ML19347E487

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IE Insp Repts 50-498/81-01 & 50-499/81-01 During Jan 1981. Noncompliance Noted:Failure to Follow Procedures for Storage & Maint of Equipment
ML19347E487
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 03/20/1981
From: Crossman W, Phillips H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16251A407 List:
References
50-498-81-01-01, 50-498-81-1-1, 50-499-81-01, 50-499-81-1, NUDOCS 8104270475
Download: ML19347E487 (18)


See also: IR 05000498/1981001

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U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-498/81-01; 50-499/81-01

Category A2

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Docket No. 50-498; 50-499

Licensee:

Houston Lighting and Power Company

Post Office Box 1700

Houston, Texas 77001

Facility Name: South Texas Project, Units 1 and 2

Inspection at:

South Texas Project, Matagorda, Texas

Inspection conducted:

January 1981

Inspector- _ [

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H.'S. Phillips, Resident Reactor Inspector

Projects Section No. 3

Date

Approved:

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W. A. Crossman, Chief, Projects Section No. 3

Datd

Inscection Summary:

Insoection of January 1981 (Recort No. 50-498/81-01: 50-499/81-01)

Areas Inscected:

Routine, announced inscection Dy tne Resicent Rea: tor

Inspector (RRI) included follow up inspections relative to noncompliances,

unresolved items, open allegations, Show Cause Order items, and storage /

maintenance of equipment; storage and handling of reactor coolant loop and

safety-related piping; and holding of safety-related piping.

tion involved seventy-five inspector-hours by one NRC inspector.This inspec-

Results:

Of the three major areas inspected, no violations or deviations

were identified in two areas.

One violation was identified in one area

(violation - failure to follow procedures for storage and maintenance of

equipment

paragraphs 4 and 7).

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DETAILS

1.

Persons Contacted

Principal Licensee Emoloyees

  • G. W. Oprea, Executive Vice President

"J. H. Goldberg, Vice President, Nuclear Engineering and Construction

  • R. A. Frazar, Quality Assurance Manager
  • L. K. English, Project Manager
  • R. A. Carvel, Project QA Supervisor (Civil / Structural)

T. J. Jordan, Supervisor Quality Systems

"D. W. Bohner, Project QA Supervisor (Electricai/I and C)

  • L. D. Wilson, Project QA Supervisor (Mechanical)

D. Powell, Construction Engineer

G. W. Jaunaul, Construction Area Supervisor

Management Analysis Comoany (MAC)

  • R. L. Hand, General QA Supervisor for Houston Lighting & Power (HL&P)

W. J. Friedrich, QA Manager for Brown and Root (B&R)

D. J. Harris, Quality Engineering Manager for B&R

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Westinghouse

Brown and Root Inc. (B&R)

  • J. McIntyre, Assistant Project Manager
  • F. W. Rothermel, PFM/ System Engineer Manager

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J. E. Adkins, Receiving, Storage, Mcintenance QC Supervisor

D. Lehr, B&R Area Engineer

  • F. G. Miller, Chief Welding Engineer

M. Hogg, Staff Engineer

V. English, Support Supervisor

J. Alford, Craft General Foreman

"J. Wood, Maintenance Foreman

W. Norris, lead Millwright

S. McCollough, Millwright

The RRI also interviewed other licensee and Brown & Root employees during

the inspection period including both craft labor and QA/QC personnel.

" Denotes those persons with whom the RRI held on-site management meetings

during the inspection period.

2.

Licensee Action on show Cause Order, Aor11 30.1960

The RRI reviewed Show Cause Order,Section V.A.,

Items 1,2,3,5,6,7,

8, 9 and 10 and determined that action had been taken or was sufficiently

complete to allow the RRI to recommend the resumption of placement of

safety-related complex concrete on a limited basis.

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The RRI continued the follow-up inspection relative to Show Cause Order,

Items 1 and 6 as follows:

(0 pen) Show Cause Order, Item V.A.(1): Management Consultant Review.

a.

HL&P Management of Program to Control All Aspects of the South

Texas Project; Revision of Organizational Responsibilities to

control the Design, Procurement and Construction Activities of the

Licensee's Prime Contractor, Brown & Root, Inc. (B&R), and HL&P

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Overall Responsibility for QA/QC Program.

-The RRI reviewed objective evidence relative to commitments listed

in the licensee's letter ST-HL-AE-533, dated September 18, 1980, and

closed the following items:

Item

Basis for Closing

A4

HL&P Procedure PSQP-A8, Revision 1, January 5,1981,

describes the evaluation of data for trends.

A5

PSQP-A9, Revision 0 issued September 26, 1980, and

sign-in sheets for training were reviewed.

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A10

Upper level management has participated in all

A18

phases of the project during the past months as

documented in meeting minutes in Brown & Root

correspondence, dated August 1, 1980, September 4,

1980, October 29, 1980, and November 12, 1980.

A13

The following courses have been conducted for the

QA/QC Management Team, which also included the

participation of Construction and Engineering

Management:

Subject

Date

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Management Seminar, PEJS-710-BT

September 19-20, 1980

Oasis Motor Inn, Bay City, Texas

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Philip Crosby Associates, Inc.

September 15, 1980

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Quality College

September 22, 1980

Winter Park, Florida

October 6, 1980

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October 27, 1980

Neva-"ar 10, 1c00

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-Quality Improvement Program

September 22-23, 1980

South Texas Project Site

A126

Data Analysis Summary, performed by Brown & Root Inc. ,

was documented in correspondence SQA-4327, dated

November 25, 1980. This analysis was an evaluation

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of nonconformance for trends in order for such non-

conformances and root causes to be corrected. Such

periodic reviews will continue during the life of

the project.

H1

The documents reviewed and listed in A10 above showed

a distribution to all key managers.

A monthly QA

Report, documented in correspondence ST-HS-HL-01383,

dated October 9, 1980, from HL&P Site QA Management

to top HL&P Management.

