IR 05000498/1987007

Insp Repts 50-498/87-07 & 50-499/87-07 on 870202-0327.No Violations Noted.Major Areas Inspected:Site Tours,Licensee Action on Previous Insp Findings,Previously Reported Items & IE Circulars

ML20215B174
Person / Time
Site:	South Texas
Issue date:	06/02/1987
From:	Garrison D, Clay Johnson, Mcneill W, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215B141	List: IR 05000498/1987007 ML20215B139
References
50-498-87-07, 50-499-87-07, IEC-81-05, NUDOCS 8706170245
Download: ML20215B174 (24)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report':

50-498/87-07 Construction Permits:

CPPR-128 50-499/87-07 CPPR-129

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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 (STP)

Inspection At:

STP, Matagorda County, Texas Inspection Conducted:

February 2 through March 27, 1987 Inspectors:

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~ C: 'E. Johpson, Senior Resident Inspector, Project

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Section C, Reactor Projects Branch as gp D.'L. Garrison,ResidentInspector, Project Section C, Reactor Projects Branch tatfA

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l R. G.

ayfor,ProjectInspector, Project Dew Section C, Reactor Projects Branch

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&Nn W. M. McNeill, Project IKspector, Project Ddte~

Section A, Reactor Projects Branch l

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870617024507gj9g PDR ADOCK O PDR O

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r-2-I Approved:

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G. L.

Tonst e, Chief,. Project 5'ection C, Reactor Da[e projects ranch In~spection Summary.

Jnspection Conducted February 2 through March 27, 1987 (Report 50-498/87-07; 50-499/87-07)

e Areas' Inspected:

Routine, unannounced inspection including site tours, licensee action (on previous inspection findings, licensee action on previously-reported. items, licensee action on IE Circulars, procurement, receiving and storage, safety-related-structural steel, post-tensioning, safety-related components,. safety-related pipe supports and restraints,. protective _ coatings, cooling water reservoir, concrete testing, and followup on. allegations.

Results: Within the 13 areas inspected, no violations or deviations were identified.

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DETAILS

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Persons Contacted-s a

y Principal Licensee Employees

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• Scott Head, Lead Project Compliance Engineer

• J. T.~ Westermeier, Project Manager

• T.- J. Jordan, Project QA Manager

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• C. A. Ayala,-Project Compliance T

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• M. Wisenburg, Deputy Project Manager

• B. L. Hall, Deputy Program Manager, SAFETEAM

• A. C. McIntyre, Principal Engineer

• W..P. Evans, Project Compliance Engineer

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• J. E.. Geiger, GeneraljManager, Nuclear Assurance E. R. Rivera, Nuclear Purchasing i

I. L.'Guthrie,-Manager, SAFETEAM D. W Glasson, Invertigator, SAFETEAM J. Johnson,_ Project QA Supervisor H. J. Donschke, Lead QA Specialist

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M. F. Hutcheson, Staff Engineer ~

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G. Ondriska,. Lead Startup Engineer

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Bechtel-Power Corporation (Bechtel)

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K. Hess, Deputy Project Manager

• C. W. Humes, Site Project Engineer

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• W._P. Murphy, Project Services Superintendent'

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• L. W. Hurst, Project QA Manager

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• R. H. Medina-, Lead QA Engineer P. Bursin,' Contracts l

B. Teitz,. Purchasing:

-i L'. Lockridge, Receiving B. Senn, Receiving Inspection R. Bryan, Construction Manager C. Ingle,' Quality Control J. O' Hair, Operations Plant Services Engineer

.V. K. Malhotra, Lead Code Engineer l

Ebasco Services Inc. (Ebasco)

W. M. Pardee, QA Systems Manager

• A. M. Cutrona,'QA Manager

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R. E. Powe, Lead QAE Systems

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C. J. Bowman, N5 Technical Assistant G. D. Slater, N5 Supervisor Presc'on W. Schneider, Quality Control H. Gorawshi, Project Manager

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• Denotes those individuals attecding the exit interview ccnducted on March 27,.1987.

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Inadditiontotheabove,theNRC'inspectorsa[sohelddicussionswith

.other members of the HL&P, Bechtel, Prescon, and Ebasco staffs..

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. Site Tours.

The NRC resident inspectors made.' routine site tours of Units 1 and.2"in

order to observe ongoing work activities and the condition of installed

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. safety-related equipment, and plant stetus. The following areas were.

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inspected:

fuel handling buildings (FHB), mechanical and electrical auxiliary buildings (MEAB)f, diesel generator buildings;(DGB), reactor l

containmentbuildings(RCB and associdted laydown areas.

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s Within the areas inspected,~ no violations or deviations were identified.'

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3.5 Licensee Action'on Previous Inspecdon Findings s-(Closed)' Violation (498;499/8612-07; EA86-10, Item I.B.1)

TheaboveidentifieditemwasclosedinNRCInspectidn

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i Report 50-498/86-32; 50-499/86-32 as Violation 498;M 9/8612-07, Part 1.-

.in accordance with NRC, RIV letter dated September 24, 1986 hto the-licensee, this item should have been identified as above.

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(Closed) Violation (498;499/8612-08; fi36-10, Item I.B. 2)

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The above identified ihr5 was.closdMn NRC Inspection

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Report 50-498/86-32; 50-499/N -32 4,6 Violation 498;49J/8612-07L Part 2.'

In accordance with NRC. ily letter dcted September 24, 1986, to'the licensee, this item shwid have been identified as above.

(Closed) Violation (498;499/8612-09; EA86-10, Item 1.B.3)

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The above identified item was closed in NRC Inspection'

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Report 50-498/86-32; 50-499/S6-32 as Violation 498;499/86-12-07, Part 3.

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In accordance with NRC, RIV letter dated September 24, 1986, to the S

licensee, this item should have been ide,otified as above.

