IR 05000498/1987030

Insp Repts 50-498/87-30 & 50-499/87-30 on 861117-19 & 870420-0522.No Violations or Deviations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings, Followup on Allegations,Safeteam & Nuclear Security Dept

ML20235T586
Person / Time
Site:	South Texas
Issue date:	10/02/1987
From:	Constable G, Emerson M, Mcneill W, Tomlinson D, Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235T568	List: IR 05000498/1987030 ML20235T565
References
50-498-87-30, 50-499-87-30, NUDOCS 8710130137
Download: ML20235T586 (17)

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l APPENDIX l

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U.S. NUCLEAR REGULATORY.' COMMISSION '

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REGION IV

NRC Inspection Report: 50-498/87-30 Construction Permits: CPPR-128:

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50-499/87-30' CPPR-129 t i,' i Dockets: 50-498' Category: / 11 '

l Licensee: Houston Lighting & Power Company (HL&P)~

P. O. Box 1700 Houston, Texas 77001 Facility Name: South Texas. Project, Units 1 and 2 (STP) d Inspection At: STP, Matagorda County, Texas .

Inspection Conducted: November 17-19, 1986, and April.20 through May 22, 1987 l t J Inspectors: .

7 b .i W. M. McNeill, Reactor 'In'tpector, Project Date

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Section A, Reactor Projects Branch

R. Wise, Radiation Specialist, Facilities

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Radiological Protection Section

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M. li4Rmerson, Investigations and Allegations

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c).pp gy Date .

Coordinator 1

l '-/ To D. P. Tomlinsoh, RhactoT Inspector p Diiye /~/

Engineering Section

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Approved: _/ ) //) 7 WL.iConstable...ChieK Project SectAon C Dafe /

8710130137 DR 871006 ADOCK 05000498 PDR

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i 2 j Inspection Summary Inspection Conducted November 17-19, 1986, and April 20 through May 22, 1987 (Report 50-498/87-30; 50-499/87-30)  ;

i Areas Inspected: Routine, announced inspection of licensee actions on previous I inspection findings, followup on allegations, SAFETEAM and the Nuclear Security

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I Departmen Results: Within the areas inspected, no violations or deviations were identifie I-l I

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DETAILS 's

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i y i., PersonsCotitacteN O Principal License [ Personnel lh .)

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• J. - E. Geiger, General Manager, Nuclear Assurance .

I. L. Cethries Panager, SAFETEAM "

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B. L. Hali,cDeputy Manager, SAFETEAM / I

• S. F; Head, Lead Project Compliance Engineer l

/ A. O. Hill, Manager,-Nuclear Security Department (NSD)

M. F. Hutcheson, Staff Engineer r

• T. J. Jordan, Project QA Manager 3 M. A. Burnett, Principal Engineer, Site Licensing j C.'sR. Miller, Security Coordinator, NSD J U. E. Moore, Supervisor, NSD T. J. Sharpe, Investigator, SAFETEAM ,

R. Cink, Lead Investigator, SAFETEAM )

R. Darrin, Investigator, SAFETEAM J. C. Gallagher, Investigator Coordinator, SAFETEAM

• J. T. Westermeier, General Manager

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Bechtel Power Corporation

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J. O' Hair, Operational Plant Service Project Engineer Ebasco Services In K. Gilkerson, QA Engineer

• R. E. Powe, Lead QA Engineer Systems j R. Vesaly, Raceway QC Supervisor

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• Denotes those individuals atte 4 ding an exit i'nterview with the NRC i inspector ~

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I Licensee Actions on Previous Inspection Findings (Closed) Unresolved Item 498/8614-01; 499/8614-010 ' Work packages were

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found. wit.h errors oct being properly identITied and documente ,

s A surveill'ance was performed (No. SE-1465) on May 23-29,1986, by Ebasco'

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which verified the NRC initial observations. It also expanded the cample to include work packages on ten field welds, one bolted connection and i eight valves. It found the observation in question to be an isolated cas Surveillance Report No. SE-1465 concluded that the valve control card  !

program was being properly implemented. Additional surveillance,  ;

Nos. SB-1155 performed June 9 through July 3, 1986;.and 58-1122 performed June 10-18, 1986, were done by Bechtel to provide assurance that work packages included correct references to hardware and associated document !

