ML19347E490
| ML19347E490 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/25/1980 |
| From: | Eric Turner HOUSTON LIGHTING & POWER CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML16251A407 | List:
|
| References | |
| ST-HL-AE-408, NUDOCS 8104270480 | |
| Download: ML19347E490 (2) | |
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l'N HIW l Meus:cn. Tens 77C01 January :5, 1980 ST-HL-AE-408 SFN: C-05 0 Mr. W. C. Seidle, Chief Reacto.Censtrue:ien 5 Engineering Sepport 3 ranch U.S. Nuclear Regula: cry Cen=ission Office of Inspection and Enforce =en:
Regien IV 611 Ryan Pla:a Drive, Suite 1000 Arlingten, TX 76012
SUBJECT:
SCUTH TEXAS PRCJECT El.ECTRIC GENERATING STATICN RESPONSE TO NRC INSPECTION FINDINGS DCCKET NCS. 50-498/79-14 AND 50-499/79-14
Dear Mr. Seidle:
The ic11cwing is the additional inic=a:icn you rec.uested en the ite=s of ncncc=p11ance identified in IE Inspection Repor:
Nos. 50-498/79-14 and 50-499/79-14 and addressed in your le::er of January 11, 1980.
Failure of CC Insree:cr to Initial and Date Suurienental En: v l
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Cer ective Action Taken The concrete placement card en which -he original en:ry was =ade has been initialed and dated by the inspec:cr who cade the ent:y.
2.
Rec ence Cent ci Written instrue:icas have been reissued en naking changes and la e entries en QA dec -a--'--
an.
3rcwn i Rcot QC persennel will be reins:=cted en -he proper nethods for aking changes and la:e en ries on QA doc.:=ents:icn. This reins = ction vill be in wri:-
en fern and the inst =ction given will be decu=ented.
STAFF EXHIBIT NO. 34 8.104270 N hh hhh
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Ecus:en Ljerg i P w Co.g
}t:. Seille January 25, 1980
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Ca:e :ull C ::mliance Will be Achieved Cc::ective ac icn and recur ence ::n: ci will be completed by February 1, 1980.
Very ::uly yours,
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E. A. Tur:.er, Vice Presiden:
Power Plan: Construe:icn 6 Technical Se:tices EAT::ka ec: Messrs. C. W. Cprea, Jr.
R. A. F:s:a:
D. G. Barker M. L. Bc::hel: (CP-L)
J. W. Moore (CP!.)
J. 3. Poston (CPS)
R. C. Mecke (CPS)
R. L. Hancock (CCA)
M. C. Ni:cholas (COA)
W. N. Phillips T. D. 5:anley G. 3. Painter M. D. Schwar: (Baker & Bot:s)
H. S. Phillips (NRC)
J. R. Geur:s (35R)
U. D. Douglas (35R)
C. W. Vincen: (35R)
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ut UNITED STATES a
of NUCLEAR REGULATORY COMMISSION O T*
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April 30, 1980 In Reply Refer To:
RIV Docket No. 50-498/Rpt. 80-07 50-499/Rpt. 80-07 Houston Lighting and Power Company ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700 Houston, Texas 77001 Gentlemen:
This refers to the inspection conducted by Mr. W. G. Hubacek of our staff during the period April 8-11, 1980, of activities authorized by NRC Construc-tion Permits No. CPPR-128 and 129 for South Texas Project, Units No. 1 and 2, and to the discussion of our findings with L. D. Wilson and other nembers of your staff at the conclusion of the inspection.
Areas examined during the inspection and our findings are distcussed in the
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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.
During the inspection, it was found that certain activities under your license appear to be in nonconpliance with Appendix B to 10 CFR 50 of the NRC Regulations,
" Quality Assurance Criteria for Nuclear Power Plants." The item of noncompliance and references to the pertinent requirements are identified in the enclosed Notice of Violation.
We have also exa=ined actions ycu have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph 2 of the enclosed report.
This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office within 30 days of your receipt of this notice, a written state =ent or explanation in reply including:
(1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further nonce =pliance; and (3) the date when full compliance will be achieved.
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STAFF EXHIBIT T40. 35 8006 ng o. 2f gr
Houston Lighting and Power Company April 30, 1980 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 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons j
why it is claimed that the information is proprietary. The application should I
be prepared so that any proprietary information identified is contained in an j
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.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincer41y, l
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W. C. Seidl Chief Reactor Construction and Engineering Support Branch
Enclosures:
1.
Appendix A, Notice of Violation 2.
IE Inspection Report No. 50-498/80-07 l
50-499/80-07 1
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50-498/80-07 50-499/80-07
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Appendix A NOTICE OF VIOLATION l
Based on the results of the NRC inspection conducted on April 8-11, 1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Construction Permit CPPR-129 as indicated below:
Failure to Follow Procedure for Storage of Material 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be performed in accordance with instructions, procedures or drawings.
