IR 05000498/1985019

Insp Repts 50-498/85-19 & 50-499/85-17 on 850930-1122. Violation Noted:Filler Matl Issue Repts (Fmir) for Some Supports Listed Welders Unidentified on Mpdc & Fmir Matl Ref Numbers Not Documented on Mpdc

ML20140D827
Person / Time
Site:	South Texas
Issue date:	01/16/1986
From:	Constable G, Ireland R, Clay Johnson, Renee Taylor, Tomlinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140D802	List: IR 05000930/2011022 ML20140D796 ML20140D827
References
50-498-85-19, 50-499-85-17, NUDOCS 8602030121
Download: ML20140D827 (14)

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- APPENDIX B

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U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/85-19 Construction Permits: CPPR-128 50-499/85-17 CPPR-129 Dockets: 50-498 50-499

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Licensee: Houston Lighting & Power Company (HL&P)

P. O. Box 1700

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Houston, Texas 77001 Facility Name: . South Texas Project, Units 1 and 2 Inspection At: South Texas Project, Matagorda County, Texas

. Inspection Conducted: September 30 - November 22, 1985 Inspectors: k a, dr_, e m, )-16 - 8 6

, C..E. Johnson, Senio0 Resident Inspector Date

! Project Section C, Reactor Projects Branch (paragraphs 1, 2, 3, 5, 6, & 7)

/ ->GW-R. G. Taylor, Project Inspector, Project Date Secti6n C, Reactor Projects Branch-(paragraph 3)

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, } 'lanblJ I-/C hY,

/p D. Tomlin9en, Reactor Inspector, Date i Engineering Section, Reactor Safety

, Branch (paragra JL_4) .

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) g Approved: / f7 G. L.TUnstaMef-Chief, Project Section C

///F Date '

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Reactor Projects Branch R. E. Ireland, Chipf, Engineering Section Date Reactor Safety Branch 0602030121 860129 PDR ADOCK 05000490 G PDR

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-2-Inspection Summary Inspection Conducted September 30 through November 22, 1985 (Report 50-498/

85-19;50-499/85-17)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, allegation follow-up, pipe support records review, and reactor coolant pressure boundary piping. The inspection involved 323 inspection-hours onsite by three NRC inspector Results: Within the scope of this inspection, one violation was identified and is discussed in paragraph 5.

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-3-DETAILS Persons Contacted Principal Licensee Employees

• S. Head, Lead Project Compliance Engineer

• K. O'Gara, Project Compliance Engineer R. R. Hernandez, Supervisor, Project Compliance S. Hubbard, QA Welding Engineer

• T. Jordan, Project QA Manager

• I. L. Guthrie, Project Manager, Safeteam

• W. N. Phillips, Project Manager, Safeteam (outgoing)

• G. B. Rodgers, Construction Manager Other Personnel Bechtel Power Corporation (Bechtel)

• W. Miller, Deputy PQAM

• D. Bryan, Construction Manager

• H. Medina, Lead QAE

• W. Humes, Site Project Engineer Ebasco Services, Inc. (Ebasco)

I J. Johnson, Lead Documentation Specialist (Welding)

D. Sprouse, QC Supervisor (Welding)

F. Miller, Welding Superintendent

• A. M. Cutrona, QA Kanager

• J. Taylor, Site Manager Westinghouse C. Hahn, Welding Engineer

• Denotes those individuals attending the exit interview conducted on November 26, 198 . Site Tour **

The NRC inspector made several site tours through Unit 1 and 2 facilities in order to observe safety-related work in process, the condition of safety-related equipment, and general plant statu No violations or deviations were identified.