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(Closed) Violation (498;4928612-04;EA36-10,ItemI.A.4),

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This item related to a find ng that certain mechanical equipment

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components were found not'tosconform to requirements.

NRC followup, as documented in NRC Inspection Report 50-498/86-22; 50-499/86-20, indicated satisfaction with the lice mee's disposition of the concern with the

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reactor water makeup tank foundation but expressed dissatisfaction with j

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the licensee's, then established, position that all of the deficient heating, ventilating, and air conditioning (HVAC) component supports were related to failure of one QC inspector to properly inspect. The NRC inspector ihdicated that his review showed that.at least four inspectors

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were involved. The licensee responded by reinspecting all HVAC support (62) as opposed to the earlier sample inspection. Based on the reinspection, seven additional supports were rejected and involveC a, total

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-5-of eight QC inspectors. All deficiencies were documented on nonconformance reports and dispositioned appropriately.

The licensee addressed the generic implications of the'eight QC inspectors apparent failure to properly inspect by' examining activities of these persons in areas other than HVAC equipment supports.

Evaluation indicated that only I

one of the eight failed to meet a criteria that 95 percent of items i

reinspected were deficiency free.

Further evaluation indicated this person was not adequately knowledgeable in interpretation of weld symbols shown on engineering drawings which caused him to accept welds not meeting requirements. The QC inspector was provided additional instruction in this. area and has apparently performed acceptably in his work assignments since that time. The NRC inspector also reviewed the broad generic corrective actions ~ the licensee committed to in his response date October 9, 1986, to'EA86-10 which included training of both craft and QC personnel, clarification of procedures, and supervisory monitoring of QC p,ersonnel activities. The NRC inspector reviewed selected reports documenting each of these actions and had no further questions. This item is tbrisidered closed.

(Closed) Violation (498;499/8612-06; EA86-10, Item I.A.6)

This con'cerned a finding that bolting had been over tightened in

structural steel framing designed to having sliding (slip) joints to

,. relieve thermally induced stresses.

Engineering criteria at the time of installation.had defined the bolts to be " snug-tight." The craft and Quality Control (QC) took snug-tight to be as defined in the American Institute for Steel Construction (AISC) Code which is the full ef fort of a normal man applied y.o a spud wrench.

It appears that this " full effort" produced breakaway torque values in some bolts equivalent to that obtained under more deliberate tightening with a calibrated torque wrench.

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licensee committed to providing specific torque values for the bolts and i

to rework all joints except for certain connections which had been t

evaluated as "use-as-is" since other mechanisms to relieve the thermal stress were present.

Based on a review of applicable conconformance 4-reports and interviews with licensee Quality Assurance (QA) personnel, the L

NRC inspector is satisfied that the required rework has been accomplished.

The broad, generic. corrective action program was previously discussed N

under Violation 4 3;499/8612-04 above.

This item is considered closed.

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Licensee Action on Previously Reported Items (10 CFR 50.55(e))

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I (Closed) IRC-240 Standby Diesel Generator Fuel Oil Anomaly

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The original design for scavenging excess fuel oil pumped to the diesel was not in accordance with the licensee commitments. A new code class seismic line and check valve have been added to rectify the deficiency.

(Closed) IRC-114 Defective Standby Diesel Generator Lube Oil Strainer l

Basket Tksitemha.sbeenpreviouslyreportedbyCoope. Energy Services under the

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provisions of 10 CFR,Part 21.

The defective strainer baskets have been replecad with a new der,ign which have been qualified by performance p+

Lusting by Zurn Industrfes, the original manufacturer.

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Licensee' Actionion IE Circulars (IEC)

(Closed)-IEC 81-05 Self-Aligned Rod End Bushings

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1This item of concern was_the improper staking of rod end bearings in sway st'uts.

In some' installations, the-bearing was found to be~ loose; r

therefore, the bearing would separate-from the~ strut.

The licensee's specification and quality. procedures require inspectiuns'

for. this and. related problems' with sway strut installation.

The NRC inspector had no further questions and IE Circular 81-05.is considered closed.

6.

Procurement, Receiving; and Storage An inspection of the procurement of materials and supplies and the Lreceiving and warehouse storage was performed in order to verify the

- adequacy of the process and the adherence to procedural requirements;

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Site Procurement Materials,. supplies, and contracts are handled by HL&P nuclear purchasing and Bechtel procurement.

These groups are responsible for assuring that there is an approved vendors listing, that requisitions have the proper review, that regulatory. requirements are included, and that the purchasing process conforms to the appropriate procedures which are:

Standard Site Procedure (SSP) 46, " Field Material Requisition, Preparation and Approval." Related procedures are:

Inspection Procedure (IP) 5.1Q and IP 5.3Q for operations; Quality Assurance Inspection. Procedure (QAIP) 10.0 for spares; PSQP 6.1 for Westinghouse orders; Nuclear Purchasing Procedure (NPP) 5.0 for HL&P direct purchase; and WPP/QCI-.10.0, IJI-4.0, and IJI-5.0 for Bechtel.procurements.

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Requisition Review and Approval In the Bechtel organization, material engineering generates the requisitions which go to the purchasing agent for quotes and then through the QA review cycle for inclusion of requirements in accordance with SSP 46.

The NRC inspector reviewed the QA log and two requisitions in the QA

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department. Also two completed purchase orders were reviewed in the j

purchasing department for inclusion of requirements and one request

in the nuclear purchasing department were examined, i

The Bechtel contracts department is also represented in the review process for contracts this group will administer.

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Receiving Inspection

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The purchasing agent forwards the purchase order to receiving

inspection after an item is bought.

It is further forwarded to j

receiving QC if it is a safety-related order.

Two purchase orders j

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were reviewed in the receiving department and.two in.the QC receivi'ng,

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group. When the purchased materia'l' arrives, it is.then stored'in the g

warehouses or issued for use.

SSP 13,;" Material Control," and-

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LSSP.44, " Storage and Maintenance of Permanent Plant Equipment,"

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govern these processes.