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Six work packages were reviewed in Surveillance No. 58-1155 and five work packages in Surveillance No. SB-1122. No discrepancies were noted. The i

NRC inspector reviewed the above referenced surveillance _by Ebasco and Bechtel and found no problems with the conclusion This item is close (Closed) Open Item 498/8638-01; 499/8638-01: SAFETEAM to review other l investigations of cold spring after some faulty -logic was identified in the investigation of Concern No. 10874 in that.the weld identified in the allegation was not the closure weld; therefore, alignment of the pipe for the weld could not have resulted in cold spring in the pip SAFETEAM has reviewed all other concerns on cold spring and verified that investigative activities and their review by the review committee are sati s factory. There was no evidence of faulty logic as found in Concern No. 10874 in the e+her concerns. This process has been documented and was reviewed by the NRC inspector. The NRC inspector concludes that the faulty logic, attributing cold spring to a weld which was not the closure weld, with Allegation No. 4-86-A-029 (Concern No. 10874) was isolate This item and Allegation 4-86-A-029 are technically close (Closed) Open Item 498/8638-02; 499/8638-02: SAFETEAM.to review and establish the root cause of problems, the failure to follow QA program requirements identified in Concern No. 10742. The QA program requirements in question were to have proper paperwork for process control and proper documentation of nonconforming condition SAFETEAM has reviewed their concerns to establish the root cause, scope of the problem and preventative action. This further review has eliminated root causes such as inadequate training. It was established that the problems were unique to the individuals involved (personality conflicts).

The NRC inspector reviewed the documentation of this activity and agreed with the conclusion This item and Allegation 4-86-A-054 are technically close (Closed) Open Item 498/8632-01; 499/8632-01: Review of supplemental audit activities taken as preventive actions to Violation 498/8612-07; 499/8612-07, part The licensee and the NRC inspector reviewed in detail Audit Nos. S41-601, S44-601, and 547-601 and the 11 Standard Deficiency Reports issued as a result of these audits. Further review has established that the first audit (S41-601) on mechanical interface questions did precipitate the-subsequent audits (S44-601 and 547-601) on electrical and other subvendor j interface questions and that a number of findings were documented. A l

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5-notable amount of corrective and preventive actions were taken as a resul However, no significant deficiencies were identified such as defined in 10 CFR 50.55e(1)(iii).

This item is closed.

l (Closed) Open Item 498/8707-03; 499/8707-03: Followup.on l Allegation 4-86-A-111. See Allegation 4-86-A-111 which follows in this l report.

l Followup on Allegations (Technically Closed) Allegation 4-84-A-070 This allegation was that QC personnel had been harassed in several ways by a supervisor. This allegation was at first expressed to Ebasco in June 1984 and investigated by Ebasco QA as Concern No.84-08E. A total'of six issues were raised at that time. The six issues were being accused of holding up work, not applying uniform inspection standards, causing duplicate work, not trying to work with other personnel, falsifying reports, and " fudging" calculations. At the same time that this allegation was expressed to Ebasco it wri, in part, addressed to Houston Lighting and Power Co. (HL&P) who independently investigated the allegation as Concern No. 84-15 Some of the issues addressed to HL&P were the same: being accused of holding up work, not applying uniform inspection standards and falsifying reports, but new issues were also raised which included:

refusal to perform inspections, inaccuracy of tools, time-sheet errors, and stolen documents. The rest of the original issues (causing duplicate work, not trying to work with other personnel, and " fudging" calculations) were

! dropped by the allegers, but of course still investigated. Later in l November 1984, a SAFETEAM concern was registered (Concern No. 10341) on two l

issues namely: discrimination in the assignment of overtime and falsification of an inspection repor In January 1985, yet another SAFETEAM concern was registered (Concern No. 10480) on three previously identified issues: discrimination in the assignment of overtime, nonsupport by supervisor, and harassment by an engineer. These later issues were addressed in Ebasco Investigation No. 8501E also in January 198 In April 1985, a SAFETEAM concern was registered (Concern No. 10568) on three issues: unfair reduction in force, harassment by supervision, and an invalidated nonconformance report (NCR).' All of the above were concerns expressed by several inspectors generally operating in union as they expressed their concerns. Only a few technical issues were addressed such as inspection report falsificatio In all of the above investigative activity by Ebasco, SAFETEAM, and HL&P none of the issues were substantiated. The technical issues were not substantiated in that :

although an inspection report differed from field notes in regard to I certain parameters of inspection, both were found to be within toleranc J I

