided by ML&P, the NRC determined that this program, if properly implemented, could provide the additional assurances of design adequacy normally provided by an Independent Design Verification Program (IDVP). Formal acceptance of the EAP as a substitute for as IDVP was Irovided via letter to ML&P dated August 20, 198 The NRC monitored the STP Engineering Assurance Program in three phases for Task 85-1, Control Room HVAC, Task 85-2, Component Cooling Water System and Task 85-3, Offsite AC Power and Medium Voltage AC Power Supply Systems: (1)

implementation of program plan and procedures, (2) review and evaluation of audit results and (3) followup of corrective actions. The first phase of inspection was accomplished at the headquarters of the Stone and Webster Engineering Co. (SWRC) in Boston during the week of April 23, 1985. The report of this inspection (No. 50-494/85-09) was forwarded to ML&P on July 12, 1985. The second phase of inspection for Tasks 85-1 and 85-2 was accomplished at SWEC's headquarters in Boston from July 22, 1985 through July 26, 1985 and a report of this inspection (No. 50-498/85-14) was forwarded to ML&P on August 28, 1985. The second phase of inspection for Task 85-3 was accomplished at SWEC's headquarters in Boston from October 15, 1985 through October 17, 1985. The report of that inspection (No.50-498/85-22) was forwarded to ML&P on November 18, 1945. In addition, the NRC inspected action ites resolution and corrective actions associated with Tasks 83-1, 83-3, 84-1, 84-2, and 84-3. (Report 50-498/

85-26 dated March 25, 1986). Purpose The purpose of this inspection was to conduct phase 3 of our monitoring program, via. verification of adequacy of the corrective actica associated with EAP Tasks 85-1, 85-2, and 85-3. In addition, the NRC reviewed the status of all comments or concerne from the prior NRC inspections of the South Texas Project EAP: Inspection Report Nos. 50-498/85-09, 85-14, 85-22, and 85-2 . Personnel Contacted The following is a brief list of key personnel contacted during this inspection:

Name Position R. A. Frasar NL&P EA Program Manager S. R. Basu NL&P EA Program Staff M. E. Chakravorty ML&P EA Program Staff R. D. Reed NL&P EA Program Staff J. E. Woods NL&P EA Program Staff D. E. Root ML&P Engineering C. R. Allen NL&P Engineering W. L. Schuler Bechtel Engineering N. Joonejo Sechtel Engineering B. D. Shah Bechtel Engineering N. Getaan Sechtel Engineering N. Bali Bechtel Engineering

. General Conclusions

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The NRC Inspection Team reviewed a large number of calculations, diagrams, specifications, and other design documents during the five day inspection, as further detailed in this report. Based on this review, the NRC Team concluded that the resolution of action itema and the verification of the STP Project commitments by Engineering Assurance personnel were supported by sufficient technical justification. Through the staff's review of the open items associated with, Inspection Report No. 50-498/85-26, one issue was identi-fied in the civil / structural discipline as a failure to meet an FSAR licensing commitment. This issue concerns application of only 20% of the live load when combined with seismic loads for the reactor containment building design and has been referred to NRR for resolution on September 15, 1936. In addition, sinor inconsistencies were noted in certain documents during this inspection that had no impact on plant design and were essentially of the type which would be corrected during the STP Design Finalisation and Document Turnover Program. The staff noted that HL&P is relying on the STP Design Finalization and Document Turnover Program to address the generic impact of the documentation inconsistencies and the staff recognizes that beplementation of such a program is essential. The NRC concluded that Engineering Assurance Tasks 85-1, 85-2, and 85-3 reflect an indepth analysis of the state of design of the South Texas Project and provide substantial additional assurance of the implementation of an acceptable design process. Details of,the inspection of each major tech-nical discipline are contained in Addendum 1 to this repor Based on a review of comments or concerns from prior NRC inspections of the South Texas EAP, the NRC Team determined that sufficient action had been taken to close each of these items. Rationale for closure of the individual items is contained in Addendum 2 to this report. The NRC inspection reports which were reviewed were Report No. 50-498/85-09, 85-14, 85-22, and 85-2 .

