ML20154F504
| ML20154F504 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/05/1988 |
| From: | Calvo J Office of Nuclear Reactor Regulation |
| To: | Marsh L Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20154F387 | List: |
| References | |
| FOIA-88-107 NUDOCS 8805230270 | |
| Download: ML20154F504 (87) | |
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g NUCLEAR REGULATORY COMMISSION
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February 5,1988 o.<*
MEMORANDUM FOR:
L. B. "Tad" Marsh, Chief Mechnical Engineering Branch FROM:
Jose A. Calvo. Director Project Directorate - IV Division of Reactor Projects - 111.
IV. V and Speu al Projects
SUBJECT:
REQUEST FOR ASSISTANCE TO THE SOUTH TEXAS SSAT The Safety Significance Assessrrent Team (SSAT) has been following up on technical inforrration mace available by allegers through the Government Accountability Proacet (GAP). Some of the questions raised by this information requires technical judgements that can be made raore appropriately by your branch. This memorandur.1 is to request assistance from one or more members of your branch to help in making the necessary technical Judgements.
The questions are related to the adequacy of methods to resolve non-confortr.ance reports related to cottponents such as the steam generator, the reactor vessel, the reactor coolant pumps. and etc. being out of plumb (verticality). The SSAT will do whatever is required to facilitate a rapid decision raaking process.
Sincerely.
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Jose A. Calvo. Director Project Directorate - IV Division of Reactor Projects - 111.
IV. Y and Special Projects cc:
D. M. Crutchfield L. Shao J. Richardson gg j
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This report provides the results of a review by the Safety Significance Assessment Team (SSATI of the Nuclear Regulatory Comission (NRC) of alleged construction irregularities at Houston Lighting and Power's South Texas Pro.iect (STP), Unit 1 and ? IDocket Nos. FO-498, 50-499), located in Matagorda Ccunty, Texas. These allegations were provided to the NRC by the Government Account-ability Project (GAP) which received them from approximatelv 36 current and former employees of STP, and covered a wide range of concerns with hardware and quality assurance and control, and issues of management, harassment and intimi-dation and wrongdoing. Only those concerns considered by the S$AT to be technically-oriented and safety-related were selected for review based on their possible safety significance, generic implications, specificiyy to a particular plant component, system or structure, and to provide a multidiscipline overview of the STP Ouality Assurance Program implementation and eff etiveness.
The SSAT was not able to identify any technical concern hat may have required holding up ongoing operations-or construction-related activities at the STP
- facility, i
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I CONTENTS l
i Page
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ABSTRACT..........................................................
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SAFETY $1GNIFICANCE ASSESSMENT TEAM (SSAT)........................
v 1.
INTRC0ilCTION AND BACKGROUND..................................
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2.
REVIEW APPROACH AND METHODOLOGY.....,........................
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2.1 Governrent Accountability Project's (GAP)
Allegations File......................................
2.0 Screening and Categorization of Allegations.........,'...
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?.3 Compil a ti on o f Allega tion Ca ta.................... [....
{
2.4 Selection of Allegations fcr Site Inspection...../.....
2.5 I n s pe c t i o n F 16 n........................................
I 2.6 Interviews with A11egers................................
?.7 Communications with Houston Lighting l
andPower(HLAP).....................................
j 3.
S tPMA R Y O F A S S E SSMENT.......................................
3.1 I n s pe c t i o n F i n d i n g s....................................
I 3.1.1 Allega tions Ins pected........................
3.1.2 Ralance of Allegations....
3.2 Overall Review Ef fort..............
3.3 Overall Assessment and Conclusions 4
ACTIONS REQUIRED OF HL&P....................................
S.
REVI EWS O F ALLEGATION CATEGORI ES./..........................
5.1 Piping and Pechanical Compor.ents........................
5.2 Valves..................................................
5.3 Heating Ventilation and Air Conditioning (HVAC)........
i Page l
5.4 Fasteners..............................................
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5.5 Welding................................................
5.6 Electrical Cable, Conduit and Instrumentation...........
i 5.7 Concrete and Scils.....................................
5.8 Coatings...............................................
f 5.9 Ouality Assurance /Ouality Control......................
5.10 Polar Crane and Orbital Bridge.........................
5.11 Non Sai'e ty-Pel a ted Corce rn s............................
APPENDICES i
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I APPENDIX A ABBREVIATIONS APPF.NDIX B S$4T INSPEC710N PLANS Appendix C SSAT PLANT WALKDOWN WITH ALLEGER OBSEFVATIONS TABLES I
FIGURES EXHIBITS l
1 i
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SAFETY SIGNIFICANCE ASSESSPEFT TEAM (SSAT)
The SSAT consisted of thirteen rerbers of the NRC staff who, collectively, reprasant NO years of engireering and scientific experience, of which 245 years were in the nuclear field in mechanical, electrical, instrumenta-tien, civil, structural and metallurgical engineering, quality assurar.ce and control, inspection, censtructico, operations, prcject management and regula-tory activities.
p The SSAT members that conducted the STP onsite inspection cf alleged deficiencies during the week of January 18-22, 1988 were e sare individuals /that perfortned the iritial screening of GAP's allegation. ThhsWnspecticr. ado involved NRC p
Region IV and resident inspector personnel who provided back rourd irfortnation related to previous inspection ac+ivities and substantiva opport to the SSAT.
Also, the SSAT sought the assistance of the mechanical engineering branch and material engineering branch of HRC's Office of Nuclear Reactor Regulation I
(NRR) te confirm the adecuacy of Pralysis pertaining to the installation of Nuclear Steam Supply System (NSSS) components. Adfitionalassistarcewas provided by various NRC offices ir matters related to congressicnal and putlic affairs,allegationmaragement,allegersinter[ews,investigatiers,ardlegal, editing, administrative, word processing and lephone conference services support. Moreover, the Heritage Reporting /C'orporatict provided assistance to l
SSAT in recordirg and trenscribing teleph e conversation with the allegers.
l f ort r sted b 1 1
l NRC SSAT Name Functiio Area J. Calvo Tean Director P. O'Connor Project Manager Project / Allegation Compilation & Trackinn R. Correia Team Leader Technical Overall
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NRC SSAT (continued)
Name Function Area J. Durr Advisor to Team Leader W. Johnson Inspector Region IV Liason E. Tomlinson Deputv Team Leader A Allegers Interview Arragements/HVAC G. Johnson Reviewer / Inspector Welding K. Naidu Reviewer / Inspector Electrical and Instrumentation M. Oliveri Inspector Non-Destructive Examination P. Milano Deputy Team Leader B OA/0C P. Prescott Reviewer / Inspector Piping & Vechanical Components A. Lee Reviewer / Inspector hes R. Lipinski Reviewer / Inspector C,il/ Structural J. Rajan*
Reviewer Piping & Mechanical Components H. Ashar*
Reviewer Civil / Structural
- Reviewers participation was limited to the initial review of the allegations at GAP's offices NRC Region IV and Resident In,spectors Personnel Involved Name Function Area L. Constable Support Inspection i
D. Garrison Support Inspection D. Carpenter Support Inspection C. Johnson Support Inspection NRC Region IV and Resident Inspectors Personnel Involved (continued)
Nana Fu,nction Area W. McNeil Support Incpaction E. Hildebrand Support Irr.pect on J. Bess Support Inspe tior OTHER NRC STAFF Name Function Area L. B. Marsh Advisor Mechanical P. T. Kuo Advisor Mechanical S. Peu Advisor Mechanical C. Y. Cherg Advisor Paterials
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K. Wichman Adviser Materials D. Murphy Addsor Investigaticr.s M
A1 W
- c :;ccant Public Af41rs 4 Q___
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Supgrt Fubiic Affairs A. Vietti-Cook Advisor A11egers Interviews
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Curgr = fenal ^##eits N. P. Kadambi.
Supp t Prnject Management P. Noonan Sup ort Administrative S. Ramsey S pport Admirittrative ricp erc Cw 4 - ce g Rennke -
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Co,ntractors -
eporti orporation Name Function Area
- l. A Support aer Conversation i
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All ers Cor. vers on ecording e
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INTRODUCTION AND BACKGROUND in January 1987, the Government Acccuntability Fro.iect / GAP) informed the PTC that they had begun an investigaticn into allegations concerning the safety cf the Scuth Texas Project (STP).
GAP received these safety allegations from approximately 36 current and fonner employees of STF. GAP infonred the NRC that upcn completion of the investigation a public report would be issued. GAP advised the NPC that unless it was willing tc estabilsh an indigerdent team
/
tc pocess the allegations, GAP would turn over the allegat)ons to the State Attorney General's office, corgressional ccm ittees, and Other regulatory and
/
mur.icipal bcdies.
Correspondence followed between the NPC Executive Dipctor of Operations (E00) and GAP regarding managen.ent of the allegatiers, pfterrepeatedrequestsfor the infonnation, the EDO issued a subpoena requesping GAP's attorney, Billie P. -
Garde, tc testify and produce dccuments regarding the STP allegations. On May
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22, 1987, attorneys for GAP and the NRC entere into an agreement.
CAP agreed to move tc quash the subpoena by May ?9, 1987 arguing that compliarce with the subpcena would compromise the public health nd safety, the E00 has no authority to issue the subpoena, and the attorney-ci ent privilege and work oroduct dcctrine preclude divulgement of the inf mation requested.
The NRC agreed to continue the appearance date for the subpoena from Pay 26, 1987, until 14 cays after the decision / on the motion to quash, unless the parties agreed on an earlier date.
he NPC disagreed with GAP's reasoning to quash the subpoena arguing that t failure of the NRC to obtain the allecations would mere likely ccmpromise the public health and safety, particularly if the i
allegations were substantiated.
I TheU.S.DistrictCourtrulfenOctober 27, 1987 to deny enforcement of the NPC's subpoena because of the possibility of "abridgement of constitutionally protected associational rights."
In addition, the court stated that, "Alter-natives minimizing the intrusion on associational rights must be carefully and conscientiously explored before resort may be had to the court's process."
Subsequently, an agreement was reached between the EDO and GAP on the main elements of a process that would provide the NRC staff limited access to infortnation which might be of relevance in the forthcoming licensing decisions
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _. ~
regarding STP. On November If, 1987, a neeting was held in the ED0 offices in Fethesda, Maryland with !!RC r'eff and GAP representatives. The NRC technical staff reviewers present were penritted to ser brief sumaries of the allegations in the possess 4cr of GAP.
During the mcrtirg, the NPC technical staff attempted to essess the safety significance of tFr allegations. Powever, the infomation made available to the techriical steff was lacking in specificity and no con-clur.icrs en safety significance could be reached.
Ir order fer the hRC technical steff to gain accesr, tc rore detailed infomatior,, arrangements were agreed p
upon for the NRC technical staff to review records pcrtaining to the allegatiere.
p 7.t CAP's offices in Washingter, D. C.
Includedintheagree7t.rtwasthatthe protercl for the NRC staff's work at U.Ps offices was to protect, to GAP's satisfaction, the idertity of the allecers.
2.0 REVIEW APPROACH AND PETHODOLOGY 2.1 Government Accountability Project's (GAP) All gation Files Ar f;RC team was assembled, referred herei fter as SSAT (Safety Significarce Assessment Team) to review AP records of the interviews with the allegers (referred by GAP as neerred individuals - CI) and individual allegatiers that GAP enure ated from the interviews.
The SSAT completed its review of t,e infomation made available by GAP in December 1987. This infonnation onsisted of audio tapes of some of the interviews conducted by a GAP c nsultant with the allegers, the consultant's hand-written text extrapolated frcr the interview tapes acccrpanied with supporting infomation, and legation data compilations which included a brief description of the co cern.
GAP's initial categoriza on of the allegations listed duplicate corcerns under different review isciplires. Because of this, the SSAT initially had to consider appro inately 700 allegatiers. When these duplicaticos were reconciled, there were 570 individually enumerated allegations. Of these 576, approxinately 160 allegations were variations cf the initial allegation and merely restated some additional facets nf the original
i allegation suel as possible docur.entatior. prcblems, inspectier ccreerns or intimidatien and harassment related to cr caused by the initial ellegation.
GAP categorized the allegations into the followirt sections: safety-related, intimidatier and harer<nent, wrong deirg, and rer t.afety-ralated with 26 discipline subsets and four suh-discipline categories. Teble 2.1 presents tFc categorization and designation of allegatiore used by GAP.
The GAP censultant's hardwritten text was assembled ir rurbered files which certained referenen raterials related to the allecations. There were apprcximately 20 files with varying quantitier e text and refercrce data and two separate files containing 576 individu allegation data sheets. As agreed, at the completion of the revi
, all the records exanined by SSAT remained at GAP's headquarters nd the identity of the ellegers represented by U P was kept confident al by SSAT.
2.2 Screening and Categorization of A11egatiens The initial screening was perforred by S AT members who have comprehensive knowledge in particular areas related c the alleged concerns; rechanical electrical, instrurertatior, civil, s ructural and metallurgical engineering, cuality essurance and control, ruel r plant construction end operations and the NRC inspectier program. T ese technical disciplines were supple-mented by cther staff members exp.rienced in project management and engineering to axtract the safe -related cercerns from the harastrert ard intimidation, wrong doing, ard anagement issuer.
SSAT nembers reviewed each a legation, its associated interview text and reference material file in heir crea of expertise. Screening also included listening to all er interview audio tapes to verify the accuracy j
s of the written text GAP's consultant had extrapolated from them.
Generally, the SSAT's initial tereening determined that a large majority of the allegations lacked specificity in identifying a particular corpenent, system or location about which the alleger was concerned. To assure that all aspects of GAP identified allegations were reviewed and evaluated, the 1
4 SSAT forwarded to the NRC's Office of Investigatior, all allegations that they reviewed which were categorized as harassr>ent and intimidation or wror.g doing.
2.3 Compilation of Allegation Data The results of the SSAT review and initial screening were docurerted and identified by GAP allegation number.
Examination o the concerns conveyed by the allegations by SSAT showed that the ccnon characteristics perrritteo grouping and prioritization. The grouping proc 7ts would enable efficient use of SSAT resources to conduct physical insp,ections, and the priorizaticn process would etable assessrents of wider im lications such as determination o' root causes and generic implications as ell as probing for evidence of-cuality assurance breakdown. Therefore, c,AT assembled the concerns cerveyed by the allegations into groups ith cernron characteristics. The SSAT's generated information was entere into a corrputerized data base and each GAP allegation was assigned to o of the following allegation catagories: Pechanical and Piping; ' ectrical, Civil / Structural; Ouality Assurance and Control (QA/QC); Hara sment and Intimidation; Wrong Doing; NPC and Management issues. Each. tegory had several subsets that were used to specify more closely, is es that each allegation appeared to be addressing. Table 2-2 presents SSAT allegation groups.
2.4 Selection of Allegations for ite Inspection From approximately 700 ori inal allegations found in GAP's files, the SSAT sorted them out to de#1ete repeated allegations and those considered to be r.on safety-relate !and harassment and intimidation and wrongdoing.
As indicated from the esults of this sort presented below, the SSAT determined that out of the 700 original GAP's allegations, approxiriately enly 2?6 remained as possible candidates for onsite inspection at STP.
These 226 allegations were considered by SSAT to be technically-oriented and possibly safety-related.
SSAT classified approxire.tely 250 GAP's allegetiens as harassment and intiriidation and wrongdoir.g erd they were referred to NRC's Office of Irvestigations by the SSAT for their review.
Approximately 100 of the CAP's allegations were fourd by the SSAT not to be of rignificant safety concern. These were generally ellegations related to the cost of the ccrstructier effort, industrial safety, perte.rnel practices er managerert activities. These non safety.related allegations are considered riosed and there is no reed for further review.