The NRC inspector reviewed the above concerns and their associated reports i and investigations. Based on the inspector's review and the reviews by j

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several independent organizations of many specific examples of harassment, none of which were substantiated, this allegation is considered not substantiate (Technically Closed) Allegation 4-85-A-068 This allegation was general in nature. The allegation was that quantity rather than quality was emphasized. This allegation was not addressed to SAFETEAM by the individual. However, the general subject had been the subject of a number of SAFETEAM concern '

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The NRC inspector found that SAFETEAM has records of 70 concerns dealing l with " quantity vs. quality." Only 6 of the 70 have been substantiate These figures do not appear to indicate a significant. trend in the 1920 concerns registered to date. In addition to not indicating a significant trend in reporting of concerns, the frequency of substantiation does .t '

appear to be significant. The NRC inspector found that the problems identified as substantiated were isolated events where supervision had emphasized quantity but not really at the expense of quality. For example, the amount of work reported performed was not accurate but no inspections 1 or rework were indeed sacrificed because of the inaccurate reports. Based '

on the general information provided this allegation could not be substantiated.

1 (Technically Closed) Allegation 4-85-A-116

This allegation was that Ebasco had engaged in improper construction practices in Unit Specifically it was alleged that there was no weld preparation for a -inch plate around the ring duct at elevation -2 feet between azimuth 100 to 206 ; installation of.the above was performed without proper paperwork; that work was performed on hold material (red tagged); and that work progressed past QC hold points in this same are The first issue was investigated as SAFETEAM Concern No. 10823. The ;

SAFETEAM investigation found that the welds in question were tack welds and ;

some were indeed made without the weld bevel or preparation. However, the- l investigation concluded that the absence of bevel did not affect the weld integrit Cleaning with Dimetcote No. 6, an ethyl silicote inorganic zinc paint used as a rust inhibitor or the weld surfaces was also questioned by the concerne .

Subsequent testing has proven that welding on surfaces i coated with Dimetcote No. 6 does not effect the weld integrit The SAFETEAM report concluded this concern could not be substantiate .l The latter three issues were investigated as SAFETEAM Concern No. 1083 The investigation concluded that hold points on Construction Traveler No. 2158220-006 were violate The SAFETEAM recommendations were for disciplinary action on the foreman involved and an NCR to be issue The foreman was terminated and NCR No. CC-03370 was issue In regard to the performance of work on hold material (red tagged), the investigation found l that work was performed on red-tagged structural beams at azimuth 159 elevation -2 feet. SAFETEAM recommended disciplinary action against the I

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participants and an NCR be written. Written warnings were issued and the condition also identified on NCR CC-03370. The inspector' involved was als retrained. This situation could have been.the subject of a conditional release and that is the reference to the installation without. proper l paperwor A conditional release could have been used since the hold i condition (red tag) was because of a coating problem which had no bearing on the welding of the clips to beam in questio The NRC inspector reviewed the SAFETEAM investigation and verified the facts, conclusions, and corrective action Although substantiated in part, the conditions appear isolated and immediate corrective action was taken; therefore, the licensees resolution of these issues was appropriat The alleger was tested in four inspection disciplines. His-lowest grade was on the ASME weldin Two of the four people tested.at the same time were interviewed. The others had left the site. They reported that they had not received a " study guide." The alleger was subsequently terminated for unrelated cause. The personnel interviewed believe that the " study guide" was stolen from the site. The " study guide" distribution was limited and the certification of this individual existed for a very limited period of time. The exam in question was voided by Ebasco at the time they became aware of this incident and subsequent personnel were tested with a new exa (Technically Closed) Allegation 4-85-A-108 This allegation identified that electrical supports, in particular cabie tray clips, were installed without QC inspection, cable tray clips were subjected to unauthorized rework, production was pushed in violation of- ,

l procedures, QC notification for inspection was not ' performed by personnel l required by procedures, that rework was performed before issuance of field i change requests (FCRs) and the rework again reworked to comply with the J FCR, and that incorrect material was used for cable tray clips because it failed to have the applicable stamping of a clover leaf.

l A review of SAFETEAM files found that this allegation was not submitted to )

l SAFETEAM nor were the subjects of this allegation addressed by SAFETEAM a j a concern.

