ST-HL-AE-1638, Responds to Potential Enforcement Actions Cited in Const Appraisal Team 851021-1101 & 1112-22 Insps & Items Mentioned in NRC & Executive Summary.Aggressive Action Taken in Areas Requiring Improvement,Per Util

Responds to Potential Enforcement Actions Cited in Const Appraisal Team 851021-1101 & 1112-22 Insps & Items Mentioned in NRC & Executive Summary.Aggressive Action Taken in Areas Requiring Improvement,Per Util

ML20203N102
Person / Time
Site:	South Texas
Issue date:	04/02/1986
From:	Goldberg J HOUSTON LIGHTING & POWER CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
CON-#286-676 OL, ST-HL-AE-1638, NUDOCS 8605050031
Download: ML20203N102 (57)

Text

8 r-The Light Company n.,m,,, ugumim._ m n.,e> n.,mi.,,ame>i m-n April 2, 1986 ST-HL-AE-1638 File No. D.41

- q' n-g { { \\/7 F

{;ir~~

-1 Mr. Robert D. Martin Regional Administrator, Region IV j< g.g g U. S. Nuclear Regulatory Commission t 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 l {

~j South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Action Taken In Response To The NRC CAT Inspection

Dear Mr. Martin:

HL&P has carefully reviewed the report of the inspection conducted by the CAT on October 21-November 1, and November 12-22, 1985, at the South Texas Project site, as well as the NRC cover letter of February 5, 1986, including Appendix A (Executive Summary) and Appendix B (Potential ,

Enforcement Actions).

Attachment 1 to this letter describes our actions in response to the Potential Enforcement Actions. Attachment 2 provides responses to items which were mentioned in the transmittal letter and Executive Summary which were not identified as potential enforcement actions.

We have noted that the CAT concluded that " Hardware and documentation for construction activities were generally in accordance with requirements and licensee commitments"; however, the inspection identified a number of construction program weaknesses. These overall conclusions are generally similar to those that were presented to us at the CAT exit meeting which was held on November 27, 1985. As stated in our letter of January 10, 1986, we have taken aggressive action in those Project areas which require improvement to assure completion of the Project in a quality manner.

Our letter of January 10, 1986, described a number of measures that we had taken to address NRC findings preliminarily identified at the CAT exit meeting. Those actions are already producing significant improvements in Project performance in many of the areas addressed by the CAT findings. We were pleased to note in Mr. Taylor's cover letter of February 5, 1986, that those actions will be included as part of the NRC's continuing review of the CAT report.

L1/NRC/ltr 8605050031 860402 I PDR ADOCK 05000498 G pop

%r 358 t/t

1 t

• Houston Lighting & Power Company ST-HL-AE-1638 File No. D.41 Page 2 of 3 The corrective actions described in my January 10 letter and in Attachment 1 are bringing about measurable improvement in the quality of completed construction work. For example, the number of deficiencies identified by Project Quality Control in installed components has been continuing to trend downward. This demonstrates that the actions taken subsequent to the CAT exit (i.e., increased training of craftsmen and quality control inspectors, pre-inspection checks of completed construction work by craft supervision, better defined accountability of craft supervision for the quality of their work, and increased management presence in the work areas) have significantly improved the Project's performance in completing installations in accordance with design requirements.

There also have been improvements in the tit iliness of implementing corrective actions. Since the beginning of 1986, I and key members of my staff have increased our presence on site. In that period there has been a reduction in the number of open NCRs and other QA deficiency documents and a trend toward further reduction.

Examples of prompt corrective actions of which your staff is aware include timely action to resolve the recent 10CFR50.55(e) potentially reportable items concerning the assumptions in the FSAR Chapter 15 analyses related to the auxiliary feedwater system and the deficiencies in the installation of multi-pin connectors. We also acted promptly to resolve an issue regarding the adequacy of the QC inspection of structural steel bolts raised by an NRC inspector during a recent inspection. The question waa addressed by a detailed analysis during the course of the NRC inspection and resolved to the inspector's satisfaction.

We hope that the observable improvements I have noted will be taken into account as the NRC further considers the matters identified in Appendix B. I would also call to your attention that, in the course of reviewing the CAT report, we have identified information not available to the CAT team, which bears importantly on some of the items listed in Appendix B and puts them in a new perspective for purposes of considering whether they warrant enforcement action. This new information is included in Attachment 1.

As indicated in our letter of January 10, 1986, HL&P management is fully committed to completing the South Texas Project in a quality manner.

We believe that the actions taken as a result of the CAT inspection demonstrate our ability to identify and correct problems, our responsiveness to NRC concerns, and our commitment to take actions that address and resolve not only specific problems but their underlying causes.

Ll/NRC/ltr

)

+ Houston Lighting & Power Company ST-HL-AE-1638 File No. D.41 Page 3 of 3 We would be pleased to provide any additional information that would be useful to the NRC in reviewing these matters.

Very truly yaurs, s'

• g-J. H. Goldberg 6t_{)

Group Vice President,iluclear JEG:MRW:kg Attachment 1. Responses to Potential Enforcement Actions Attachment 2. Response to Cover Letter & Executive Summary h

L1/NRC/1tr i

b

t s

Ilouston Lighting & Power Company ST-HL-AE-1638 File No.: D.41 cc:

Hugh L. Thompson, Jr. , Director Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 N. Prasad Kadambi, Project Manager La nny A. Sinkin U.S. Nuclear Regulatory Commission Christic Institute 7920 Norfolk Avenue 1324 North Capitol Street Bethesda, MD 20814 Washington, DC 20002 Claude E. Johnson Oreste R. Pirfo, Esquire Senior Resident Inspector /STP IIearing Attorney c/o U.S. Nuclear Regulatory Office of the Executive Legal Director Commission U.S. Nuclear Regulatory Commission P.O. Box 910 Wanhington, DC 20555 Bay City, TX 77414 Charles Bechhoefer, Esquire M.D. Schwarz, Jr. , Esquire Chairman, Atomic Safety &

Baker & Botts Licensing Board One Shell Plaza U.S. Nuclear Regulatory Commission Houston, TX 77002 Wa:ahington, DC 20555 J.R. Newman, Esquire Dr. James C. Lamb, III Newman & Holtzinger, P.C. 313 Woodhaven Road 1615 L Street, N.W. Chapel Hill, NC 27514 Washington, DC 20036 Judge Frederick J. Shon Director, Office of Inspection Atomic Safety and Licensing Board and Enforcement U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555

, Mr. Ray Coldstein, Esquire T.V. Shockley/R.L. Range 1001 Vaughn Building Central Power & Light Company 807 Brazos P.O. Box 2121 Austin, TX 78701 Corpus Christi, TX 78403 Citizens for Equitable Utilities, Inc.

H.L. Peterson/C. Pokorny c/o Ms. Peggy Buchorn City of Austin Route 1, Box 1684 P.O. Box 1088 Brazoria, TX 77422 Austin, TX 78767 Docketing & Service Section J.B. Poston/A. vonRosenberg Office of the Secretary City Public Service Board U.S. Nuclear Regulatory Commission P.O. Box 1771 Washington, DC 20555 San Antonio, TX 78296 (3 Copies) l Advisory Committee on Reactor Safeguards U.S. Nuclear ReSulatory Commission 1717 11 Street Washington, DC 20555 Revised 12/2/85 L1/NRC/ltr

r- -

, ST-HL-AE-1638, AttechmInt 1 POTENTIAL ENFORCEMENT ACTION 1 I. NRC STATEMENT "10 CFR 50 Appendix B, Criterion III, as implemented by the South Texas Project (STP) Quality Assurance Plan (QAP) Section 3.0, requires that measures be established for the identification and control of <

design interfaces and coordination among design organizations. These measures shall include the review, approval, release, distribution, and revision of documents involving design interfaces.

Contrary to these requirements, at the time of this inspection:

a. The licensee failed to provide adequate interface between the design organizations (architect / engineer (AE), and the nuclear steam system supplier (NSSS)), and the organizations performing the physical work. This was evidenced by the inability of the licensee to provide a design baseline wiring drawing for NSSS supplied motor operated valves, the AE's revised designs not being provided to the NSSS for their review and incorporation into NSSS drawings, and the inability to correlate the actual wiring with current design documents. (Section II.B.3.b (8))

b. Vendor tolerance requirements for the mounting dimension of the annubar flow probe en essential cooling water piping were not included on installation drawings and subsequently a number of annubar mounting flanges were mislocated with respect to the distances from the pipe outer wall. (Section III.B.l.b)" .

Responses to parts I.a and I.b are separately set forth below:

II. REPLY (I.a)

For purposes of clarity, the three individual specifics listed in the NRC Statement are addressed separately:

A. "This was evidenced by the inability of the licensee to provide a design baseline drawing for NSSS supplied motor operated valves . . ."

During the CAT inspection it was found that a MOV was not consistent with the design baseline wiring diagram, although the MOV had not been modified after receipt. Subsequent investigation has determined that the cause of this inconsistency was that the vendor shipped two replacement Unit 2 MOVs in 1985 in a wiring configuration that included a design change which was not reflected in the design baseline drawing. At the time of the CAT inspection, the status of the design configuration of MOVs was not clearly documented; therefore, we were unable to explain this inconsistency to the CAT inspector.

