IR 05000498/1986006

Insp Repts 50-498/86-06 & 50-499/86-06 on 860217-0404. Violations & Unresolved Item Noted:Failure to Follow Procedures & Provide Adequate in-place Storage/Protection & Work Performed W/O Approved Control Document

ML20211K720
Person / Time
Site:	South Texas
Issue date:	06/16/1986
From:	Constable G, Garrison D, Clay Johnson, Tomlinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211K683	List: IR 05000498/1986006 ML20211K678 ML20211K686
References
50-498-86-06, 50-498-86-1-1, 50-498-86-6, 50-499-86-06, 50-499-86-6, IEIN-84-29, IEIN-84-30, IEIN-84-31, IEIN-84-32, IEIN-84-33, IEIN-84-34, IEIN-84-56, IEIN-84-5606, NUDOCS 8606300234
Download: ML20211K720 (19)

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APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/86-06 Construction Permits: CPPR-128 50-499/86-06 CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P. O. Box 1700 ,

Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: February 17 through April 4, 1986 Inspectors: YS C.E.Johpon,SeniorResidentInspector, D'att

/k Project Section C, Reactor Projects Branch sh D. L. Garfison, Resident Inspector, Project a

Diter Section C, Reactor Projects Branch

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h/ h 0. ~P jfys v TomMn'sdn, ~Rsactor Inspector, Project E-27 -IG Date Section C, Reactor Projects Branch Other NRC personnel: J. F. Lara, CO-0P Student

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Approved: .

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[G. L. constablef Chief, Project Section C, Date M Eic 6 Projects Branch 8606300234 e60624 PDR ADOCK 05000498 G PDR

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Inspection Summary Inspection Conducted February 17 through April 4, 1986 (Report 50-498/86-06; 50-499/86-06)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection. findings, IE Information Notices, site tours, licensee identified items, auxiliary feodwater pumps, concrete placements, Incore Instrumentation system, HVAC, pilot valves, small bore piping, and structural stee Results: During this inspection three violations and one unresolved item were identified (failure to folloe procedures, failure to provide adequate inplace storage, protection, and work performed without an approved control document, paragraphs 6, 10 and 11).

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DETAILS l 1 Persons Contacted Principal Licensee Employees,

• J. T. Westermeier, Project Manager

• T. Jordan, Project QA Manager

• C. McIntyre, Project Engineer S. Head, Principal Engineer

• K. O'Gara, Licensing Engineer

• R. J. Daly, Startup Manager J. Geiger, Manager, Nuclear Assurance R. Attar, Supervising Project Engineer

• S. Shukla, Licensing Engineer

• M. Berg, Site Engineering

• M. Wisenburg, Manager, Nuclear Licensing

• Denotes those individuals attending the exit interview conducted on April 4, 198 The NRC inspectors also interviewed other personnel of Bechtel Power Corporation and Ebasco Service, In . Site Tour The NRC inspectors made several site tours and inspections in order to observe the condition of equipment, plant status, and ongoing work activities. The following parts of the plants were inspected: auxiliary diesel generator (lighting) building, security building (east), fuel building, containments, mechanical / electrical auxiliary buildings, essential valve room, Unit 1, warehouses A-D, storage yards and the document control vaul No violations or deviations were identifie . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (82-18-02) (four parts) This item concerned a " summary" of anchor bolt work orders for six cach 1 1/4 X 20" long A193 bolts, were at first review of the summary, apparently not included. The " summary" of anchor bolt work orders after detailed review was found to include the items which were further described on Shop Work Request (SWR) 485 The " summary" erroneously listed the bolts as being 30" instead of 20". Drawing 1-C-1505/6 indicated the correct length and the shop work and fabrication records indicated that the correct length and type of bolts were use *

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4 This concern was two groups of anchor bolts which were noted as being fabricated from improper material. SWR 2850 and 3171 showed a type VI bolt which, in actuality, should have been type IV (typographical error) bolts, in accordance with drawings 0-C-6087 and 9-C-414 This item concerned site fabricated bolts listed in a summary, however, Unit 1 bolts were not shown. It was determined that the bolts for Unit 1 were vendor supplied and were not required to be shown on the site summary; also a notation for drawing 1-C-4066 was in error and caused some confusion. Even though some were not listed on the sumnary, all were accounted fo This item references five documents, each of which indicated an anomaly in the size of anchor bolts which should have been the same size: (1) drawing (1-C-1502-9) and (2) test data sheet 992 were determined to be correct; (3) the summary, (4) NCR SM3714A and (5) hardness test data sheet indicated incorrect sizes. The concerns on this item have been reviewed by the NRC inspector and it was determined that the resolution to the concern was adequate and that the correct size bolting was use *The four parts to 82-18-02 have been adequately addresse These items are considered close (Closed) Unresolved Item (8301-1)