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Addendum 1 Specific Discipline Sussearies The follow'ing are summary descriptions, presented in accordance with each of the major disciplines associated with Tasks 85-1, 85-2, and 85-3. The basic inspection approach utilised by the staff was to review the initial action item

. identified by SWEC, and then to review the documentation trail between EA, ML&P Engineering, Bechtel Engineering, and possibly SWEC, to ensure that the resulting corrective action,was responsive to the initial or evolved concer Mechanical Systems The resolution and verification of the following action items were reviewed in the mechanical systems area: Action Items 85-1-1, 5, 14.1, 16.3, 17, 20.8, 21.2, 34.2, 34.3, 44.1, and 54, and Action Items 85-2-1, 4, 9a, 9c, s lla,'lle, 12b, 12 , 13a, 3 13b, 15b, 15c, 15d, 15c, 20s, and 31. The following observations pertain to the most significant action items. Action items considered of lesser significance are not addressed in this repor Action Item 85-1-16.3 identified inconsistencies between various MVAC calcu-lations with regard to motor horsepower data and static pressure data for air-handling units. Further investigation revealed that two of the three calcu-lations contained correct data in accordance with manufacturer's information but that the third calculation had not been updated to the latest informatio The third calculation was updated with no impact on design. The staff reviewed all three calculations and determined that this was not a major concer Further, the staff noted that the STP Design Finalisation and System Turnover Program is intended to rectify this type of inconsistency prior to turnover of design documents from Sechtel to EL&P. The staff considers this matter close Action Item 85-1-34.3 involved questions regarding the safety-classification of deluge piping and water drain piping to charcoal units in the Control Room MVAC system. Questions were raised due to inconsistencies between P&ID's and specifications. Further investigation revealed that the deluge piping was non-safety piping (seismically supported), as indicated in a change to the specification. The P&ID had not been updated after the speci-fication was changed but was being tracked on a system punch-list. The drain piping was safety-class 3 and was properly reflected in both the P&ID and the specification which invalidated the original concern. The staff reviewed the associated documents, including the subsequently updated P&ID, and determined this item'is close Action Item 85-2-9.a concerned the calculation of net positive-suction-head (NP8H) available to the CCW pumps in view of the potential to draw a vacuum in the CCW surge tank. Calculation MC5307 was revised to show that sufficient NP8N was available under the entremely conservative assumption of an absolute vacuum (i.e. O psia) in the surge tank. The staff reviewed this calculation and concurs with the result. Basically, the 48-foot column of water in a 4-inch diameter pipe between the pump suction and an empty surge tank provides ade-quate NPSH regardless of tank vacuum. Furthermore, for other reasons, the tank is now constantly vented to atmosphere and therefore the question of tank vacuum is moot. In view of the foregoing, the staff considers the matter of NP8H to the CCW pumps to be close .-

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Action Item 85-2-11.0 and 11.c raiosd a concern relatise to the design

pressure of the CCW surge tank. Basically, the design calculation did not contain the most limiting condition for thermal expansion within the tan Subsequently, the relief valve was replaced by a 4" overflow pipe when the need for nitrogen blanketing was eliminated by an unrelated decision to

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change the corrosion inhibitor. Following this change, tank pressure calculations were totally revised to reflect the revised configuratio These calculations (MC6007 and MC6008) verify that surge tank design pressure is adequate. The staff reviewed calculations MC6007 and MC6008 and agrees that the adequa'cy of surge tank design pressure is properly documented. This item is close *

Action Item 85-2-20.d raised questions regarding whether or not pressures imposed by CCW surge tank static head could exceed CCW system design pressures at the lowest point in the system under all operating modes. The CCW system pressure calculation (MC5858) was revised to address this concern. The staff reviewed all calculations associated with surge tank pressure and CCW system pressure and agrees that all associated concerns have been adequately resolve This item is close Action Item 85-2-31 involved questions of the automatic trip of the CCW pumps on low surge tank level to protect the pumps from cavitating or running dry. Although the initial project response was that low level switches would automatically trip the affected pump, it was later discovered that the cable for these switches did not meet safety-grade requirements due to lack of separation from non-1E cable. Consequently, the automatic trip feature of the switches was disabled to prevent a possible common-mode failure from tripping all CCW pumps. Trip of a pump on low level now relies upon operator action to ensure that the automatic trip has been disabled. The staff reviewed the failure-modes-and-effects analysis (FMEA) associated with the CCW system (MC5658) and agrees that operator action is acceptable because:

(1) There is safety-grade alarm sad indication of low surge tank level to alert the operato (2) Even if one CCW train is lost, the two remaining trains provide 100%

system capacity, and (3) There is no credible single failure which would cause loss of more than one CCW pump due to piping rupture or other system leakag This ites is close El_ectrical Power The resolution and verification of the following action items were reviewed in the electrical power area: Action Items 85-1-3, 9 and 58; 85-3-1, 2, 4, 5, 8, 9, 22, 24, 32, 34, 35, 36, 37, 45, 46, 49, 50, 62 and 6 Items of most significance are discussed below while itens of lesser significance have not been discussed in this report. In addition to reviewing the previ-ously mentioned action items, the staff reviews and discusses at the end of this section, a HIAP commitment to increase the sample size associated with Engineer-ins Assurance's review of approved equipment qualification test reports for equipment located in harsh environment Action Item 85-1-9 involved HVAC duct heaters in the main control room and in the relay room which are secured under accident conditions by an accident signa Since the breakers which secure the heaters are non-1E, the concern

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l was that their failure to trip could result in high temperatures in the

,, control room or the relay room. In response to the concern, the STP project

! performed calculation 3V110MC6029 to determine the resulting temperatures,

should the heaters remain energized for a period of 30 minutes before being

manually tripped by an operator. With regard to the relay room, the Project

decided to disconnect the relay room heaters which resolved this concer '

l The Project also decided to retain the connection to the control room

heaters and place them under administrative control since the calculation J

showed that the maximum temperature in the control room would be 98* F

prior to the. manual operator action. Since all control room instruments

, are qualified for 104* F, and since a tesperature rise to 98* F for 30 minutes ,

i will cause little inconvenience to the operators, this action was considered i

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to be satisfactory. The EA team reviewed the effects of the temperature rise j on control room equipment and found no appreciable change in instrument accuracy.

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The EA team noted that there are no solid state electronic circuits in the j main control room and that plant computers are located in other areas with j independent MVAC units. In view of these findings, the EA team concurred with j the Project action. The NRC staff also reviewed this matter and determined

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the action to be acceptable. Further, operator action to secure the heaters

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will likely occur in much less than 30 minutes since the operators will be !

I aware of the increasing temperature prior to reaching 98* F. This item l l is close !

Action Item 85-3-24 indicated that specifications for the diesel generator

neutral grounding transformer were not provided. The EA team reviewed l calculation EC5021/0, vendor memorandum ST-GL-YB-900027, and drawing 9E-PEAA-01/6. The calculation indicated that ground over-voltage relay 59N

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was specified for a setting of 16 volts which corresponds to only 75% of the !

diesel generator winding protection in lieu of 100%. This appears to be a misapplication of the particular relay. EA team has identified this item to i project engineering for evaluation of design adequacy including any appropriate t design modification. Discussions with EA and project personnel convinced the ;

staff that the technical significance of this issue is understood and is being i tracked. Even though a final corrective action was not completed at the time j of inspection, the staff is satisfied that this issue will be appropriately

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' resolved. This observation is close i Action Ites 85-3-49 indicated that the diesel generators were sized using i brake horsepower ratings of the loads rather than motor nameplate horsepower i l ratings. This fact was not identified in the FSAR. The EA team subsequently i l reviewed amendment 53 to the FSAR and concluded that the concern had been '

i adequately resolved. The NRC team reviewed this matter and indicated that an j increase in brake horsepower demand due to changed process configurations

(i.e. future demand may be higher than present values but less than nameplate ;

values) may increase diesel loading. The EA team stated that such situations a l would be highly unusual but in any event wouAd be accommodated by the designed

33% overload capacity of the generator. The NRC evaluated this information and considers this response to be acceptable. This item is closed, i

During the inspection of ITA 84-2, the NRC team noted that the sample size [

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selected for review of environmental qualification of equipment located in a '

harsh environment was not large enough to provide confidence that the qualifica- (

l tion program was being properly implemented. The EA team indicated that addi- ;

{ tional items would be reviewed in ITA 85-3. During the inspection of ITA 85-3, -

