IR 05000498/1988002

Insp Repts 50-498/88-02 & 50-499/88-02 on 880104-29.No Violations or Deviations Noted.Major Areas Inspected: Allegations,Hvac,Duct Sealant Matl,Nsss Equipment in Unit 1, Electric Cable & Battery Room Mods

ML20148J232
Person / Time
Site:	South Texas
Issue date:	03/11/1988
From:	Barnes I, Gilbert L, Hunnicutt D, Singh A, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148J212	List: IR 05000498/1988002 ML20148J206
References
50-498-88-02, 50-498-88-2, 50-499-88-02, 50-499-88-2, NUDOCS 8803300208
Download: ML20148J232 (14)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

E NRC Inspection Report: 50-498/88-02 Operating License: NPF-71 50-499/88-02 Construction Permit: 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 (STP), Units 1 and 2 Inspection At: STP, Matagorda County, Texas Inspection Conducted: January 4-29, 1988 8cd 3/7/8'4" Inspectors:[e L. D. Gilbert, Reactor Inspector, MaterialsDate and Qualc Programs Section, Division of Reactor fety

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g A. Singh, Reactor Inspector, Plant Systems r Section, Division of Reactor Safety

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. f. Vickrey(, Reactor 7bspectorT0perational Da PrograYs Se'ttion, Division _f Reactor Safety b N$ wNW D. M. Hunnicutt, Senior Project Engineer

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f Project Section D, Division of Reactor Projects 8803300208 880322

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I. Barnes,schief, Materials and Quality- .

Date-Programs Section,. Division of Reactor Safety Inspection Summary Inspection Con' ducted January 4-29, 1988 (Report.50-498/88-02)

' Areas Inspected: Routine, unannounced inspection of. allegations; heating, ventilation, and air conditioning (HVAC) duct sealant material; nuclear steam system supplier (NSSS) equipment in Unit 1; electric cable; battery room modifications; and Unit 1 reactor vessel pressure transient protectio Results: Within the six areas inspected, no violations or deviations were

. identified. Two unresolved items are identified in paragraphs 6 and Inspection Conducted January 4-29, 1988 (Report 50-499/88-02)

Areas Inspected: Routine, unannounced inspection of allegations; heating, ventilation, and air conditioning sealant materials; nuclear welding; electric cable; and battery room modification Results: Within the five areas inspected, no violations were identifie An unresolved item is identified in paragraph 7.

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DETAILS

' Persons Contacted Principal Licensee Personnel

• E. Vaughn, Vice President, Nuclear Operations

• J. T. Westermeier, Project Manager

• J. E. Geiger, Nuclear Assurance Manager

• T. J. Jordan, Project Quality Assurance (QA) Manager

• M. A. McBurnett, Operations Support and Licensing Manager

• J. S. Phelps, Licensing. Supervisory Engineer

• D. C. King, Construction Manager

• S. M. Head, Licensin C. M. Turner, Consulting Engineer K. Jolley, Construction Coordinator J. Bombard, QA Technical Specialist W. Evans, Licensing J. Johnson, Project QA D. Thompson, Project QA Bechtel Energy Corporation

• R. W. Miller, Project QA Manager

• R. D. Bryan, Construction Manager R. Randels, Mechnical Engineering Group Su C. F. O'Neil, Engineering Manager (Unit 2)pervisor Ebasco Services, In *D. D. White, Construction Manager

'~ *A. M. Cutrona, Quality Program Site Manager F. G. Miller, Welding Superintendent NRC l

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• A. B. Beach, Deputy Director, Division of Reactor Projects

• J. P. Jaudon, Deputy Director, Division of Reactor Safety

• C, E. Johnson, Senior Resident Inspector

• D L. Garrison, Resident Inspector

• D. R. Carpenter, Senior Resident Inspector l The NRC inspectors also interviewed other licensee and contractor employees l

during the inspectio * Denotes those personnel attending the exit meetin Re .

