ML20213E331
| ML20213E331 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/05/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| References | |
| EA-86-010, EA-86-10, NUDOCS 8611130107 | |
| Download: ML20213E331 (2) | |
See also: IR 05000498/1986022
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In Reply Refer To:
Dockets: 50-498/EA-10
50-499/EA-10
Houston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
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P. O. Box 1700
Houston, Texas
77001
Gentlemen:
Thank you for your letter of October 9,1986, in response to our letter and
Notice of Violation dated August 20, 1986. We have reviewed your reply and
find it responsive to the concerns raised in our Notice of Violation. During
an inspection which concluded on September 19, 1986, (NRC Inspection
Report 50-498/86-22; 50-499/86-20) members of the original CAT inspection
group selectively followed up certain aspects of your corrective actions and
found them acceptable with one exception which your letter properly
addresses.
We will continue to review the implementation of your corrective actions
during future inspections to determine that full compliance has been achieved
and maintained.
Sincerely,
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J. E. Gagliardo, Chief
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Reactor Projects Branch
.,
cc:
Houston Lighting & Power Company
ATTN:
M. Wisenberg, Manager,
Nuclear Licensing
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P. O. Box 1700
Houston, Texas
77001
Brian Berwick, Esquire
Asst. Attorney General
Environmental Protection Division
P. O. Box 12548,-Capitol Station
78711
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Houston Lighting & Power Company-
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Lanny Alan Sinkin
Citizens Concerned About Nuclear
Power, Inc.
Christic Institute
1324 North Capitol Street
Washington, D.C.
20002
Charles Bechhoefer, Esquire
Chairman, Atomic Safety & Licensing
Board
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Dr. James C. Lamb, . III
313 Woodhaven Road
Chapel Hill, North Carolina
27514
Frederick J. Shon
Administrative Law Judge
Atomic Safety and Licensing Board
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Alvin H. Gutterman
Newman & Holtzinger, P.C.
1615 L St., N.W., Suite 1000
-Washington, D.C.
20036
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Texas Radiation' Control Program Director
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RPB
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R. D. Martin, RA
RRI-CONST.
Section Chief (RPB/C)
R&SPB
R. D. Martin, RA
RIV File
D. Weiss, LFMB (AR-2015)
RSTS Operator
R. Pirfo, ELD
R. G. Taylor, RPB/C
RSB
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B.LA. Breslau, RPB/C
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The Light
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COIIIpEf flousmn 1.ighiing & Power
no. Ih 1700 llouston,'Icxas < ,001 (7I3) 22M211
Octcber
9, 1986
ST-HL-AE-1754
File No.: D.41
,d
Mr. Robert D. Martin
OCT I 51986
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Regional Administrator, Region IV
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U. S. Nuclear Regulatory Commission
~
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
South Texas Project
Units 1 & 2
Docket Nos. STN 50-498, SIN 50-499
.
Response to Notice of Violation
NRC Inspection Report Nos. 50-498/85-21 and 50-499/85-19,
50-498/85-24 and 50-499/85-21, 50-498/86-12 and 50-499/86-12
Dear Mr. Martin:
Attachment I to this letter constitutes Houston Lighting & Power
Company's response to Notice of Violation EA 86-10 and your letter dated
August 20, 1986. A 21 day extension of the time by which this response was
to be filed was requested by Mr. M. R. Wisenburg (HL&P) and granted by Mr. L.
Constable (NRC) via telephone discussions on September 15 and 24, 1986. Our
response describes the specific actions taken to correct the deficiencies
identified in the Notice of Violation and those additional actions taken to
prevent recurrence. Attachment 1 includes much of the same information
previously provided in our April 2, 1986, preliminary response. Additional
information, based on our reevaluation of that response in light of your
August 20, 1986, letter and the Notice of Violation, as well as the updated
status of our actions, is indicated by a change-bar in the right margin.
Each
of the responses to the Notices of Violation references the applicable NRC item
number.
Houston Lighting & Power has undertaken a number of initiatives to
improve the effectiveness of the inspection process at the South Texas Project.
They include strengthening the training program, improving the inspector
certification process, and implementing the QC Performance Monitoring Program.
In addition, the Continuous Monitoring Program described in my letter of
January 10, 1986, and discussed with you and members of your staff at the
August 13, 1986, meeting at the South Texas Project site, provides an
additional real-time check on the effectiveness of the inspection process.
Our verification of the effectiveness of inspections will continue to be
performed through our program of audits, surveillances, and effectiveness
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Houston 1.ighting & Power Company
ST-HL-AE-1754
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File No.: D.41
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inspections, now supplemented by the QC Performance Monitoring Program and
Continuous Monitoring. The data from these verifications is routinely reviewed
by QA to determine trends and appropriate action is taken to correct identified
weaknesses.
We have taken actions to assure that the deficiencies identified during
the CAT inspection are not indicative of potential deficiencies in the as-built
plant. These actions include an analysis of each deficiency to determine the
root cause(s); an examination of similar areas / processes to determine the
extent of the deficiency; remedial actions to correct the specific deficiency
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as well as corrective action to remedy the root cause(s) so as to preclude
recurrence of.the problem; and verification of the implementation of both
remedial and corrective actions. These actions are described in detail in
Attachment 1.
Although Potential Enforcement Actions Nos. 4 and 7 were withdrawn as
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stated in the cover letter to Inspection Report 50-498/86-12,50-499/86-12,we
have continued the implementation of the committed actions in response to PEA
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No. 4 described in our April 2, 1986, preliminary response. Those actions are
essentially complete with a few items remaining to be closed.
Additional assurance regarding the effectiveness of the inspection
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process and the adequacy of the as-built plant is provided by the other
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initiatives put into place which were described in my January 10, 1986, letter
and discussed with you at the August 13, 1986, meeting at the South Texas
Project site. These initiatives include significantly increasing HL&P's
management presence on site; realigning of contractor organizations;
reassigning of key project personnel; increasing training of construction
,
personnel; and implementing an improved system for holding supervisors
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' responsible for work completed. We believe that these actions taken together
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have significantly enhanced the quality of workmanship and inspection
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activities at the South Texas Project.
Houston Lighting & Power remains fully committed to completing the South
Texas Project in a quality manner.
Very truly yours,
n
J. H. Goldberg
Group Vice President, Nuclear
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JHG/JEG/MRW:jkg
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Attachment 1: Response to Notice of Violation
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Houston Lighting & Power Company
ST-HL-AE-1754
File No.: D.41
cc:
Hugh L. Thompson, Jr. , Director
J. B. Poston/A. vonRosenberg
Division of PWR Licensing - A
City Public Service Board
Office of Nuclear Reactor Regulation
P.O. Box 1771
U.S. Nuclear Regulatory Commission
San Antonio, TX 78296
Washington, DC 20555
Brian E. Berwick, Esquire
N. Prasad Kadambi, Project Manager
Assistant Attorney General for
U.S. Nuclear Regulatory Commission
the State of Texas
7920 Norfolk Avenue
P.O. Box 12548, Capitol Station
Bethesda, MD 20814
Austin, TX 78711
Claude E. Johnson
Lanny A. Sinkin
Senior Resident Inspector /STP
Christic Institute
c/o U.S. Nuclear Regulatory
1324 North Capitol Street
Commission
Washington, D.C.
20002
P.O. Box 910
Bay City, TX 77414
.