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-4-3. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-498/499 83-11-03) Filing of Procedurally Required Logs:

This item concerns a finding that accountability type logs are required to be maintained by some procedure The NRC-inspector had noted that the procedures were deficient in clear instructions on filing the log The applicable procedure, QCP-17.1, Revision 2, " Quality Assurance Records," has been changed to include the statement: "5.8 All logs maintained in accordance with QC procedures shall be transferred to the Ebasco records group, upon completion of all activities relative to the scope of these logs, for further processing in accordance with their procedures." This item is considered close (Closed) Deviation (50-498/77-12; 50-499/77-07) Design Review Committee:

This finding noted that the licensee's Design Review Committee was not performing the functions described in the PSAR. The licensee indicated his intent to clarify the responsibilities of the above committee upon issuance of the FSA The FSAR was submitted in July 1978 and Section 17.1 was revised as indicated by the licensee in his response to the deviation. The NRC directed deletion of Section 17.1 via question 42 on October 9, 1978, and further directed that revisions to the QA program for design and construction be submitted independent of the FSAR for review. The licensee responded to this direction by submittal of a separate docketed Quality Assurance Program Description in 1980. This document no longer discussed the " Design Review Committee" with the functions of the committee vested in other organization This item is considered close (Closed) Violation (50-498/79-19-50; 50-499/79-19-50) Failure by Brown & Root to Perform Supplemental Audits:

This item is considered closed since Brown & Root has had no involvement in the South Texas Project that would require supplemental audits since early 198 (Closed) Unresolved Item (50-498/83-01-04) Storage Requirements and Equipment Identification:

The NRC inspector, by review of pertinent documents and interviews with involved personnel determined that the equipment involved was two large nonsafety 15kv switchgear cabinets rather than safety-related motor control centers. Procurement of nonsafety equipment under a safety-related specification is acceptable; however, safety-related storage requirements are not applicable to nonsafety equipment. This item is considered close " o

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(Closed) Unresolved Item (8315-06) Nonconformance Report (NCR) Tags Not Completed During a periodic spot-check of NCR tags in the field and in the warehouse areas, the NRC inspector observed that the NCR number block on the form .

sometimes contained information other than the identifying NCR number. In some cases the word "Pending" or "N/A" had been entered. In other cases the~NCR number was entered but no further information describing the nonconforming condition. It was explained to the NRC inspector that this practice was permitted by governing procedures. The NRC inspector questioned this as an acceptable practice and stated that this would be

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considered an unresolved item pending further revie The NRC inspector reviewed the original QCP 15.1, and early revisions, noting that the application of the NRC tag was not clearly defined. The NCR tags were allowed to be placed on the material, prior to issuance of the NCR, to serve as notification that a nonconformance had been note QCP 15.1, Revision 4, dated January 26, 1984, clarified this by stating that the NCR tag will be attached only after validation of the NCR and the entering of the number on the tag. This item is close . Follow-up on Allegations

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(Closed) Allegation 4-84-A-092 (Inappropriate Weld Rods)

On September 3, 1985, Region IV received a phone call from an individual with concerns about the site purchase of a * certain type of welding filler material. His specific concerns were: The type 7018 weld rods are 2 inches shorter than the standard 14" rods he is use to using, Welders cannot achieve a 2" weld length in the overhead position with these shorter rods, The flux coating on the rod is chipped and cracked, causing excessive weld spatter and weld porosit The filler material was produced in another country and shipped to Houston for sale. At one time he mentioned Mexico and later the Philippine Islands as the point of productio On September 6, 1985, the same individual expressed these concerns to the South Texas Safeteam and forwarded a copy of his letter to the Region IV office. On September 10, 1985, Region IV contacted this individual by telephone and confirmed these concern The NRC inspector ascertained that the filler material was purchased by Bechtel from Oerlikon Welding Industries located in Houston, Texas. This-is a new supplier for STP. When questioned by the NRC inspector, the Bechtel purchasing agent stated that the reasons for