GAP's original allegations
........ 700 Repeated allegation Identification Numbers............. 12A 584 Harassment and Intimidation, and wrongdoing allegations ider.tified by GAP and SSAT
..... 234 350 Non safety-related allegaticrs identified by GAP ard SSAT
........ 138 212 Available allegations j
for ensite int.pection selection
............................... 212 This sort also identifiad that t of the 576 allegations enumerated by GAP, only 16 could be sited tog specific locaticr system or component.
The remaining 560 allegations / referred only in general tems to items of G
Itshouldbenote/that the ellegers h not yet been
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concern.
interviewed by SSAT at thi time +o obtain specific infomatier in support of their allegati ns. However, as indicated in Section 2.6, the additional ir. formation ovided by the allegers via telephona conversatiort. te SSAT continued to be deficient on specifics with a few exceptiens.
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6-Notwithstanding the lack cf specificity, the SSAT Q erfonn ed
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an ensite inspection so a determinaticn ceuld be made concerning the safety significance of the allegations.
From the 276 allegations, the SSAT selectea for onsite inspection at the STP facility, 10 primary areas, each identified by a iven allegation (referred hereinafter as the primary allecationl.
n addition to the prirary allegations, 61 additional secondary allec tions were selected which ccnveyed similar ccccerns as the primary a egations.
The 71 allegations selected by SSAT represent approxim tely 317 of the total nurrber of allegations that the SSAT considered as the only cessible candidates for inspection.
The selected alle ations are representative of the technical concerns conveyed by the al egers represented by GAP, and -
bounded the 226 allegations. The selectio was based on the safety significance, generic implications, speci icity to a particular plant ccrrponent, systerr or structure, and to p ovide a multidiscipline overview of STP's Cuality Assurance Prcgram impi mentation and effectiveness.
Furthennore, the 16 allegations includ ng specific information were included as part of the 71 allegaticr. selected for inspection.
The selected allegations encompass the following areas: Piping and mechanical components; valves; he ting, ventilation and air conditioning (HVAC); fasteners; welding; ele rical cable and instrumentation; civil and structural; coatings; qual y assurance and control; and polar crane and orbital bridge.
2.5 Inspection Plan The SSAT members selected for the onsite inspection were the same individuals that performed the review, evaluation, and screening of the GAP's allegations.
Given the general non-specific nature of the allegations, the use of these experienced reviewers as inspection toam members greatly facilitated the effort.
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In view of the lack of specificity included in many of the selected allegation areas, tb SSAT approach for resoluticn of the allegations censidered a bread, gereric icok at the areas of concern.
Detailed inspection plans were prepared by the SSAT including inspector guidance to assure ccr. sister.Cy in the inspectiC3 process.
The plans included provisions for cerr.oining cther relatec' cr unrelped issues with
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the selected GAP allegstiens in the event that was tiee#d to ensure that the substance of the allegations did not reveal the [entifyofthose
-6 allegers that would be requesting confidentiality. The plans focused on
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Unit 1 of STP except for a few cases when the a egations also reade y
specific reference to construction irregularit es in Unit 2.
The SSAT p
inspection plans are included in Appendix R.
In addition to followirg the inspection an the SSAT revieweo other sources of infonration such as NRC Regfon IV inspection raports pertaining to the resolution of South Texas Pro tct facility allegations; NRR inspec-tions data and safety evaluation r orts; HL&P's SAFETEAM records, and other docurrentation to determine hether they provide any additional infonration related to an alle r's concern.
The SSAT ccnducted the ens e inspection during the week of January 18-??.,
1988. Also it involved gion IV and resident inspector personnel who provided background inf nnation related to previous inspection activities.
During the site insp tion, the SSAT inspected those areas related to the selected 71 allega[ons and focused their efforts on the safety-significance
]
of the technical c'oncerns in those areas.
2.6 Interviews with Allegers Pecause of the gereral lack of specificity and detail included in GAP's allegation files, the SSAT rr.ade arrangements with GAP to conduct interviews with the allegers so specific information could be obtained for the allegatiens selected for inspection. The SSAT provided for GAP the selected allegations to allow GAP to identify and contact the appropriate allegers for interviews. GAP identified 19 allegers involved with the selected allegaticns, however, only 10 allegers could be reached.
According to GAP, these allegers were the cr4s who have the most significant concerns. They were interviewed via telephone by the SSfT with GAP included to provide guidance to the allegers and conversatiers were transcribed. Alsc, SSAT ccnoucted face to face interviews with twc cf the 10 allegers previcusly interviewed by telephcre witho t GAP teing irvolved and conversatiens were not recorded. The intervi Ws Were Conducted j
pr' "nd during the ensite inspection at the STP fac ity.
]
CA aed the allegers interviewed not to reveal th ir tity to However,twooftheallegersdidnotfollowpisadvifeandrevealM S.
th ir identities to SSAT. No confidentiality agre ments 'ith the allegers were requested. Only one of the alleger intervi d expressed concern atout its identity being revealed if qu stions were aske P
and its consultants concerning the information provided tc SSAT. The SSAT rade adjustments to the inspection plan o prevent the identity of this alleger from being known.
Although GAP's cooperativeness facilitat the interviews with the allegers, the additicnal inforwation provided to SAT continued to be deficient on specifics with a few exceptions. The imited arount of specificity obtained from these interviews only quired minor adjustments to establisted inspection plans.
2.7 Comunications with Houston Ligh ing and Power (HLAP)
The SSAT conducted an entranc neeting with representatives cf Houston Lighting and Power and their engireering and construction censultants on January 18, 19P8. HL&P int oduced their SSAT counterparts and assured that all of the necessary materials, site accesses and personnel wculd he available for the SSAT. During the inspection, HL&P and its consultants prorptly accomodated the SSAT's requests which greatly facilitated the inspection effort.
Table 2.1 GAP allegation categorization and designation SECTION DISCIPLINE CATEGORY ALLEGATION RELATED ALLEGATIONS I - Safety-Related A-Piping / Mechanical /
- a. Hardware 0001 -9999**
.1,
.7,
.3, atc.
Instrumentation B-Electrical II - Intimidation /
C-Civil / Structural Harrassment D-Heating, Ventilation
- b. Documentation /
and Air Conditioning Drawince.
III - Wrongdoing E-thgineering/ Design
- c. Inspact'on/
i F-Procilrement/ Purchasing Testing IV - Non Safety-Related G-Equipment' Qualification
- d. Other l
H-Fire Protection I-Quality Arsurance/
Quality Control /
N-5/ Systems Completion J-Welding K-Safety /sacurity L-Health Physics M-Seismic & Environmental XAMPLES N-Ceneric (all disciplices) 0- Personnel I A a - Q001= Safety related/Pipino/ hardware P-Maragement specific allegation number Q-Training R-NRC s '
S-Safeteam T-EBASCO I A b - 000I.1 (same), subcet documentation ll-llouston Lighting and Power V-System Complete & Turnover W-Authorized Nuclear Inspection X-Qualification of Personnel Y-Bechtel Z-Document Control
- Allegations numbers are cross-referenced to actual GAP allegation number.
=_
Tabla ?.2 SSAT allecation groups A.
MECHANICAL AN4 PIPING 1.
PIPING A.
Pipe C.
Configuratier B.
Hydro D.
Chloride Contamination 2.
VALVES A.
Limitorque C.
Missiro B.
Installation 2.
MATERIALS A.
Tracaability B.
Cnmpatability 4.
- HEATING, A.
Procurement C.
Fabrication VENTLATION R
Installation D.
Testing AND AIR CONDITIONIFO (HVAC) 5.
SESIMIC QUALIFICATION 6.
FASTENEP.S A.
Cnuntarfeit/ Foreign 7.
WELDING A.
Peld Rod C.
Welder ID B.
Qualificatiers D.
Traceability O.
OTHER B.
ELECTRICAL 1.
SPLICES A.
aychen 2.
CABLE AND CONDUIT 3.
INSTRUMENTATIOP A.
ENVIPONMENTAL QUALIF,J ATION 0.
OTHER C
CIVIL / STRUCTURAL 1.
CONCRETE 2.
SOIt s 3.
COATINGS 0.
OTHER
Table 2.2 (continuad)
D.
00ALITY ASSURANCE /
OVALITY CONTROL QA/0C I.
DESIGN CONTROL E.
PP0CllREMENT 3.
DOCUPENT CONTROL d.
CC INSPECTION A.
Inspection Racords B.
Travellers C.
Hold Point
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D.
Authorized Nuclear Inepector E.
Nnn-Conformance Reports (NCRs) 5.
ASPUILT vs DESIGN 6.
SYSTEM TURNOVEP 7.
FSAR/ SPECIFICATIONS 8.
PROCEDURES 0.
OTHER E.
HARPASSMENT & INTIMIDATION (safety-relat d issues only)
F.
URONG DOING (safety-related issues on14)
G.
NRC H.
,MANAGEMEFT 1.
HOUSTON LIGHTING AND POWER,HL8P) 2.
BECHTEL 3.
EBASCO 4.
INTERMECH 5.
PERSONNEL PRACTICES 6.
TRAINING 7.
SAFETEAM 0.
OTHER 0.
OTHER
.g.
3.
SLTFARY AND CONCLUSIONS 3.1 Inspection Findings The SSAT fcund that several of the allegations selected for nspection j
at the STF facility were substantiated at sone peint in th construction history. Evidence of this was apparent froni the docunent tion of engineering, inspection and special revins within those areas exami ed by the SSAT.
Pcwever, the SSAT found that STP's Cuality Assurance P ogran. implener.ta-tion was successful in identifying the concerns and pplying appropriate corrective actions.
The SSAT determined as a result of their inspec ion efforts, including 1
l interviews conducted with available allegers, hat the allegations examined 1
could be placed in the following categories:
1 Tctal j
Allegations Substantiated Deficiency corrected by blLP 11 Deficiency evaluated and etermined to be acceptatlt i
"as-is" by PL&P DeficiencyJourWe non safety-related by SSAT 5
ggg iciencyfoundbyS$A 3C 4
Allegations Unsubstant ted No deficiencies ound by SSAT P1 Lack of specif ity, and generic review of area of 29 concern perfor;ned by SSAT found no problems Total number cf allegations for selected onsite inspections 71 Table 3.'1 of this report gives examples of the type of allegations in each of the above categories.
2.1.1 Allegations Inspected The characterizaticr. cf the h allegations selected fo inspection at the STP facility are presented in Table 3.2, and cludes a brief sumary c# the statenents obtaimd ty SSAT from GAP s files, as augnented by inforn;ation obtained by SSAT fron. th alleger interviews.
Also, this table shcws other characteristics per, aining to the area of concern that were inspected by SSAT, and the! number of duplicated and other related allegations per category w ch have been closed as a result of SSAT inspection conducted at STP site.
3.1.?
Palance of Allegations As a result of the broad, generic and rogrammatic lock given to the areas of concern by the SSAT to comp sate for the lack of specificity conveyed by the allegat ons, many other hardware ard 0A/QC related characteristics were inspected by SSAT. These are discussed through Section 5.1 o his report.
As scon as the inspection resuits of the selected allegations became j
available, the SSAT examined the remaining allegations to detennine which ones needed further cpnsideration, or have been satisfactorily resolved based on the find,ings of the inspection.
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Some of the remaining ailegations were dispositioned by SSAT because j
they were found to be/ duplicate to the allegations selected for inspection. Other remaining related allegations were dispositioned because the concerns were enveloped by the SSAT inspection. Table 3.2 identifies the other characteristics inspected by SSAT, as well as the number of duplicate and related allegations.
i Many of the remairirp duplicate allegatioris ircluded concerns raised by the allegers that tha deficiency conveyed by the prirary GAP allrgetien was alsc r.ot ade n. a cr. c.cn-conicrrarce reportr. These issues were addressed ty the SSAT where encugh specificity was pecviueu Lt te the system, corrponent or structure that Fed the 7.11eged deficiency. The SSAT determined that ma i isst!rs reviewed did not have non-conformance. reportn gererated or the foilevirg reasons:
the problem or deficiency was noted uring in-process construction activitiet vban final quality nspectior.s vere not yet called for; the iter was being modified or changed as required by er.gineering and described on a field cht.r_e document and; the item was non-safety related for vFich non-co formance reports are ret written, and if the item was found te e deficient, it was addressed or engineering field change decuncnt. and/or inspection reports.
As part of this examination, tba AT used NRC Fegicn IV inspectior -
reports and HJ.&P's SAFETEAM irve tigation reports that were deterinired $hvide additior.-
insight concerning the allrtaticos under rev9 wb SHAT. These eports worr evaluated by SSAT and found tha",a res ed certr.ir identical allegations that they were currently b pursued by SAT.
It was detenr.ined that those ellecationsofinteresttySSATwereappropriatelydispositiortdir these reperts. The cor.ttr.ts of these reterts after being evaluated bySSATwereusedtosy[pertSSATfirdirgsardprovidedthe i
basis for disposition 'rg some of the balance of allegations where applicable.
The SSAT's resu s of this examination are presented below.
Available allegations for onsite inspection selection
.......... 212 Allegations selected for inspection
.............................,71 141 4
l ( Frm p revi ou s pc se )............................. 141 Balance of Allegations Puplicate....................
71 Pelated......................
4_5 Sub Total......
............. 116 116 Total Prreining A11Egatiers.......................
30 Of the 212 allegations identified in Section '2.0 as possible candidates for inspection, 71 warr. inspected at the site and 110 were dispositicr#
for it.e raasons given above. The rcrainirp 30 allegatiers lack s cificity to detemine whett.or they can be enveloped by the review perfomed by SSAT. However, SSAT cnnsiders these allegations of lesser irportance and hava no irrediate safety significance. The SSAT considers them closed tr.til such a time that specific inferration will justify furthae NRC review.
3.2 Overall Review Effort it.c FSAT cnnsisted cf thirteen members of the NPC staff. They perfomed tFr iritial screening of allegatiers at GAP's offices in Washington, D.C.,
and conducted the onsite fespection of calected allegations at STP. This inspection also irvolved NRC Regior IV and resider.t inspector personnel who provided background infomation related to previous inspection activities and substantive support to the SSAT.
A 6
6 Also, the SSAT was assisted by the inechanicel engineering branch and bterial kngineering Yranch of NRC's Office of Fuclear Reactor kegulation (NRR) to confim the adequacy of ane. lysis pertaining to the inste11ation of NSSS components. Additional assistance was provided by various NRC g
I.Q officet ir rattars related to congveraieral and public affairs, allegation reregement, conducting allegers interviews and investigatiene, &
crd legal, administrative, editing, werc prccessing erd telephore
~
conference services support. Mcreover, ce ractor personnel provided support in reccrdir.g ano transcribing
.AT's telephone conversations with the allegers.
Since Ncvember 19,1CP7 when the initial assessnent of the GAP's allegations corcencec until February 29, 1988, approximately 3,335 ERC staff and certractor bcuts were spent in the review of these allecations A
breakdcwn of these hcurs is as follcws:
Sta.f/Cor or
}Murs NRC SSAT GAP's Headquarters Files Review............
...... 900-TP Site Inspection (1/18-2?/88)........
...... 1,010
- E aluation of Balance of Allegations
.d Prepa ra ti on of Report.................... 1,000-Other NR NRR Staff................
.................... 100-NRC Region IV..................
....................... 300-Reporting Co tractor.......
........................... 75-Total Staff / Con ract Hours.......
.................. 3,335-
- It includes 400 hou of ov time 3.3 Overall Assessment and Conc 1 icr An essential part of the SSAT' inspection effort besides detemining the safety significance of a technical issues examined, was also to focus en the QA aspects of ach area examined. Table 3.3 shows the 10 CFR Part 50 Appendix B Cua ity Assurance Criteria that were evaluated in the allegation areas revi by SSAT. This focus was to detemine if the QA prograin at STF was effective in identifying, solving, correcting and satisfactorily closing safety significant, technical issues as well as
-la-those cf programatic concerns. The SSAT also measured the effectiveness of the assurance of quality in the res nsible line organizations for each area ard issue examined. This was done because quality organizations are responsible to see that line organization programs are in place and are being implerented. This is acconplished through a system of audits and surveillarces. When prcblems are identified in a line organization, it is Quality Assurance's responsibility to see that effective corrective acticns are implerented and that the resolution of the identified deficien-cies are correcting itie prctlem not,iust the syn toms of the problem.