l The NRC inspector, based on the room and elevation information supplied by the alleger, found that approximately 500 cable trays had been installed.in the areas identified. A significant number (about 20 percent) of these l

cable trays were nonsafety-related. All safety-related cable trays were l required by procedures to be subjected to QC inspection. Nonsafety-related cable trays were required by procedures to be subjected to a sample inspection by Ebasco field engineers. A sample of approximately 20 safety-related cable tray installation records (EE-580 cards) were inspected. It was noted that inspection of cable tray clips was performed !

sometime after installation. In one case, the sample inspection was 14 months after installation. However, all of the records did indicate that inspection was indeed performed. It was also verified by interview

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with Ebasco inspection personnel thatl inspections of such activities as cable tray clip welding was generally days if not weeks after the I installation activit The inspection of cable tray clip welding was described in quality control procedures (QCPs) such as QCP Nos. 10.16 and ,

9.5. At Step 4 on the EE-580 card, hardware used for mounting of a raceway (cable tray clips) was to be verified as the approved type, size, grade, and assembled in accordance with the applicable detail drawing. Material was to be verified in accordance' with procedure No. ASP-5. In review of {

the sample of EE-5?0 cards, it was noted that on occasions nonconforming 1 l conditions were documented on NCRs and deficiency notices (DNs).

l l In regard to material identification it was found by the NRC inspector that ASTM A-36 grade steel for safety-related use was identified with a color

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code and a clover. leaf stamp. The clover leaf stamp was applied after j onsite testing to upgrade such for safety related applications. It was )

also found by the NRC inspector that A-36 material was on site for several years (1984 to 1986) which was vendor tested and color coded (red gray) but not stampe q In review of the sample of EE-580 cards a high frequency of NCRs and DNs was noted by the NRC inspector. Further investigation found that this trend was identified in trend reports such as No. TIR E-015 dated July 198 Drawing violations and damage were frequent nonconforming condition Corrective actions included . additional training and use of a checklist for  !

construction. Subsequently a Management Corrective Action Request (MCAR)

No. 17 was issued in November 1905 because hardware was' installed not in accordance with the detail drawing. Corrective action was to train I construction supervisio A review was made by the NRC inspector of the DN and NCR history in the i area of cable tray installation'n. It was found that reports such as NCR l No. CE 05624 did document that unauthorized rework did occur on occasio l In regard to cable tray clips being installed without QC inspection, it appears that all safety-related trays were inspected and some nonsafety-related trays were not inspected. In addition, these inspections were performed not "in process" at the time of the construction activity l but " final" sometime later which would give'the appearance of having been missed. In regard to unauthorized rework, it appears that unauthorized 3 rework was identified during inspection activities; Nwever, the question  ;

of whether all unauthorized rework was identified, is inconclusive. In  !

addition to the " final" inspection of the hardware, surveillance did i identify unauthorized rework on occasio Examples of this are in Report j Nos. C-480 and C-502 dated July and September 198 '

In regard to production being pushed in violation of procedures, the above referenced.nonconformance reports on unauthorized rework support such an i observation. However, it should be noted that such problems were identified at the time of the events and corrective action was taken as a-result. In regard to notification for inspection, it was found that the '

required inspections were performed immaterial of who may have phoned the

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request to QC. In regard to rework being performed before issuance of FCRs, again inspections did verify conformance to the approved FC Nonconformance reports did on occasion note violations to FCR requirement In regard to incorrect material, the absence of a clover leaf in the time frame in question does not mean incorrect material was used for installatio In summary, this allegation is partially substantiated for the issues of unauthorized rework and pushing productio On unauthorized rework it can be said that the problems were indeed identified; however, both of these problems appear.to have been identified at the time of.their occurrence and adequate corrective actions take l

, This allegation is partially substantiated, however, significant impact on '

safet (Technically Closed) Allegation 4-86-A-111 This allegation relates to numerous problems identified on operability,  !

maintainability, and accessibility of equipment which for example wa addressed previously in NRC Inspection Report No. 50-498;49s/87-07. Issues remaining open (0 pen Item 8707-03) at the conclusion of that inspection were the establishment of other items that were identified by the concernee during other meetings and on tours. In addition, the NRC inspector looked'

for additional items, like B-66 which had been initially dispositioned by the Task Force to " accept-as-is," but was later reworked as part of hot functional testin SAFETEAM established that there are only three known walkdowns in which the concernee was accompanied by Bechtel engineering personnel. A new Concern  ;