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Review of B&R minutes of monthly Project QA Meeting,

MS

dated August 1, 1980, September 24, 1950, and

November 12,19 0, showed reports being forwarded to

the cperating ci nmittee and board.

H11

Review of graphical presentation attached to HL&P

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letter (ST-HL-AE-568), dated October 31, 1980.

This

graph shows staffing from 1980 - 1986.

M5

The HL&P letter (ST-HL-AE-533), dated September 18, 1980,

Item No. M6 named the committee and shcwed the

commitment to be complete.

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b.

(0 pen) Show Cause Order, Item V.A.(6): The Licensee Shall Develop a

More Effective System to Provide for the Identification and Correction

of the Root Causes of the Nonconformances Which Occur.

The RRI reviewed commitments listed in the previously referenced

letter (ST-HL-AE-533) and closed the following items:

A126 &

Reference the basis for closing Item A126 previously

A127

listed in their report for Show Cause Order Item V.A.(1).

A151

HL&P letter ST-HS-00603, dated October 14, 1980, and B&R

letter SQA-4327, dated November 25, 1980, transmitted

trend analysis reports to HL&P Quality System and Audit

groups.

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B&R letters, minutes of QA meetings, dated August 1,

1980, A";"ct !?, , cog,

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1950, gave tne status of nonconformances, audit

deficiencies, and corrective action reports.

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3.

Licensee Action on Previous Inspection Findings

(Closed) Open Allegation (50-498/79-19-04): Vertical Cracks in Structural

Steel Clips in the Boron Injection Room of RCB, Unit 1, Elevation 36'.

HL&P had investigated this item by locating the area described above and

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inspecting the clips.

Inspection revealed that the clips had defects

and the condition has been identified in Brown and Root Nonconformance

Report No. S-C 4522, dated August 13, 1980.

The RRI reviewed this report to assure that the nonconformance was

identified and controlled in accordance with the B&R QA program.

The

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defect will be repaired in accordance with routine repair procedures.

The allegation was substantiated.

The RRI had no further questions on this item.

(0 pen) Allegation (50-498/79-19-05):

Pipe Sleeve Weld Defect 1/4" Deep

at Az. 300 Degrees, Elevation 8' in RCB, Unit 1 Near Work Panel 15.

HL&P investigated this allegation by locating and inspecting.the area

described above. Visual inspection of the area and review of drawings

showel that there were no pipe sleeves in this area.

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The LII visually inspected the area and observed that there were no

pi;e sleeves where welding had taken place. However, the RRI observed

that a pipe run passed through the wall at the alleged location and

requested inspection records and nondestructive examination of welds in

the general vicinity of piping run 2C 361P-SI-1205-KB2 (Revision 2).

This item will be reviewed after the examinations are made.

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(Closed) Open Allegation (50-498/79-19-06; 50-499/79-19-06):

Classification

of the Containment Polar Crane.

This allegation was based on the

alleger's premise that the equipment should be classified as safety-

related. An IE inspector explained that the STP FSAR Table 3.2.A-1,

page 3.2-22 did not require the equipment to be safety-related.

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on page 3.2-29, Ammendment 2 (October 9, 1978), states in part, "During

and after a seismic event, the component and it's supports are designed

to retain structural integrity and prevent collapse and damage to safety-

related equipment and structures.

Operability need not be retained."

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The RRI contacted the NRR Project Manager at NRC Headquarters to

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determine if this matter of changing the FSAR classification should

be pursued by NRR.

The present classification is correct, therefore,

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this matter is closed.

This allegation was substantiated, however, the classification will

remain nonsafety-related/ seismic.

The RRI had no further questions on this matter.

(Closed) Open Allegation (50-a98M 9-19-07; 50-299/79-19-07):

Storage of

Electrical /Mectanical Penetrations and Lack of Understanding by Warehouse

Electricians of Pegger Tests on Motors. The RRI visually inspected or

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observed the storage of electrical and mechanical penetrations. The

penetrations were stored in accordance with ANSI N45.2.2 and Brown & Root

Procedure GCP 35, Revision 0, dated August 28, 1979. The electricians were

retrained in meggering equipment on August 25, 1980.

The above actions

were documented in B&R Memo No. ST-BC-HS-03528, dated August 25, 1980.

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Minor maintenance problems were experienced relative to maintaining

the nitrogen blanket on electrical penetrations. The pressures on some

penetrations were decaying at a faster rate than desired, however, there

was no evidence to show that the condition was detrimental to the pene-

trations. As a precautionary measure, the frequency of inspection of

nitrogen pressure was changed from monthly to weekly. Maintenance

personnel were interviewed and they stated that they knew of no other

detrimental conditions. NCR No. SN-G1-4786 described a nonconformance

condition on mechanical penetrations.

In this instance, the minimum level

of storage required by ANSI N45.2.2 is Level "D"; however, B&R TRD A710G002-C

required Level "B" whicn exceeds the minimum requirement.

This allegation was substantiated in part, in that, there were scme minor

discrepancies that were identified and documented, however, they were

not deleterious to the equipment and had been corrected.

The allegation

that electricians did not understand megger testing could not be sub-

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stantiated, however, all had received training in megger testing.

The RRI had no further questions on this matter.

(Closed) Noncompliance (50-498/78-16; 50-499/78-16):

Failure to Ins::ect

Storage and Maintenance In Accordance With Procedures.

B&R Proredure MCP-3,

Revision 3, dated August 4, 1978, paragraph 3.1.2.2 and Append x "C,"

paragraphs II.a. through d. required 100% surveillance of m.intenance on

Class IE equipment by QC personnel. This procedure was not being followed.

Brown & Root Procedure GCP-35, Revision 3, dated February 21, 1980, now

requires verification of in process maintenance and storage instructions

and QC is now required to perform ESMI implementation verification on a

minimum of 50 items per week. This requirement has been exceeded during

the last several months since QC was performing 100% verification to assure

that the system was operating properly.

(Closed) Unresolved Item (50-498/78-18):

Storage cf Charging Pumps and a

Positive Displacement

mp in Mechanical Electrical Auxiliary Building

(MEAB) No. 1.