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Storage

The NRC inspector. inspected the main warehouses and storage' yards including all outside areas for conformance to the requirements of:

-Specification,5A3000GS1002, " Storage Requirements."

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. Unit 2 Walkdown'~

A walkdown was made of the storage areas / construction trailers and

'i areas.where materials have been placed after removed from the l

buildings.during a general cleanup'.

The areas around Unit 2 are:

being rearranged.and small warehouses. built to established warehouse control directly at the unit.

The material control plan by the:

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licensee.is-.to make available supplies to the craft without a trip to

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the main: warehouses and to rid the general, area of'small uncontrolled areas of materials and supplies.

The following areas were' inspected:

Carpenter shop area, civil. area, HVAC area, mechanical area,

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balance of plant (80P) piping, all small trailers', and paint

. area. Two inspections were made one with the Unit 2 Bechtel

~ Construction. manager and one.with the licensee material. control manager.

The current program should aid considerably in better issue and use of materials and construction items.

The NRC inspector performed four inspections of the small

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warehouses and found them to be orderly and in accordance with-storage requirements'.

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Conclusion No violations or. deviations-were noted in the review of the.

purchasing, receiving, and storage program. The-program appears to be functioning properly.

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. Safety-Related Structural' Steel-a.

Specification Review q

I The NRC inspector reviewed procedures and. specifications pertainirg to safety-related structural steel for both Units 1 and 2.

procedures / specifications appear to be adequate with sufficient technical criteria.

Procedures / specification reviewed are listed below:

Specification 3A010SS0030, " Erection of Structural Steel and

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Miscellaneous Steel," Revision 8, dated August 21, 198,

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SSP 11, " Fabrication, Erection, and Bolt-Up, of Structural

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Steel," Revision 2, dated July 24, 1986.

No violations or deviations were identified.

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Structural. Steel' Records (Unit 1)

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'An inspection"and audit of structural steel assembly and inspection'

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< records was performed in order to verify thatithe building turnover program.is adequately identifying and correcting deficient items and that the structures'or equipment.and the inspections thereof are pr,operly documented and retrievable.

The NRC inspector inspected 12 connections of the bottom chord of the

roof trusses in the fuel handling building (FHB).

Each connection-plate joined 4-to-6 members to the main trusses and had 4-to-6 bolts.

.per connection.

The NRC inspectors reviewed 68 bolted connections.

These connections are. documented on the.following inspection reports:

00012B'

00036B

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00020B 00037B

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000218 00038B

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.The drawings use'd in the inspection and' record review were:

14926-4019-02018-AAB - US Steel Roof Plan

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- 3F01-95-3004, Revision 1 - FHB Roof Framing Plan Bottom Chord

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3F01-9S-3003, Revision 3 - FHB Roof Framing Plan Top Chord

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It appears that the building turnover program is functioning properly..No. violations or deviations'were identified in'the review.

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Post-Tensioning (Unit 2)'

An inspection of the activities concerning the installation of the prestressing system was performed in order to verify that the installation was adequate and in accordance with the specifications.

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Procedure Review A detailed review of the FSAR and national codes and standards,

including all aspects of design was performed during the Unit 1 inspectior of comparable installations as documented in NRC Inspection Report 50-498/85-13; 50-499/85-13.

No changes of significance _have been made since that time. This inspection covered the specification, site specific procedures, and the contractor (Prescon) quality procedures and installation manual requirements.

The following documents were reviewed:

Final Safety Analysis Report '(FSAR) Section 3.8,

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Pages 3.8-35/3.8-38 Bechtel. Specification 2C239CS004, " Containment Post-Tensioning

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" Vertical and Horizontal Tendons"

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Prescon Procedure Field Quality Control Procedure (FQCP) STP-04,

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Revision 0, " Quality Control Procedures - Vertical and Horizontal Tendons"-

The procedures contain the inspection requirements as outlinedLin the FSAR and specifications. The licensee audit plan included a

.i scheduled QA audit of.Prescon:for the July 1987 timeframe..

Additionally, four surveillances, two by Bechtel QA and two by'HL&P QA, were. performed. The NRC. inspector reviewed these reports and found them to be satisfactory.

The report numbers were SB-1656,

.SB-1663, SH-958, and ALB-29.

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Work Observation The NRC inspector observed the receipt inspection process for seven horizontal tendons.

It was observed that the tendons were properly wrapped, rigged with flexible slings, stored on plastic covered dunnage,Eand covered with weather proofing plastic..The. tendons observed were:

2-1-H094,~100, 106,.112, 118,'124, and 130. The process was found to be'in compliance with the procedures.

The tendon cover cans were inspected in the contractor yard and near Unit 2.

The cans were in accordance with the fabrication requirements and did not exhibit any damage or deterioration and were properly stored.

- During a survey of work in the tendon gallery, it was noted that 47 vertical tendons were installed, 10 were stressed, and several ready for stressing. No problems were noted in the stressing operation, on tendons already button-headed or the cleanliness and condition of the base plates.

There has been problems with the intrusion of water into nine, vertical sheaths. The. engineer is evaluating this condition which is not' considered serious. A possible remedial action will be injection of grout or a similar approved substance to stop the water.

NCRs have been generated to record the condition.

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Records The NRC inspector reviewed the documentation associated with the receipt inspection of the seven horizontal tendons. The receiving inspection reports, shipping records, fabrication records, and mill test reports for the tendon wire and the stressing washers were found to be complete and acceptable.

No violations or deviations were identified.

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Safety-Related Components a.

Procedure Review - (Residual Heat Removal (RHR) Heat Exchangers)

The NRC inspector reviewed Westinghouse general instruction manual i

for auxiliary heat exchangers and Equipment Specification (ES) G-952780,

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Revision 0.

It appears that technical requirements and design criteria as detailed in the FSAR associated with the RHR heat exchangers have been adequately addressed for the design, procurement, receipt,.