Oreste R. Pirfo, Esquire
Hearing Attorney
M.D. Schwarz, Jr. , Esquire
Office of the Executive Legal Director
Baker & Botts
U.S. Nuclear Regulatory Commission
One Shell Plaza
Washington, DC 20555
Houston, TX 77002
Citizens for Equitable Utilities, Inc.
J.R. Newman, Esquire
c/o Ms. Peggy Buchorn
Newman & Holtzinger, P.C.
Route 1, Box 1684
1615 L Street, N.W.
Brazoria, TX 77422
Washington, DC 20036
Do'keting & Service Section
c
Director, Office of Inspection
Office of the Secretary
and Enforcement
U.S. Nuclear Regulatory Commission
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Washington, DC 20555
(3 Copies)
T.V. Shockley/R.L. Range
Advisory Committee on Reactor Safeguards
Central Power & Light Company
U.S. Nuclear Regulatory Commission
P.O. Box 2121
1717 H Street
Corpus Christi, TX 78403
Washington, DC 20555
A. Backus/J. E. Malaski
City of Austin
P.O. Box 1088
Austin, TX 78767
Revised 10/09/86
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ST-HL-AE-1754, Attachment 1
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NOTICE OF VIOLATION I.A.
I.
NRC STATEMENT
"10 CFR Part 50, Appendix B, Criterion X, as implemented by the South
Texas Project Quality Assurance Plan (STP QAP), Section 10.1, requires
that a program for inspection of activities affecting quality be
established and executed by or for the organization performing the
activity to verify conformance with the documented instructions,
procedures, and drawings for accomplishing the activity.
Contrary to the above, at the time of the inspections, the licensee's
inspection program failed to verify conformance to instructions,
procedures, and drawings. Components and structures which had been
previously inspected and accepted by the licensee's contractor Quality
Control (QC) personnel and which were subsequently found by the NRC to
not meet specified requirements are listed below:
1.
Deficiencies were identified with the installation of eight of ten
instruments and instrument tubing supports.
Examples of these
deficiencies included dimensions exceeding tolerance Timits on
five installations, an incorrect weld configuration on a tubing
support, a support installed in accordance with an incorrect
drawing detail, and a support installed with a clamp missing.
(Construction Appraisal Team Potential Enforcement Action (CAT
PEA) 6.a)
2.
Twelve of 30 socket welds in 2-inch schedule 160 piping were found
to be undersized. Additional examinations of approximately 200
welds of this type found at least 15 percent of these welds to be
undersized.
(CAT PEA 6.b)
3.
On six lugged wafer valves, hex-head cap screws had been
substituted for threaded studs and nuts which were not in
accordance with the applicable essential cooling water piping
installation isometric drawings and related bill of material.
(CAT PEA 6.c)
4.
Eight of 12 mechanical equipment items were not constructed or
other-wise installed in accordance with applicable design or
specified installation requirements. (CAT PEA 6.d as modified by
Inspection Report 50-498/86-12; 50-499/86-12)
5.
Fourteen of 41 supports / restraints were found to have completed
structural welds smaller than those specified in the design
drawings.
(CAT PEA 6.e)
6.
Forty-three of 68 high strength bolts for structural steel sliding
connections were found to be over-tightened.
QC inspections had
not assured that the bolts were installed to a " snug tight"
condition, as specified in inspection procedures, which would
allow movement in the connection.
(CAT PEA 6.f)"
Page 1 of 26
ST-HL-AE-1754, Attachment 1
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II. REPLY (I.A.1) (86-12-01)
It was determined that all of the final inspections and acceptances of
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the tubed instrument installations had been performed by one
individual. This included the eight instruments identified in the NRC
CAT report.
Four instances were identified where attributes which had been
inspected by other inspectors were rejected during reinspection.
However, responsibility for these attributes belonged to the inspector
mentioned above who performed final verification.
Based upon this inspector's performance, an assessment was conducted
of the instrumentation inspection certification program, the governing
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Construction and Quality Control (QC) procedures, and the methods used
by QC supervisors to assess the performance of inspectors under their
supervision.
It was determined that weaknesses in these were a
contributing factor.
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.A.1) (86-12-01)
Work was stopped on all safety related instrumentation installations.
The individual inspector, who performed the inadeouate inspections,
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has been removed from the project.
The Instrumentation QC group was trained in the CAT findings, other
specific deficiencies, specification requirements, and inspection
methodology. This included " hands-on" training.
A reinspection of safety related tubed instrument installations has
been accomplished to reverify inspection status.
In addition, other
accessible commodities inspected and accepted by the inspector in
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question were identified and reinspected. Deficiencies identified
have been documented and a disposition provided. NCRs have been
initiated on those items inspected by the inspector in question but
which are now inaccessible for reinspection.
Each of the items on
these NCRs is being evaluated by Engineering.
A Standard Site Procedure, " Instrumentation Installation," was issued.
This is an enhancement of the procedures which were in place and
consolidates Construction and QC procedures. Applicable QC and
Construction personnel have been trained to the requirements and
instructions in this new procedure.
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A review of the acceptance criteria has been conducted. Unnecessary
or overly restrictive requirements have been eliminated. This allows
QC to concentrate on essential attributes.
An assessment was conducted of the instrumentation inspection and
certification program. As a result, practical examinations have
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ST-HL-AE-1754, Attachment 1
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been enhanced to include extensive evaluations of the candidate's
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field performance.
The certification programs for the other inspection disciplines were
reviewed and it was determined that they were adequate.
Construction has implemented a program to improve the accountability
of craft supervision for the quality of the installation. The results
of QC inspections are reviewed on a weekly basis by Ebasco Site
Management and appropriate action taken to address areas of weakness.
A QC Performance Monitoring Program has been instituted. This program
consists of field observation by the QC discipline supervisor of the
performance of each inspector at least once a month. These
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observations include:
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Verification of consistency with established
inspection methodology
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Proper completion of inspection records
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Proper application of the inspector's experience
in problem resolution.
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IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.A.1) (86-12-01)
Not applicable.
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.A.1) (86-12-01)
Full compliance will be achieved on October 31, 1986, when the
Engineering evaluation of the inaccessible items is completed.
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II. REPLY (I.A.2) (86-12-02)
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Investigation has determined that the root cause of this problem was
a lack of appropriate formal training of the craftsmen (pipe fitter
welders) and QC inspectors in the use of appropriate measuring devices
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to ensure the adequacy of minimum leg and throat dimensions for fillet
welds on socket welded connections.
III.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED (I.A.2) (86-12-02)
A 100% reinspection of schedule 160 welds has been performed.
Twenty-nine welds were identified as nonconforming.
Fifteen were
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ST-HL-AE-1754, Attachment 1
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determined to be acceptable-as-is; ten were reworked; and four
eliminated by design evolution.
A reinspection of a 10% sample of schedule 40 (310 welds) and schedule
80 (313 welds) was performed. One schedule 40 weld and four schedule
80 welds were undersized which represents a reject rate of .3% and
1.3% respectively. Of the five total undersized welds, the one
schedule 40 and two of the schedule 80 were determined acceptable by
adoption of an ASME Code Case (N-316). The two remaining schedule 80
welds were reworked.
Due to the minor nature of the rework (1/16"
maximum weld build-up), no further inspections are considered
necessary.
The appropriate Construction and QC procedures were revised to more
clearly delineate fillet weld dimensions on socket welded connections.
All QC inspectors responsible for field inspections, as well as all
pipe fitter welders and welding supervisors, were formally trained to
all relevant attributes for fillet welds on all pipe sizes and
schedules. Special fillet weld gauges were purchased for measuring
socket fillets.