Brown & Root Quality Construction Procedure GCP-35, " Storage and Maintenance,"
Revision 3, requires that protective covers and closures be intact.
Contrary to the above:
l During inspection of equipment storage on April 8, 1980, the IE inspector observed that a protective cover had been removed from a weld preparation on pipe penetration M-39 in the Unit 2 Reactor Containment Building (RCB)
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and a steel hook, used to support scaffolding on the exterior of the RCB, was in direct contact with the weld preparation.
This is an erm tion,
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
50-498/80-07; 50-499/80-07 Docket No.
50-498; 50-499 Category A2 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 County, Texas Inspection Conducted: April 8-11, 1980 Inspector: h, NOI2wd 52P!?C W. G. Hubacek, Reactor Inspector Date Projects Section g
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Accompanying Personnel P. G. Wisco, Nuclear Technologist, Philippine Atomic Energy Commission l
Approved:
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[8C 2w W. A. Crossman, Chief, Projects Section Date
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Inspection Sumary:
l Inspection on April 8-11, 1980 (Report No. 50-498/80-07; 50-499/80-07)
Areas Inspected: Routine, unannounced inspection of licensee's corrective action in response to previously identified inspection findings. The inspection involved twenty-three inspector hours by one NRC inspector.
Results: One item of noncompliance was identified (infraction - failure to i
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follow procedure for storage of material - paragraph 3).
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UNITED STATES 3'
NUCLEAR REGULATORY COMMISSION M EoION IV
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In Reply Refer to:
RIV Docket No. 50-498/Rpt. 79-15 50-499/Rpt. 79-15 l
Houston Lighting and Power Company Attn:
Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Pox 1700 Houston, Texas 77001 Centlemen:
This refers to the inspection conducted by our Resident Inspector, Mr. H. S. Phillips, during the period of September 1979 of activieles authorized by NRC Construction Pernits No. CPPR-128 and 129 for the South Texas Project, Units No.1 and 2, and to the discussion of our findings with Mr. L. D. Wilson and other = embers of your staff during the inspection period.
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Areas examined during the inspection and our findings are discussed in the enciased inspection report. Within these areas, the inspection con-sisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.
ruring the inspection, it was found that certain activities under your
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license appear to be in noncompliance with Appendix 3 to 10 CFR 50 of the l
NRC Regulations, " Quality Assurance Criteria for Nuclear Power Plants."
The item of noncompliance and references to the pertinent requirements are i
identified in the enclosed Notice of Violation.
i Two new unresolved items are identified in paragraph 3 of the enclosed l
report.
i This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within l
30 days of your receipt of this notice, a written state =ent or explatsatica in reply including:
(1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which v111 be taken to avoid further noncompliance; and (3) the date when full co=pliance vill be achieved g.}.
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October 1% 1979 I
In accordance with Section 2.790 of the NRC's " Rules of Pra'ctice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the i
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 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must i
include a full statement of the reasons why it is claimed that the infor-mation is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the applicatioc, 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.
Should you have any questions concerning this inspection, we vill be
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pleased to discuss them with you.
l Sincerely, i
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.~c-W. C. Seidle, Chief Reactor Construction and Engineering Support Branch I
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Enc 1osures:
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Appendix A; Notice of Violation 2.
IE Inspection Report No. 50-498/79-15 50-499/79-15 t
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Docket No. 50-498 50-499 Apper. dix A NOTICE OF VIOLATION
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Based on the results of the NRC inspection conducted during the period of September 1979 it appears that certain of your activities were not conducted i
in full compliance with the conditions of your.NRC Construction Permit No. CPPR-129 as indicated below:
Failure to Follow Concrete Consolidation Proceduce Criterion V of 10 CFR 50, Appendix B requires that activities affecting quality shall be accomplished in accordance with instruction, procedures or drawings.
The Brown & Root (B&R) QA Construction Procedure CCP-4, Revision 10, Section 3.5, " Consolidation," paragraph 3.5.4 states in part, "When concrete is applied in successive layers, vibrators must penetrate completely through the upper layer and at least six inches into the acxt lower plastic layer to ensure thorough "conding."
Contrary to the,above:
On September 17, 1979, the Resident Inspector observed, that during place-ment of Pour No. CS2-W7 in the Reactor Containment Building, one of geven vibgator personnel was not vibrating the concrete properly at Az 160 -
165, in that, the vibrator did not penetrate completely throu~gh the upper layer and a' least six inches into the next lower plastic layer to ensure thorough bonding. The Resident Inspector called this to the attention of a Brown and Root Inspector (roving).
He agreed that the consolidation was improper and directed that this area be revibrated.