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fabrication, installation, testing, and inspection.

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Observation of Work The NRC inspector observed and evaluated work performance, work in

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progress, and completed work to determine whether activities relative i

to the. Unit 2 RHR heat exchangers were being accomplished in accordance with NRC requirements, FSAR commitments, and licensee

procedures.

There were three,RHR heat exchangers observed. Majority of the work j

was in progress; however, the bolting of each anchor bolt foundation i

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were completed and three field welds (one per exchanger) was complete.

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'During this observation certain attributes were observed as listed below:

.l Documentation has been prepared and maintained as required by l

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receipt inspection instructions Storage, handling, and protection was in accordance with

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manufacturer's instruction and established procedures.

orientation, alignment, mounting (proper location, placement, torquin Installation requirements such as

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tolerances were met.

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Records Review The NRC inspector reviewed documentation associated with the welding of the completed field welds on each exchanger, mechanical equipment installation checklist (MEIC), and the code date package for Unit 2 RHR heat exchangers. The code data package contained pertinent data

such as certificate of compliance, material certification, l

radiographic data, nondestructive examination (NDE) test reports, and required American Society of Mechanical Engineers (ASME) data' forms.

The records reviewed appeared to be in accordance to site procedures / specifications. Documents reviewed are listed as follows:

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Data Package Field Weld (FW}

4C369PRH459, Sheet 3 N04,WNDP 0183 FW0001, line 2312 4C369PRH459, Sheet 3 N04,WNDP 0169 FW0001, line 2104 2C369PRH459, Sheet 5 N04,WNDP 0235 FW0012, line 2103 3C01-2-C-1515, Revision 8 3C01-2-C-1569 Revision 5 5A01-0-C-0005, Revision 19 6C18-9-N-5004, Revision 5 MEIC

2312-40 2312-4E 2312-4F No violations or deviations were identified.

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Safety-Related Pipe Supports and Restraints

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Procedure Review The NRC inspector reviewed procedures and specifications related to

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safety-related pipe supports and restraints.

Review of these procedures indicate that technical requirements detailed or i

referenced in the FSAR associated with safety-related pipe supports have been adequately addressed in these procedures / specifications.

One concern was identified in paragraph 5.7.3.4 of Specification 5L340JS1002. The concern is listed below in more detail.

Paragraph 5.7.3.4 in Specification SL340JS1002 allows additional

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welding in excess of that required by the design drawing. This is not good industry practice and does not appear to be a well

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controlled process as described by Criterion'IX of Appendix B.

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The NRC inspector informed the licensee of this concern, the-licensee stated that technically they don't have a problem.

'TheNRC.inspecto[informedthelicenseethattechnicaljustification

must be shown fora' worst case bases to prove this.

is presented.' (498;499/8707-01) pen item until adequate justifications This will be considered <as an o

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'k Observation ~

The. NRC inspector visually examined; random selected pipe supports and restraints in Unit 2 containment and mechanical auxiliary building's (MAB).'. Observation and examination by the NRC inspector

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indicates that QC is -properly inspecting the' installation:of pipe supports and. restraints in compliance with licensee commitments, applicable' codes, and, site. specifications.

ItLis also apparent thst the licensee's work control system is functioning ~ properly. There..

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was one minor deficiency noted (bent paddle) on' Support CC-9485-HL-5017c which.is considered to be an isolated case. The licensee: initiated NCR No. CS04678 to' correct the deficiency. Supports examined are listed below:

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. Records-The NRC inspector reviewed records of the pipe sup) orts and restraints examined.

Records reviewed indicated tlat the licensee has.an adequate record system and give.s reasonable assurance that the m

records reflect work accomplishments consistent with' licensee

. commitments. Records' reviewed are listed below:

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No violation or deviations were identified.

11. " Protective Coatings

.The purpose of this inspection was to review procedures and specifications related to the application and inspection of safety-related protective coatings inside Unit 2 containment building to determine if they were adequate. This inspection was also initiated because of observations of y

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-13-non-nuclear safety-related coatings in Unit 2 FHB by the NRC inspectors on a daily tour, which indicated defective coatings due to inadequate surface preparation, unsatisfactory ambient conditions, or poor application practices.

Procedure Review The NRC inspector reviewed Saecification 3C080AS1001, Revision 14. " Field Coating of Surfaces Inside tie Reactor Containment Building," Construction Site Procedure (CSP) 30, Revision 7, " Field Preparation and Coating of Surfaces Inside the RCB," and Quality Control Procedure (QCP) 10.8, Revision 8 " Protective Coatings Inspection." Review of the specifications / procedures indicate that sufficient technical data.and criteria are included. However, one concern was noted in paragraph 9.1.8 of Specification 3C080AS1001. This paragraph list parameters which may be

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expanded to limits beyond standard practice such as anchor profile, ambient conditions and curing time. The licensee has chosen to give (1)-

tolerances, some in percentages to several parameters.

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anchor profile has a 115 percent deviation, and dew point has a minimum of 3 F below surface temperature. Most manufacturers recommend a certain depth profile depending on the material used, and a minimum of 5 F below surface temperature..The licensee was informed by the NRC ins sector that more information was needed relative to these tolerances and tie licensee

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provided letters from the manufacturers justifying the tolerance

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parameters.

No violations or deviations were identified.

12. Cooling Water Reservoir The purpose of this inspection was to monitor the ongoing activities of the cooling water reservoir.

The NRC. inspector and licensee consultant reviewed the remedial work plan and schedule and made an inspection of the outer circumference of the reservoir including all drainage. The licensee is carrying out a planned

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program for the installation of additional monitoring devices in preparation for a reservoir fill from the existing elevation of

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approximately +35 feet to +47 feet during the period of October 1987 to December 1988.

The remedial work includes cleaning and relining of certain drainage ditches, inspection and stabilization of the spillway area and installation of additional piezometers and relief wells.