Each gauge in each set is labeled with the specific
pipe size, schedule, and fitting type.
performed follow up surveillances in order to provide assurance that
fillet weld dimensions are as required.
Standard Deficiency Report (SDR) E-349 was initiated on October 31,
1985, to document corrective actions. After QA verification of the
corrective action taken, this SDR was subsequently closed on April 3,
1986.
In addition, refer to Part III,31.A.1, (page 3) for statements
concerning improved craft supervision accountability for quality and
the QC Performance Monitoring Program.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.A.2) (86-12-02)
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Not applicable.
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.A.2) (86-12-02)
Full compliance was achieved on April 17, 1986, when the last NCR was
closed.
II.
REPLY (I.A.3) (86-12-03)
Investigation has determined that two deficiencies existed in the
field that were accepted by QC:
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ST-HL-AE-1754, Attachment 1
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1.
Cap screws of improper length had been installed in several of the
lug wafer valves.
2.
Cap screws had been substituted without appropriate documentation,
i.e., an FCN, prior to installation.
Investigation has determined that the following are the root causes:
1
1.
Failure to follow procedures and inadequate craft training.
2.
QC acceptance was based upon verifying torque value. The
inspection procedure did not require the physical measurement and
documentation of the length and diameter of the cap screws to be
installed.
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III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.A.3) (86-11-03)
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Appropriate Construction and Field Engineering personnel have been
retrained to all of the requirements concerning cap screw
substitutions.
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The appropriate QC procedure was revised to require verification and
documentation of approved cap screw substitutions including length,
diameter, and material type. QC personnel were trained.
A 100% reinspection of cap screw substitutions in safety related
lugged wafer valves has been completed. Valves installed with
incorrect / indeterminate cap screws have been documented on ten NCRs.
The NCRs have been dispositioned to replace cap screws that did not
meet a conservative thread engagement equivalent to one bolt diameter.
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A review was performed to determine whether improper cap screw
substitutions had been made on valves other than the lugged wafer
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valves. No problems were identified.
In addition, refer to Part III, I.A.1, (page 3) for statements
concerning improved craft supervision accountability for quality and
the QC Performance Monitoring Program.
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IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.A.3) (86-12-03)
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Not applicable.
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.A.3) (86-12-03)
Full compliance was achieved on September 16, 1986, when the last NCR
was closed,
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ST-HL-AE-1754, Attachment 1
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II. REPLY (I.A.4) (86-12-04)
An investigation of the CAT observations listed in Table III-5 of the
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NRC CAT Inspection Report resulted in the following actions:
a.
ASME Mechanical Equipment and Tanks
Reactor Water Make-up Tank
The removal of the Flexcell material was evaluated and it was
determined that the floor of the tank can withstand the resulting
additional stresses.
Replacement of the material is not required.
The cause of the condition was the removal of a portion of the
Flexcell cushion so that the area under the tank could be
investigated for microbiological 1y induced corrosion (MIC).
Containment Spray Pump, High and Low Head Safety
Injection Pumps
Bolting Material Control
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Fastener material control for components is addressed in the
response to Notice of Violation I.C.2.
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b.
HVAC Components and Supports
Welding, Bolt Tightening and Damage Deficiencies
on EAB Return Air Fan, Charging Pump Supply Cooler
and fuel Handling Building Filter Support Frames
These deficiencies have been documented on Nonconformance Reports.
Investigation concluded that these deficiencies were caused by
inadequate training and supervision of the craft and the QC
inspectors.
A reinspection of HVAC support ' frames which were inspected and
accepted by mechanical inspectors has been accomplished.
Deficiencies have been documented and a disposition provided.
III.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.A.4) (86-12-04)
a.
ASME Mechanical Equipment and Tanks
The Construction procedure has been revised to add the requirement
for a construction process sheet for both safety and non-safety
related mechanical equipment.
In addition to this and other
enhancements, the previous Construction and QC procedures were
consolidated in the new construction procedure. Appropriate
personnel have been trained in the requirements of the new
procedure.
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ST-HL-AE-1754, Attachment 1
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A documentation review of both construction and QC records for ten
pieces of mechanical equipment was performed to ensure that the
vendor requirements were met. This review was completed with
satisfactory results.
b.
HVAC Components and Supports
The same type of procedure enhancements and training associated
with the ASME equipment has been accomplished for this equipment.
The responsibility for inspection of HVAC component support frames
was transferred from the mechanical equipment to the HVAC
inspection group.
In addition, refer to Part III, I.A.1, (page 3) for statements
concerning craft supervision accountability for quality and the QC
Performance Monitoring Program.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.A.4) (86-12-04)
Not applicable.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.A.4) (86-12-04)
Full compliance was achieved on September 25, 1986, when the actions
associated with the reinspection effort were completed.
II.
REPLY (I.A.5) (86-12-05)
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We have evaluated the information contained in Table IV-1 of the CAT
Inspection Report and determined that only the table entries listed
below are the subject of the Notice of Violation:
Table IV-1
Applicable Pipe
Item
Support
Deficiency
(3)
CC-1317-HL5006
1 undersize fillet weld
(5)
CV-1209-RR0002*
7 undersize fillet welds *
(8)
CC-1480-RR00ll
3 undersize skewed connection welds
(9)
SI-1301-HL5010
1 undersize skewed connection weld
(15)
CC-1303-HL5003
2 undersize fillet welds
I undersize skewed connection weld
(16)
SI-1105-RR0038
1 undersize skewed connection weld
A review of the NCR generated against this support and the
applicable design drawing shows evidence that only five safety
related fillet welds could be undersize.
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ST-HL-AE-1754, Attachment 1
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We have determined that the problem is limited to skewed connection
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welds based on the following:
Approximately 475 pipe support fillet welds were examined by the
Construction Appraisal Team, of which only eight (five on support
CV-1209-RR0002; two on support CC-1303-HL5003; and one on support
CC-1317-HL-5006) were undersized. These conditions have been
identified on three NCRs which have been dispositioned (one " rework"
and two "use-as-is") and closed as of March 28, 1986. This does not
constitute a problem relative to the inspection of structural fillet
welds, nor is it indicative of a widespread hardware deficiency.
The root cause of undersized skewed connection welds was lack of
training and imprecise procedural requirements delineating criteria
for leg size, throat size, and acceptable weld profiles.
III. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED (I.A.5) (86-12-05)
1.
One hundred twenty-one Class 1, 2, and 3 pipe supports containing
skewed welded connections have been reinspected. Twenty of the
pipe supports reinspected were found to have undersized skewed
weld connections. These have been dispositioned "use-as-is" based
upon engineering evaluation.
2.
Fifty structural steel connections having skewed welds were
reinspected. No deficiencies were found.
3.
Those HVAC supports having skewed weld connections were
reinspected (10 total). Two undersized skewed weld connections
were identified on one support. An NCR was initiated and
dispositioned "use-as-is."
4.
A sample of 33 electrical supports having skewed weld connections
has been inspected. Two undersized skewed weld connections were
identified on one support. An NCR was initiated and dispositioned
"use-as-is."
Applicable procedures have been revised to incorporate detailed
inspection and acceptance criteria for skewed connection welds.
Applicable personnel have been retrained to the procedural
requirements.
In addition, refer to Part III, I.A.1, (page 3) for statements
concerning improved craft supervision accountability for quality and
the QC Performance Monitoring Program.