During an inspection conducted December 19-22, 1978, the

IE inspector found these pumps and electrical motors to be stored in an area

where excessive concrete curing water caused excessive humidity.

Protection

of this equipment under these conditions appeared to be marginal.

The

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IE inspector considered this item unresolved f.ince the licensee had

issued Brown & Root a memo to correct similar conditions.

The RRI inspected and observed this equipment on January 29, 1981, after

reviewing procedures and the quality history regarding storage and

maintenance.

This matter is upgraded to a violation.

See paragraph 5 of this report

for details.

(Closed) Unresolved Item (50-498/79-13; 50-499/79-13):

ESMI Cards for liigh

Head Safety Injection Pump No. 3 and Pump Motor Had Switched Equipeent

Numbers on the Respective Cards.

During an investigation conducted on

August 6-10, 1979, the IE inspector identified the condition described

above and considered this item unresolved since HL&P site discrepancy

memo (SDM) M-051 identified a similar discrepancy.

The licensee on January 30, 1981, verified that the equipment numbers now

match the proper ESMI cards.

The RRI reviewed objective evidence (ESMI

cards) and determined that corrections were made.

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(Closed) Unresolved Item (50-498/79-19-02; 50-499/79-19-02):

Licensee is

Correcting Problems Found in the Resolution of Old NCRs on Storage /

Maintenance.

During the NRC investigation conducted from November 19, 1979,

to February 7, 1980, an IE inspector followed uo on Allegation No. 9A

described in Investigation Report No. 79-19.

The IE inspector found that

the licensee's and contractor's system had identified the problems

desc.-ibed in the allegation and was in the process of taking corrective

action; however, the action was not complete.

Therefore, the IE inspector

left the item open pending final action and NRC review of the action.

The RRI reviewed Corrective Action Reports (CARS) No. 5-139, 5-149 and 5-157A

and confirmed that the licensee had required B&R to take corrective action.

A large file documenting corrective actions relative to HL&P Concern

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Memo (CM-064) and Site Discrepancy Memo (SDM-051) was also reviewed.

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The RRI performed routine and follow up inspection during November and

December 1980 and January 1981 and determined the in place storage of

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equipment was not adequate.

This item is upgraded to a violation since in place storage has been a

continuing problem fron December 1978 until the present.

(See paragraph 5

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of this report)

(Closed) Unresolved Item (50-498/79-22):

MEAB 1 Centrifugal Charging Pump 1A

and Electric Motor Heavily Contaminated with Sandblast Grit and Dust.

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During an NRC inspection conducted December 11-14, 1979, the above con-

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that this condition had been identified on a B&R ESMI Verification

Report, dated November 29, 1979, and immediate steps would be taken to

correct the inadequate storage conditions.

On January 29, 1981, the RRI inspected the subject pumps in MEA 8 1.

The

area where the pumps were stored still had a large amount of sandblast

grit and dust.

This item is upgraded to a violation, see paragraph 5 of this repcrt.

(Closed) Unresolved Item (50-498/80-10-01; 50-499/80-10-01):

Essential

Cooling Pump Motors Did Not Have Current Applied to Windings.

During a

routine inspection in May 1980, the RRI observed that power to tha subject

motors had been disconnected.

Three subsequent inspections were made of

this area since that date and no further problems were found relative to

power to electrical motors.

(Cicsed) Unresolved Item (50-498/80-33-01):

Sandblast Grit and Dust in

the Reactor Vessel, Loop Piping, Reactor Internals and Access Control to

this Equipment.

The RRI identified this condition on approximately

November 19, 1980, and discussed the conditions with licensee site

representatives on that date.

The RRI further discussed the unresolved

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item with licensee representatives on approximately December 19, 1980,

and advised that the unresolved item would be included in the NRC

Inspection Report No. 80-33, which described the November and December 1980

inspection findings.

In a meeting held on January 7, 1981, the RRI was

informed that the conditions described above were acceptable for this

stage of construction.

This item was upgraded to a violation on January 23, 1981, see para-

graph 4.b.

4.

Storace and Maintenance of Eouiement - Reactor Containment Building No. I

a.

Backoround

Unsatisfactory conditions relative to storage and maintenance of

safety-related equipment have been identified during NRC inspections

conducted from December 19-22, 1978, to January 1, 1981.

The licensee

informed the IE inspector that an HL&P memo had been issued to

Brown & Root, Inc. on December 19, 1978, to take action relative to

in place storage requirements for equipment and assure that requirements

were implemented.

The licensee subsequently upgraded the memo to a

Concern Memo (CM-064) on December 29, 1978, and then CM-064 was up-

graded to a Site Discrepancy Memo (SCM-M051) on August 7, 1979.

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The Concern Memo (CM-064) documented the NRC inspector's unresolved

item relative to the inadequate protection of equipment in MEAB,

Unit 1 and subsequently the licensee determined that storage pro-

tection recommended by the vendor was not consistently maintained;

and additionally, maintenance information for the positive displace-

went pump was not on the maintenance card.

Site Discrepancy Memo 50M-M051 was opened as a result of unsatis-

factory corrective action on the part of Brown & Root, Inc. At

that time the licensee considered the problem to be generic.

Eleven letters or memos followed and documented partially adequate

responses, extensions and inadequate corrective action until finally

Corrective Action Report No. 5-157 was issued on November 7, 1979.

It was closed out in B&R correspondence (BC-25991), dated April 15,

1980. HL&P correspondence (ST-HS-BC-01809), dated June 16, 1980,

closed out the B&R memo (SDM-MOSI) which had identified a generic

problem in B&R storage and maintenance.

The items identified in NRC reports from December 20, 1978, through

January 1,1981, were reviewed and inspected by the RRI for corrective

action as described in paragraph 3 of this report. During an exit

meeting held on January 23, 1981, the licensee was informed that all

open unresolved items pertaining to storage and maintenance would be

reviewed to determine if a generic problem remains and to close out

items where satisfactory results were found.

