ML20151W825

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Advises That Vendor Insp Rept 99900823/83-01 May Be Released to Public
ML20151W825
Person / Time
Issue date: 08/04/1988
From: Westerman T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20151W819 List:
References
FOIA-88-173, REF-QA-99900823 NUDOCS 8808250147
Download: ML20151W825 (1)
v • d • e


Text

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MEMORANDUM T0: FILE i FROM: T. F. Westerman, Enforcement Officer

SUBJECT:

DIVERSIFIED THREADED PRODUCTS (INSPECTION REPORT 99900823/83-01)

Per conversation with Dick Herr, OIA on November 17, 1983, he stated that Vendor Inspection Report 99900823/83-01 could be released, although 01 Investigation Report has not been released.

7//Ada T. F. Westerman Enforcement Officer O YL (C V.f Ts1h-8s-05 ma -- k I CULLEDG00-173 pyg

ORGANIZATION: D! VERS!FIED THREADED PRODUCTS COMPANY MIDDLEBURG HEIGHTS, OHIO REPORT INSPECTION INSPECTION 14 0 . - 99900923/83-01 DATF(S) 6/13-17/M 04-stTF H0HPS- 19 CORRESPONDENCE ADDRESS: Diversified Threaded Products Company ATTN: Mr. Alan Thomas Chairman of the Board 18685 Sheldon Road Middleburg Heights, Ohio 44130 -

ORGANIZATIONAL CONTACT: Mr. Paul Novotel, General Manager TELEPHONE NUMBER: (216) 267-1640 PRINCIPAL PRODUCT: Threaded fasteners.

NUCLEAR INDUSTRY ACTIVITY: Approximately 35 percent of sales.

ASSIGNED INSPECTOR: O~m P-zo-A3 g J. T. Conway, Reactive and Component Program Dates Section (R& CPS)

OTHER INSPECTOR (S):

APPROVED BY: / 8-.m f-2o-ea I. Barnes, Chief, R& CPS Dates INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.

B. SCOPE: This inspection was made as a result of allegations pertaining to the fabrication of nuclear bolting from nonnuclear grade materials.

In addition, the inspection included an evaluation of QA program implementation with respect to training, control of purchased material and services, manufacturing control, audits, and reporting of defects.

PLANT SITE APPLICABILITY:

Not identified.

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ORbANIZATION: DIVERSIFIED THREADED PRODUCTS COMPANY MIDDLEBURG HEIGHTS, OHIO REPORT IN5PECIiON NO.: 99900823/83-01 RESULTS: PAGE 2 of 5 A. VIOLATIONS:

Contrary to Sections 21.6 and 21.21 of 10 CFR Part 21:

1. A copy of 10 CFR Part 21 that was posted was not the current copy dated December 30, 1982.
2. Procedures to evaluate deviations or inform the licensee or purchaser of the deviation did not exist.

B. NONCONFORMANCF,S:

1. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraph 1.3 of Section VI and paragraph 3.0 of Section VII of the Quality Assurance Manual (QAM), a review of 18 sales / purchase orders (P0s) from Diversified Threaded Products (DTP) for the purchase of nuclear material or services revealed the following:
a. P0 N-2358 dated August 17, 1981, to Ryerson Steel did not specify 10 CFR Part 21 requirements or SA-540 material as referenced in ITT Grinnell's PO 53414-N to DTP.
b. P0 N-4624 dated December 14, 1982, to Texas Bolt did not specify 10 CFR Part 21 requirements as referenced in NPS's P0 AUS 3737 to DTP. ,
c. PO 832 dated July 13, 1979, to Bethlehem Steel and P0 N-3335 dated August 9,1982, to Tensile Testing Company were not documented as being reviewed by the QA Manager.
2. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 13.1 of SA-194, and NCA-3867.4(a)(1), review of 21 procurement packages for nuclear material indicated that the specific data contained in DTP's certifications to their customers differed from the specific data contained in the certified material test reports from the manufacturer / supplier for the following cases:
a. Materials were certified by DTP as SA-194, Grade 8, and "solution annealed and water quenched" for PO 310054. The manufacturer's certification did not identify the material specification nor I indicata that a proof load test had been performed as required by SA-194.