1 L

, ST-HL-AE-1638, Atttchment 1 L ..

l B. ". . . the AE's revised designs not being provided to the NSSS for their review and incorporation into the NSSS drawings . ..

Bechtel elementary wiring diagrams are the controlling design documents for construction. The Bechtel elementaries for MOVs are-based upon E functional d:* sign requirements and include revisions by Bechtel. Satisfaction of E functional requirements is established by the Bechtel elementary, and revisions to these drawings need be supplied to y only if the H functional requirements are affected. Since the changes to the BEC-elementaries for the MOVs did not affect W functional requirements, the changes were not supplied to y for review.

( C. ". . . and the inability to correlate the actual wiring with the current design documents."

The primary cause of the deficiencies in wiring configuration of Unit 1MOVswasanerrormadebytheBechtelengineerresponsiQle for assembly of the Configuration Control Packaga (CCP). This engineer did not recognize the actual MOV wiring configuration and provided instructions to Construction which referenced an outdated design document. (No CCPs had been issued for Unit 2.) An additional contributing factor which affected one jumper was the

! failure to control the sequence of implementation of Bechtel CCPs.

As a result of these deficiencies, a reexamination of the interface between the AE, NSSS supplier, and the constructor was undertaken and actions taken to strengthen the interface are described under Part IV below. To determine if there was evidence of a widespread interface weakness, an investigation was performed on the Reactor Trip Switchgear (RTS) and the Solid State Protection System (SSPS). These systems are a E design and had changes initiated by H and Bechtel that were implemented by both E and Ebasco. The investigation concluded that the changes to both systems were correctly implemented, f III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.a) t An inspection program was implemented by which individual MOVs were examined, reworked, and upgraded, as required, leading to release for turnover and startup testing.

{ All 58 MOVs supplied by E for Unit 1 have been inspected by a special l task team, and the rework will be complete by June 1, 1986. This same inspection and rework program will be performed on the Unit 2 MOVs.

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.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.a)

The Configuration Control Package (CCP) will continue to be used to control the implementation of all future E design changes to MOVs.

2

ST-ht-AE-1638, Attachssnt 1 Strengthened design controls have been put in place to assure that all y changes, as identified by the H 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 other CCPs.

A procedure has been issued to clarify and strengthen the implementation responsibilities between the various organizations concerning CCPs. Completed CCP work and "in process" CCPs will be reviewed for proper sequencing.

To prevent any confusion relevant to the MOVs wiring design, a Bechtel wiring diagram for the Unit 1 E 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 will be developed for Unit 2.

The governing document for electrical functioring of MOVs is the Bechtel elementary drawing. All of the appropriate non-H vendor wiring drawings are being revised to assure compatibility with the Bechtel elementary drawing. Future changes will be reflected, where appropriate, with a change to the vendor drawing as well as to the Bechtel elementary drawing.

MOVs that are purchased in the future will be inspected upon receipt for proper wiring configuration.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.a)

Rework of Unit 1 hardware is scheduled to be complete June 1, 1986.

The schedule for Unit 2 hardware is under development.

The review of completed and "in process" CCPs will be completed on June 27, 1986.

II. REPLY (I b)

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 tolerance a 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 ACillEVED (I.b)

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 would be satisfied by a lower level of accuracy of the flow elements than provided by the original 3

, ST-HL-AE-1638, Attcchmtnt 1 vendor tolerances. The vendor has confirmed that less strict tolerances would be adequate to provide the lower level of accuracy actually required. The Engineering evaluation also verified that 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.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I b)

Not applicable V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I,b)

Full compliance was achieved on January 3, 1986.

4

ST-HL-AE-1638, Attcchm:nt 1 POTENTIAL ENFORCEMENT ACTION 2 I. NRC STATEMENT "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 commensurate with those applied to the original design.

Contrary to these requirements, at the time of this inspection:

a. 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 Bechtel drawing No. 3M01-0-S-4043.

(Section VII.B.3.b.(5))

b. Six field change requests (Nos. BC-01202, CC-03426, CC-04949, CC-04461, BS-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))"

Responses to parts I a and I.b are separately set forth below:

II. REPLY (I.a)

The CAT Inspection Report (Ref.1), Table VII-6, further defines the details of the finding as follows:

"Bechtel drawing No. 3M01-9-S-4043, issued on November 5, 1984, revised the structural steel floor plan in the Mechanical and Electrical Auxiliary Building between column lines 30 and 32, and column lines M8 and H, at plan elevation 69 ft. -6 in. Field Change Notice (FCN) 1-C-0265, issued on March 6, 1985, provides the fabrication details for the structural steel adjacent to a pair of HVAC openings located in the southeast corner of the floor plan. The CAT team requested the calculations for the structiral steel detailed on the FCN. Bechtel indicates that engineering judgment was used to size the installed steel. However, this engineering judgment was not documented. The Bechtel civil / structural site organization has verbally indicated that ca lculations could not be retrieved for any of the four above-referenced days of structural steel in the Mechanical and Electrical Auxiliary Building."

The addition of four bays of structural steel refers to the floor framing added in Revision 1 of Bechtel Drawing 3M01-9-S-4043 issued on November 5, 1984.

5

ST-HL-AE-1638, Attcchm:nt 1 Revision 0 of the subject drawing, issued by Bechtel on July 23, 1984, deleted the same four bays of steel from the original drawing issued-for-construction by the previous architect engineer, Brown &

Root (B&R), and substituted revised framing details. The Revision 0 changes were dictated by layout changes in effect at the time.

The back-up calculations for the deleted steel framing, and for the modifications to the framing due to the layout change were documented in calculations SC-081-0 and CC-6140-0 respectively. SC-081-0 was the B&R calculation accepted by Bechtel on July 16, 1984, and partially superseded at the area in question by Bechtel calculation CC-6140-0 issued June 30, 1984.

Revision 1 of the drawing was issued as a result of a further change in layout which reinstituted the B&R design with minor modifications.

At the time Revision 1 was issued, SC-081-0 was accepted in whole by Bechtel as the appropriate backup calculation for the steel framing of the area in question and calculation CC-6140-0 was voided.

The minor modifications introduced with Revision 1 of the drawing which were not included in calculation SC-081-0 consisted of changes to two beams (i.e., shortening their span); deletion of two beams; and the addition of one beam (of a larger size than an existing beam with the same span) as a result of enlarging an HVAC penetration in the southeast corner of the platform.

Bechtel's statement to the CAT inspector that engineering judgment was used to size the installed steel refered to the sizing of the members used for framing the modified HVAC opening. These members, as well as the remainder of the members for the four bays of steel mentioned in the CAT report, support only grating with a live load of 100 psf, a stairway, and light HVAC duct loads at the penetrations. As stated above, calculation SC 081-0 provided the back-up for sizing of members shown on Revision 0, as well as the main members for the four bays reinstituted by Revision 1 of the drawing.

Engineering Department Procedure 4.46, " Project Drawings,"

specifically assigns to the Engineering Group Supervisor the responsibility for " completion of design work on drawings" and for an

" engineering check for conformance of drawings to design calcula-tions". A comparison of Revision 0 and Revision 1 of the framing around the HVAC opening in question was made, and it was determined by the responsible engineers that the nature of the change did not warrant a detailed analysis. The engineer's initials on Revision 1 of the drawing attest to the acceptability of the change.

As noted by the NRC, FCN 1 C-0265 provides fabrication details of steel previously designed in Revision 1 of the drawing. The fabrication details provided on the FCN would not affect the design calculation.

In summary, a calculation was performed by B&R and accepted by Bechtel for the four bays of structural steel shown on the November 5, 1984, revision of Bechtel drawing No. 3M01-9 S 4043. Other modifications introduced by Revision 1 of the drawing were minor and accepted by 6

V ST-HL-AE-1638, Att: chm:nt 1 engineering evaluation based on a review of the original B&R calculations. This evaluation was documented by the engineer's signature on the drawing revision. Therefore, design control measures consistent with the nature of the changes involved and commensurate with the measures applied to the original design were applied to the design changes introduced by the subject drawing revision. Never the less, because of the concern raised by the NRC, a calculation (Calculation SC-081-1 Addenda A & B) was performed which confirmed the engineer's evaluation.

We request the NRC to reconsider whether this is an example of a violation of Criterion III.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I a)

Not applicable.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.a)

Not applicable V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.a)

Not applicable II. REPLY (I,b)

Each of the observations cited in the proposed 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:

Observation Cause

1. FCR BC-01202 Failure to follow procedures

2. FCR CC-03426 Applicability of Unit 1 change documents to Unit 2

3. DCN No. 7 Applicability of Unit 1 change documents to Unit 2

4. FCR CC-04949 Drafting mistake

5. FCR CC-04461 Applicability of Unit 1 change documents to Unit 2 7

z

, ST-HL-AE-1638, Atttchment 1 Observation Cause

6. FCN BS-1-0194 Minor clarity concern

7. FCN BS-1-0235 Drafting mistake When an amendment initially generated to request or document a change to the proposed or existing design in one unit is subsequently ,

extended to apply to the remaining unit, this extension is not considered a modification. Unless otherwise noted, changes to one unit are routinely reviewed at incorp. ration for applicability to the other unit. Application of the changt to the other unit is not considered a change in technical scope. Therefore, such changes are not treated as modifications.

In addition to the Unit 2 applicability concern, the examples cited in Table I reflect two cases of minor drafting mistakes and one case where technical information was revised i uring incorporation of the amendment.