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-6-changing suppliers were economics, time, and risk of handling damag It was felt that the lower initial cost of the filler material, the shorter turn-around time between order and delivery, and the elimination of potential handling damage because of local delivery were considered adequate justification for changing supplier Prior to issuance of the purchase order, Bechtel conducted an in-depth audit of the Oerlikon manufacturing facility. Oerlikon was added to the approved vendors list based upon the satisfactory results of this audit, and a purchase order was issued for 60,000 pounds of type 7018 filler material with a 3/32" diameter. A partial shipment was received on July 12, 1985, and the first issue from the warehouse to field activities was on August 4, 198 Several days later, welding supervisors, QC inspectors, and the Ebasco welding engineering office began receiving similar complaints about this filler materia Virtually all of the complaints were about excessive weld spatter, weld porosity, broken flux coatings, and uneven consumption rate of the weld ro Ebasco welding engineering performed a visual inspection of the flux coating on rod in the field and found that a significant percentage had cracked and broken areas and that the flux was not of uniform thickness along the length of the rod The flux coating on arc welding electrodes serves three functions: arc stabilization, prevention of oxidation of the molten weld puddle, and to provide additives to the weld to produce the

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desired chemical and physical properties. The flux coating anomalies mentioned above would probably result in weld spatter, weld porosity, unstable arc characteristics, and erratic rod consumption. Several sealed containers were opened in the warehouse and the same conditions were note Although the material certifications and all supporting documentation indicated that the rod was as ordered, the usage and visual inspection proved that it was not suitable for the high quality welding required at a nuclear construction site. The partial shipment received from Oerlikon consisted of two different lot numbers. After opening several more sealed containers, it was determined that Lot No. 10450 contained flux discrepancies and that Lot No. 10496 appeared to be acceptable for us A representative from Oerliknn visited STP on August 16, 1985, and a joint inspection of both lots of material was performed by Oerlikon, Bechtel, and Ebasc All agreed that the flux coating was unacceptable and the remainder of Lot No. 10450 that had been issued for use was retrieved from the field. Oerlikon stated that they would retract the unused portion of the 20,000 pounds of material identified as Lot No. 10450 and replace it with another lot of material having a higher quality flux coatin Prior to issuing any filler material bearing the second lot number (10496),

Ebasco conducted several weldability tests at the Weld Qualification Center onsite. Three welding supervisors were instructed to weld for several hours each using Oerlikon Lot No. 10496 material in the flat, vertical, and overhead positions and make independent evaluations of the ro Each of

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-7-the three submitted signed statements to the Ebasco welding engineer stating that they felt the filler material and flux coatings were adequate to produce quality welds. Two of these welds were selected at random and subjected to radiographic inspection. Both were found to be acceptabl Based upon this information, Lot No. 10496 was issued for use by field activitie When the remainder of Lot No. 10450 was withdrawn from the field issue stations, 18,960 pounds were recovered leaving 1,040 pounds unrecovere It is not certain how much of this was used on safety-related or nonsafety-related welding. As a minimum, visual inspection is performed on all safety-related welds and the excessive weld spatter and weld porosity would be cause for rejection of any weld exhibiting these conditions. Because of the inspections performed, any rejectable anoma)ies resulting from the use of this filler material would be subjected to rework or removal of the weld. It was noted by the NRC inspector and the others who examined Lot No. 10450 that not every piece of welding rod had an inadequate flux coating. Although most of the rods were found to be acceptable, the deficient ones were found in sufficient quantity to question the acceptability of the entire lot. Because of inspections performed on all safety related welding and the sporadic occurrence of flux coating defects, it has been determined that use of the 1,040 pounds of material will have virtually no safety significanc After Region IV was contacted by the concerned individual, an additional weldability test was conducted at the request of the NRC inspector. Ebasco selected a certified welder who reported to the Welder Qualification Center on September 17, 1985. This test was observed by the NRC inspector and cognizant representatives of HL&P and Ebasco. The welder, operating in the vertical position, stated that he had no difficulty in making several welds. The observers noted that the weld rod produced a very stable arc, smooth weld contour, no undercutting, and only minimal weld spatte No surface porosity was noted in the final weld surface The alleger stated, in concern 1, that the Oerlikon filler material is 2" shorter than those produced by other manufacturers. The ASME l Code, AWS standards, and other industry-accepted standards contain no requirements for the length of welding rods. Although the traditional length for 3/32" rod is 14", Oerlikon has opted to produce theirs in 12" lengths. The rationale for this is that 3/32" rod is commonly used for tack welding and other relatively small applications. The shorter rod length should result in shorter rod stubs being scrapped and a higher percentage of each rod being used to produce weld This was seen as being a monetary advantage to the projec Although this concern was substantiated, it violates no site or industry standar _ _ _. . .