I the NRC noted that the following additional items had been reviewed:

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. ASME III solenoid valves

EVAC dampers Reactor containment building fan coolers ASME III modulating control valves Motor driven auxiliary feedwater pump motors The results of these reviews have been documented as action items, where appropriate. The NRC team reviewed the action items and found the reviews to be acceptable and the action items to be properly resolved. The NRC team also noted that the Project EQ group has been conducting a verification program for installed equipment to assure that the as-supplied hardware

, conformed to equipment qualification test reports. This effort envelops

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the hardware changes identified by the NRC's Construction Assessment Team (CAT) inspection. The NRC inspected samples of the verification program and found it to be acceptable. The adequacy of the EAP verification of the EQ design process implementation is close Controls Discipline Resolution and verification of the following action items were reviewed in

the Controls Discipline: Action Items 85-1-4, 52, 63, 64, 67, 69, 70 and 79; 85-2-46b, 62b, 63a, 67k, 671 and 67u; and 85-3, 81, 85, 86, 88, 8:), 90 1 and 10 Items of most significance are discussed below while items of lesser significance have not been discussed in this report. In addition to reviewing the previously

mentioned action items, the staff reviewed two other matters: (1) instrument

set point determinations and (2) flooding of the computer room based on non-safety-related cooling units and fed from the normal chilled water supply

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system. The discussions resolving and closing out these two items are at the

conclusion of the selected action ites discussion.

4 Action item 85-1-4 noted that smoke and toxic gas detectors were identified I

as class IE when in fact, they are not. This equipment is not available as

! class IE, but is consercially available to mine safety and underwriter laboratory standards. A review of FSAR change request (CR) 658 and FSAR j section 9.4.1.1 confirms that the equipment is now classified non-1E. This

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item is closed.

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Action item 85-1-63 involves the laying of non-1E equipment cable in conduit with IE equipment cable and evaluating the consequences of a non-1E fault upon the safety-related circuitry. The project corrected the specific occurrence l by eliminating the associated non-1E hardware and reviewed other applications

! to assure that other non-1E equipment cables were not laid with IE equipment

cables. A staff review of safety evaluation report 90470, section 7.3.2.12 i

and logic / elementary drawings confirms that the non-1E flow switch has been disconnected and that there are no other occurrences of non-1E equipment cables laying with IE equipment cables. This action is considered acceptable and the item is closed.

l Action item 85-1-67 pointed out that contact #27 of HS-050dA has no useful l function when transferred from the control room to local position. A review l of elementary wiring diagram 9-E-CH11-01, Rev. 03 by the staff has confirmed j

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that the switch contact has been removed and local control is available from the chiller panel. This action is acceptable and the item is closed.

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Acti:a item 85-3-85 c: tad th2 pr:s::nca cf a functicani element en th2 legic diagram (PDS-7008 on 9-Z-40091) which was not shown on elementary diagram

, 9E-CD13-01. A review of the current revisions of these drawings indicates that the elementary diagram was revised to include the device. This observation occurred because the condensate system has been assigned a low priority in regard to plant startup efforts and, therefore, the elementary diagram was not immediately revised when the device was added to the logic diagram. This item is close Action item 85-3-86 points out five (5) discrepancies between York Vendor Drawings and the licensee's elementary diagrams / logic diagrams (York V/D 14926-4310-00011-DYD and licensee 9-E-CH11-01/9-Z-4153). The staff confirmed that all of the discrepancies have been corrected. This item is close Action item 85-3-100 identified eight (8) concerns regarding discrepancies between the ESF load sequencer elessatary diagram, logic diagrams and FSAR section 8-3. Staff review of FSAR change request CR 928 and revisions to logic diagram 9-Z-42127 confirms that the licensee's commitments to correctly identifying the three mode conditions (i.e. safety injection (SI), loss of offsite power (LOOP) and SI and LOOP) and the initiation of proper responses are acceptable. This item is close Earlier STP inspection reports (i.e. 85-09 and 85-14) had noted that instru-mentation setpoint calculations had not been reviewed by EA since Bechtel had not yet initiated that design aspect. However, HL&P had committed to review setpoint calculations and as a consequence of HL&P's commitment, these items were identified as closed in the subject inspection reports. To verify that Bechtel had commenced its setpoint evaluation, the staff reviewed the following documentation:

Calculation No. 92C6003, " Equations to be Used in the Development of Balance of Plant (BOP) Safety-Related Setpoints."