Based upon a concern identified by the Institute of Nuclear Power Operations Construction Project Evaluation of STP in May 1985, the project instituted and recently 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 amendments had an impact on construction. The items identified during this review were similar in character and occurred during the same time frame as Item 1 in Table I which was identified by the CAT.

Based upon the low frequency of construction impact, we believe the program is adequately controlled, and we request the NRC to reconsider whether this is representative of a violation of Criterion III.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.b)

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 approved amendmont 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 been trained.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.b)

No further corrective action is required beyond that described in Section III.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.b)

The project is in full compliance with established requirements.

8

]

\

ST-HL-AE-1638, Attcchm;nt 1 Table I Results of Investigation of Observations

1. "Fiald 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 incorporated 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 to 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 ocher-wise 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. Engineering does not view this to be a change of technical scope that falls under the auspices of a modification.

The conclusion is that the design Engineer erred during the incorpora-tion 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-03426 was issued on June 23, 1984 against Rev. 7 of Bechtel drawing 3M35-9S-37417. The FCR was issued to shift a piece of supplementary steel in plan to provide support for a hanger for Unit 1 only. The FCR was incorporated into Rev. 8 of the Bechtel drawing, but this detail is now applicable to both Units 1 and 2. The drawing revision block does not indicate that the FCR was modified upon incorporation into the drawing. The Bechtel civil / structural site engineering organization indicates that the decision was made to shift for Unit 2 as well, at the time the FCR was incorporated into the drawing."

l Table I-l

ST-HL-AE-1638, AttcchmInt 1

RESPONSE

As previously stated in response to Item No. 1, Engineering does not view the unit applicability as a modification to the technical content of the amendment. The drawing in question is designated for use in both Units 1 and 2.

3. "DCN No. 7 was issued on September 26, 1984 against Rev. 1 of Bechtel drawing 3C01-9-S-1600. The DCN was issued to provide support details for RHR pumps A, B and C in Unit 1 containment. The DCN was modified upon incorporation into Rev. 2 of the Bechtel drawing, as noted on the drawing revision block, to be applicable to both Units 1 and 2."

RESPONSE

Refer to Item No. 2 response.

4. "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."

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 incorporated into Revision 8 of the parent drawing and the hole size appropriately ideatified.

5. "FCR BC-01279 was issued on July 24, 1984 against Rev. 1 of Bechtel drawing 7G22-9S-2010. The FCR adds a supplementary steel beam to provide support for exhaust fans 8V321(2)VFN013 and -4 (nonsafety) in the turbine generator building. The addition of the supplementary steel is required because of interference with a concrete block wall.

FCk 3C-01279 was superseded by FCR CC-04461, which restricted the identical support detail for installation in the Unit 1 only.

FCR-04461 was modified upon incorporation into Rev. 3 of the Bechtel drawing, as noted in the drawing revision block, for installation in Units 1 and 2. The Bechtel civil / structural site engineering organization issued DCN No. 4 on November 18, 1985 to restrict the application of FCR CC-04461 to Unit 1 only."

Table I-2

.- ST-HL AE-1638, Attechasnt 1 L RESPONSE l FCR-04461 was technically incorporated as written. The reference to the modification was due to the differences in the manner used in L dimensioning the members. Also in the FCR the existing concrete block is shown; whereas, in the referenced framing drawing it is not shown.

Framing drawings, as a standard, do not depict this level of detail; the intent of the drawing is to identify and locate structural steel.

General arrangement, or architectural drawings, would identify the existence and location of block walls. This is not a modification to the technical content of the previously approved amendment document.

Relative to the applicability of the change to both Unit 1 and 2, Engineering believed that the concrete block wall interference would exist for both units and therefore issued the change applicable to both. However, Construction decided that since the block wall had yet

!. to be installed, it would be more efficient to carry the support steel all the way out and provide a block out in the wall for the beam to pass through, and thus eliminate the need for an additional member.

As previously stated, the unit applicability of the amendment is not a modification.

6. "FCN BS-1-0194 was issued on July 9,1984 against Bechtel drawing CV-9010-GU0006, Rev. 1. The FCN revised the bill of materials for a pipe support configuration to allow the installation of a rigid sway strut from bulk stock for Unit 1 only. The FCN also specified the center-to-center dimensions for the Unit 1 struts. However, the drawing did not properly specify the different center-to-center (C-C) dimensions required for the struts. The C-C dimensions for the Unit 2 struts were listed in the bill of materials (apparently past practice) while the C-C dimensions for the Unit 1 struts were dimensioned on the drawing. However, the drawing did not restrict the use of these strut C-C dimensions to the Unit 1 struts. The Bechtel pipe support group site engineering organization issued DCN No. 1 on November 18, 1985 to correct the drawing."

RESPONSE

The referenced FCN identified that the Unit 1 struts were not available on site and had to be obtained from field stock and cut to fit. The drawing revision that incorporated the FCN still showed the center to center (C-C) dimensions of the Unit 2 struts in the bill of materials. The bill of materials showed the Unit 1 strut C-Cs to be the stock length (i.e., 103 inch) and noted they were to be " field cut to fit". The field cut C-C dimensions of the Unit 1 struts (27 5/16" and 34 7/8") were provided on the elevation drawing along with the new Unit 1 as-built pipe center line dimensions. The new Unit 1 as-built pipe center line dimensions were flagged " Unit 1 only" but the corresponding Unit 1 strut C-C dimensions were not. The Unit 2 struts were provided in accordance with the C-C dimensions shown in the bill of materials and field cut dimensions were not applicable. A DCN was issued duric; the CAT inspection to flag the C-C dimensions as " Unit 1 only" in order to eliminate confusion during erection of the Unit 2 supports.

Table I-3 I

ST-HL-AE-1638, Att:chment 1

7. "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 1 and 2. The supporting steel for these supports appeared to require stiffeners, and the team then reviewed the pipe support calculation. Rev.1 of calculation l 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 i

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 l

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

l Failure to cloud the specific change (i.e., additional stiffener l 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.

I i

l l

Table I-4

ST-HL-AE-1638, Attcchm2nt 1 POTENTIAL ENFORCEMENT ACTION 3 I. NRC STATEMENT "10 CFR 50 Appendix B, Criterion 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.

Contrary to the these requirements, at time of this inspection:

a. The licensee failed to identify the deficiencies in the bolting of load-side terminal extensions and in the insulating barriers supplied with certain molded case breakers in motor control centers. These deficiencies have the potential for causing phase-to-phase faulting or inadvertent circuit interruption.

Further, the licensee was not able to confirm that the load-side terminal extensions or insulating barriers were seismically qualified. (Section II.B.3.b.(4))

b. The NRC CAT inspectors found several deficiencies in vendor supplied components. The deficiencies included undersized welds in tanks and heat exchangers and radiographs which did not have the required weld and film quality. These also include 5KV 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)"

Responses to parts I.a and I.b are separately set forth below:

II. REPLY (I.a)

An examination of the Class lE 480 volt Motor Control Centers (MCCs) identified the following deficiencies:

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 l reducing the available length of screw thread for making a proper electrical connection.

9

0 .

, ST-HL-AE-1638, Atttchment 1

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 (60) circuit breakers (30 in each unit) had tha 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 configuration or other similar hardware details.

Since the MCCs were subject to source surveillance, receipt inspection consisted only of a visual inspection for exterior damage and a confirmation that the required paperwork was present and correct. The 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 10CFR50.55e on March 26, 1986.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.a)

Nonconformance Reports were written for the 60 circuit breakers. For 58 of these breakers, the cable was #2 AUG size or less. These connections were made directly to the circuit breaker. This eliminated the need for the extensions and barriers.

10

y

, ST-HL-AE-1638, Attachmsnt 1 The remaining 2 breakers were reworked by utilizing longer screws which assure sufficient thread engagement for the bus extensions. In addition, all 3 phases of the circuit breaker extension were insulated with heat shrink tubing; eliminating the need for the barriers.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.a)

The specification for MCCs will be revised to require Engineering approval of the use of modified connectors, terminal boards.,or bus pads when standard sizes will not accept the cable size required by the project.

V, DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.a)

April 30, 1986 when the specification change is issued.

II. REPLY (I.b, UNDERSIZED WELDS)

For clarity, the three individual specifics listed in item b. are addressed separately:

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 seven tanks and heat exchangers were found to have welds that deviated from the required drawing sizes. No ,

inspection of tanks and heat exchangers (subsequent to inspection by the vendor) had been performed prior to the CAT inspection.

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.

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.b. UNDERSIZED WELDS)

The actions below have been taken on the undersized welds in tanks and

! heat exchangers: (Reference Table IV-5)

1. Undersized fillet welds on Diesel Fuel Storage Tank supplied by Brown-Minneapolis Tank (BMT). NCR HM-3094 issued, dispositioned "use-as-is."

2. Undersized fillet welds found on BMT supplied Component Cooling Water (CCW) surge tank. NCR HM-3075 issued, dispositioned "use-as-is."

1 i 11 4

, ST-HL-AE-1638, Attach: tnt 1

3. Undersized fillet welds found on Struthers-Wells CCW heat exchanger. NCR HM-03074 issued, dispositioned "use as is."

4. Undersized fillet welds found on Joseph Oat supplied Residual Heat Removal (RHR) heat exchanger. NCR HM-3022 issued, dispositioned "use as is."