Subsequently, unresolved

matters 78-18; 79-19-02, 79-22 and 80-33-01 were upgraded to violations

as a result of the findings described in paragraphs 4 and 5.

b.

Reactor Pressure Vessel (RPV), RPV Internals Main Coolant Loco (MCL)

Pioing and MCL Pumo Volutes

On approximately November 19, 1980, the RRI identified unsatisfactory

storage conditions in the RPV, MCL piping and in areas where the

internals were separately stored.

Licensee representatives were

informed that the RPV, MCL piping (upper and lower) and the internals

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had fine sandblast grit and/or dust inside. Also, the RRI informed

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the licensee that access was not controlled since the RRI was able

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to enter the vessel unchallenged and without shoe covers. The licensee

was informed on November 19 and December 19, 1980, that these matters

would be documented as unresolved items in NRC Report No. 50-498,

80-33; 50-499/80-33.

On January 7,1981, the RRI was advised that the HL&P QA Manager

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of the South Texas Project and the Westinghouse Site Manager

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considered the previously described conditions to be acceptable

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and he was advised that they wanted to meet with him.

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stated that the conditions were totally acceptable, commensurate

with the status of construction.

The licansee was advised by

the Westinghouse Manager to do nothing, but since it is the

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licensee's vessel, they could do as they wished. He further

advised that the vessel was not in a storage condition.

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RRI stated that the vessel had been stored in place since being

placed in Unit 1 Containment. Also, the RRI pointed out that

little or no work had been performed inside the vessel or

loop since welding had ceased in early 1980 continuing through

December 1980.

On January 12, 1981, the RRI informed the HL&P

Manager QA STP that protecting the vessel from sandblast dust

or grit and access control to the vessel are required per

ANSI N45.2.2, paragraphs 2.7.4 and 6.2.1, respectively.

The

RRI again stated that the in place storage was inadequate.

On January 21, 1981, the RRI and the RRI's supervisor met

with the HL&P QA Manager, Project Manager and Discipline Project

QA Supervisor to discuss the conditions. HL&P representatives

stated at this time that access control would be improved;

however, dust was not considered a problem.

On January 22, 1981, the RRI and the RRI's supervisor performed

a follow-up inspection and found that the area around the top

circumference of the vessel had not been sealed with Griffolyn.

The area was open and allowed dust, grit anc rodents to enter.

Access to the internals was not controlled as stated it the

previous days meeting.

At a meeting, the HL&P Manager STP

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was advised of these conditions. He stated the vessel would

be sealed and access would be controlled.

On January 23, 1981, the RRI performed another follow-up

inspection at 8:30 a.m. and found that the vessel had been

sealed but several holes in the old covering, about one foot

in di3 meter remained at approximately 9:30 a.m.

The RRI

advised the HL&P QA Manager that unresolved Item No. 50-498/80-33-01

had been upgraded to a violation.

Reactor coolant pump casings 1A, 18, 1C and 1D are in place

and welded to loop piping which is connected to the reactor

vessel.

These casings had plywood protective covers, however,

one-half or three quarter inch gaps between the plywood covers

and nachined surfaces allowed sandblast grit and dust to enter

the casings and loop. This equipment was not sealed well enough

to meet Level "D" storage requirements.

The RRI subsequently performed a follow-up inspection and found

that the reactor vessel, piping loop and reactor coolant pump

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casings have now been properly sealed.

The protection of thimble

storage guides and racks meets Level

"D" storage requirements.

This reactor vessel head was adequately protected to level

"D"

storage requirements and access was controlled.

ihe failure to acaquately protect equipment storea in piace and

to adequately control access as de:-cribed above and as required

by B&R Procedure GCP-35, Revision 3 (February 21, 1980), para-

grschs 3.2.1, and 3.5.4 is a violation of 10 CFR Part 50, Ap;encix B,

Criterion V.

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Residual Heat Removal (RHR) Pumps

On Janaury 26, 1981, the RRI continued the inspection of equip-

ment stored in place in Reactor Building, Unit 1 to determine

the effects of the sandblasting operation.

Residual Heat Re.moval (RHR) pumps 1A, 18 and 1C were stored

in an area where heavy sandblasting had taken place.

The

pumps were covered with Griffolyn.

Pumps 1A and IB were not

protected in such a manner that would preclude sandblast grit

and dust from getting into the bearings.

Pump 3C could not

be inspected because sand was piled outside of the door which

was sealed.

The RRI determined that a Nonconformance Report had not been

written to identify the inadequate protection of this equipment.

This equipment was stored to Level

"B"

requirements until it

was moved to the Reactor Building and stored in place.

The

protection now given will not meet Level

"D" requirements

for protection against airborne contamination.

This failure to identify that the RHR pumps were contaminated

and issue a Nonconformance Report as required by Brown and Root

Procedure GCP-35, Revision 3 is a violation of 10 CFR Part 50,

Appendix B Criterion V.

d.

Steam Generators

The RRI visually inspected the outside appearance of the Steam

Generators.

In an interview with the cognizant engineer, it was

noted that the nitrogen purge was removed from the shell side

(secondary) exposing carbon steel matarial to atmospheric

conditions with openings sealed.

Special equipment was pur-

chased to control the environment, however, it'had not been

connected because Westinghouse did not want to expose the

Steam Generators to the present environment.

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This matter is an unresolved item pending further review.

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(No. 50-498/81-01-04)

e.

Safety Injection System Accumulators and Pressurizer

Three Safety Injection System accumulators are stored in place

and have a nitrogen blanket.

Protection of this equipment meets

Level "0" storage requirements.

This Pressurizer was stored in olace and had a nitracan bl='kat.

The storage met Level "D" requirements.

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No violations or deviatiens were identified.

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5.

Storage and Maintenance of Ecufpment - Mechanical / Electrical Auxiliary

Builoing

On January 29, 1981, the RRI inspected the in place storage of equipment

in Mechanical Electrical Auxiliary Building (MEA 8), Unit 1.