4 This is an infraction.
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 50-498/79-15; 50-499/79-15 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77]01 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda, Texas Inspection conducted: September 17-30, 1979 d
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e H. S. Phillips, Resident Reactor Inspector Date 9/79 Approved:
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W. A. Crossman, Chief, Projects Section Date i
Inspection Summarv:
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Inspection of September 1979 (Report 50-498/79-15; 50-499/79-15) l Areas Inspected: Routine inspection by the Resident Re;<; tor Inspector (RRI) l of safety related construction activities including the placement of containment structural concrete, Unit 2.
Construction progress was assessed during two plant tours of the Reactor Containment Buildings, Units 1 and 2.
The inspec-l tion involved sixteen inspector-hours by one NRC inspector.
Results:
One item of noncompliance (infraction - failure to follow concrete placement procedures paragraph 3) was identified in one of two areas inspected.
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i November 13, 1979 ST-HL-AE-392 SFN: C-OS70 Mr. W. C. Seidle Reactor Construction C Engineering Support Branch U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Pla:a Drive. Suite 1000 Arlington, TX 76012
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FIhTINGS DOCKET NOS. 50-498/79-15 AND S0-499/79-1S
Dear Mr. Seidle:
The following is Houston Lighting 6 Power Company's (HL5P)
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response to the ites of noncomplience identified in IE Inspection Report Numbers S0-498/79-15 and 50-499/79-15, dated October 19, 1979.
A.
Failure to Follow Concrete Consolidation Procedure Corrective Action The lack of vibrator penetration referenced by the Resident NRC Inspector in Report 79-15 has to do with leveling the "as-placed" concrete prior to the process of vibration. This is a common practice and was explained to the F.esident NRC Inspector by the Brown & Root (BSR) roving inspector. The Brown
& Root roving inspector did direct the area to be re-vibrated as an initial reaction to the Resident NRC Inspector's observation; however, in subsequent discussions with the construction fore =an, it was deter =ined that the vibrator operator was leveling concrete in accordance with his ins ructions. The concrete received a thorough vibration subsequent to the leveling process, as called for by procedure, and this was verified by Brown 6 f.co: Quality Centrol Inspectors.
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Mr. Seidle November 13, 1979 Page Two e
Recurrence Cont:ni, Personnel involved with NRC interface have been reminded to thoroughly evaluate observations made by others and to react in accordance with estab-lished project procedures in order to min 4=4:e misunderstandings and overreactions.
Very truly yours,
) G.,,L= -_ :2_-
E. A. Turner, Vice President Power Plant Construction
& Technical Services EAT:rka ec: Messrs. G. W. Oprea, Jr.
R. A. Fra:ar D. G. Barker M. L. Borchelt (CPL)
J. W. Moore (CPL)
J. B. Poston (CPS)
R. C. Mecke (CPS)
R. L. Hancock (COA)
M. C. Nitcholas (COA)
T. D. Stanley G. B. Painter M. D. Schwar: (Baker 6 Botts) 4 H. S. Phillips (NRC)
J. R. Guerts (BSR)
C. W. Vincent (BSR)
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 3%'
REoloN IV 7 l T Y' 1 e 611 RY AN PLAZA oRIVE, SutTE 1000
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oyw January 24, 1980 In Reply Refer To:
RIV Docket No. 50-498/Rpt. 79-15 50-499/Rpt. 79-15 Houston Lighting and Power Company KiDI: Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700 Houston, Texas 77001 Gentlemen:
Thank you for your letter of November 13, 1979, in response to our letter dated October 19, 1979, and the attached Notice of Violation. As a result of our review, we find that additional information is required.
Your response f ails to address measures that have or will be taken to assure compliance with concrete consolidation procedures.
Your response states that the improper vibration, referenced by the Resident Reactor Inspector (RRI) in IE Report 79-15, accumily involved levem g of "as placed" concrete prior to the process of consolidation of the concrete by vibration. The RRI does not concut with this position and states that the area where the i= proper consolidation was observed was level at the time the improper vibration was observed by the RRI and the accompanying Brown &
l Root (B&R) roving QC inspector. Inasmuch as the area was already level, the RRI =aintains that the obsetved vibrator operations could not have been performed for the purpose of leveling "high spots" as allowed by ACI 309-72.
The RRI also states that the B&R QC inspector acknowledged the i= proper vibra-tion and went i= mediately to the vibrator crew foreman and requested that the subject area be revibrated. The area was then revibrated. The RRI did not suggest or request that the area be revibrated, however, this on-the-spot corrective action was appropriate.
We do not concur with your position that this item of noncompliance was the result of =isunderstandings or over reactions.
I STAFF E*HIBIT NO. 38 (W
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4 Houston Lighting and Power Company January 24, 1980 You are requested to provide, within 20 days of the receipt of this letter, additional information related to this matter including: (1) correc:ive steps which have been taken to assure proper vibration of concrete and the results achieved; (2) corrective steps which will be emken to avoid further noncom-pliance; and (3) the date when full compliance vill be achieved.
Should you have any questions concerning this matiter, we will be pleased to discuss them with you.
