ML20203P201
| ML20203P201 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/02/1986 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 8605060394 | |
| Download: ML20203P201 (35) | |
See also: IR 05000498/1985021
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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May 2, 1986
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MEMORANDUM FOR:
E. H. Johnson, Director
Division of Reactor Safety and Projects
Region IV
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FROM:
J. G. Partlow, Director
Division of Inspection Programs
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Office of Inspection and Enforcement
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SUBJECT:
ASSESSMENT OF IMPLEMENTATION OF THE NRC INSPECTION
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PROGRAM BY REGION IV AT SOUTH TEXAS PROJECT
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The Office of Inspection and Enforcement described to the Commission in SECY
82-150A the assessment of the implementation of the NRC inspection program in
conjunction with Construction Appraisal Team (CAT) inspections.
Accordingly,
we have examined Region IV's implementation of the construction inspection
program based on the October-November 1985 CAT inspection at the South Texas
Project.
The results of the inspection were documented in Inspection Report
50-498/85-21 and 50-499/85-19 dated February 5, 1986.
The enclosure to this
memorandum documents the results of our assessment of the construction
inspection program implementation.
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J. G. Partlow, Director
Divis ion of Inspection Programs
Offic'e of Inspection and Enforcement
Enclosure:
Assessment
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J. Taylor, IE
R. D. Martin, Region IV
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REGIONAL CONSTRUCTION INSPECTION
PROGRAM ASSESSMENT - OUTLINE
FOR SOUTH TEXAS PROJECT
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I.
Objective
II. Assessment Activities
III. Assessment Findings
A.
Discipline Areas
1.
CAT Findings
2.
Assessment
3.
Recommendations
IV.
Review of Inspection Reports and 766 Hours
A.
Scope
B.
Assessment
C.
Recommendations
V.
SALP Reports
VI. Overall Assessment Conclusions
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REGIONAL CONSTRUCTION INSPECTION PROGRAM
ASSESSMENT - SOUTH TEXAS PROJECT (R-IV)
I.
OBJECTIVE
The objective of this assessment is to evaluate Region IV's implementation
of the Light Water Reactor Inspection Program-construction Phase (con-
struction inspection program) and to make an overall assessment of the
adequacy of Region IV's oversight of construction activities at the South
Texas Project site.
The Construction Appraisal Team (CAT) of the Division of Inspection
Programs conducted an announced construction inspection at the South
Texas Project (STP) Units 1 and 2 during the period of October 21-November
1 and November 12-22, 1985.
While the predominant effort of the inspec-
tion team was devoted to hardware inspection, the team also evaluated the
control of design changes and corrective actions.
The Executive Summary
and Potential Enforcement Actions of the STP CAT inspection report
(50-498/85-21 and 50-499/85-19) are provided as Appendix A and Appendix B,
respectively.
II. ASSESSMENT ACTIVITIES
A review was made of Region IV inspection reports, SALP reports, and
construction deficiency reports related to STP, to identify those defi-
ciencies that were previously identified by Region IV. inspectors or the
licensee.
The review included applicable open items and violations, and
SALP reports for the periods ending November 30, 1983 and June 30, 1985.
The regional inspection effort at STP was determined through a review and
analysis of inspection reports and the 766 Computer System inspection data
for the period of 1979 through September, 1985.
The overall and 1985
manhours of direct inspection effort at STP Unit 1 were also compared to
other sites in a similar stage of construction.
III. ASSESSMENT FINDINGS
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A.
Electrical and Instrumentation Construction
1.
CAT Findings
It was noted that a number of raceway installations did not
meet the licensee's FSAR commitment for spatial separation.
Although originally identified by the licensee in 1984, the
procedural and administrative controls have only recently
been developed.
Cable and termination installations were generally found to
be in accordance with design requirements with the excep-
tion of some isolated deficiencies.
However, several
construction practices were identified to have the poten-
tial for cable damage.
The color of a number of cables was
also found to have faded, complicating divisional identifi-
cation.
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Load-side terminal extensions on a number of molded case
circuit breakers in Class 1E motor control centers were
found to have the potential for circuit interruption or
phase-to phase faulting.
Numerous hardware deficiencies and a lack of design change
control were identified in the wiring of Westinghouse
supplied motor operated valves.
Numerous deficiencies were identified in a limited sample
of instrumentation installations.
2.
Assessment
Problems in the area of electrical separation have been
identified by the NRC CAT at numerous plants and have
resulted in the issuance of IE Information Notice 85-11.
The licensee first documented electrical separation prob-
lems at STP in May 1984.
A review of the region's inspec-
tion reports indicated that the inspection requirements for
raceway installations have not yet been completed.
The region's and CAT's inspection findings for cable and
terminations are consistent .
The fading of cable jacket
color was previously identified by the region.
The region's work observation inspections for installed
electrical equipment have so far been limited to the
internals for control room cabinets and the mounting of a
cabinet in a switchgear room (inspection report 50-498/
85-04).
Their findings in these areas are also supported
by the CAT findings.
The region's inspection reports document very little effort in
the inspection of instrumentation construction.
This is
primarily due to the lack of construction in this area as
documented in the SALP reports 50-498/499/83-26 and
50-498/499/85-12.
3.
Recommendation
The region should continue with their routine inspection program
in the electrical construction area and schedule the continuance
of inspections for instrumentation construction.
Regional
inspection emphasis should be on areas of construction found
deficient during prior regional inspections and the CAT
inspection.
It is also recommended that special attention be
given to monitoring the licensee's deferred program for assuring
adequate electrical separation.
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B.
Mechanical Construction
1.
CAT Findings
The NRC CAT inspection for the area of QC accepted piping
installations identified a number of hardware deficiencies.
These are as follows:
The CAT inspectors identified six lugged wafer valves in
the Unit ; essential cooling water system in which hex-head
cap screws in the flange to valve joints were shorter than
required, and identified other similar type valves for which
threaded studs and nuts had been substituted without documen-
tation.
Two annubar flow probe mounting flanges were mislocated with
respect to the distance from the pipe outer wall, based on
the installation dimensions supplied by the vendor.
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Only two pipe supports / restraints were found with deficien-
cies; one with pipe clamp to horizontal member clearance
discrepancy and the other with an undersize strap.
The NRC CAT identified a number of programmatic / procedural
weaknesses, as well as inadequate QC inspection, in the area of
mechanical equipment installations.
They are as follova:
Several discrepancies were noted in the reassembly of Unit 1
pumps:
containment spray pump B, low head safety injection
pump 8 and high head safety injection pump B.
Six HVAC mechanical equipment components inspected had
several discrepancies.
Some are as follows: missing and
undersize welds, unshimed foundations, and improper concrete
expansion anchor embedment to concrete cored holes.
Reactor water makeup tanks specified ring of cushion material
(FLEXCELL) had been removed after QC acceptance of tank's
installation.
2.
Assessment
The routine inspection under IP 37051 for sampling whether
hardware installations meet design requirements is scheduled
in the inspection procedure for implementation at one year
prior to OL.
It is likely that regional inspectors would
have identified similar piping installation deficiencies to
that found by the NRC CAT during their implementation of the
IP 37051 inspection.
Also, it is noted that, according to
766 data (see Attachment II), no inspection time was recorded
for several modules in piping and mechanical components
areas.
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The general programmatic / procedural weaknesses, as well as
inadequate QC inspection, in the area of rcechanical equipment
would likely be identified through implementation of the
followup Phase II (before work is 60% complete) construction
inspection procedures. However, to date the region has only
completed the initial (before work is 20% complete) inspec-
tion of safety-related components. As the initial inspection
in this area does not present the opportunity to include an
adequate sample of the licensee's completed mechanical
equipment hardware installations, the mechanical equipment
discrepancies noted by the NRC CAT could not have been
readily identified by the region's inspections conducted to
date.