This item concerned mixing of anchor bolt types on shop work requests No. 1213 for Units 1 and 2. Eight bolts in question were required to be ASTM-A193, but were found to be ASTM-A36. NCR disposition required the addition of eight A193 bolts to the affected pads. Verification was made by the NRC inspector, and is satisfactory. This item is considered close (Closed) Unresolved Item (8301-2)

This item concerned eight bolts fabricated and installed of A36 material instead of the required A193; these bolts have been replaced by A193 bolts in both Units 1 and 2 pads. The NRC inspector reviewed the complete document package which verified the action was accomplished. This item is considered close (Closed) Unresolved Item (8301-3)

This item concerned the control of shop fabricated anchor bolts and the end use. Although a procedure was not available covering this area, it was determined that the Shop Work Requests / Miscellaneous Steel Shop Work Request, Miscellaneous Steel Shop Fabrication and Data Card was ample to trace the material This item is considered close (Closed) Violation (8302-01)

This item concerned the inability to retrieve documents as follows:

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5 Hardness test data sheets:

These sheets have been located, Documentation of calibration of two hardness machines:

These machines are not calibrated equipmen . Documentation of hardness test bars:

Attempts to gather this material have not been successful since the testing performed was only to distinguish between two materials of completely differing hardness value Red-line drawings:

These drawings are nonpermanent engineer markups and are not considered permanent records. The engineering data derived from the drawings is reported in the Technical Reference Document SA840SR163- Records of training of personnel performing hardness tests: ,

Training records have been retrieved from Brown and Root for all but two inspectors. The Bechtel program has reverified all of the items of concern (a-e), the NRC inspector determined that adequate corrective action has been perfonne (Closed) Unresolved Item (8308-02)

The first part of this item concerned the methodology in which Brown and Root personnel established the hardness values for certain materials. The purpose of this program was only to differentiate between ASTM A36 and A193 which is considerable in values (Tensile Strength A36-80,000 ps1/A193-B7 125,000 psi). The details of this program are outlined in the licensee letter to the NRC of August 1,1984, concerning phase II of the Anchor Bolt Program.

l The second part of this item also questions Brown and Root methodology for

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establishing traceability through Test Data Sheets, Site Work Requests, and Summary Sheets. Considerable minor irregularities were noted. The licensee's response to each detail was reviewed by the NRC inspector and was found to be satisfactory. This item is considered close (Closed) Violation (8320-01)

This item concerned the lack of a Bro,vn and Root training program for inspectors who inspected bolt threading. The Bechtel reverification program of Brown and Root work was performed to applicable procedures and

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their training program is documented in procedure CIP 2.2-24. The training procedure was reviewed and determined to be adequate. The Brown and Root work was reverified by Bechtel utilizing qualified procedures by trained inspectors. This item is considered close (Closed) Deviation (8320-02)

This deviation involved the testing of anchor bolts that were considered inaccessible at the time by Brown and Root. The Bechtel reverification program assessed all safety-related A-193 bolting based on a review of the design drawings and is described in paragraph 2.1 in the Technical Evalua- ,

tion of Anchor Bolts and Embedded Rods. The procedure (2.2-12, Testing of A36 and A193 Field Fabricated, Installed Anchor Bolts), training, and results of the test program were reviewed and found to be adequat (Closed) Unresolved Item (8320-03)

This item cc::cerned the review of an NCR (B&R S-M456). The NRC inspector raised a concern over the fit of nuts which were measured and found to be dpparently nonconforming. Subsequent investigation revealed that the wrong

"go"/"no-go" plug gauge had been used in the measurement. The correct

"Go/High Working Plug Gage" was used in remeasuring the nuts which were determined to be satisfactory. The NRC inspector verified the differences in pitch diameters in gauges by comparing Lab Standard Class W gauge #100213-7 to Working Plug gauge Class X #STCC396 This item has been satisfactorily addressed and considered close (Closed) Unresolved Item (8320-04)