The SSAT deternir.ed that the Quality Assuranc (QA) and line organizations involved with the issues examined during th inspection have effectively assured that QA programs at all levels of iplementation are in place and
that any problems which arise are correc d satisfactorily.
Except for a very few isclated instances, the SSAT d ermined that the engineering, construction, administrative and manag rial organizations at STP have been effective in assuring that deficienci s are identified, selved and corrected to preclude repetition.
The SSAT also determined that in.any instances, the allegers concerns dic exist at one tire during con truction activities at STP. However, many of these allegations appe to have been made without the knowledge of the procedures for assurin quality that have been in place during constructionandarecontinufngtoday.
4 ACTIONS REQUIRED BY HL&P
[
4.1 Raychem splices As a result of the SS T inspection in the electrical and instrumentation area of concern, one deficiency was identified by the SSAT: A Raychem cable splice was f nd in Unit 1 that had not been reinspected for proper installation as required as part of an earlier reinspection program at
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Table 3.2 Characterization of allegations selected for onsite inspectior.
and dispositir,n of balance of allegations gA pefated o
9 thee' Category Selected Characterization of Duplicated Characteristics Allegations No.
Area Allegations Allegations Allegations Inspected Closed 1
Piping and 9
Pipe Joints not properly 3
Design Control 1
Mechanical installed; pipe to tank Cceponents connections inadequate; filter screens in NSSS loop daraged during testing; valves and purps y
are inaccessible for maintrrarce and operat ier.;
stear generetcr installed cut-of-plumb; aluminum bronze pipe contains micro-organisms that are T
i detrimental to the equip-rent in the systeme.;
(
questionable ASME N-5 documents wher a pipe
'g whip restraint was deleted from drawin 2
Valves 4
20" of valves y e installed 5
Design Control I
backwards; J60 t.imitorque Valve Installation 2
valves vpre not properly Valve Paintenance 1
maintaihed; valves were inytflied out of location; remote valve extensfers were interfering with conduit and pipe supports.
3 ilVAC 10 HVAC welds were rot cleaned 5
HVAC Irstc11ation 1
prior to painting; HVAC Design Control 1
ductwork and supports not CC IIold Points 1
1 1rstalled per specifica
- IIVAC 1-aleriretion 7
tions; material sicler from HVAC comparients and
Table 3.2 (contirurd) Other Related Category Selected Characterization of Duplicated Charactcristics Allegations No.
Area Allegations Allegations Allegations Inspected Closed reused elserbere; HVAC installed ton close to other eeuipment -- seismic tolerances violated; caulking used to seal ductwork not adequate; HVAC welds not in accer-dance with specificatiens; Unit 1 HVAC darper never tested -- similar item in Unit E requireo replace-ment; wrong size angle iron used in HVAC supports; liVAC ductwork signed-off as complete when it was o 4
Fasteners 11 Concrete anchor bo. ret 6
reunterfeit fasterers 1
installed per dure; fastener Testing I
fasteners fry questionable Fastencr Paterial 1
U.S. compames and fcreign Certification countr ef used in plant; fas ers in plant do not
_t specifications; 5
Welding 9,'
Weld rod traceability 3
Vciding Procest 4
lost; faulty weld rod 0A Welding Program 1
used all over; welders Weld Decurentation 1
not certified; welds do not have welder's I.D.;
welds I.D.'s falsified.
e e
I
Tchle 3.2 (continued) Other Related Cctegory Selected Characterization of Duplicated Characteristics Allegatiert.
No.
Area Allegations Allegations Allegations Inspected Closed 6
Electrical ord 9
Raychem cable splices 9
Instrumentatice do not meet safety stanrv dards; noncoeformancegf reports not writtrn for improperly installe 2
cable splices; cable
.l pulled using a core-a-long; flex conduit not in-stalled per requirements; weld splatter found on ir. core instrumentation guide tubes; addition radiation protection required for LWPS pan reactor reclant in ment lines shoul have 2 valves inst d of 1; flow transmi ters re-moved aft final inspec ons.
7 Civil / Structural 4
R ars drilled through; 4
rack tr. basemat of fuel Handling Building; improper backfill used; backfill did not pass tests.
/
8 Coatings 1
Coatings on orbital bridge 7
Inspector Certification 1
flaking ar.d chipping.
Coating Procedurcs 4
Surface Preparatico 1
Coating Integrity 1
9 Quality IP ASNE N-5 reports invalid; fa CA Record Traceability
?
Assurance /
inadecuate engineering Material Compatability 1
Ouality and design; as-built System lurnover 1
Control
Table 3.2 (continued) Other Related Cctegory Selected Characterization of Duplicated Characteristics A11egaticns No.
Area Allegations Allegations Allegations Inspected Closed items do not agree with Loit Torque procedures 1
as-designed configurations; CC Inspection Records 3
inadequate field document Transiticr Plan I
control.
Docurert Cdntrol I
Recje ' pt' Inspectior.
2
,IMependent Verification 1
Contractor Oversight 1
10 Polar Crane and 2
Polar Crane and Orbital 1
Orbital Bridge Bridge have deficiencies that have not been cor-rected.
11 Non Safety-Related ?
H*iAC diffeser plate 3
OA Conflict of Interest I
was modified for Unit cimilar item in Uni was not modified-cleanliness bar er violations; rker confidentia ity Tctals 71 71 45
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iable 3.3 QA criteria evalu3 tion in ollegaticn areas t
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y y
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y y
y y
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'S Y
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Y Y
Y Y
Y Y
Y Y
Y 'Y HVAC
'Y Y
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Fasteners
!Y Y
Y Y
Y Y
Y Y
Y Y
Yj Y t
Welding Y
Y Y
Y Y
Y Y
Y Y
Y Y
Electrical &
i Instrumentation Y
Y Y
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Y Y
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Civil / Structural y
y y
y y
y y
y y
y y*
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Coating Y
Y Y
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Y Y
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Y Y
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f}A/QC Y
Y Y
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Polar Crane and
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Y Y:
y y
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Non-Sa fety Related 1,Y Y
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PL&P on its ein initiative perforned a generic e>6niination of Raychem splices in both Units 1 & T tc verify that prchlems siniilar to the un-reinspected Raychem splice ir. electrical penetration EPA-19 do nct exist in the plart.
HL&F has inforned SSAT that it has re-examined records perta cirs tc the Paycheni reinspection program. To date, February 16, 1988, LAP has
/
identified th.t cr,e cther Raycherr splice in a Unit I reafter containment electrical penetraticr. and six Raychem splices not in containment penetra-tiens have reinspection decorrentation that is inadequa/te or missir.g. As a result, HL&P advised SSAT that they will conduct a,100% review of all Raychem splice reinspection cocunentation ard will physically reinspect any splices shown to have inadequate docurrentation.
The SSAT has reviewed some of the results of the FLAP re-examinations for Ur.it 1 and has concurred with the findings. However, prior to ascension -
frca 5% power for Unit I and fuel loading or Unit ?, HL&P shall cceplete all the exan:inations concerning Raychem lices and corrective actions that were necessary.
a.2 Nuclear Steam Supply System (NSSS) Components The SSAT sought the assistance of the NRC NRR technical staff to further confim the acceptability cf PL P's analyses for justifying out-of-pluth
~
(verticality) tolerances of r4cr NS$$ components in Unit 1,,
The C
staff has ret with HL&P and ts consultants and concluded that the ar yses had satisfactorily resolve the concerns. Powever, prior to ascension from 5% power for Unit i HL&F shall sutait a repo NRC documenting the results of the ana sis.
Further review by N@CM staff, if required, will be docurented in 'a separate SER.
j
5.
REVIEWS OF ALLEGATI0h CATEGOPIES
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E.1 Piping and Mechanical Components E.1.1 Thrust Restraints fcr Ruried Mechanical Jcirt Pipec 5.1.1.1 Characterizatine cf Allegation
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It is alleged that urvarground yard composite riping made from ductile iror and utilizing methanical joints had been burie (prior to November 1984) without the required anchorage supporte uch as tia code and thrust blocks. An interview with the alleger re ealed that approximately six systems were involved, notably t e essential ecoling water system (ECW) which provides cooling for afety-related components during noma 1 plant operations, after a 1 s of cooling accident (l.CCA), a loss of offsite power (LOOP) eve
, as well as all other desigr basis events.
5.1.1.?
Details The SSAT reviewod all inferwation presanted wi h the allegation and the voeurertation provided by HL&P during the inspection. The<e included such items as potential change noti es (PCN), engineering correspondence, American National Standards Institute /American Water Works Association (ANSI /AWWA) etandards, p pe specificatinrs, twenty-four composite piping drawirgs, pipine ar instrumentation diagrams (P&ID),ccstestimatesforpipingexcay ion and a list of all mechanical joint pipe installed by Brown and Root (BLR) and Ebasco as of November 1984.
The SSAT reviewed three intereffice memorandums (IDH) written by various site civil / structural engineers and project engineers concerning this issue.
In ION No.31168, dated November 15, 1984, it was stated that, when the South Texas Project was being designed and constructed by Brown & Root (B&R), design of buried mebanical joint pressure pipe was the respersibility of the B&R Piping Group. However, when
_N Pechtel took over design responsibility for the project, the respon-sibility was assumed by the STP Plant Design Group. Durine a field visit in March 1984, SiW Civil / Structural personnel noted that mechanical joint pipe wee being buried without restraint devicas hecause it was later recognized that restraint devices were not recuired by tFe Plant design drawinne or any specification. The IOM also stated that mark-up drawingt erd several design decurant packages related to the mechanical joint pressure piping were evailable.
These drawings and design documents showed which pipe was ins +all.d by B&R, and which pipe wat installed by Ebasce prior to Septerb, r 1984 A review of the destgr documents and any recormrdatic s to avoid the excavatien of pipe was requested in the IOM.
In respense to IOM No. 31168. IOM No. 33293 dated Noverb 20, 1984, stated that a review was performad for the submitted d urents and it was concluded that thrust restraints rust be provided on the installed pipas. The reasoning was that there is no mechanice. mechanism to resist the longitudinal thrust forces and thus, wi heut restraints. ]
the joint ray easily come apart under internal p essure c uncertrelledleakagQndessectatedconsequen owever, the IOM also stated that accordirg to procedure, the nstalled pipes should have been hydrotested before backfilling to k place and that temporary restraints should have been provided duri g te tirg. The memo also stated that often times such temporary straints ere not removed by the cont-actor and possibly B&R and/o Ebasco may have left ther in place. Documentation that such res+ aints exist, if aveilable, could avoid excavatien and installation.f rettraints.
On March 15, 1985, IOM No. 341 1 was issued stati m that cerceptual
/
designs were developed for t e buried thrust restreints at bends nf underground pressure pipes ith mechanical jeirts. A list of the bends wPs prepared from tha 24 marked-up plant design drawirgs and a recomended type of restraint was called out for each bend. There was also an attached cost estimate developed from the conceptual i
designs. Potential change rotice (PCN) addressing the engineering
- corcerns "and corstruction ecsts for the pipe restraints described in the IOMs was initiated on March 17, 1985. Attached to the PCN was a list of all mechanical joint pipe installed by B&R and Ebasco as cf November 1984 which included six piping ryttems. The systems and pipe Sizes involved were as follows
6" essential cccling water system (EW), 6" essential cooling pond make-up (EP), 8" #resh water supply (SW), 8"&6" well water (WW), 4"83" potable water (PW) ard 8"&4" service water supply (TW).
The SSAT reviewad the PCN issued on fierch 12, 1985 to d ernine what actions were taken by PL&P for the excavation and modi ication of the buried pipe. The SSAT was aise provided with IOM No. 38180 indicating that a design charge approvel review board (DCAR Bo d)netonJuly P M85 and iejected the PCN. The DCAR Peard conc uded that leakage ipes buried without rertraints would not re uit ir snrious consequences such as damage to safety-related sy tems, components or-structures.
In lieu of the verification and c rective action propcsed in the PCN, the DCAR Poard determine that area surface monitoring would be adequate.
In view of th s decision, a checklist ard Sketch No. C-635 showing the locations f potential leaks were prepared, for utilization of turface monit ring.
Shortly after the DCAR Board decision w s made, some excavations incidentallyexposedseveralmechanicpjointswithtierods.
HL&P deterrined that these joints were ad quate and subsequartly reduced the number of locations to be mont red. Uninspected joint locations remained on the checklist for vis al monitoring during the inspection program. To aid in the monitorAng, the existing soil over these areas was removed and limestere ard crushed rock was put ir placed over them to allcw any leakage which might cccur to rise to the surface at' eve the joint for prompt idertification and location of the problem. The SSAT also verified that plant design drawings for buried pipe were revised by DCNs to require thrust restrairts in future applicatiers.
The SSAT also reviewed the marked-up sketch C-f35, corposite piping checklist, and several excavation backfill *equest and detemined that the ections being taken for the monitoring of potentirl leeks were acceptable.
The SSAT reviewed the corpceite drewings for the affected systers, all DCNs fer pipe installed after September 198d, the PAIDr depicting the complete D! cystan, applicable pipino and excavation spkeifica-tions and a the marked-up rketch C-635.
From this revi w the SSAT datemined that the buried lines without thrust restre rts ware classified as non safety-related. Of note was that, hile the EW Systan is safety-related, the 6" buried line in ou tion was a non safety-related portion and is used fer discha ging intaka ctrainer' backwash to the pond (a non safety-related func on). Seve*al DCNs issued during and after September 1984 against the applicable compos-ite drawings were reviewed ard found to rec,u e the use of tie rods -
and thrust restraints for future installati ns. None of the piping or backfill specifications wc** found to classified as safety-related.
5.1.1.3 Cerclusion The SSAT dotorrired that this alle tien was substantiated ir part.
While it was found that some buri d pipe was insta11ad without thrust restraints, none of tha affecte lines were sefaty-related and adequete action was taken on t s concern.
Potential leakege from these joints was being monito ed and it had been evaluated that possible leakage would not feet safety-related systems, structures or components.
5.1.1.4 Action Pequired None i
5.1.2 Full Fle[ Filter Screen Failuree 5.1.2.1 Characterization of Allegation It is alleged that the Raactor Coolant System (RCS) needs to be inspected after approximately two hundred full flow filter screens disintecrated during hot functional testing of the RCS.
5.1.2.2 Details The SSAT reviewed a detailed Kettinghouse re rt, WCAP-11506, dated Jure 1, 1987, entitled "Full Flow Filter Re vary and Equipment Assessment." The repcrt stated that after comp 1* tion nf hot func-tional testirg at South Texas Project Uni 1, which spanned 28 days under full flow and operating tempc-a'ur s, inspection cf the full-flow fC ters installed on the 1cwer core sup ort plate in the reactor vessel revealed that degradation of 57 of the 192 filters had occurred.
The filters are used during both cold and hot functional testing to help rereve any debris from tha prim ry coelant systen. The Unit i filters had experienced certain deg adations ranging from small tears or holes in the scraen material to the cerplate loss of four filter screens. As a result, the filter debris cireclated throughout the primary coolant system and parts of the attached auxiliery systems durirg testing.
The Westinghouse repnet discu sed the design of the Full Flow Filters, the results of inspections p7tfonned on equipment in the primary coolant and certain auxilia y systems, results of c:etallurgical enminations perfomed on be filters, and the evaluatiens of the effects of the untecnvered filter debric or equipment. Additionally, the report contained e safety evaluation justifying operation of the plant with urrecovered filter debris.