Calculation No. 92C6018, " Device Uncertainty Estimate for Fluid Components, Inc. (FCI) Model FR72-LL (W/ Circuit Board #5181)."

t Calculation No. 9ZC6019, " Instrument Loop Uncertainty Equation (ILUE)

and Determination of Trip Set Points for CCW Surge Tank Level NNS Isolation."

Drawing 4Z01-9-Z-48004, " BOP Safety Related Actuation

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Channels, Uncertainty Allowances and Associated Trip Set Points."

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Additionally, the staff noted that in application of Regulatory Guide 1.105

" Instrument Setpoints" the licensee had established a listing of instrumentation

requiring calculations to support the assigned setpoint values. The staff ( reviewed the aforementioned documents for scope, intent and implementation and i was satisfied that an effective program for performing instrumentation setpoint j calculations is in place. This item is close The staff also reviewed the issue regarding the potential flooding effects in

. the control room area caused by failure of the non-1E computer room cooling

units during a seismic event. This issue was originally addressed in inspection l reports 85-09 and 85-14 and was closed out based on the applicant's assurance l

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th:t ca cvaluatien w:uld tcka placa. Th2 stcff agress with th2 licensse's assessment that since the computer is not safety-related, its functionality is

not required following a seismic event and subsequent shutdown. Also, the staff concurs that sufficient volume exists under the computer floor to allow sufficient time to discover the flooding prior to the occurrence of any detrimental effect This ites is close Civil / Structural In the Civil / Structural area the team reviewed the supplemental study done for task 83- This additional assessment was performed in response to open item 85-26-1 from inspection report 85-26. The following observations address the most significant action items. Action items of lesser significance are not addressed in this repor Action Item 83-1s-2 involves the design of steel framing at elevation 68'-0" of the containment internal structures. The calculations reviewed by the EA team showed that the updated computer analysis results were not used in design. The Project's response to this ites states that the existing design calculations use more conservative information. The EA team has reviewed the load comparisons made by the project team and has verified this statemen The staff agrees with the EA team and this action item is close Action Item 83-1s-3 states that the thermal growth of the internal structural steel columns extending from the sat at elevation 11'-0" to the operating floor at elevation 68'-0" due to the abnormal condition was not considered in the analysis of the operating floor structure. The Project in turn has performed calculations (CC5426, Rev.0) to show that the loads induced due to thermal growth of these columns did not increase the column axial stresses or the local bending stresses. This action item was closed by the EA team after inspection of these additional calculations. The staff also reviewed these calculations and agrees with the EA team's assessment. This action item is close Action Item 83-1s-4 questioned the validity of the assumption made in the analysis and design of the isolation valve cubicle. This assumption states that the worst case cubicle with respect to steel and concrete stresses was the one located between column lines S9 and R EA team felt that the cubicle wall along column line N5 might be a more critical situation for design, invalidating the Project's assumption of the worst case design. The Project, in response to this action item, has performed additional calculations (CC6252, Rev. 0), using the EA team's worst case assumption, showing that the stresses in steel and concrete obtained do not exceed the permissible limits. The EA team has reviewed these calculations and found the response acceptable. The staff agrees with the EA team and considers this action item close Action Item 85-1s-23.2 states that calculation CC9601 requires that a spacer plate be located in the middle of each brace member for the HVAC duct support Such bracing members are made from structural double angles. The purpose of providing a space plate is to reduce the unsupported length of the member reducing the possibility of buckling of the double angles. Contrary to the requirements set by the above mentioned calculation the review by the EA team on the Control Room HVAC duct supports showed that drawing number M-28502 (sheet 1) does not contain these spacer plates. The Project, in response to this action item, has performed a review of all spacer plate requirements and has performed calculations (CC9623, Rev. 0) to identify bracing where spacer

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pictso ora rIquirsd. They h2v2 iccued c g:neric drcwing (5-V-01-0-M-29500, Sh. 6 Rev 0), that shows these requirements. These drawings, as well as the

calculations, were reviewed by the NRC staff. The staff determined that the requirements had been properly implemented. This item is considered close .