This item concerned the use of minor bolt thread diameters as a criteria for acceptance; Brown and Root calculation 3A790SC276-B. The Brown and Root verification program did rat address this aspec In the Bechtel reevaluation program (calculation CC9900 and 9901), the major thread and pitch diameters were used as the basis for evaluating stress and not the minor diameter. The remeasurement program verified the adequacy of all reported undersize threads on bolts as reported by Brown and Root. This item has been satisfactorily addressed and considered close (Closed) Unresolved item (8320-05)

The item of concern was that crane rail embeds were misfabricated. The NRC inspector has verified that the embed plates and welded rods are of the correct material (ASTM-A36). This item is considered close (Closed) Unresolved item (8320-08)

This item concerned NCR BC-00274, in which it was reported that A36 material was used in lieu of A193 and was considered an unresolved item pending review of other NCRs for recurrence control. Since the time of

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i this item, the entire anchor bolt reverification program has identified

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possible nonconfonnances and handled them according to procedures. The

! present NCR program encompasses an extensive program to identify and resolve trends. This item is considered close I

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(Closed) Violation (8322-01)  ;

This violation concerned the acceptability of Brown and Root and Ebasco site-fabricated threaded bars. This item has been evaluated with a sample size of 466 bolts being carefully measured at 2 points (90 degrees apart)  ;

, on the threads; this by the engineer's analysis, gives a 95% confidence i

level that no more than 9% of Brown and Root and 2.2% of Ebasco fabricated I rods are slightly out of tolerance undersize, which is acceptable. This

, item is explained in detail in the Technical Evaluation of Anchor Bolt This item has been adequately addressed and is considered closed.

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(Closed) Violation (8322-02)

l This violation concerned the disposition of NCRs and is as follows:

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- NCR #BS-00086 - 119 of 1500 1" X 3 1/2" bolts were found unacceptable on receipt. The NRC inspector had questions about the remaining 138 '

1 These 1381 bolts were verified to be in the warehouse in a controlled j state and stamped. It was not determined why the bolts were not on a t j Brown and Root inventory log.

i i NCR #AC-00038 - 26" X 9" structural wide flange steel with some linear

{ indications. The piece found was scrapped. The balance of the j material was to be inspected as it was cut and fabricated to site

procedures. The original defect was found during routine inspection; i therefore, any further defects would presumably be found during' ,

j similar inspections as the procedures for receipt, fabrication and l

installation appeared to have been adequat t

' NCR #HC-00409 - This NCR concerned improper threading of an anchor bol The type of material was questioned. The material was *

l identified as being correct and the corrective action adequate in that

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the defective threads were removed and replaced with proper threads.

l These items have been adequately addressed and are considered closed.

i L (Closed) Unresolved item (8322-05)

l This item concerned thread engagement of 1 1/4" diameter bolts into j threaded holes in 1" thick end plates. Review by the NRC inspector

' indicated that Bechtel calculation CC9930 verified the adequacy of ~this

) configuration with shear loads up to 41.1ksi. This item is considered

closed.

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4. Licensee Action on Previously Reported Items (50.55e)

Klosed)IRC#13and195

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The NRC inspector reviewed the following two items in conjunction with other items noted under licensee action on previous inspection finding IRC #13 concerned threading of steel rod and IRC #195 concerned mixing of

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two types of steel bar. Both are considered resolve . Licensee Action on IE Notices The following IE Notices were reviewed and the licensee's responses and actions were determined to be satisfactory. Thus, the listed notices are closed:

84-29 Circuit breakers 84-30 HVAC 84-31 Actuators 84-32 Water haniner 84-33 Cotter pins 84-34 Breathing air cylinders 84-56 Emergency breathing apparatus 6. Incore Instrumentation System The NRC inspector inspected Unit 1 incore instrumentation seal plate connections and noted several discrepancies: Thimble guide tubes 20 and 30 and their respective seal plate markings were interchanged by utilizing a Westinghouse Field Deficiency Report (FDR). Seal plate markings for thimble tubes 2 and 4 were also interc..anged by using the same FD However, the tubes themselves were not interchanged to match their respective seal plate markings.