The NRC Office of huclear Reactor Regulation (NRR) had also reviewed this Wastirghouse docurent in their evaluation of this incident. The result? were provided in a Safety Eveluation Report (SER), dated 1
6-
~
October 8,1987, entitled "Full Flow Filter Recovery and Equiprert Assessment." The SER provided the results of the FRR staff's review and evaluation of HLLP's activities to address the effects of filter debris on the equipment exposed during the hot functional ter.t and operability of equipmant with unrecovered filter debris in the reactor conlant and auxiliary systems. The SER concluded that the results of the plant inspection performed by HL&P indicate no evidance of physical damage which would prevent the safe cpe/ration of the plant including the fact thet the plant would no be a'fected even if unrecovered filter dabris remains in the system The NRR staff, ccteluded that the unrecovered filter debris d d not constitute a threat to the safe. operation of South Texas Project, Unit.1.
5.1.2.3 Cerclusion
/
The SSAT deterrined that this allegation as substantiated in pa*t due to the fact that the full flow filt rs did experience som i
degradetion. However, tha nurbar of f iter screens which experienced sore fonn of degradation was 57, not 00 as originally alleged.
Also, the problem had bean fully eva uated by Westinghouse and HL&P.
The NRC Office of Nuclear Reactor R gulatier had reviewed the results of this evaluation and inspections and concurred that the operability of the urit would not be affected The SSAT also concurred with these findings.
5.1.2.4 Action Required l
i None i
1 5.1.3 Pipe To Tank Connections t
5.1.3.1 Characterizatier of Allegation 4
It is alleged that twc-inch pipe nozzles require reinforcements at tank ecrrections. This allegation cercorns the situation where no reirforcements wera penvided zt nozzles whera five two-inch pipes I
were conrected to five separate tanks.
5.1.3.2 Details The SSAT examined all of the above mentioned two-ir h pipe nozzle conrections ir Roons #057, #059, 10598, 8061, and #071 of the Mechanical Auxiliary Building, South Texas Project Unit 1.
The tanks involved were the Waste Evaporator Cordensate Tark, the aurdry/ Hot Shower Tank 1A, the LWPS (Liquid Waste Process Syst.) Monitor Tank 1A, the Floor Drain Tenk 1A, and the Waste Holdup T k 1A. These tanks were listed by HL&P as non safety-related compo ents. The SSAT inspected -
each of the nozzle connecticns and found ach of the lines to be adequately supported and the nozzle con etions appeared to be adequately welded.
The SSAT aise parfonned a detailed r view of HL&P's design calculations for the nozzle cerrections which i luded the specifications describing the technical requirements applic le to the design, fr,brication, inspection, and installation of e tanks. Specification FR019NS0014, Rev. 2, dated April 28, 1987, e titled Specification for Field-Erected i
Stainless Steel Tanks, was app icable tc the Floor Drain Tank 1A while the other tanks were c <ered under Specification 70249NS017-D, Rev. E., dated May 9, 19E3, entitled Specification for Shep Fabricated Atmospheric Tarks.
The SSAT also reviewed the design drawings of the es-built piping configurations as well as their corresponding mathematical exdels used for computer analyses.
For the proposed simple static enalyses, j
the models were founti to be adequate representation of the field 4
i
.t.
~
configurations.
In all tre casas reviewed, the SSAT detertrined that the stresses calculated at the nozzine were well within the ellewables required by the Specifications.
It should be notad that this allegaticr bed been ccvered under two indeperdert invertigations. One by the licenter's SAFETEAM (Concern flo. 11??7), whereas the other by FPC Reginr IV (IR-87-30. Both irvostigations concluded that the nozzle connecticro h d sufficiant strength without reinferrament.
5.1.3.3 Conclusior The SSAT determined that this allegation rega ding lack of reinforce-ments at 2" pipe rezzle connectinns to the t nks was not substantitted.
The strest analysis of the 2" pipet indicat d that the nozzle stresses were well within the allowables.
In addi on, the five tanks which were involved in the allegation ara non fety-rele+ed.
5.1.3.8 Actions Required None 5.1.4 Stear Cererator 5.1.4.1 Characterization of A11egatier It is alleged that stean gare ator (S.G.) No. 1-D was installed out of plurb such that the steam cutlet nozzle is 11 to 13 inches from its required positier. This,would require pipire and support modifi-cations which eculd affect the original load and stress analysis for those cceperants.
5.1.4.2 Details The SSAT requested all infen ation or the steam genera *.cr irsuas in order to detemire if the steam generator was cet installed CorrPCtly.
The SSAT reviewed ?!ceconfomance Report (?!CR) No. RN-00035, dated March 2, 1983, for steam generator-i-D. TheNCRdes[riptionstatad that steer canerator 1-D (or No. 4) had been date nad by optical curvey to be out of plumb approximately 0.157 ire as per feet, er approximately 0.75 dageres. NCR BN-00035 was di positioned "use-as-is" since the existing verticality of stear garcra+ r No. 1-0 (4) had been evaluated as acceptable by Westinghouse stated ir letter No.
ST-WY-YS-00023 dated March 7, 1983. The dis osition also r.tated that the additional quettions raisad by Bechtel rgineering in Letter No.
ST-YS-WY-00030, dated March 14, 1983, were ratisfactorily answered ard supplementation of Westinghouse's ra onal war rade available in Westinghouse letter No. ST-WY-YS-00026 ted March 4, 1983.
The SSAT reviewed Westinghouse Letter o SY-VY-YS-00022 dated March 7,1923, entitled "S.G. #1, #2 f3 and #4 plumbness." The letterstatedthat,basedonrafine7entsurveydatareceivedfrom Bechtel Engineering, Westinghouse ccepted the verticality (plumbnest) of S.G. Nos. 2 and 3 since the pl bness for thaea were within the recorrended tolerance of 0.5 deg!were, marinum.
es However, Westingbnuse indicated that S.G. Nos. I ard outside of the recemanded tolerance and that further revi.w was required for their acceptability.
j i
The SSAT alte reviewed Westin heuse Letter No. SY-WY-YS-00023, dated Farch7,1983, entitled"StepGeneratoriland#4Plurtness".
The letter stated that Westingtruse design engineers have reviewed the refired survey data for S.G. Nos. I and 4 and made an evaluatioa for possible effects on p**formance characteristier, system analysis.
structural and design analysis, seismic aralysis, and piping analysis.
Based er thes*, Westinghouse recr e ended that Bechtel Erpineering accept the presert location of the stear ganerators.
Or Parch 14, 1983 Bechtel Energy Corporation (BEC) intead Letter No. ST-YS-WY-CC030 in resperte to the Westinghousa evaluation. The letter requested furthr.r clarification of several c,uattions that resulted during the BEC review of tht Wastincheuse letter. These questions raired enneerns over the potentie.1 affects on stress ir the S.G. tubes and tutesheet, design assumptiens in the ASME Design Rapor+.. and the level indication components. On March 14,/1983, Westinchouse responded to these items in Letter No. ST-WYuYS-00026 and satisfactorily addressed the BEC concerrs.
In addition to these letters, the SSAT reviewed the W stinghcuse Mecharical Service Manual Vcl. I,Section IV, Paragr ph 11, dated April 19, 1978 that was utilized for tha finel ali ment of S.G.
No. 4 (1-D), the construction operation traveler
. 35-1197 dated August C, 1979 which was utilized for final S.G. aligrrart acceptance by OA/QC, the S.G. Panufacturers Data Report, d ted Juna 15, 1982, the Brown & Root (B&R) composite pipirg drawin s No. 50-15-1D-5016 and 5035, and a latter discussing the plumbne s of the remainire three staar cerera+ ors Nos. 1, ?, and 3 (Wer inghouse letter No.
ST-PY-YS-00027).
The SSAT questierad the effect that the o -of-plumbnass cerdition of S.G. #1 and #4 had on other corponent in the Nuclear Steam Supply System (NSSS) Loop. STP staff presente to the SSAT a report entitled "Status of NSSS Pelated NonConformance.eports," dated August P, 1983,providedtoHoustonLightinganjPowerCompany(HL&P)by Bechtel Erergy Corporation. The repo t stated that, after identification of the S.G. anoralies, a survery an review of the as-installed condition of all NSSS equipment in tritt I was undertaken. The equipnert found to be nonconfornirs was documented in the report along with the actions necessary to resolve the condition. The following sumarizes the conditinr$ reted in the report.
, ~
1.
S.G. Upper and I.ower lateral Raitraints f
I The gerarators are displaced b,s va*ying amounts relative to the upper and lower lateral restraints, due to the inclination of the c+eer eenerators. As a result, nonennfoming reports (NCRS) were issued to docurent the problen.
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Mattinghouse reviewed the renconfoming conditier apd stated that tha cut-of-plumbness wts not severe and erly / minor rodifica-tiers would be nacessery to ensura an adequate support system.
After the modifications were iirpler.ented. West ghousa issued l
1etterNo.ST-WN-4-1468datedFebruary12,If85,statingthata a review was perfomed for the applicable N s and as-built measurement infon atier for the lateral su crts and detemined that the supperts were acceptable es irst led.
t 2.
Steam Generater (SG)/Reector Coolant Fu (RCP) Vertical Supports i
Detailed surveye were perfonned that i dicated the following j
items associated with the SG/RCP ver ical support enlerrs were nisaligned:
i e.
Column base plates are r tated with respect to the anchor bolt pattern.
b.
Colurns exhibit lack o parallelism with respect to each other, c.
Columns do ret exhi it correct inclination towards the reactor.
d.
Columns have tre verse inclination with respect +o the i
reactor.
e.
Columns are rotated with respect to the bases and S.G. ndapters.
4 f.
Equipmant columns are eccertric to slab support eclumns in excess of allewable tolerances.
1 As a result, NCRs were issued and Westinghouse perfnrred an analysis which irdicated that the concerrs essociated with items (a) through (e) above were not significant fron P stress aralysis or crercbility standpoirt.
It was elso stated that the cencerns acreciated with the eccentricity cf tha columns would j
be ratolved by shifting the acuipment support basa plafer to meet the Bechtel tolarance requirements.
In these c ses where the required telerarcos could not be met by shiftin the base pictes, it was stated that analyses would be perf ed te ensure that the load 14 nits on both the structeral and quipment supporte. were not exceeded.
This issue was also discussed in the Westing cuse corresrendence dated February 17, 1985 and ound to be acceptable as installed.
3.
Reactor Coolant Pump Surveys were taken that indicated the reactor coolant punps (RCPs) devie.to from the design cold etition by small amounts.
Westinghouse stated that design to erarces are not specified for the RCP centerline displacerer.ts nd that proper fit-up is assuned to occur by the reactor colant pipe cold leg fit-up to the pump discharge nozzles. Al o, an as-built stress analysis was perfomed which verified the acceptability of the systen.
Based on the above infomati n, there ware to NCRs issued or this iten.
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4.
Steam Generator Piping Since the steam generatnr nozzles were displaced leterally l
by of the lean of the steam generators, sore modifications in the piping attached to the steem generator was necessary.
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Detailed surveys were taken to determine the recuired layout for the main steam, feedwater, and auxiliary feedwater lines. NCRs were issued for those li et that did not fit up properly with t
their respective nozzles. Affected piping wet modified in the field and in the shop as nece:tary to provide proper 'it-up.
E.
Reactor Vessel Surveys taken on the reactor vessel indicated that the.eacter vessel core tupport ledge was unlevel by an amount gr eter than the allowed tolerances. The surveys indierted that he slope excaaded the Westinghnuse acceptance criteria as r tated in the Brown & Root Quality Construction Procedure # 040 PMCP-10.
The tolerarce recuirarrnts specified by Wertirg)touse were idertical to those specified for cther Westing'ouse reacters.
The tolerance renvirements for the ledge ersu ed that the core barrel retaned its verticality ty a specifie amount, thus facilitating lirearity and proper fit-up cf all reactor components.
Additional optical surveys were taken to erify the slepe of the core support ledge. After reviewing thi data, the preliminary evaluation indicated that two saparate ut related cercerns existed.
First, there apparently was tilt nf the vessel that may have beer associated with the dif eterntial settlement of the Reactor Containment Buildino (PA i basemat. The second 7
concern was assccieted with the waviness of the cree support ledge which may exceed the Westin cuse flatnest criteria.
On October 14, 1983 Westinghouse add essed the two concerns vie correspondence No. ST-WN-YB-629 en tied "Evaluation of Reactor Vessel Tilt and Waviness." The e trerpondence stated in part, that Westinghouse has eveluated the reported conditions and concluded that cut-of-levelness condition of the reactor vessel support ledge and mating surface does not constitute a safety hazard and that the
-H-plant may operate without repair. Westinghcu':e also stated that the reacter vessel tilt results in no riprificant impact on the reacter's operation, reactor vertel nozzle lerds or piping / support leeds.
HL&P has been monitoring the differertiel settlement of all vital structures from the beginning cf construction in accordance with the FSAP ecmitments. The SSAT reviewed the differentiel f.ettlement data for the reactor contairrent building and noted that it has retrained within the design tolerarces.
In addition the SSAT teught the assistance of the NRC NRR +Prhnical staff to further confim the acceptability of HL&P's eralyses for justifying cut-of-plumb (verticality) condition of tre steam generators and the etber i
out-of-tnlerance conditions noted with major NSSS corponents in Unit l'.
5.1.4.3 Conclusions The SSAT detemined that this allagation w substertieted in part.
While the. condition relating to the verti ality of stear generator l
1-0 was found to exirt, the condition w analyzed and evaluated to 1
be acceptable, documented properly in nonconfomance *eport, and satisfactorily disresitinned.
i The NRC NRR staff bas met with HL&P and its ccrsultants and concluded that the analyses had satisfactori.y resolved the concerer.
5.1.4.4 Action Required PriortoascensionfronEfpoprforUnit1.HL&Pshallsubmita report to NRC documenting tKe results of the analyris. Further review by NRC NRR staff, if required, will be documented in separete SER.
w y v.
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.. _ _ _ _ 5.1.5 Reactor Coolant Syrten Pipe Whip Restrairt 5.1.5.1 Characterizatior, cf Allegation It is alleged that pipe whip restrairt No. RC1125-R1 was de, lated from the design drawing via a field change request (FCR)pdApril 1987. ThisrastrainthasthraaClass1largeborefoadpaterpipe supportr attached to it. The restreint is located in the irtercorridor of the reactor conteirrert building, Unit 1, Room #21. An N-5 Code Data Report was gererated at the same time that th FCR was written.
This reker the N-5 code data repert information a d traceability of the attached pipe supports rucstionable.
5.1.5.2 Details The SSAT reviewad the reactor ccolant pipa hip restrcirt Design
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Drawing No. RC-1125-R1 and all associated esign dorementation for the large bore pipe tupports that have re ained attachad to the pipe whip restraint structure. The larga bor. pipe support design drewings raviewed ware FW-9012-HLS011 Revision
, and RC-9125-FL5007. Revision 4.
The SSAT perfomed a field walkdown to assure that tha subject supports were the only two large bore attachtertr. to the pipe whip restreint. The SSAT also perfortred limited as-built cofiguration inspection of the large bore supper s to verify items such as utili:t-tion of correct r.aterial, support ocatier and orientation, load settings, heat numbers, and mater al traceability.
Each of these areas was fcund to be acceptable.
In addition, this infomatier coincided fully with the docum tation provided in the applicable N-5 Ccde Data Reports reviewed by te SSAT.
