ML20039D421

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IE Insp Rept 50-458/81-11 on 811001-1115.Noncompliance Noted:Failure to Follow Procedures for Notification of Reportable Deficiencies & Deviation from NRC Commitment Re Reinforcing Steel
ML20039D421
Person / Time
Site: River Bend 
Issue date: 12/04/1981
From: Beach A, Crossman W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20039D406 List:
References
50-458-81-11, NUDOCS 8201040075
Download: ML20039D421 (13)


See also: IR 05000458/1981011

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APPENDIX C

U. S. NUCLEAR REGULATORY COMMISSION

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REGION IV

Report:

50-458/81-11

Docket:

50-458

Licensee:

Gulf States Utilities

Post Office Box 2951

Beaumont, Texas 77704

Facility Name:

River Bend, Unit No. 1

Inspection at:

River Bend Site

Inspection Conducted:

October 1 through November 15, 1981

Inspector:

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11/2"d1

E. B.~ Beach, Resident Reactor inspector

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. Approved:

e=----

W. A. Crossman, Chief, Projects Section 3

Date

Inspection Summary:

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Inspection During October and November (Report No. 50-458/81-11)

Areas Inspected: Routine, announced inspection by the Resident Inspector (RRI)

including follow up to previous inspection findings; follow up of licensee

identified items; concrete placement activities; welding of safety-related

piping and pipe supports; structural steel erection; and Class IE electric

equipment qualification. The inspection involved 130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br /> by one NRC in-

spector.

Results: Of the six major areas inspected, no violations or deviations

were identified in four areas, one violation was identified involving

licensee identified items (Violation - Failure to Follow Procedures for

Notification of Reportable Deficiencies, paragraph 3), and one deviation

was identified involving placement of reinforcing steel.(Deviation -

Deviation to ACI 318 Requirements Relating to Substitution of Grade 60

Reinforcing Steel for Grade 40 Reinforcing Steel, paragraph SA).

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Persons Contactqd

Principal Licensee Employees

  • P. D. Graham, Director, Quality Assurance
  • C. L. Ballard, Supervisor, Quality Assurance
  • R. B. Stafford, Supervisor, Quality Assurance
  • G. V. King, Supervisor, Quality Assurance

H. G. Domschke, QA Engineer

K. C. Hodges, QA Engineer

I. M. Malik, QA Engineer

R. E. Oprea, QA Engineer

W. S. Stuart, QA Engineer

E. A. Troncelleti, QA Engineer

  • T. C. Crouse, Superintendent, Site Construction
  • M. A. Walton, Director, Site Engineering

Stone and Webster Personnel

  • C. D. Lundin, Manager, Project Quality Assurance
  • R. L. Spence, Superintendent, Field Quality Control (FQC)

G. M. Byrnes, Assistant Superintendent, FQC

  • J. D. Davis, Assistant Superintendent, FQC

R. L. Whitley, Assistant Superintendent, FQC

  • W. I. Clifford, Senior Resident Manager

C. A. Goody, Resident Manager

E. A. Sweeny, Superintendent of Site Engineering

  • P. D. Hanks, General Superintendent, Construction
  • D. P. Barry, Superintendent, Construction Services

The RRI also interviewed additional licensee, Stone and Webster, and

other contractor personnel during this inspection period.

  • Denotes those persons with whom the RRI held on-site management mect-

ings during this inspection period.

2.

Action on Previous Inspection Findings

(Closed)UnresolvedItem(50-458/79-03): Concrete Mix Design - Water

Acceptance Criteria.

The River Bend FSAR requires that mixing water

be clean and free from injurious amounts of oils, acids, alkaltes,

salts, organic materials, or other substances deleterious to concrete

or steel.

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NRC Inspection Report 50-458/79-03 in paragraph 5 states, " National

Mobile Concrete Corporation's Quality Assurance program manual,

Section 123.2.7 states that, ' Water used for mixing the end product and

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-producing ice will comply with ' Water and Water for Ice' of the

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contract Specification.'

Stone and Webster Specification No. 210.350,

' Mixing and Delivering Concrete,' requires, under the section entitled

' Water and Water for _ Ice,' that the water conform to the requirements

contained in Stone and Webster's Specification No. 210.360, ' Concrete

Testing Services.'