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2. Allegation Review _(_ Technically Closed) Allegation RIV-87-A-0088 The NRC inspector reviewed the results of the allegation investigations performed by the onsite SAFETEAM. Allegation RIV-87-A-0088 involved an anonymous letter listing 25 separate concerns involving theft, falsification, waste, security, harassment, intimidation, favoritism, conspiracy, drugs, and fitness-for-duty issues. These 25 concerns lacked substantive detail. The NRC and HL&P received identical copies of this letter from an anonymous source (or sources).

The SAFETEAM personnel investigated and evaluated each of the 25 concerns. All of the concerns were classified as nonsafety-relate The NRC inspector found that the SAFETEAM investigation and evaluation had detennined that 22 of these concerns were not substantiated either in total or in par The following three allegations, considered substantiated by SAFETEAM, are described below: This concern declared that two named employees were operating an illegal raffle on the _ job. This concern was partially substantiated and appropriately handled by the license . This concern involved a racially motivated "prank" between three individuals. This concern was appropriately dispositioned by Ebasco, HL&P, and the Sheetmetal Workers' International Association (SMWIA). This concern related to an alleged sale of drugs to a named site employee. STP records show that this employee successfully

, passed three fitness-for-duty exa 11 nations during calendar l year 1987. This allegation is considered substantiated by SAFETEAM in that the named individual was found on site,

! however, the allegation that this employee may have used drugs was not substantiated.

I l The NRC inspectors' findings agreed with the SAFETEAM classification of "nonsafety-related" for each of these 25 identified concern These allegations are technically closed.

, (Technically Closed) Allegation RIV-87-A-0044 i Allegation RIV-87-A-0044 involved an alleger whose allegation was

' forwarded to the Department of Labor (00L). This concern declared that the alleger's contractor had harassed him and terminated his employment because of his attempts to do quality work and his complaints to a SAFETEAM investigator. The NRC inspector reviewed the results of the SAFETEAM evaluation and investigation of this concer The SAFETEAM records and discussions with SAFETEAM personnel determined that the alleger was terminated on September 25,

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1986, via a mailgram. The documented cause for the employee's termination was excessive absenteeism in violation of Job Rule No. 11. The SAFETEAM investigation records indicated that the employee had failed to report for work on the following dates:

August 4, 6, 17, 18, and 29; and the entire week ending on September 21, 1986. The SAFETEAM records indicated that the employee had never exited through the SAFETEAM nor reported a concern to the SAFETEA SAFETEAM personnel could not recall a failure of SAFETEAM personnel to document an entrance or exit meeting with this allege Although the alleger claimed that he had received permission on September 14, 1986 to take leave, there are no records of this request to support the allegers' claim. This allegation was not substantiated by the SAFETEAM investigatio The NRC inspector's review and evaluation of the SAFETEAM records for these two allegations indicated that the SAFETEAM had investigated and evaluated these allegations and concerns appropriately. The NRC inspector agreed with the SAFETEAM conclusions related to these allegations. These allegat'ons are considered resolved and are technically close c. (Technically Closed) Allegation 4-87-A-087 Essential cooling water (ECW) power cables, in Unit 1, were alleged to be located in an area (manhole No. 5) which could become floode Furthermore,- it was alleged that these cables were not qualified for submergenc The NRC inspector reviewed the cable installation cards for cables AIEWAACIGA, BIEWABCIGA, and CIEWACCIG These cables are the power supply cables to ECW pumps 1A, 1B, and 1C, respectively. The receiving and inspection records for the associated cables, RIP No. 6942, were reviewe The records were found to contain certification that the cables met the requirements for gravimetric water absorption and accelerated water absorption and thus the safety-related cables were qualified for submergence. The cables were tested in accordance with Insulated Cable Engineers Association (ICEA) methods,.as specified in IEEE Standards 383 and 50 The NRC inspector inspected the power cables at the essential cooling intake structure for proper identification and routing to the underground conduit. Manholes A0XYABKEM51, BOXYABKEM51, and C0XYABKEM51 were inspected to verify that the cables were properly routed in accordance with the cable cards. There was no evidence of flooding in the manholes or deterioration of any cables therei Nonsafety Manhole N0XYABKHM05 (Manhole No. 5) was inspected and found to be substantially flooded with most of the cables therein either totally or partially submerged. The NRC inspectors visual inspection of this