The SSAT also reviewed the ec!culations for the large bore pipe
.I supports and the procedures governing the cesign coordination process in which pipe suppert designs that are to be attached to civil / structural restraints are forwarded to the Civil / Structural Department (C/S) for i
._. ~.
i revievt. The SSAT revirvrd two support interface load sheets for pipe supperts No. FW-9012-HL5011 and PC-9125-HL5007 and prrecdure Nn. pE0-027 entit1rd., "Civil / Structural (C/S) Directive for the Review of Pipe Support Drawings." Secticn 3.1 of the procadura states ir part, that pipe support drawings ara te be reviewed by the C/S to assura that the structural elements, such as beams, columnc, slabs, and walls, are properly loadcd.
Suponrt interfaca load sheets are to ba submitted to C/S upon completion of ergineering design of the support. A review by C/S is not a "hold point" for the' initial
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issuance of support drawingt.
If any corrective action /s required by C/S, it is indicated or tha pipe support drawiro ** urned to the pipa support group by memorandum to be incorporated, the pipe
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support group in the raxt revisien of the draring. The SSAT found that these procedures wera adeo,uate.
The SSAT reviewed Calculation No. CC-5944, File No. C-37 Revision 7.
Infomation on the calculation cover sheet ir.cated that the calcula-tion for pipe whip restreirt No. RC 1125-R1 ~ad been deleted because the energy absorbing raterial (EAM) frction of the pipe restraint was removed. However, there is a pessibility er it to be reactivated ir the future.
It also stated that portions of the restraint that were installed are being used to as pipe sup rts structures. However, due to the magnitude of the design pip whip restrairt loads compared te the pipe support loads, nn analysi needs to be perfomed. Basad on these facts, this calculation was prepared as a reference only, andshouldthepipewhipvertraintpereactivated,accrsistency check of the reference drawings, 5 ecificatiers, and other applicable data rust be perfemad at that ti e.
While reviewing the design dra ng for the pipe whip restraint, the SSAT noted "Note 7" which stated thatt the pipe whip restrair.ts (PWR) defined on the drawing were rot required based on the revised analyses, the PWR suppert r.tructures which are already crected may be left in place provided that cornpletion cf the structural erection and successful acceptance inspection of the completed work is docu-mented by the constructer through established precedures. and struc-tures which are partie.11y erected or questiceable because of uncertain compir.tien, or not documented as completed and inspected, eball be removed.
/rawing that edded However, the SSAT also noted a revision to th d
tiote 5 which stated that no additional attac'rerts are to be made to thir (PWR) restraint. The SSAT inferred H P that thir rete enuld be misinterpreted by other engineering disci ines and should removed or 1
revised to restrict attachments unless a proved by Civil / Structural Ergineering. Prior to the cerclusion o the inspection, the Civil /
Structural Departnent reviewed all des gn dravings for Units 1 and 2.
No other notes of this type were feu
, and the above note was corrected which was verified by the SAT.
5.1.5.3 Cenclusien The SSAT detemired that this c legation was not substartiated. Tha design documentation that was eveloped to remove the Structure as a pipe whip restraint war adequ te as well as the design documents and code data reports for the at ached feedwater pipe supports.
5.1.5.4 Action Required None 5.1.6 Alur.inum-Bronze Piping 5.1.6.1 Characterization of Allegation It is alleged that the design of the Essential Cooling Water (ECW) system is inadequate. Specifically, the alleger is cone.erned that
the aluminum-bronze pipa used in the ECW systen does not have adequatn j
wall thickness to compensate for metal less due to microbioingically induced corrosion (MIC) over the life of the plant, and that later in plant life tha piping could fail due to rettlement or a seismic event. The allager is further ccr.corred that this pipe has barr subjected to MIC for many years prior to the FCW system being placed in service. The alleger is also cercerred that c rrosion debris could enter ECW pumps and nther system componert, thereby rerdering the ECW system incapable of perfor-ing its saf y function.
S.I.6.2 Details MIC has baen erd contintes to be eddresse on a generic basir by the NRC staff.
IE Information Notice No. 85 30, "Microbiological 1y Induced Corrosion of Cortainmert Servic Water Syrter'," dated April -
19, 1985 addresses the subject of VIC.
In this notice, the NRC staff acknowledges the potential for bacter al prowth under almost any conditions, and describes some ganer 1 methods for inhibiting MIC.
Sore of the methods for inhibitire MIC discussed in the retice include the usa ef water chemical treatme t, use of cathodic pretection j
systems, and procedures to ensur that systems are ret subject to low flow rates or stagnant conditi s which favor biofouling and concen-tration cell corrosion.
The SSAT has reviewed the TP ECW systen darign and operation to detemire if the recomendations erntained in the notice are being implemented. The follow 1rg 15 a sumary of findings by the SSAT:
STP has implemented procedures which call fer treating the ECW operating loops (there are 3 ECW loops per unit - 2 are generally in service) with injections of sodium hypochlorite and sodium bromide three times a day. This combination of chemicals has been shown to be very effective in preventing biofouling at STP.
ECW loops which are not in operation are cperated for short periods on a weekly basis +c preclude stagnation and pessible biological growth.
Etr Inops which are to be shut dowr for more thar 7 days are treated with sodium hypnchicrite and sodium bromide prior to shutting down.
The ECW system is a partially einsad loop / system.Water is taken from the Essential Cooling Reservo'ir (ECR), is pemped through tha ECW operating loops, and discharged back to the ECR. Heat picked up from ECW equi t is dissipated to the atmosphere. Maka up water to compe sate for evaporation and bleed off to maintain water qualit is added as required. With this design, chemical water trea,ent introduced into the ECW operating loops every day avent.11y is discharged inte the ECR, resulting in e residual of the cals beirg raintained in the ECR. Thus, the source of wat for the ECW loops is also protected against biological ouling.
Based on the above, the SSAT has concluded that the licensee has implemented the recorrerdations of IE Inforr.ation Notice No. 85-30 with respect to inhibiting PIC In~ addition to the measures or inhibiting FIC described above, the design of the ECW system i such thet there are numerous places where the system can be inspected for the prasence of biological fouling.
Some of these places are discussed below.
TheComponentCoolingWater(CCW)heatexchareerwaterboxes are connected to the 36" pipe coming directly frm the ECW j
pumps. When the water bexes are oper, it is possible to inspect the large bore pipe for a distance of approximately I
i I 8-10 feat. Also, if necessary, the ECW loops can be draired i
and the large here pipe made accessible for inspection for even greater distarces.
\\
Thare is a low flow area next to the tube sheets on the cutlet sida of heat exchangers. Since biological fouling increeses as flow rate decreases, the cutlet side cf heat exchangers would be the logical place for biological fculing to begin, if it were to occur at all. Allheatexchangersin[beECWsystem are accessible for ir!pection.
Bielegical fouling (MIC) terds to block f ow in small bere pipirg. The smellest diameter piping 4 the ECW system are the a
tubes in the Emergency Diesel Cererato (EDG) fuel oil (FO) heat exchanger.
If biological fouli vere to occur in small diamete p4pire (heet exchanger tut
), it weuld occur firnt in the EDG FO haat exchanger. This h at exchanger is readily i
accessible Tor 'nspection.
I ThedesignoftheECWsystemsatST[makesitpossibletoinspact P
forthepresenceofbiologicalfouyirginlargeborepipe,small bore pipe, ard in regions of low low. Ar indication of bioingical i
fouling in any of triese areas wo 1d serve as an indication that corrective actions would be re ired. By procedure, STP's chemical ergineering personnel are ret fied whenever any portion of the ECW systems are cpened for inste tion / maintenance so that the opened portion of the system can e inspected for biological feuling.
If
{
any bacteria is fcund in the ECW systems, FL8P has the capability on i
site to detemine whether or not the tacteria present could cause MIC.
l The SSAT has detemined that a portier of the underground pipe in j
the ECW systen was physically inspected prior to placing the system 4
O itt service. The resul+s of this inspection shcw + hat some small bacterial grcwths were feund, but there was nn irdication of pitting of the pipe as is typical when PIC is present. The amount of bacterial growth fcurd was minimal and would rot affect flow ir the underground pipe.
In addition, to the chemicai wcter treatment and the physicc1 irspec-tien capability, the ECW systen perfonnance can be incnitored and used as an indicator of the presence of biological fouling. Reduced flow rates and/or changes in heat transfer thrcugh heat exchangers are positive indicatiers that of biolecical fouling may be occurring.
Syster rerfomance is monitored on a regular basis.
5.1.6.3 Conclusion The SSAT detemined that tha allegation was ro substantiated.
Vhile it is possible for MIC to occur in the CW systen at STP, the SSAT found that the measures taken to inhibi bactericlogical fouling are adequate. Sheuld such fouling occur, tP has adecuate procedures and inspection capability to er.sure early detection which would allow corrective actions to be implemented bef re significant damage is done. Based on the above, the SSAT con ludes that using the aluminum-bronze piping in the ECW sys ms at STP is acceptable.
At the time of this report, the NRC staff is still evaluating the resistance of aluminum-brerze pipe to MIC. There is scre evidence that aluminum-bron:e pipa is les susceptible te PIC than carbor steel or stainless steel pipe. The NRC staff will continue to review this issue as part of its gen ric study of MIC. The above SSAT conclusiens, however, would 'only be reinforced should it be shown that aluminum-bronze pipe has a high resitterce to MIC.
i 5.1.6.4 Action Required h' ore j
5.1.7 Equipment Accessibility 5.1.7.1 Characterizatico of Allegation It is alleged that the desion of STP is inadequate,'bacausa provisions were not rade for accessibility to pumps, motors / valves, gages, and other equiprent, for operation, maintenarce and repair.
It is
~~
also alleged that the STP design is ir violation of 10 CFR Part 50, Appendix B, Criterion III with respect to acce sibility. Two allegers identified three corcerns of a timilar natur / regarding the design of STP. An intervice was conducted with one of the a'.'rrers, who provided additional inferr.ation as indicat below, in support of his allegations.
5.1.7.?
Cetails Two of the three allegations are conc rns raised by the same individual.
This alleger wer interviewed by the AT. Curing the interview, the i
SSAT requested the alleger to provi e specific details with rer.pect to systems, locations, and compone ts, that were inaccessible. The alleger did not respond directly o the requests fnr specifics from the SSAT.
Instead, the alleger greed to show the SSAT its concerns (astatedtotalof72).
Tha second alleger was ret m de available for interview by the SSAT.
Consequently, no spet.ifics were provided es to system, component, er locatien.
1 i
l 1
i The individual expressing rumerous concerrs regarding accessibility was initially identified only by a number, but was subsequently identifird by name. During the review cf en-site records, the SSAT i
determined that tha sano individual had raired numerous identical ccreerns during plant tours ir the latter part of 1986. The *ecords also showed that all cf the alleger'= corcerns had beer reviewed and dispesitierad by HL&P's SAFETE/F., During the telephone interview of the alleger by the SSAT, the alleger made a reference to reports he had received relative to his concerns. The records reviewed shewed that the FLI,P's SAFETEAM had corresponded with the alleger regarding the disposition cf his concerns. Basedontherecordsj$tSTPandthe interview of the alleger, the SSAT then concluded that the cencerns raised in the allegation given to GAP are the same,c/
oncerns the alleger reve to the STP SAFETEAM.
Subsequently, he SSAT deterrired that an independert eudit of the STP SAFETEAM's rvestigations of the allecer's concerns would be more productive th a rite tcur to revisit these concorrs with the alleger.
The SSAT selected a representative sampla the alleger's concerns and independently raviewed HL&P's SAFETE
's investigatier ard disposi-tion of these concerns. At the conclusi 5 of the review, the SSAT could find no reason to disagree with e STP SAFETEAM findings.
In addition to the abnve review, dur ng walkdowns of several systems at STP, the SSAT was looking for rp cific instances where ireccessi-bility of components had created a safety corcern. At the conclusion of the SSAT inspectinn at STP, n such conditions had bean ider.tified.
l 1
5.1.7.3 Conclusiens The SSAT detemined that the allegar's concerns are almost all associated with non-safety related systems and components.
In the f
isolated instances where a safety related cceponent wat irvolved, the SSAT determined that those cases did not impact safe plert operation or shutdown. Based rn the above, the SSAT detr.rrired that the r.liegations regardirg ireccessibility of pumps, rotors salves, gauces, and other equipeert v:ere not substantiated with resp *ct to safe plant eperation erd shutdown.
With respect to the allegation regarding 10 CFR Part 50,' Aprendix B, Criterion III viciations, the SSAT was unable to establish that safety related systems and componcrts were irvolved/ Thus, the
/
SSAT detemined that this allegatier was alto not substantiated.
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S.I.7.4 Action Required Ncr.e t
I
5.T Valves 5.2.1 Valve Installation 5.P.1.1 Characterizatier of Allegation It is alleged that incorrect insta11atier of valves has resultad ir twenty percent of the velves having the wenrc crientation to the systrr flow (i.e. installed backwards). An interview with alleger revealed re additieral infometien regarding the locetion or type of j
valves.
5.2.1.?
Details The SSAT reviewed the applicable documents controlling the installation of valves includirs Standard Site Procedure SSP-10, Rev. 4, 1987, entitled "Installations and Fielt Fabrication [of Piping,' ard SSP-18, Rev. 4, 1987, entitled "General ASME III Welding Requirenents." These documentsprovidedetailedguidelinesforveiveinstallationprocedure, j
location, and oriantatien. Particularly, they require that unless
/
specifically shown differently on the desi n drawing, valves with the
)
valva orientation markings, such as flow rrows, shall be oriented in the same direction as the flow arrows for the lines strwn nn the iscretric drawings. The SSAT attempted to obtain specific infomation regarding system, locatier, and valve pes involved from the alleger.
However, no such infomation could be btained. The only information that the alleger previded was that in an unnamed plant construction progress report, a staterert was not d that 20 percent of nyerall ecuipment items (pumps, valves, its uments,etc.)hadnotbeen i
completely installed at the time, o streific mention was r,ade by the alleger, however, about the ty e of installation deficiencies such as mis-orientatier of valves. Thut, in view of the lack of specific installations, the SSAT's approach for the resolutten cf this concern incleted the perfomance of a generic review and inspac-tion of valve installations in STP Unit 1.
4 i
As stated previously, a review of the controlling docueents indicated the existence of detailed procedures for valve irste11ation. The
2 SSAT then precaeded with the review of the actor.1 records wherein the precedures were implemerited. Thit included QC inspection repcrts for valve installation fer both flarged ar.d welded cor.rections. Two Syrtens were selected for ir-dapth review, the Chemical Volume and Control System (CVCS) and the Component Cooling Water System (CCWS).
QC inspection reports vere reviewed for the various types of valves installed in these systems and fourd to be satisfactory. Also, re non-ecr.formance reports could be identified that were directly related to tha alleged backyard installation of valves.
The SSAT aise reviewed the insta11atien of valves i the auxiliary feedwater syrten to detertnine if any of the valves had been installed backwards or had barn already replaced because of intergranular strett errosion cracking (IGFCC). The SSAT de mine.d that quality inspections found that sere prefabricated drai valve and pipe assemblies had been installed backwards and w re evalueted to ba acceptable as-is sirce the function of those valves was not affected by thrir orientetion. There were ro record indicating that valves in th4t system had been been repleced beca se of IGSCC.
Confiriration of correct vt.1ve orientatio was further r.ada throuer an independent plent walkdowr by SSAT.
pprcximately 70 valve insta11atiers cf various types were its ected. The systens covered were safety ir.4ection system, reactor colant system, chemical volume ard control systers, componert cooling water systen, erxiliary feedwater systee and emergency cooli weter systems. The SSAT found that, with the exception of ta e velves and ball valves, arrow indicators were visible on the valv bodies (e.g., check valves, globe valves, and butterfly valver and were in agreement with tha j
flow directiers shown on the is tric dre. wings. As for those gate and ball valves inspected, the S AT ceneurred with HL&P's assertrert that the valve orientations had no signifia.ance on fyrtem perfortnarce.