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. e ORbhNIZATION:DIVERSIFIED THREADEO PRODUCTS COMPANY MIDDLEBURG HEIGHTS, OHIO RLPORI lt45PLCilutt NO.: 99900823/83-01 RESULTS: PAGE 3 of 5

b. Materials were certified by DTP as SA-307, Grade A and B for P0s PDX 20336N and 50396, respectively. The manufacturer's certification did not identify the material specification for ,,

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c. Materials (nuts) were certified by DTP as ASTM A307, Grade A, with a hardness of BHN 158 for P0 42129. The manufacturer's certification identified the material as 1018 and did not indicate that the material had undergone hardness or proof load testing as required by A307. There was no indication that the required testing was performed by a service vendor.
d. 10 CFR Part 21 requirements were specified on P0s X 88217, 50096, PDX 20323N, 310176 BMP, 31054 AMP, 53414, and AUS 3737. None of the manufacturer's certifications specified 10 CFR Part 21, but DTP's certifications specified Part 21 on P0s X 88217, PDX 20336N, PDX 20323N, and AUS 3737.
e. ASME Code Section III requirements were specified as applicable on P0s X 88217 and 50096. Certification from the manufacturer was missing for P0 50096. For X 88217, DTP certified the applicability of ASME Code Section III although the manufacturer's certification did not so indicate.
3. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraphs 1.0 and 1.1 of Section VII of the QAM, reviews of 21 procurement packages for nuclear material and 24 external audit reports indicated that certain vendors had supplied material to DTP who had not been audited or surveyed by DTP, and whose furnished CMTRs did not indicate that the material was manufactured and/or supplied in accordance with an ASME approved quality program; e.g.,

Republic Steel (DTP's customer was Rockwell International), .

I Copperweld Steel, Central Steel & Wire, Crucible Specialty Metals, l and ARMCO.

l 4. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and l paragraphs 1.0 and 2.0 in Section XI of the QAM, a review of 28 shop travelers relating to nuclear orders revealed the absence of I final dimensional inspection approval on one shop traveler relating I

to P0 380 N0803-104 and two shop travelers relating to PO 52878.

ORhANIZATION:

DIVERSIFIED THREADEO PRODUCTS COMPANY MIDDLEBURG HEIGHTS, OHIO  ;

REiUKi l hM t t., t a vii NO.: 99900823/83-01 RESULTS: PAGE 4 of 5 i

5. Contrary to Criterion V of Appendix B to 10 CFR Part 50, paragraphs 6.1 and 6.2 of Section X and paragraph 1.0 of Section r XIV of the QAM, Ultra Labs Inc performed magnetic particle ,

examination in accordance with DTP's P0 N-2836 dated October 21, ,

1981, but DTP did not have the personnel qualification recnrds of the NDE personnel. -

6. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and item A of Part 2 of QAV-001, a review of nine procurement packages from ITT Grinnell revealed that OTP did not indicate on their certifications that the material was furnished to QA requirements meeting NF 2610.

C. UNRESOLVED ITEMS:

None D. OTHER FINDINGS OR COMMENTS:

1. Allegation - The NRC received allegations that DTP was purchasing non-nuclear material, fabricating it into bolting material, and certifying it as nuclear material to their customers.

The NRC inspector reviewed procurement packages relating to nuclear orders from ITT Grinnell Pipe Hanger Division (9), Johnson Controls (2), General Electric (1), NPS (6), and Rockwell International (3), and found numerous incidences where the certifications from DTP to their customers were not consistent with information contained in the certifications from the manufacturer / supplier. Nonconformances B.2 and B.6 were identified in this area of the inspection.

2. Training / Qualification _s - Training records for two QA personnel, one management personnel, and one shop personnel were reviewed to assure that personnel performing and verifying activities affecting quality were trained. Nonconformance B.5 was identified in this area of the inspection.
3. Control of Purchased Material and Services - Eighteen sales / purchase orders from DTP for nuclear material and services were reviewed to assure that material and services were purchased from qualified manufacturers / suppliers. Nonconformance B.1 was identified in this area of the inspection.

ORGANIZATION: DIVERSIFIED THREADED PRODUCTS COMPANY

. MIDDLEBURG HEIGHTS, OHIO ,

REPORT INSPECIl0N NO.: 99900823/83-01 RESULTS: PAGE 5 of 5

4. Manufacturing Control - Twenty-eight shop travelers relating to nuclear orders were reviewed to assure that identified manufacturing activities were performed and signed-off by ,

appropriate personnel. Nonconformance B.4 was identified in this area of the inspection.

5. Audits - During the review of 24 audit reports conducted on material manufacturers / suppliers and service vendors, it was noted that 5 audit reports were not signed by the auditor and one audit report did not contain a checklist.

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y-]<-A-43 Houston Lighting & Power JM 3 01984 Company The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely.