A review of that specification did not disclose

the acceptance criteria being used by the engineering staff for the

water chemical analysis.

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However, prior to placement of Category I ccncrete, qualification re-

sults .for water to be used in Category I placements- conformed to the

following water chemical analysis:

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Test

Test Results

Limits

Suspended Solids

36 ppm

42,000 ppm

Iron and Manganese

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<5 ppm

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Chlorides

25 ppm

<250 ppm

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Sulfates

.5 ppm

<8,000 ppm

Total Dissolved Solids

21 ppm

<2,000 ppm

pH

5.5

4.5 to 8.5

These requirements were incorporated into the Stone and Webster

Specification 210.360. The concentration of suspended solids, iron

and manganese, and pH readings are performed for information only;

however, none of these tests performed to date have exceeded the

established limits as delineated within the specification.

Thus, since evaluation and acceptance criteria have been established

for the water chemical analysis and the test results have been within

acceptable limits to meet the licensee's commitments in the FSAR,

this item is considered closed.

(0 pen) Unresolved Item (50-458/80-02): Compliance with ASME Certifi-

cation System Requirements. The ASliE site survey was performed at

River Bend during this inspection period.

Results of the survey in-

dicate that the contractor, Stone and Webster, who has been delegated

as the owner's agent, will receive the ASME Certification of Authori-

zation for site construction purposes. However, this item will re-

main open until the certificate is received.

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(Closed) Unresolved Item (50-458/81-06):

Substitution of Grade 60

Reinforcing Steel for Grades 40 and'50.

This unresolved item, at the

time it was identified by the NRC1 inspector, deviated from the licensee's'

commitments.

This is considered to be a deviation as discussed in

paragraph SA of this report.

Thus, this unresolved item is. considered

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. closed.

(Closed) Unresolved Item (50-458/81-06):

Time Limits for Category I

Concrete Placements.

Stone and Webster Specification _210.370, Revision 6,

" Placement of, Concrete'and Reinforcing Steel," was revised by Engineering

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and Design Coordination Report (E&DCR) C-2333 to require that' concrete be.

discharged from the truck within 90 minutes or 300 revolutions.

A review.

of the placement records referenced in paragraph 58 of this report indicates

a maximum average discharge time ~ of 40 to 60 minutes.

Thus, this item is

considered closed. -

(Closed) Infraction (50-458/79-04): . Failure to Control Ordering of Safety-

Related Concrete.

This infraction resulted from inaccurate placement

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location information printed on several . Batch Plant 1 Tickets- for safety-

related concrete placements. 'This.was in violation of the National Mobile

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Concrete Corporation (NMCC)' Site Quality Assurance' Manual, Section 130,

paragraph 137.1.

Corrective action taken to avoid further.noncompliances, as stated in-the

licensee's response, was as follows:

"A Construction Site Instruction-(CSI)

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will be generated, or an existing CSI modified, to prescribe the use and

control of the Concrete Order Form.

Training of appropriate personnel on

the requirements of the procedure will be conducted." This corrective-action

was to be completed on December 1, 1979.

CSI 3.2.1, " Control of Concrete Order Forms, Pour Cards, and Batch Tickets,"

was issued on December 5, 1979.

It appears, however, that training was not

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conducted until April and/or May oft 1980.

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Gulf States Utilities Quality Assurance Finding Report (QAFR) #81-4-23-D,

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' dated April 14, 1981, identified that documented evidence for the required

craft training for Stone and Webster personnel'was received in April 1980.

No National Mobile Craft personnel were listed.

A letter from the Director of Quality Asserance to Stone and Webster

(RBG 7296), dated March 3, 1980, documents that the required training as

indicated in the response had not been accomplished as of February 15, 1980.

Stone-and Webster responded in a letter (C-RBS-03120), dated March 17, 1980,

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that the training " conducted" was required reading of the procedure for the

ordering of concrete, and was not originally documented.

The letter

further states that, "since this was not originally documented, the require--

ment will be applied again and documented." Copies of this documentation

were to be provided by March 20, 1980.

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A response to the QAFR was received on June 2, 1981, documenting that

a training program for National Mobile Concrete Corporation was estab-

lished through Stone and Webster, and that the previously required

training had been completed as required. The NRC inspector reviewed

the appropriate documentation and verified the required corrective

action had been performed.