The incore instrumentation seal plate connections were later inspected

! dnd approved by Quality Control inspectors even though tubes 2 and 4 were not connected to their respective seal plate marking It was noted that, had construction proceeded according to the original Westinghouse design drawings, tubes 2 and 4 would have crisscrossed as they were routed from the reactor to the seal plate. Similarly, tubes 20 and 30 would also have crisscrossed. Therefore, it is apparent that the original design of the tube connectinns at the seal plate was deficien The NRC inspector reviewed records and noted that in response to Ebasco craf tsmen's Request For Engineering Assistance (REA) J-1-85-0090, a Westinghouse FDR (TGXM-10219), was generated and dispositioned instructing

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the interchange of locations for the four tube connections at the seal plate, and a revision to the design drawings was issued to reflect the change. This design revision would allow the tubes to be connected to the seal plate without crisscrossing. The appropriate mechanism for work authorization for crafts would be a Bechtel Field Change Notice (FCN) which had not yet been generated. Craftsmen proceeded to perform the work as specified by the Westinghouse FDR. This is contrary to QA procedure since the Westinghouse FDR is an uncontrolled documen Further review by the NRC inspector indicated that thimble guide tube 2 from reactor location J-7 was connected at seal plate location H-6, while thimble guide tube 4 from reactor location H-6 was connected at seal plate location J-7. Therefore, seal plate connections 2 and 4 were constructed in a nonconforming condition. Further review indicated that Quality Control inspectors inspected and approved all seal plate connections although construction was not completed in accordance with the latest approved drawin Although tubes 20 and 30 were interchanged as specified in the FDR, they will conform to the upcoming revised approved drawin The above discrepancies constitute apparent violations for failing to perform work with an opproved control document and failing to accomplish activities affecting quality in accordance with appropriate document . Inspection of Instrument Pilot Valves An inspection of Automatic Sprinkler Company (ASCO) valves was performed in order to assess the adequacy of the installation and inspection requirements in relation to the function of the valve The valves that were inspected were installed in the component cooling Water and safety injection system in the containment building. The drawings, specifications and procedures used were:

. SN129F05013, 5014, 5015, and 5016 - P&lD

. SN209F05017, 5018, and 5019 - P&ID

. ASCO catalog #NP-1

. Instrument Procedure SSP-53 - Quality Control

. Specification 5Z689ZS1027 - Instrument Construction Engineering

. CSP-47 - Construction Procedure The methods used in installation were assessed in order to verify that sensitive internal components were installed to the manufacturer's instructions. These particular types of valves are electro-mechanical instrument pilot air types, generally used to actuate system valves; some of which receive Engineered Lifeguard Feature (ESF) signals. These valves have actuation stem seats or gaskets that are made of ethylene propylene polymers, which are subject to degradation by certain types of lubricants which may enter a system if the system is not installed clean and kept clean. The failure of these valves have previously been reported in IE Notice *

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Procedures The site has been provided with adequate specifications, which detail the methods of installation; these requirements are further transcribed into Quality Procedures for safety and nonsafety applications and construction procedures, which outline the installation process in detail. Supplemental support documents are provided to complement the basic document Inspection An inspection of the valves was performed in the Bechtel warehouse "C".

Several new valves in boxes were inspected for insertion of the installation instructions, which included cautions as to the use of oils and grease on the sensitive internal parts and general condition. It was noted that the valves were qualified to IEEE 323, 382, and 344 standards. The valve code designator F Y (flow / relay) were reviewed in the instrument index and are considered instruments by the project. Each is assigned a unique number and were easily cross indexed so that the valve could be traced into the systems by valve number or type. Several valves were inspected for installation attributes as listed in the procedure It was observed that the valves appeared to be installed to the drawing requirements for valve type, fittings, supports, tubing, and identification. One filter was disassembled for physical inspection and it was determined that the internal cleanliness was adequat Records The systems are cleaned by the startup group during flushing or cleaning and prior to testing to Prerequisite Test Procedure SG-M-05. The test results are recorded on verification sheets applicable to the system cleaned. The NRC inspector reviewed isometric mark ups, cleanliness verification sheets and cleanliness verification package cover sheet (package 11A13-F01) and was satisfied that the systems were adequately cleane No violations or deviations were identifie . Inspection of Failed Small Bore Piping The NRC inspector investigated the failure of two 2" recirculation lines in the "A" train Low Head Safety Injection System that occurred during flushing operations. One line, as shown on drawing SF369PS1572, sheet A03, Revision 5, is a 2" stainless steel line welded to a socket connection and then to a 6" heade This failure was apparently caused by cyclic fatigue which was induced by water hanmer in a reverse flush. An NCR #SP03676 was generated and hold tags attached to the components as' required. A metallurgical evaluation

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was conducted by Bechtel National Inc. and the analysis is an attachment of the NCR. The second failure during the flush was another 2" stainless steel line and involved approximately 60' of pipe. This piping did not fail but was severely whipped and bent, the piping involved is identified on Isometric 5F369 PSI 572, sheet A03, Revision 4, from hanger HF5006 to hanger HF5001 (NCR #SP03677).