5. Manway nozzle incorrectly fabricated on Richmond Engineering Company supplied volume control tank. NCR HM-3095 issued, dispositioned "use as is."

6. Undersized fillet welds on Southwest Fabricating and Welding supplied accumulator tank. NCR HN-3032 issued, dispositiened "use as is."

Construction Inspection Plan (CIP) 2.2-66 has been issued to perform a reinspection of pressure retaining nozzle fillet welds on tanks / heat exchangers supplied by the vendors identified above. Additionally, a sample of similar pressure retaining fillet welds on such products or related products supplied by other vendors will be inspected.

A review determined that there are no open purchase orders for tanks / heat exchangers.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.b, UNDERSIZED WELDS)

The result of the inspection required by the CIP will determine the extent of this condition. Appropriate action will be taken.

Additionally, QA will perform surveillances of any vessel fabrication work on site to assure compliance with weld size requirements.

The status of project actions taken to address NRC Information Notices (maintained on the licensing commitment tracking system) will be provided to appropriate management, monthly, to ensure that scheduled activities are accomplished in a timely manner beginning in April 1986.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.b, UNDERSIZED WELDS)

The inspection required by the CIP will be completed by May 30, 1986.

A schedule will be developed for any resulting rework.

l l

l r II. REPLY (I.b, RADIOGRAPHS)

The NRC CAT found several deficiencies in radiographs for vendor supplied components. The deficiencies included radiographs which did not have the required weld and film quality.

Three specific incidents formed the basis for this portion of the item of violation (reference Table IV-6). Specifically they were:

12 l

-- y

. ST-HL-AE-1638, Attachmsnt 1

1. " Linear indications were found in the backing ring welds in the demineralizer tank, serial number 37740, NCR AN-03028, and AN-0329." (Note: NCR AN-0329 does not apply to this tank.)

It is important to note that the " linear indications" do not show a deficient or rejectable condition in the pressure boundary welds of the subject vessel. Actually, they show the ends of the backing ring behind the pressure boundary weld (or inside the vessel) as having been joined using a partial penetration rather than a full penetration weld. The ASME Code,Section III, Subsection ND, does not require the weld joining the ends of the backing rings to be a full penetration veld, nor is it a requirement that the weld be radiographed.

The radiographs reviewed at the time of the CAT inspection were for the shell to head girth welds and provideu objective evidence thac the quality of these welds is in compliance with the requirements of the applicable section of the ASME Code.

The referenced Nonconformance Report (AN-03028) was written during the CAT inspection to identify that the welds joining the ends of the backing rings are not in agreement with the applicable Westinghouse drawings and welding procedures. A disposition of "use-as-is" was provided since this weld has no bearing on the structural integrity of the vessel.

2. " Yellow film was found in the film packages for the volume control tank and the pressure relief tank. The project issued SDR No. 192 to cover this deficiency."

During the CAT inspection over 4000 radiographs were reviewed, of which 3 film packets were identified as containing yellowing film.

These 3 cases are described as follows:

a. " Yellowing film was found in the film package for a 16" surge line; however, the line was deleted by design change." (Refer to Note 4 of Table IV-6, Vendor Radiographs Reviewed, of the CAT Inspection Report.)

b. Yellow film was found in a film package for the pressure relief tank. An independent NDE Level III Examiner has evaluated this film. The results of the review indicate evidence of slight discoloration, but that the film was still within site quality requirements.

c. Yellow film was found in a film package for the volume control tank. This was also reviewed by the independent NDE Level III Examiner identified in Item b above. Only one radiograph showed a definite yellowing. The independent Level III Examiner pointed out in his report that due to the overlap of adjacent shots there is still 100% coverage without using the view in question.

13

y-- p ,

ST-HL-AE-1638, Attcchmant 1 The independent Level III Examiner reported that all of the radiographs reviewed meet at least the minimum image quality requirements as determined by the penetrameter image.

Based on the small number of radiographs identified as yellowing, this problem is considered isolated.

3. " Cylinder P4131, Weld W-K-H-69, showed no evidence of retakes although the reader sheet indicates some were shot. Cylinder 4133, Weld W-K, showed a linear indication of 3/4" long at interval #2.

This appears on the films for intervals 1-2 and 2-3."

The vendor has determined that the cylinders in question were used for the manufacture of piping spools. In accordance with ANSI B31.1 (the governing specification), they do not require radiography. Long seam films were forwarded to tho job site for information only. Additionally, the radiograph exhibiting a linear indication was reviewed by the Houston Lighting & Power Level III NDE Examiner, and evaluated as a surface condition and acceptable.

Based upon this information, we request that the NRC reconsider whether the three radiographic items are examples of violation of Criterion VII.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.b, RADIOGRAPHS)

Not applicable kV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.b, RADIOGRAPHS)

Not applicable V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I b, RADIOGRAPHS)

Not applicable II. REPLY (I.b, MISCELIANEOUS)

The NRC CAT found several deficiencies in other vendor supplied components. Specifically:

A. Page II-17 of the CAT report stated that for the SkV switchgear cubicles: " Appendix C of Bechtel specification 3E159ES0012 establishes requirements for control wiring within SkV metal-clad switchgear." In particular:

1. "Sitbsection E states in part . . . The preferred terminal blocks are G.E. Catalog CR-151B2, connection U2 or connection NU2. Each terminal block shall have no less than 12 points.

14

I

. ST-HL-AE-1638, Attechment 1 Contrary to this requirement NRC CAT inspectors identified several cubicles of the 41COV switchgear which contain terminal blocks with less than the 12 points specified."

Investigation determined that a Supplier Deviation Request (SDR) had been written by the vendor and approved by Engineering (in 1979) to allow the use of 8-point terminal blocks.

We request that the NRC reconsider whether this item represents a violation of Criterion VII.

2. " Subsection Q states in part . . . Adequate space shall be provided on both sides of the terminal block for connection wires and wire markers. To allow for stripping and bending on incoming cables, terminal strips shall be located a minimum of 8-inches away from cable entrances either at top or bottom.

Contrary to this requirement NRC CAT inspectors observed the location of terminal strips to be less than 8 inches from cable entrances in several switchgear cubicles."

The requirement quoted above was included in the specification as a requirement on the manufacturer to assure adequate space for field routing of cables and to accommodate any future modifications. Following receipt of the equipment, a Configuration Control Package (CCP) was issued which deliberately utilized the empty space. Since Engineering established the requirement for the purchase of the equipment with appropriate spacing requirements and also designed the modification after delivery, there is no discrepant condition.

We request that the NRC reconsider whether this item represents a violation of Criterion VII.

B. 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, the 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-0335 and fan FN002 on NCR BE-0334."

+

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 documenta-tion that the motors were inspected. Apparently, it was not 15

3

, ST-HL-AE-1638, Attachmsnt 1 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. Part IV below describes additional corrective action.

C. 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 equipment qualification reports are being corrected to reflect the class of insulation actually installed.

III. CORRECTIVE ACTIONS TAKEN AND THE RESUL,TS ACHIEVED (I,b, MISCELLANEOUS)

NCRs were issued to correct the hardware items identified in B and C and a Field Change Request (FCR) was issued to correct the vendor documentation.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.b, MISCELLANEOUS)

An evaluation will be conducted to determine if required inspection of motors was performed in similar situations.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I,b, MISCELLANEOUS)

The actions to resolve the NCRs will be complete by April 15, 1986.

The evaluation described in Part IV will be completed by April 23, 1986. A schedule will be developed for any resulting actions.

16

, ST-HL-AE-1638, Attcchm:nt 1 POTENTIAL ENFORCEMENT ACTION 4 I. NRC STATEMENT "10 CFR 50 Appendix B, Criterion VII, as implemented by the STP QAP Section 7.0, requires documentary evidence that material and equipment conform to the procurement requirements shall be available at the plant site prior to installation or use of such material and equipment. This documentary evidence shall be retained at the nuclear power plant site and be sufficient 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 the plant equipment. (Section IV.B.10.b)"

II. REPLY During the CAT inspection, NDE film required by engineering specifications was requested for three (3) Component Cooling Water (CCW) heat exchangers fabricated by Struthers Wells. The film could not be located on site. It was later determined that the film was in storage at the manufacturer's facility as permitted by Section III, Paragraph NA.4910, (Continued Record Maintenance by Owner) of the ASME Code which states:

"The Owner shall be responsible for continued maintenance of the records stipulated in NA-4930 for the life of the plant, at the power plant site, the Manufacturer's plant or other locations determined by mutual agreement."

However, at the time of the CAT inspection, the Project could not determine without extensive investigation whether required NDE film was stored on site or at the vendor's facility.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED We contacted the vendor and requested that the film be forwarded to the site.

The project has initiated action to assure accountability of ASME radiographic film for STP. The action will result in a list which contains the following information:

o Purchase order number o Item number o Item description o Vendor o Specification o Status / File location 17

?

, ST-HL-AE-1638, Attechmsnt 1 This action is scheduled for completion in August 1986.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN See Section III above.

V. DATE BY WHEN FULL COMPLIANCE WILL BE ACHIEVED The Project will be in compliance in August 1986.

18

ST-HL-AE-1638, Attachmsnt 1 POTENTIAL ENFORCEMENT ACTION 5 I. NRC STATEMENT "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 defective items.