From the review of this matter, it was obvious to the NRC inspector

that the required training was not accomplished in a timely canner.

The NRC inspector discussed this matter with licensee representatives,

and stated that even though the failure to provide training documentation

was adequately identified by the Quality Assurance Program, it is

the licensee's responsibility to ensure corrective action has been

completed on the date when full compliance is achieved. Documentation

in this case, is the objective evidence that satisfactory corrective

action has been performed, and since this documentation verified that

the corrective action had been completed, this item is considered

closed.

3.

Licensee Identified Construction Deficiency Reports

(Closed) Miscellaneous Steel Provided by CIVES Steel. The NRC Region IV

office was notified on December 6,1979, of a potentially reportable

deficiency with regard to miscellaneous steel provided by CIVES Steel

Company. The problem involved CIVES procurement of steel from suppliers

who did not meet applicable quality assurance requirements.

In addition,

a small amount of the questionable material was inadvertently installed.

A review of Stone and Webster Specification 210.320, Revision 1, "Miscel-

laneous Steel and Embedments, Category 1," indicated four Nonconformance

and Disposition (N&D) reports were initiated indicating low yield strength

readings or questionable material for plates from one of the suppliers

for CIVES Steel.

N&D 9209 documents that a test specimen obtained from the same heat as

that used on the mat anchor ring exhibited a yield strehgth of 48.3 ksi

versus the specified 50 ksi of ASTM 588-74. These were confirmatory

tests. The manufacturer's test indicated 52 ksi and 52.5 ksi. N&D 9220

documents a 47.3 ksi for this same test performed by the independent test-

ing agency.

In addition, the element nickel composition test perfomed

by the agency conflicted with the manufacturer's test results.

N&D 9225 and N&D V009 document other suspect material from this same

manufacturer and supplier to CIVES Steel.

These conditions were evaluated by the licerseo and found not to con-

stitute a reportable deficiency under the requirement of 10 CFR 50.55(e).

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Design calculations for the mat anchor ring on page' 502 of Book #005

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reflect that the first radial layer is stressed to 33'.~67 ksi and the

secondradiallayerisstressedto3f93ksi. These calculations re-

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flect strengths less than the 43.47 <si_ (with the, app' lied reduction

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factor) exhibited by confinnatory- testing.

Theseatanglesandangleframesasf.ocudentedonN&DV009andthesteel

plates as documented on N&D 9225 have noistructural significance.

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Thus, this item is considered closed.

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(0 pen) Potential Breakdown in the Qualiti-Assuranca Program of B. F.

Shaw.

Stone and Webster notified the B.,R' Shaw Cofpany b

on May 5,1981, of a breakdown in their Quality Nssurance y letter

Program

involving the unauthorized use of the Stone and Webster Procurement

Quality Assurance Representative's signature on a B. F. 'Shaw Radio-

graphic Inspection Report. Over sixteen nundred Radiographic In-

spection Reports were reviewed some time < betweenJJaf,and Septeder of

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1981, and fifteen unauthorized signatures were identif_i.ed

Sub4quen,tl,y,.

the vendor was removed from the Stone and Webster Quahfied Vendors

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list for future work until such time as they (B. T. Shaw) '" establish

integrity within their Quality Assurance Organization." -

However, the licensee was not notified by St'one and W@ ster until

September 15, 1981, and the condition was.subsequentl7' reported as a

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"potentially" reportable deficiency to the Region IV' office of the

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USNRC on September 17, 1981. The acting Quality Assurance Director

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was verbally notified of this breakdown by the Stone and Webster

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Quality Assurance Director, and was informed it did not constitute

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reportability.

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Criterion V of Appendix B to 10 CFR 50 required that . activities affect-

ing quality shall be prescribed by documented proced6res and shall be

accomplished in accordance with these procedtfres.. '/

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Stone and Webster Quality Standard 16.23 Revihon A, " Notifying Clients

of Potentially Reportable Deficiencies Under.10 CF8 50.55(e),"

establishes "... a system for the identification _ and review of de-

ficiencies to ensure that the client is potified of all deficiencies

identified by Stone and Webster that may 6e reportable to the NRC."