Sincerely, 1
L'. C. Seih, Chief Reactor Cotestruction and Engineering Support Branch 4
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ROBox 1700 ST-HL-AE-418 h-iII L-Houston. Texas 77001 SFN: C-0370 Mr. W. C. Seidle Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Pla:a Drive, Suite 1000 Arlington, TX 76012
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FINDINGS DOCKET NOS. 50-498/79-15 AND 50-499/79-15
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Dear Mr. Seidle:
The following is the additional infor=ation you requested on the item of noncompliance identified in IE Inspection Report Nos.
50-498/79-15 and 50-499/79-15 and addressed in your letter of January 24, 1980.
Failure to Follow Concrete Consolidation Procedure Corrective Action Tne concrete placement identified in your Inspection Report 79-15 was re-vibrated satisfactorily to the Resident Reactor Inspector as stated in your letter of January 24, 1980.
Recurrence Control Brown 6 Root Construction has established a require-I ment for all vibrator operators to be retrained every 90 days on the basis of current procedures, including Brown 6 Root Procedure CCP-4.
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Mr. Seidle February 12, 1980 Page Two
,s Date Action to be Comoleted All reinstruction of current vibrator personnel will be completed by February 21, 1980.
Very truly yours, d.
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- E. A. Turner, Vice President Power Plant Construction 5 Technical Services EAT:rka cc: Messrs. G. W. Oprea, Jr.
R. A. Frazar D. G. Barker M. L. Borchelt (CPL)
C. G. Thrash (CPL)
J. B. Poston (CPS)
R. C. Mecke (CPS)
R. L. Hancock (COA)
M. C. Nitcholas (COA)
T. D. Stanley L. D. Wilson G. B. Painter M. D. Schwar.. (Baker 6 Botts)
H. S. Phillips (NRC)
J. R. Geurts (B6R)
C. W. Vincent (B6R)
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o UNITEo STATES NUCLEAR REGULATORY COMMISSION 5
AEGION IV 611 RYAN PLAZA oRIVE. sulTE 1000 h
ARLINGTON. TEXAS 76011 In Reply Refer To:
November 6, 1980 RIV Docket No. 50-498/Rpt. 80-24 50-499/Rpt. 80-24 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 Messrs. J. I. Tapia and D. P.
Tomlinson of our staff during the periods August 18-22, September 2-5, and Septe=ber 16-19, 1980, of activieles authorized by NRC Construction Permits No. CPPR-128 and 129 for South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. R. A. Fra:ar and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection and our findings 4re 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 inspectors.
Within the scope of the inspection, no items of noncompliance were identified.
We have also examined actions you have taken with regard to previously identi-fied inspection findings. The status of these items is identified in paragraph 2 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 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 20 days of the date of this letter, requesting that such infor=ation be withheld from public disclosure.
The application must include a full statement of the reasons why it is claimed that the infor=ation 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.
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STAFF EXHIBIT NO. 40
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Housten Lighting and Power Company 2
November 6, 1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, j
. C. Seidle, Chief Reactor Construction and Engineering Support Branch
Enclosure:
IE Inspection Report No. 50-498/80-24 50-499/80-24 O
U. S. NUCLIAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 50-498/80-24; 50-499/30-24 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 71001 Facility Name: South Texas Project, Units 1 and 2 Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: August 18-22, September 2-5, and September 16-19, 1980 Inspectors:
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. P. Tomlinson, Reactor Inspector, Engineering Support aate Section Other Accompanying Personnel:
W. G. Hubacek, Reactor Inspector, Projects Section W. A. Crossman, Chief, Projects Section Approved:
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{,-Q.*d' December 12, 1979 In Reply Refer To:
RIV Docket No. 50-498/Rpt. 79-16 50-499/Rpt. 79-16 Houston Lighting and Power Company Atta:
Mr. E. A. Turner, Vice President Power Plant Construction and Technical Farvices Post Office Box 1700 Houston, Texas 77001 Gentlemen:
This refers to the inspection conducted by our Resident Inspector, Mr. H. S. Phillips, during the period of October 1979 of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for the South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. L. D. Wilson and other members of your staff during the inspection period.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection con-sisted of selective amination of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection, it was found that certain activities under your license appear to be in noncompliance with Appendix B to 10 CFR 50 of the NRC Regulations, " Quality Assurance Criteria for Nuclear Power Plants."
The item of noncompliance and references to the pertinent requirements are identified in the enclosed Notice of "iolation.
This notice in sent to you pursuant to the provisions of Section 2.201 of the NRC's ' Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office, within 30 days of your receipt of this notice, a written statenant or explanation in reply including:
(1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid further noncompliance; and (3) the date when full compliance vill be achieved.