No. 11445 was assigned to these items. .SAFETEAM also established another i Concern (No. 11447) which addresses a walkdown with the NRC on November 7 and 10, 1986. Concern No. 11445 addresses a walkdown on October 7, 1986, with the Assistant Project Engineer, and two walkdowns:on November 13 with the Assistant Project Manager of Completion and Test Services and Assistant Project Manager of Operating Services. As was the case with the original concern, which was addressed in NRC Inspection Report 50-498/87-07, the individual items of these new concerns were evaluated for acceptability by a Special Task Forc The Special Task Force consisted of the Bechtel 1 Assistant Project Engineer, Bechtel Lead Electrical Engineer, Bechtel-Lead l Instrument and Control Engineer, HL&P Staff Engineer, and HL&P Radiological ,

Support Supervisor. Concern No. 11445 addresses 61 items of which 28 are '

duplicates of the original concern 11227. Only one new corrective action item was identified (item No. H-14). Concern No. 11447 addresses 25 items of which 15 are duplicates'of the original Concern 11227. As in the original concern both of these reports concluded that if they were left  ;

undetected none of the concerns identified could affect the safe operation  !

or safe shutdown of the plant or affect the health and safety of the publi i

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The results of the Task Force Review have been reviewed and concurred with by the cognizant HL&P engineering personnel. As on the original concern, an independent architect and engineering consultant reviewed both of these concerns (11445 and 11447). After a field inspection by the consultant,

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the engineering resolutions of all-the new items were reconciled with field

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inspection results. Report 0FE-STP-03 dated May 4, 1987, concludes that all concern resolutions (either rework or remain-as-is) appear proper, reasonable, and in-line with acceptable engineering, maintenance, or operation practice. All dispositions appeared to follow generally acceptable operation and maintenance practice The NRC inspector reviewed the SAFETEAM and independent consultant report This review verified the dispositions on all items. It was also noted tha the disposition of the original 137 items was corrected.for Item B-35 from corrective action required to accept as is. Also the February 5, 1987, l list was verified to be correct for the disposition of Items B-61 and B-1 '

In addition, the erroneously identified room number for B-49 and the item missing on the matrix but found on page 19 of the field notes were found to be corrected, reviewed, and redispositioned by SAFETEA In regard to the new items (with the exception of potential ALARA considerations which are discussed below), the NRC inspector found none of the items impacted on the safe operation of the plant. The NRC inspector {

agreed with the disposition of the item In addition to the above, SAFETEAM developed three supplemental matrices regarding concerns Nos. 11227, 11445, and 11447. One of these matrices categorized each item in the concerns into categories of maintainability, operability, accessibility, personnel safety, design conformance, and susceptibility to damage. Another matrix related each of the categories to project activities which address that ite For example, Item No. B-1 of Concern No. 11227, which deals with the accessibility of valving in room 103 of the reactor containment building, was categorized as an accessibility question on one matrix. The other matrix then identified-some 11 project activities which address;that category of concern such as ;

valve accessibility walkdown, hot functional testing, limited power testing, and alike which would address the concern on that item. The last matrix describes the project activity, responsible organization, stage project life, purpose of activity, and disciplines affecte This matrix identified some 27 di'ferent project activities ranging from engineering design review to normal operational maintenance. The NRC inspector reviewed these matrices and noted that most but not all, items fit into one category. Each category had at least four project activities that addressed the concern and some with 11 or 13 activities. Most of the 27 project activities were completed, but not all. Exception being such activities as master completion list, limited power testing, and the lik Also, most of the project activities are subjected to NRC inspection or review. For example, such activities as engineering design review, nonconformance program, project records review, and startup testing activities have been subjected to NRC inspection. Such activities as high j energy line break analysis, seismic interaction, internal missile review l are subjected to NRC review. Only a few activities are not addressed by NRC inspection or review such as the STP model program. The NRC inspector found this was an acceptable general approach to these concerns and these type concerns on different item l l

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The NRC inspectors have reviewed the overall ALARA program and have found it to be generally acceptable. It should be noted, however, that the liquid and gaseous radioactive waste processing systems will continue to be evaluated by the Region IV staff as systems are completed and accepted by the licensee. The specific concerns raised in this allegation have been reviewed for ALARA concern Information utilized to evaluate the allegations was obtained from licensee correspondence to the NRC, SAFETEAM walkdown summaries, licensee ALARA walkdown, and from visual inspection during the allegation review which was conducted during May 21, 1987. The allegations are referenced by identification numbers assigned by SAFETEAM during their walkdow Item B-02, Concern No. 11227 stated that access to a valve gallery wa .