Pefueling

Water Purification Pump (M-0410), Centrifugal Charging Pumps (M-0370),

Baron Recycle and Waste Pumps, Letdown Chiller / Reheat Heat Exchanger

(M-0396/0395), Sealwater Heat Exchanger (M-0366), Tnermal Regenerative

Demineralizer Tanks (M-0389 through 0393) Closed Cooling Water Heat

Exchangers (M-0570 and M-0571) and Recycle Holdup Tanks (M-0019 and

M-0020) were inspected.

The nitrogen pressure on one of the Closed Cooling Water Heat Exchangers

(M-0571) was noted to be lower than required (actual 1 psi versus the

required 3 psi).

There were no covers on the Recycle Holdup Tanks while

work such as painting was being performed (immediate corrective action was

taken to replace the covers).

These matters are considered unresolved and

will be reviewed during future inspections by the RRI.

NRC Report No. 50-498/78-18; 50-499/78-18, inspection conducted December 19-22,

1978, identified inadequate storage of Centrifugal Charging and Positive

Displacement Pumps because of exposure to curing water.

NRC Report No.

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50-498/79-22; 50-499/79-22, inspection conducted December 11-14, 1979,

identified inadequate storage because sandblast material was contaminating

the Centrifugal Charging Pumps.

The RRI found that B&R had initiated an NCR on September 9, 1930, which

was almost nine months after the NRC identified the problem. NCR

No. SG-2691 idantified this pump as nonconforming and indicated that

the condition of moving parts was considered indeterminate. Additionally,

the NCR identified'the same nonconforming conditions for Chiller Pumps,

Reactor Coolant Purification Pumps and Refueling Water Purification Pumps.

The recommended corrective action response was due from the Westinghouse

Site Manager by October 30, 1980.

The Westinghouse Site QA Manager

responded to the Material Review Board with corrective action on

January 29, 1981.

l

A follow-up inspection on January 19, 1981, revealed that Centrifugal

Charging Pumps still were not properly protected since sandblast grit

!

and dust were in the storage area.

The Charging Pump area was covered

(

with a Kelly Closure and the roof was damaged, but was covered with

l

Griffolyn.

This means that the pumps have either been rotated without

l

removing the sandblast grit and dust or t!'ey have not been rotated

because the NCR was not initiated or dispositioned in a timely manner.

This matter will remain unresolved pending review of the corrective

action by the RRI.

l

l

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.

.

6.

Storace and Maintenance of Egaiement - Warehouse

The RRI accompanied a maintenance foreman who performed maintenance

of equipment selected by the RRI.

The equipment selected was that which

was previously identified by HL&P Site QA in a letter, dated March 12, 1980,

as improperly maintained. The RRI inspected the following equipment for

proper maintenance:

Reactor Make up Motor Pump Motor, 3R272NPAZ01A, ESHI-M-3088C

a.

b.

Auxiliary Lube Oil Pump Motor, WP0 274413, ESMI-M-3088C

Regenerative Heat Exchanger, WPO 274472 (maintenance not

c.

required)

d.

RHR Pump Motor, WPO 248002, ESMI-E-0742

e.

Butterfly Valve, WPO 299859 (maintenance not required)

No violations or deviations were identified.

7.

Surveillance /Inscection of Eouipment Maintenance and Storace -

Reactor Containment Building No.1

The Brown & Root quality assurance / control, housekeeping and storage

maintenance procedures require surveillance / inspection of the above

areas and records (ESMI cards).

The RRI reviewed QA Examination Check

Sheets relative to the RPV and RPV internals Housekeeping Zones.

These sheets documented inspections which showed satisfactory results

from October 14, 1980, through January 16, 1981.

These findings ao not

'

correlate with the actual conditions previously described.

B&R ESMI

Verification Reports document satisfactory storage conditions on RPV/

RPV internals from October 21, 1980, through January 1981, and these

inspections do not correlate with ac^ual conditions previo: sly described.

These verifications are based on the ti.'t! card data / instructions and

.

i

this may account for the satisfactory results since these instructions

are not entirely adequate.

ESMI Verification Report 539 (December 1980),

447 (November 1980), 425 (November 1980) reported satisfactory storage

conditions for the RHR pumps.

identified, but have not been corrected. Inadequate storage conditions have been

The RRI reviewed B&R Housekeeping Inspection Report, HIR 42, dated

March 28, 1980.

This report stated that the interior of the vessel

was not well kept, in that, sunflower seed (food), trash (paper) and

used grinding wheels littered the bottom of the Unit 1 vessel.

Even

though reinspection, performed by B&R on April 18, 1980, documented

correction of these conditions, this instance is highlightad to

e ph2:i:2 thit :cc;ss c;atrol and :acterial accountability must be

improved when work resumes inside the vessel.

13

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.

.

-

The RRI reviewed Equipment Maintenance and Storage Instruction (ESM

cards to determine if adequate instructions are available for maintenance

and inspection personnel.

maintenance was performed. The cards were also reviewed to determine if

The following was found:

No instructions were given relative to access control, material

a.

accountability or assuring that the RPV (ESMI M-0321C) is pro-

tected from airborne contamination.

The comments on the back of

the card on April 17,1980, July 12,1980, and October 9, 1980,

indicated a problem with airborne contamination and residue

left from penetrant testing,

b.

" Westinghouse Recommended Storage Criteria" recommended that

RPV internals (ESMI M-0427/M-0428) stored per Level "C" be

covered with dust cover which is fire, tear resistant and

waterproof.

No cover was observed.

The card did not have

instructions on it relative to this covering.

Sandblast grit

and dust was in this area; therefore, level "C" requirements were

not met.

The card does not state that shoe covers were required;

however, Westinghouse criteria recommended the use of shoe covers.

The notes on the ESMI card indicated dust in the area on July 28,

1980.

.

c.

RHR Pump:

instructions indicate level "B"

storage is required whileA, 6, and C, (ESMI, M-0344

in the warehouse; however, once they are stored in place, the

instructions state, " protect frcm detrimental environment."