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December 12, 1979
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J 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 subnit a written application to this office, within 20 days of the date of this letter, requesting that such infor=ation be withheld from public disclosure. The application must include a full statc=ent of the reasons why it is c1=4 mad that the infor=ation is proprietary. The application should be prepared so that any proprietary infor=ation 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 yott in this regard within the specified period, the report will be placed in the Public Document Room.
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 Reactor Construction and Engineering Support Branch
Enclosures:
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Appendix A, Notice of Violation 2.
IE Inspection Report No. 50-498/79-16 50-499/79-16 I
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Appendix A NOTICE OF VIDIATION Based on the results of the NRC inspec~, ion conducted during the period of October 1979, it appears that certain of your activities were not conducted in full compliance with the conditions of your.,NRC Construction Permits No. CPPR 128 and CPPR-129 as indicated below:
Failure to Include Appropriate Quantitative or Qualitative Acceptance Criteria in Instructions, Procedures, or Drawings Criterion V of 10 CFR 50, Appendix B, states in part, " Instructions, procedures or drawings shall include appropriate quantitative or quali-tative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Brown & Root (B&R) Specification 2A010CS028-C, paragraph 6.1.1.1,
" Construction Joint Preparation" states, "The s trface of all construction joints shall be saturated for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or as required in order that the concrete surfaces immediately prior to placement is in a saturated surface dry (SSD) condition unless otherwise approved by the Design Engineer." Paragraph 3.2.8, " Placement Preparation," states, "No excessive amounts of free standing water or foreign material which would reduce the quality of the concrete shall be present in the placement or on the surface on which concrete is to be placed."
Quality Construction Procedure CCP-3, Revision 11, paragraph 3.3.1 states, "The individual engineer and/or supervisor who performs the prepour inspection will assure conformation to plans and specifi-cations.... The inspection will be performed by the B&R construc-l tion craft supervisor (foreman, general foreman or superintendent) and by the B&R Senior Discipline Engineer or his representative ani by the respective discipline Quality Control Inspectors." Para-graph 3.3.3(2) states " Assure that all surfaces are wetted and no significant amount of free water remains."
t Contrary to the above:
1.
On September 17, 1979, the Resident Reactor Inspector (RRI) observed the placement of Pour No. CS2-W, a portion of the Reactor Building Containment wall. Final inspection had been performed prior to the pour by individuals responsible for the inspection, however, the 0
RRI found excessive fgee standing water on the prepared joint C
between Az 240 - 311. Closer examination revealed a significant I. 4 -.-L 5.-
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A small puddle of water 1-3" deep x 12" diameter was also entrapped at Az 245 between the maid steam penetration.
2.
The RRI also determined that the specifications and procedures failed to give quantitative or qualitative acceptance criteria to define what constitutes the saturated surface dry (SSD) con-dition. The specification or procedures do not define " excessive" or "significant" in regard to amounts of free standing water and accordingly free standing water is not limited.
This is an infraction.
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a U. S. NUCLEAR REGULATORY C0!ciISSION OFFICE OF INSPECTION AND ENFORCZHENT -
REGION IV Report No. 50-498/79-16; 50-499/79-16 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houstoa, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County, Texas Inspection conducted: October 1-12, 1979
/2/3[79 Inspector:
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M W. A. Crossman, Chief, Projects Section Date l
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Insoeetion during October 1979 (Recort 50-498/79-16; 50-499/79-16)
Areas Insoected: Routine inspection by the Resident Reactor Inspector (RRI) of safety-related construction activities including the follow up on placement of containment structural concrete, Unit 2; fire prevention /
protection; Essential Cooling Pond; storage of safety-related items for Units No. I and 2; and Diesel Generator Building foundation for Unit.No. 1.
The inspection involved thirty-six inspector-hours by one NRC inspector.
Results: In one of five areas inspected, one unresolved matter identified during the September inspection was upgraded to an item of noncompliance (infraction -
failure to include appropriate acceptance criteria in instructions, procedures and drawings - paragraph 2).
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Persons Contacted Prineinal Licensee Emolovees
- D. G. Barker, Project Manager
- L. K. English, Project Site Manager
- T. J. Jordan, Lead Mechanical Engineer
- D. G. Long, Lead Civil Engineer
- V. N. Phillips, Projects QA Manger
- T. D. Stanley, Projects QA Supervisor
- G. A. Marshall, QA Senior Specialist
- J. W. Soward, QA Specialist
- L. D. Wilson, Site QA Supervisor Brown & Root Emnloyees
- B. Gebhardt, B&R Engineer
- R. Parrish, B&R QC Inspector (Civil)
- G. T. Warnick, Site QA Manager Westinghouse Employees W. Leslie, Site Manager The RRI also interviewed other licensee and contractor personnel during the subject inspection period.
- Denotes management meeting regarding NRC policies and interface with the NRC Resident Reactor Inspector (RRI).
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- Denotes personnel attending management meeting and the weekly meetings I
with the RRI.
- Denotes only those personnel attending the weekly meeting with the RRI.