Contrary to these requirements, at the time of this inspection it was determined that traceability and control of some fasteners, including bolting for mechanical and electrical equipment of various types, and the unmarked bolting for electrical cable tray 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 l.b (3)

(c), (d) and (f)]"

II. REPLY For purposes of clarity, the three individual specifics stated in this item are addressed separately.

". . . traceability and control of some fasteners, including bolting for mechanical and electrical equipment of various types . . . has not been adequate to assure the use of correct materials."

Unmarked bolts were installed in equipment whose design requirements call for ASTM A307 bolts. Equip, ment vendors supply fasteners either installed in the equipment or loose to be installed by site personnel.

The higher strength bolting c&n be identified by ASTM or SAE markings; however, low strength carbon steel bolts are. frequently supplied without markings. It is common practics for manufacturers to use ASTM or SAE bolts of low strength carbon steel interchangeably.

The NRC concern related to unmarked A307 bolting at STP has previously been identified at other nuclear sites (e.g., Byron and Braidwood).

Extensive testing dor.e at these facilities has demonstrated that the unmarked bolting exceeded the ASTM tensile requirements of A307. A307 is the lowest grade of steel bolting that is commercially available.

The bolting in electrical equipment listed as unsatisfactory in Table VI-7 of the Inspection Report (with the exception of the bi-stable status control board monitors) pertained to unmarked A307 bolting.

These installations of A307 unmarked bolting are acceptable. The bolting for the monitors was slotted round head screws instead of the required square head bolts and will be replaced. This deficiency was identified on an NCR.

In addition to the questions regarding unmarked A307 bolts discussed above, the CAT inspection identified fasteners of lower than specified grade on vendor supplied mechanical equipment. NCRs have been issued for these fasteners.

19

. ST-HL-AE-1638, Attachmant 1 The source surveillance program did not consistently verify bolting in vendor's facilities. Following receipt, loose vendor bolting was controlled to the point of issue. Verification of subsequent field activities was not specifically performed. These issues are addressed in Part III.

. . . the unmarked bolting for electrical cable tray conduit supports . . . has not been adequate to assure the use of correct materials."

". . . 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."

Bulk purchased safety related bolting is uniquely identified at STP by a stamped triangle with the following exceptions:

a. Small fasteners (3,'8" and less) cannot be marked due to size.

b. A325 and A490 bolts are purchased only as safety related material and have ASTM required markings only.

c. Some A307 bolting is not furnished with manufacturer's symbol and triangle but instead is uniquely identified by a black zine chromate coating.

Exception (c) above is the subject of the NRC concern. The black zine 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 otherwise marked. Although originally purchased for use in electrical raceway installations, this black zine chromate bolting can be (and was) substituted wherever safety related A307 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 Specification 4A010GS1009, Safety Related Non-ASME Bolting Material, has been revised to authorize tl.e substitution of the black zine chromate bolting without ASTM marking in any installation requiring ASTM A307 bolting.

New site procedures SSP-52, Installation, Assembly, and Disassembly of Permanent Plant Equipment; and SSP-57, installation, Assembly, and Disassembly of Electrical Equipment, contain instructions for the control and verification of fasteners during these processes.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN Approximately 10% of the installed equipment on major safety related equipment orders will be reviewed for bolting requirements. These requirements have been tabulated and the engineers will perform a field check to verify that the installed bolting is correct. Any 20

, ST-HL-AE-1638, Attachmsnt 1 discrepancies will be documented by NCRs, corrected, and evaluated to determine if further inspections are warranted.

Purchase orders for safety related equipment that has not been delivered have been reviewed for structural bolting requirements. For equipment with structural bolting, the bolting requirements have been identified and the shop inspectors will verify that the bolting is correct prior to release for shipment.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The equipment bolting review will be complete by April 30, 1986.

Evaluation of the results and the schedule for additional inspections, if required, will be available by the same date.

21 2

ST-HL-AE-1638, Attachmint 1 POTENTIAL ENFORCEMENT ACTION 6 I. NRC STATEMENT "10 CFR 50 Appendix B, as implemented by the STP QAP Section 10.0, requires that a program for inspection of activities affecting quality be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.

Contrary to the above requirements, at the time of this inspection, the licensee's inspection program was ineffective in that:

a. Numerous deficiencies were identified with the installation of QC accepted instrumentation and instrument tubing. Examples of these deficiencies include dimensions exceeding tolerance limits on five installations inspected, an incorrect weld configuration on a tubing support, a missing support clamp, and a support installed in accordance with an incorrect drawing detail. Th. specific installations and deficiencies are detailed on Table II-7 of the report. (Section ll.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.l.b and IV.B.l.b)

c. On six lugged wafer valves, hex-head cap screws had been substituted for threaded studs and nuts inconsistent with the applicable essential cooling water piping installation isometric drawings and/or bill of materials. (Section III.B.l.b)

d. Ten of the twelve mechanical equipment items selected for the NRC CAT examination included components which were not constructed or otherwise installed in accordance with applicable design or specified installation requirements. (Section III.B.4.b and Table III-5) ,

e. A number of examples were found where completed structural welds l

in pipe supports / restraints in welded joints were smaller than j that specified in the design drawings. The list of walds is in l Table IV-1. (Sectien IV.B.1.b)

f. More than 60 percent of the inspection sample of 68 high strength bolts for structural steel sliding connections were installed over tight. Installation and inspection requirements had not been translated into appropriate procedures ensuring proper installation of the bolts in a " snug tight" condition. (Section V.B.2.b) l l

l l

i 22 l

l l

ST-HL-AE-1638, Attachmsnt 1

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 rework to QC accepted conduit installations. (Section II.B.1.b.(2))"

Responses to the seven specific items cited by the CAT inspection, as well as corrective actions and recurrence control, are separately set forth below. We believe that the general retraining of craft and QC inspection personnel, the requirement for pre-inspection checks of completed construction work by craft supervision, better defined accountability of craft supervision for the quality of their work, and increased management presence in the work areas discussed in HL&P's January 10, 1985, letter to R. D. Martin (Region IV) are directly responsive to the subject of this potential enforcement action; and have been effective in ensuring that construction completed subsequent to the CAT inspection meets design requirements. In addition, the QC Performance Monitoring Program (discussed under " Corrective Steps Which Will be Taken" [I.a] below) will ensure uniform application of inspection criteria; provide for the early detection of errors; and support the prompt resolution of engineering / construction interface difficulties.

II. REPLY (I.a)

It was determined that all of the inspections and acceptances of the tubed instrument installations had been performed by one (1) individual. This included the eight (8) instruments identified in the NRC CAT report.

Based upon this inspector's performance, an assessmant was conducted of the inscrumentation inspection training and certification program, the governing Construction and 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. (See Parts III and IV.)

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.a)

Work was stopped on all safety related instrumentation installations.

The individual inspector 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 100% reinspection of all safety related tubed instrument l

installations that had beer QC accepted has been accomplished to reverify inspection status.

23 i

(

r-

. ST-HL-AE-1638, Att:chssnt 1 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 personnel have been trained to the requirements and instructions in this new procedure.

An assessment of the QC instrumentation trcining and certification program has been performed. As a result, the examinations have been rewritten to include more questions on instrumentation.

A QC Performance Monitoring Program has been instituted. It is implemented by the discipline supervisor, and performed on each inspector at least monthly. Monitoring includes:

o Consistency of established methodology o Inspection records o Application of experience.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.a)

The training and certification programs, including examinations for the other inspection disciplines, are being reviewed.

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.a)

April 18, 1986, when the review of the training and certification programs for other disciplines will be completed.

II. REPLY (I.b)

Investigation has determined that the root cause of this problem was a lack of appropriate formal training of the craftsmen (pipe fitter welders) and quality control inspectors in the use of appropriate measuring devices to ensure minimum leg and throat dimensions for fillet welds on socket welded connections are adequate.

III. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED (I,b)

The appropriate construction and quality control procedures were j revised to more clearly delineate fillet weld dimensions on socket weided connections. All quality control 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 l each set is labeled with the specific pipe size schedule and fitting type.

l l NCRs have been initiated for the deficiencies. A reinspection is

! being conducted of socket welds.

l

! 24 L

r

. ST-HL-AE-1638, Attachmant 1 IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.b)

Additional steps, if any, will be determined when the reinspection is complete.

In addition, refer to Part III (l.a)

V. DATE WilEN FULL COMPLIANCE WILL BE ACHIEVED (I .b)

Reinspection will be complete by April 26, 1986 II. REPLY (I.c)

Investigation has determined that two (2) deficiencies existed in the field that were accepted by QC:

1. Cap screws of improper length had been insta112d 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. 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.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.c)

NCRs were initiated and these conditions were evaluated and determined not reportable under 10CFR50.55(e).

Appropriate Construction and Field Engineering personnel have been retrained to all of the requirements concerning cap screw substitutions.

The appropriate quality control procedure was revised to require verification and documentation of approved cap screw substitutions including length, diameter, and material type. QC personnel were trained.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.c)

A 100% reinspection of cap screw substitutions in lug wafer valves is being performed. Nonconforming conditions will be corrected.

In addition, refer to'Part III (1.a) l 25 i

w

ST-HL-AE-1638, Attachmant 1 V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.c)

The Project will be in full compliance on April 15, 1986, when the reinspection is completed.