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manhole found no evidence that any safety-related cables were presen During the course of the NRC inspector's review, he also inspected five Unit 2 safety-related manholes related to ECW Pump 2A power cable and found no evidence of flooding or cable damag Although Manhole-No. 5 was flooded, it did not contain safety-related cables. This allegation is technically close . Tremco Type 440-A Inspection and Review Inspection and Review Discussion This inspection was performed to evaluate the installation of Tremco 440 or 440-A in the heating, ventilation, and air conditioning (HVAC) systems for Units 1 and Tremco Type 440 is a nondrying, permanently elastic, and preformed sealant made of 100 percent solid polyisobutylene-butyl materia The material has desired adhesion and compressibility characteristics. The difference between Tremco 440 and 440-A is that the Type 440-A has an EPDM core (a hard synthetic rubber material).

The Type 440 does not have an EPDM cor The 440-A material exhibits heat resistance in the temperature range of -40 F to 200 F with no loss of oil, surface blistering, or loss of adhesion during long-term service. The fire resistance is in accordance with ASTM E-8 The Tremco gasket material was evaluated as a combustible material from two perspectives. First, it was determined whether the Tremco material was relied upon to prevent the spread of fire or to ensure duct integrity during a fir Second, the effect of adding Tremco material to the combustible fire loading calculations was considere Each of these issues was considered in the licensee's fire hazard analysis (FHA). The NRC inspectors verified that the STP FHA does not rely upon Tremco material gaskets to prevent the spread of a fire or to ensure the HVAC systems operability during a fire. In cases where duct integrity was not assumed, fire dampers are provided to prevent the spread of fire. The NRC inspectors did not identify any exceptions to this approach by STP. The licensee performed fire hazard analysis for fire area 32, zone 122, which is located in the rechanical equipment auxiliary building (MEAB) at elevation 60 fee This zone contains the maximum concentration of Tremco Type 440- The analysis showed a very insignificant increase in the total combustible loading. The flame spread is reported as a value of 20, which is conservative with respect to the STP FSAR commitment for a value of 5 . - _ , - . -

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The HVAC ducts inside the reactor containment building (RCB) are sealed with EPDM gasket material. Tremco is not used for applications within the RCB. Tremco material used at the STP facility is used only to seal joints in the safety and nonsafety-related HVAC ductwork outside the RC The NRC inspectors examined HVAC ductwork at the following plant locations in Units 1 and 2:

control rooms; electrical equipment rooms; cable spread rooms; rooms and corridors above the control rooms and adjacent to the control rooms; battery rooms; MEABs; radwaste control room (room 217);

switchgear rooms; and other safety and nonsafety-related rooms and area The NRC inspectors reviewed the following HVAC drawings and related documentation:

Drawing 5-V-11-2-V-0055-A-10, Revision 5, dated December 2, 1987, and Revision 4, dated October 11, 1985 Drawing 5-V-2-V-0056-A-10, Revision 5, dated January 13, 1987 Drawing 5-V-11-2-V-0056-B-10, Revision 5, dated January 13, 1987 Standard Site Procedure SSP-38, Revision 1, dated December 11, 1987 During the walkdown of the plant, the NRC inspectors verified that Tremco materials were installed as a sealant between more than 50 percent of the bolted joints in the HVAC ductwork; however, Tremco materials were not installed on removable duct sections, duct heaters, fire dampers, or on electric or pneumatic sealant surface Further, the NRC inspectors review of drawings and standard site Procedure SSP-38, Revision 1, verified that the Tremco materials were installed in accordance with the appropriate procedure _ - _ _ _ _ - _. . _ - _ . _ _ . _ _ - _ _ . _ . _ _ ._ _ _ _ _ _ -