Originst Signed 3/

L H. Johnson E. H. Johnson, Chief Reactor Project Branch 1

Enclosures:

Appendix A - Notice of Violation Appendix B - NRC Inspection Report 50-498/83-24 50-499/83-24 bec to DMB (IE01) bec RIV:

RPB1 Resident Inspector RPB2 Section Chief (RPS-B)

TPB J. Gagliardo J. Collins A. Vietti C. Wisner T. Westeman RIV File MIS System TEXAS DEPARTMENT OF HEALTH

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NOV 1 s 1933 h .g. . ll: q sanun Docket No. 99900823/83-01 l

i Diversified Threaded Products Company ATTN: Mr. A. Thomas (

Chairman of the Board

'.0685 Sheldon Road Middleburg Heights, Ohio 44130 Gentlemen: ,

a This refers to the inspection conducted by Mr. J. T. Conway of this office on June 13-17, 1983, of your facility at Middleburg Heights, Ohio, associated with the fabrication of bolting materials and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.

This inspection was made in conjunction with an investigation by the Region IV Of fice of Investigations as a result of the receipt of allegations pertaining to the fabrication of nuclear bolting from nonnuclear grade materials.

Investigation findings will be issued separately. ,

Areas examined and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector.

During the inspection it was found that the implementation of your QA program failed to meet certain NRC requirements. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter.

This Notice of Violation is sent to you pursuant to the provisions of Section 206 of the Energy Reorganization Act of 1974. You are required to submit to this office within 30 days from the date of this letter, a written statement containing: (1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and f preventive measures were or will be completed. Consideration may be given to extending your response time for good cause shown. ,

You are also requested to submit a similar written statement for each item t which appears in the enclosed Notice of Nonconformance. '

-gvrtu fb3Aes-ns , l a,e w 1

Diversified Threaded Products Company .

It is apparent from the results of this inspection that serious deficiencies existed in the implementation of your quality assurance program relative to the fabrication of bolting materials.

As a result of both your specific failure to comply with applicable provisions of Part 21 as noted in Appendix A, and the deficiencies identified in Appendix B, we are concerned that the Commission may not have been adequately informed, as required by 10 CFR Part 21.21(b)(3), relative to defects or failure to comply.

You are therefore requested as part of your corrective action, to reassess your past actions for full conformance to Part 21 requirements. Should the results of your evaluations conclude that the Commission has not been adequately informed as required under Part 21, you are requested to provide in writing a statement addressing your corrective actions as noted above.

The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a). notify this office by telephone within 10 days from the date of this letter of your intention to file a request for withholding; and (b) submit within 25 days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than 7 days are available for your review, please notify this office promptly so that a new due date nay be established. Consistent with i Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on i

the basis which it is claimed that the information should be withheld from i public disclosure.. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. {

i Should you have any questions concerning this inspection, we will be pleased to I discuss them with you.

Sincerely, f.

t f

U1 otapovs, ef [

Vendor Program Branch I

I

Diversified Threaded Products Corrpany

Enclosures:

1. Appendix A - Notice of Violation
2. Appendix B - Notice of Nonconfortnance
3. Appendix C - Inspection Report No. 99900823/83-01
4. Appendix 0 - Inspection Data Sheets (2 pages)

o i ,

i APPENDIX A

]

b Diversified Threaded Products Company P

Docket No. 99900823/83-01 /

i NOTICE OF VIOLATION f

As a result of the inspection conducted on June 13-17, 1983, and in accordance  !:

with Section 206 of the Energy Reorganization Act of 1974 and its implementing 5 l

regulation 10 CFR Part 21, the following violation was identified and has been categorized in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix B), 47 FR 9987 (March 9, 1982):

i Section 21.6 of 10 CFR Part 21 dated December 30, 1982, states, in part, "(a)

. Each . . . corporation . . . subject to the regulations in this part, shall '

3 post current copies of the following documents . . . (1) the regulations in this part, (2) Section 206 of the Energy Reorganization Act of 1974, and (3) l procedures pursuant to the regulations in this part." j Section 21.21 states, in part: "(a) Each . . . corporation . . . subject to the regulations in this part shall adopt appropriate procedures to: (1) f provide for; (i) evaluating deviations; or (ii) informing the licensee or  ;

purchaser of the deviation in order that the licensee or purchaser may cause 4 the deviation to be evaluated unless the deviation has been corrected . . . ." -i Contrary to the above:

s I

1. A copy of 10 CFR Part 21 that was posted was not the current copy dated December 30, 1982.

4 2. Procedures to evaluate deviations or-inforr, the licensee or purchasor of r the deviation did not exist.

! This is a Severity Level V Violation (Supplement VII).