obstructed and would present a radiation exposure problem if not j removed. Access to the valve gallery is provided through an additional door from the east sid j I No greater potential of exposure to radiation will result from using the designed access to the valve gallery from the east sid I Item B-34, Concern No. 11227 stated that a series of valves located in an extremely hot radiation area are inaccessible for operation. Two of the valves were identified by'the licensee as process valves and require remote operation, two additional valves (BR205 and BR207) were not yet installed, and four vent valves were accessibl The space in which the valves are installed is limited but sufficient for normal operation, and should not present a radiation exposure problem when operation is require Item K-01, Concern No.11227 stated that a rubber hose attached to Control Valve CV-0381A will be affected by radiatio The vendor design package states that the rubber hose with protective braid will accommodate movement of operation and is designed for radiation exposure to 50 rads per hour. The equipment specification (G-95285) in which the Control Valve CV-0381A is covered requires that the valves and all parts thereof be capable of withstanding radiation exposure of 50 rads per hour in gamma.- The equipment supplier has certified that the valve can withstand an exposure of 50 rads per hou It is accepted that rems and rads are equivalent terms except for exposure of humans. It is also accepted that exposure to radiation will " affect" materials to some degree and therefore the allegation is-true but appears to have little safety significance since the exposure has been considered in the desig Item R-01, Concern No. 11227 stated that lines coming from a Liquid Waste Processing System (LWPS) seal water panel will contain radioactive water and require additional protection to prevent outleakage of radioactive water from the system.

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i The licensee reviewed.the design and the expected differential I pressures on the seals and stated that pressure on seal water system in the seal water egress corridor is higher than pressure in the LWPS l panel. With seal failure, no radioactive water could pass through the seal water corridors and present a contamination problem in the seal water supply line Item I-01 through I-14, Concern.No. 11227 and Item R-02, Concern No. 11445 stated that conduits on the floor form contamination traps at points of attachment to the floo These conduits and the respective conduit straps have sufficient clearance under the conduits and around the anchored straps to permit cleaning if necessar Item 001, Concern No. 11447 regarded access to.RHR pump seals for inspection, and stated that the pump seal is'approximately 9 feet above floor level, and that lowering the pump would reduce the potential for radiation exposure during operations and maintenanc The licensee reviewed the allegation and stated that the pumps are vertical operating pumps with bottom suction and side discharge and that the physical configuration would not permit lowering of the pum The pump is used infrequently during refueling outages and cooldown only. The mechanical seals are not normally inspected during operation and that failure of pump seals is immediately known by vibration monitorin J An ALARA review will be conducted prior to seal. replacement, and this review will be conducted in accordance with licensee approved )

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Item 002, Concern No. 11447 stated that two valves should be relocated to the front side of the pump to reduce radiation exposure to operators and maintenance personne One valve is a drain valve used to drain piping prior to pump maintenance while the other valve is an instrument root valve and is normally open. During normal operations no access is required. The pump is used infrequently during refueling outages and cooldow An ALARA review will normally be conducted prior to any pump maintenance and this review will be conducted in accordance with licensee approved procedures and accepted industry practices, t

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Based on the above review, activities of the technical and ALARA concerns as well as the generic approach, to this allegation are acceptable. The NRC inspector considers this allegation to have been partially substantiated; however, the design, construction, and operating procedures ;

of the facility address these types of concerns. Normal and acceptable l

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industry practice is that these kinds of considerations sre evaluated during the design of the plant. Subsequent testing and operational activities then normally result in system improvements to enhance the operators ability to safely operate the facilit In addition,.throughout the life of the plant, improvements are made as experience is gained and radiation levels are taken into account for specific maintenance or operational activitie HL&P has the programs and procedures in place to control these activities which will be routinely inspected by the NRC staf (Technically Closed) Allegation 4-87-A-005 This allegation was that Ebasco QC personnel had. identified problems associated with the processing of Field Change Request (FCR) No. EH-0026 This allegation was previously closed in NRC Inspection Report 50-498; 499/86-38. Upon review of additional information, namely a Department of Labor (00L) 210(a) compliant by the alleger, it was determined that the-exact area of concern had not been addressed. The DOL complaint identified that welding of fuel handling building HVAC plenum did not conform with the FCR in questio The NRC inspector found that Ebasco had performed an investigation into this allegation subsequent to the DOL complaint. The Ebasco investigation concluded that at the time of the initial welding inspection, welding configurations were not in accordance with the FCR and that the welds should have been documented on an NCR or D A later FCR (No. EL-01149)