II. REPLY (I.d)

An investigation of the CAT observations listed on Table III-5 resulted in the following actions:

1. 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 cushion so that the area under the tank could be investigated for microbiologically influenced corrosion (MIC).

High and Low Head Safety Injection Pumps, Containment Spray Pumps The investigation determined that the new 0 rings were not installed in order to utilize the old 0-rings during preliminary testing based on an agreement between Westingnouse and Bechtel:

The new O-rings are to be installed apprcximately six months prior to pump operation, at which time a vendor representative will monitor final refurbishment.

We request that the NRC reconsider whether this item is representative of a violation of Criterion X.

Containment Spray Pump, High and Low Head Safety Injection Pumps - Bolting Material Control Fastener material control for components is addressed in the response to Potential Enforcement Action #5.

RHR Pumps A and C - Torquing of Foundation Bolts Not Completed Prior to Leveling The CAT concern was that the specific sequence requirements of the Construction Process Sheet (CPS) were not followed and that as a result, subsequent torquing of the foundation bolts could affect the leveling already achieved. Our investigation has concluded that this installation was performed in accordance with the CPS and the referenced drawings for equipment installation.

As identified by the CAT inspector, the initial step in the installation sequence was to install the pump supports which 26

~

. ST-HL-AE-1638, Attachmant 1 suggests that final torquing of the foundation bolts is achieved.

We failed, however, at the time of the inspection to make clear to che NRC inspector the companion requirements of the mechanical equipment installation drawing SYOl9M24002 (also listed on the construction process sheet) which specify that the anchor bolts be tightened "sufficiently to tightly clamp all shim stacks" prior to leveling. The same drawing requires that final torquing cannot be performed until the grout has set, which is to be done after rough alignment of the pump. The mounting pad levelness is maintained due to the process controls of tightening of the anchor bolts to the shims to achieve levelness, grouting after pump installation, and waiting until the grout is set to perform final torquing.

Based on this explanation of the procese we request that the NRC reconsider whether this item is represe aative of a violation of Criterion X.

2. 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.

An inspection of five additional support frames was conducted, and four of the five were acceptable. The fifth had numerous deficiencies similar to those identified by the CAT. All of these newly identified deficiencies, plus those previously 1

identified on HVAC components and supports by the CAT were accepted by one QC inspector, i Note: Our investigation has determined that the distance of attachment welds to the edge of the embed plate was not in violation of the drawing for the Charging Pump Supply Cooler.

Fuel Handling Building Filter Expansion Anchors These installations were reinspected and no nonconformances were identified.

[ We request that the NRC reconsider whether this item represents a i

violation of Criterion X.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.d)

The construction procedure was revised to add the requirement for a l construction process sheet for both safety and non-safety ,

mechanical /HVAC equipment. Training has been conducted.

i l

l 27 l

a

ST-HL-AE-1638, Attachm:nt 1 i

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.

We have determined that the deficiencies in HVAC support frames identified by the CAT, as well as those identified by the inspection noted in Part II.2 above, had been accepted by one QC inspector. The inspector has been removed from the project. (This is the same inspector identified in I.a.)

1. ASME Mechanical Equipment and Tanks A Standard Site Procedure has been developed and issued. This procedure is an enhancement and combines the requirements of the construction and the QC procedure.

2. HVAC Components and Supports A Standard Site Procedure has been developed and issued. This procedure is an enhancement and combines the requirements of the construction and QC procedure.

Appropriate personnel have been trained to the requirements of these procedures.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.d)

A reinspection of other commodities accepted by the individual identified in Part III is being performed.

In addition, refer to Part III (l.a).

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.d)

The Project will be in full complianca on June 30, 1986, when the reinspection of other ccmmodities is complete.

II. REPLY (I.e)

We have evaluated the information contained in Table IV-1 and determined that only the table entries listed below are the subject of the proposed Notice of Violation:

Table IV-1 Applicable Pipe Item Support Deficiency (3) CC-1317-HL5006 1 Undersize fillet veld (5) CV-1209-RR0002* 7 Undersize fillet welds *

(8) CC-1480-RR0011 3 Undersize skewed connections (9) SI-1301-HL5010 1 Undersize connection (15) CC-1303 -HL5003 2 Fillets undersize 1 Undersize skewed connection (16) SI-1105-RR0038** 1 Shewed fillet undersize **

28

. ST-HL-AE-1638, Attichmint 1

• A review of the NCR generated against this support and the applicable design drawing shows evidence that only 5 fillet welds could be undersize.

• • This support was due to be reinspected in conjunction with NCR-CS-00875. The reinspection of the support had not been performed as of the CAT assessment. Subsequent to the CAT exit conference, the support was redesigned and will be replaced.

We have determined that the problem is limited to skewed connection welds based on the following:

1. Approximately 475 fillet welds were examined of which only 8 (5 on support CV-1209-RR0002; 2 on support CC-1303-HL5003; and 1 on support CC-1317-HL-5006) were undersize. We believe that this does not constitute a problem relative to the inspection of structural fillet welds, nor is it indicative of a widespread hardware deficiency.

2. The majority of skewed connections examined by the NRC CAT, however, were found to be rejectable.

3. Fifty structural steel connections having skewed welds were reinspected. No deficiencies were found.

4. All 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.

5. A sample inspection of electrical supports having skewed weld connections is being conducted.

The root cause of undersize 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.e)

Applicable procedures have been revised to incorporate detailed .'

inspection and acceptance criteria for skewed connections.

All applicable personnel have been retrained to the procedural requirements.

! NCRs have been initiated for the items in Table IV.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.e)

See Parc III In addition, refer to Part III (l.a) 29 I

ST-HL-AE-1638, Attrchmsnt 1 V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.e)

The sample inspection of the electrical supports will be completed by May 17, 1986. A schedule will be developed for any additional inspection or rework.

II. REPLY (I.f)

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 RGB 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.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I. f)

Revisions to the pertinent design drawings have been issued to provide an acceptable range of torque values.

Nonconformance Reports (NCRs) were issued and an evaluation for reportability was conducted. The evaluation concluded that the condition was not reportable. Disposition for the NCRs is to rework all the structural steel and ring duct sliding connections with slotted holes. The HVAC riser duct sliding connections were evaluated and accepted as is.

IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I.f)

See Section III In addition, refer to Part III (l.a)

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.f)

The Project will be in full compliance April 4,1986, when the rework

will be completed.

, II. REPLY (I.g)

As discussed below, all but two of the bolts on the 28 conduit runs in question (approximately 430 bolts) either had the required torque seal or documentation had been issued to accomplish the rework and subsequent reinspection.

30

. ST-HL-AE-1638, Attachmsnt 1 Each of the deficiencies identified by the NRC CAT Team was researched. Although reinspections for torque had not yet been accomplished following rework, the reinspections had not been performed because Construction had not completed the reinspection documentation and presented it to QC for inspection. This progression of the documentation and inspections followed the established procedural requirements.

We request the NRC to reconsider whether this is an example of violation of Criterion X.

III. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (I.g)

Not applicable IV. CORRECTIVE STEPS WHICH WILL BE TAKEN (I. Q Not applicable Refer to Part III (1.a)

V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED (I.g)

Not 4.pp1L able i

4

[ 31 l

ST-HL-AE-1638, Attcchmsnt 1 POTENTIAL ENFORCEMENT ACTION 7 I. NRC STATEMENT "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 conditions 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.

Contrary to these requirements, at the time of the inspection, the licensee'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."

II. REPLY The corrective actions discussed in Potential Enforcement Action #7 were undertaken by HL&P in 1985 as a result of the discovery that some of the radiographic film for the reactor vessel head was missing from the inventory provided by a Westinghouse sub-tier vendor. The specific film involved was subsequently located at the vendor's facility and forwarded to the Site Records Center.

The action to prevent recurrence was to review the remainder of the radiographic film supplied to STP under NSSS contracts. This program will be completed in March 1986; and provides a complete status of radiographic film required for NSSS ASME equipment at STP.

As stated in the violation, this action was initiated in May 1985. In July 1985, consideration was given to expanding the action to include the balance of plant suppliers. Based upon the data available at that time, (approximately 7000 radiographs reviewed, no major problems) it was decided that there was not sufficient evidence of a problem to justify expanding the corrective action.

As of March 1986, the status of approximately 80,000 radiographs has been reviewed with a deficiency rate of .4%. These statistics substantiate the decision not to expand the review effort.

We request the NRC to reconsider whether this is an example of a violation of Criterion XVI.

III. CORRECTIVE ACTION AND RESULTS ACHIEVEb Not applicable 32

1 1

, ST-HL-AE-1638, Attcchment 1 IV. CORRECTIVE STEPS WHICH WILL BE TAKEN Not applicable V. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Not applicable i

l 33 i

1 i --..__a

s ATTACIM NT 2 Responses to Items in the Transmittal Letter (Dated February 5,1986) and the Executive Summary 1 i l

_ _ _ _ _ _ _ _ _ - _ _ _ _ f

Attachment 2 ST-HL-AE-1638 NRC CONCERN A (transmittal letter page 2, Executive Summary item 10)

Timeliness of planned corrective actions for the identification of deficiencies in the separation of electrical raceways, cable and terminations.

RESPONSE

This concern was also noted in HL&P's Pre-CAT inspection and was reviewed by a Project task force which provided its recommendations in September,1985.