Section 4.'2.1 of this procedure states, "Any, Stone end 41ebster em-

ployee having evidence that a potentially reportable' deficiency may

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exist shall report the occurrence in writing to the approv' iate first

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reviewer."

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River Bend Project Procedure 10.5, Revision 0, "Potentially Reportable

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Deficiencies - 10 CFR 50.55(e)," requires in Section 2 that the Stone

[r' %'l and Webster Project Manager notify the GSU Vice President of Operations

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p' and Technical Systems of a potentially reportable deficiency within

seven days of receiving initial notification of same from the designated

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The {ailu're.to notify the licensee of this potential breakdown while

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extensive' evaluation was being performed is considered to be a vio-

lation to Criterion V of Appendix B to 10 CFR 50; i.e., failure to

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fo low procedures that implement Criterion V requirements.

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Site Tour

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The NRC inspector toured the safety-related plant areas several times

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during the inspection period to observe the progress of construction

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Noyiolations or' deviations were identified.

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_ Concrete Placement Activities

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Placement of Reinforcing Steel

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/ The NRC inspector reviewed Section 3.8 of the FSAR and related-

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Stone and Webster construction specifications applicable to con .

crete placement.

It was noted that the FSAR, in Section 3.8.4.2,

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s'tates that ACI 318.1971, "American Concrete Institute -Building

Cgde Requirtments for Reinforced Concrete" (including 1974 supple-

n',ent) is used in the structural design of concrete and steel com-

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ponentscof Seismic Category I structures (this is referenced in

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NP M Tcpection-Report 50-458/81-10, paragraph 2).

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, ACI 3'18, Section 10.3.2 requires, for flexural members and for mem--

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ratie thall not exceed 0.75 of that which would produce balanced

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conditions for the section under flexure without axial load.

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This code provision to limit the tension reinforcement is to allow

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the steel to govern and reach yield without brittle concrete failures.

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As referenced in NRC Inspection Report 50-458/81-05, an Engineering

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and Design Coordination Report, E&DCR P-1283 was written to revise

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the specification requirements to allow the use of Grade 60

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material" on a one-bar-to-one-bar basis in lieu of Grade 40 material

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or Grade 50 material.

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On. February 5, 1981, a Stone and Webster Engineering Report was

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issued directing that for structures designed for applicable loads

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.in accordance with ACI 318, both ASTM A 615, Grade 40 and ASTM

A 615, Grade 60 satisfy the specified yield strength and may be

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used interchangeably. However, it failed to address the requirements

of Section 10.3.2 of ACI 318.

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' A Stone and Webster letter ' dated August 24, 1981, states that en-

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gineering has performed a review of their calculations for Quality

Assurance Category I reinforced concrete structures for compliance

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with the ACI 318-71 Code Requirement to limit the amount of rein-

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forcing in flexurai members to 75% of the " balanced" design con-

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dition. The results indicate that 10 isolated areas exist that -

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would require further review relative to the ACI Code Requirement

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if Grade 60 reinforcing were substituted for the specified grade

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. 'of material. When this list was reviewed against the rebar fab-

ricator's records, it was found that nine of the areas of concern

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had been fabricated from the specified grade of material leaving

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only one area to consider; a pipe tunnel roof slab. Since the

' pipe tunnel ' reinforcing had already been fabricated, but not yet

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constructed, the bar spacing and strength of the concrete were

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modified tci conform to a Grade 60 design.

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It further' states, " Future designs will include a check for a

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" balanced" design condition using the specified strength of rein-

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fo.rcing as well as a Grade 60 substitution. Areas where a Grade 60

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' substitution is not allowed will be noted on the design drawing."

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.However, these.calculrcions appear to have been made as a result

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of the concern ident'fied by the NRC inspector in NRC Inspection

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-Repott 50-458/81-0G, regarding the substitution of the steel.

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k Cor.cr'eting placements were made without full compliance to NRC

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'% 4.ommitments, The NRC inspector has been assured that loads at

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~~ River Bend are such that the steel will never be in the plastic

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range;<however, reinforcing steel was substituted without adequate

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' consideration .for the requirements of ACI Section 10.3.2.

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NRC inspector must also be assured that all buildings were and

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-. will be reviewed for the" balanced" design condition.