IV. CORRECTIVE STE PS WHICH WILL BE TAKEN (I. A.5) (86-12-05)
Not applicable.
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Page 8 of 26
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ST-HL-AE-1754, Attachment 1
.
.
,
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.A.5) (86-12-05)
Standard Deficiency Report (SDR E-382) was initiated on December 13,
1985, to document corrective actions. Full compliance was achieved on
June 26, 1986, when SDR E-382 was closed.
II.
REPLY (I.A.6) (86-12-06)
Main structural steel framing inside the Reactor Containment Building
(RCB), the Isolation Valve Cubicle (IVC), and the Heating Ventilating
and Air Conditioning (HVAC) ring duct and riser duct inside the RCB
was designed to have specific bolted connections with slotted holes.
The bolts were to be installed in a " snug tight" condition to allow
free movement of members under changing thermal or pressure
,
conditions. No specific torquing requirements were provided.
This lack of specificity caused improper torquing by Construction and
did not provide QC inspection with verifiable inspection acceptance
criteria.
In addition to the items above, the Polar Crane rail girder supports
have slotted connections which were addressed in NRC Unresolved Item
83-16-05.
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.A.6) (86-12-06)
Revisions to the pertinent design drawings have been issued to provide
an acceptable range of torque values.
Nonconformance Reports (NCRs) were issued and a rework disposition
provided for the structural steel and ring duct sliding connections
with slotted holes. The HVAC riser duct sliding connections were
evaluated by Engineering and accepted as is. All rework has been
completed, accepted, and the NCRs closed.
In addition, refer to Part III, I.A.1, (page 3) for statements
concerning improved craft supervision accountability for quality and
the QC Performance Monitoring Program.
IV.
CORRECTIVE STEPS WHICH WILL BE TAKEN (I.A.6) (86-12-06)
Not applicable.
l
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.A.6) (86-12-06)
Full compliance was achieved May 1, 1986, when the last NCR was
closed.
Page 9 of 26
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ST-HL-AE-1754, Attachment 1
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,
.
NOTICE OF VIOLATION I.B.
4
I.
NRC STATEMENT
"10 CFR Part 50, Appendix B, Criterion III, as implemented by STP QAP,
Section 3, requires that design control measures provide for verifying
or, checking the adequacy of design and that design changes, including
field changes, be subject to design control measures commensurate with
those applied to the original design.
Contrary to the above, it was determined at the time of the
inspections that design control measures had failed to verify the
'
adequacy of design in that:
'
Configuration Control Package (CCP) 0243 for modification of motor
1.
operated valves had been issued and reviewed by the
Architect / Engineer for field implemer,tation with significant
i
errors in the directions provided.
(CAT PEA 1.a as modified by
Inspection Report 50-498/86-12; 50-499/86-12)
2.
The Architect / Engineer had issued and reviewed drawings for
installation of annubar flow measurement devices in safety-related
systems that did not include vendor installation tolerances.
(CAT PEA 1.b as modified by Inspection Report 50-498/86-12;
50-499/86-12)
3.
The Architect / Engineer had issued and reviewed installation
drawings for certain instrument and sample lines connected to the
Unit I reactor coolant system pressurizer that did not include the
Nuclear Steam System Supplier required flow restriction orifice in
each of the five lines.
(Inspection Report 50-498/85-24;
50-499/85-21 as modified by Inspection Report 50-498/86-12;
50-499/86-12)
t
4.
Design drawings which incorporated Field Change Requests BC-01202,
l
CC-04949, and Field Change Notice BS-1-0235 had been issued and
l
reviewed by the Architect / Engineer in a manner that differed from
the change document (BS-1-0235) or contained drafting errors
l
(BC-01202 and CC-04949).
(CAT PEA 2.b as modified by Inspection
l
Report 50-498/86-12; 50-499/86-12)"
l
l
,
j
II.
REPLY (I.B.1) (86-12-07)
The primary cause of the deficiencies in wiring configuration of
Unit 1 MOVs was an error made by the Bechtel engineer responsible for
I
assembly of the Configuration Control Package (CCP). This engineer
'
did not recognize the actual M0V wiring configuration and provided
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Page 10 of 26
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ST-HL-AE-1754, Attachment 1
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instructions to Construction which referenced an outdated Westinghouse
(W) design document. An additional contributing factor which affected
.
one jumper was the failure to control the sequence of implementation
,
of Bechtel CCPs.
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.B.1) (86-12-07)
,
i
An inspection program was implemented by which individual MOVs were
examined, reworked, and upgraded, as required, leading to release for
turnover and startup testing.
A review was performed to determine whether the MOVs furnished by
other vendors might have similar wiring discrepancies. No wiring
discrepancies were identified.
.
All 58 MOVs supplied by W for Unit I have been inspected by a special
task team, and the reworE associated with that inspection was complete
,
i
on July 3, 1986. Although no CCPs had been issued for Unit 2, a
similar inspection and rework program will be performed on the Unit 2
MOVs.
-
To prevent any confusion relevant to the MOVs wiring design, a Bechtel
wiring diagram for the Unit 1 W supplied MOVs has been developed which
provides point-to-point wiring information.
Future changes will be
reflected, where appropriate, with a change to this drawing as well as
to the Bechtel elementary drawing. A similar point-to-point wiring
diagram is being developed for Unit 2.
To further strengthen design control, W changes that require physical
implementation, as identified by the W FCN process, are incorporated
into a CCP which is then issued for implementation.
Each CCP is
annotated to specify when the CCP should be implemented in relation to
i
other CCPs. Completed and "in process" CCPs have been reviewed for
l
proper sequencing.
The project has reviewed CCPs developed by the engineer who made the
error which led to the wiring configuration deficiency. Minor
deficiencies were identified and corrected; no hardware rework was
required. This engineer is no longer employed at STP.
}
To further assure the integrity of the design control process, an
l
investigation was performed on the Reactor Trip Switchgear and the
Solid State Protection System. These systems are W designs and had
changes initiated by W and Bechtel that were incorporated into CCPs
that were implemented by both W and Ebasco.
The investigation
concluded that the changes to 50th systems were correctly implemented.
This event is considered to be an isolated case of faulty CCP
preparation.
,
Page 11 of 26
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ST-HL-AE-1754, Attachment 1
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IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.B.1) (86-12-07)
Not applicable.
I
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.B.1) (86-12-07)
.
Rework of Unit I hardware was completed July 3,1986. A Unit 2
inspection and rework program will be scheduled consistent with the
Unit 2 construction sequence.
II.
REPLY (I.B.2) (86-12-08)
The vendor drawings and Bechtel isometrics were subjected to an
interdisciplinary review in accordance with Bechtel Engineering
procedures. However, due to an oversight, the vendor-specified
tolerances for installation of annubars were not included nor
referenced on the isometric drawings. This resulted in the
installation of 19 annubars in accordance with generic piping
installation tolerances as opposed to the tighter tolerances specified
by the vendor.
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.B.2) (86-12-08)
An Engineering evaluation of the 19 installed annubar flow elements in
safety related piping systems has been completed.
It was concluded
that the system functional requirements can be satisfied with a lower
level of accuracy of the flow elements than would have been provided
by the original vendor tolerances. The vendor has ccnfirmed that less
strict installation tolerances would provide the level of accuracy
actually required. The Engineering evaluation also verified that
t
t
these flow element functions are not essential to plant safety as used
in these systems.