The notes on the ESMI card for Pump A indicate that level "B"

storage could not be maintained because of sand and water as

of July 31, 1979.

On August 22, 1979, the notes indicated that

the shaft could not be rotated quarterly as required on the

card, however, the Westinghouse representative stated that the

requirement would be deleted.

Similar notes relative to dirt,

shaft rotation occurred on April 17 and 24, 1980, May 22, 1980,

and July 17, 1980.

Similar notes were found on the ESMI cards

for Pumps B and C.

with Level "0" requirements.These pumps are not stored in accordance

,

This failure to develop adequate instructions and procedures that incor-

!

Revision 3 (Februaryporate vendor maintenance, ANSI N45.2.2 and B&R Pro

21, 1980)

,

j

violation of 10 CFR 50, Appendix B, Criterion V. requirements for in place storage is

!

8.

Receivina and Storace

The RRI reviewed South Texas Project Monthly Site QA Activity

Report No. 43, December 1980, and made the folleving ahec~e-ti:r.s:

14

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.

.

a.

Receiving

Eighty-three inspection reports were generated for receipt

inspection activities during this reporting period.

Eighteen of

these reports reflected unsatisfactory conditions resulting in

fourteen NCRs being issued (all eighteen are covered by these NCRs).

One hundred ninety-one warehouse requisitions were approved for

issue to construction.

Present inspection backlog as of December 27,

1980 is nineteen.

b.

Storage

Storage and maintenance requirements, as indicated by ESMI cards,

were verified on 1,548 items.

Sixty-four unsatisfactory conditions

were noted and placed on " suspense hold." Thirty-one of the

seventy areas inspected and documented on storage inspection report

forms showed unsatisfactory conditions.

No NCRs were generated

as a result of unsatisfactory maintenance / storage inspection

reports.

Only four percent of the 1,548 items that were inspected for

storage and maintenance showed unsatisfactory conditions.

However, forty-four percent of the storage areas inspected

were unsatisfactory and no nonconformance report was issued

nor was a trend identified.

In view of the RRI inspection

findings, it appears that a trend should have been identified.

These matters will be considered unresolved pending further review by the

RRI.

9.

Review of Open Nonconformance Reoorts

The RRI reviewed the January 27, 1981, computer run which listed

all open Nonconformance Reports.

As a result of reviewing several

l

Nonconformance Reports in detail, it was found that approximately

forty-nine nonconformancas, which were controlled by the Brown & Root

nonconformance system, had been closed out by letters from the

Westinghouse Site Manager. The letters stated that the Nonconformance

Reports (NCRs) were closed on this Westinghouse equipment because no

i

l

nonconformance ever existed.

1

'

The subject nonconformances dealt with the following equipment:

a.

Computer Cabinet

l

b.

Four-inch Dischram Actuatad Control Valve

c.

Reactor Coolant Pumo Internals

l

15

l

I

l

l

!

_ _ _ _ _ _ -__ _ - ____ - - ______-______

_

,

_

-

d.

Pressurizer Relief Tank

Steam Generator

e.

f.

Reactor Trip Switchgear

The above examples appear to be valid nonconformances

testing, design criteria and reports should have

The description of

.

a

Westinghouse site operations dJes not have a

.

m procedure to

This item is unresolved pending further inspection.

.

10.

B&R Maintenance and Storace Orcanization

.

Section 3.1 describes responsibilities of the PQA S

, 1980).

house Department, Storage and Maintenance (S&M) Department

, Ware-

Discipline Superintendent and S&M Technicians.

, Area

The RRI was unable to obtain an up-to-date organization for the

-

site construction organization and has unsuccessfully attempted to

obtain such charts since August 1980.

a February 1980 chart; however

The only chart available was

correct the condition when appr,oved and distributed.a draft was available whi

Engineering Manager to discuss how the organizatio

RRI was given an organizational chart, dated October 27

The

.

Maintenance Procedure GCP-35, Revision 3, dated

, 1980.

The RRI found that GCP-35, Revision 3, dated February 20

That is, they perform duties relative to receipt inspection

, 1980, does not

maintenance and ESMI records for safety-related equipment.

, scheduling

of an updated organization chart and a description o

appropriate procedure (GCP-35, Revision 3 (February 19

11.

Veldina of Safety-Related Pinino

The RRI visually inersc+

ater piping, CC-1103-WA3 (Sheet 1) Spool 1, in MEA 3-1 at elevat

25'.

.

No violations or deviations were icentified.

16

_

.

.

12.

Unresolved Items

Unresolved items are matters about which more information is required

in order to ascertain whether they are acceptable items, violation,

or deviations.

Six unresolved items disclosed during the inspection

are discussed in paragraphs 4, 5, 8, 9 and 10.

13. Management Meetinas

The RRI met with one or more of the persons identified in paragraph 1 on

January 7, 9, 15, 19, 20, 21, 23, 27, 28 and 29, 1981, to discuss inspection

findings and to discuss licensee actions and positions.

.

17

.

. .

. _ _ . . . _ .

_]

. . , . . _

.

_

Ixsnc Io a.

II Inspection Report No. 50-498/81-01; 50-499/81-01

Licensee:

Houston Lighting and Power Company

Location:

Matagorda County, Texas

Tacility:

South Texas Project, Units 1 & 2

Type of Licenses:

}{,1250 I*de, PWR

Opa of I: spec:1en:

Pesident, routine, announced

Dates of I:spectica: January 1931

Ca:es of Previous I: spec:ien:

tiovember - December 1980

I: spec: ors:

HSPhillips

SCCPE OF I'ISPECTION

Resident inspection program for construction

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84

UNITED STATES

yj

NUCCEAR REGULATORY COMMIS810N

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sit avam et.aza on ve, surre isos

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AnuwoTow,Taxas mii

,

January 27, 1981

In Reply Refer To:

"

RIV

'

Docket No. 50-498/Rpt. 81-02

50-499/Rpt. 81-02

-

9

Houston Lighting and Power Company

ATTN:

Mr. G. W. Oprea, Jr.