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l Addendum 2 i Status of Prior NRC Inspection Itees The following is the status of NRC inspection comments or concerns from the following NRC inspection reports on the South Texas Project EAP:

, Report Nos. '50-498/85-09, 85-14, 85-22, and 85-2 Inspection No. 50'-498/85-09 In Attachment 1 to NRC Inspection Report 50-498/84-14, all inspection items from Inspection Report 50-498/85-09 were closed except for observation I.2.b. Attachment I went on to state that 9 specific items would be reviewed by the NRC in forthcoming inspections to ensure proper resolution by HL&P. The status of these 9 observations is provided belo OBS.N Description Status Remarks I. The HVAC arrangement Closed The scaling of dimensional drawings used in the EA information from the HVAC review did not contain arrangement drawings, as was the dimensional informa- done by the EA reviewer was tion needed to substan- confirmed to be sufficient tiate the HVAC calculatio to support this type of calculatio I. A specification referenced Closed The necessary information and in a calculation as pro- was obtained from the vendor I. viding input data no and added to specificatio longer contained the input There was no impact on the informatio calculatio I. For HVAC heat load calcu- Closed Cable energization at any and lations, it was assumed that given time is now assumed as I. only 60% of the cables in a 100% rather than 60% for heat t

tray will be energized at a load calculations. This did time. This is not a conser- not affect the results of the vative assumptio subject calculations.

I i I It was not apparent as to Closed This item is closed since EA

! how the EA team was review- Task 85-2, Supplement, now l ing the design change directly evaluates the design l change proces , III. Set point calculations had Closed The staff's review of set

! not yet been prepared point calculations during r

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and therefore were not the August 1986 inspection reviewe at BEC offices in Houston has resolved this concern.

l III.2.c.1) The use of non-1E trip Closed Action Item 85-1-9, discussed relays to trip duct earlier in this report, has heaters under accident adequately resolved this conditions was not concer resolve . - - - , - - - . - - . . _ - - .- _ . . . _ - - _ . - . - - . - . , _ . - . - . . -

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2) Evaluate flooding effects Closed Refer to discussion at the

. regarding failure of non- end of Controls Discipline safety-related computer room in this repor cooling unit during a seismic even II A number of items were Closed NRC inspection report left open pending con- 50-498/85-22, which addressed firmation of.their EA Task 85-3, has confirmed inclusion in EA Task that the items of concern have 85- Leen included in EA Task

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85- Inspection No. 50-498/85-14 OBS.N Description Status Comment If specific information Closed Examples of annotations and in a review plan thorough documentation of (e.g. input data) is review plans were observed spot-checked rather during this inspectio than completely verified, this should be annotated in the review pla .2 Action items should Closed Examples were observed of identify the implications action items with the of recommended corrective implications of recommended action rather than simply corrective action ( stating that a specifi- DRP-85-2-5-M26).

cation (of an already installed tank) should be correcte .3 HL&P had committed to Closed DRP 85-2-M48 was added to compare a sample of compare isometrics to node connecting analyses. Seven isometrics elements in network were reviewed. There were analysis to isometric no significant errors note drawing .1 The EA program has not Closed EA Task 85-2 Supplement, addressed the design was initiated specifically change control proces to address the design change control proces .1 Review Plans for 85-1 and Closed The EA team has initiated 85-2 did not address a walk-down EA Task 86- internal panel wiring This EA Task addresses the

separation, concern and will verify l separation internal to i panels and cabinets.

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. Inspection No. 50-498/85-22 Electrical Power Para.No. Description Status Comment DC breakers for class IE Closed The installed breakers are battery chargers were rated for 400 amps, thus calculated for 350 amp negating the original con-The maximum current in cern that the DC breakers the circuit per vendor were undersize data can be as high as 375 amp .b The EA review of calcula- Closed The EA team is reviewing tion EC-5036 "DC Cable calculations made available Sizing" w.3s not complete by the Project under EA due to insdequate action item 85-3-7 information, Inspection N /85-26 Mechanical Components Item Description Status Comment