The filling of the reservoir and subsequent evaluation of the data from test will establish the hydrologic parameters for the structure. During the review and inspection, no areas of noncompliance were identified.

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Concrete Testing

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An inspection of the concrete testing activities was performed to assess

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the adequacy and adherence to the procedures of the testing requirements.

The concrete testing concerned Pour No. 9-DB-F-033-005.

The NRC inspector witnessed the sampling from the truck, temperature measurement, consistency testing, and air content testing.

It was noted that the f

method of. sampling, roding.. handling. and testing were in accordance to the American Society for Testing and Materials (ASTM) standards.

The unit weight testing and cylinder making were not observed. The concrete testing technician recorded the applicable data on the concrete test results data form.

No violations or deviations were identified.

14.

SAFETEAM Audit Review-Alicenseeaudit(530-701) was performed. from January 19 to February 13, 1987, to determine if employees had been' impacted in their employment, e.g., harassmant or intimation, because they had identified concerns to SAFETEAM.

Both manual, e.g., millwrights, boilermakers, carpenters, ironworkers, pipefitters, electricians; and nonmanual, e.g. QA/QC engineers, inspectors, employees were reviewed. The records of exit L

interviews, performance evaluations, rankings, termination, transfers, rate changes, warnings, and suspensions were audited. Only 2 employees were found to have conditions which suggested possible impact on their termination. An indepth review of the circumstances involving these employees found no evidence of harassment or intimation. The audit concluded that'there was no indication that any employees had been retaliated against for going to SAFETEAM.

The NRC inspector reviewed the report and data of this audit.

The inspector noted that of the sample of individuals reviewed who had gone to SAFETEAM was 123. Of these, 57 had been terminated for various reasons (forced, voluntary, or reduction in force).

This percentage (46 percent) is consistent with the general site turn over rate.

Based on the above, the NRC inspector agrees with the audit conclusions.

No violations or deviations were identified.

15.

Followup on Allegations j

(Closed) Allegation 4-86-A-017 This allegation was received, via telephone, by the NRC Region IV

. allegation coordinator on February 13, 1986. The complainant stated that he had found numerous errors in civil work packages that had been processed by the "QA Record Review Group."

The NRC inspector reviewed all civil packages (28) which had been reviewed during the identified period.

In one package, it was found that two

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blocks on a cadweld report were not checked; however, they were judged by the NRC inspector as not important:to the quality of cadweld.

In addition, the NRC inspector observed that some pages needed renumbering.

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.The NRC inspector did not note any errors'or omissions that 'had not

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. already -been corrected while reviewing the remaining packages. The number

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of corrections by this group did not appear to be excessive. The contention that there were errors in the docunentation was substantiated-

. by:the NRC inspector; however, the review did not indicate that any of the errors'were of safety significance.

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(Closed) Allegation 4-86-A-077 This allegation was that'Ebasco had numerous errors in the records of-safety-related. equipment and that the deficiencies were not being addressed by management even though a Management Corrective Action Request,'(MCAR)hadbeendrafted(seealsoAllegation4-87-A-008below).-

The alleger identified the MCAR as draft MCAR No.16. SAFETEAM

investigated this as. Concern No. 11225, a third party concern which are

- those concerns coming to the attention of.the SAFETEAM'from a source other

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than directly from the concernee.

In this case the source was information

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filed with the Department of Labor under the Energy Reorganization Act, Article'210..The SAFETEAM investigation found that MCAR No. 16 had been drafted as of November 5,1985, but was apparently not issued formally

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>4 because it was considered to cover much the same ground as Standard

- Deficiency Report (SDR)' No. E-014 that had been issued on January 17, 1985. The SDR was issued as the result of an audit finding docunented in Audit Report No. A-116-1 performed in August 1984.

Following issuance of the~SDR,. Surveillance No. SE-0817 was performed and a draft report prepared but apparently not issued.- SDR No. E-014 was closed on April 9, 1986, but SAFETEAM found in its review of the attachments to draft MCAR No.16 that 11 errors in 10 record packages originally identified were still uncorrected. SAFETEAM recommended that the errors be corrected.

SAFETEAM deemed that the allegation was substantiated.

The'NRC inspector duplicated the SAFETEAM investigation by a review of the

=draf t version of MCAR No.16, as well as SDR No. E-014, Audit No. A-116, and the associated surveillances.

It was found that draft MCAR No. 16 had five attachments.

The first attachment covered essentially the scope as SDR No. E-014. The second attachment covered essentially the same scope

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of deficiencies outlined in the unissued Surveillance Report No. SE-0817

- while the third attachment was a listing of additional deficiencies found

by the document review group (N-5 group).- The. fourth attachment was a l

listing of welder qualification records that had been reviewed and with j

.which there was no fault. The fifth attachment was a listing of Document Deficiency Memorandums (DDMs). This list of the deficiencies that identified some', if not all, of the deficiencies identified in attachment three.

It also appears that the second and third attachments were the results of the unissued Surveillance Report No. SE-0817.

It appears that when the decision was made to not issue or to void draft MCAR No. 16, no consideration was given to the fact that the deficiencies in attachments

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-16-o two and'three were not covered by SDR No. E-014.. When SDR No.-E-014 was closed, only the errors covered by' attachment one of draft MCAR No.16 had

been apparently addressed. Based upon the information outlined above, the NRC, inspector considers the allegation substantiated in that quality record' packages do contain numerous deficiencies.

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i In' order to ascertain the consequences of the above disposition in' terms'

of the licensee's quality assurance program and.the effect of the record i

deficiencies on plant safety, the NPC inspector requested; additional

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information.

The NRC inspector was informed by the licensee's quality

trend analysis group that at least 6 audits and/or surveillances of the

record. review process had been performed by.the licensee, Bechtel and

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Ebasco which.resulted in 11 SDRs being issued.. SDR No. B-212 issued'by q

Bechtel as aLresult of_ Audit No."SB-967; SDR No. E-448 issued by Ebasco as

a result of Surveillance Nos. SE-1305 and -1434; SDR Nos. E-504, -505, and j-506 issued as a result of Audit No..M-19-601; SDR Nos. E-512 and -513 l

issued as -result of followup to a concern identified in Surveillance.