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. Consideration for this design requirement should have been in-

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change was made. Thus, since calculations were not available as

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s cation change appears to deviate from the licensee's commitments.

stated at the time this concern was identified, the specifi-

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This is considered'to be a deviation.

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b.

Placement of Concrete

The NRC inspector reviewed the Stone and Webster Construction

Specification 210.370, Revision 7, Addendum 1, " Placing Con-

crete and Reinforcing Steel." Pre-placement, placement, finish,

and curing records were then reviewed for the following Cat-

egory I concrete placement:

Placement

Date

PSW-HDFM-125

5/26/81

RB-SW-EQ-HTC-105

6/23/81

AB-8-W109G2

7/11/81

PSW-HDFM-140

7/24/81

RB-7-W105

7/26/81

RB-7-W111

8/12/81

AB-10-W137J5

8/12/81

PSW-HDFM-147-I

8/22/81

AB-12-W141P1

9/05/81

RB-3-W160

9/26/81

During this review, it was noted that several unit weight tests

performed in accordance with ASTM C138 for Category I concrete

placements were performed and documented on Category II placement

records. ANSI N 45.2.5, " Structural Inspection and Testing During

the Construction Phase," requires this test be performed once

daily during production. Licensee representatives verified that

Stone and Webster Field Quality Control (FQC) performed the re-

quired test and documented the test results on the placement

records for the concrete batch from which the tests were performed.

These placements were appropriately referenced on the Category I

placement records.

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It was also noted that placement records for interior wall

placements and placements below grade indicated a minimum limit

of 0% for the air entraining agent as accept / reject criteria.

The River Bend FSAR, on page 3.8-82 states, "An air-entraining

agent is used in the concrete in an amount sufficient to satisfy

ACI 301, Section 3.4.1 (durability)."

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Licensee representatives stated that the requirements of ACI 301,

Section 3.4.1 are applicable to " concrete of normal weight which

will be subject to potentially destructive exposure." Thus,

these requirements are not applicable to interior wall placements

and concrete placements below grade.

As referenced in NRC Inspection Report 50-458/80-06, the use of air

entrainment must be controlled in accordance with standard industry

practice.

Placement records reviewed indicated that air entrain-

ment was being used properly and in accordance with standard in-

dustry practice. Thus, the licensee is meeting his commitment as

stated in his letter of October 21, 1981 (RBG 8849).

To complete the review of concrete placement activities, the NRC

inspector reviewed fifteen N&D's involving improper consolidation

of concrete. All nonconformances reviewed reflected wall areas

with voids of minor depth and/or honeycombing. All areas were

repaired te,. adequate procedures and were appropriately documented.

No violations or deviations were identified.

6.

Installation Requirements for Safety-Related Piping and Pipe Supports

and Component Supports

The NRC inspector initiated this portion of the inspection with the

review of the Stone and Webster Specification 228.000, Revision 1,

" Piping Engineering and Design." This specification implements the

ASME Boiler and Pressure Vessel Code,Section III, Division 1, Nuclear

Power Plant Components, dated July 1, 1974. A review of Stone and

Webster Specification 228.160, Revision 1, " Fabrication and Erection

of Piping" revealed that these specifications implement similiar

requirements.

Further review of specification requirements for piping and pipe support

installation established that the Stone and Webster Specification 228.130,

Revision 1, " Design and Fabricstion of Power Plant Piping Supports" and

228.312, Revision 1, " Field Fabrication and Erection of Pipe Supports"

incorporate the requirement of the ASI1E Boiler and Pressure Vessel Code,

Section III, Division I, Nuclear Power Plant Components, dated July 1, 1974,

as well as ti.a June 30, 1974 Addendum.

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Stone and Webster Specification 221.900, Revision 1, ." Fabrication of

Component Supports" implements the requirements of the 1977 Edition of

the Code, including the Winter 1978 Addendum. . Stone and Webster

Specification 229/160, Revision 1, " Mechanical Installation - Category I"

incorporates the -equirements of the ASME Code, 1974 through Summer 1978

Addenda.

