ML20151V023
| ML20151V023 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/05/1986 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20151V027 | List: |
| References | |
| CON-#186-041, CON-#186-41 OL, NUDOCS 8602110177 | |
| Download: ML20151V023 (15) | |
See also: IR 05000498/1985021
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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WASHINGTON. D. C. 20555
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February 5, 1986
D:cket Nos. 50-498
and 50-499
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Houston Lighting and Power Company
ATTN:
'4r. J. H. Goldberg
Group Vice President - Nuclear
P. O. Box 1700
Houston, TX 77001
Gentlemen:
SUBJECT:
CONSTRUCTION APPRAISAL TEAM INSPECTION 50-498/85-21 AND 50-499/85-1
Enclosed is the report of the Construction Appraisal Team (CAT) inspection
conducted by the Office of Inspection and Enforcement (IE) on October 21-
November 1 and November 12-22, 1985, at the South Texas Project site.
The
Construction Appraisal Team was composed of members of IE, Region IV, and a-
number of consultants.
The inspection covered construction activities
authorized by NRC Construction Permits CPPR-128 and CPPR-129.
This inspection is the fourteenth in a series of construction appraisal
inspections conducted by the Office of Inspection and Enforcement.
The
results of these inspections are being used to evaluate the management control
of construction activities'and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inspection.
Within these areas, the effort consisted primarily of detailed inspection of
selected hardware subsequent to quality control inspections, a review of
selected portions of your Quality Assurance Program, examination of procedures
and records, and observation of work activities.
Appendix A to this letter is an Executive Summary of the results of this
inspection and of conclusions reached by this office.
This inspection identi-
fied a number of significant deficiencies.
These included hardware and design
control deficiencies which in most cas'es resulted from weaknesses in your
construction program.
The significance of the identified deficiencies was
generally acknowledged in the actions taken by your site organizations during
and immediately after the NRC CAT inspection.
These actions included:
the
initiation of appropriate nonconformance reports and other corrective action
documentation; a voluntary stop work order for all construction and startup
activities involving the modification of wiring for motor operated valves; and
your notifications to our Region IV office of certain deficiencies potentially
reportable under 10 CFR 50.55(e).
We are concerned by the significance, implications and the occurrence of
identified deficiencies in various areas of construction which were inspected.
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Houston Lighting and Power Company
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February 5,1986
These areas include:
the modifications of wiring for motor operated valves;
the uncontrolled modification of design change documents; the configuration of
molded case circuit breakers with load-side terminal extensions and insulation
barriers ~in vendor supplied motor control centers; the retrievability, location
and availability of radiographic film and documentation from balance of plant
suppliers; and certain quality control accepted installations of instrumenta-
tion and tubing, socket welds in 2-inch Schedule 160 piping, mechanical equip-
ment, and bolting for structural steel sliding connections.
Additional manage-
ment attention is required for these and the other areas of construction
discussed in Appendix A to ensure that completed installations meet design
requirements and that appropriate and timely corrective action is taken to
prevent the recurrence of construction program weaknesses which were the cause
of the identified hardware deficiencies.
The significance of certain NRC CAT findings were mitigated due to the correc-
tive actions you have already initiated to resolve like findings of your
self-initiated pre-CAT inspection.
Examples of these include:
the planned
corrective action for the identification of deficiencies in the separation of
electrical raceways, the program improvements you have implemented for the
inspection or reinspection of piping supports / restraints, and your reported
plans for the reinspection of structural steel.
These activities are recog-
nized as contributing directly to providing the required assurance of the
quality of construction for your project.
However, we are concerned with the
timeliness of some of these planned corrective actions. An example is your
plan for delaying plant walkdowns for the identification of problems with
electrical raceway separation and the delay in implementing the program you
have developed for the identification of improper clearance between piping,
supports / restraints and other hardware.
The delay in implementation of these
corrective actions, in our opinion, increase the likelihood of further problems
and could cause delays in the satisfactory completion of construction at the
South Texas Project.
We have recently received a copy of your January 10, 1986 letter to Mr. Robert
D. Martin relating to actions being taken to address project areas requiring
improvement. Your letter will be included as part of our continuing review of
this matter.
Appendix B to this letter contains a list of potential enforcement actions
based on the NRC CAT inspection.