Executive Vice President

Post Office Box 1700

Houston, Texas 77001

_

Gentlemen:

This refers to the inspection conducted by Mr. D. P. Tomlinson of our staff

during the period January 5-9, 1981, of activities authorized by NRC Con-

struction Permits No. CPPR-128 and 129 for the South Texas Project, Units

No.1 and 2, and to the discussion of our findings with Mr. R. Hand and

other members of your staff at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the

enclosed inspection report. Within these areas, the inspection consisted

.

of selective examination of procedures and representative records, inter-

views with personnel, and observations by the inspector.

.

Within the scope of the inspection, no violations were identified.

We have also examined actions'you have taken with regard to previously

identified inspection findings. The status of these items is identified

in paragraph 4 of the enclosed report.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2.

Title 10 Code of Federal Regulations, a copy of this letter and the enclosed

inspection report will be placed in the NRC's Public Occument Room.

If ^he

report contains any infonnation that you believe to be proprietary, it is

necessary that you submit a written application to this office, within 20 days

i

'

of the date of this letter, requesting that such infonnation be withheld from

public disclosure.

The application must include a full statement of the reasons

l

why it is claimed that the information is proprietary.

The application should

be prepared so that any proprietary information identified is contained in an

enclosure to the application, since the application without the enclosure will

also be placed in the Public Document Room.

If we do not hear from you in this

regard within the specified period, the report will be placed in the Public

Document Room.

STAFF EXHIBIT f40. 84

DM E d

0o90097

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.

.

- -

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6

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.

.

Houston Lighting and Power

Company

-2-

January 27,1981

Should you have any questions concerning this inspection, we will he pleased

to discuss them with you.

Sincerely.

l }f

=E"

_

W. C. Sei

e. Chief

Reactor Co truction and

Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-498/81-02

50-499/81-02

.

_

.

.

U. S. NUCLEAR REGULATORY COMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

.

Report No. 50-498/81-02; 50-499/81-02

Docket No. 50-498; 50-499

. Category A2

Licensee: Houston Lighting and Power Company

Post Office Box 1700

l

Houston, Texas 77001

Facility Name: South Texas Project, Units 1 & 2

i

Inspection at: South Texas Project, Matagorda County, Texas

Inspection conducted: January 5-9, 1981

Inspector:

wf

l-24-al

D. P. TomlinsdrrtTeactor Inspector, Engineering Support

Date

Section

Approved:

/

//27/8/

a=_-__-

W. A.~Crossman, Chief, Projects Section

Date

.

/ /'

l- W H

R. E. Hall, Chief Engineering Support Section

Date

1

Inspection Summary:

'

Insoection on January 5-9, 1981 (Report No. 50 408/81-02; 50-499/81-02)

Areas Inscected:

Unannounced follow-up inspection of construction activities

pertaining to the resumption of ASME welding, re-examination and repair of

existing ASME welds; and review of responses to NRC Inspection Report No.

l

50-498/79-19; 50-499/79-19 findings. The inspection involved thirty

inspector-hours by one NRC inspector.

i

Results: No violations were identified.

1

l

l

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OwPE of

l

$1o310o34E

1

_

..

.

_

.

. - . -

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. _ . . .

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. _-

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-

,

.

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,

,

i

I

DETAILS

i

1.

Persons Contacted

Principal Licensee Encloyees

__

_

  • T. J. Jordan, Supervisor, Quality Systems
  • L. D. Wilson, Project QA Supervisor

Other Personnel

  • R. Hand, Project QA General Supervisor, Management Analysis Company (MAC)

R. McCarra, Welding Engineer, Brown & Root (B&R)

G. Genzer, Welding Supervisor, B&R

F. G. Miller, Senior Welding Engineer, B&R

The IE inspector also contacted other licensee and centractor employees

including members of the QA/QC and engineering staffs.

  • Denotes those attending the exit interview.

I

2.

Site Tour

The IE inspector tound several areas of the site to observe construction

operations and general housekeeping. Areas visited were Reactor Building

No.1 MEAB No.1, MEAB No. 2 and several storage areas.

No violations were noted.

3.

Resumption of ASMEsWelding

The IE inspector reviewed the B&R Ten Week Work Plan for resumption of

ASME Code welding.

A tour was made of MEAB No. 1, cubes 3E, 3F and 3J

to visually inspect completed welds and to observe welding activities in

progress.

Of the twenty-two piping welds completed, four wem randomly

selected for visual inspection. The four welds, all in the component

cooling system, were: CC 1425-FW 0008, CC 1428-FW 0005, CC 1428-FW 0008

and CC 1428-FW 0011. The weld surfaces and adjacent base material were

!

visually inspected for conditions such as undercut, excessive reinforce-

ment, por:,sity, cracks, arc strikes, proper contour and general weld

appearance. All four appeared to meet the Code recuirements. The IE

inspector witnessed part of the joint edge preparation repair operation

on weld CC 1435-FW 0006.

The weld prep area had been damaged during

l

handling and required minor repairs prior to welding.

A review of

documentation showed that work was being performed in accordance with

MECP-4, Revision 11 and was being accomplished by a qualified welder.

Portions of the pre-weld fit-up and tack welding operations were observed

on welds CC 1410-FW 0002 and CC 1435-FW 0004.

The operations observed

appeared to be in accordance with MECP-4, Revision 11 and Code require-

ments.

-2-

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l

- - . . . . - -

- .

.

- -

. . - - -

. - .

-.

.-

. _ - - - .

~

.

i

.

.

During a tour of the fabrication shop, the IE inspector observed several

small bore piping assemblies in various stages of completion, but no

work was being accomplished on them at the time.

Control of tools and

handling equipment for stainless steel, material appeared to be adequate

in the fabrication shop.

The IE inspector observed reinspection operations being performed on

three circumferential welds that were part of the ECW system. These

joints were located in the material lay-down yard and were being liquid

penetrant inspected as part of the ongoing re-examination and repair

program. The IE inspector did not determine the identificacion numbers

j

of these joints, but observed the inspection techniques from a distance.