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l APPENDIX B i

Diversified Threaded Products Company Docket No. 99900823/83-01 ,

l l

NOTICE OF NONCONFORMANCE l l

Based on the results of an NRC inspection conducted on June 13-17, 1983, it appears that certain of your activities were not conducted in accordance with l NRC requirements as indicated below: i Criterion V of Appendix B to 10 CFR Part 50 states: "Activities affectng quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Isihtructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."  ;

Nonconformances with these requirements are as follows: L A. Paragraph 1.3 of Section VI, Revision 4, of the Quality Assurance Manual (QAM) states, in part, "All sales orders shall be reviewed by the Quality Assurance Manager to be sure that all quality requirements are defined as referenced in the customer's purchase order."

Paragraph 3.0 of Section VII, Revision 5 of the QAM states, in part, "Purchase Orders for code materials or services shall be reviewed by the Quality Assurance Manager prior to issuance to the vendor."

Contrary to the above, a review of eighteen sales / purchase orders (P0s) from Diversified Threaded Products (DTP) for the purchase of nuclear material or services revealed the following:

1. PO N-2358 c:ted August 17, 1981, to Ryerson Steel did not specify 10 CFR Part 21 requirements or SA 540 material as referenced in ITT Grinnell's PO 53414-N to DTP.
2. PO N-4624 dated December 14, 1982, to Texas Bolt did not specify 10 CFR Part 21 requirements as referenced in NPS's P0 AUS 3737 to DTP.

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3. P0 832 dated July 13, 1979, to Bethlehem Steel and P0 N-3335 dated Auoust 9,1982, ta Tensile Testing Company were not documented as be 'n reviewed by the QA Manager.

B. A+ v ?1 procurement packages for nuclear material indicated that pu, s. s to DTP referenced ASME material specifications (15 P0s), ,

Sec. quirements (2 P0s), and 10 CFR Part 21 requirements (8 P0s).

Sect of Materials Specification SA-194 in Section II of the ASME Code ... ,, in part, ". . . a certification that the nuts were manufactured and tested in accordance with this specification may be the bas.is of acceptance of the nuts."

NCA-3867.4(a)(1) states, in part, "The Certified Material Test Report shall include the actual results of all required chemical analyses, tests, and examinations."

Contrary to the above, the specific data contained in DTP's certifications to their customers differed from the specific data contained in the certified material test reports from the manufacturer / supplier for the following cases:

1. Materials were certified by DTP as SA-194, Grade 8, and "solution annealed and water quenched" for P0 310054. The manufacturer's certification did not identify the material specification nor indicate that a proof load test had been performed as required by SA-194.
2. Materials were certified by DTP as SA-307, Grade A and 8 for P0s PDX 20336N and 50096, respectively. The manufacturer's certification did not identify the material specification for P0 PDX 20336N and certification from the manufacturer was missing for PO 50096.
3. Materials (nuts) were certified by DTP as ASTM A307, Grade A, with a hardness of BHN 158 for P0 42129. The menufacturer's certification identified the material a7 1018 and did not indicate that the material had undergone hardness or proof load testing as required by l

A307. There was no indication that the required testing was performed by a service vendor.

4. 10 CFR Part 21 requirements were specified on P0s X 88217, 50096, PDX 20336N, PDX 20323N, 310176 BMP, 31054 AMP, 53414, and AUS 3737.

Noe of the manufacturer's certifications specified 10 CFR Part 21, but DTP's certifications specified Part 21 for P0s X 88217, PDX 20336N, PDX 20323N, and AUS 3737.

5. ASME Code Section III requirements were specified as applicable on PCs X 88217 and 50096 Certification from the manufacturer was missing for PO 50096. For P0 X 88217, DTP certified the applicability of ASME Code Section III, although the manufacturer's certification did not so indicate. ,

C. Paragraph 1.0 of Section VII, Revision 5, o' the QAM states, in part,"The purchase of stock material for the manufachure of cooe fasteners . . . may be only from vendors who have been approved by the Quality Assurance Manager for the material or services which are required."

Paragraph 1.1 states, in part, "Approval of vendors may be made on the basis of surveys and audits by the Quality Assurance Manager."

Contrary to the above, reviews of 21 procurement packages for nuclear material and 24 external audit reports indicated that certain vendors had supplied material to DTP who had not been audited or surveyed by DTP, and whose furnished CMTRs did not indicate that the material was manufactured and/or supplied in accordance with an ASME approved quality program; e.g. ,

Republic Steel (DTP's customer was Rockwell International), Copperweld Steel, Central Steel & Wire, Cruc'ble Speciality Metals, and ARMCO.

D. Paragraph 1.0 of Section XI, Revision 5, of the QAM states, in part, "tthere measurements are performed on items . . . the approval of these measurements shall be indicated on the Diversified Threaded Products shop traveler by the observing inspector . . . ."