These are being reviewed by the Office.of
Inspection and Enforcement and the NRC Region IV Office for appropriate action.
In addition, Region IV will be following your corrective action for deficien-
cies identified during this inspection.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room.
No reply to this letter is
required at this time.
You will be required to respond to these findings
after a decision is made regarding appropriate inforcement action.
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Houston Lighting and Power Company
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February 5,1986
Should you have any questions concerning this inspection, please contact us or
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the Region IV Office.
Sincerely,
,
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ieT M.
ay1
, Director
fice of Ins ection and Enforcement
Enclosures:
1.
Appendix A, E.<ecutive Summary
2.
Appendix B, Potential Enforcement Actions
3.
Inspection Report
cc w/ enclosures:
See next page
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Houston Lighting and Power Company
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February 5,1986
1
cc w/ enclosures:
Houston Lighting & Power Company
ATTN: Mr. M. Wisenberg, Manager
Nuclear Licensing
P. O. Box 1700
Houston, Texas 77001
Brian Berwick, Esquire
Asst. Attorney General
Environmental Protection Division
P. O. Box 12548, Capitol Station
Lanny Alan Sinkin
Citizens Concerned About
Nuclear Power, Inc.
3022 Porter Street, N.W., #304
Washington, D.C.
20008
Charles Bechhoefer, Esquire
Chairman, Atomic Safety & Licensing
Board
U.S. Nuclear Regulatory Commission
Washingten, D.C.
20555
Dr. Jac.s C. Lamb, III
333 Woodhaven Road
Chapel Hill, North Carolina 27514
Frederick J. Shon
Administrative Law Judge
Atomic Safety and Licensing Board
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Ray Goldstein, Esquire
Gray, Allison and Becker
100 Vaughn Building
807 Brazos
Texas Radiation Control Program Director
(need to get address from Region IV)
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Houston Lighting and Power Company
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February 5,1986
Distribution
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APPENDIX A
EXECUTIVE SUMMARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at
Houston Lighting and Power's South Texas Project (STP), Units 1 and 2, during the
period October 21-November 1 and November 12-22, 1985.
OVERALL CONCLUSIONS
Hardware and documentation for construction activities were generally in
accordance with requirements and licensee commitments.
However, the NRC CAT
did identify a number of hardware deficiencies that in most cases have resulted
from construction program weaknesses.
These include:
1.
A lack of effective design change control between the architect / engineer
(AE) and the nuclear steam system supplier (NSSS) which has resulted in
the inability to correlate the actual wiring configuration of valve motor
operators with design. The actions taken for prior site organization
audit findings involving the adequacy of AE/NSSS design interface of the
wiring design in another area also indicate a weakness in the applica-
tion of corrective action measures.
In addition, a significant number of
hardware and workmanship deficiencies were identified with the wiring of
motor operated vahes.
2.
Significant deficiencies in the configuration of Class 1E molded case
circuit breakers with load-side terminal extensions and insulating
barriers indicate that the licensee's inspection program was ineffective.
The indicators of this ineffectiveness include source surveillance,
receipt, and field cable termination inspections that failed to identify
and correct these conditions.
3.
A number of installation and procedural deficiencies were identified in
mechanical equipment and in bolting of valve flange pipe installations for
which Quality Control (QC) inspections had been completed.
The omission
of a vendor tolerance dimension on the installation instructions for the
mounting of annubar flow probe devices indicates a weakness in the design /
construction interface.
4.
The numerous instances of overtightened bolts in structural steel sliding
connections indicates that the licensee's installation and inspection
programs were particularly ineffective in this area.
Certain licensee
evaluations performed during the inspection to address NRC CAT concerns
are considered questionable.
These include questions related to the
extent the clay layer beneath the Essential Cooling Water (ECW) piping
will expand .pon cessation of the dewatering system and the potential of
this occurrence to over stress the ECW piping, the potential for addi-
tional forces to be exerted on the Unit 2 tendon access wall due to the
omission of the 3-inch seismic joint, and the effect of the practice of
cross flange welding on the design strength of loaded structural steel.
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5.
A lack of traceability of fasteners for electrical equipment, certain
vendor supplied equipment assemblies and bolting used in cable tray and
conduit supports was identified by the NRC CAT.