- Denotes principal personnel contacted during inspections.
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2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (499/79-15-1): Excessive Free Standing Water in Concrete Placement Area. The Resident Reactor Inspector (RRI) i observed excessive free standing water on an existing concrete joint in the placement area of Reactor Building Containment Wall, Unit No.1.
Closer examination showed that an area (4' x 8-10')- war covered with approximately % to inch of water. The Brown and Roor Specification 2A010CS028-C, Section 3.2.8 dated April 26, 1979, states in part, "No excessive amounts of free standing water ur material which would reduce the quality of the concrete shall be present in the placement or on the surface on which concrete is to be poured." The Brown and Root Procedure CCP-3, Revision 11, Section 3.3, "Prepour Inspection," paragraph 3.3.3(2) states, " Assure that all surfaces are wetted and no significant amount of free standing water remains."
The area engineer had signed off the prepour card even though a 1.arge area of trapped water covered the joint as described above. The water was subsequently removed from the joint after the RRI observed the condition and stated that the condition was questionable. The water was removed by soaking rags and squeezing them out after jetting with compressed air failed to remove the water.
The RRI considered the matter unresolved at the time because the specification and procedure used words such as "significant" and
" excessive" amounts of free standing water. The RRI stated that action should be taken to revise or clarify the specification and procedure.
Subsequent contacts with several civil engineer's specialists, and the Portland Cement Association revealed that the condition described above was unacceptable. Additionally, literature such as Portland Cement Association Engineering Bulletin, " Design and Control of Concrete Mixtures," Eleventh Edition, page 58, states " Hardened con-crete should be moistened thoroughly before new concrete is placed
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Where the concrete has dried out, it may be necessary to saturate i
it for a day or more. No pools of water should be left on the wetted surface when the new concrete is placed." ASME III, Division 2, l
Subsection CB-4252, " Construction Joints," states the same.
The licensee provided the Eollowing answers to RRI based on an internal Houston Lighting and Power Company (HL&P) memo dated October 15, 1979:
"The concrete specification currently states, 'No excessive amounts of free standing water or foreign material which would reduce the quality of the concrete shall be present in the placement... which requires at each placement, concurrence between the area engineer and the Quality Control inspector before the pour may proceed. Should a conflict cecur, the PSE will make the final interpretation of the specification's intent.
g "To specify no free standing water is impractical and technically unjustified. Such restrictive requrements would.only serve to further shackle construction into unnecessary delays.
"From an engineering viewpoint, limited amounts of free standing water left in a placement have no detrimental effects on the quality of the concrete.
"Even in the event a situation exists where th'e quantity of water is questionable, any acverse effects can be eliminated through utilization of proper construction practices.
" Construction encounters such varied ' situations it is impossible to define generic criteria for a maximum permissible amount of water. Therefore it is the position of B&R and HI.&P engineering to allow construction (construction engineering implied) to accept or reject residual water based on their own independent engineering judgment in the assessment of each pour situation."
The RRI reviewed the answers as additional information provided and found that the licensee did not provide clarification of the terms such as " excessive amounts" or "significant amounts" of free standing water. The answer also failed to assure that instruc-tions, procedures and drawings include apprcpriate quantitative or qualitative acceptance criteria.
l This finding represents a noncompliance with Criterion V of 10 CFR 50, Appendix B.
3.
Fire Prevention / Protection. Units 1 and 2
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The Resident Reactor Inspector (RRI) observed fire prevention and protection activities.in areas containing combustible materials which could lead to damage of safety-related structures, systems or components.
The RRI observed prevention / protection measures to assure 1:ompliance with ANSI N45.2.2-1972, paragraph C.2.3, " Packing, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants,"
and ANSI N45.2.3, paragraph 3.2.3, " Housekeeping During the Construction Phase of Nuclear Power Plants," for the following:
a.
non-flammable protective coverings i
b.
accumulation of wooden scaffolding and wooden shoring material 4
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flammable packaging materials in proper containers d.
proper storage of flammable liquid e.
control of heat sources t
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fire protection / suppression equipment g.
fire drill (in process) 4.
Essential Cooling Pond (ECP) a.
Description FSAR, volume 5, paragraph 2.3.6 describes the purpose and size of the ECP. The purpose of the ECP is to provide a source of cooling water for safe plant shutdown and is used as the normal heat sink for plant auxiliaries. The ECP covers 45.6 acres @ el 25' and 40 acres @ el 17'. It is surrounded by an embankment 6C50' long.
b.
Status of Work The majority of work has been completed on the ECP. However, the intake and discharge structures and placement of safety-related concrete on the southeast embankment are yet to be completed.
c.
Engineering The RRI met with project engineers assigned to the ECP area to discuss work completed and documented in the FSAR as follows:
(1) soil and foundation - investigation and geotechnical engineering de. sign (2) design bases - Section 9.2.5, referenced in paragraph 2.5.6 I
(3) ECP foundation and abutment treatment, that is, stripping top soil, removal of silty or sandy soil and replacement with clay.