The A/E is analyzing the flushing operation in order to determine the exact Cduse It is tentatively felt that reverse flow with higher than design flow velocities through two kerotest diaphram valves with floating stems was th'e source of the water hamme From a review of the testing, failures, procedures and analysis, it is concluded that the problem may not have been foreseen and that the licensee programs are being followed for corrective actio No violations or deviations were identifie . Structural Steel The NRC inspector reviewed several drawings and nonconformance reports concerning detail 10, Type VII structural embed plates. The NRC inspector Wds informed that detdil 10 Type VII embed plates are used only in the containment. Embed plates Types G and H are used in all structure However, G and H embed plates are given inspection criteria such as center to center spacing and edge distance. Detail 10, Type VII embed plates are not given any criteria as suc The NRC inspector was informed by Bechtel engineers that types G and H embed plates were give.n this criteria because of the heavy multiple loads these plates carry. Their justification for not giving this criteria for Type VII embed plates was that these plates would not be carrying multiple loads, and that the only additional attachments to the plate would be instrument 4-tion lines and electrical conduit, which would be minimal and accounted for by the design engineers. A walk-down of Type VII embed plates by Bechtel identified that some plates did carry multiple load The NRC inspector had several meetings with Bechtel and HL&P engineers on this subjec Inspection criteria will now be given for detail 10, Type VII embed plates and the plates carrying multiple loads have been evaluated by Bechtel engineering. Evaluation by Bechtel indicated no problem with the Type VII embed plates that were identified as having multiple load Drawing change notices (DCNs), specification change notices (SCN), and interim change notices (ICNs) to procedures have been implemented which gives inspection criteria for Type VII Plate No violations or deviations were identifie . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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10. HVAC Procedures / Specification / Qualification Test Plan (a) Leak test The NRC inspector procedures for HVAC reviewed duct and the following)

housing, documents: for installation of (b specification safety class and nonsafety class liVAC equipment and duct work (Appendix C),

(c) environment qualification test plan and procedure for gaskets and sealant / adhesives for HVAC duct assemblies, and (d) data sheet for Dow Corning #999. Items a and b were satisfactory; however, c and d had several uncertainties which have not yet been answered and are described as follows:

Review of the environmental qualification test described a test plan wnich qualifies a Tremco gasket with sealant (Dow Corning #999) to 40 years normal / abnormal / accident conditions in the Fuel Handling Building and to 6 years normal / abnormal / accident conditions for outside containmen Bechtel engineering informed the NRC inspector du:ing a telephone conference

, that the test was completed, but the results would not be available until June 198 Review of this test plan and data sheet for Dow Corning #999 indicated issues which ap; eared not to be addressed. The first was an illustration in words of the method of application of the Tremco gasket tape and Dow Corning #999 sealant. The application observed in the field by the NRC inspector was different from that given by the qualification test plan. Second, the test plan did not take into account the back pressure escaping underneath the embedded angle iron as described in the observation paragraph following. Third, there were no test results for review. Fourth, the data sheet for Dow Corning #999 recommends that #999 should not be used on masonry substrates such as concrete, marble, limestone and brick; however, there are applications over concrete at ST The NRC inspector oiscussed these issues with Bechtel and HL&P engineer The NRC inspector was informed that issues 1 and 2 had recently been submitted to Wyle laboratories for supplemental evaluation for qualification for the application at STP. Issue 4 is now being evaluated by the licensee in conjunction with Dow Cornin Until further information and test results are reviewed for issues 1, 2, and 3, these will be considered as unresolved.(8606-04)

Observation The NRC inspector observed a leak test on a safety-related HVAC syste During the observation, the NRC inspector questioned the type of sealant used to prevent leakage behind the angle iron frame embedded in concret The types of sealant used are Dow Corning 795 and 999. The NRC inspector examined several locations on safety-related and nonsafety-related HVAC syste;as where this sealant had been applied. Applications of Dow