Paragrapn 2.0 states, in part, "Final dimensional inspection approval shall be indicated by the dated signature of the Quality Assurance inspector on the Diversified Threaded Products shop traveler . . . ."

Contrary to the above, a review of 28 shop travelers relating to nuclear orders revealed the absence of final dimensional inspector approval on one shop traveler relating to P0 380 N0803-104 and two shop travelers relating to P0 52878.

E. Paragraph 6.1 of Section X, Revision 5, of the QAM states, "Personnel conducting non-destructive examination shall be considered in the employ of Diversified Threaded Products relative to their responsibilities."

Paragraph 6.2 states, in part, "Qualifications of non-destructive examination individuals shall be in conformance with the code and with the recommended practices of SNT-TC-1A, 1975."

Paragraph 1.0 of Section XIV, Revision 3, of the QAM states, in part, "Quality records shall include . . . qualifications of personnel . . . ."

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Contrary to the above, Ultra Labs, Inc., performed magnetic particle examination in accordance with DTP's P0 N-2836 dated October 21,1981, but DTP did not have the personnel qualification records of the NDE persornel.

F. ITT Grinnell, Pipe Hanger Division imposed the requirements of QAV-001 ,

in their P0s to DTP for nuclear material. Item A of Part 2 of QAV-001 states, "Material shall be certified by the first-line supplier / manufacturer as being furnished to QA requirements meeting NF 2610."

Contrary to the above, a review of nine procurement packages from ITT Grinnell revealed that DTP did not indicate on their certifications that the material was furnished to QA requirements meeting NF 2610.

\

In Reply Refer To: JAN 3 01984 Dockets: 50-498/83-24 50-499/83-24 Houston Lighting & Power Company TsA-80-D3 ATTN: G. W. Oprea, Jr.

Executive Vice President P.O. Box 1700 Houston, Texas 77001 Gentlemen:

I This refers to the inspection conducted under the Resident Inspection Program by Messrs. D. P. Tomlinson and J. I. Tapia of this office during the period November 1-30,1983, of activities authorized by NRC Construction l Permits CPPR-128 and 129 for the South Texas P oject, Units 1 and 2, and to the discussion of our findings with members of your staff at the conclusion of the inspection.

Areas examined during the inspection included a review of previously identified inspection findings, site tours, allegations followup and backfill placanent activities. Within these areas, the inspection consisted of selective examina-tion of procedures and representative records, interviews and personnel, and -

observations by the NRC inspectors. These findings are doctanented in the enclosed inspection report. 1 l

During this inspection, it was found that certain of your activities were in I violation of NRC requirements. Consequently,you are required to respond to this violation, in writing, in accordance with the provisions of Section 2.201 of the NRC's "Rules of Practice," Part 2 Title 10, Code of Federal Regulations.

Your response should be based on the specifics contained in the Notice of j Violation enclosed with this letter. j One unresolved item is identified in paragraph 5 of the enclosed inspection report.

We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items in identified in paragraph 3 of the enclosed report.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Doctanent Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written -

application to withhold information contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements.of 2.790(b)(1 ,g

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APPENDIX A NOTICE OF VIOLATION f i

Houston Power & Light Company Dockets: 50-498/83-24 <

. South Texas Project 50-49E/83-24 Permits: CPPR-128 CPPR-129  ;

b Based on the results of an NRC inspection conducted during the period of *

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November 1-30, 1983, and in accordance with the NRC Enforcement Policy ji (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the following 'i violation was identified:

Failure to Follow Standard Test Method  ;

s Bechtel Power Corporation specification for field and laboratory testing r of earthwork construction, 2YO60YSO44, references ASTM D2049-69, "Relative Density of Cohensionless Soils." j ASTM D2049-69, "Relative Density of Cohensionless Soils," Table 2, I requires that a funnel pouring device be used in the minimum density test  ?

for soil samples having a maximum size of soil particle of 3/8". [

t Contrary to the above, backfill having a maximum size of soil particle of  ;

3/8" was tested for minimum density using a scoop.

~

This is a Severity Level IV Violation. (Supplement IIO) (498/8324-02) t Pursuant to the provisions of 10 CFR 2.201, Houston Lighting & Power Company  ;

is hereby required to submit to this office, within 30 days of the date of f this Notice, a written statement or explanation in reply, including: (1) the *

corrective steps which have been taken and the results achieved; (2) corrective b l steps which will be taken to avoid further violations; and (3) the date when I full compliance will be achieved. Consideration may be given to extending l your response time for good cause shown.  !