These deficiencies were
magnified by the AE's change to a specification in the electrical area to
delete the requirement for the manufacturers' marking on fasteners.
6.
Certain areas of weakness were experienced during the inspection of
design change control.
In addition to the matter of motor operated valves
discussed above, these included the control of the modification of design
changes during their incorporation into design drawings; .the undocumented
use of engineering judgment in lieu of explicit or generic calculations
for ensuring the adequacy of design in certain design change documents;
and the conflicting definitions for configuration control packages in
issued revisions of governing procedures (Bechtel, EDP 4.72 and
WPP-22.0, and Ebasco, ASP-17).
7.
Additional areas of weakness were found in the applicattun of correc-
tive action measures for the previously identified significant deficien-
cies in the maintenance of permanent plant equipment during the construc-
tion phase.
The operations maintenance program does not address whether
an identified deficiency could affect the equipment's ability to perform
its design function or its operational maintenance program.
Also, weak-
ness was found in the control of " HOLD" tags.
8.
Weaknesses were found in the area of nondestructive examination records
for balance of plant suppliers.
This included a weakness in the licensee
program for audit review and acceptance of these records.
In addition,
after the radiographs for the reactor vessel head were discovered to
be missing in May 1985, the licensee's scope of corrective actions did
not address whether the records of balance of plant suppliers performing
nondestructive examination activities may be similarly affected.
9.
A significant number of reworked conduit installations were lacking QC
reinspection for bolt torque.
This indicates a weakness in the program
for inspection of installations reworked after initial QC acceptance.
10.
The project's response to identified deficiencies in electrical raceway
separation was questioned.
The decision was made to postpone further
separation inspections until the time of area turnover.
The NRC CAT is
concerned with modifications to correct separation deficiencies that
may adversely affect plant systems already accepted and turned over to
startup or operations, in addition to being more difficult to identify
after construction is completed.
This concern was also raised by the STP
pre-CAT verification team.
These construction program weaknesses indicate that additional management
attention is required to assure that completed installations meet design
requirements.
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AREAS INSPECTED AND RESULTS
Electrical and Instrumentation Construction
The samples of electrical construction inspected generally met the applicable
design requirements and installation specifications.
However, several signifi-
cant design and construction deficiencies in electrical construction, and
numerous installation discrepancies in instrumentation construction were
identified.
The configuration of molded case circuit breakers with load-side terminal
extensions and insulating barriers in installed Class IE motor control centers
was found to be deficient in that the potential for phase-to phase faulting or
inadvertent circuit interruption exist.
Relevant inspection activities, which
had been completed, including source surveillance, receipt inspection, and field
cable termination inspection did not identify these deficiencies.
Additionally,
the seismic qualification of equipment which exhibits this configuration could
not be verified.
Hardware and workmanship deficiencies were found in all of the 16 installed
motor operated valves inspected by the NRC CAT.
In addition, lack of adequate
design and installation control for the wiring of motor operators supplied by
Westinghouse Corporation (NSSS vendor) and further modified by the architect /
engineer resulted in various organizations not being supplied the required
wiring configuration documents.
Numerous dimensional and workmanship deficiencies were found in the instrumen-
tation construction sample inspected.
This included an installation which had
undergone the licensee's QC Effectiveness Inspection conducted after final
construction QC inspection and turnover to the startup organization.
Examples
of these deficiencies include dimensions exceeding tolerance limits on five
installations, an incorrect weld configuration on a support, a missing support
clamp, and a support installed in accordance with an incorrect drawing detail.
In addition, attachments were being made to existing supports without the
required engineering review and approvals.
Several items of Class 1E equipment were found to deviate from their
applicable specification requirements.
These included the mislocation of
terminal strips and fewer than the required minimum number of terminal block
points in several switchgear cubicles, the absence of required vendor installed
terminal lugs on three fan motors, and the incorrect insulation class for a
pump motor.
The conduit strap bolts for a significant number of the conduit installations
inspected did not exhibit the required torque seal.
Since this is due to
their removal and reinstallation without reinspection by QC, increased controls
are required for inspection of rework of QC accepted conduit installations.