(1) The sample size of the Closed Review of the verification pipe supports reviewed plan of action items 84-3-18, was not large enough 19, and 28a as attached to to ensure that the memorandum from R. Frazar to generic aspects were J. Goldberg dated January 23, adequately verifie (#ST-HL-35235) indicated that a more representative sample had been reviewed by HL&P to ensure that the cor-rective action had been generically resolve (2) HL&P had previously Closed As discussed with HL&P, two committed to ensure methods for tracking these that all additional action items are utilize action items resulting The first method is for items from the EA verification of potential significanc would be submitted to The EAP assigns action item Bechtel for respons numbers to these and tracks and verifies closure via their normal EAP verification proces Review of action items 84-2-42

, and 84-2-43, indicated that such an approach is being implemente The second method of tracking is for additional action items that are transmitted to project engineering without EAP

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verification. These items e

are determined by EAP to be of relatively minor signifi-cance and are forwarded to Bechtel project engineering for resolution and verification of corrective action. The staff verified that Bechtel

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tem to obtain project evalu-

ations of all such additional action items. Additionally HL&P is planning to perform a project document turnover review, to ensure consistency between key design documents and drawings. The staff dis-cursed the " Design Finaliza-tion and Document Turnover Programs" with HL&P and Bechtel and verified that actions for implementation are in progres Civil / Structural An auditable path was not Closed Additional work was performed maintained of the review by HL&P and the SWEC EA team work packages during the to establish completeness of acceptance of Brown & Root the turnover (the isolation work by Bechtel in the civil / valve cubicle, reinforced con-structural are crete, and internal structural steel were reviewed). The staff reviewed the HL&P and EA work and determined that it resolved the concern. As a separate matter, the staff identified a technical issue involving BEC's use of 20% of the live load for some concrete and steel structures (when combined with earthquake effects).

This matter has been referred to NRR for resolution since it is an apparent deviation from a licensing commitmen The concern in Inspection Report No. 50-478/85-26 is considered closed for pur-poses of this inspection.

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5 J. H. Goldberg - 2-Distribution:

DCS.016-NRC PDR Local PDR QA8 Reading DQAVT Reading JMTaylor, IE ,

.RStarostecki, IE BKGrimes, IE HJMiller, IE EVImbro, IE RWParkhill, IE PKadambi, NI HThompson, NRR TMNovak, NRR WButler, NRR EHylton, NRR AEOD OELD NMSS RES ACRS (10)

NSIC NTIS Regional Administrators

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Regional Division Directors TSpeis, NRR ELJordan, IE JAxelrad, IE Team Members HBoulden, OIA SECY OPE

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Brian Berwick, Es .

Resident Inspector /Scuth Texas Assistant Attorney General Project Environmental Protection Division c/o U.S. Nuclear Regulatory Comission P. D. Box 12548 P. O. Box 910 Capitol Station bay City, Texas 77414 Austin, Texas 78711 Mr. Jonathan Davis ,

Mr. J. T. Westermeir Assistant City Attorney l Manager, South Texas Project City of Austin i Hoeston Lighting and Power Company P. O. Box 1088 P. O. Box 1700 Austin, Texas 78767

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Houston, Texas 77001

.., Mr. H. L. Peterson Citizens Concerned About Nuclear

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Mr. G. Pokorny Power City cf Austin 5106 Casa Oro P. O. Box 1088 San Antonio, Texas 78233 -

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< Austin, Texas 78767 Mr. Mark R. Wisenberg '

Mr. J. 8. Poston Manager, Nuclear Licensing

Mr. A. Von Rosenberg Houston Lighting and Power Company

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I ! City Public Service Boad P. O. Box 1700 P. O. Box 1771 Houston, Texas 77001

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San Antonio, Texas i8296 l- Mr. Ch'arles Halligan Jack R. Newrnan. Es ,

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Mr. Burton L. Lex

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1615 L Street, P. 0. Box 2166 Washington, D.C. 20036 Houston, Texas 77001 Melbert Schwartz, Jr., Es Mr. E. R. Brooks Baker & Botts Mr R. L. Range

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Ncuston, Texas 77002 , P. 0. Box 2122 Ccrpus Christi Texas 78403

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Executive Director Citizens for Equitable utilities, In Route 1, Box 1684 Brazoria, Tesas 77422

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Houston Lighting and Power Company Suite 1309 7910 Woodmont Avenue Bethesda, Maryland 20814 .

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