In addition, SSAT conducted er extensive review of the pre-operational test reports for the Cherical and Volume Control System and the Correrent Cooling Water Syster. The primary objective of this review
)
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was to detemine if there were any anomalies ir the system performance during testirg which were attributable tr valve mis-orientation ned whether thir resulted in issuance of ner-ennfomerce repcrts. Ttt review irdicated tFtt although some non-crrfomance reports had been I
issued, rene were a result of valve mis-nrientation.
5.2.1.3 Cerclusion l
The SSAT detemired that the allegatirn regardin backward irt+ella-tirr of 20 percert of valves was not sobrtentia ed. Based en a telephone interview with the alleger, tha SSAT found that the percen-tage wes actually steart to refer to status of the completion for nyerall plant equiprert items er categories nstead of valve deficien -
cies. The SSAT found no evidence that val s were installed backwards at STP, Unit 1.
5.2.1.a Action Required Nnne 5.7.2 Valve Maintenance and Peassembly 5.P.2.1 Characterizatter of Allegation It is alleged that approxinately 60 valves with limitorque operators j
did not receive preper maintenan e prior to insta11atien.
It is also alleged that when valve? were r ved from systeet frr reworking, various parts were intercharge during reassembly, the velves were mislocated when reinstal'rd, nd the flanged connec*.irrs were not properly to*qued.
In additi n, it is alleger' that valves were received with vender applie inorgaric zine cratings that were rot adequately cured and were removed from the valve erd operator assembly by sandble.rting.
l
-4 5.2.2.2 Details Since no specific infomatier ebeut systems, locationi, Prd types of alleged valves were evtilable, the SSAT cnnducted a gereric review cf th* subject matter conveyet by the allegatiens. The SSAT reviewed Standard Site Procedures SSP-10, Rev. 4, dated 12/23/P7, Installation ord Field Fabrication of Pipirg, erd SSP-18. Fev. 4, dated I?/31/87.
General ASME I!! Wrldittg kequirements, to verify the ecquirements and guidelires for pre-installation irspection ard irsta.11ation of valves. TheSSATalsoreviewedSSP-24,Rev.2,de}ed12/31/P.7 Disassetrbly/Reasserbly of Safety and Non-Safety-R 1sted Valves, for 7
the detailed guidelines of 0C verification of each applicable disassembly and reassenbly step.
SSP 48, Rev. 4, dated 11/19/87 Equipment or omponent Interchanged, was t.lso reviewed. This procedure provides nstructions for pemaneht plert equipment, components, er material in erchange betrean Unit I and Unit 2, or any 1cce.tions within ettber nit, or ener en facilities that reouire identical items. The SEAT understood that this precadure tppliestoequipment,crrpenentsormaterfalswhicharepurchasedto the same sp*cifications, meets designed quipeert cualifications, ar*
pbyrically identical, and heve idertica/ perfomerce characterittics, but differ orly in name tag idertifica ion.
In the review of the above documentsj the SSAT found that detailed j
procedures and guidelines were ir p/ ace which were able to 1Nntify
,nd eliminate all the potential erpas of enrcern stated in the allegations. This procedural revlew was supplemented by the SSAT reviewofSTPQCinspectionrepo[j ts for an extensive list of valves in tha chemical e.rt volume contr,o1 system ard the component cooling water systen, as reported in Sectinr 5.2.1.
In all cases, either no non-confoming condition was identified, or and for those noncon.
fnming cerditions found, correcthe actions had been taken and corcerns had been setisfactorily resolved. Also as previously stated, the SSAT walkdown of 70 valve irsta11ations did not reveel
any discrepancy in the as-built velve configurations or locatiers, f
and any interferances with other equipment or ary accessability or ether conditions which eigM S r(lated to the ellegation.
l In regard to sand blastirg cf valves, the issue was criginated fron creting failures of 5000 volvas in storage caused lartaly to the lack ef proper coating curing tina. Philesomecoatirgfwererecevarable, others were repaired. / bout 25valveshadtohav7thecoatings reworked at the plant site.
Forthislaterinstfnce,ncnconformance reportswerewrittenandveredispositionedto7equiresancblasting for renoval of the dar. aged coatings. The valves were required to be
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properlyprotectedandheredisasserbledacco7dingtothespecifications.
AnFRCinspectionhadbeenpreviouslyconducJedonthisitemand similar conclusions were drevr to the satisfactory conduct cf this evolution.
6.7.2.3 Corelusion i
The SSAT deterrired that the allegations ver* not substantiate except for the valve coating ecreern wh ch was substantiated in part. The SSAT fourd ' hat proper contr is were found to exist and were implenanted for the disassembly, f.aintenance, ard reinste11a of valves. Although a nonconforming rdition had existed with the verdor coating nf some valves, the SS T found the condition to ba properly documented and adequate cor ective action taken.
5.2.2.4 Action Requ -ed None 1
5.2.3 Radiatier Effects on Ortrol Valve Pose I
-C-5.P. 3.1 Characte iration of Allegation It is alleged that the rubber hose attached to control valve CV-0381A will degrade if exposed to radiation.
5.2.3.2 Details The SSAT detemined that this cercern had been previou ly brcught to the attention of the STP SAFETEAM ard indPrardantly ddressed by inspecters from NRC Pegicn IV. TheSSATrrviewadpherecordsapplic-eble to this item and determined that the rubber ose in question has a protective braid which is designed to withsta d radiation expcsure up to 50 rads per hour. The equipment specifi ation (G-95285), in
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which covers control valve CV-0381A requires hat valves ard all of their components be capeble of withstandi g radiation exposures of 50 rads per hcur.
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Valve CV-0381A is located in room 31, el vation 10' of the Unit 1 mechanical electrical auxiliary buildir (MEAB). This area of the j
MEAB is certidered to be a high radiat er area with exposure rates greater than 100 millirads/ hour.
Ho ver, the estimated exposure rate in room 31 is 1.9 rads per hou. This exposure rate was deter-mir.ed from Bechtel calculation No. C5028, Revision 0.
The valve and j
its components have been designed o acecmodate 50 rads per hour and the. actual expected exposure in e valve location is 1.9 rads per hou'r.
5.2.3.3 Conclusion The SSAT detemined that tb s allegation was not subs,tartiated. The SSAT concludes that the rubber hose attached to the valve will not be affected by radiauon exposure.
E.2.3.4 Action Required None
5.2.4 Valve Extersion Interferences 5.2.4.1 Characterization of Allegttier It is alleged that mareal remote operatcrs for Vaher Nos.1/CV-0254A and 1-CV-C092/TCV-03814 are ir certt.ct with an electrical certuit and a pipe support, respectively.
No noncerfomance "cpceJ[ were written
+o docurert these interferences and no corrective ac+ ion was taken.
5.P.4.2 Details The SSAT reviewed the desigr control documenta ion referencing the correction of tha interference conditions for these valves. The
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design changes were completed under Field C nge Request, FCR No.
BP-02542 and Drawing No. 8373064 for valve /CV-025aA and FCR No.
DP-07266 and Drawing No. 4M369PCV217 for alve 1/CV-0092/TCV-03814. -
The SSAT perfontsd a field walkdown and limited inspection of the as-built configuration of the subject v lves to verify items such as adec,uate cleararces between component ard the manual remote crerators, utili:ation of correct hardware, val e locatier ard orientation, heat numbers and material traceability, hese items were all feurd to be acceptable. The SJAT also noted t at the manual remote operators for the subject valves were classifie as non safety-related class 9 comperents per tile supplier bill of matarials and HL&P Specification No..L639T50507.
In addition, a 1 engineering and QC installation inspection records were review d and found to be acceptable.
It was also determined that no NCRs were written te document those inter-ferences because the instal tion was considered to be in-precess anc' ren safety-related.
/
The SSAT also reviewed two NRC Region IV Inspection Peports, Nos.
50-498/87-07; 50-499/87-07 dated June 3, 1987 and 50-498-30; 50-499/
87-30 dated October 6, 1987, in which this concern had previously been evaluated. The reports indicated that these items were identified
)
l j by HL&P on the Pastar Completion List (liCL) prior tc the tima the alleger identified the problar during a tour of the plant on October ?,
1986. HL&P's SAFETEAV dccumentation under an HL&P Memorandum dated Septanber 25, 1987 also evaluated this issue. The SSAT found that the rework which entrected the interference problems was not perfomed until after the alleger's tour nf the plant. During the field walk down the SSAT alte inspected several other valves installed in safety-related systems for the following alleged discrepancies:
interferencesbetweenremotevalveoperatorsardetherccdperents, aycessive remote valve extensions, valve inaccessability/, and reversed valve installatirr.. No discrepancies were r ed.
5.2.4.3 Conclusion
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The SSAT determined that allegation was substan ated ir part due to the fact that the interferences had existed be ween the rerual remoti operators on the subject valves and other enn onents, however, these interferences were identified, documented, a.d the appropriate corr >ctive action was taker.
5.2.4.4 Action Recuired None
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l l
5.3 Hesting, Ventilation ar.c Air Conditioring (HVAC)
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5.3.1 Installation Cookbook 5.3.1.1 Characterization cf Allegation It is alleged that the "Ccokbook" was confusing ard difficult to interpret and it was subfect to extensive revisions.,The "Cookbook" vias supposed to have universal application with respect to HVA.C l angers and supports.
In theory, a craftsperscn ir the field cculd Mt the stop prepared pieces for a given hanger r support and, using the "Cookbook", readily determine how to semble and install a hanger or support at ari) specified location.
e "Cookbook" was supposed to prcvide all requisite information including hanger or support configuration, assembly and weld det ils, ard installation details to ccver all possible fleid conditi ns.
There are concerns that (1) HVAC duct ha ers and supports may net bt adequate because of misinterpretation of the "Cookbcok" for any given application, and (2) that the revisions to the "Cockbook" may have caused existing hangers and suppoi15 be in ncn-ccnfcnrarce with current criteria even though the hang rs or supports night have criginally been installed correctly.
The SSAT interviewed one alleger w o had expressed concerns regardirg use of the "Cookbook". This alle er was unable to identify any specific exarrples of how and whe e use of the "Cookbook" resulted in i
unacceptable installations of H AC hangers and supports.
In addition, it was not clear whether the a eger was relating first hand experience, er cassing on second hand inf iation. Also, SSAT review of GAP files was equally urproducti with respect to identifying specific examples of unacceptable PV C hangers and supports resulting frorr use of the "Cookbook."
5.3.1.2 Details The SSAT determined that use of the "Cookbook" in the field as the basis for installing HVAC hangers and sun. orts was stepped scretime in 1983. The fact that the "Cookbook" was oc longer in use wa a r.
indication to the SSAT that the allegation might be substanti ted, at least in part.
o further pursue this possibility, the AT requested that HL&P essen.ble a ccnplete package which dete led when use of the 'Ccckbook" was stcpped, how much FVAC du work had been installed at tie tire its use was stopped, and wha effect the use of the "Cookbook" had or. the adequacy cf HVAC bang rs and supports fct their interded purpose.
FLIP provided copies of the appropriate sections of "Specification For The installation of Safety Class and Nonsafety Class HVAC Equip -
r.ent ar.d Cuctwork for the Pouston Lighting and Po er Cnrpary Scuth Texas Electric Generating Station SV279VS1003" ( eferred hereinafter as the specificatiora). The data provided by H &P includes Revisier 0, Addendum 1, Revision 1 and Pevision 2 of the a propriate sections of the specificaticns. HL&P also provided Speci ication Change Notices (SCN) F-3, 6 and 9.
The SSAT reviewed the d ta proviced and trade the following observations.
In Revision 0 of t e specificaticns dated December 28, 1982, Paragraph 5.P.1.3 reads in part, that "all HVAC supports shall be erected in accordance w th HVAC Supports Design P.anual (the Cookbook)--." Addendum I t the specifications, dated June 29, 1983, changed Paragraph 5.2.1.
to read, in part, that "all HVAC supports and flanged mer.bers shal be o ected in accorce ce with Duct Fabricator's drawings reviewed;.d released by Bechtel or in accordance with Var.ual of HVAC Duc M and Duct Supports--." SCN 9, dated January 20, 1904, further revises Paragraph 5.2.1.3 of the specifications to read "HVAC duct supports shall be installed and inspectedinaccordancewithductsupportdetaildrawings(Cut Sheets) prepared by the Duct Fabricator and accepted by Bechtel Site Engineering."
In sumary, the data provided by HL&P docurients the evolution from priury reliance on the "Cookbook" to eliminaticn of thi. "Cookbook" as a field guide fcr installation of HVAC dus._ _
duct supports. This evolution occurred in just over one year /1?/
to 1/0d). Since January 19Ed, all HVAC ducts and duct supports ha-been erected using cut sheets which shcw all installation details ard which leave octhir4 to be mterpreted by field personnel.
HL&P also provided computer printcuts which listed the completien dates for HVAC duct installaticns at STP.
For the pericd frcrr Decer.ber 1987 to January 1983, very little HVAC duct was installed
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in L'ni'. I and ncne was installed in linit 2.
Prior to Decer.1ber 1987, the major HVAC activity at STP was removal of duct and upports installed by Brown & Root.
In sumary, the SSAT dete.ined that only a strall percentage of the HVAC duct supports in linit I were installed -
using the "Cookbook".
The last data package provided by HL&P included selection of inspecticn packages covering inspections of HVA installations by Ebasco CC. These reports covered both early d et installations and early inspections. While a number of the pac ages reviewed included rework requirerrents for the item inspected, he SSAT determined that all inspection packages ir.dicated that insp ction of the HVAC install-aticn was done in accordar.ce with cut she s and not the "Cookbook."
5.3.1.3 Conclusion The SSAT determined that:
1)
The allegation regardin the "Cookbook" was partially set-j stantiated to the extent that it was confusing.
This determination is based on discussions with NRC Resident inspectors, discussions with HL&P personnel, actions taken by HL&P/Bechtel to eliminate field use of the "Cookbook" and SSAT independent assessirent. That portion of the allegation which addresses the possibility that use of the
.4 "Cookbook" resulted in unacceptatile installaticns could not be substartiettd.
Tl.e dccerentation reviewed by the SSAT shows that sone HVAC duct supports did require rework, but the root cat.se of the cerests cculd not be detennined; i.e., it could not be shown that misintetpretatfore of the "Cockbeck" was the cause.
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2)
Only a limited an.ount of HVAC duct supports in Urit I were installed using the "Cookbook" for guidance. T c rajority of HVAC duct supports were installed ir, accord nce with cut sheets. All HVAC duct supports in Unit 2'were, or will be installed in accordance with cut stE ts. All OC inspecticns in Units 1 and 2 were, or will e done using cut sheets.
In sunitary, the SSAT ccncluces that the HVAC ducts supports for STP -
Units 1 and 2 were installed in accordance with d ign.
5.2.1.4 Action Required None 5.2.?
Miscellaneous HVAC Allegations 5.3.2.1 Characterization of Allegation It is alleged, in general, there were pr lems with:
a)
Ductwork and welds were not cleane prior to paintir.g.
b)
HVAC material stolen, the heat number removed frcm the caterial, and new heat nurber was inscribed by the person (s) stenling the material.
.g.
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c)
Separation of PVAC ducts from piping, hangers, conduits, ard en.bedn:ents for seismic considerations, d)
Caulking used to seal HVAC plenur.s.
C FG C datp r in the er.ergency diesel generator (EPG) tuilding fer l' nit 2 was founc to be defective, ard that the correspor. ding darrper in the ECG building for l' nit I had not been tested./
g)
Cuctwork in ECG building was signed off as complete bv GC when iri fact, it was rot complete.
Each of these seven allegations was initihlly reviewed at the GAP offices prior to the SSAT inspection at STF. The SS was unable to obtain ary specific data from the alleger files mai ained by GAP, and norie of the individuals associated with these llegations was rade available for intervicws by the SSAT.