Application of the new tolerances to the 19 flow elements already
installed demonstrated that the as-installed condition was acceptable
in 12 cases. The remaining 7 installations were modified to bring
them within the new tolerances. These modifications are complete.
Both the vendor drawings and the affected piping isometrics were
amended by Field Change Requests (FCRs) to reference the revised
dimensional information required for proper annubar flow element
installations.
Future installations will be in accordance with these
revised drawings.
In addition, the Engineering evaluation verified that other
instrumentation connected to process pipes do not have similar vendor
imposed tolerances.
Page 12 of 26
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ST-HL-AE-1754, Attachment 1
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.
A supplemental technical audit was performed by HL&P to determine if
vendor information was being adequately incorporated into the
applicable design documents. The audit included a review of
approximately 176 vendor documents and 124 corresponding Bechtel
design disclosure documents. There were technical specialists
assigned to the audit from the applicable disciplines of mechanical,
I&C, and electrical. The audit team did not identify any instances of
failure to incorporate vendor requirements into the Bechtel design
disclosure documents. Other types of deficiencies, none of which
affect hardware installation, were identified and are being corrected.
IV.
CORRECTIVE STEPS WHICH WILL BE TAKEN (I.B.2) (86-12-08)
Not applicable.
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.B.2) (86-12-08)
Full compliance was achieved on January 3,1986.
.
II. REPLY (I.B.3) (86-12-09)
The information below was previously transmitted to you in a
letter from J. H. Goldberg to R. D. Martin dated March 3, 1986
(ST-HL-AE-1612).
A design error occurred as a result of the failure to provide the
specific detail on Drawing 1-P-5051, " Composite Piping Reactor
Containment Building R.T.D. Manifold Loop Piping," for the flow
restrictors to be provided by the Architect / Engineer (A/E). The
correct (in-line) flow restrictors were not shown on the drawing as
!
required by the Piping and Instrumentation Diagram (P&ID) for the five
~
connections on each pressurizer (four level instrumentation lines and
I
onesampleline). This deficiency resulted from differences between
l
the applicable notes on the NSSS Flow Diagram and the P&ID. These
!
differences are as follows:
1
The Westinghouse Flow Diagram for the Reactor Coolant System (Drawing
l
No. 1207E14, sheets I though 3) shows the design requirements
-
j
specified to the A/E. Sheet 2 pertains to the pressurizer and defines
i
the requirements for pressurizer flow restrictors as follows:
I
"A/E to provide 3/8" ID flow restrictor with
piping for Class 1 - Class 2 transition at
pressurizer liquid space level instrumentation
and sample nozzles, similar to arrangement shown
i
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by Note 5, W Flow Diagram Legend Dwg."
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Page 13 of 26
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ST-HL-AE-1754, Attachment 1
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,
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The P&ID 5R149F06003 equivalent note is as follows:
" Provide 3/8 flow restrictor per Drawing 9P05051
to change from SCI to SC2 at restrictor."
The significant phrase "with piping" was not identified and
specifically addressed to assure the design met the requirements for
providing the flow restrictors as part of the instrument and sample
line connections to the pressurizer nozzles. The " typical" flow
orifice detail provided on the Westinghouse Flow Diagram Legend
drawing was provided for branch connections onto Class 1 piping. This
detail was accurately translated from W drawings to Drawing 9P05051.
However, the " typical" detail was not suitable for use in welding the
instrument and sample lines to the pressurizer nozzles since Drawing
9P05051 showed the required flow restrictor at the vessel wall. Since
the words "with piping" had been omitted from the P&ID note during the
preparation of the piping isometric drawings, the designer assumed
that the required flow restrictors were provided by Westinghouse as
part of the pressurizer nozzles in accordance with Drawing 9P05051.
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.B.3) (86-12-09)
,
The piping drawings were revised to include the required in-line
flow restrictors (DCN #1 to 2C379PRC6590 A2/A2 and DCN #2 to
SC369PRC457-A09). The Unit I flow restrictors were fabricated
and installed by February 11,1986(NCRBP-3535).
A detailed review of NSSS Flow Diagrams versus Bechtel P& ids has
been completed. No other significant discrepancies were found. The
r
Bechtel Engineering resolutions of minor differences have been
evaluated by Westinghouse and determined to be acceptable.
,
A Houston Lighting & Power Quality Assurance supplemental audit of
Bechtel/ Westinghouse design input process assessed the technical
adequacy of the identification and incorporation of Bechtel/
Westinghouse design inputs into the appropriate design disclosure
documents. The audit was completed on February 28, 1986, and no
significant discrepancies were found.
The results of the Bechtel P&ID review indicate the flow restrictor
4
'.
problem was an isolated case of inaccurately transcribing drawing
information. Nevertheless, appropriate mechanical discipline
engineering supervision and lead engineers have been re-instructed in
the requirements of reviewing NSSS design inputs. Training was
!
!
completed on February 4,1986.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.B.3) (86-12-09)
1
l
Not applicable.
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Page 14 of 26
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ST-HL-AE-1754, Attachment 1
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.B.3) (86-12-09)
HL&P was in full compliance on February 11, 1986, when flow
restrictors were installed.
II.
REPLY (I.B.4) (86-12-10)
Each of the observations cited in the Notice of Violation has been
investigated. Table I contains the specific results of the
investigation. Additionally, the cause of each observation has been
identified as follows:
FCR BC-01202, failure to follow procedures;
FCR CC-04949 and FCN BS-1-0235, drafting mistakes.
The examples cited in Table I reflect two cases of minor drafting
mistakes, and one case where technical information was revised during
incorporation of the amendment. None of these items resulted in
incorrect installations.
Based upon a concern identified by the Institute of Nuclear Power
Operations Construction Project Evaluation of STP in May 1985, the
project instituted and completed a review of approximately 165,000
revisions to drawings and specifications for the extent and impact of
modified amendments, and concluded that less than .05% of these
revisions were modifications that had an impact on construction. The
items identified during this review were similar in character and
occurred during the same time frame as Item I in Table I which was
identified by the CAT.
'
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.B.4) (86-12-10)
Refer to Table I for specific actions taken.
Engineering Department procedures have been revised. The procedures
now require that if technical information contained in the previously
l
approved amendment is changed, it can only be changed by the issue of
another amendment.
Editorial changes must be identified in the
revision block of the parent document. Appropriate personnel have
l
been trained.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.B.4) (86-12-10)
Not applicable.
l
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.B.4) (86-12-10)
Full compliance was achieved January 7, 1986.
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Page 15 of 26
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ST-HL-AE-1754, Attachment 1
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Table I
Results of Investigation of Observations
1. " Field Change Request (FCR) BC-01202 was issued on June 13, 1984 against
Rev. 2 of Bechtel drawing 3M01-9-C-4312. The FCR was issued to reduce an
oversized HVAC opening. A modified version of the FCR (as noted in the
drawing revision block) was incorporated into revision 3 of the Bechtel
drawing, which was issued on October 4, 1984. As shown on the drawing,
the detail is now applicable to both Units 1 and 2.
It appears that the
penetration was reworked in accordance with the FCR, so that the as-built
configuration is not in agreement with the design drawing. The Bechtel
civil / structural site engineering organization indicates that FCR
BC-01202 was incorrectly incorporated into Rev. 3 of the Bechtel drawing,
and issued Drawing Change Notice (DCN) No. 3 on November 16, 1985 to
correct the drawing."