The River Bend.FSAR, in Section 3.9.1.4.2As requires that Seismic

Category I ASME Code Class 1, 2, and 3 piping be analyzed and designed

in accordance with ASME Section III, 1974 edition. Pipe supports

are analyzed and designed in accordance with the 1974 Edition, in-

cluding the Summer 1974 Addenda. Component supports are designed in

accordance with the ASME Section III 1977 Edition up to and including

the Winter 1978 Addenda. The specification requirements reflect

these appropriate FSAR commitments for analysis and design.

However, the NRC inspector needs to ascertain the specific ASME Code

and Edition to be used for the installation of piping, piping supports,-

and component supports at the River Bend facility. NRC Inspection

Report 50-458/80-02 states, in paragraph 5, "It was confirmed,

... that ASME B&PV Code,Section III, Division I,1974 through Summer

1976 Addenda is in effect during the construction phase at River

Bend." More information is needed so _ that the NRC inspector can en-

sure a consistent use of the ASME Code and Edition for the applicable

installation to be performed. Thus, this matter is considered to be

unresolved.

No violations or deviations were identified.

7.

Structural Steel Erection

The NRC inspector reviewed Stone and Webster Specification' 210.310,

Revision 6, " Structural Steel." The applicable FSAR requirements, as-

well as the Quality Assurance Inspection Plan, " Category I Structural

Steel." dated August 12, 1981, were also reviewed.

A review of selected Category I structural steel members received at

the site after June 1980, indicated that the nonconformances as dis-

cussed in NRC Inspection Report 50-458/80-13 did not exist. The Quality

Assurance Inspection Plan, Attribute W-19, Item 15, indicated that

all completed welds were to be visually inspected rather than a ran-

dom sample as previously practiced prior to the identification of the

nonconformances.

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This was discussed with the Vendor Inspection Branch and it was de-

termined that an inspection of the supplier's shop, as requested by

a December 15, 1980 memorandum, would not now be necessary in that the

nonconforming conditions have been corrected.

The NRC inspector, however, will review all nonconformances identified

on steel received prior to June 1980, to determine if the deficiencies

should have been reported under the c.ontext of 10 CFR 50.55(e) and if

the deficiencies have been properly repaired. Current specification

requirements will also be reviewed in the next reporting period to

ensure the requirements comply with AWS D1.1.

No violations or deviations were identified.

8.

Class IE Electrical Equipment Qualification

The Stone and Webster Specification 244.523, Addendum 4, " Standby Static

Battery Chargers" specifies requirements for Power Conversion Products

to furnish standby static battery chargers to the River Bend Project.

On October 7,1981, Brown and Root, Inc. , contractor of the South Texas

Project at that time, provided written notification of a reportable defect

in accordance with 10 CFR 21, regarding similiar Class IE battery chargers

supplied by Power Conversion Products. .The notification states "the

deficient conditions could compromise the Class IE qualification of the

battery chargers... and may be of significance in a generic sense."

As a result of this notification, an NRC inspector from the Vendor In-

spection Branch, Reactive Inspection Section of the NRC Region IV Office,

performed an inspection of Power Conversion Products. . Discussions with

the inspector disclosed that several nonconformances were identified

during the inspection. Some forti-five sites, including River Bend, were

supplied with these chargers, and the matter was currently being evaluated

in NRC Headquarters as more information is obtained.

Additionally, it was brought to the NRC inspector's attention during the

inspection period that the Rockbestos Company 300 volt power cable is to

be installed only in plant areas not subject to the enviormental extremes

resulting from a high energy line break accident.

Stone and Webster is

currently examining various cable constructions which will fulfill all

technical and qualification requirements for service in plant areas sub-

ject to this type of accident. This is documented in Stone and Webster's

letter of August 24, 1981, to the licensee (RBG 6798). Thus, the proper

use of this cable is being evaluated and no cable of this type has been

installed to date in any of the plant areas.

No violations or deviations were identified.

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9.

Unresolved Item

Unresolved items are matters about which more information is required

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

or deviations. One such item has been discussed within this report.

It will be entitled as follows in future discussion:

Paragraph 6

" Specific ASME Code and Addenda for Safety-Related Piping

and Support Installation."

10.

Management Interviews

The RRI met with one or more of the persons identified in paragraph I at

various times during the inspection period. An exit meeting was held

on November 13, 1981, to discuss various findings and observations made

during this inspection period.

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