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Corning 795 observed indicated poor adhesion characteristics. Dow Corning 999 appeared to have better adhesion characteristics than 795; however, there were a few places where 999 had poor adhesio The NRC inspector asked a Bechtel and HL&P HVAC engineer if these sealants were rated for this type of application and whether the sealants could withstand back pressure that would be applied during normal / accidental conditions. The back pressure question surfaced when the NRC inspector observed a leak test that showed excessive leakage behind the angle iron of the duct embedded in concrete. The NRC inspector was told that the sealant Was applied at the point of leakag The NRC inspector requested the qualification test data for sealant used for revie . Safety-Related Components Receipt Inspection The NRC inspector reviewed receipt inspection procedures for the Unit 1 motor operated auxiliary feedwater pumps and the turbine driven auxiliary feed pump. Receipt inspection records indicated that procedures were followed properly and nonconformance reports were initiated on discrepant documentation upon receipt of auxiliary feed water pumps. Documentation has been prepared and maintained as required by receipt inspection instruction Installation The auxiliary feedwater pumps and motors are set in place in their general location; however, final torque of bolts, tolerances, and clearances have not been performed because the pumps are in proces Final QC acceptance has not been performe Appropriate drawings, manufacturer's details and instructions are available to installers. Installation requirements, construction drawings, specifications, and work procedures are technically adequat h iew of the installation documentation indicated that disassembly of duXiliary feedWdter pumps #3A141MPA02 and 03 was performed without QC verification. This was documented as a procedural violation of hold points and NCR #CM3214 was initiated. This was identified by Ebasco Q Instorage maintenance records / schedules were available on a computer printou Inspection and installation records were available, but not complete because of inprocess wor Protection and Maintenance After Installation Observation by the NRC inspector indicated that inspection activities, including scope and frequency of inspections, are being performed according

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to instructions. Records are being maintained to document the inspections and frequenc The NRC inspector also examined the auxiliary feedwater pumps for physical damage. Examination revealed that inplace protection was not adequat Examples of damage or discrepancies noted are listed as follows:

. Motor-bearing thermocouple nipple broken

. Bearing covers were not in place which leaves bearing internals exposed to dirt and dust

. Rust on pump casting

. Space heater door open, exposing bare wire

. Unistrut on pump pedestal broken

. Flex-conduit broken

. Throttle valve open to atnosphere

. Gauges cracked and broken This appears to be inadequate inplace protection for the auxiliary feedwater pumps based on site procedures and specifications. This is an dpparentviolation.(86-06-03)

A Standard Deficiency Report (SDR-E-434) was initiated af ter the findings I were brought to management's attention. All area superintendents and I supervisors have been retrained on inplace equipment protection to enhance their understanding of specification 5A300GS100 Unit 1 auxiliary feedwater pumps and motors now have adequate inplace protection and NCRs have been initiated documenting all physical damag I Corrective action was ininediate and effective and has been completed for i the feedwater pumps and motors. The licensee has examined other equipments l to assure that other comparable inplace storage problems were identified, ,

documented, and corrected. The NRC inspector determined that appropriate i corrective and preventative actions have been taken, j personnel Interviews The NRC inspector interviewed several persons engaged in work activities associated with installation and inspection of the auxiliary feedwater pump These persons were knowledgeable and appeared to have adequate ability to perform their assigned duties and responsibilitie l I

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Records Review The NRC inspector reviewed receiving inspection records, inplace maintenance records, and installation inspection records. It appeared that the licensee's system for preparing, reviewing and maintaining records is functioning properl There is reasonable assurance that the records reflect work accomplishments consistent with site requirement . Concrete The NRC inspector observed placements 2-RC-W-188-025, Unit 2 RCB Dome, El 180'-5" 194'-5". Inspection of the placement in progress indicate d no violations or deviations. Records reviewed were legible and accurat No violations or deviations were identifie . Followup on Allegations (Closed) Allegation 4-86-A-001 Possible Security Problem The NRC resident inspector was contacted by telephone at his home by a subcontractor employee who was concerned about his being admitted through the site North Gate without providing positive identification. The individual stated that he usually entered the construction area via the East Gate, but on Saturday, December 28, 1985, he entered through the North Gate and had no trouble getting a temporary badge from the contract security guard stationed there. The individual stated that the guard at the North Gate recognized him as a current subcontractor employe The above events occurred during the transition period from one series of work days and hours to another. The change occurred when the major work force was taken off of 2 rotating 10-hour shifts of 4 days each and placed on a single 8-hour, 5-day work week. This necessitated a change in the entry point for many of the employees due to car pool changes and modifica-tion of the assigned parking areas. Normally an individuals picture badge is moved to his preferred entry point within one day of notifying the

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security force, but because of the sheer volume of change requests, some were not moved for several days. In the event that an individual's picture badge was not at his designated entry point, the individual was provided

! with a temporary visitors badge upon proper identification. In some cases individuals were required to show a valid drivers license, company l

identification card, or other identification prior to receiving the visitors temporary badge, in most cases, however, the persons requesting temporary badges were known by the contract security personnel to be site employees.