5.3.2.2 Cetails Due to lack of specificity, the SSAT perfortr d a broad, general inspection in the HVAC area or bnits 1 anc ' in crder to assess the above concerns raised by the allegers, a)
The alleger is concerned that ductw rk and welds were not cleaned prior to painting.
The SS T's understanding of this allegation is that the welds were not cleaned to remove slag, and inspected prior to painting The SSAT inspected nurerous welds at random locations thro ghout both Units at STP and were unable to identify any unacceptable welds.
Unacceptable condi-tions such as porosity, uricercut, or ir. adequate weld sir? can be identified ever. if the weld is painted.
- _ _ _ _ _ _ _ _ ~
b)
The SSAT understanding of the alleger's concern is that HVAC r.aterial was stolen, the hcat r,ut.ber ra.cveu from the raterial, and rew heat nuttu w65 fr. scribed by the person (s) stealing the raterial. No further details were made available to the SSAT.
In the absence of specific locaticns, the SSAT was unable to identify the concern of this individual. As a result, the SSAT review HLtP's fabrication and installation process for HVAC raterial and it was detern.ined that in certain cases HVAC traterial is fabricated ar>d issued for a specific purpcse, location and applicaticn, Therefore, if a portion of ductwerk, or its structural support steel is lost or stolen it could not be substituted in the field for the reascos sta d above. The SSAT also determined that in all safety-relate applications there was QC involvernent to not only verify t at the correct ider.tification Nos, were present boi that th correct material was utilized, proper installatien was perfc.ec (i.e., material-fit-up) ard that the compatible filler wel material was used.
Ir addition, the SSAT performed field wal downs and documentation reviews ard did not identi y ary abocrralities with HVAC welds, sheet netel materials r fabrication, and its structural support steel.
c)
This allegation addressed the separa ion of HVAC ducts from piping, hangers, cerduits, and enbe.ents for seismic considera-tions. One allegation states that 'VAC ducts could be less than the required distar.ces fe et pipic, hangers, etc. The other allegation states that con. plier,c to seismic tolerances is indeterminate.
There were no locations, tolerances violated,y ecifics as to what systems, or time frame during which they occurred. The allegers were not rade available to be interviewed by the SSAT in crder to obtain specific data. However, SSAT conducted several field walkdowns during which no instances were identified where c'ucts were routed in such a manner that other equipn.ent wculd interfere with them during a seismic event.
m r--
,w-
+ - ~, -
v--v d)
This allegation concerned caulking used te seal HVAC plenums.
The alleger asserts that the coulking used could not withstand j
the plenum pressure which resulted in leaks. The SSAT has j
reviewed the allegers file 6t the 6F office. ar.d have concluded that the plenums are located ir. the STP fuel handling building.
Feycnd that, no specifics are given, and ttt-611eger v.as not nade available (cr interview by the SSAT. Howey r, the SSAT detertuined that all HVAC systems for STP Unit have beer successfully tested for proper operation, ard any system leaks that may have occurred have been corrected.
Rhile the SSAT wa TP, an issue pert nir.g to HVAC duct gasketing.a t fal was riised at Comanc e Peak. This gasket material, TRl#CO 44CA, whs four.d to be highly flamable. The same mater 1 is used xtensively at TP, The SSAT will folloy l
the gasket me.
issue at Comanc Peak thrcush resoluticn -
and then determine its app 1cabili y to STP.
1 e)
This allegation concerned a HVAC damper in the emergency diesel generator (EDG) building for Un t 2 that was found to be defective, and that the corresponding der er ir. the Unit 1 EDG building had not b en tested. The SSAT wa unable to cetermire the damper identification ard the alle r was not rade available for interview by the SSAT. He set, the SSAT detertrined that all Unit 1 HVAC systems, incl ding those in the EDG building, have been tested for proper eration and found to be acceptable.
The SSAT detennined that systun testing includes proper operation cf all damper s, including the damper of concern to the alleger, f)
This allegation addressed ductwcrk in the EDG building which was i
signed off as complete by QC when in fact, it was not cceplete.
The alleger files reviewed by the SSAT did not contain any specific safety concerns regarding the above ductwork, and the alleger was not made available for interview by the SSAT. As a i
result, the SSAT perfonred a field walkdown of all Unit 1 EDG
.g.
building HVAC ductwcrk te ceten. int if ir. fact all HVAC installa-tion was complete. Ttt SEC hr.1eviewed the applicable installation records (i.e., traveler packages and weld records) and no deficiencies were noted.
Also, the SSAT ccr. ducted interviews with c,ualified operations personnel and performed further reviews of the dcucnentation anc determined that all Unit 1 PVAC systems, including those in the ECG building has beenccmpletedandtestedthrcughstart-uptesingandno deficiencies were identified during the inspection.
l 5.3.2.3 Concluster Based on the results of field inspections, t e SSAT detemined that allegatiens a), b) and c) were not substan ated. However, thc wrongdoing aspects of all(gation b) have en referred to NRC OI for-further review.
Eased en the lack of specific infornat on, and considering that all Unit 1 HVAC systers have been success ully tested, the SSAT concludes that allegaticn d) was no substantiated.
a L
&(
Allegaticn e) concerr.
thu hV ^ cair.per in the EDG building for Unit 2 was not substa Itiated due to lack of specific infortration.
With regard to the concern that the corresKnding dairper in the p
Unit 1 EDG building has not been tested, the SSAT concludes that the damper of concern to tre al)e/ger has been tested. Thus, this part j
of the allegation was also r.ot substantiated.
Based on the results cf fielo inspections and the system testing perfomed, the SSAT concludes that the safety-related aspects of allegation f) were not substantiated.
Powever, the allcgation is classified by SSAT as wrongdoing and has been referred the MRC 01 for further review.
5.4 Fastners 5.4.1 Hilti Bolts 5.4.1.1 Characterization of Allegatien It is alleged that Hilti-Vwik concrete exparston anchor bolts were r.ot installed accordir.g to site procedures. An interview was corducted with the alleger who acknowledged that instalitticr. problems with the bolts were corrected.
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5.4.1.2 Cetails The SSAT reviewed STP site procedures 'or the selection, i tallation and inspection of concrete expansion anchors.
Brown & R t(B&R)
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Quality Ccnstruction Procedure CCP-23 "Installation of afety Related Concrete Expansion Ancher Ecits," Revision 0, dated 0 sober 23, 1979 through Revision 2, dated September 16, 19P.7 requir that c field -
rec,ut.st for engineering action (FREA) must be pr red whenever expansicn anchor bolts are to be used in locati.r r ct specified by the engineering drawirgs. The precedure refers o the Scuth Texas Project Technical Reference Docunent No. SAC 1 0010. "Design, Install-ation, Testirg and Inspection of Concrete Ex ansion Anchor Bolts.
It states that the approved concrete experficr. ar.chers to be used are Hilti-Kwik bolts purchased as safety reietec material and they are the only type to be used icr petriar.ert [afety related installations.
It further describes the inspection, erification and surveillance and cther aspects of construction ccedure as related to installaticn cf expansion anchors.
The SSAT revit.wed the current training program used at STP for the instruction of workers in the installation and inspection of concrete expansion anchor bolts. Training Procedure No. QCP-2,1, "Indoctrination, Training and Qualification of Quality Control Personnel to Ah51 F45.2.6 and ASME Section III, Division 2 Requirements," Revision 0, was issued on March 25, 1902. The SSAT was inforTr,ed by HL8P l
J personnel that the training program has been implemented from the Legir.ning of constructicn and the instructicn was provided by the Milti staff.
SSAT also reviewed the Procedure SSP-14 "Stud Anchor Installatien and Inspectea," Pevision 0, dated October 25, 1985, thrcugh Revision 2, dated recember 18, 1987.
SSAT reviewed CTIPS Prdule IV A "Installation and Inspection of Ccncrete Anchors" which was used as training traterial by Ebasco Construction Inc. (ECI) personnel who conducted training classes on installation of centreta anchors.
In accition, the SSAT reviewed two oroject quality assurance surveillance reports dated July 30 1984, reporting over the period of July 23 through July 26, 1984 reviewed, which describe the Hilti anchcrs drillir [dErronstrations perfonred by ECI. The reports ir.dicate thu. dril ing of concrete was supervised erd was not perforfed in a random fa ion.
SSAT reviewed FRC Inspection Report 50-498/8 13 which describes ccr.cerns regarding anchor bolts. The repor states that the NFC inspectors concerns were well fcunded. H ever, there was no notice of violaticn issued because the deficien es which previously existed had been corrected.
On January 30, 1988, SSAT interviewe the alleger, by telephene.
The alleger stated thatfapproximate yd June 1985, he noticed Hilti bolts had not been installed accor ing to the precedure by unqualified cra f tworkers. He also stated the the problems were corrected.
E.4.1.3 Cenclusion The SSAT determined that the allegation was not substantiated.
The SSAT deterrtined that the craft received appropriate training in the installation of the Hilti anchors from the manufacturer and that the QA/(C pregram ensured the adequacy of installation. The SSAT
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determined that although the forv.al training prcgrari was irtroduced in 1979 by the issuarcc c' the procedure CCP-23, "Installation of Safety Related Cor. crete Expar. sir.r. /nchor Bolts," the training cf the craft and quality centrol was initiated at the begirning of construc-ticr.
5.d.1.4 Action F.equired None 5.4.2 Threaded Fastners E.d.T.1 Characterization of Allegation It is alleged that threaded fasteners were manufactured abroa and irrported to the l'SA, ar.d they were tr.anufactured acccrding t the stardards which might have been different from the ASTM an ASPE applicable requirerrents. Two vendors were identified as upplying questionable fasteners: Lone Star Screw Company and Ca inal Indus-tttal Procucts Corporation.
/r irterview was ccr. ducted with two allegers that in icated that the fasteners of suspicious ctigin tight be fcund on e her l' nits 1 or 2 bigh pressure piping ur.d equiptrent. The allegers did not provide trore details regarding the location of questicca le fasteners.
5.4.2.2 Details The SSAT concentrated its review on three i sues:
- 1) what was the effort initiated by Bechtel Energy Cortcre icn (EEC) to verify the adecuacy of fasteners procured by Browr,
.d Root, Inc., (B&R) prior to the time when Bechtel became the Arc itect/ Engineer (A/E) in
l t, -
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19Pa, 2) what were the procuren.ent procedures folicwed by the original A/E, B&P, and 3) what are the cut rent procurenent practices by the present A/E, FEC.
I The allegations identified two suppliers, the Lone Star Screw Co.,
Inc., and the Cardinal Industrial Freduct Corporation as being i
delinquent in supplying c,Lestionable fasteners.
These concerns wereraisedalsobyBEC,duringtheturnoverrevie/prcgraand b3 the !!PC staff inspections. The BEC program d r.ct include threaded fasteners which were supplied with corr onents of materials or equiprrent, per threadeG festeners purchasep by the BEC herre office.
It concentrated en the threaded fas eners purchased by the job site.
The results of this turnover review effc t by BEC are summarized in a report entitled "Prcgram for the Veri ication of the Adequacy of -
Threaded Fasteners," dated September
, 1984, Pevision 2.
The program included:
sample testi49 of pertinent attributes of those threaded fasterers needed f construction but having incortplete decurentation; a review of docurr tation and generic concerns on threaded fasteners; engineering evaluations of potential concerns identified in the review of d unentaticr.; and a testing prcgram to determine adequacy of faster rs (used or to be used) which had inccmplete documentation a could not be corrected by the vendor.
The program review of do rnentation identified seven concerns which required further clarificatier.. These seven concerns involved three vendors.
Lone Star Screw Cortpany (Lone Star) ameng them. A generic NonComplianceReport(NCR)wasgeneratedtodocumenttheconcerns with these vendors, the one against tone Star being BM-00134 Lone Star provided the requested docunentation which resolved all but nir.e lirie itens listed on the generic f;CR written to document missing test results on Lene Star Purchase Orders (P.O.).
The issue was that
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Lone Star could not find test results f or F.C.1?035 items 40-47, (A-3C7 bolts), and prccf Ic6u tests results for P.O.14176 item 4 (A194-2H nuts). In crder to verify adequacy of these items, sarrples were sent to Coffers Laboratory for testing. Sirce all iterrs (40-47) of F.C.12035 were of the sane heat, (?07C388) only four samples needed to be tested. Out of these, item /C was tested for hardness, anc itets 41, tr and 47 for tersile strength. The SSAT reviewed Coffer Laboratories Inc. test results, #2777-83 dated July 15, 1983, (2776-83 dated July 19, 1983, a2779-83 dated July 15, 1983 and
- 2780-83 dated July 19, 1983, which provided the reguired infomation and indicate that the sartples were tested satisfa terily and in accordance with Coffer Laboratories 1983 CA Sys ms Manual, Revision 4, approved by Bechtel Power Corporation on Ju e 15, 1983.
The SSAT -
also reviewed Coffer Laboratories Test Repor No. 2781-83, dated August 1, 1983, which states that six nuts ere received for proof load testing in accordance with the specif cation ASTM-A194-8?A grade EH Heavy Hex and were found to be tisfactory after proof loading.
The S5AT reviewed a memorandurr to B.
. VcCullough dated July 26, 1983, which contained the final lis of Purchase Order line items which had been detertiiried tc be ac ptable for release to construction.
i The n+roranduni states that the re ining line items (40-47 of P. O.
1?035 and 4 of P. O. 14176) whic are currently t,eing tested will be dispositioned by NCR No. BM-001 4 Item 7 of Attachment 3 to NCR BM-00134 states that Items 40j 7 of P. O. 12035 are acceptable ar.d Item 9 states that Item 4 of f. O. 14176 is acceptable. The SSAT was j
informed that during the tife of the BEC investigation of field purchases there were some fastoners that had already been installed in the field.
Since all of the P.O.s have been accounted for and all j
cf the naterial had been found to be acceptable, the questier of whether the item is in stock or on the equipnent becorres troot.
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Parallel to the investigaticr. conducted by the field office of the adequacy of fastener s described above, BFC Engir.eerir.g also reviewed the BAR records for faster.et procurerier.t s. The SSAT detemined that the outcome of this investigaticn was that all of the rnaterial previded by Lcre Star was fcund to be acceptable with the exception of Items 53, 59 and 62 of P. O. 35-1197-0343. These items requirec additional testing and records review.
Two MCRs were written against these items. NCR BP-C3364 states that the Lone Star test reports required the nuts to be ASFE Section III, SA 194-74 Grade F6 Peavy Hex.
Mcwever,'T designation was non-existent in the 1974 ecition of ASME Code. This matter was dispost-tiened because it was found that 1974 S-76 edition o the code added -
the designation "F" to distinguish the three diffe ent chemistries for Grade 6 material. NCR BP-C27(5 sintes that ccre strip test of ICP., 750 lbs is required. SSAT reviewed the d sposition of this NCR-ar.d detern. ired that the nuts were subjected the required proof 1 cad tests and may be "used-as-is."
In cent',usion, the SSAT detern.ined that 11 Lone Star material was found to be acceptable ar.d that there s ne r.eed to charge any hardware.
The SSAT reviewed records pertinen to fasteners purchased from Cardinal. B&R purchases were mad by the field office as well as by eng'ineering. BEC's review dete.ined that there was nc rccord of any purchases by B&R of any fasten rs from Cardinal.
1 In 1984, Bechtel representatives visited Cardinal's facilities to evaluate the impact on material shipped to STP as a result of NRC staff findings relative to deficiencies with materials supplied by Cardinal.
Two questions were raised, nurely, the hardness test utilized by Cardinal (Izod irrpact rethod rather than Charpy) and stress relieving temperature beir.g belcw the minimum required. The Bechtel trip report recovmended that the above questions be subjected to an engineering evalu6 tion.
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SSAT examined NCR No. RC-00469 which contains resolution of all identified deficiencies with Cardinal raterials procured for STP.