SALP Report 50-498/499/85-12 rated as Category 2 the three
mechanical areas. This rating is consistent with the NRC
CnT's conclusions in the mechanical areas of piping systems
and supports, and HVAC.
In the area of safety-related
components the rating of 2, although consistent with the
results of region inspections conducted for that period in
the area of the storage and preservation of components, is
considered inconsistent with the NRC CAT's inspection find-
ings for the installation of safety related components.
3.
Recommendations
The construction inspection program is determined to be adequate
if implemented in a timely manner.
DI/RCPB will evaluate the
need for enhancement of inspection requirements or guidance
relative'to licensee's programs for the installation and inspec-
tion of mechanical equipment.
Region IV will need to review the
status of completion of the inspection program for mechanical
equipment and also follow the licensee's corrective actions for
mechanical equipment and other CAT findings.
C.
Welding - NDE
1.
CAT Findings
The NRC CAT inspectors identified undersized socket welds on 2-
inch schedule 160 piping and found that vendor procured tanks
and heat exchangers were accepted and installed with deficient
In addition, some vendor supplied radiographs did not
have the required weld and film quality.
The team also
encountered difficulties in retrievability and location of
vendor NDE film and documentation pertaining to the Balance of
Plant scope of supply.
In addition, the licensee subsequent to
their discovery of missing radiographs for the reactor head,
required only the Nuclear Steam System Supplier to take correc-
tive action and did not address the other vendors.
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2.
Assessment
Based on the 766 Computer System Data, the region has not
implemented a number of the construction inspection proce-
dures in the area of welding.
See Attachment II.
The undersized socket welds were found in 2-inch schedule 160
piping.
This piping size was relatively small in quantity
when compared to other piping sizes and may not have been
in the region's inspection sample.
3.
Recommendation
The construction inspection procedures fcr this area are deter-
mined to be adequate and a schedule for implementing remaining
welding procedures should be established.
An IE Information
Notice has been issued relating to the tank and heat exchanger
weld problems.
It is also recommended that the region review
the licensee's program to ensure the identification of welding
and NDE requirements, and the existence and location of vendor.
documentation for this area.
The region should also followup on
the applicant's rework and inspection of the installed 2-inch
schedule 160 piping with undersize welds.
D.
Civil and Structural Assessment
1.
CAT Findings
A seismic separation space in the Unit 2 tendon access wall
at azimuth 302 and elevationL13 ft 3 inches was found
omitted.
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Structural steel sliding connections were found to have
bolts installed too tight.
In addition, site inspection
procedures for sliding connections were inadequate.
Cross flange welding on fully loaded members without
engineering evaluation appears to be allowed in the project
specifications.
It was not demonstrated th'at the A clay layer beneath the
2
essential cooling water (ECW) pipes would not swell and
cause overstressing of pipes once the site dewatering system
is discontinued.
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It was not demonstrated that the concrete expansion anchor
bolts with an a110wable 1/16 inch slip were adequate to
support Class I piping ^or equipment.
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2.
Assessment
A review of the regional inspection reports found that a number
of the CAT findings, such as noted,above,
had not been pre-
viously identified by the'regiorai office.
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It was noted that, according to 766 data (see Attachment II),
no inspection time was recorded for structural concrete modules
47063B and 47065B.
It is not apparent that the region's inspection sample included
a review of the concrete expansion anchor (CEA) qualification
test reports.
However, the inspection of CEA qualification test
reports is not emphasized in the construction inspection program
procedures.
3.
Recommendations
The inspection procedures in the areas of geotechnical/
foundations, structural concrete, and structural steel are
considered adequate.
Region inspections did not identify a
number of the CAT findings.
However, DI/RCPB will review the
need to include a more definitive inspection requirement for
review of cross flange welding without engineering evaluation,
clay swell once dewatering is discontinued, and CEA qualifica-
tion test reports.
Region IV will need to follow the licensee's
corrective actions for the resolution of NRC CAT findings.
Region IV should have devoted a portion of inspection work to
IPs 470638 and 47065B when those IPs were in force.
E.
Material Traceability and Control
1.
CAT Findings
Lack of traceability was found for fastener materials for
certain large vendor supplied mechanical and electrical
equipment assemblies mounted on skids and for certain
electrical equipment and cable tray and conduit supports.
Also, documentation to permit verification of traceability
of fasteners for certain equipment was not located by the
licensee during the inspection.
2.
Assessment
The large number of fastener problems found by the NRC CAT
regarding fasteners furnished with vendor supplied equipment,
not previously identified by the region, may indicate a weakness
in the construction inspection program.
The following NRC regional activities indicate reasonable
inspection of traceability aspects, except for fasteners on
vendor supplied equipment:
In several inspection reports in 1982 and 1983 the site was
noted to have severe problems in control of anchor bolts and
embedded items.
Several NRC violations and unresolved items
were issued.
STP inspection report (IR) 50-498/499/85-05 indicates that
the control and traceability of weld filler material was
satisfactory.
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In STP IR 50-498/499/85-04 material traceability was
verified as satisfactory in the three areas of Reactor
Vessel Internals, Electrical Cable and Equipment, and Fire
Protection system.
In STP IR 50-498/499/85-06, traceability concerning HVAC
systems, concrete, and spent fuel racks was found to be
satisfactory.
In STP IR 50-498/499/85-10, the resident inspector's report
on concrete and anchor bolts records did not identify any
traceability findings.
In STP IR 50-498/499/85-15, open item 85-06-03 on lack of
traceability for components of spent fuel racks resulted in
a Level IV violation.
3.
Recommendations
The construction inspection program and its implementation in
this area is determined to be adequate.
The NRC regional office
should review licensee corrective action activities to rectify
the mechanical bolting problems, particularly to assure that
fasteners for mounting vendor supplied equipment are of required
material and are traceable. Also, the region should monitor
licensee's program to correct the problems associated with the
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deletion of specification requirements for marking of bolting
used in the electrical area.
F.
Corrective Action Systems
1.
CAT Findings
The licensee's corrective action program was found to be
generally acceptable, with some exceptions.
The licensee's
program did not:
Prevent or identify the problem with material traceability
of fasteners furnished with vendor supplied equipmeit.
Address the need to assess and evaluate damage to equipment
due to past deficiencies in preventative maintenance and
incorporate such considerations into operational main-
tenance programs.
Recognize the need to conduct a reasonable quantity of
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audits of actual radiographs of both field welds ar.u <endor
supplied welds.
Also, failure of audits or correctik
actions to assure that vendors required to supply radio-
graphs were readily identified and that the location of
radiographs and records were known and readily retrievable
as required.
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Identify the need for timely and effective corrective
action activities for certain electrical items:
motor
operated valves and motor control centers.
Result in the effective application and control of " HOLD"
tags on nonconforming material and equipment.
2.
Assessment
The construction inspection program was determined to be ade-
quate.
In general, the NRC CAT found that satisfactory proce-
dures were in place for corrective action systems.
The following NRC regional activities indicate reasonable
monitoring of the licensee's corrective action system.
In STP inspection report (IR) 50-498/499/85-06, the Region
IV resident inspector reviewed the Deficiency Reporting
System concerning 50.55(e) matters.
Logging, forms,
sequencing, time elements and general processing to the NRC
was evaluated.
No discrepancies were noted.
In STP IR 50-498/499/85-10, the Region IV resident inspec-
tor reviewed the Construction / Engineering Deficiency
Reporting to 50.55(e).