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The NRC inspectors concluded that the use of Tremco 440 and 440-A as an HVAC joint sealant at STP Units 1 and 2 was supported by engineering analyses, that the material was properly installed, and that its analyses. presence was taken into account properly in fire hazards No violations or deviations were identified, Nonconformance Report (NCR) Review The NRC inspector reviewed the NCR files for HVAC system air in-leakage to the control room air recirculation system. The NRC inspector did not identify any NCR that would indicate in-leakage or excessive leakage from the HVAC system control room air recirculation system. The following NCR files were reviewed:

CH-00001 through 00882, dated May 5, 1983, through July 2, 1984 BH-00001 through 00090, dated March 6, 1984, through January 22, 1986 BH-030000 through CH-03396, dated September 19, 1985, through January 22, 1988 CH-00864, "Gasket for Removable Duct," dated August 14, 1985 CH-00450, "HVAC Duct," dated January 17, 1985 CH-00445, "Tremco 440," dated January 17, 1985, and letter Tremco to Bechtel, "Tremco 440 Tape Vehicle Extrusion in Metal Ductwork Laps," dated January 22, 1985 CH-00408, "Tremco 440A Shim Gasket," dated December 17, 1984 CH-03004, "Duct Pc, #1-1-0087-114," dated September 3, 1985 l

No violations or deviations were identifie . NSSS Equipment Installation Followup in Unit 1 The following items were reviewed in support of the NRR Safety Significance Assessment Team effort: Primary System Components The NRC inspector completed a followup inspection to review an item discussed in NRC Inspection Report 50-498/83-06, paragraph 7, dated May 4, 1983. Out-of-plumb (out-of-vertical) anomalies were originally discovered in the position of the steam generators (SG) in Unit 1. Documentation indicated that SG No. I was 0.78 degrees l

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9 out-of-plumb and SG No. 4 was 0.75 degrees out-of-plumb. These anomalies were identified during an optical survey. Subsequent to this optical survey, HL&P completed a review and evaluation of the as-installed condition of all NSSS equipment in Unit 1. The NSSS had determined that the out-of-plumb condition, as measured, was not a concern because the out-of-plumb condition would not adversely affect the stress analysis, seismic considerations, or operability of these SGs. The final disposition was to use the SGs "as-is".

HL&P, in conjunction with the NSSS, performed analyses of the effects of the out-of-plumb condition of the SG on other components, including the vertical supports; the SG lateral restraints; the SG reactor coolant pump (RCP) vertical restraints; and the piping;izer pressur seismic lug. It was demonstrated that the SG misalignment would not adversely affect the stress analysis, seismic considerations, or operability of these components. The calculations indicated that, for the worst case, stresses would be increased from 35 percent of allowable to 50 percent of allowable. The final disposition was to use these components in the "as-in" conditio The NRC inspector reviewed these evaluations, analyses, and calculations and determined that the values reported by HL&P and the NSSS were technically sound and that HL&Ps decision to use the components in the "as-is" condition will not constitute a safety or an operability proble This item is closed, Reactor Pressure Vessel HL&P documentation indicated that the reactor pressure vessel was set in place using erection tolerances stated in Bro'wn & Root Quality Construction Proceoure A040XPM-P-10 "Setting the Reactor Vessel."

The sus;'cted out-of-tolerance condition was resolved by Westinghouse Letter Si WN-YB-629, dated October 4, 1983. Based on the calculations and evaluations contained in this letter, the out-of-levelness condition on the reactor pressure vessel support ledge and the mating surface, does not constitute a safety concer The NRC inspector reviewed the calculations and evaluations and determined that the basis for acceptance was technically sound and that the decision to use the Primary System "as-is" will not constitute a safety or an operability problem. This item is close No violations or deviations were identifie . Nuclear Welding (55050)