Observation from a distance was utilized, in this instance, to verify

that procedural times and techniques were being complied with when the

' inspection personnel were unaware that they were being observed. The

remote observation indicated that the inspections were being conducted

within the parameters established by inspection procedure ST-NDEP-4.1,

Revision 9.

Qualification verification of the personnel perfonning the

l

inspection was accomplished by having the area supervisor identify the

inspectors and reviewing the qualification records of each. This review

indicated that all three inspectors were properly qualified in accordance

!

with the provisions of SNT-TC-1A.

l

l

4.

Status of Previously Identified Items

The status of remaining open items from IE Inspection

port No.

50-498/79-19; 50-499/79-19 and from the response to the resultant Order

to Show Cause related to welding and NDE was reviewed.

None of the

remaining open items have been completed and documented a.uch that

corrective action could be thoroughly verified.

No items were closed

during this inspection.

5.

Exit Interview

The IE inspector met with licensee representatives (denoted in paragraph

1) at the conclusion of the inspection on January 9,1981. The findings

of this inspection were discussed with emchasis on the need for closure

of the remaining open items.

I

-3-

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NRC C:nstructicn Permi s No. CP::.-123 anc 129 f:r Scu n Texas F- je::, Units NO.

1 anc 2, arc to the ciscussien :# cur fincines witn Mr. R. A.

ra:ar anc ::ner

tem:ers of your staf# a :ne c:nclusien of :ne ins:ec-i:n.

Areas examined curing :ne ins:ecticn and Our fincings are ciscussac in :ne

enciesec inscection report.

Within :nese areas, ne ins:ecticn c nsis:ac Of

' selective examination of prececures and recresentative rec:rcs, interviews

'

w1:n persennei, anc coservattens :y ne inspec::rs.

.

.

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. the ins:ecticn, no vic,iatiens were 1 cent- Sec.

Wi n. .in :ne sc ce of

.

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We nave also examined acti:ns ycu have taken wi n regarc :: Orevicusly icenti-

ried Inspection r,incings,

ine status of :nese items is icent 7,ec in :aragracn

..

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2 of :ne enclosed recort.

p

In accordance witn Secticn 2.790 of :ne NRC's " Rules Of ?ractice," Par: 2,

i

Title 10, C:ce of Federal Regula:icns, a :cy of :nis letter and :ne enciesec

ins:ecticn re cr: will :e

iacec in ne NRC's Fu:lic Jacumen: R:cm.

f ne

i

r?cor: c:n 3 ins any informa:1cn :na; ycu :elieve

be Or:crie ary, it is

necessary Ona; ycu succit a wri :en a: lica:icn to : Mis of' ice, wi nin 25 days

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STAFF EXHIBIT N0. 85

l

Osts of

wmm

P00R ORIGINAL

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C:=ary

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February 11, 1981

-

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I!cuid ycu have any cuss ::ns ::ncer-ing nis ins ecti:n, we will be :leasec

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React:r unstruction inc

Engineering Su::cr; Sranen

Encicsure:

E :ns:ecticn Re:cr; .'ic. 5C-GE/31-03

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U. S. NUCLEA? DEGULATOov C0=ISSION

OFFICE CF IN5;ECTION AND ENFCCCEMENT

..,

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De:cet No. 50-495/51-03; 50-499/51-C3

Oc:vr: *:. 50-49:: 50-uis

Category A2

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Inspection at:

Scutn Texas Project, Matagorda County, Texas

Inspection Concuctec:

January 19-23, 1981

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Insoect:rs:

Section

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g J. I. Tapia, Reactor Inspector, Engineering Supper:

(Paragraphs 1, 2, 3, 4 & 5)

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L. D. Gilbert, Reacter Inspector, Engineering supper: sec 1on

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(Paragrepns 1, 3 & 5)

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Other

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Accompanying

Personnel:

W. A. Crossman, Chief, Projects Section

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Approved:

W. A. Crossman, Chief, Projects Section

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R. E. Hall, Chief, Engineering Sucoort Section

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DUPLICATE DOCUMENT

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Entire docum nt previously

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION fV

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811 RYAN PLAZA DRIVE. SUITE 1000

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ARUNGTON. TEXAS 76011

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March 12, 1981

In Reply Refer To:

RIV

Docket Nos. 50-498/Rpt. 81-04

50-499/Rpt. 81-04

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Houston Lighting and Power Company

ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President

Post Office Box 1700

Houston, Texas 77001

Gentlemen:

This refers to the inspection conducted by our Resident Reactor Inspector,

Mr. H. S. Phillips, during February 1981, of activities authorized by NRC

Construction Pennits No. CPPR-128 and 129 for the South Texas Project,

Units No.1 and ^, and to the discussions of our findings with Mr. R. A.

Frazar and other members of your staff at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the

enclosed inspection report. Within these areas, the inspection consisted

of selective examination of procedures and representative records, interviews

with personnel, and observations by the inspector.

Within the scope of the inspection, no violations or deviations were identified.

We have also examined actions you have taken with recard to previously identified

inspection findings. The status of these items is identified in paragraphs 2

and 3 of t:.e enclosed report.

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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and the enclosed

inspection report will be placed in the NRC's Public Document Room.

If the

report contains any information that you believe to be proprietary, it is

necessary that you submit a written application to this office, within 25 days

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of the date of this letter, requesting that such information be withheld from

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public disclosure. The application must include a full statement of the reasons

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, The application should

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why it is claimed that the infomation is proprietary.

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oe prepared so that any pmpriei.ary iniorr.auon icenurled is contained in an

ancicsure to the application, since the applicat.on without the enclosure will

also be placed in the Public Document Rcom.

If we do not hear from you in this

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recard within the specified period, the report will be placed in the Public

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ocument Room.

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STAFF EXHIBIT N0. 86

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Houston Lighting and Power Company

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March 12,1981

Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Sincerely,

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& W. C. Seidle, Chief

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Engineering Inspection Branch

Enclosure:

IE Inspection Report No. 50-498/81-04

50-499/81-04

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