The FSAR specified a minimum (CH, CL) liquid limit of thirty and a minimum plasticity index of ten. The engineers stated that the tests confirmed tha the materials met specified limits.
(4) Borrow material was used to control the embankment and dikes. On-site clays and sand strengths were recorded in Subsections 2.5.5.2.1 and 2.5.6.4.2.4, respectively.
(5) Embankment crest measurement was recorded as 8' above the berm and 9' above the original ground surface.
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(6) Interim dike crest measurement was 12' above the berm and 13' above the ground surface.
(7) Exterior and interior embankment (dike cross sections were recorded as being built to 3 to 1 slope).
d.
Observation of 'Jork
. The RRI observed that several work activities were in progress as follows:
(1) Borrow Mfaterial l
Borrow material was being hauled in to spread on the bottom of the ECP. Test results to assure desired properties were stated to be at Pittburgh Testing Iaboratory. Engineers assigned to this area stated that materials met specified l
limits.
(2) Concrete Safety-related concrete was being placed on the Toe Block on Embankment (location: right side station 25 + 85 to 22 + 86).
Pour No. TB-ERT-25+92 was being placed on October 9, 1979.
The following was observed to be satisfactory:
-(a) proper mix specified/ delivered (B-1-3-11) per design drawing No. 0Y-0103-4 (b) mixing time / revolutions (c) temperature control i
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l (d) testing at placement (slump, air, temperature) i (e) adequate crew (f) rebar clean, forms tight (g) proper placement and vibration (h) TNMEC Cure '68-191 was specified.
(RRI did not verify j
application since placement was not complete.)
(i) B&R inspector had performed preplacement inspection and was at scene of placement. Crew supervisors were also present.
No items of noncompliance or deviations were identified.
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Foundations, Unit 1 The RRI observed the completed work where the Diesel Generator (DG) will be located. The seal slab and a protective six inch slab had been poured. A Brown & Root inspector and a trade superintendent were reviewing the Diesel Generator (DG) layout IC-5000-1, Revision 3, Drawing 3-D-05.
The RRI reviewed the drawing to determine where the DG will be located. Rebar and embeds will be placed during the next several months after which a foundation will be poured.
The foundation is to be located on backfill which requires testing /
compaction.
i' No items of noncompliance or deviations were identified.
6.
Storage of Safety Related Items The RRI observed the storage and/or maintenance of the following items:
Units Description of System No. of Comments Items Safety-related Restraints 6
Stored inside on 1
1428-28/24/03/16/59; dunnage CC1111-SH03 Safetv-related Components 1
Stored per PPM-0233 1
Nitrogen purge main-tenance and stored in place 2
Accumulators Nitrogen purge. Stored outside.
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1 RER Heat Exchanger 1
stored per procedure I
Heat Exchanger Component 1
Stored per PPM Cooling Water 1899-6 1
RCDT Heat Exchanger 1
Per PPM-0295-9 l
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Reactor Vessel 1
Vessel 1
Stored in place w/o dessicant per Westinghouse direction 2
Vessel 1
stored outside with exterior protected and dessicant on inside l
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Units Description of System No. of Comments Items 1
Head I
stored inside 2
L'ead I
stored outside on dunnage per PPM-0110-3 1&2 Upper Tie Plate, 5940A02 2
stored outside per lower Internals, SN39127 2
~ procedure Upper Internals, 45862 1
Comoonent Cooling Water Stored inside MEAB Piping: 1303-WA 2
on dunnage or posi-1428-WA3 1
tion to be welded 2
Essential Cooling Water Piping: Laydown area 6
Stored in arez on dunnage 1
Reactor Pressure Coolant 8
Inside containment Boundary Piping (Spool in place pieces that join to inlet /
outlet nozzles The RRI noted that the dessicant indicator in Unit I vessel showed that the dessicant was expended. Further, the Westinghouse Site Representative stated that the dessicant had been removed and the opening resealed when the vessel was set inside containment. The RRI questioned the need for dessicant during storage outside while dessicant was not required while stored (interim) inside. The reason given for the different requirement was the fact that long term storage requires dessicant while short term / interim storage does not.
The removal of the nitrogen purge on the secondary side of the steam generators was similar to the matter discussed above. In this case nitrogen was removed prior to setting the steam generators inside containment. The RRI questioned the need for interim storage require-ments regarding the inside of the secondary side of the steam generators.
The Westinghouse Represent,ative stated there was a need for the inert gas purge for long term storage but not for short term storage.
The RRI reviewed ANSI N45.2.2, Westinghouse (WEC) Equipment Manuals and WEC/STP site criteria. No requirement for dessicant was found.
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the vessel and steam generators.
No items of noncompliance or deviation were identified.
7.