As discussed in the CAT report (pg. II-3), during the CAT inspection a Stan-dard Site Procedure, SSP-45 was issued which provides direction to assure the required separation between electrical items. Appropriate personnel were trained in the requirements of SSP-45 and it is now being implemented for electrical raceway, cable, and terminations. This inspection includes review of the spatial relationships of newly installed electrical items to prior installations.

In addition, a separate inspection is being conducted of electrical equipment which contains cables of more than one separation group. This inspection is to identify separation issues internal to the equipment as well as issues involving external cable and raceway adjacent to the equipment.

This inspection will be completed in April 1986.

Most separation deficiencies will be corrected before area turnover.

The reviews performed under SSP-45 and the on-going cable separation inspection provide for timely identification and correction of electrical separation issues.

1

z-L ~

Attachment 2

, ST-HL-AE-1638 NRC CONCERN B (transmittal letter page 2)

Timeliness of planned corrective actions for the identification of improper clearance between piping supports / restraints and other hardware.

{ RESPONSE The STP design minimizes the incidence of inadequate clearance between piping supports / restraints and other hardware because the buildings are large and the seismic response spectra are of relatively low magnitude. This was confirmed in a recent Limited Readiness Review Audit of 40 substantially

( completed rooms, which found only one example of a violation of the design separations acceptance criteria.

To provide added assurance that proper clearance is considered in initial installations, in August, 1985 conservative separations guidelines were issued for use by Construction. Deviations from these separations guidelines are documented and identified to Engineering.

In addition, at the time of system turnover, walkdowns are conducted to identify any additional deviations from the design separations acceptance criteria. These walkdowns occur substantially before the area turnover.

The STP design features discussed above, the utilization of the sepa-rations guidelines, and the walkdowns at system turnover assure that there is little risk that the walkdowns at area turnover will identify a significant number of inadequate clearance conditions.

r M

m

. /

Attachment 2 ST-HL-AE-1638 NRC CONCERN C (Executive Summary item 1) i lt appears that the generic aspects of prior site organization audit findings involving the AE/NSSS design interface were not applied by Westinghouse to the M0V work.

One HL&P audit report, S26-501, September 24, 1985, addressed field wiring changes by Westinghouse on other electrical equipment inspected and accepted at the site without prior written authorization for the changes.

Project team audit S15-501 dated April 15, 1985, referenced a prior HL&P audit M24-501 of Westinghouse which addressed deficiencies in the electrical area.

REPLY The previous audit findings were ir. the same topical area: design interface control. However, the specific findings from the previous audits are not related to the specific problems encountered on the M0V installations.

Our investigation and detailed explanation of the causes of the M0V problems are discussed in the response to Potential Enforcement Action 1.a.

(Attachment 1)

Audit S26-501 identified a concern with Westinghouse performing modifications prior to obtaining documented approval. No M0V's were modified without documented approval.

The generic findings identified in audit M24-501, which are also refer-enced in S15-501 were

1) Westinghouse did not have prccedures for the on-site control of Nonconformance Reports, Field Change Requests and procedure review and approval.

Although the procedures developed by Westinghouse as corrective action were applicable to the M0V work, none of the MOV problems are related to this issue.

2) Objective evidence could not be provided to demonstrate that Field Change Requests issued by Bechtel against Westinghouse design documents were reviewed and approved by Westinghouse engineering.

The corrective action provided for Westinghouse sign-off on Bechtel FCRs issued against Westinghouse documents. Although the topical area is the same, none of the MOV problems are attributable to deficiencies of this type.

3

/

r-

'O Attachment 2 ST-HL-AE-1638 NRC CONCERN D (Executive Summary item 4)

The expansion of the clay beneath the Essential Cooling Water (ECW) piping upon cessation of the site dewatering could cause differential displacements of the ECW pipes. This displacement could cause the ECW pipes to become overstressed.

RESPONSE

The bottom of the ECW trench is in the A2 clay layer at approximately

+15 ft mean sea level. The thickness of the A2 clay layer below the trench varies from 7 ft to 21 ft.

The potentially expansive nature of the A2 clay layer was recognized and taken into consideration in the foundation design (Reference 1).

Woodward-Clyde Consultants (WCC) performed laboratory tests on samples from the A2 Clay Layer and concluded that the clay exhibited expansive behavior.

However, the A2 Clay Layer was not expected to experience significant moisture content changes except near exposed surfaces in excavations. Construction procedures were implemented to minimize the amount of time clay in excavations remained exposed.

The moisture content of the clay has not changed significantly either from exposure during construction or from dewatering:

a. During construction the clay in the trench excavation was exposed for only shcrt periods before it was insulated from the effects of sun ight and wind.

b. Dewatering does not dry out the soil; it only removes the free water in the voids that is not retained by capillary action. The degree of saturation of the A2 clay layer prior. to construction was 100 percent; the degree of saturation during construction is conservatively estimated to be 90 to 95 percent.

c. A comparison 07 test results from the preconstruction period to the test results obtained during 1982-1983 ECW trench excavation (about seven years after the start of dewatering) demonstrates that the average moisture content of the A2 clay layer changed very little (24.8% to 24.6%).

When the moisture content is above 20% and the degree of saturation is greater than 90%, there is very little potential for volume change. Based upon linear swell tests and the moisture conditions at STP, WCC estimated the uppei bound of volume change in the A2 clay layer to be on the order of .25 percent.

4 j

Attachment 2 ST-HL-AE-1638 In addition, the confining pressure of the trench backfill, which is approximately equal to the average swell pressure of 0.75 tons per square foot for the A2 clay layer, will virtually eliminate the tiny amount of swell otherwise anticipated. (Reference 3)

Finally, design criteria provisions require that a certain amount of differential movement be considered in the analysis of piping. The ECW pipe is designed to withstand the effects of 1-1/2 inch differential settlement per 1,000 feet of pipe length. Volume change due to rewatering, if it takes place at all, will occur over a large area. Consequently, the potential for signif-icant differential movement due to clay volume change is negligible. The flexibility of the piping system would enable the pipe to accommodate any differential movement that might result from clay expansion. This further alleviates any concern about swelling of the clay.

REFERENCES:

1. Woodward-Clyde Consultants Report D160XR035-WL

2. FSAR Tables 2.5.A 6-1 and 2.5.4-1

3. Woodward-Clyde Consultants Letter ST-XC-YB-0152, dated February 17, 1986 5

MAR 31 '86 13:25 HOUSTON TEXAS P.4 F e p

Additional Information CAT Item V.B.l.B (Seismic Joint Between MEAB & RCB)

The seismic joint in question was not repaired for the following reasons:'

a) Our study of settlement showed that the joint would not be stressed because the rate of containment settlement is higher than that of the ~

MEAB and therefore would not create a structural problem.

b) Assuming the worst sce.1ario. i.e. M AB wall bears on the containment base mat, the tip of the MEAB wall would crack to relieve the stress, creating a leakage path into the access shaft. Stopping the leakage by grouting would be simpler and less costly than trying to repair the joint by introducing the missing jaint filler. The grouting operation can be performed without dewatering.

c) Cost considerations: ,In order to repair the joint with minimum risk to backfill, the water table needs to be brought down to below the joint locally. To eliminate all concrete to concrete contact, one needs to cut through both layers of water steos. Repairs to water stops would be costly and there would be a high M sk of ineffective r6 pairs resulting in leakage into the access shaft.

7019N:0274N

f Attachment 2 ST-HL-AE-1638 NRC CONCERN E (Executive summary item 4)

During a general walkdown, the NRC CAT identified a crack in the Unit 2 azimuth 304* tendon access wall at elevation (-)13 ft 3 inches which was subsequently chipped out. It was identified that the 3 inch seismic joint material had not been installed between the Reactor Containment Building mat and the tendon access wall as required by drawing 3M01-9-C-4320 Rev. O.

Bechtel Engineering (BEC) issued NCR HCO3170 and determined that the disposition of this NCR would be to "use as is". The basis of the disposition was that all settlements had taken place, the bearing surface area was small, and the vertical seismic movements would be small at this location.

The NRC CAT expressed concern that BEC's disposition did not adequately address the seismic movement of the mat and the forces on the tendon access wall that would result from the predicted unfavorable relative heaves of the two adjoining buildings once the dewatering system is discontinued.

RESPONSE

The basis for the disposition of NCR HCO3170 was not adequately explained at the time of the CAT inspection and subsequent meetings. With regard to the settlement considerations used as part of the basis for the NCR disposition, the correct statement is that the observed settlements between the RCB and the MEAB near the wall in question do not indicate any tendency for the MEAB wall to be progressively bearing on the RCB basemat.

The settlement behavior of the structures is being closely monitored.

Near the location of the missing seismic joint, there is a pair of Structural Benchmarks installed to monitor the relative movement of the two structures (MEAB and RCB). A comparison of the actual relative movement of these SBM's indicated that the RCB, which is the deeper and heavier of the two structures, is settling at a slightly higher rate than the MEAB. This is consistent with the predictions of analytical studies. The heave predicted by these analytical studies is not expected to reverse this favorable trend, as the mechanism causing this heave is predicted to have a uniform effect on all structures.

HL&P will monitor settlement throughout the life of the plant and is currently providing annual updates in the FSAR, Section 2.5.C. The data is periodically evaluated by project engineering personnel as well as by independent geotechnical consultants (Woodward-Clyde Consultants) and any differential movement which would appear likely to cause unacceptable stress levels in structural elements will be evaluated and appropriate action taken.