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- No. SE-1398; and SDR Nos.. H-438, -439, -449, and -454-issued as a result

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of-an HL&P. Audit No. G-51-601 were reviewed in; detail with their i

associated audits or surveillances'by,the NRC, inspector.

Based upon a

review of these ac.tivity reports,-it' appears that while problems have been

identified with the process, they have been corrected in accordance with j

procedures. HL&P in response to the SAFETEAM recommendation reviewed the

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errors that were identified in the draft MCAR No. 16.,This review concluded that the errors were either corrected subsequently or were no problem (ofsuch~aminor' character)andthatcorrectionwasunnecessary.

But some. nontechnical (administrative) errors still' required correction

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and SDR No. H-405 was issued.

The NRC inspector. reviewed the administrative controls for handling MCARs.

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Quality Assurance Instruction No.11, revealed that there-was no provision

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for either voiding or'not issuing a MCAR once it has been drafted and given a serial number. There is a-requirement that each MCAR be approved by a member of QA management which implies that in the absence of such approval, the draft would not be formally issued.

Information provided by the licensee indicated that a total of 23 MCARs had been assigned serial

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numbers of which only MCAR Nos. 16 and 18 appear not to have been issued.

A file copy of the draft MCAR No. 16 had been retained.

In the case of MCAR No.18 there was no file copy of the draft.

The NRC inspector was informed that MCAR No. 23 was later issued to cover the same overall scope as MCAR No. 18. The subject of MCAR Nos. 18 and 23 was missed hold points as documented on Nonconformance Reports (NCRs).

NCRs do have a mechanism for closing specific issues. An MCAR does not need to be issued in order to effect specific corrective actions in the case of draft MCAR No. 18.

The generic corrective action was subsequently addressed in MCAR No. 23.

-The above described practice is not in violation of any NRC regulatory requirement or any licensee commitment.

Based on interviews with personnel active in the N-5 group, it would appear that early in the group's history problems were identified, but the mechanisms to deal with their issues were not clearly established.

Records _ originated by construction and QC are subject to a review by QC.

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Records are then' subject to a review for errors, omissions, etc., by Site Quality Records (SQR) or more recently by project Record Review Program (PRRP). Records are then placed in storage by the Records Management System -(RMS) and subsequently drawn out by the N-5 group. The N-5 group reviews and collates records for the purpose of issuance of-N-5 forms'as required by ASME Code.

Now, the appropriate procedures have been clearly established and appear to be functioning as intended.

Current members of the N-5 group say they are satisfied with the resolution of issues and the current program.

The NRC inspector concluded that the licensee and its agents have taken i

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appropriate management actions to address the problem of errors in safety-related record packages.

(Closed) Allegation 4-87-A-008 This allegation was that Ebasco had numerous documentation errors in i

records of safety-related equipment. SAFETEAM had investigated.a similar concern (see allegation.4-86-A-077 above).

In particular the attachments j

to draft MCAR No.- 16 of details in regards to errors identified by the

N-5 group and handling of SDRs have already been addressed above. Some

additional details'.in regard to traceability ASME Code name plates, a memo. dated December 9, 1985, and Code Case No. 225 were provided to the NRC.

The NRC inspector found that the N-5 group had been established in late

~1985.; The procedure governing its activities was QCP No. 17.2 which was

'still later replaced by QAI No. 25 which was still later replaced by SSP No. 21 in early 1986. The N-5 group did not issue any completed N-5 forms until mid-1986.

Presently a little more than 1/2 of the required (155) N 5 forms have been issued.

It appears th'at early in the

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N-5 group's history, e.g. late 1985, there was confusion on the scope and direction of the N-5 group.

For example, there was no formal method of documentation of problems. The procedure identified the use of NCRs i

however, NCRs were also required to have a hardware impact. Documentation

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errors do not'necessarily have a hardware' impact. Also, verification of hardware identification in the field was originally to be performed by the N-5 group but was later changed (Interim Change Notice (ICN) No. 3 to 21,1986) to the as-built verification by the Piping SSP.No. 21, dated May(PIR). Based on interviews with personnel active in Installation Review the N-5 group, it would appear that early in the group's history problems were identified, but the mechanisms to deal with these issued were not clearly established. Now, however, the appropriate procedures have been clearly established and appear to be functioning as intended.

Current members of the N-5 group say they are satisfied with the resolution of issues and the current program. More recently, 1986, N-5groupactivitieshavebeensubjecttotwoHL&P(SH-0856andSH-0835)

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and two Bechtel (SB-1179 and SB-1327) surveillances with no problems l

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identifie e

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-18-In regard to the traceability questions raised, the material identified on NPP-1 form Serial No.'37115 has been replaced prior to this inspection with material identified on form Serial No. 40250 which was traceable to the hardware installed. The material identified on NPP-1 form Serial No. 37697 was found to be traceable to the hardware installed. A review of current records found no further problems.

In regard to code name plates it was found that ASME (NCA-8312) requires nameplates only when the size or use will accommodate a nameplate. The materials identified were 3-inch pipe subassemblies which do not readily accommodate nameplates, therefore, their absence is an acceptable

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condition.

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The problems identified in the December 9, 1985, memo all appear to have been addressed prior to the NRC inspection.

In regard to Code Case No. 225, the NRC inspector found that the Code Case in question has been annulled because its requirements have been incorporated into.the Summer 1979 Edition of the ASME Code.

Prior to incorporation, Code Case No. 225 had been approved by the NRC in Regulatory. Guide 1.85.

The Bechtel specification identifies that the ASME Code Winter 1975 plus the Code Case maybe used or Winter of 1982 for this application (supports).