The NRC inspector selectively reviewed 62 completed documentation packages for safety-related welds; these consisted of 22 ASME Section III Code Class 1 welds, 20 ASME Section III Code Class 3 welds, and 20 ASME Section III Code Class MC welds. The Class 1 welds were selected from the reactor coolant and residual heat removal piping systems, the control rod

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drive mechanism, the bottom mounted instrumentation tubes, and the degassing pipecap on the reactor vessel head. The Class 3 welds were selected from the reactor makeup, the component cooling, the essential service water, and the chemical, and volume control piping systems. The Class MC welds were selected from the feedwater, auxiliary feedwater, chemical and volume control, safety injection, containment spray, main steam, and steam generator blowdown piping systems. The review included all containment piping penetration welds that required postweld heat treatmen In areas reviewed, the weld records were complete, accurate, and retrievabl Since the observation of work inspection for nuclear welding was performed in a previous inspection which is documented in Inspection Report 50-499/86-01, this inspection was limited to a record revie No violations or deviations were identifie . Electrical Cables The purpose of this inspection was to determine whether activities relative to safety-related electric cable systems are being controlled and accomplished in accordance with safety analysis report commitments and licensee procedures. The inspection included direct observation of work in-process and of completed work, Work Observation, Unit 2 The NRC inspector reviewed the cable pull cards, termination cards, and receiving inspection records (RIP) associated with the electrical cables listed below:

Cable N Code N RIP N C2MB03C1SM XCCTK 8400 l A2PK04C4SL CA712 3381

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A2PNAECISA RA306 2414 B2PK02C2WB CBB12 4944 82PL05C2SA 1B3P6 3968 A2PL01J1WR SA114 11816 A2RC05C1WK CA512 12597 B2RCADC1LA RB310 11046 B2RCADC1LC RB310 11046 l C2CV06C1SA CC712 10034 B2RC10C8PA XB2WA D2RC10C8PB 103P6 3968 B2SPACCISA RB302 453 C2SPADCISA RB302 5193

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A2S1AAC1E PA125 8654 A2S105CISA CAB 12- 2014-A2S129C1XC 1A5Q6 4431 82S1ALC1LB RB304 13164 A2S122C3WD XA8LB 15041 82SP21CC5C CB312- 9900 A2SP22CSSA 1A3P6 6280 B2SP16CGSD CB212 990 SP22CXSA 183P6- 3968-C2SP22CUSA 1C9P6' 3650 A2EWAACIGA 3PA125 8654 The NRC inspector verified that the above cable terminations agreed with the termination cards. Each termination was checked back to the last raceway or beyond to determine whether:

o raceway and conduit conditions were adequate for the cables installed; o cable routing was correct; o separation was maintained; o cable identification was preserved; o proper bending radius was maintained; and o cable entry to the terminal point was acceptabl Each Raychem splice was verified on the termination cards, and all termination points were verified by color code and proper wire and cable markings. All terminations were found to be procer'iy located and acceptabl The NRC inspector examined the RIPS for each cable for proper documentation and cable certification records. All RIPS were found to be acceptable and cross checked with the cable cards for proper cable code and cable reel number The NRC inspector observed one cable pull operation, Cable No. C2CHACC1LB, in which the following determinations were made:

o the cable was as specified and identified; o cable routing was correct; o proper bending radius was maintained; o coiled cables were properly secured and protected;

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o' installation and inspection activities were being documented during the activ_ity; and o- electricians were adequately qualified and traine Three in-process terminations (i.e. , for a motor, an instrument, and a relay panel) were observed which included Raychem splicin The NRC inspector determined from his observation that:

o proper procedures were being followed; o qualified field engineers and electricians were being used; o the required tools were being used and they had current calibration; o qualitied inspectors were observing and documenting the activities; o terminations were properly made up; and o equipment was as specifie During the course of observing these terminations and the above cable pull, the NRC inspector observed that the personnel exhibited a good attitude toward quality work and that there was apparent cooperation between craft and inspection personne The NRC inspector observed one cable cutting operation in the cable shed to evaluate proper operations involving the following:

o selection of the proper reel; o proper documentation; o cable inspection; o in-place storage; and l

