ML20050D881

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IE Insp Repts 50-498/82-01 & 50-499/82-01 During Jan 1982. Noncompliance Noted:Warehouse Contained Unflagged Electrodes & safety-related Fasteners,Pipe Fittings & Valves Missing Release for Const Tags
ML20050D881
Person / Time
Site: South Texas  
Issue date: 03/23/1982
From: Boardman J, Boardmn J, Hill W, Martin L, Oberg C, Tomlinson D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
References
50-498-82-01, 50-498-82-1, 50-499-82-01, 50-499-82-1, NUDOCS 8204120404
Download: ML20050D881 (13)


See also: IR 05000498/1982001

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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

Report:

50-498/82-01; 50-499/82-01

Dockets:

50-498

50-499

Licensee:

Houston Lighting and Power Company (HL&P)

P. O. Box 1700

Houston, Texas 77001

Facility:

South Texas Project, Units 1 and 2

Inspection At: South Texas Project, and HL&P Corporate Office, Houston, Texas

Inspection Conducted:

This report covers the month of January 1982

Inspector:

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. Martin, Aeactor Inspector, RPS-B

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(Details Section B)

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C.R.Oberg,InspecyonSpecialist

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Reviewed By:

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D. M. Hunnicutt, Chief, Engineering Section

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Approved By:

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W. A. Crossman, Chief

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Reactor Project Section B

Inspection Summary:

Inspection conducted during month of January 1982 (Report: 50-498/82-01; 50-499/82-01)

Areas Inspected: Details Section A - Quadrex Report Review and Status; Details

Section B - Transition Activities Site / Houston; Details Section C - Storage and

Maintenance Activities onsite.

This inspection period involved 201 inspector-

hours by eight NRC inspectors.

Results:

In the three areas inspected, no violations or deviations were identified

in two of the areas.

One violation was identified in the area of storage and

maintenance onsite relating to warehouse storage (Details Section C, paragraph 3).

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DETAILS SECTION A

1.

Persons Contacted

Principal Licensee Employees

S. M. Dew, Manager, Engineering Department

L. R. Jacobi, Jr., Supervising Engineer, Nuclear Safety & Licensing

C. G. Robertson, Manager, Nuclear Licensing Department

J. G. White, Principal Engineer, Nuclear Engineering

M. Powell, Team Leader, Licensing

2.

Quadrex Report *

a.

General

The inspector met with licensee representatives on January 20, 21,

and 22, 1982, initiating a special inspection effort concerning the

Quadrex Report.

The purpose of the initial meeting was to determine

the manner in which Houston Lighting & Power (HL&P) plans to resolve

the issues identified in the Quadrex Report,

b.

Background

The Quadrex Corporation, under contract to HL&P, conducted a study

of the Brown and Root (B&R) design and engineering activities.

A report of their efforts was issued in early May 1981.

The

purpose of the study was to conduct an independent review of the

B&R design and engineering program.

The Quadrex Report is a three

volume document.

Volume I is an executive summary of the findings.

B&R response and Quadrex assessment of design questions are

provided in Volumes II and III.

The Quadrex Corporation conducted a review of the following technical

disciplines:

Civil / Structural

Computer Programs and Codes

Electrical / Instrumentation and Control

Geotechnic

HVAC

Mechanical

Nuclear Analysis

Piping and Supports / Stress and Special Stress

Radiological Control

  • " Design Review of Brown & Root Engineering Work for the South Texas Project,"

(three volumes), a study conducted by the Quadrex Corporation, 1700 Dell Avenue,

Campbell, California,

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A sampling program was devised to provide indication of potentially

weak areas in the STP plant design.

3.

HL&P Actions Regarding the Quadrex Report

Through discussion with HL&P personnel and review of correspondence, it

was determined that an independent Bechtel task group has been established

to review the Quadrex Report.

Currently, the Bechtel assessment is scheduled for completion by the end

of March 1982.

It is to contain comments by B&R and Quadrex Corporation.

HL&P plans to submit the Bechtel Report to the NRC (RIV) as soon as it is

received.

The NRC inspector told the HL&P personnel that the NRC is planning to

track all Quadrex findings to their resolution.

In addition, contacts

would be made with the Bechtel task group and, subsequently, with the

Quadrex Corporation.

The purpose of the initial meeting with the

Bechtel task group leader was to identify the Bechtel approach to the

Quadrex findings and to discuss the extent of NRC's concerns regard-

ing the Quadrex Report.

4.