All reported items from January 1,
1984 to June 30, 1985 were evaluated in detail.
The
procedures, reporting methods and time, evaluation and
corrective action were evaluated and found to be adequate.
Additionally, 115 IE circulars, information notices and
bulletins were evaluated for corrective action and closed.
In STP irs 50-498/499/85-04, 85-06, 85-10 and 85-13 the
resident inspectors evaluated unresolved items, violations
and open items from previous reports for corrective action.
In STP inspection reports generated in 1982 and 1983
approximately 25 unresolved items and violations were
persued by'NRC concerning anchor bolts and embedded items.
The region indicated that an extensive report concerning
the licensee evaluation of these items has been generated
and is awaiting review by Region IV inspectors.
In STP IR 50-498/499/85-07, the Region IV inspector veri-
fled corrective action on six nonconformance reports, all
of which were noted as satisfactory.
3.
Recommendation:
The construction inspection program in this area is determined
to be adequate.
The region should assure that the licensee
reviews areas of identified problems including fastener
materials, preventive maintenance, NDE records, wiring changes
and " HOLD" tags for determining cause and appropriate corrective
action to prevent recurrence.
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G.
Design and Design Change Control
1.
CAT Findings
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A lack of effective design change control between the
architect / engineer (AE), the nuclear steam system supplier
(NSSS) and the organizations performing the physical work
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was identified.
This was evidenced by the inability of the
licensee to provide a design baseline wiring drawing for
NSSS supplied motor operated valves (MOVs), the AE's
revised designs not being provided to the NSSS for their
review and incorporation into NSSS drawings, and the
inability to correlate the actual wiring with current
design documents.
Vendor tolerance requirements for the mounting dimension of
the annubar flow probe on essential cooling water piping
were not included on installation drawings and subsequently
a number of annubar mounting flanges were mislocated with
respect to the distance from the pipe outer wall.
Deficiencies were found in the control of modifications
being made to change documents upon their incorporation
into the design drawings.
Six Field Change Requests and
one Drawing Change Notice were modified upon incorporation
into the design drawings without being adequately reviewed,
approved and documented to reflect changes in technical
content or scope.
The undocumented use of engineering judgment in lieu of
explicit or generic calculations for ensuring the adequacy
of design in certain design change documents was identified.
The licensee could not provide calculations or documented
engineering judgment to substantiate the design adequacy of
the addition of four bays of structural steel detailed on the
November 5,1984 revision of 8echtel Drawing No.
Conflicting definitions for configuration control packages
were identified in issued revisions of governing procedures
of the AE and construction organizations (Bechtel, EDP 4.72
and WPP-22.0, and Ebasco, ASP-17).
The controls for posting unincorporated design changes on
design documents were not adequately implemented at one
reference station.
2.
Assessment
The 766 Computer System Data reports for the South Texas
Project do not show any hours expended against inspection
procedures (IPs) 37051, 370518, 37055 and 370558 and may be
in error based on our review of the region inspection
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reports.
Some hours were expended in 1982 during the AE
(B&R/Bechtel) transition period against IP 379958 " Design
Inspection".
A limited review of the South Texas Project irs from IR
50-498/83-10 thro w IR 50-498/85-16 identified the following
items related to the CAT inspection findings:
IE 50-498/83-26 (SALP) stated that HL&P identified a
held document control problem and took corrective
action.
IR 50-498/84-07 stated that NRC inspectors identified
field document control problems.
IR 50-498/84-08 stated that NRC inspectors identified
discrepancies between Westinghouse requirements for
subvendor components and those stated in the subvendor
manuals.
IR 50-498/85-06 stated that NRC inspectors checked
document control stations and found no discrepancies.
IR 50-498/85-12 (SALP) stated that three inspections
were held during the p elod December 1, 1983 through
June 30, 1985 which indicated that there was improve-
ment in the Design and Design Change Control process.
The inspections concerned the issue, distribution, and
recall of documents.
3.
Recommendations
The region should review the 766 Computer System database to
determine if it accurately records the inspection hours expended
in the areas of design document control, design, and design
change control. Also, the region should consider increasing
their inspection effort in the area of design change control for
areas of identified deficiencies.
The IE inspection procedures
are adequate in the design change control area.
IV.
REVIEW 0F STP INSPECTION REPORTS AND 766 HOURS
A.
Scope
The resident and regional inspection reports through September 1985
(report 50-498/499/85-16) were reviewed for conformance to MC 0610
and 0611 requirements.
They were evaluated to determine whether they
include the required information, were sufficiently comprehensive,
and were issued in a timely manner.
The inspection hours reported against STP Unit 1 under the MC 2512
program were reviewed.
The reports from the 766 Computer System
used in this evaluation included hours from inspections completed as
of September 27, 1985 and reported to the 766 System as of January
16, 1986.
For the purposes of this review the hourt, were adjusted to
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exclude module hours which are not a part of the Phase 2 construction
inspection program.
This consisted of almost 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> reported
against modules 37995 (design inspection) and 41990 (training).
However, it is apparent that most of this time was expended in the
region's overview of AE activities during the transition from Brown &
Root to Bechtel.
The inspection hours for 1985 (January through September) and for
the plant history (1975 through 1985) were compared to several other
sites.
These comparison sites were chosen based on their similarity
to the South Texas Project.
All the sites are PWRs and are either
single units, the first unit of multiple units or are sufficiently
different from their first unit to be considered a single unit.
The
estimated stage of completion for the sites are between 85 and 90
percent.
B.
Assessment
The 766 Computer System data for South Texas Unit 1 shows that a
total of 7159 hours0.0829 days <br />1.989 hours <br />0.0118 weeks <br />0.00272 months <br /> have been recorded against the MC 2512 construc-
tion inspection program procedures since January 1975, with 1757 of
these hours expended between January through September 1985.
A
comparison of hours for STP Unit 1 and five other sites is illus-
trated on Attachment I and indicates that, although the STP hours for
1985 are close to the average, the total plant hours are approxi-
mately 20 percent below the average for all six facilities.
The review of MC 2512 inspection procedures required to be imple-
mented and the inspection hours recorded by Region IV indicate that
the inspection program's completion status is not commensurate with
the reported stage of construction of STP Unit 1.
Eighty-two proce-
dures are 50 percent or less complete with no hours reported against
41 of those procedures.
This compares to the reported stage of
completion at the site of 87 percent.
However, the reported comple-
tion may not be an accurate estimate of the actual completion status
which the region considers to be less. A summary of the total number
of procedures used by the region in implementing the construction
inspection program and a breakdown of hours into discipline areas are
shown on Attachment II.
Attachment II also identifies the 41 inspec-
tion procedures by area for which no inspection hours have been
recorded.
In addition, Attachment III shows the total number of
inspections and reported hours for each inspection procedure of MC 2512.
A review of the program priorities and schedule for implementation
of the 41 inspection procedures with no hours reported in the 766
Computer System data file was performed to provide further clarifi-
cation of the implementation status of these procedures.
The review
found that only 28 of the 41 inspection procedures can be considered
some what late in their implementation as the windows for initiation
of inspection for 13 procedures have not been missed. A further
breakdown of these procedures as related to areas of construction
are:
Geotechnical - 1 IP, Structural Concrete - 2 IPs, Piping - 6
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IPs, Mechanical Components - 3 IPs, Electrical and Instrumentation -
3 IPs, Welding - 13 IPs.
The individual procedures are identified in
Attachment II.
A further review shows that 6 of the 13 welding and NDE procedures
for which no hours are recorded are from the 550XX series of proce-
dures which were superceded in 1979 by the 551XX series of proce-
dures.