In either case the requirements are equivalent

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and the NRC inspector found no problems with the way the' issue was handled.

The allegation that numerous documentation errors existed in records of safety-related equipment was substantiated as noted above in Allegation 4-86-A-77.

The additional details were substantiated in part; i

however, the individual problems had been satisfactorily resolved prior to

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the NRC inspection.

Concern No. 11095 The NRC inspector reviewed this issue as part of an independent review of SAFETEAM' activities. These concerns were that certain valve dimensions after repair operations could be less than the vendor's original requirements and that engineers were not inspecting for seismic requirements. These concerns were investigated by SAFETEAM as concern No. 11095.

The SAFETEAM found that design engineering had no problem with the change in-valve dimensions when repair operations (cut out) occurred. SAFETEAM did not substantiate this concern.

In regard to the engineer signoff of seismic requirements, SAFETEAM substantiated this concern and recommended that a wrongdoing investigation be initiated. The wrongdoing investigation found no substantiation of wrongdoin _ _ _ _ _ _

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-19-I The SAFETEAM report identifies that an SDR No. E-423 was written to document the failures to follow procedures in regard to seismic inspection.

It seems that seismic' separation criteria were not established prior to summer 1985..This was identified during an INPO audit and a' finding was written. A Deficiency Evaluation Report (DER) No.85-018 was issued in May 1985 to identify this problem to the NRC which is still open pending Bechtel walkdown of all of the unit.

ICNs Nos. 5 and 6 were issued in January 1986 against SSP 10. A Notice of Procedure Violation, dated February 27, 1986, was written by the licensee documenting that engineers were failing to follow procedures.

In addition, an Ebasco Surveillance No. SE-1567 in June 1986 also identified a concern in this area that engineers were not thoroughly checking seismic requirements.

In April 1986, the. SDR No. E-423 was issued and it was used to close the Notice of Procedure Violation. The SAFETEAM report noted that the ICNs were in conflict in regard to seismic separation as an essential or nonessential inspection characteristic.

The NRC inspector reviewed the SAFETEAM files of this investigation and the activities and records of this individual's subsequent identification of these concerns to HL&P QA. The individual also identified three additional concerns when he supplied QA this information. QA addressed one of these additional concerns on hold tags in its close out'of SDR No. H-293. Two of these additional concerns on heat number verification and training information were resolved as a misunderstanding.

In regard to the-valve dimension concern, a Request for Engineering Assistance (REA)No.P-1-86-354 was issued which confirmed the SAFETEAM finding that there was no problem.

It would appear that the SAFETEAM investigation is satisfactory.

It should be noted that the attachments to DER No.85-018 identify that SSP Nos. 9, 10, 11, 28, 38, and two unissued SSPs were impacted by this problem. The NRC inspector found no conflict in the ICNs. The concern occurred because field engineers failed to follow procedures. Corrective action is documented in SDR No. E-423.

It should be noted, however, that as defined in SSP No. 61, the Ebasco inspection of seismic requirements is an inprocess type of inspection.

Bechtel has the responsibility for the final inspection of seismic requirements.

The NRC evaluation of this concern is that it is substantiated but of minor significance. Appropriate corrective action was taken to resolve the issue.

No violations or deviations were identified.

(Closed) Allegation 4-86-A-100

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This allegation was.that Ebasco had numerous nonqualified welders welding l

and that Filler Metal Issue Requests (FMIRs) contained errors. This allegation was not addressed by the individual to SAFETEAM. A review of SAFETEAM files found 14 similar concerns. Of these concerns, 5 of 14 were substantiated. This does not appear to be a significant number of the I

total substantiated concerns (170). Hence, the SAFETEAM did not identify this issue as a trend in SAFETEAM concerns.

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The NRC inspector found MCAR Nos. 19 and 20 which were relevant to this I

allegation of. chronic and numerous violations of the welding qualification procedure..It should be noted that the welding qualification procedure, SSP No. 31, is more conservative than ASME Code requirements e.g., more than one weld must be made.to extend qualification and qualification is extended only 1 month rather than 3 months. MCAR No. 19, issued against construction, on June 20, 1986, and closed on January 16, 1987, had as its corrective action a change to the procedure (SSP No. 30) on FMIRs. The

' approval of FMIRs was limited to fewer people. The qualification status of a welder was now to be verified at the time an FMIR was issued.

Welding engineering was to survey the FMIRs weekly. The welder

. ualification status chart and the FMIR forms were changed to ease their q

use by personnel.

The corrective actions to MCAR No. 20, issued against

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inspection, on September 28, 1986, and closed on December 4, 1986, were to change the inspection procedure (SSP No. 18) so'that all welder qualifications were verified at fit-up and final inspection _ points. Also, welding. inspectors were assigned to the rod issue stations until September 1986._ In addition to the above, a surveillance was performed of all ASME welds prior to September 24, 1986. The scope of this surveillance (SE-1753) was of the 23,600 previously inspected welds. A total of 40 welds were identified on NCRs as a result. This allegation was ver_1fied in that some unqualified welders had been welding. However, this problem was identified by Ebasco.QA in MCARs and corrective and preventive action taken.

Close out of MCAR No.19 was based on 25 clear surveillances and closecut of MCAR No. 20 was based on 22 clear surveillances.

Since MCAR Nos. 19 and 20 were closed, only 1 instance of unqualified welders has been found. The NRC inspector reviewed a sample of 60 FMIRs issued on February 23 and 24. This review found all were approved properly.

The welders were qualified and that there were no obvious errors or omissio.s of required data. This allegation was n

substantiated but found to have been addressed prior to the NRC inspection by Ebasco with appropriate corrective and preventive actions.