provided an "as built" condition that would have oeen suitable for 'a justifying an accept-as-is dispositio The QC supervisor failed to validate a DN on the welding in question and failed to properly document this justification for invalidatio The NRC inspector found that the welding was subsequently documented on an NCR No. CH-03251 which accepted the welding in its'as-is condition. The 1 licensee did perform a review of this investigation and an independent followu The licensee found the-Ebasco investigation adequate and ,

thorough with no further investigation require In summary, the allegation is substantiated in regard to FCR EH-0026 Welding did not conform to the FCR; however, there appears to be no quality problem in that the welding was acceptable to engineering. The NRC inspector found nothing to disagree with that disposition. The ,

nonconforming condition involved a few feet of slightly undersize welds where shim plates had been used on one side of the plenu . SAFETEAM and the Nuclear Security Department (Investigations) l SAFETEAM Program The SAFETEAM was initially reviewed during a Region IV inspection conducted during October 21-25, 1985, and documented in NRC Inspection Report 50-498/85-18 and 50-499/85-16, Additional inspections of L

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l l SAFETEAM activities involving specific allegations have been conducted I on a continuing basis. SAFETEAM activities were also inspected as part of the operational readiness inspection (50-498/87-45).

Organizational Structure J The HL&P SAFETEAM Program is implemented under the direction of a Program Manager, SAFETEAM who reports to the Manager of Nuclear Assurance, who in turn reports to the Group Vice President, Nuclea The Deputy Manager, SAFETEAM is also responsible for the interviewers who obtain information from the various alleger Investigative Personnel At the time of this inspection, one Investigator Coordinator maintained responsibility for the activities of nine SAFETEAM investigators. A review of the personnel files revealed that eight of the investigators' educational and work experience was directly related to quality assurance / quality control. The remaining investigator possessed an undergraduate degree in criminology and has had previous law enforcement experience while serving in the United States Air Force. This investigator [

presently acts as one of the lead SAFETEAM investigator The Investigator Coordinator and three investigators were interviewed during this inspection. These individuals seemed highly motivated and possessed a good understanding of SAFETEAM procedures and regulations. These individuals also appeared to understand NRC jurisdiction and deportability requirement Information Flow I The manner in which SAFETEAM obtains documents and tracks i allegations remains consistent with that previously reported J under the aforementioned inspection reports. The SAFETEAM j organization has added the capability to obtain specific an j detailed information from their computer system through a " word i search" program capabilit l Review of SAFETEAM Files A computer printout of all substantiated nuclear safety and quality concerns, identified as Class 1, was obtained from ,

SAFETEA As of November 17, 1986, SAFETEAM records contained 1 96 substantiated allegations which involved nuclear safety and '

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quality which were designated Class 1. Of this list, 16 files were randomly chosen and reviewed for adequacy. The documentation associated with each case appeared to be complete and followed a logical sequence. The individual cases were discussed with the responsible investigators and no examples of improper or inadequate SAFETEAM activity were identified. Each

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of the substantiated cases reviewed contained recommendations which were forwarded to the SAFETEAM Review Committee for disposition. The SAFETEAM Review Committee is composed of the HL&P Engineering Manager, a senior Ebasco representative,-the HL&P General Manager for Nuclear Assurance, the SAFETEAM Program Manager and the SAFETEAM Investigator Coordinato Implementation of SAFETEAM Program The SAFETEAM program is being implemented as planne The classification of concerns, confidentiality, management support, documentation, management notification, and trending, as reported in the aforementioned inspection report remains in effec As observed during previous inspections, the actions taken by management regarding SAFETEAM recommendations are not clearly l documente The NRC inspector was not able to determine if any l actions were taken based on these recommendations through his l interview of the investigators and review of SAFETEAM rec.ords.

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This inspector observation is viewed as a program weakness. A review of the SAFETEAM Review Committee was not conducted during this inspectio b. Nuclear Security Department (NSD)

The Nuclear Security Department (NSD) is assigned the responsibility for the investigation of all potential wrongdoing matters which affect safety, security, personnel, and operations at STP. NSD documentation describes wrongdoing as follows:

"the generic definition of wrongdoing is defined by the NRC as deliberate, purposeful, willful violation of NRC regulations, licensee technical specifications, licensee commitments to the NRC or other laws or statutes of interest to the NRC. Examples of the allegations that-are referred to NSD by SAFETEAM are concerns involving record falsification; willful or deliberate violations; material false statements; discrimination as covered under section 210(a) of the Energy Reorganization Act; etc."