However, only the welding requirements were superceded and
the NDE requirements of the 550XX procedures remained as MC 2512
inspection items until the current welding procedures (55050, 55100)
and NDE procedures (57050, 57060, 57070, 57080, 55090) were issued in
June 1983.
Two thirds (almost 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />) of the total welding and
NDE inspection effort was conducted and reported by the Region I NDE
van inspection in 1984 (report 50-498/499/84-02) against the current
procedures.
Subsequent regional inspections for welding and NDE have
also been reported against the current program requirements.
The
region is currently reevaluating the outstanding program inspection
requirements to assure that they will be sufficiently performed.
Six of the inspection procedures which should have been initiated
with no hours reported are in the piping construction area.
The
region has indicated that when originally scheduled, qualified
inspectors were unavailable or assigned to higher priority projects.
The region has currently rescheduled these requirements and has begun
inspections.
Discussions with the region on outstanding inspection procedures
indicate that a large effort was devoted to followup on 50.55(e)
reports and reactive inspections and not charged against the routine
inspection program, although the inspections were applicable. A
comparison of the hours charged against the followup procedures as a
percentage of the total effort bears this out.
Although followup
averages only 20 percent of the overall inspections at several
similar sites, it is almost 30 percent of the total effort at STP.
This is also evident in several inspection reports (50-498/499/84-08
and 85-06) which discuss design and design change inspections as
followup to previously identified items. We agree that there are
instances where some credit for followup inspection effort could be
taken for fulfilling routine construction program requirements in
specific areas.
However, some additional inspection effort, beyond
followup effort, is required to fully meet the intent of a particular
inspection procedure.
The region should review this matter to ensure
that the appropriate blend of procedure inspection and followup
efforts have been applied to specific program areas to provide
reasonable assurance that the hardware is acceptable.
It is acknowledged that the implementation of the inspection program
at the STP site was impacted by a set of unique circumstances.
This
included a change in the AE and Constructor and several work stop-
ages, causing the region to conduct inspections under the extended
construction delay procedures from November 1981 through January
,
1983.
In addition, Region IV had four plants in NTOL status in 1984
and 1985, including two sites with extensive Technical Review efforts,
which required a great deal of region resources.
This necessitated
reassigning a resident inspector from STP to one of the NT0L sites
-12-
,
.
for a period of time.
The region indicates that as resources are now
becoming available, it will be able to emphasize the continuation of
the routine construction inspection program at STP.
A breakdown of inspection hours into the three main procedure areas
(procedure review, work observation, and records review) indicates a
majority of effort was expeaded in performing the work observation
modules.
Forty-eight percent of the total inspection time in these
three areas was spent on hardware inspection.
This emphasis on
hardware inspections is consistent with the current policy of the
construction inspection program.
A review of the inspection reports written by resident and regional
inspectors indicate that they are well written, clear and concise,
and sufficiently document findings.
The content and format of the
reports meet the requirements of MC 0610.
Although the inspection
procedures are not specifically identified in the reports as sug-
gested by MC 0610, the section titles are generally descriptive
enough to indicate which module has been used.
The review of the 1985 inspection reports found that the average time
to issue a report (last day of inspection to transmittal letter date)
is triple that of the MC 0610 requirement of 20 days.
The days to
issue 1985 reports ranged from 17 days (85-04) to 145 days (85-01),
averaged 63 days and are illustrated in the chart below:
Report No.
Inspection Office
Days to Issue
85-01
Resident
145
85-03
Resident
121
85-04
Resident
17
85-06
Resident
53
85-07
Region
55
85-10
Resident
27
85-13
Resident
46
85-16
Region
40
AVERAGE:
63
Discussions with the region indicate that turnover in personnel and
problems with electronic transfer of documents contributed to this
problem.
The region has also instituted new deadlines for submission
of reports by inspectors and is currently tracking this item.
In addition, the region began performing the proprietary review
in-house and eliminated the proprietary review statement from the
report transmittal letter.
This is commensurate with MC 0611
requirements.
C.
Recommendations
The region's current awareness of the status of program completion
and further plans for evaluating and completing remaining inspection
requirements, along with the increased inspection resources for STP,
should assure that the program is adequately completed.
-13-
.
.
.
fhe region should review the blending of routine inspection effort
and followup effort to ensure that the intent of inspection
procedures is covered and that the hardware is acceptable.
The high quality of the inspection reports themselves is expected
to continue.
The actions now being taken for issuing inspection
reports should resolve the timeliness problem in this area.
V.
SALP REPORTS
An analysis was made of the most recent SALP report (IR 50-498/85-12,
50-499/85-12) for the period December 1, 1983 - June 30, 1985. Generally,
the SALP report reflec% mostly Category 2 ratings with Category 1, ratings
for Training, Corre:.cive Action Reporting and Design and Design Change
Control.
However, the SALP report did not rate Instrumentation and
Control Systems and Pre-operational Testing due to limited construction
activities in these areas.
The previous SALP report for the period December 1, 1982 - November 30,
1983 indicated Category 1 performance for Piping Systems and Supports,
Electrical Power Supply and Distribution, and for Licensing Activities,
and the most recent SALP report as noted above indicated a decreased
performance to Category 2 in these areas.
This decrease appears to be
generally in agreement with the CAT findings.
The most recent SALP report for the period December 1,1983 - June 30,1985
indicated improved performance for the following arean
Previous SALP
Most Recent SALP
Material Control
3
2
Corrective Action and Reporting
3
1
Design and Design Change Control
2
1
NRC CAT examinations for material control included a broad sample of
various types of plant hardware.
The resulting CAT findings were, in
most part, limited to uncertainties regarding the material traceability
of fasteners used in mounting equipment and electrical raceway installa-
tions.
This uncertainty was generally due to the lack of required
fastener markings and/or documentation for verifying fastener trace-
ability. The broad sample of hardware examined by the NRC CAT, would
support the 2 rating for this area.
The NRC CAT findings do not support the number 1 performance rating for
Corrective Action and Reporting.
This is due to failure to identify,
perform and rerert corrective actions required for problems with material
traceability r.f fasteners, deficiencies in prevertive maintenance, and
certain electrical items.
In regard to the area of Design and Design Change Control, the NRC CAT
findings do not support tne assigned Category 1 rating for this area.
Thic is primarily due to the significance of the NRC CAT findings relative
to wiring changes to motor operated valves, modification of design changes
on their incorporation into design drawings, and the absence of documenta-
tion of calculations to support tho technical adequacy of the design
change addition of four bays of structural steel.
-14-
.
.
The previous and present SALP report assigned a performance rating of 2
for the area of Quality Program and Administrative Controls.
Additional-
ly, the licensee's performance was noted as generally improved over the
course of the SALP assessment period.
However, the NRC CAT findings, in
aggregate, are an indication that further improvement in the trend for
direct management attention and involvement in the construction for the
STP is warranted.
VI.
OVERALL ASSESSMENT CONCLUSIONS
The implementation of the construction inspection program at STP is
generally adequate.
The CAT inspection findings were generally in agree-
ment with and supportive of the regional inspection findings in most
construction areas.
It is recognized that the CAT inspection sample in
various areas was large relative to the normal region samples, and that
the CAT might discover findings that were not covered by the smaller
region samples.
However, the CAT did identify a number of different
concerns in the area of civil and structural canstruction, where the
region's inspection program is essentially complete.
The CAT also identi-
fied some weaknesses in the mechanical construction area which the region
did not identify during their inspection of the construction in this area.
The regional inspections that have been performed appear to have been
thorough and their reporting has been detailed and concise.
The inspec-
tion emphasis on hardware is consistent with the current program policy.