Mechanical Construction
Piping, pipe supports / restraints, concrete expansion anchors and heating
ventilation and air conditioning hardware (supports / restraints, duct sections,
fire dampers) were generally found to be installed in accordance with require-
ments or with deficiencies that generally had previously been identified.
However, significant deficiencies were identified in two areas of piping
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installation.
These included the design tolerance dimension error applicable
to the mounting of numerous annubar flow probes and the alternate bolting used
in lugged wafer valves.
A significant number of hardware deficiencies were identified in ten of the
twelve mechanical equipment items inspected.
The sample of equipment was
diverse and included:
the reactor water makeup tank, various pumps (RHR,
containment spray, and low and high head safety injection), charging pump
coolers, EAB return air fan, and a fuel handling building filter.
The identi-
fied deficiencies included items such as:
the uncontrolled removal of speci-
fied tank cushion material (FLEXCELL), incorrect / indeterminate fastener
material, missing shim for an equipment mounting pad, a damaged foundation beam
flange, welding of a gussett plate to the edge of embed which exceeded speci-
fied tolerances, missing and undersized welds, and bolt holes not per drawing.
The number and significance of the deficiencies identified, indicated a lack of
overall effectiveness in the installation and inspection programs for mechani-
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cal equipment.
Welding and Nondestructive Examination
Welding and nondestructive examination activities were generally found to be
conducted in accordance with the governing codes and specifications.
However
a number of examples were found where completed structural welds in pipe
supports / restraints were smaller than that specified in the design drawings
and some skewed welded connections were not supported by calculations.
Also,a
number of undersized socket welds were found in 2-inch schedule 160 piping
spools.
Some vendor supplied tanks and heat exchangers were found to have undersized
weld reinforcement in " nozzle to shell" and "manway to shell" joints.
The NRC
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previously issued Information Notice 85-33 on the subject of undersized "ASME
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category D" joints in tanks and heat exchangers notifying the licensees of
potentially significant deficiencies in this area.
The NRC CAT inspectors did
not find evidence that the project had reviewed the content of the information
notice for applicability to their facility.
The NRC CAT inspectors also found a small number of radiographs.which had
unacceptable weld quality.
In addition, the team encountered difficulties in
retrievability and location of vendor NDE film and documentation covering
the Balance of Plant (80P).
This indicated a need for a means to identify NDE
requirements, and the location and existence of NDE film and documentation for
,
BOP equipment supplied by vendors.
In May 1985, the project had identified
missing radiographs for the reactor head and as a result has instituted a
program requiring Westinghouse to submit monthly reports concerning status and
availability of NDE film and documentation.
The NRC CAT findings indicate that
the licensee's corrective action should have also covered the B0P suppliers.
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Civil and Structural Construction
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General quality of reinforced concrete construction was observed to be
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adequate. The issue of omission of the 3-inch seismic joint relative to the
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tendon access wall of the Unit 2 Reactor Containment Building at azimuth 304*
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and elevation (-)13 ft and 3 inches needs to be adequately evaluated and
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appropriate actions taken.
In general, structural steel installation appeared
to be adequate.
However, a high rate of deficiencies was identified in the
overtightening of bolting for structural steel sliding connections for which
the licensee has committed to perform a 100 percent reinspection to ensure that
bolting is torqued to the proper level.
The extent to which the underlying and adjacent clay soil layer supporting the
Essential Cooling Water (ECW) piping will swell when the dewatering system is
discontinued remains a question which requires further revi u by the licensee
and NRC.
Material Traceability and Control
The licensee's material traceability and control program was generally found
to be acceptable.
However, lack of traceability was found for fastener
materials for certain large vendor supplied mechanical equipment assemblies
mounted on skids and for certain electrical equipment.
It was also found that
engineering had deleted the requirement of the specified national standard for
manufacturers marking of fasteners intended for electrical cable tray and
conduit supports, which contributed to the resulting uncertainty of control and
traceability during and after installation.
Desian Change Control.
The design change control program was determined to be generally in accordance
with site procedures with several exceptions. These include:
The deficiencies identified with respect to the installation of
Westinghouse supplied motor operated valves indicates that a design
control weakness exists in the AE/NSSS interface at STP.
The controls for posting unincorporated design changes on design documents
were not adequately implemented at one reference station.