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! In the above areas of inspection, the NRC inspector noted one discrepancy in a vendor-supplied termination boot modification. The licensee has taken action on NCR SE-07198 to address the problem.

i l The NRC inspector inspected several identical boots in other termination locations. No other discrepancies were noted and this was determined by the NRC inspector to be an isolated cas No violations or deviations were identifie b. Raychem Splice Followup, Unit 1 f

The NRC inspector followed up on Surveillance Report SH-1186 conducted by the utility on January 21 and 22, 1988, on sampling of engineering splice review log. The NRC inspector examined the

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Raychem splice on Cable End BIDJ10C2SV-1 that had not been reinspected during the Raychem reinspection program. The NRC inspector also looked at other Raychem splices selected at random in the Unit I relay room. During the inspection of a Raychem splice on Cable C1XE3CRH001 in the reactor vessel water level indicating (RVLIS) cabinet, the NRC inspector noted that the top north cutout access cover plate was not fastened down. The licensee has taken action on Maintenance Work Request (MWR) AM-58843 and completed the work on the RVLIS satisfactorily. The licensee indicated to the NRC inspector that they still had not determined why this work item had not been completed and what their corrective actions would be. This item will remain a unresolved item pending a review by the NRC inspector of the cause of the cabinet being ope (498/8802-01)

With regard to Raychem splicing, no violations or deviations were identifie . Battery Room Modifications (Units 1 and 2)

The NRC inspector had noted in October 1987, that there was a berm which did not extend to the wall for the 1800 AH safety-related batteries. The licensee had issued an engineering support request on October 7, 1987, to extend the berm. On October 21, 1987, the licensee informed the NRC inspector that the berm was unnecessary. The NRC inspector requested that the licensee explain why the berm was part of the original design but was no longer neede This item is considered unresolved pending receipt of the analysis from the licensee. (498/8802-02 and 499/8802-01)

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8. Inspection of Licensee's Actions Taken to Implement Unresolved Safety Ts' sue A-26: Reactor Vessel Pressure Transient Protection

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During this inspection period, an inspection was performed to verify that the licensee has an effective mitigation system for low-temperature overpressure transient conditions in accordance with their comitments

, concerning Unresolved Safety Issue A-26.

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l Station Procedure No.1P0P03-ZG-0008, dated July 27, 1987 l

Station Procedure No.1P0P03-ZG-0001, dated January 21, 1988 Station Procedure No. 1 POP 03-ZG-0007, dated January 21, 1988 Plant Procedure No. OPGP03-ZA-0002, Revision 7, dated January 24, 1988 l

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Piping and Instrumentation Diagram RCS Pressurizer Diagram No. 5R149F05003, Revision 4, dated June 17, 1987 Reactor Coolant Pressurizer Power Relief Valves Logic Diagram, SR-14-9-Z-42160 The NRC inspector performed an inspection to determine that STP, Unit I has installed and demonstrated controls and procedures to mitigate a postulated low-temperature overpressure conditions at Unit 1. The NRC inspector reviewed the procedures and administrative controls which are in place to aid the operator in controlling the reactor coolant system pressure during low-temperature operation. The documentation reviewed showed that an overpressure protection system at STP, Unit 1 is designe and installed to prevent exceeding the applicable technical specification and 10 CFR Part 50, Appendix G, limits for the reactor pressure during plant cooldown or startup. A redundant protection against a low temperature overpressure event is provided throu pressurizer power operated relief valves (PORVs)gh the use to mitigate of two potential pressure transients. The STP PORVs are safety-related and Class IE powere The actions and commitments established by the licensee in response to USI A-26, "Reactor Vessel Transient Protection for Pressurized Water Reactors, appeared to ensure that an effective mitigation system has been established for low-temperature overpressure condition No violations or deviations were identifie . Exit Interview The NRC inspectors met with licensee representatives, denoted in paragraph 1, on January 29, 1988, and summarized the scope and findings of the inspection.