However, the completion status of the program does not correspond to the
reported stage of completion of construction for the site.
This apparently
is partly due to the previous assignment of inspection resources to other
regional NT0L priorities and the region's schedule for program completion
based on the view that the licensee's estimate for completion of site
construction is optimistic.
The region's current reevaluation of the
status of program completion and rescheduling of inspection requirements
should assure the completion of the remaining elements of the construction
inspection program.
The CAT findings also support the most recent SALP evaluation in the
areas of Piping Systems and Supports, Electrical Power Supply and Distri-
bution, and Licensing Activities.
However, they do not support the
imoroved performance indicated for Corrective Action and Reporting and for
Design and Design Change Control.
!
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t
APPENDIX A
EXECUTIVE SUMARY
-
An announced NRC Construction Appraisal Team (CAT) inspection was" conducted at
Houston Lighting and Power's South Texas Project (STP), Units 1 and 2, during the
period October 21-N)vember 1 and November 12-22, 1985.
I
OVERALL CONCLUSIONS
,
Hardware and documentation for construction activities were generally in
accordance with requirements and licensee commitments.
However, the NRC CAT
did identify a number of hardware deficiencies that in most cases have resultd
from construction program weaknesses. These include:
,
,
.
1.
A lack of effective design change control between the architect / engineer
(AE) and the nuclear steam system supplier (NSSS) which has resulted in
the inability to correlate the actual wiring configuration of valve motor
'
operators with design.
The actions taken for prior site organization
-
audit findings involving the adequacy of AE/NSSS design interface of the
wiring design in another area also indicate a weakness in the applica-
tion of corrective action measures.
In addition, a significant number of
hardware and workmanship deficiencies were identified with the wiring of
motor operated valves.
'
2.
Significant deficiencies in the configuration of Class 1E molded case
circuit breakers with load-side terminal extensions and insulating
barriers indicate that the licensee's inspection program was ineffective.
The indicators of this ineffectiveness include source surveillance,
1
receipt, and field cable termination inspections that failed to identify
and correct these conditions.
j
!
3.
A number of installation and procedural deficiencies were identified in
!
mechanical equipment and in bolting of valve flange pipe installations for
l
which Quality Control (QC) inspections had been completed.
The omission
i
of a vendor tolerance dimension en the installation instructions for the
mounting of annubar flow probe devices indicates a weakness in the design /
construction interface.
4.
The numerous instances of overtightened bolts in structural steel sliding
connections indicates that the licensee's installation and inspection
j
programs were particularly ineffective in this area.
Certain licensee
evaluations performed during the inspection to address NRC CAT concerns
'
are considered questionable.
These include questions related to the
extent the clay layer beneath the Essential Cooling Water (ECW) piping
<
will expand upon cessation of the dewatering system and the potential of
,
'
this occurrence to over stress the ECW piping, the potential for addi-
i
tional forces to be exerted on the Unit 2 tendon access wall due to the
omission of the 3-inch seismic joint, and the effect of the practice of
cross flange welding on the design strength of loaded structural steel.
(
f
A-1
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--
,,,,,--,v._,,-----na,-_.,---.
- - - - - . - - -
,----------e---,-------,.n-, . ,
---,n,
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5.
A lack of traceability of fasteners for electrical equipment, certain
vendor supplied equipment assemblies and bolting used in cable tray and
conduit supports was identified by the NRC CAT.
These deficiencies were
magnified by the AE's change to a specification in the electrical area to
delete the requirement for the manufacturers' marking on fasteners.
6.
Certain areas of weakness were experienced during the inspection of
design change control.
In addition to the matter of motor operated valves
discussed above, these included the control of the modification of design
changes during their incorporation into design drawings; the undocumented
use of engineering judgment in lieu of explicit or generic calculations
for ensuring the adequacy of design in certain design change documents;
and the conflicting definitions for configuration control packages in
issued revisions of governing procedures (Bechtel, EDP 4.72 and
WPP-22.0, and Ebasco, ASP-17).
7.
Additional areas of weakness were found in the application of correc-
tive action measures for the previously identified significant deficien-
cies in the maintenance of permanent plant equipment during the construc-
tion phase. The operations maintenance program does not address whether
an identified deficiency could affect the equipment's ability to perform
its design function or its operational maintenance program.
Also, weak-
ness was found in the control of " HOLD" tags.
8.
Weaknesses were found in the area of nondestructive examination records
for balance of plant suppliers.
This included a weakness in the licensee
program for audit review and acceptance of these records.
In addition,
after the radiographs for the reactor vessel head were discovered to
be missing in May 1985, the licensee's scope of corrective actions did
not address whether the records of balance of plant suppliers performing
nondestructive examination activities may be similarly affected.
9.
A significant number of reworked conduit installations were lacking QC
reinspection for bolt torque.
This indicates a weakness in the program
for inspection of installations reworked after initial QC acceptance.
10. The project's response to identified deficiencies in electrical raceway
separation was questioned.
The decision was made to postpone further
separation inspections until the time of area turnover.
The NRC CAT is
concerned with modifications to correct separation deficiencies that
may adversely affect plant systems already accepted and turned over to
startup or operations, in addition to being more difficult to identify
after construction is completed.
This concern was also raised by the STP
pre-CAT verification team.
,
I
i
These construction program weaknesses indicate that additional management
4ttention is required to assure that completed installations meet design
l
requirements.
i
.
A-2
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.
AREAS INSPECTED AND RESULTS
'
,
l
Electrical and Instrumentation Construction
The samples of electrical construction inspected generally met the applicable
design requirements and installation specifications.
However, several signifi-
cant design and construction deficiencies in electrical constructi.on, and
I
numerous installation discrepancies in instrumentation construction were
,
identified.
The configuration of molded case circuit breakers with load-side terminal
extensions and insulating barriers in installed Class IE motor control centers
was found to be deficient in that the potential for phase-to phase faulting or
inadvertent circuit interruption exist.
Relevant inspection activities, which
had been completed,
cable termination in. including source surveillance, receipt inspection, and field
j
spection did not identify these deficiencies.
Additionally,
'
the seismic qualification of equipment which exhibits this configuration could
1
not be verified.
Hardware and workmanship deficiencies were found in all of the 16 installed
motor operated valves inspected by the NRC CAT.
In addition, lack of adequate
-
design and installation control for the wiring of motor operators supplied by
Westinghouse Corporation (NSSS vendor) and further modified by the architect /
engineer resulted in various organizations not being supplied the required
wiring configuration documents.
Numerous dimensional and workmanship deficiencies were found in the instrumen-
tation construction sam
undergone the licensee'ple inspected.
This included an installation which had
s QC Effectiveness Inspection conducted after final
construction QC inspection and turnover to the startup organization.
Examples
.
of these deficiencies include dimensions exceeding tolerance limits on five
'
inst'a11ations, an incorrect weld configuration on a support, a missing support
clamp, and a support installed in accordance with an incorrect drawing detail.
In addition, attachments were being made to existing supports without the
required engineering review and approvals.
Several items of Class 1E equipment were found to deviate from their
applicable specification requirements.
These included the mislocation of
terminal strips and fewer than the required minimum number of terminal block
points in several switchgear cubicles, the absence of required vendor installed
terminal lugs on three fan motors, and the incorrect insulation class for a
pump motor.
The conduit strap bolts for a significant number of the conduit installations
inspected did not exhibit the required torque seal.
Since this is due to
their removal and reinsta11ation without reinspection by QC, increased controls
are required for inspection of rework of QC accepted conduit installations.
Mechanical Construction
.