Management Meeting

The NRC inspector met with one or more of the persons identified in

paragraph 1, on January 22, 1982, to discuss inspection information.

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DETAILS SECTION 8

1.

Person Contacted

Principal Licensee Employees

J. E. Geiger, Project QA Manager

D. R. Keating, Project QA General Supervisor

J. W. Williams, Site Manager

J. W. Estella, Supervisor Quality Systems / Admin.

T. J. Jordan, Project QA Supervisor

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R. M. McDaniel, Quality Assurance

M. E. Powell, Licensing Assistant Team Leader

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J. L. Blau, Supervisor Project Engineering

J. G. White, Engineering

J. R. Molleda, Engineering

Bechtel Personnel

J. L. Hurley, Project Engineering Manager

K. R. Dotterer, Project QAE

D. T. Krisha, QA Manager

A. W. Stenerson, Deputy QA Manager

B. R. McCullough, Manager, Construction

J. R. Downs, Deputy Manager, Construction

R. L. Patterson, Manager Division QA

Brown and Root Personnel

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A. W. Smith, Project QA Manager

D. J. Harris, Assistant Project QA Manager

F. W. Rothermel, Assistant Project Manager

P. S. Jordan, Licensing Manager

J. H. Wawrzeniak, Assistant Engineering Project Manager

R. D. Hamilton, Engineering Coordinator

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The above listed personnel were present at one or more meetings held during

January 11-14, 1982, at the South Texas Project and the HL&P Corporate

Field Office in Houston, Texas.

2.

General

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W. A. Crossman, W. G. Hubacek, and L. E. Martin of Region IV, met with

licensee representatives, Bechtel, and Brown and Root personnel on site

and in Houston, to discuss the transfer of responsibilities to Bechtel

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and the yet unnamed constructor.

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The basic transition program was discussed, including status and the

various organizational responsibilities.

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3.

Onsite Activities

Brown and Root has approximately 600 people onsite.

They are involved in

care and maintenance, receiving and storage, ASME walkdowns, and document

control activities.

Bechtel has approximately 130 people onsite involved-

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in ASME walkdowns, system statusing and procurement turnover.

Bechtel

is presently operating under a Memorandum of Understanding as the Bechtel

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contract is not scheduled to take effect until February 15, 1982.

The inspectors reviewed the schedules and Bechtel staffing plans through

the defined transition periods.

The ASME interface agreement may be

issued by January 15, 1982, the Project Quality Program Manual should be

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complete by mid-February, and the ASME walkdowns should be complete by

the first week in February.

4.

Houston Corporate Field Office and A/E Transition

The transfer of the engineering effort is to be accomplished via Brown and

Root assembled work packages (160 packages) and subpackages (approximately

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1400).

B&R submits the packages to Bechtel.

HL&P, at this time, is only

statusing the packages and tracking them.

The present B&R contract

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expires April 30, 1982.

If the preparation of work packages has not been

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completed, HL&P will subcontract B&R to completion.

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HL&P will review in total, the final draft of the work package report and

will have surveillance responsibilities.

HL&P QA will review procedures

and audit the transition activities.

The NRC inspectors outlined the basic inspection program for the transition

period and delineated the key individuals from Region IV to be used as

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contacts.

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The discussions, both at the site and in Houston, were mutually beneficial.

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The inspectors had no further questions.

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DETAILS SECTION C

1.

Persons Contacted

Principal Licensee Employees

  • J. E. Geiger, Project Quality Assurance Manager
  • D. F. Bednarczyk, Project Quality Assurance Supervisor, Civil
  • F. T. Alkov, Project Material Control
  • D. L. Teague, QA Specialist

S. K. Hubbard, Senior QA Specialist

R. Russell, Construction Engineer

  • D. R. Keating, Project Quality Assurance General Supervisor

J. W. Estella, Supervisor, Quality Systems / Administration

J. W. Williams, Site Manager

  • I.

P. Morrow, Construction Superintendent

Other Personnel

  • A. W. Smith, Project Quality Assurance Manager, Brown & Root (B&R)
  • F. W. Rothermel, Assistant Project Manager, B&R
  • D. J. Harris, Assistant Project Quality Assurance Manager, B&R
  • K. L. Clegg, Special Projects, B&R
  • R. A. Meggison, Project QC Engineer, Bechtel Power Corp.