The security personnel are periodically rotated from one entry point to another and are able to recognize many of the employees and subcontractors on sight, i

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The,NRC inspector reviewed the current site security procedures related to site access and interviewed two of the licensee security supervisors. This review and these interviews did not indicate that any access requirement or security procedure had been violate Based on the above information this item is close (Closed) Allegation 4-85-A-090 (Inappropriate Safeteam Actions)

A letter was received by the STP Senior Resident Inspector on August 22, 1985, detailing the authors concerns over the actions of Safeteam and licensee employees during the investigation of allegations. The individual, who presented his letter in person, was employed at the time as an EBASCO QC inspector working on Unit As stated in his letter, and again in an interview with the NRC inspector, he was contacted on six separate occasions and questioned by several Safeteam investigators and one licensee QA supervisor. This questioning concerned an allegation of wrong doing that occurred in the individuals work area. Although neither he nor his actions were the subject of the allegation he was questioned because he worked in the same area at the same time the wrong doing was alleged to have occurre The individual stated that he had been " harassed, intimidated, manipulated and embarrassed" as Well ab having been " accused . . . of lying or storytelling." He was concerned that this abuse was affecting his home life and work performance and that the repeated questioning was placing his credibility in question. The individual seemed very concerned that other persons had been, or might be subjected to the same type of " abusive and embarrassing treatment in the futur The NRC inspector interviewed four Safeteam investigators, the investiga-tions coordinator, the Safeteam manager, and the cognizant licensee QA supervisor to ascertain the validity of the individuals concerns. These interviews revealed that the individual, as he stated, was repeatedly questioned by several investigators about matters concerning an allegation received by the Safetea The Safeteam manager stated that the early stages of this investigation were conducted in a manner contrary to the Safeteam nor This was due in part, he stated, to the reassignment of investigators and the need to repeat the interviews to maintain continuity. Because the Safeteam members are investigators and most of them have limited knowledge in the technical or nuclear safety aspects of some allegations it is often necessary for them to seek the assistance of quality or engineering personnel. In this case, a licensee QA supervisor with a background in civil engineering was consulted, resulting in another interview with the concerned individual and entailed further time away f rom his work area. These incidents of repeated interviewing raised questions by his tellow workers as to the extent of the individuals involvement in the allegation. The individual felt that the notoriety he was receiving and the attitude of his fellow workers toward him were affecting his performance of work assigne __ __ __ - _. .

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The above concerns were presented in writing and verbally to the NkC inspector during a seventh and final interview concerning this allegatio The NRC inspector relayed the apologies of the Safeteam manager and licensee management for any abuse or embarrassment inflicted on the individual along with the assurance that all investigators had been reinstructed in the protocol of Safeteam investigations. The Safeteam manager further stated that future investigations would be more closely monitored to ensure the fat snd unbiased treatment of those being interviewe Following this final interview with the NRC inspector the individual stated that he was satisfied with the actions taken and had no further concerns with the conduct of the Safetea Based upon the NRC inspector's review and interviews, this item is close (Closed) Allegation 4-85-A-122 (Alleged Cover Up Drug Investigation Results)

An anonymous alleger contacted Citizens Concerned About Nuclear Power (CCANP) and advised that "many" of the South Texas Project personnel who were to be fired for failing drug screening tests were not fired because these people could implicate the site operations group. The .'

alleger also stated that information of operations group involvement was kept from the NRC and ASLB. This was forwarded in a letter to the NRC Office of Investigations in Washington, D.C. The letter from CCANP was received by Region IV in November 198 The screening program referred to by CCANP was initiated as a result of a concern expressed to the STP Safeteam about possible onsite and offsite drug use by the contract security force (Wackenhut Corporation). Wackenhut Corporation, when notified of this concern, began a 100% polygraph screening of all contract security personnel. Of the 74 Wackenhut Corporation employees questioned, 28 were terminated based upon the polygraph results or the results of an intensified review of their original employment documentation. In several cases the polygraph results indicated that some of the information in the personnel files was not correc Wackenhut Corporation conducted their polygraph screening of their personnel with no prior notification given to those questioned. One of the conditions for employment at STP as a member of the contract security force is the total abstinence from drug use, either onsite or offsite, while employed in this capacity. Those individuals whose polygraph responses indicated that they were not complying with this were terminated. It is