Piping, pipe supports / restraints, concrete expansion anchors and heating
ventilation and air conditioning hardware (supports / restraints, duct sections,
fire dampers) were generally found to be installed in accordance with require-
ments or with deficiencies that generally had previously been identified.
'
However, significant deficiencies were identified in two areas of piping
A-3
.
- -----
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- , ,- - , _ , . - - - - - - . - - - , - ~ - - - - , - - - - , . , - . . - , -
, , , , - -
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- - - - - - - -
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installation.
These included the design tolerance dimension error applicable
to the mounting of numerous annubar flow probes and the alto.iate bolting used
in lugged wafer valves.
A significant number of hardware deficiencies were identified in t;en of the
twelve mechanical equipment items inspected.
The sample of equipment was
diverse and included:
the reactor water makeup tank, various pumps (RHR,
containment spray, and low and high head safety injection), charging pump
coolers, EAB return air fan, and a fuel handling building filter.
The identi-
fied deficiencies included items such as:
the uncontrolled removal of spect-
fled tank cushion material (FLEXCELL), incorrect / indeterminate fastener
material, missing shim for an equipment mounting pad, a damaged foundation beam
flange, welding of a gussett plate to the edge of embed which exceeded speci-
fied tolerances, missing and undersized welds, and bolt holes not per drawing.
The number and significance of the deficiencies identified, indicated a lack of
overall effectiveness in the installation and inspection programs for mechani-
cal equipment.
Welding and Nondestructive Examination
Welding and nondestructive examination activities were generally found to be
conducted in accordince with the governing codes and specifications.
However
a number of examples were found where completed structural welds in pipe
supports / restraints were smaller than that specified in the design drawings
-
and some skewed welded connections were not supported by calculations.
Also, a
number of undersized socket welds were found in 2-inch schedule 160 piping
spools.
Some vendor supplied tanks and heat exchangers were found to have undersized
weld reinforcement in " nozzle to shell" and "manway to shell" joints.
The NRC
previously issued Information Notice 85-33 on the subject of undersized "ASME
category D" joints in tanks and heat exchangers notifying the licensees of
potentially significant deficiencies in this area.
The NRC CAT inspectors did
not find evidence that the project had reviewed the content of the information
notice for applicability to their facility.
The NRC CAT inspectors also found a small number of radiographs which had
unacceptable weld quality.
In addition, the team encountered difficulties in
retrievability and location of vendor NDE film and documentation covering
the Balance of Plant (80P).
This indicated a need for a means to identify NDE
requirements, and the location and existence of NDE film and documentation for
BOP equipment supplied by vendors.
In May 1985, the project had identified
missing radiographs for the reactor head and as a result has instituted a
program requiring Westinghouse to submit monthly reports concerning status and
availability of NDE film and documentation.
The NRC CAT findings indicate that
the licensee's corrective action should have also covered the B0P suppliers.
Civil and Structural Construction
General quality of reinforced concrete construction was observed to be
'
adequate. The issue of omission of the 3-inch seismic joint relative to the
tendon access wall of the Unit 2 Reactor Containment Building at azimuth 304'
and elevation (-)13 ft and 3 inches needs to be adequately evaluated and
A-4
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.
-
.
.
.
,
appropriate actions taken.
In general, structural steel installation appeared
to be adequate.
However, a high rate of deficiencies was identified in the
overtightening of bolting for structural steel s_liding connections for which
the licensee has committed to perform a 100 percent reinspection to ensure that
bolting is torqued to the proper level.
.
The extent to which the underlying and adjacent clay soil layer supporting the
Essential Cooling Water (ECW) piping will swell when the dewatering system is
discontinued remains a question which requires further review by the licensee
and NRC.
Material Traceability and Control
The licensee's material traceability and control program was generally found
to be acceptable.
However, lack of traceability was found for fastener
materials for certain large vendor supplied mechanical equipment assemblies
'
mounted on skids and for certain electrical equipment.
It was also found that
engineering had deleted the requirement of the specified national standard for
manufacturers marking of fasteners intended for electrical cable tray and
conduit supports, which contributed to the resulting uncertainty of control and
traceability during and after installation.
Design Change Control
The design change control program was determined to be generally in accordance
with site procedures with several exceptions.
These include:
.
The deficiencies identified with respect to the installation of
Westinghouse supplied motor operated valves indicates that a design
control weakness exists in the AE/NSSS interface at STP.
The controls for pos' ting unincorporated design changes on design documents
were not adequately implemented at one reference station.
The control of modifications being made to change documents upon their
incorporation into the design drawings.
Identified changes to the origi-
nal scope or technical content of the change document were not being
adequately documented, reviewed and approved.
The conflicting definitions for configuration control packages in issued
revisions of governing procedures of the AE and constructor organiza-
tions.
Corrective Action Systems
Appropriate corrective. action systems and procedures were generally found
to be in place except for certain areas.
These include:
weaknesses in areas
involving control of fastener materials, preventive maintenance, audits and
records of radiographs, unidentified deficiencies with certain electrical
items (motor operated valves, motor control centers, and instrumentation
construction), and control of " HOLD" tags.
A-5
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,
APPENDIX B
POTENTIAL ENFORCEMENT ACTIONS
.
'
As a result of the NRC CAT inspection of October 21-November 1 and November 12-
22, 1985 at the South Texas Project site, the following items are.being referred
to Region IV as Potential Enforcement Actions. Section references are to the
detailed portion of the inspection report.
1.
10 CFR 50 Appendix B, Criterion III, as implemented by the South Texas
Project (STP) Quality Assurance Plan (QAP) Section 3.0, requires that
measures be established for the identification and control of design
interfaces and coordination among design organizations.
These measures
shall include the review, approval, release, distribution, and revision
of documents involving design interfaces.
-
Contrary to these requirements, at the time of this inspection:
The licensee failed to provide adequate interface between the design
a.
organizations (architect / engineer (AE), and the nuclear steam system
<
supplier (NSSS)), and the organizations performing the physical work.
This was evidenced by the inability of the licensee to provide a
design baseline wiring drawing for NSSS supplied motor operated
valves, the AE's revised designs not being provided to the NSSS for
their review and incorporation into NSSS drawings, and the inability
to ccLrrelate the actual wiring with current design documents.
(Section II.B.3.b.(8))
.
b.
Vendor tolerance requirements for the mounting dimension of the
annubar flow probe on essential cooling water piping were not
included on installation drawings and subsequently a number of
annubar mounting flanges were mislocated with respect to the distance
from the pipe outer wall.
(Section III.B.1.b).
2.
10 CFR 50 Appendix B, Criterion III, as implemented by the STP QAP
Section 3.0, requires that design control measures provide for verifying or
checking the adequacy of design and that design changes including field
!
changes, shall be subject to design control measures com,mensurate with
l
those applied to the original design.
Contrary to these requirements, at the time of this inspection:
The licensee could not provide calculations or documented engineering
.
a.
judgment to substantiate the design adequacy of the addition of four
bays of structural steel detailed on the November 5, 1984 revision of
Bechtel drawing No. 3M01-9-S-4043. (Saction VII.B.3.b.(5))
b.
Six field change request (Nos. BC-01202, CC-03426, CC-04945,
CC-044E1, PS-1-0194, and BS-1-0235) and one drawing change notice
(No. 7) were modified upon incorporation into the design drawings
without being adequately reviewed, approved and documented to reflect
changes in technical content or scope.
(Section VII.B.3.b.(2))
B-1
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3.
10 CFR 50 Appendix B, Criteria VII, as implemented by the STP QAP Section
7.0., requires that measures be established to assure that purchased
equipment conform to the procurement documents.
These measures shall
provide objective evidence of the quality furnished by the contractor or
subcontractor.