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Dated: 330W [

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION REGION IV iiRC Inspection Report: 50-498/83-24 50-499/83-24 Dockets : 50-498; 50-499 Construction Permits: CPPR-128 CPPR-129 Li cense,e : Houston Lighting & Power Company (HL&P)

P.O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project (STP), Units 1 and 2 Inspection Conducted November 1-30, 1983 Inspectors : [6 ,~ //Ed[8V

. P. Tomlinson, Senior Resident Inspector Date 04~-

heJ.1. Tapia, Reactor Inspector 438r Date f Reactor Project Section A Approved: /6 ._ lf W. A. Crossman, Chief Date Reactor Project Section B Inspection Sunnary Inspection Conducted November 1-30, 1983 (Report 50-498/83-24;50-499/83-24)-

Areas Inspected: Routine, announced inspection of previously identifie'd

\ inspection findings; site tours; allegations followup; and backfill placement activities. The inspection involved 38 inspection hours onsite by two NRC inspectors. -

Results : Within the four areas inspected, one violation was identified (failure to follow standard test method, paragraph 5).

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' 2 Detail s

1. Persons Contacted Principal Licensee Employees D. Barker, Project Manager
  • J. Barker, Supervising Project Engineer
  • D. Bednarczyk, Project QA Supervisor-Civil / Structural D. Bohner, Project QA Supervisor-Electrical J. Estella, Supervisor, Quality Systems J. Geiger, Manager, Quality Assurance J. Goldberg, Vice President, Nuclear Engineering and Construction
  • R. Hawkins, Construction Superintendent, Support Services S. Hubbard, Senior QA Specialist
  • D. Keating, Project QA General Supervisor I. Morrow, Construction Superintendent G. Oprea, Executive Vice President
  • J. Williams, Site Manager
  • M. Wisenburg, Manager, Nuclear Licensing C. Wright, Project QA Supervisor-Mechanical /NDE Other Personnel Bechtel Power Corporation (Bechtel)
  • J. Downs, Deputy Manager of Construction
  • L. Hurst, Project QA Manager
  • M. Lawson, Deputy SQE J. Little, Assistant Project Resident Engineer _

Ebasco, Services, Inc. (Ebasco)

  • J. Cenich, Construction Manager R. Cumings , QA Site Supervisor R. Grippardi, QC Site Supervisor
  • C. Hawn, Quality Program Site Manager
  • Denotes those individuals attending one or more management meetings during the inspection period.
2. Site Tours Routine tours of the site were conducted by the NRC inspector observing housekeeping activities; general cleanliness; protection and preservation of equipment and material; personnel access control; and plant status as follows:
a. Units 1 and 2 Reactor Containment Buildings, Mechanical-Electrical Auxiliary Buildings, Fuel Handling Buildings, and Diesel Generator Buildings,
b. Site Reservoir, essential cooling pond, and storage areas, including the warehouse, laydown areas, and the welding fabrication shop.

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3 With regard to the above areas, the NRC inspector confirmed the following.

(1) Safety-related and storage areas were free from accumulations of trash, refuse, and debris.

(2) Work areas were clean and orderly.

(3) Tools, equipment, and material were renened to their proper storage locations when no longer in um.

3. Licensee Action On Previous Inspection Findings (Closed) Unresolved Item (498 and 499/8209-01) Incomplete Installation of Cable Tray Supports. During a review of field verification reports (FVR),

the NRC inspector noted various written comments related to the current status of cable tray supports. These connents were recorded during walk-down inspections of the cable tray supports and included such items as incomplete installation, material deficiencies, inadequate separation and insufficient room for future installations. The NRC inspector wanted to assure that documentation generated during these inspections would be further examined during a later portion of the transition phase.

All of the deficiencies noted above and all other deficiencies noted on cable tray supports have been fully documented on nonconformance reports (NCR), and will be dispositioned individually or generically. Each NCR contains the identification number of the affected support, its location, a description of the deficiency, and disposition, as determined by engineer-ing. Several supports and/or conditions may be listed on one NCR and may -

be dispositioned on a case-by-case basis or may be blanket dispositioned.

The NRC inspector reviewed NCRs BE-00069, BE-00070, BE-00071, BE-00072, BE-00073, BE-00074, BE-00087, BE-00088, BE-00089, BE-00090, and BE-00098.

Each gave an accurate and comprehensive description of the deficiencies, the identification of the support, the location of the support, the dis-position of the deficiencies and a narrative explaining the engineering (

justification for that disposition. Because of the NCR followup of the 1 walkdown inspection findings, this item is no longer unresolved.

This item is closed.