RESPONSE
Revision 3 of the drawing incorrectly inct eporated the FCR. This was
caused by a misunderstanding of the required minimum clearance necessary
for duct installation. With the exception of the l'-1" dimension, all
other attributes of the FCR were properly incorporated. DCN No. 3 was
subsequently issued tt, correct the discrepancy. Further, FCR BC-01202
was initially issued to effect a change to Unit No. I design. The FCR
was generated against a Category "9" drawing which designates
applicability to both Units 1 and 2.
Unless otherwise noted, the FCR
would then be reviewed at incorporation by Engineering for applicability
of change to Unit No. 2.
In this case, it was determined that this same
change would be applicable for Unit No. 2.
The conclusion is tnat the design Engineer erred during the incorporation
of the FCR (i.e., revised technical information outside the bounds of the
Project Procedures). The Project Procedures have been revised to make
more clear that changes of a technical' nature to previously approved
amendment documents upon incorporation, require the issuance of another
change document (i.e., DCN, FCR/FCN or SCN).
2. "FCR CC-04949 was issued on December 22, 1984 against Rev. 3 of Bechtel
drawing 7G-22-9-S-2002. The FCR revised support details for relay racks
ERR 126 (nonsafety) in Units 1 and 2.
The FCR was modified upon
incorporation into Rev. 3 of the Bechtel drawing, as noted in the drawing
revision block, and as detailed on the drawing. However, the location of
the revised steel in plan was not clouded, and the 13/16 in. bolt holes
for the support channel were not transferred onto the drawing. The
Bechtel civil / structural site engineering organization has verified that
the support was installed as detailed on the drawing, and issued DCN No.
18 on November 18, 1985 to correct the drafting error."
,
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Table I-l
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ST-HL-AE-1754, Attachment 1
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RESPONSE
The omission of the hole size in the supporting steel, i.e., channel, and
failure to cloud the change in the drawing is a drafting mistake. As
indicated in the observation, however, the support was installed as
depicted in the design drawing.
Standard detailing practices and/or AISC
Code dictate that for a 3/4" diameter bolt, a 13/16" diameter hole is
provided unless otherwise noted. DCN No. 18 was issued to ensure
consistency between the previously approved amendment document, i.e., FCR
No. CC-04949 and the design drawing. DCN No. 18 has subsequently been
i
incorporated into Revision 8 of the parent drawing and the hole size
appropriately identified.
3. "FCN BS-1-0235 was issued on August 5, 1984 against Rev. 2 of Bechtel
drawing CC-9215-RR0005. The FCN was incorporated into Rev. 3 of the
Bechtel drawing on March 12, 1985. The team reviewed the drawing, which
details separate pipe supports for Unit I and 2.
The supporting steel
for these supports appeared to require stiffeners, and the team then
reviewed the pipe support calculation. Rev. I of calculation
JC-CC-92-15-RR0005, dated September 30, 1985, does require beam
stiffeners for both the pipe support supplementary steel and the
supporting framing steel.
Bechtel issued two separate configuration
control packages on October 30, 1985 to add beam stiffeners to the pipe
support steel, CCP-1-M-0066-00 and 2-M-ST-0067-00; however, the beam
stiffeners to be added to the supplementary steel for the Unit 2 pipe
support were not clouded on the pipe support drawing. The Bechtel pipe
support group site engineering organization issued FCR XEJ-00371
on November 18, 1985 to correct the configuration control package for
Unit 2."
,
RESPONSE
Failure to cloud the specific change (i.e., additional stiffener plates)
was a drafting mistake and has been corrected by issuance of the
aforementioned XFCR. However, this mistake would not have caused the
stiffeners to be overlooked as they themselves were clearly identified in
the Bill of Material as well as a special detail (i.e., Detail No. 9) as
being required.
Table I-2
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ST-HL-AE-1754, Attachment 1
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l
.
NOTICE OF VIOLATION I.C.
I.
NRC STATEMENT
"10 CFR Part 50, Appendix B, Criterion VII, as implemented by the STP
QAP, Section 7.0, requires that measures be established to assure that
purchased equipment conforms to the procurement documents and that
there shall be documented objective evidence of quality of the
purchased equipment.
Contrary to above, it was determined, at time of the inspections, for
equipment accepted by the licensee that:
1.
Several motor control centers were found not to meet Bechtel
purchase specification 3E179ES1054 in that terminal extensions had
beon installed although these had not been specified and the
bolting was too short for the load side terminal extensions on the
molded case circuit breakers to properly secure the extensions.
In addition, insulating barriers installed between the extenders
were inadequately secured and frequently were dislodged during
installation which could allow phase-to-phase short circuits.
(CAT PEA 3.a)
2.
Fourteen of the 20 pieces of mechanical equipment were found not
to meet procurement documents in that the bolting was not
traceable or when traceable, was not in accordance with vendor
defined requirements or with Architect / Engineer specifications for
the equipment.
(CAT PEA 5 as modified by Inspection Report
50-498/86-12; 50-499/86-12)
3.
Six of the eight vendor-furnished tanks and heat exchangers did
not meet procurement documents in that undersized welds were found
on supports and nozzles.
(CAT PEA 3.b)
'
4.
Four electric motors furnished by vendors were found to be not in
conformance with the procurement document (Equipment Specification
3E319ES1040) in that three motors did not have the required
terminal lugs installed on electrical connections and one motor
had insulation rated for'a lower maximum temperature.
(CAT PEA 3.b)"
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,
II.
REPLY (I.C.1) (86-12-11)
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An examination of the Class 1E 480 volt Motor Control Centers (MCCs)
identified the following deficiencies:
.
Page 16 of 26
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ST-HL-AE-1754, Attachment 1
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1.
Loose connections were discovered at the bus extensions on the
load terminals of ITE type HE molded case circuit breakers. The
vendor-installed screws connecting bus extensions to the circuit
breakers lacked sufficient thread engagement to maintain tight
connections. The screws in question are 1/4" diameter by 1/2"
long pan head screws installed with star lock washers, and were
furnished by the vendor for load side cable connections. However,
1/4" thick copper bus extensions had been added by the vendor to
the breaker to accommodate field cable larger than #2AWG, thereby
reducing the available length of screw thread for making a proper
electrical connection.
2.
The vendor-installed plastic barriers between the molded case
circuit breaker bus extensions in the MCCs were found to be loose
and, in some cases, missing. The barriers are press fit into
slots located on the bottom of the circuit breaker and maintain
electrical insulation between adjacent buses. Some of the missing
'
barriers had fallen into the bottom of the cubicles.
Sixty circuit breakers (30 in each unit) had the bus extensions
described above. No specific authorization for the extensions was
supplied by Bechtel, nor requested by the vendor. The vendor
considered the extensions to be necessary to meet the cable
termination design requirements identified in the specification.
A sample inspection of similar circuit breakers supplied by other
manufacturers was conducted and although extensions were found on
another manufacturer's circuit breakers, no similar deficiencies were
identified.
A review of the vendor drawings of both manufacturers who supplied
extensions determined that the extension details were not shown.
Electrical drawings of this type do not typically depict terminal
l
configuration or other similar hardware details.
!
Since the MCCs were subject to source surveillance, receipt inspection
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!
consisted only of a visual inspection for exterior damage and a
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confirmation that the required paperwork was present and correct. The
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deficiencies noted were not identified by construction QC personnel
since the procedural requirements for electrical termination
activities did not call for an in-depth inspection of the breaker.
The vendor has confirmed that the seismic test report demonstrates
that the extensions and barriers were in place during testing.