L. Hearn, Warehouse General Foreman, B&R

F. Dunham, General Foreman, Paint Department, B&R

J. Wood, Foreman, Permanent Plant Maintenance, B&R

D. Coppeler, Project Quality Control Superintendent, B&R

A. A. Brown, PPM Records Supervisor, B&R

  • A. W. Stenerson, Deputy QA Manager, Bechtel

D. R. Downs, Deputy Manager, Construction, Bechtel

  • B. R. McCullough, Construction Manager, Bechtel
  • D. T. Krisna, Project QA Manager, Bechtel
  • Denotes those persons attending one or more of the exit meetings during

January 1982.

2.

Site Tour

Routine tours of the site were conducted by the Senior Resident Inspector

and the region-based inspectors to observe housekeeping activities, general

cleanliness, protection and preservation of equipment and material, personnel

access control, and plant status.

Areas observed included:

Units 1 and 2

Reactor Containment Buildings, Mechanical-Electrical Auxiliary

Buildings, Fuel Handling Buildings, and Diesel Generator Buildings

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Site

Reservoir, Essential Cooling Pond, and storage areas, including

the warehouses, laydown areas, and the welding fabrication shop.

With regard to the above areas, the inspectors confirmed the following:

Safety-related and storage areas were free from an accumulation of

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trash, refuse, and debris.

The areas were clean and free of foreign matter.

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Tools, equipment, and material were returned to their proper storage

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location when no longer in use.

An accumulation of fine sand or grit was observed in the Mechanical-Electrical

Auxiliary Building (MEAB) and cleaning was in progress by assigned personnel.

Through discussion with licensee personnel and review of previous records,

the inspector learned that this item of concern was previously identified

and acknowledged by the licensee.

The inspector will continue to monitor

the cleaning efforts as part of the routine inspection program.

Any items

of concern identified during the tour were presented to the licensee and

resolved by management personnel.

Of particular interest during these tours were the measures being taken to

prevent potential degradation of components and materials during the

current extended construction delay.

Most of the loose materials stored

in the Reactor Containment Building (RCB) and MEAB have been inventoried and

removed to warehouse storage areas.

Approximately 15 stacks of structural

steel and pipe spools in these two areas were observed by the inspectors.

Each was tagged with an identification sheet which tied each stack to a

specific job and drawing number.

Much of the installed piping was tagged

with vinyl tape strips of various colors or color combinations identifying

the individual piping systems and the persons conducting the inventory.

Each system is being walked down and visually inspected by Bechtel as part

of the design review portion of the transition phase of construction turnover.

During the tour of the warehouse areas, numerous pallets of material returned

from the construction areas were noted.

Each was identified as noted above,

and was traceable to a particular job and drawing number.

No in-depth review

was conducted of the warehouse storage procedures as Brown & Root still

retains this function which has been satisfactorily reviewed during

previous inspections.

General warehouse conditions appeared adequate.

Material was neatly stored, heaters were operational, and equipment requir-

ing energization was energized.

The ends of all piping spools observed,

whether stored or installed, were capped and sealed, as were the open-

ings on pumps, valves and other components.

Any items of concern identified during these tours were presented to the

licensee and resolved by management personnel.

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3.

Storage and Maintenance

The inspectors observed activities in several warehouses and other

designated storage areas with particular attention paid to the following

activities:

Classification and location of specific equipment - Various storage

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areas were segregated and classified as levels A through D to

provide appropriate storage and environmental control for various

types of equipment.

Temperature and humidity were being measured and recorded to confirm

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that ambient conditions were being controlled as appropriate.

Storage areas were not being used to store food, drink, or salt.

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An active program was in effect to control rodents and small animals.

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Racks, crates, and cribbing were carrying the full weight without

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component distortion.

All items were labeled and stored in a manner that allows access

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for inspection.

Fire protection systems and equipment were available for use.

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Sufficient dunnage was available to materials and components in

storage.

Canvas or plastic covering was available for weather protection,

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as required.

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Protective covers and seals were properly attached.

Personnel access to the storage locations were adequtely controlled.

The inspectors noted numerous maintenance personnel who were performing

checks and preventative maintenance procedures.

During the week of January 18-22, 1982, the following findings were

identified.

10 CFR Part 50, Appendix B, Criterion V, requires that, " Activities af fect-

ing quality shall be prescribed by documented instructions, procedures, or

drawings, of a type appropriate to the circumstances and shall be accom-

plished in accordance with these instructions, procedures, or drawings.

Instructions, procedures, or drawings shall include appropriate quantitative

or qualitative acceptance criteria for determining that important activities

have been satisfactorily accomplished."