The control of modifications being made to change documer'.s upon their
incorporation into the design drawings.
Identified changes to the origi-
nal scope or technical content of the change document were not being
adequately documented, reviewed and approved.
The conflicting definitions for configuration control packages in issued
revisions of governing procedures of the AE and constructor organiza-
tions.
Corrective Action Systems
Appropriate corrective action systems and procedures were generally found
to be in place except for certain areas.
These include:
weaknesses in areas
involving control of fastener materials, preventive maintenance, audits and
records of radiographs, unidentified deficiencies with certain electrical
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items (motor operated valves, motor control centers, and instrumentation
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construction), and control of " HOLD" tags.
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APPENDIX B
POTENTIAL ENFORCEMENT ACTIONS
As a result of the NRC CAT inspection of October 21-November 1 and November 12-
22, 1985 at the South Texas Project site, the following items are being referred
to Region IV as Potential Enforcement Actions.
Section references are to the
detailed portion of the inspection report.
1.
10 CFR 50 Appendix B, Criterion III, as implemented by the South Texas
Project (STP) Quality Assurance Plan (QAP) Section 3.0, requires that
measures be established for the identification and control of design
interfaces and coordination among design organizations.
These measures
shall include the review, approval, release, distribution, and revision
of documents involving design interfaces.
Contrary to these requirements, at the time of this inspection:
a.
The licensee failed to provide adequate interface between the design
organizations (architect / engineer (AE), and the nuclear steam system
supplier (NSSS)), and the organizations performing the physical work.
This was evidenced by the inability of the licensee to provide a
design baseline wiring drawing for NSSS supplied motor operated
valves, the AE's revised designs not being provided to the NSSS for
their review and incorporation into NSSS drawings, and the inability
to correlate the actual wiring with current design documents.
(Section II.B.3.b.(8))
b.
Vendor tolerance requirements for the mounting dimension of the
annubar flow probe on essential cooling water piping were not
included on installation drawings and subsequently a number of
annubar mounting flanges were mislocated with respect to the distance
from the pipe outer wall.
(Section III.B.I.b).
2.
10 CFR 50 Appendix 8, Criterion III, as implemented by the STP QAP
Section 3.0, requires that design control measures provide for verifying or
checking the adequacy of design and that design changes, including field
changes, shall be subject to design control measures ccmmensurate with
those applied to the original design.
Contrary to these requirements, at the time of this inspection:
a.
The licensee could not provide calm stions or documented engineering
jtdgment to substantiate the design edequacy of the addition of four
bays of structural steel detailed on the November 5, 1984 revision of
Bechtel drawing No. 3M01-9-S-4043. (dection VII.B.3.b.(5))
b.
Six field change request (Nos. BC-01202, CC-03426, CC-04949,
CC-04461, BS-1-0194, and 85-1-0235) and one drawing change notice
(No. 7) were modified upon incorporation into the design drawings
without being adequately reviewed, approved and documented to reflect
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changes in technical content or scope.
(Section VII.B.3.b.(2))
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3.
10 CFR 50 Appendix B, Criteria VII, as implemented by the STP QAP Section
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7.0., requires that measures be established to assure that purchased
equipment conform to the procurement documents.
These measures shall
provide objective evidence of the quality furnished by the contractor or
subcontractor.
<
Contrary to these requirements, at the time of this inspection:
a.
The licensee failed to identify the deficiencies in the bolting of
load-side terminal extensions and in the insulating barriers supplied
with certain molded case breakers in motor control centers.
These
deficiencies have the potential for causing phase-to phase faulting
or inadvertent circuit interruption.
Further, the licensee was not
able to confirm that the load-side terminal extensions or insulating
barriers were seismically qualified.
(Section II.B.3.b.(4))
b.
The NRC CAT inspectors found several deficiencies in vendor supplied
components.
The deficiencies included undersized welds in tanks and
heat exchangers and radiographs which did not have the required weld
and film qua'ity. These also include SKV switchgear cubicles with
mislocated terminal strips and terminal blocks with less than the
minimum required terminal points, fan motors which did not have the
required vendor installed terminal lugs, and a pump motor without the
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required class of insulation.
(Sections II.B.3.b and IV.B.10.b with
Table IV-5 and Table IV-6)
4.