(Closed) Allegation 4-86-A-090 This allegation was that insulation pads on chill water lines coming right out of the reactor-(sic) were installed improperly without cleaning and

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removal of gaps on holding clips that-hold insulation on the pipe. This allegation was not addressed by this-individual to SAFETEAM nor was a similar concern found in the SAFETEAM files.

i No chill water lines connect directly to the reactor, however assuming

that the individual may have been referring to the Reactor Containment Building, the NRC inspector reviewed the Safety Analysis Report and found all chiller piping to the reactor buildings were classified as nonsafety except for the containment penetration itself.

The containment penetrations and their associated piping were field inspected by the NRC inspector and found to have no insulation or antisweat coverings. Attempts to contact the alleger for further details have been unsuccessfu _

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-21-i (0 pen) Allegation 4-86-A-111 l

This allegation was that there were many installations of instrumentation

and valves which had accessibility, operability and maintainability problems. This concern was investigated as SAFETEAM concern numbered 11227.

During a tour on October 10-11, 1985, the concernee identified 137 items to SAFETEAM. These 137 items were grouped into 20 generic problem areas, e.g. valve inaccessible, monorail interferences, improper supports. A special task force of; project, electrical construction, piping, instrumentation and controls, radiological support, and operating plant service personnel, a total of 10 individuals, reviewed these 137 items.

This review addressed issues.such as ALARA, maintenance, egress, operational, and nuclear vs personnel safety. Of the 137 items, 12 items were.found to require some corrective action. Of these items, 4 of 12 had been previously identified by HL&P. The SAFETEAM report concludes that

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none of the concerns identified could affect the safe operation or safe shutdown of the plant or affect the health or safety of the public.

It

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also concludes that items identified for rework would eventually have been addressed through normal maintenance activities.

It adds that "many independent on going activities and systematically implement programs designed to focus on specific areas or types of installations with the

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plant," could also addressed the same problems.

It identifies those activities and programs to be internal missile walkdown, valve accessibility walkdown, ALARA, etc. The SAFETEAM and engineering effort were reviewed by an independent nuclear architect / engineering consultant, Stone and Webster Engineering Corporation. The final Report 15871.01 PFESTP-02, dated March 11, 1987, stated that it reviewed the concerns, the engineering response and performed a field inspection of all items (except 3). The consultant report concluded "all dispositions appeared to follow generally accepted operations and maintenance practices."

It does note that Item B-66 was reworked after it had been dispositioned use as is.

The NRC inspector reviewed the SAFETEAM report and its files of the investigation.

It was established that the concernee had meetings and/or tours with Bechtel management personnel on September 6, October 7, and November 13, 1986, during which he identified items which do not appear in

the SAFETEAM list of 137 items.

SAFETEAM agreed to reopen the investigation to address all items identified by the concernee. The NRC inspector found that the October 7 tour was documented at the time; however, the November 13 tour was not documented.

During a review of the SAFETEAM field notes the NRC inspector found that the room identification of one item, B49, was erroneously identified in the SAFETEAM report. Also one item found on Page 19.of the field notes was omitted'from the list of 137 items in the SAFETEAM report.

The results of the October 7,1986, tour were, in part, identified on Design Change Approval Requests (DCARs) Nos. 740, 741, 742, and 743. Only DCAR No. 742 was approved.

No action was required on the remaining DCARs.

DCAR No. 742 relocated Drain Valve IA-1285 and airhead assembly in Room No. 67F at elevation 10 feet of the Electrical Auxiliary Building (EAB) in order to make it more accessible.

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l It was noted by the NRC inspector that-Item No. B-35 in the SAFETEAM report, the subject of DCAR No. 741, was identified as needing corrective

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action. However, this item was previously identified during the October 7,1986, tour by the concernee and the DCAR was rejected on November 3, 1986.. Therefore,' the corrective action was to " accept-as-is."

It was.also' found that the report dated January 28, 1987,'to the NRC and'

the concernee, identified Item No. B-61 as needing corrective action and not Item No. B-18 as not needing corrective action; however, the current

list of.the findings, dated February 5, 1987, were just the opposite.

1 The egress'puth walkdown was performed in September 1986', noted that the draft-report (punch list) dated December 3,-1986, did not cover the same areas as the problems identified by the concernee.

In addition, the valve'

accessibility walkdown had been performed, in part, on only about 30 of

.approximately 200 piping and instrumentation drawings (P& ids). Likewise it does notLyet cover the'same areas as the problems identified by the concernee. These generic programs could have identified these types of concerns if. they had covered the same areas.

A review of the engineering evaluation of the 137 items by the NRC inspector found that none of the items identified, in particular those for which corrective' action had been dispositioned, impacted on the safe operation of the plant, except for some possible ALARA considerations which will be the subject of a subsequent NRC inspection.

Examples of'

items reviewed are:

Item No. A-006 deals with nonsafety-related conduit, Item Nos. B-017 and B-018 deal with a safety-related valve'but not its

operation; only maintenance.

Item Nos. B-020, B-021, and B-022 deal with j

nonsafety-related valves and strainer.

Item No. B-035 deals with a valve-in the fire protection system but not its operation, only maintenance.

It

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is used to isolate other valves used to isolate hose stations etc.

Item j

No. B-054 an instrument vent valve for a safety-related air operated valve j

that is a redundant backup valve.

In regard to Item Nos. M-01, M-02, and A-03, they deal with safety-related valves and their operability..

However, these items were identified by the licensee prior to the

concernee's identification on the Master Completion List. The NRC l

inspector visually inspected a sample of the 17 items including a review of all identified for corrective action.

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This allegation will remain open pending review of the additional items that are expected to be added as a result of a reconstruction of the early meeting and tour.with Bechtel/Ebasco senior management and the alleger that had not been previously' documented item by item. One open item is the review of items like B-66 where after'the " accept-as-is" disposition of-a condition in the SAFETEAM report then it was then reworked as a

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result of startup activities.

(498;499/8707-03)

16.

Exit Interview

The NRC inspector met with licensee representatives (denoted in paragraph 1) on March 27, 1987, and summarized the scope and findings of the inspection.

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