.
Y
Contrary to these requirements, at the time of this inspection:
~
The licensee failed to identify the deficiencies in the bolting of
a.
load-side terminal extensions and in the insulating barriers supplied
with certain molded case breakers in motor control centers:
These
i
deff ciencies have the potential for causing phase-to phase faulting
=
or inadvertent circuit interruption.
Further, the licensee was not
able to confirm that the load side terminal extensions or insulating
barriers were seismically qualified.
(Section II.B.3.b.(4))
b.
The NRC CAT inspectors found several deficiencies in vendor supplied
components.
The deficiencies included undersized welds in tanks and
heat exchangers and radiographs which did not have the required weld
and film quality.
These also include SKV switchgear cubicles with
mislocated terminal strips and terminal blocks with less than the
<
minimum required terminal points, fan motors which did not have the
required vendor installed terminal lugs, and a pump motor without the -
required class of insulation.
(Sections II.B.3.b and IV.B.10.b with
Table IV-5 and Table IV-6)
,
4.
10 CFR 50 Appendix B, Criterion VII, as implemented by the STP QAP Section
-
7.0, requires documentary evidence that material and equipment conform to
the procurement requirements shall be available at the plant site prior to
installation or use of such material and equipment.
This documentary
.
i
evidence shall be retained at the nuclear power plant site and be suffi-
cient to identify the specific requirements, such as codes, standards, or
specifications, met by the purchase material and equipment.
,
Contrary to the requirements, at the time of this inspection the licensee
could not determine the location of NDE film and documentation required by
engineering specifications as documented evidence of the quality of welding
'
for equipment and hardware procured from various vendors for the balance
of plant equipment.
(Section IV.B.10.b)
5.
10 CFR 50 Appendix B, Criterion VIII, as implemented by the STP QAP
'
Section 8.0, requires that measures be established for the control of
materials, parts and components to prevent the use of incorrect or defec-
tive items.
Contrcry to these requirements, at the time of this inspection it was
determined that traceability and control of some fasteners, including
bolting for mechanical and electrical equipment of various types, and
the unmarked bolting for electrical cable tray and conduit supports, has
not been adequate to assure the use of correct materials. Also, the
,
deletion of the requirement for marking of fasteners required to comply
with national standards contributed to the loss of traceability and
'
control of the referenced unmarked bolting.
[Section VI.B.1.b (3)(c), (d)
cnd (f)]
B-2
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6.
10 CFR 50 Appendix B, Criterion X, as implemented by the STP QAP Section
10.0, requires that a program for inspection of activities affecting
quality be established and executed by or for the organifation performing
i
the activity to verify conformance with the documented instructions,
procedures and drawings for accomplishing the activity.
.
Contrary to the above requirements, at the time of this inspection, the
i
licensee's inspection program was ineffective in that:
Numerous deficiencies were identified with the installation of QC
a.
1
accepted instrumentation and instrument tubing.
Examples of these
deficiencies include dimensions exceeding tolerance limits on five
installations inspected, an incorrect weld configuration on a tubing
support, a missing support clamp, and a support installed in accord-
ance with an incorrect drawing detail. The specific installations
and deficiencies are detailed on Table II-7 of the report.
(Section
II.B.4.b)
b.
A number of undersized socket welds were found in 2-inch schedule
160 piping.
Additional examinations of approximately 200 QC accepted
field welds of this type found at least 15 percent to be undersized.
,
(Sections III.B.1.b and IV.B.1.b)
-
On six lugged wafer valves, hex-head cap screws had been substituted
c.
for threaded studs and nuts inconsistent with the applicable essen-
,
tial cooling water piping installation isometric drawing and/or bill
of materials.
(Section II.I.B.1.b)
d.
Ten of the twelve mechanical equipment items selected for NRC CAT
examination included components which were not constructed or other-
wise installed in accordance with applicable design or specified
installation requirements.
(Section III.B.4.b. and Table III-5)
A number of examples were found where completed structural welds in
e.
pipe supports / restraints in welded joints were smaller than that
specified in the design drawings.
The list of these welds is in
Table IV-1.
(Section IV.B.1.b)
i
f.
More than 60 percent of the inspection sample of 68 high strength
bolts for structural steel sliding connections were installed over-
tight.
Installation and inspection requirements had not been
translatedintoappropriateproceduresensuringproperinstallation-
,
of the bolts in a ' snug tight" condition.
(Section V.B.2.b)
g.
Strap bolts on 8 of the 28 conduit runs inspected did not exhibit
the required torque seal.
Reinspections for torque had not been
'
accomplished following,qawofk to QC accepted conduit installations.
(Section II.B.1.b.(2))
'
7.
10 CFR 50 Appendix B, Criterion XVI, as implemented by~the STP QAP Section
.
16.0, requires that measures shall be established to assure that condi-
tions adverse to quality such as failures, malfunctions, deficiencies,
deviations, defective material and equipment, and nonconformances are
promptly corrected.
In the case of significant conditions adverse to
quality, the measures shall assure that the cause of the condition is
determined and corrective action taken to preclude repetition.
B-3
-
,
_
_
_
. _ _
.
.
.
.
.
.
Contrary to these requirements, at the time of the inspection the licen-
see's corrective actions were found to be inadequate in that the balance
of plant suppliers of'NDE film and documentation were not included in the
corrective actions taken after the radiographs for the reactor vessel head
were discovered to be missing in May 1985.
.
.
.
e
1
I
l
i
I
j
-
l
B-4
.
.
-.
. .
ATTACHMENT I
MC 2512 . INSPECTION HOURS
COMPARISON OF STP TO SELECTED SITES
2.8 -
2688
2.5 -
'
2.4 -
2304
,
2.2 -
jy i.' -: >>57--
~
g- M"C.
- 1750
-
-
.
g
1.5 -
r
343,
g
1.4 -
,
1.2 -
'
-
1-
O.8 -
O
4,
/2
4,
-
-
0
,
,
,
,
January through September 1985
i
13
I -
12 -
11 -
10656
-1
10 -
g417
9322
8796
9-
.
5513____/
__
,
,,
rap *
-__ __
j$
~
7159
/
-
O
,#
,#
,
,
,
,
STP- 1
BD-1
BF-1
VG-1
BV-2
HC-1
Total hours: Jon 1975 through Sep 1955
BD-1: Braidwood Unit 1
HC-1: Hope Creek Unit 1
BF-1: Bellefonte Unit 1
STP-1: South Texas Project Unit 1
BV-2: Beaver Valley Unit 2
VG-1: Vogtle Unit 1
I-l
.
.
.
.
.
ATTACHMENT II
766 DATA SUMMARY
MC 2512 STATUS OF SOUTH TEXAS UNIT 1
Summary of Manual Chapter 2512 Inspection Procedures (IPs) used, manhour
expenditures and distributions among program requirements.
Manhours are
those recorded in the 766 Computer System as of January 16, 1986.
A.
Phase 2 (Construction) Procedures Used and Total Inspection Hours
Program
No. of Procedures Used
Inspection Hours
2512
135
7159
Other
3
682
B.
Total Hours per Inspection Area for MC 2512
Inspection Area
Hours
Percentage
Management Meetings
425
6
Quality Assurance
282
4
Design and As-Built
0
0
Geotechnical
213
3
Structural Concrete
319
4
Structural Steel
203
3
Piping
18
<1
Mechanical Components
520
7
Electrical
191
3
Instrumentation
21
<1
Containment Penetrations
16
<1
Welding /NDE
900
13
Containment Test
0
0
Fire Prevention / Protection
24
<1
Inservice /Preservice Inspection
0
0
Environmental Protection
46
1
Followup
2099
29
Independent Inspection
1669
23
Miscellaneous
213
3
7IB
165 (Approx)
C.