Management Meeting The RRI inspector met with management from the Houston office. The following topics were discussed by the RRI:
NRC Laterface with site personnel Lines of communication, that is, telephone, daily contacts and weekly meetings Government regulation prohibiting apparent conflict of interest' Enforcement per Manual Chapter 0800 and the Resident Inspector's interpretation of 0800 as relates to the Resident Inspection Program RRI reports to be made monthly and interim reports to be made if item of noncompliance is identified early in the month Office hours are to be flexible in order to perform backshift work, however, core hours were given The RRI met with licensee representatives weekly to discuss findings.
The licensee requested that such meetings be held each Friday. Sub-sequently, the request was changed to Thursday at 9:00 a.m. because the site presently works four ten hour days and most personnel are not on site on Friday.
No meetings were held during the period October 15-30 because the RRI was not on site during this period. The RRI did meet with licensee personnel on October 31, to discuss unresolved matters identified in the month of September.
l The RRI told the licensee's site representative that Unresolved Matter j
(50-499/79-15-1) would be upgraded to an item of noncompliance based on l
additional information obtained. This is discussed in paragraph 2 of l
i this report. The licensee' acknowledged the finding.
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Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012 l
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION TINDINGS DOCKET NOS. 50-498/79-16 AND 50-499/79-16
Dear Mr. Seidle:
The following is our response to the item of noncompliance identified in IE Inspection Report Nos. 50-498/79-16 and 50-499/
79-16, dated Dececher 12, 1979.
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Failure to Include Appropriate Quantitative or Qualitative Acceptance Criteria in Inst uctions, Procedures or Drawings Corrective Action The Brown & Root Concrete Construction Specification 2A010CS028 and the Brown & Root Quality Construction Procedure A040KPCCP-3 are being revised to state that no standing water will be allowed on construction joints unless it is documented and approved by the area Construction Epgineer. Documentation shall con-sist of a brief narrative (or listing) of locations, sizes, and average depths of all bodies of standing water on th-hardened surface of the joint.
This document-; ion will be written on the pour card.
It is noted that this philosophy has been followed through-out construction thus far at the South Texas Project, and the documentation described above is the oniv major change to the existing methods.
B STAFF EXHIBIT N0. 42
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Recurrence Control The Concrete Construction Specification and the Quality Construction Procedure are being revised and re-issued.
Retraining vill be conducted on January 18, 1980, to inform affected personnel of the,. changes. These actions will provide recurrence control.
- The completion of corrective action and recurrence control of this item vill be achieved by January 18, 1980.
Very truly yours, Y
o 42..\\/ w w E. A. Turner, Vice President Power Plant Construction j
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& Technical Services i
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cc: Messrs. G. W. Oprea, Jr.
R. A. Prazar D. G. Barker T. D. S'.anley G. B. */ sinter M. L. Borchelt (CPL)
J. W. Moore (CPL)
J. B. Poston (CPS)
R. C. Mecke (CPS)
R. L. Hancock (COA)
M. C. Nitcholas (COA)
M. D. Schkarz (Baker & Botts)
H. S. Phillips (NRC)
J. R. Geurts (B&R)
C. W. Vincent (B&R)
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ii NUCLEAR REGULATORY COMMISSION a
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.g March 3, 1980 In Reply Refer To:
RIV Docket No. 50-498/Rpt. 79-16 50-499/Rpt. 79-16 l
Houston Lighting and Power Company ATTN:
Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700 Houston, Texas 77001 l
Gentlemen:
Thank you for your letter of January 15, 1980, in response to our letter dated December 12, 1979, and the attached Notice of Violation. As a result of our review, we find that additional information is required in regard to Item 2.
Item 2, Quantitative or Qualitative Acceptance Criteria I
Specifically, your response fails to include quantitative or qualitative criteria in regard to the amount of free standing water that vill be allowed on a concrete construction joint.
Also, your proposed corrective action of changing the Brown & Root Concrete Construction Specification 2A010CS028 and the Brown & Root Quality Construction Procedure A040KPCCP-3 to allow the area construction engineer, on a case-by-case basis, to assess, document and approve the amount of f ree standing water to be allowed on a construction joint is contrary to Criterion X.
Criterion X requires that such inspection be perfor: sed by individuals other than those who performed the activity being inspected.
Brown & Root QC inspectors are responsible for inspecting construction activities for conformance with established specifications and procedures.
Consequently, in this case, quantitative or qualitative acceptance criteria must be included in the specifications and procedures.
STAFF EXHIBIT N0. 43 c3
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I You are requested te provide, within 20 days of.*'the receipt of this letter:
l (1) additional information related to Item 2 above; and.(2) dates when full compliance will be achieved for kil itema described.
Should you have any questions concerning these matters, we will be pleased to discuss them with you.
Sincerelyj o
W. C. Seidl' Chief Reactor Con ruction and Engineering Support Branch 4
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