With regard to the seismic movements, the maximum relative vertical displacement calculated between the MEAB and the RCB during the SSE is 0.23".

A displacement of this low magnitude does not represent a potential for structural damage to the wall in question.

6

Attachment 2 ST-HL-AE-1638 NRC CONCERN F (Executive Summary item 4)

Project specifications permit welding across the flanges on fully loaded structural steel members. The NRC CAT asked if an engineering evaluation had been performed (similar to that indicated in AWS D.1.1, Section 7.5.1) to determine, whether or not a member is permitted to carry a live-load stress while welding on it.

RESPONSE

The following provisions for transverse welding across flanges are defined in subsection 7.2.2.9 of the STP Specification 3A010SS0030:

" Transverse welding across flanges is permissible in all instances if the weld size is equal to or less than 0.75 times the flange thickness. If the weld size is larger than 0.75 times the flange thickness, the weld may not be made in the middle one-third of the member's length, but is permitted elsewhere. If the member is supporting only its own dead weight (i.e., concrete slabs, or upper levels are not in place), the above limitations do not apply. The above limitations do not apply for welding onto auxiliary steel' members and onto structural steel members which are part of cable tray, conduit or HVAC duct supports."

These provisions ate patterned after a Bechtel Thermal Power Organization (TP0) recommended standard, and are not based on STP-specific analytical or experimental considerations. The TP0 recommended practice was developed in recognition of generic concerns on the subject of welding across flanges of loaded members and does not reflect the results of analyses that quantify the structural degradation resulting from specific instances of transverse welding. The evaluation required by the AWS D1.1 Code is intended as a precaution for welding operations performed on members carrying live-load stresses that presumably are relative'- ligh and approach the allowable capacity of the members. The evaluat.on assigned to the Engineer in that subsection of the code is fulfilled by the following considerations which form the basis of Bechtel's position that welding across flanges within the provisions of subsection 7.2.2.9 of the STP specification 3A010SS0030 does not compromise the integrity of any structure:

1. Beams for Category 1 structures are characterized as simply-supported beams with maximum fiber stresses at midspan. Therefore, the STP provision to exclude large welds from the middle third of the member's length prohibits large welds in the high stress areas.

2. At least 35% of the total governing flexural stress of the Category I structural beams originate from seismic stresses. Thus, members were stressed, at most, to 65% of their allowable capacity, assuming the unlikely case that full loading existed when the welding was done.

7

r-Attachment 2 ST-HL-AE-1638

3. The primary concern with welding on an installed member is tne reduction in yield strength that occurs at elevated temperatures.

The' primary means of minimizing the temperature increase in the member is to limit the size of the transverse weld. The provisions of the STP specification address weld size limitations.

4. Welding across the flange of existing structural members is typi-cally performed for the attachment of supports (i.e. pipe, HVAC, cable tray, conduit and fire protection). These welds are usually single pass and meet the minimum fillet weld sizes of AWS D1.1, table 2.7.- In addition, these welds rarely extend for the full flange width. Thus, it is unlikely that temperatures during welding would reach levels to affect the yield strength of the members.

8

Attachment 2 ST-HL-AE-1638 NRC CONCERN G (Executive Sumary item 6)

The NRC CAT identified conflicting definitions for configuration control packages in issued revisions of governing procedures (Bechtel EDP 4.72 and WPP-22.0, and Ebasco ASP-17).

RESPONSE

Procedures WPP-22.0 and ASP-17 have been superceded by issuance of a new standard site procedure (SSP-37). SSP-37 and EDP 4.72 now contain the same definition and procedural method for handling revisions to configuration control packages.

9

)

Attachment 2 ST-HL-AE-1638 NRC CONCERN H (Executive Summary item 7)

" Additional areas of weakness were found in the application of corrective action measures for previously identified deficiencies in the maintenance of permanent plant equipment during the construction 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."

RESPONSE

Various deficiencies in maintenance of permanent plant equipment were identified in the last half of 1984.

Deficiencies were documented and corrected as they were identified.

However, effective measures were not taken to address the overall adequacy of the program.

As a result of the recognition of the programmatic deficiencies in December, 1984, the following actions were instituted:

Procedures were revised to provide additional controls.

Training needs of crafts and supervisory personnel were reevaluated and additional training was provided.

The maintenance program was reorganized and responsibility for its implementation reassigned to the Construction Manager.

The Bechtel " Storage and Maintenance Technical Support" (SMTS) group was integrated with the PPM group, to expedite resolution of maintenance discrepancies, evaluate and trend discrepancies and facilitate communication between craft personnel and Engineering.

Subsequently, as a result of a concern expressed by the NRC Resident Inspector, baseline inspection / verification of implementation of lubrication requirements was completed in July of 1985. Major areas of concern identified were the commingling of grease and the overgreasing of bearings.

These conditions were reported to the NRC under 10CFR50.55(e) requirements.

HL&P management is currently conducting regular reviews of the status of the corrective actions for the PPM program. In addition, HL&P is more closely monitoring the overall inplementation of the program on a regular basis.

HL&P Operations will review significant maintenance deficiencies identified during the construction and test phases of the project (prior to turnover to operations). The results of the review will be factored into the Operation Maintenance Equipment History Program.

10

)

i e'

o Attachment 2 ST-HL-AE-1638 NRC CONCERN I (Executive Summary item 7)

"Open Nonconformance Reports (NCR's) and related equipment requiring Hold Tags for 58 items were reviewed for verification. Hold Tags for 13 items (22%) were missing or improperly controlled."

RESPONSE

All the deficiencies identified by the CAT have been corrected. Addi-tinnal investigation disclosed that hold tag control deficiencies can be categorized as follows:

1. tags not put into place in a timely fashion;

2. tags not removed quickly.following NCR closure;

3. tags missing The process of NCR validation and placing hold tags has been streamlined and made more efficient to resolve item 1 above. QC inspectors have been reinstructed in the necessity of timely hold tag removal (item 2).

To specifically address item 3, as well as monitor hold tag procedural compliance in general, QA will perform surveillances of hold tags on a regular basis. These surveillances began in December, 1985.

11 J

T g .

h Attachment 2 ST-HL-AE-1638 NRC CONCERN J (Executive Summary page A-5)

" Appropriate corrective action systems and procedures were generally found to be in place except for certain areas. These include: Weaknesses in . . . audits . . . of radiographs."

The CAT report goes on to state in Section VIII, " Review of the total of 21 prior audits of welding /NDE revealed only two audits that addressed RT records packages and retrievability (audits M11-301 and G35-502). These two audits included three weld joints for one audit and six weld joints for the other. The total of 9 weld joints (of approximately 25,000 weld joints) is a very small sample to have been audited."

RESPONSE

The HL&P Quality Assurance Program Description states in Section 9.0 Control of Special Processes, " Audits and surveillances of special process activities are performed by either HL&P, BEC or ESI Quality Assurance personnel to ensure compliance with all aspects of the Quality Assurance Program" (emphasis added). Although the audit samples are small, HL&P has performed approximately 40 surveillances of over 300 weld joints for proper records, film quality and weld quality. These surveillances have been performed by the HL&P Level III NDE examiner. The surveillances are HL&P's primary method of verifying radiography program quality. Taken together the audits and surveillances represent a review of a substantial sample of the welds in the plant. This audit and surveillance activity meets the letter and intent of our Quality Assurance commitments.

Although we feel our program objectives have beer met, we will direct future audits to specifically address a larger samnie cf radiographic records.

12 1

3 D

Attachment 2 ST-HL-AE-1638 NRC CONCERN K (Executive Summary page A-3)

" Numerous dimensional and workmanship deficiencies were found in the instrumentation construction sample inspected. This included an installation which had undergone the licensee's QC Effectiveness Inspection conducted after final construction QC inspection and turnover to the startup organization."

The CAT report goes on to state in Section II, "Two of the five instruments, AIEWFT6854 and C1EWFT6873, inspected by the Effectiveness Program coincided with the NRC CAT sample. Although the Effectiveness Program has identified installation deficiencies similar to those found by the NRC CAT, they failed to identify the out of tolerance dimensions found with the installation of CIEWFT6873."

RESPONSE

For C1EWFT6873, the HL&P inspector wrote a nonconformance report (NCR) documenting that the wrong support was installed. The dimensional errors noted by the CAT team were due to the incorrect support installation. Once the HL&P inspector noted the incorrect installation there was no reason to proceed with making the dimensional inspections.

4 I

13 l

)

e, -

Attachment 2 ST-HL-AE-1638 NRC CONCERN L (Executive Summary page A-5)

"The controls for posting unincorporated design changes on design docu-ments were not adequately implemented at one reference station."

RESPONSE

The circumstances which resulted in this discrepancy were unique and applicable to the reference stations only.

The drawings audited by the CAT had a large number of unincorporated amendments. A supplement sheet was issued to tabulate these amendments as part of the drawing. The amendments should have been removed from the drawing because they were now listed on the supplement sheet. This was not done at one reference station. As a result, the amendments were listed on both the drawings and the supplement sheet.

The Field Document Control Center has performed an audit of all electrical drawings in the Unit I and Unit 2 reference stations. The posting problem noted by the CAT was isolated to recently revised electrical drawings at the one station. There is no indication of a generic problem.

14 m- j