The majority of investigations conducted by NSD are' originated by the SAFETEA A limited number of additional investigations are initiated based on information provided by individuals directly contacting NS In addition to " wrongdoing" investigations, NSD conducts investigations of the following categories: drugs, alcohol, theft, vandalism, employee misconduct, possession of weapons, Plant Access Authorization System (PAAS) background investigations, failure to report, and Wackenhut irregularity report i i

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Evaluation by IMPELL On September 17, 1986,.the IMPELL Corporation of Norcross, Georgia, conducted a " categorization of wrongdoing allegations" performed in support of the NSD. This categorization was the initial step towards an indepth NSD investigation of potential wrongdoing allegation Utilizing the proposed NRC Manual Chapter 0517. " Management of Allegations," and the " Interface Agreement Between STP and SAFETEAM," a review of 64 packages containing potential

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wrongdoing allegations was performed by IMPELL. Within the l 64 packages, 72 separate concerns were identified of which l 30 concerns were considered to involve potential wrongdoing in need of further investigation. A majority of wrongdoing concerns

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involved welding QA/QC concerns. No wrongdoing concerns were identified in the areas of engineering, material control, operations, and/or industrial safet Review of NSD Files During this inspection, 69 files categorized as wrongdoing investigations were found to have been closed by NSD. A review of 16 of these files was conducted to evaluate the adequacy of NSD documentation.

l l The wrongdoing investigations which were found to have been l closed during the previous 6 months were found to include a revised report writing format. This "new" format included the following paragraph headings: Background, Persons Contacted, Investigative Action, Investigative Results, Conclusions, and Attachments. It should be noted that the attachments section of the report often included detailed written statements from the alleger, witnesses or other principals involved in the investigatio This "new" report writing format was found to be a clear,

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concise, and complete approach to investigative reporting. This l

format was evaluated as a major improvement to the report format

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used by NSD prior to a 1987. The majority of 1986 files were i found to contain uncorroborated statements of fact and conclusions. Written statements, from the investigations'

principals, were usually not present. The reports did not fully explain the investigations and left unanswered question A review of the investigations conducted by NSD, subsequent to

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the IMPELL evaluation, revealed many cases in which the NSD investigative conclusions contradicted IMPELL's conclusion This contradiction was usually not explained or documented. The following nine NSD investigations were evaluated as having inadequate documentation to support the conclusion reached by the

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NS NSD Case Nos. 86-007F, 86-0008F,'86-0009F, 86-0010F, j 86-0011F, 86-0012F, 86-0013F, 86-0014F, and 86-0015F. This 1 inspector observation is viewed as a program weaknes Interview of NSD Personnel

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During the course of this inspection, the investigative supervisor of NSD and three NSD investigators were interviewe These personnel were able to explain that the contradictions arising between the-IMPELL report and the NSD investigations were proper and that numerous errors had been discovered within the l IMPELL repor NSD personnel acknowledged that theNSD

' investigative reports, conducted subsequent to the IMPELL-evaluation, lacked detail. .These individuals hiso acknowledged that the 1980 and older NSD reports did not allow the uninformed reader to understand the details of the investigation Observations and Conclusions During this inspection, it was observed that'the most apparent weakness of the investigations conducted by NSD' involved the NSD investigations conducted as a result of the evaluation of wrongdoing concerns by IMPEL These reports did not. follow a logical pattern and were void of supporting facts to-justify the i conclusions. These reports also relied heavily on the interview of the SAFETEAM Investigator Coordinator. It was observed that the IMPELL suggestions were not routinely followed and that IMPELL mistakes were not documente The NSD interpretation of NRC's definition of wrongdoing appeared to be somewhat confuse The NRC inspector provided NRC's most current interpretation of wrongdoing and investigation initiation to NS . Exit Interview The NRC inspectors met with Messrs. I. L. Guthrie, B. D. Hall, and others several times during the course of the inspection of SAFETEAM AND NSD investigations to obtain additional information and to discuss the NRC inspector's conclusions. At an exit interview on April 24, 1987, with the individuals noted above, the licensee committed to address the above i program weaknesses including rewriting and clarifying all investigations !

involving concerns evaluated by IMPELL that resulted in contradiction l

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