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important to note that in no instance did the polygraph results indicate any onsite use of drugs by those questioned. Apparently the use of drugs by the Wackenhut personnel was limited to offsite use during non-work hour During the Wackenhut questioning other site personnel were either named or described by the individuals as being users or possible users of controlled substance _ _ _ _ _ . __ ______-___ _______ -_ ______ ______ ___________________ __ ________ _ __ _____________ _ - _ - _ _

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These individuals identified by the contract security personnel as being potential users were employed by HL8P, Bechtel, EBASCO, and STP subcontrac-tors. A sample from each group was selected and interviewed by the licensee Nuclear Security Division. This was direct questioning only and did not include the use of a polygraph. Each of these who admitted to offsite use of any controlled substance was informally counseled and informed by site supervision to cease this activity. There were no terminations as a result of these interviews because abstinence from these substances was not a condition of employment for STP employees other than the contract security force. These interviews, which were concluded on October 1,1985, indicated that all use of drugs was being done offsite.

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No onsite drug use by any employee could be substantiate The results of this screening program were documented by licensee Nuclear Security Division in interim report S85-0034, dated October 7, 1985, and final report dated Hovember 5,1965, along with a Fitness For Duty program descriptio Because of personal privacy legalities encountered, the Fitness for Duty Program was announced several months prior to its initiation. Posters were conspicuously placed in all work areas and supervisorc verbally informed their subordinates of the program. It was clearly stated that the base-line urinalysis testing would begin in January 1986, and that any person with positive test results would be terminated. At this point in time the onsite or offsite use of any controlled substance by any STP employee, regardless of company affiliation or employment capacity, became grounds for immediate dismissal. Prior to January 1986, only the Wackenhut personnel were subject to this requiremen HLAP management and site security have routinely contacted the resident inspectors and the Region IV office on drug activities in progress and of monitoring and testing activities. Details of the current Fitness For Duty" program are included in Inspection Report 50-498/85-24; 50-499/85-2 .

When the Safeteam received the original concern, the NRC Senior Resident Inspector and Region IV were notified. The results of the Wackenhut polygraph testing and the subsequent employee questioning were made available to the resident inspectors and Region IV shortly af ter their report issue dates. There was no apparent unwillingness to share this information with the NR The NRC inspector found no instance where a person who should have been terminated was not, under the policies in effect at the time of the questioning. Wackenhut Corporation actions appear to have been thorough in that they terminated 38% of their total onsite security force in an effort to provide a drug-free wcrk environmen _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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As stated above, all site employees were informed of the Fitness For Duty Program well in advance. The information was disseminated far enough in advance for an individual who refrained from use to be free of residual effects which could result in positive test results. The penalty for positive urinalysis results was clearly stated and all personnel were informed that if they were currently using any controlled substance, they should stop immediately or seek employment elsewhere. Advance notice of the Fitness For Duty Program was given so that those users who were serious about their employment could comply with the new employment requiremen To date, there has been only one failure by a licensee employee of the urinalysis test. This was not an onsite employee. Approximately 75% of all those under the umbrella category " Operations" have been subjected to the base-line testing without a single failur To further' assure a drug-free environment at this site, the Fitness For Duty Program has included provisions to retest all employees at intervals after the base-line testing has been completed. Provisions have also been provided to require rotest if an individual is suspected of using drug In the event that a current employee fails the Fitness For Duty urinalysis, regardless of his company affiliation, a review of work performed by him is done to determine if 1e did anything that was safety-related or could ultimately affect the construction or operation of the plant. If any safety-related work had been performed, a documented inspection of this would be done immediately. The Work Quality Review Committee (WQRC) will periodically meet and discuss each of these evaluations. The WQRC, in an effort to cover all areas of site employment, consists of representatives from Safeteam, Licensing, Project Engineering, Quality Assurance, Bechtel Project Management, EBASCO, and HLP Nuclear Security Division. At these meetings, each evaluation will be reviewed thoroughly but the name of individual will not be revealed to members of the WQR There is no evidence that any attempt was made to conceal information from the NRC or ASLB. On the contrary, this information was made available to the Senior Resident inspector and Region IV in a prompt manner. Further, there is no evidence of anyone failing the polygraph test or the Fitness For Duty urinalysis being retained by any organization at ST This allegation is close . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item relating to HVAC was identified and discussed in paragraph 10, 15. Exit Interview The NRC inspector met with licensee representatives (denoted in paragraph 1)

on April 4,1986, and summarized the scope and findings of the inspection.