(Closed) Unresolved Item (498 and 499/8216-02) Code Status Report Documentation. During a review of ASME transition packages documenting the status of components, supports, and appurtenances, the NRC inspector noted that on NCR SM-9763 stating that "installation documentation is not available at the time of code installation statusing, ie, operational travelers, mechanical data sheet, etc."

NCR SM-9763 was a Brown & Root "rollover" NCR that documented the current status of 41 separate items. Documentation was not complete for these items because permanent installation had not yet been accomplished. In some cases the equipment had been moved into its approximate location and tomporarily "stored-in-place." In other cases the equipment was mounted on embeds that had not been permanently located and grouted.

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This was a general NCR written to cover items that lacked documentation .

because the work had not been accomplished at the time of the status and work package turnover.

This item is closed.

(Closed) Unresolved Item (498 and 499/8315-02) Marking of Bulk Bolting Material. During a tour of the warehouse area, the NRC inspector noted that some bulk ordered safety-related bolting material was purchased without a requirement for stamp identification of the individual pieces.

In these cases the parts are stamped onsite by a QC inspector. No procedure could be identified which detailed the inspections or verifica-tions required to assure that all prerequisite conditions were satisified prior to marking. These inspections were explained verbally by the QC inspector but were not proceduralized.

WPP/QCI 12.4, "Material Identification and Marking Requirements," specifies that QC shall verify the ASME Code Class, if applicable, and the safety-related category of the items prior to marking of the material. A procedural change notice (PCN) was issued which further details the inspections required by QC personnel. This change now directs QC to verify that safety-related items were procured and received as safety-related by tracing the items back to the purchase order, material receiving report, or receiving inspection report. Verification of ASME class is now being performed by the QC inspector through a thorough review of all receipt documentation before the identifying stamps are applied. Revision 5 to Procedure WPP/QCI 12.4, which clarifies the inspection requirements, be-came effective on October 28, 1983.

This item is considered closed. _

(Closed) Unresolved During Item (498 and 499/8315-05) a routine Control inspection, the NRC of Small Parts inspector for noticed Code Pipe Supports.

that on two adjacent pipe supports the clamp-to-strut connection was made using different types of fasteners. One connection was made using a pin The NRC inspector expressed and a threaded bolt was used on the other.

concern that small parts may be lost or that a substitution of material could occur during installation or assembly.

Ebasco Procudures QCP-10.12, CSP-7, and ASP-5 address the verification and installation of piping supports. These have all been revised to include a marking / tagging / color coding system of identification of all parts.

Verification of all parts of the hanger or support is part of the final inspection perfonned to assure that all parts are in accordance with the appropriate drawing and the manufacturers specification. At the time the NRC inspector noted this condition, the hangers were in the process of being installed and the incorrect fasteners were being used temporarily as a construction aid. The installation was not complete and the final inspection had not been perfonned.

This item is closed.

(Closed) UnresolvedItem(498and499/8318-02) Support Beam Not Connected The NRC inspector observed one end to Embed in Unit 1 Containment Wall. The opposite end of a support beam welded to a structural floor member.

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tenninated adjacent to an embed in the containment wall with no attachment clips or connecting welds. This item was passed on to a licensee QA repre-sentative for further investigation.

This structural beam is located at elevation 22', approximatedly 20' south of column 3. The condition noted was noted in Bechtel's Phase "A" transition package and is also identified on Bechtel NCR-GC00152 and is awaiting ,

di sposi ti.on. The structural steel drawing for this beam shows that clips are to be welded to the adjacent embed and a bolted connection made to the l beam. No final inspections have been made of this structure. )

This item is closed.

(Closed) Unresolved Item (498 and 499/8318-03) Use of DN Tag to Track Incomplete Construction. The NRC inspector observed a NCR tag attached to a structural steel member in Unit 1 Fuel Handling Building stating that the connection bolts had not been installed. The NRC inspector expressed his concern that either the QC inspector had inspected the area before it was ready or the NCR tag was being improperly used as a tracking mech-anism for the installation of the bolts.

The tag in question was a "Deficiency Notice" (DN) attached by an Ebasco QC inspector. The DN tags are used to identify discrepancies which do not require an engineering evaluation prior to disposition. Because the discrepancy was of this nature, the use of a DN was proper. DN 164-C was issued to document the lack of A-307 bolts, nuts, and washers for the diagonal braces.

This item is closed.

(Closed) Unresolved Item (498 and 499/8318-04) Material Control of Embeds.

The NRC inspector examined a bundled lot of embeds located in a material lay-down area adjacent to Unit 2 MEAB. Following a discussion with a QC inspector it was unclear to the NRC inspector who was responsible for assuring that the embeds are of the correct material prior to installation.