Basically, the NPC stated that Cardinal did nct provide justificaticr for tte beat treatrent terperature used on applicable Caroir.ai Certified Material Test Report (CMTP). The material in question was narufactured by Sumitomc Shoji raisba, Ltc:., Japan, ar.d tFe temperature range listed en the CMTR was lower than that specified by the ASTP Specification for A 103-B7 (1040 degrees F vs 1100 degrees F).
Another problem ideritified was that Cardinal's Custerrer Certificaticr.s Reports stated Charpy inpact tests, had been used, but othe supportir.g documents obtair.ed by Bechtel indicated Izod irrpact test :ere utilized.
Ir *.iew of the uncertainties listed above, Bechtel deci ed to return rest of the Cardinal material to the vendor (Shipping iotice No.
2078).
Furthermore, Cardirtl was requested te prov de amended Certified Paterial Test F.epcrts (CMTR's) for the terial nct returned, ccnsisting of heat Nos. x 107E, 9723D, 9423E, 98 4D, 8724B and N6308-after the required Charpy V-nctch testing has en performed.
SSAT examined NCR BC-00469 which sisinfied accepta ce and completion of the tests by CC and also the modified CMTRs rom the Cardinal.
The SSAT interviewed two allegers to try o determir.e more specific information regarding the faulty fasten s.
The allegers infortred the SSAT that some suspect bolts have uel markings: one forgeo marking indicating the tranufacturer p d the other stamped with letter "C", indicating that they were supp The allegers providedtheSSATwithseveralexam/fedbyCardinal.
ples of fastener markings of suspicious origins. The allege also statea that the fasteners of suspicious origin might be found on high pressure piping ard equiptrent 1
on either of the two units of STP. The allegers did not provide the SSAT with any more details regarding the location of the questionable I
fasteners. The SSAT embarked on an inspection of bolts already installed in the field. Curing this effort SSAT inspected the following:
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1)
Unit I - Fuel Handling Building (FHC) a)
High Head Safety Inspection Punp (E1.-?9.0 f t) b)
Check Valve 1-SI-0002C (Train C) c)
Check Valve 1-51-00028 (Train B) d)
Potor Operated Valve (MOV) No. 1-SI-MOV-0001E e)
Figh Fead Safety Injection Valve (purp discharge) 2)
Unit II a)
Containment Charging Fun.p Flange (discharge) b)
PositiveDisplacementChargingPump(lineNo.CV2112-A-A1) c)
Heat Exchanger 3R191NAX1-01A d)
PacificCheckValve(FenetrationRoom,E[.34.0ft)
()
Containtnent - Chemical Environrent Con rol Letdcwn Feat Exchanger f)
Component Cooling Low Pressure line (E1. 57.0 ft) (Serial No.2312-3B) g)
Residual Heat Removal Exchanger Comporent Cooling Water line Train "B" (El 42.0 ft).
During the inspection, fasteners with starped letter "C" were observed by the SSAT but the forged kings specifiec by the alleger could not be found. The SSAT also i spected fasteners in field l
warehouse and found on them the mar ings from Cardinal. The SSAT determined that th fasteners we e bought by Cardinal from Guyon Alloys.
Records evie ed by the SAT indicated that heat numbers j
and NCR BC-00469 i entifie these fasteners to be from the save P.O. as those whic h been re ested because the wrong hardness test was used and a lower stress r Iieving temperature was specified.
The SSAT did not observe any deficiency in documentation reviewed.
The SSAT detennined that S P is currently embarked on a testing program of fastners in re conse to NRC Bulletin 87-02. The results of the sampling and testieng of fastners used at the STP were being
5.s Welding
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5.5.1 Weld Rod 5.5.1.1 Characterizatien of Allegation It is alleged that faulty weld rods were used in welding all over the site by all disciplines for approxirratel) six months and that the flux cn this weld red was uneven, causing "finger railing"'ard "toe nailirg". These ccr.ditions relating to arc stability c Id cause porosity ard poor quality welds.
An interview was conducted with the alleger who pr ided additional infonration in suppcit cf this aiksaticr. as indi ated below.
5.5.1.2 Cetails The elleged faulty weld red being referred was type E6013 (AWS Classification for high titania potassium cated covered mild steel welding electrodes used in the shielded n tal arc welding process).
This faulty material was alleged to hav been used under welding pro-cedure specification no. WP-167, and t have been utilized for approx-irrately six nonths to a year, from mi 1985 to late 1986. The faulty welding electrodes were rar.ufacture by Atorarc and used by HVAC and other discipline welders.
In response to the SSAT requests for infor-mation abcut specific locations where the weld rod was used and where defective welds might be located the alleger stated that it had been used in the fuel handling build ng (FHB), the mechanical auxiliary building (MEAB), reactor cont [innent building (RCB), diesel generator building (DGB), and the turbine generator builoing (TGB), at all ele-vations. The reactor containrent fan cooling system duct pctch plates in the PCB were cited as a specific locations where the faulty weld rod was used.
l The SSAT reviewed docurents relevant to the inspection of this allegs-tion including welding procedure specifications nos. WP-167 and WP-5,
4 l weld rod purchase order 3, hu. cue a ct: Froceaure SSF-30 entitled "Weld Filler Metal Control," Situation / Problem Investigation Report S-13 dated September 20, 1985, HL&P's SAFETEAM records of welding-related allegations, ar:d a list of controllea welding material refer-ence numbers. Based en the results from the review of weld rod pur-chase orders, the list of controlled welding trattrid reference r.urrbers, and welding procedure specifications nos. WP-167 and WP-5, the SSAT determined that type E6C1~. (lu u tdes had neither been purchased nor required by the specifications.
The electrode types required by WPS-167 are E6010 (high cellulose sodium covered) and E6011 (high cellulose potassium covered) while the higher strength E7018 (iron powder, low hydrogen covered) electrcde was required by WP-4. A i
review of the HL&P's SAFETEAM records and NRC Region IV i.spection reports by the SSAT did not reveal any concerns with th E6010 or E6011 electrodes.
However, several concerns had been xpressed l
regarding type E7018 electrodes manufactured by Oerlifen Welding Industries. Since the Situation / Problem Investigati n Report involving Oerlikon supplied material fell within the time fr ce that the alleger stated faulty weld red was used at STP facj lity, and the fact that E6013 electrodes appear to have never been ted, the SSAT decided to investigate the use of the Oerlikon supplied 7018 electrodes and assess the safety significance of its use.
From the SSAT review of documentation concer ing the Oerlikon E7018 welding material, Bechtel Energy Ccrporatio was found to have con-ducted an extensive audit of the manufactuffng facility of Cerlikon Welding Industries, Inc., a local supplier. After satisfactory results were obtained from the audit, Cerlikon was added to the approved vendors list.
Bechtel Eriergy Ccrporation subsequently issued purchase order no. Ido?6/BF4946 for 60,000 pounds of 3/30" diameter type E7018 welding electrode. On July '.2,198S, Bechtel received a partial shiprent of the electrodes and began issuing the this material from lot no. 10450 for field use in early August 1985.
HL&P's SAFETEAM documents show that complaints by STP site personnel of poor quality E7018 weld roa began after the early August 1985 date when the Oerlikon E7018 electrodes were issued.
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Investigation of the con. plaints by Ebasco welding personnel determined that the flux coating en some of the Oerlikon E7CIF. electrodes was not ureiformly deposited along the weld wire length and coatings were found cracked or broken. Sir.ct the #iux ccating provides shielding to prevert oxidation of the molten weld puddle, stabilizes the arc, and provides additives to produce the required material chemistry and mechanical properties, the flux coating irregularities discovered probably would have caused the ccnoitiuns noted by the a fecer.
The SSAT determined that following additional inspect ons of the material by Eechtel, Ebasco, and an Cer11kon Weldin Industries representative, it was agreed that the flux coatin on a significant number of rods in lot No. 10450 was unacceptable, thereby warranting -
return of the lot to the manufacturer.
Of the 2.000 pounds of weld material in the lot, approximately 19,000 poun were returned to Oerlikon Welding Industries in late August or early September 1985. -
In an effort to determine whether the E701E electrodes in the unaccep-table lot had been used in place of E6010 r E6011 electrodes for HVAC welding, the SSAT requested Ebasco to pr are weldrents of the same j
material used in the HVAC system with t different type electrodes, E6011 and E701P. This was conducted t ascertain the typical bead characteristics of each electrode to id in the HVAC weld inspections.
The welds made with the E7018 electr de show a smcother surface pre-file than that made with the E6011 od (see Figure _).
The SSAT conducted an extensive visual inspection of numerous welds on ducts and supports in the HVAC system in the VEAB, RCB, DGB, FHR, and the space above the control room. Although most of the welds had been painted, thereby making it difficult to fully interpret each of the weldrent characteristics, the visual inspections perfonred on the welds were sufficient to allow the SSAT to determine whether the welds were of good quality and appeared to meet design specifications and AWS Pelding Code requirements.
In addition, fourteen HVAC system support construction packages were reviewed by the SSAT for dates of
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final sign off and ccepleteness ne coniated to the Filler Paterial Issue Records (FMIR's) dates. Also, the SSAT reviewed the certifica-tions of the welders who perfornied the welds on these supports. The SSAT determined that the docurents were in order, the correct welding electrodes were issued, ard the welders were qualified to weld to both applicable welding procedures, WP-167 and WP-5.
The SSAT also determined that these weldnents had been inspected and accepted by the CC organization.
5.5.1.3 Cct:clusien The SSAT determined that this allegation was par fally substantiated g
in that a weldirg electrode problem hao existe at STP in the time frame of concern. However, the welding elect ode involved was E7018, not E6013, and the extent of the problem was not as widespread as the allegation indicated. The defective E7018 lectrodes represented only a small percentage of the total fill material on site, and corrective action had been prornptly irrp1,ented to preclude its widespread use and to identify and rt-pa r faulty welds if necessary.
Furth'ermore, the SSAT did not find any evidence of faulty structural j
welds (where E7018 is used) during i inspection of STP.
5.5.1.a Action Pequired None 5.5.2 Weld / Welder Identification Traceability E. E. T. 1 Characterization of Allegation j
It is alleged that welds were not stamped with the welder identifica-tion number at the time of completion but stairped later by welders who had not perforrad the welding and that the procedure for identify-ing welders who perfonred welds does not allow for traceability.
J
1 An interview was conducted with the alleger who provided additional j
information, as indicated belcw, in support cf this allegation.
j 5.5.2.2 Petails The alleger identified the concern to be with the structural welding in the HVAC system. Specifically, the FVAC welding in/the mechanical and electrical auxilicry tuilding (FEAB) was suppose to have instar.ces where completed welds did nct have the proper welde s' identifictticr.
stamps affixed.
If the construction ttaveler pack ges did net indicate that the welds h&d been accepted by (C, he welds were ground out and the structure rewelded.
Powever in some instances, welds were stamped with welders' identificatic stamps according to filler material issue records (FMIRs) used to ocument the withdrawal of weld rod from an issuing station. Accord g to the alleger, welders' identification symbols were stamped on weld by matchir.g the dates on the FMIRs to dates that welders worked in e areas of the bnstamped welds. Thus, it was alleged that the righ stamp was not necessarily placed on the right weld. The time peric cited by the alleger was between late 1983 to 1986.
The SSAT found from the records of HL&P's SAFETEAM investigations j
that eight cases of alleged loss of we,1d/ welder identification trace-ability had been documented during the time period cited by the allegers. TheSSATreviewedNRCRe/onIVInspectionReportNo.
50-498/86-38 that documented the fi dings of investigations perforred by the HL&P's SAFETEAM and fcund t at problems with quality control l
procedures for inspection of structural steel had existed in 1984 As noted in the inspection report, the quality control procedures at that tirne required each QC inspector to perform two in-process inspections per day and all final inspections of completed work.
However, due to the thirty-to-one craft-to-inspector ratio that existed, considerable delays in QC inspections may have also contri-buted to allowing the condition to take place and to the delay in the prcept icentification of this situation.
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wnrenEmm1M 7
A0TICE 0,,f, f118,3,, QOR!,11ggqt For More Inforce sion N ADWRY C0;.:...,,,,,,;
mithe Public Citisen U8W AFFAIRS i
p b M % ILXA3 512/477-1155 tiehard Condit. IAF e-202/2J2-dS50 Whe 805 JECT Is Ths tou th Texa s !1uclea r Projec t 8 ate Enough to Opera te ?
A report to Texans by the Government Accountability Projac t on the signifiestee of the esarly 400 emfe ty allega tions made by Whistleblowers.
N 1
p w= -
% C,A 5555:
1:00 - 2:00, March 2, 1984
,~
t VIERS:
The Speakers commi t tee Room, S ta te capi tol 8PEAKERE:
h tillia Garde - an a t torney wi th' the Gove rnmen t i
Accoun tabili ty Projec t.
She has represented workers at seventeen other troubled nuclear plants across the country.
Edna O t tney-an inves tiga tor f or the Government i
Accountabili ty Projec t a t the Sou th Texa s Plan t. S he has worked as an inves tiga tor a t four plants and as a quality assurance i
engineer a t two nuclear plants. Whila employed se a quality assursace engineer a t the Clinton, tilinois plan t, she vtote the program the t ves used for a comple te review of all documenta tion and the "w alkdown" used to a ssu re tha t the plan t w a s sa f e enough to operate.
TOPICS Tot. O!8CUS$10N The significance of the nearly 400 allega tions regarding saf e ty made by the 56 whistleblowers about the South Texas Nuclear Plant.
e C AP'S a t te mp ts to se t the Nuclea r Regula tory Commission to f ully inves tiga te these allega tions.
W by the N kC* s recent inves tiga tion of the se alleg,a tions was not adequate. Their invat tiga tion took only four days and they only looked a t 60 of the allags tions.
W hy they bellsve the NRC should be required to 40 4 f ull relaves tiga tion of all of the sa f e ty silega tions a t the plant and should be requirad to make a public report prior to licensing.
( A vo te is currently scheduled for March 10, 1988.)
MOTICE This press conference will follow an indepth briefing for Congre e sional and 1,agis ta tive e tp t t the t wtil be held from 9:00 to 11:30 A.M., M a rc h 2, in Room tot of the Reagan building.
Fre e e a re invi ted to a tiend dep th review of the allega tions.the ea rlie r briefing f or a more in-A sustary of the allega tions is on the reverse of this shee t.
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l NOV SgtIOUS Att THE ALLt0AT19N8 ?
The aTieja7t oiis~1nclud e s
- creek in the floor of the fuel handling building
- wilitui aover-ups of serious design, hardwere, and documente tion discrepanetes
- coun terf eit f as toers the t do no t see t e tross th and hea t specifica tions
- valves and piping are L aproperly ins talled and
!apossible or dif ficult to use in emergency situa tions interfering with, harassing, firing
.or intimida ting workers who a ttempted to report estety concerns to their superiors or to the NEC
- contings designed to pro.tect workers froa 4xposure to radia tion are flaking off or eracked pipe joints and welds may no t be adequa te q ua li ty of cer tain velds in doubt MANY OF THE ALLEGATIONS CONCERN COST Oyttt0N8 tutsr. ALLT5U1085 INCLo6TT in tentional sisrepresen ta tion of quantities cf as terials ins talled, ntedless scrapping of ove r $ 39 6,000 worth of useable ma te rials, equipment installed out of order causing co m ple te d vock to have to be ripped out to ins tall equipment, contractors cloised inaceplete work was comple te and turned it over to H.L.6 P.
as finished.
This will allow f or worked needed to compie to the plast to be billed to the partners as opera ting and maintenance cos ts vhich are subject to avah less regulatory scrutiny, inaccura te count of hours on specifia jobs, hanging "siles" of hea ting ventitetton and air conditoning ductwork tha t la ter had to be tors out because equipment that should have been ins talled' firs t uas not.
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