The root cause of the deficient extension / barrier installations was
the failure of the vendor to follow proper design and manufacturing
practices.
This condition was evaluated and reported to the NRC as " reportable"
pursuant to 10CFR50.55(e) on March 26, 1986.
Page 17 of 26
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ST-HL-AE-1754, Attachment 1
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III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.C.1) (86-12-11)
Nonconformance Reports (NCRs) were written for the 60 circuit
breakers.
For 58 of these breakers, the cable was #2AWG size or less.
This enables the connections to be made directly to the circuit
breaker. This eliminated the need for the extensions and barriers.
Originally, the remaining two breakers were reworked by utilizing
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'
longer screws which assure sufficient thread engagement for the bus
extensions.
In addition, all three phases of the circuit breaker
extension were insulated with heat shrink tubing; eliminating the need
s
%s
for the barriers. Subsequently, a design change eliminated the use of
one of these two breakers.
,
The specification for MCCs was revised to require Engineering approval
l
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of the use of modified connectors, terminal boards, or bus pads when
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standard sizes will not accept the cable size required by the project.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.C.1) (86-12-11)
Not applicable.
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l
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.C.1) (86-12-11)
Full compliance was achieved April 4,1986.
l
,
II.
REPLY (I.C.2) (86-12-12)
Site receiving inspection does not check bolting for proper marking
when that bolting is furnished on the equipment or packaged with the
,
equipment for site installation.
Inspection of the bolting would
,
i
normally be performed by the vendor under his inspection program.
s
1
The identified bolting inconsistencies could have resulted from
,
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deficient vendor control of bolting or from assembly / disassembly
operations at the site during which bolting could have been removed
s
and incorrect bolting substituted.
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III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.C.2) (86-12-12)
<
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Purchase orders for safety related equipment were reviewed for
structural bolting requirements.
For equipment not yet shipped, shop
,
j
inspectors will verify correct bolting prior to shipment.
A'10% sample of safety related rotating mechanical equipment in
Urit 1, which included at least one item from every purchase order,
was reviewed to verify that items in the field are in compliance with
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Page 18 of 26
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ST-HL-AE-1754, Attachment 1
bolting requirements. Out of 111 items inspected, 11 discrepancies
were found involving four vendors. An additional inspection was
conducted to inspect the remaining Unit I rotating mechanical
equipment furnished by these four vendors.
Five additional
discrepancies were found. NCRs were written and a disposition
provided for the 16 discrepant conditions in Unit 1.
NCRs have been
initiated for the components provided by these vendors in Unit 2.
Standard Site Procedures (SSP)-52, " Installation, Assembly, and
Disassembly of Permanent Plant Equipment"; and SSP-57, " Installation,
Assembly, and Disassembly of Electrical Equipment," have been
implemented containing instructions for control and verification of
fasteners during these processes.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.C.2) (86-12-12)
Not applicable.
l
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.C.2) (86-12-12)
Full compliance will be achieved on Unit I when the last NCR is closed
on October 31, 1986. Unit 2 NCRs will be worked off and closed
consistent with the Unit 2 construction sequence.
II.
REPLY (I.C.3) (86-12-13)
The NRC CAT found that the size of the nozzle and manway weld
reinforcement did not meet the requirements stated in the vendor
drawings. A total of six tanks and heat exchangers were found to
have welds that deviated from the sizes required by the applicable
drawings. No inspection of tanks and heat exchangers (subsequent to
inspection by the vendor) had been performed prior to the CAT
inspection.
l
The root cause for this discrepancy was the vendor's failure to follow
shop fabrication drawing requirements.
A contributing cause was that the project had not completed its
investigation of NRC Information Notice 85-33 prior to the CAT.
t
i
The Information Notice was received and an action plan developed in
!
June 1985. At the time of the CAT inspection, the inspection of
vendor supplied tanks and heat exchangers had not yet taken place.
III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.C.3) (86-12-13)
The undersized welds identified during the CAT inspection have been
identified on NCRs and dispositioned "use-as-is" based upon
Engineering evaluation.
Page 19 of 26
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ST-HL-AE-1754, Attachment 1
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A reinspection of pressure retaining nozzle fillet welds on tanks / heat
exchangers supplied by the vendors identified during the CAT
inspection has been performed. Additionally, a sample of similar
safety-related pressure retaining fillet welds on such products or
related products supplied by other vendors has been inspected.
The reinspection revealed additional deviations. The NCRs generated
as a result of the reinspection have been dispositioned "use-as-is"
based upon Engineering evaluation.
A review determined that there are no open purchase orders for tanks /
heat exchangers.
The status of project actions taken to address NRC Information Notices
(maintained on the Licensing Commitment Tracking System) is provided
[
to appropriate management monthly to ensure that scheduled activities
are accomplished in a timely manner.
QA has performed surveillances of field vessel fabrication work on
site with acceptable results.
.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.C.3) (86-12-13)
Not applicable.
l
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.C.3) (86-12-13)
Full compliance was achieved on September 12, 1986, when the NCRs that
document this problem were closed
II. REPLY (I.C.4) (86-12-14)
The NRC CAT found the following deficiencies in vendor supplied
components:
Page 11-14 of the CAT report stated:
"Bechtel specification 3E319ES1040 requires motors under 250
'
horsepower (HP) rating to have vendor installed terminal lugs on the
motor leads. The two air handling unit fan motors inspected,
3V111FN014 and FN016, did not have the required terminal lugs. The
braided jackets on the fan motor leads were also found to be frayed.
A third fan motor, FN002, identified by the NRC CAT mechanical
inspectors was also found in this condition. Although these are not
considered significant hardware deficiencies by the NRC CAT, she
appropriate terminal lugs need to be installed when the fan motors are
terminated to their permanent power source.
Fans FN014 and FN016 were
subsequently documented on NCR BE-3335 and fan FN002 on NCR BE-3334."
,e
Page 20 of 26
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ST-HL-AE-1754, Attachment 1
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Investigation has determined that the motors were shipped with, but
separate from, the air handling units.
Source inspection was
performed on the air handling units; but, there is no documentation
'
that the motors were inspected. Apparently, it was not understood
during receipt inspection that the motors had not been source
inspected. As noted by the NRC, the absence of lugs "are not
considered significant hardware deficiencies." The requirement for
lugs to be provided by the manufacturer is not essential to the
function of the equipment, but is intended to save field installation
manhours.
The absence of lugs would have been discovered in the
termination process and they would have been added at that time. The
NCRs will assure that the appropriate terminal lugs are installed.
Page II-14 of the CAT report stated:
"The Bechtel specification also requires motors under 250 HP rating to
have an insulation rating of Class F (135* C) or H (150 C). The
nameplate and vendor manual for the reactor makeup water pump motor
3R271NPA101A indicate the motor insulation is only Class B (110 C).
This requires evaluation by the licensee to assure the motor is
adequate for its intended service environment."
An investigation of the motors supplied under this purchase order
determined that the nameplates and equipment data sheets certified
compliance with the insulation class specified in the original
specification, i.e., Class B; however, the vendor actually as a
practice supplies the higher grade. When Bechtel later upgraded the
insulation class, the need to change the nameplates and data sheets
was not recognized. The vendor has confirmed that the correct
insulation was supplied and the nameplates, equipment data sheets, and
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equipment qualification reports have been corrected to reflect the
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class of insulation actually installed.
III. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED (I.C.4) (86-12-14)
NCRs were issued to correct the hardware items and a Field Change
Request (FCR) was issued to correct the vendor documentation.
An evaluation was performed of safety-related motors including fans
to see if Bechtel had upgraded the insulation class resulting in
inaccurate nameplates or data sheets. One additional case of a
purchase order which was upgraded was identified but no inconsis-
tencies exist between nameplates and data sheets with respect to
insulation class.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.C.4) (86-12-14)
Not applicable.
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.C.4) (86-12-14)
Full compliance was achieved on September 26, 1986, when the
evaluation of other safety-related motors was completed.
Page 21 of 26
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ST-HL-AE-1754, Attachment 1
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NOTICE OF VIOLATION II.A
I.
NRC STATEMENT
"10 CFR Part 50, Appendix B, Criterion VIII, as implemented by the STP
QAP, Section 8.0, requires that measures be established for control of
materials, parts, and components to prevent the use of incorrect or
defective items. The applicable specifications for load transformers
and battery racks required the use of ASTM A-307 bolting. ASTM A-307
requires that each bolt be marked, as a minimum, with the
manufacturer's identification.
Contrary to above, at time of the inspections, unidentified fasteners
had been used in the field assembly of electrical equipment.
(CAT PEA 5 as modified by Inspection Report 50-498/86-12;
50-499/86-12)"
II.
REPLY (II.A) (86-12-15)
Unmarked bolts were installed in equipment whose design requirements
call for ASTM A-307 bolts. Equipment vendors supply fasteners either
installed in the equipment or packaged separately to be installed by
site personnel. The higher strength bolting can be identified by ASTM
or SAE markings; however, low strength carbon steel bolts are
frequently supplied without markings.
It is common practice for
equipment manufacturers to use ASTM or SAE bolts of low strength
carbon steel interchangeably.
A-307 bolts without the manufacturer's mark have been bulk purchased
for general field use. These bolts are uniquely identifiable by a
black zinc chromate coating. The black zinc chromate coating does
provide a positive method of identification, is more readily visible
than markings, and is particularly useful for the small fasteners used
extensively in HVAC and electrical installations that cannot be
i
otherwise marked. Although originally purchased for use in electrical
I
raceway installations, this black zinc chromate bolting can be (and
was) substituted wherever safety related A-307 bolting is required.
This substitution was not specifically authorized by the specification
for safety related non-ASME bolting.
III. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED (II.A) (86-12-15)
Specification 4A010GS1009, Safety Related Non-ASME Bolting Material,
has been revised to authorize the substitution of the black zinc
chromate bolting without ASTM marking in any installation requiring
ASTM A-307 bolting.
A test was conducted at Southwestern Laboratories using 60 bolts
chosen at random representative of the sizes and surface finishes used
at STP. The resulting data shows that the samples tested exceed the
Page 22 of 25
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ST-HL-AE-1754, Attachment 1
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minimum tensile strength required by ASTM A-307, and met the chemical
properties required by ASTM. This test confirmed that the low
strength carbon steel bolting supplied to the STP meets ASTM A-307
requirements.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (II.A) (86-12-15)
Not applicable.
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (II.A) (86-12-15)
Full compliance has been achieved.
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Page 23 of 26
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ST-HL-AE-1754, Attachment 1
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4.
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NOTICE OF VIOLATION II.B
I.
NRC STATEMENT
"10 CFR Part 50, Appendix B, Criterion XVI, as implemented by the STP
QAP, Section 16.0, requires that measures shall be established to
assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, defective material and equipment, and
nonconformances, are promptly corrected.
Contrary to these requirements, three nonconforming conditions were
identified by both the NRC inspector and the licensee regarding bent
instrument nozzle piping on both the Unit 1 and Unit 2 reactor coolant
system pressurizers and five missing orifices. One to three weeks
elapsed from the initial observations before issuance of a
nonconformance report or the application of " hold tags" to the
equipment for the nonconforming conditions. The subsequent issuance
of the nonconformance report and the application of hold tags occurred
after the NRC questioned licensee personnel regarding their progress
toward resolution of the observed problem.
(Inspection Report
50-498/85-24; 50-499/85-21)"
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II.
REPLY II.B (1) (86-12-16)
Although the skewed pressurizer nozzle was outside the acceptable
tolerance of i 1 , it was anticipated that an Engineering evaluation
would confirm that the nozzle was acceptable as is.
Project personnel failed to recognize that this deficiency required a
nonconformance report (NCR) even though the W Field Deficiency Report
(FDR) written to document the deficiency was anticipated to be
dispositioned "use-as-is."
III.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED II.B (1) (86-12-16)
A NCR was initiated and hold tags were placed on the nozzle on
January 31, 1986.
In addition, Standard Site Procedure (SSP)-8,
"Nonconformance Reports," was revised to require W to initiate a NCR
for deficient conditions detected by W personnel against items where W
is the "N" Certificate Holder / Supplier.
IV. CORRECTIVE STEPS v!HICH WILL BE TAKEN II.B (1) (86-12-16)
Not applicable.
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED II.B (1) (86-12-16)
The project was in full compliance on January 31, 1986.
Page 24 of 26
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ST-HL-AE-1754, Attachment 1
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II. REPLY II.B (2) (86-12-16)
The NRC raised a question as to the location of the orifices in the
instrument taps indicated on the applicable P& ids. An investigation
determined that the flow orifices were not installed.
See response to Notice of Violation I.B.3.
Nonconformance reports are normally not written to document design
inconsistencies. The specific condition of missing flow restrictors
was corrected by the issuance of a Design Change Notice revising the
applicable piping drawings. However, a NCR was issued on January 31,
1986, to further control this condition and facilitate correction of
the hardware problems.
III. CORRECTIVE ACTION AND RESULTS ACHIEVED II.B (2) (86-12-16)
See Section II above.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN II.B (2) (86-12-16) ,
Not applicable.
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V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED II.B (2) (86-12-16)
Not applicable.
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II. REPLY II.B (3) (86-12-16)
On January 20, 1986, the site inspector informed HL&P that the
Unit 2 pressurizer had a severely bent instrument tap. As a result
of these discussions, a nonconformance report (NCR) was generated on
January 20, 1986. However as of the day of the NRC exit (January 31,
1986), the appropriate hold tag had not been placed. The hold tag was
placed immediately following the exit.
Investigation revealed that a
considerable backlog existed in the NCR hold tag process which could
have delayed placing of hold tags for up to two weeks. This
constituted an unacceptable delay between the identification of a
problem and the placing of the appropriate hold tag.
III. CORRECTIVE ACTION AND RESULTS ACHIEVED II.B (3) (86-12-16)
As indicated above, a hold tag was placed on the bent instrument tap
immediately following the NRC exit.
In addition, administrative
changes were made in the NCR/ hold tag process to speed up the
placement of hold tags.
Specifically, the process has been changed so
that immediately after NCR validation, a NCR number is obtained and a
Page 25 of 26
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ST-HL-AE-1754, Attachment 1
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hold tag placed.
Before this change, NCRs were sent to the NCR
coordinator for assigning of numbers and then returned to the
initiator for placement of hold tags.
QC inspectors have been trained
in the revised procedural requirements.
IV. CORRECTIVE STEPS WHICH WILL BE TAKEN II.B (3) (86-12-16)
Not applicable.
V.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED II.B (3) (86-12-16)
The project was in full compliance on April 17, 1986, when the
training of the QC inspectors was completed.
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Page 26 of 26
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