10 CFR 50 Appendix B, Criterion VII, as implemented by the STP QAP Section
7.0, requires documentary evidence that material and equipment conform to
the procurement requirements shall be available at the plant site prior to
installation or use of such material and equipment.
This documentary
evidence shall be retained at the nuclear power plant site and be suffi-
cient to identify the specific requirements, such as codes, standards, or
specifications, met by the purchase material and equipment.
Contrary to the requirements, at the time of this inspection the licensee
could not determine the location of NDE film and documentation required by
engineering specifications as documented evidence of the quality of welding
for equipment and hardware procured from various vendors for the balance
of plant equipment.
(Section IV.B.10.b)
5.
10 CFR 50 Appendix B, Criterion VIII, as implemented by the STP QAP
Section 8.0, requires that measures be established for the control of
materials, parts and components to prevent the use of incorrect or defec-
tive items.
Contrary to these requirements, at the time of this inspection it was
determined that traceability and control of some fasteners, including
bolting for mechanical and electrical equipment of various types, and
the unmarked bolting for electrical cable tray and conduit supports, has
not been adequate to assure the use of correct materials.
Also, the
deletion of the requirement for marking of fasteners required to comply
with national standards contributed to the loss of traceability and
control of the referenced unmarked bolting.
[Section VI.B.1.b (3)(c), (d)
and (f)]
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6.
10 CFR 50 Appendix B, Criterion X, as implemented by the STP QAP Section
10.0, requires that a program for inspection of activities affecting
quality be established and executed by or for the organization performing
the activity to verify conformance with the documented instructions,
procedures and drawings for accomplishing the activity.
Contrary to the above requirements, at the time of this inspection, the
licensee's inspection program was ineffective in that:
a.
Numerous deficiencies were identified with the installation of QC
accepted instrumentation and instrument tubing.
Examples of these
deficiencies include dimensions exceeding tolerance limits on five
installations inspected, an incorrect weld configuration on a tubing
support, a missing support clamp, and a support installed in accord-
ance with an incorrect drawing detail.
The specific installations
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and deficiencies are detailed on Table II-7 of the report.
(Section
II.B.4.b)
b.
A number of undersized socket welds were found in 2-inch schedule
160 piping.
Additional examinations of approximately 200 QC accepted
field welds of this type found at least 15 percent to be undersized.
(Sections III.B.1.b and IV.B.1.b)
c.
On six lugged wafer valves, hex-head cap screws had been substituted
for threaded studs and nuts inconsistent with the applicable essen-
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tial cooling water piping installation isometric drawing and/or bill
of materials.
(Section III.B.1.b)
.
d.
Ten of the twelve mechanical equipment items selected for NRC CAT
-examination included components which were not constructed or other-
wise installed in accordance with applicable design or specified
installation requirements.
(Section III.B.4.b. and Table III-5)
e.
A number of examples were found where completed structural welds in
pipe supports / restraints in welded joints were smaller than that
specified in the design drawings.
The list of these welds is in
Table IV-1.
(Section IV.B.1.b)
f.
More than 60 percent of the inspection sample of 68 high strength
bolts for structural steel sliding connections were installed over-
tight.
Installation and inspection requirements had not been
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translated into appropriate procedures ensuring proper installation
of the bolts in a ' snug tight" condition.
(Section V.B.2.b)
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g.
Strap bolts on 8 of the 28 conduit runs inspected did not exhibit
the required torque seal.
Reinspections for torque had not been
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accomplished following rework to QC accepted conduit installations.
(Section II.B.1.b.(2))
7.
10 CFR 50 Appendix B, Criterion XVI, as implemented by the STP QAP Section
16.0, requires that measures shall be established to assure that condi-
tions adverse to quality such as failures, malfunctions, deficiencies,
deviations, defective material and equipment, and nonconformances are
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promptly corrected.
In the case of significant conditions adverse to
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quality, the measures shall assure that the cause of the condition is
>
determined and corrective action taken to preclude repetition.
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Contrary to these requirements, at the time of the inspection the licen--
see's corrective actions were found to be inadequate in that the balance
- of plant suppliers of NDE film and documentation were not included in the
corrective actions taken after the radiographs for the reactor vessel head
were discovered to be missing in May 1985.
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