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The following are examples of an apparent violation of the requirement

that activities affecting quality be accomplished in accordance with

documented procedures or instructions:

a.

Brown and Root Procedure A040KPMECP-8, Revision 0, " Control of

Welding Material," dated June 13, 1978, paragraph 8.5.3.2, requires

that material returned without the original flag tag shall be

stored in the Material Distribution Station (MDS) as Miscellaneous

Weld Filler Material (MWFM), and transferred to the Welder Qualifi-

cation and Training Center (WQTC) for training only.

On January 18,

1982, an NRC inspector in the licensee warehouse storage area for

welding material identified three boxes of bare welding wire which

licensee personnel indicated were for use for safety-related

applications.

These three boxes had been issued from the warehouse

and had been returned to the warehouse.

Each box contained one or

more lengths of bare wire which had no flag tag, but these boxes had

not been sent to the WQTC as required.

These boxes were transferred

to the WQTC by the licensee after this condition was identified by

the NRC inspector.

b.

Brown and Root Procedure ST-QAP-13.1, Revision 0, Amendment 0.1,

" Receiving Inspection," effective December 15, 1981, paragraph 3.14,

requires that items determined to be acceptable shall be identified

with a " Release for Construction" tag until the material is released

from warehouse control. On January 18 and 19, 1982, . two NRC inspectors

found 21 lots of safety-related fasteners, pipe fittings and valves

stored in licensee warehouse, under warehouse control, without the

required " Release for Construction" tags.

Subsequently, licensee

personnel provided the NRC inspector with a copy of licensee Quality

Assurance Corrective Action Report (CAR) Number HP-032, dated

November 23, 1981, which identified this same type of deficiency for

safety-related materials stored under warehouse control in storage

level D laydown areas.

Failure to accomplish activities affecting Quality as prescribed in

documented instructions or procedures is an apparent violation of

10 CFR Part 50, Appendix B, Criterion V.

This is a violation. (8201-1)

4.

Storage of Construction Materials

The NRC inspectors toured storage areas for the diesel generators, for

instrumentation and control systems material, and for coatings (paints).

The licensee's contractor has been controlling shelf life for coatings.

Contractor procedures for safety related coatings, such as Specification

3A810W5017-C, " Service Level I Coatings for Concrete Surfaces," including

Design Change Notices and Field Change Requests through November 5, 1981,

exclude coating thinners from shelf life control, even though shelf life

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of thinners is specified by manufacturers for Level 1 (safety-related)

coatings.

This will remain an unresolved item until the licensee has

documentation substantiating that shelf life control is not required

for thinners, and that use of thinners having exceeded the manufacturers'

established shelf life will not result in degradation of Level I coatings

throughout plant life during all postulated conditions, including the

Design Base Accident. (8201-02)

5.

Aluminum Bronze Pipe and Components for the Essential Cooling Water (ECW)

System

During the inspection, an NRC inspector discussed with licensee personnel

the licensee's use of aluminum bronze pipe and components in the essential

cooling water system which is safety-related.

Based on his previous experi-

ience, the NRC inspector was aware of the phenomenon of "De-aluminization."

"De-aluminization" is the dissolving of aluminum from an aluminum bronze

alloy under certain environmental conditions, such as use with saline water,

unless the aluminum bronze alloy is stabilized by the addition of approx-

imately 4 percent nickel.

"De-aluminization" reduces the strength of the

material and has been known to make the material permeable to liquids.

A

subsequent discussion with licensee personnel indicates that the aluminum

bronze material specified for the ECW system was not nickel stabilized and

that the possibility of de-aluminization had not been considered or technically

evaluated.

Pending technical verification that "de-aluminization" will not

occur or have a deleterious effect on the aluminum bronze pipe and components

installed in the ECW system, this will remain an unresolved item. (8201-03)

6.

Unresolved Items

Unresolved items are matters about which more information is required in

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

deviations.

Two unresolved items are identified in paragraphs 4 and 5

of this section of the report.

7.

Exit Meetings

Exit meetings were held on January 14, 21, and 29, 1982, with the licensee

representatives to discuss the scope and findings of that particular span of

the inspection period.

The violation (paragraph 3) and the two unresolved

items (paragraphs 4 and 5) were identified.

During this time, Mr. W. M. Hill reported to the South Texas Project as the

Senior Resident Inspector for the USNRC.

Mr. Hill met with appropriate

site personnel in an introductory meeting.

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