Distribution of IPs by Percent Completion As Reported in
766 System
Percent Completion
No.
Percent
25% or less*
68
47
26 - 50%
14
10
51 - 75%
18
12
76 - 99%
12
8
'
100%
34
23
ITB
IDU
- Includes all applicable IPs with no hours recorded against them as of
January 16, 1986.
II-1
,
.-
D.
Applicable IPs With No Inspection Hours Recorded in 766 System as of
January 16, 1986
Design & As-Built
- 370558 *37051B
Geotechnical
46153B
Structural Concrete
47063B 47065B
Piping
490518 49053B
49054B 49055B
49061B 49063B
Mechanical Components
500748 500753
500908
Electrical / Instrumentation
51064B 51066B
520518 *520548
- 52055B *52056B
- 52064B *520668
Welding /NDE
55063B 55064B
55065B *55066B
55075B
551538 55154B
551558 55156B
551588 55175B
55176B- 551788
551858
Containment Test
- 630508
Inservice /Preservice Inspection
- 73051B *730528
- 73053B *73055B
- The designated inspection windows for these procedures have not been
missed.
.
II-2
..
.
ATTACHMENT III
INSPECTION PROGRAM HISTORY FOR SOUTH TEXAS 1
Inspections Performed at South Texas 1
A.
Civil and Structural Procedures
1.
Site Preparation
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
45051B
1
4
100
C
45053
1
21-
80
-
45053B
1
L
100
C
45055B
1
9
100
C
2.
Lakes, Dams and Canals
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections-
Hours
Completion
Status
45061B
2
3
100
C
450638
2
4
100
C
45063C
3
4
20
-
45065B
2
4
100
C
3.
Foundations
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
46051B
1
8
100
C
46053B
8
81
100
C
46053C
1
16
100
C
46055B
5
54
100
C
4.
Mtainment(StructuralConcrete)
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
47051B
3
23
10
L
47053B
2
27
100
C
47053C
12
96
100
C
47054B
10
54
100
C
470558
5
51
100
C
47056B
9
59
100
C
470618
1
8
-
-
47063C
1
1
10
-
III-1
_
._
.
.
5.
Containment (Steel Structures & Supports)
48051B
2
17
-
-
48053B
8
60
-
-
48053C
3
8
59
-
48055B
10
65
80
-
"
6.
Safety-Related Structures (Structural Steel & Supports)
480618
2
7
50
-
48063B
4
14
40
-
48063C
6
20
30
-
480658
4
12
30
-
8.
Mechanical Construction Procedures
1.
Reactor Coolant Pressure Boundary Piping
49053C
4
4
60
-
2.
Safety-Related Piping
49063
1
4
10
-
49063C
5
7
60
-
49065B
1
3
30
-
3.
Reactor Vessel Installation
i
50051B
2
21
60
-
50053
1
5
80
-
500538
2
17
70
-
50053C
6
39
80
-
50055B
2
35
60
-
4.
Reactor Vessel Internals
50061B
2
9
100
C
50063B
3
32
100
P
50063C
5
22
100
C
'
500658
2
16
100
C
5.
Safety Related Components
4
Total
Reported
Procedure
Number of
Staff
Percent
Reported
,
[
Number
Inspections
Hours
Completion
Status
500718
2
8
-
-
50073
1
40
80
-
l
50073B
3
14
10
-
50073C
8
15
60
-
,
III-2
L
-
.--
-. -
-
. ...
.
.
__
.
._
_ - -
.
.--
-.
.
.
.
6.
Safety-Related Pipe Support & Restraint Systems
50090
2
102
30
-
50090C
3
3
10
-
7.
Spent Fuel Storage Racks
50095
1
8
60
-
50095B
1
35
40
-
,
8.
Safety-Related HVAC Systems
4
50100
2
99
40
-
C.
Electrical & Instrumentation Construction Procedures
1.
Electrical Components & Systems
51051B
4
25
30
-
<
i
51053B
1
2
10
-
51053C
5
7
60
-
51054B
1
2
10
-
51055B
1
2
10
-
51056B
2
11
10
-
2.
Electrical Cables & Terminations
51061B
7
55
70
-
510638
2
2
10
-
51063C
4
56
20
-
51065B
4
29
20
-
3.
Instrumentation Components & Systems
51053B
1
1
10
-
t
4.
Instrumentation Cables & Terminations
52061B
3
17
25
-
520638
1
1
10
-
52063C
1
1
59
-
52065B
1
1
10
-
D.
Containment Penetration Procedures
l
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
53051B
1
2
100
C
53053B
1
3
20
1
-
!
53053C
5
5
60
-
53055B
1
6
10
-
,
k
III-3
.
-
-
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.,,em----,~-
snm~
,
w
-
,--,-we
,
w.
.-----a
w-
-
-->nsn--
.
.
E.
Welding and NDE Procedures
1.
Nuclear Welding - General
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
55050
2
114
40
-
55100
1
50
90
-
2.
Containment Structural Steel Welding
55051B
2
14
100
C
55053B
6
30
90
-
55053C
2
2
10
-
55055B
2
26
90
-
3.
Safety-Related Structures Welding
55061B
1
8
20
-
55063C
4
24
60
-
4.
Reactor Coolant Pressure Boundary Piping Welding
550718
1
8
40
-
550738
2
18
20
-
55073C-
1-
1
10
-
5.
Safety-Related Piping Welding
550818
1
9
10
-
55083B
2
13
20
-
55083C
6
30
80
-
550858
2
13
100
C
6.
Steel Structures and Supports
55151B
2
7
100
C
55152B
2
7
100
C
55157B
2
8
100
C
7.
Reactor Coolant Loop Piping
551718
3
7
90
C
551728
3
10
100
C
55173B
2
9
20
C
551778
1
1
60
C
III-4
-
-
.
-
8.
Other Safety-Related Piping Welding
55181B
2
3
80
C
551828
6
29
100
C
551838
3
10
10
-
551868
1
1
10
C
551878
4
11
100
C
551888
1
11
20
C
9.
57050
1
60
70
-
57060
1
50
70
-
57070
1
3
70
-
57080
1
30
30
-
57090
1
283
90
-
F.
Miscellaneous Inspection Procedures
1.
Meetings, QA, As-Builts, Fire Protection / Prevention, Construction
Delay, Contair. ment SIT, Environmental Protection and Fuel Storage
307028
10
67
-
-
30703B/C
170
358
-
-
350608
1
25
30
-
35061
1
40
100
C
350618
3
127
40
-
35065
1
16
100
C
35065B
3
15
30
-
352003'
1
59
100
C
42051C
-
3
4
60
-
64053B
1
20
100
C
802208
6
46
100
C
92051B
10
57
92053B
13
83
920558
10
49
94600
1
12
2.
Followup and Independent Inspection
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
361008
1
4
100
C
907128
1
6
927008
19
156
92700C
7
41
92701B
51
383
92702
3
95
927028
47
699
92702C
7
147
92703B
14
356
92703C
2
13
III-5
L
r.
- k
-
.
.
.
-i-
Total
Reported
Procedure
Number of
Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
,
,
,.
,
.,
y
. 927048
r
2
g
-
'
-C 927058-
7
78
{< 92706,92705C
2
35
'
e
13
391
/
92706B
104
1108
-
.92/06C
14
' 170
i
927158:
1
2
,
937008
1
51
.
97707
1
36
,
,
5
r e -'
u
. *
!
-
b
.k
~
V" a
. . ,
l
's
,
1
,
S
,
,
W
III-6
-
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