When structural steel is received, Bechtel engineering reviews the material certification and mill test reports to verify that the material is of the correct type and that all demensional, chemical, and physical requirements are met. The material is then transferred to Ebasco and is color-code painted in accordance with Bechtel Specification 3A010550030, Revision 1, SCN-10. These requirements are passed on in Bechtel Procedure WPP/QCI 12.4 and Ebasco Procedure ASP-5. When the color-coded embeds are received by field activities the material color is verified by Ebasco QC prior to the placement of concrete. The QC inspector also verifies the presence of the designator "Q" or "NQ" stamped on the embed, adjacent to the existing piece mark, which indicated that the embed is to be used for safety-related or nonsafety-related application. For field fabrication of embeds, the traceability of the material is similarly established by the color-code and is verified by Ebasco QC in accordance with Procedure QCP 10.7. -

This item is closed.

4. Allegations Followup A fonner STP employee met with a member of the Region IV investigation staff and expressed concern over several events that occurred onsite during his

i 6 l period of employment. Two of these were fonvarded to the SRI for further evaluation.

a. Reportability of Item The alleger stated that an item he thought was reportable to the NRC under the provisions of 10 CFR Part 50.55(e) was not reported.

During the h water (ECW) ydrostatic piping, a testtesting of a section plug failed and the of essential pipe cooling was thrown from its temporary supports onto the ground. The alleger feels that this should have been formally reported.

It must be noted that the failure of a temporary pipe plug does not cunstitute a failure of the item under test. Following the plug failure, the pipe was replaced on its temporary supports and engineering was notified. It was detennined by engineering that tnis was not reportable as 10 CFR Part 50.55(e) states, in part, that "the holder of the construction permit shall notify the NRC of each deficiency found in design and construction, which, were it to have remained uncorrected could have affected adversely the safety of operations of the Nuclear power Plant." Part of the immediate engineering action was to request a dimensional and liquid penetrant examination of the pipe ends and all welds on this pipe section. This section of pipe was sucessfully hydrostatically tested and welded into place following those inspections. Because these inspections did not reveal any deficiencies which met the above criterion, this item was not formally reported. .

b. Rigging Practice The alleger further stated that he has concerns about the rigging practice utilized in the installation and alignment of the reactor coolant system (RCS) loop piping. He states that he reported to his supervisor that the crossover piping sections to connect the RCS pumps to the steam generators were lifted into place using the steam generator legs as lift points. He states no actions were taken for 3 weeks after he notified his supervisor.

Westinghouse Electric Corporation (Westinghouse) installation instructions for the RCS piping does not state specific requirements for the movement and placement of the piping but does state that it should be done in accordance with good rigging practices. The NRC inspector found that this incident was noted by licensee QA personnel as it was being done and "hold" tags were applied the same day. A review of the Westinghouse specification did not indicate that this was a violation of any requirements but the lift points were relocated prior to lifting the pipe from the floor into its installed position. ..

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7 Based on the above findings, the NRC inspector plans no additional action at this time.

5. Backfill Placement Activities An inspection was conducted of oigoing backfill placement activities east of the Unit 2 Auxiliary Building. One in-place density test was witnessed.

Through discussions with contractor and laboratory personnel present, it was determined that continuous QC inspection during the placement of backfill does not occur. Ebasco's QC procedure for the inspection of backfill, QCP-10.10, only requires the QC inspector to, "monitor the operation on a daily basis during the actual placing of structural backfill." Through discussions with QC personnel and from a review of available records it was determined that such an inspection frequency requirement has the potential for the placing of backfill without adequate QC inspection. The number of in-place density tests which had to be re-run indicated that there has not been as good a control over the compaction process as possible. Since the NRC inspector's review of this matter was limited in scope, this matter will remain unresolved pending further review. (8324-01)

During the review of laboratory test results of relative density determinations it was determined that Bechtel, by letter dated April 6, 1983, directed PTL to modify their test procedure to implement the scoop in lieu of the required pouring device. ASTM 02049-69, "Relative Density of Cohesionless Soils," Table 2, requires that a funnel pouring device be used in the minimum density test for soil samples having a maximum size of soil particle of 3/8". The material used at STP meets this requirement. The change to the scoop results in lower values of minimum density which in turn makes it easier to satisfy the field requirement for minimum percent compaction. This is in t ulation of the requirements of the ASTM Standard Test Method. (8324-02)

6. Unresolved Item An unresolved item is a matter about more infonnation is required in order to determine whether it is an acceptable item, a violation, or a deviation. One unresolved item is discussed in paragraph 5 of this report.
7. Management Meetings Maetings were held periodically with licensee management personnel during the course of his inspection to discuss inspection scope and findings.

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