-8-The alleger stated, in concern 2, that he was unable to produce a 2" length of weld in the overhead position with this shorter length rod. The alleger is a welder involved in the welding of steel Unistrut shapes for electrical supports. This is done with " stitch" of " chain" welding which consists of a series of intermittent welds of a specified length separated by unwelded areas of a specified length. In this case the required weld length is 2".

None of the three supervisors or the welder mentioned above voiced this concern. Although the requirement governing his welding states that each weld shall be 2" long, there is no stipulation that this be accomplished using a single electrod This allegation could not be substantiate It violates no site or industry standar The alleger stated, in concern 3, that the f ax coating on the Oerlikon rod is chipped and cracked, causing excessive weld spatter and weld porosity. As stated above, Lot No. 10450 of Oerlikon 3/32" filler material was found to have a flux coating of less than acceptable quality. Lot No. 10496, presently being used in the field, was found to be acceptable by visual inspectiAn and the weldability tests performe Although this allegation was substantiated, it has since been correcte This allegation has little or no safety significance as all safety-related welds are inspected and the conditions, as stated, would be cause for rejection of the wel The alleger stated, in concern 4, that the filler material was produced in a foreign country and shipped to Houston for sale. As a result of this concern, the NRC inspector reviewed the purchase order requirements and receiving inspection documentation for this material. Clause 14 of this purchase order clearly states that the material shall be of domestic origi The flux coating applied to the surface of welding rod is a combination of elements formulated to produce the desired weld characteristics. This combination should produce a stable welding arc, smooth deposition rate, uniform finished surface and, most importantly, the required chemical and physical properties in the weld metal. The combination of elements used by various manufacturers is the only real difference between filler materials of the same type produced by different manufacturers. The chemical composition of the various fluxes are considered to be trade secrets and highly proprietary. The flux is mixed and applied to domestic wire in the Oerlikon Houston facility and the finished product is, therefore, considered to be of domestic origin and in compliance with clause 14 of the purchase orde This allegation could not be substantiate As stated above, concerns 2 and 4 could not be substantiate Concern 1, although substantiated, violated no site or industry standard and has no

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-9-safety significance. Concern 3, although substantiated, was corrected prior to the alleger notifying Region IV of his concerns. Because of this prompt retrieval of deficient material and the inspections performed on safety-related welds, this item is deemed to have no safety significanc Based on the above findings, Allegation 4-85-A-092 is close (Closed) Allegation 4-85-A-080 (Alleged Mismanagement of Safeteam)

On July 16, 1985, an individual telephoned Region IV and presented a general allegation about mismanagement of the South Texas Project Safetea The individual stated that a letter with specific information and selected documents would be forthcomin This has not been received. Several unsuccessful attempts were made to contact the individual by telephone and on August 1, 1985, an unacknowledged certified letter was sent by Region IV to the address provided by the individual. The NRC inspector also made seven unsuccessful attempts at telephone contact between October 1 and 4, 198 Because the individual identified himself as a former Safeteam investigator at STP, the NRC inspector contacted the Safeteam and learned that the same allegations had been received by them several months prior to the NRC notification. In an effort to avoid any appearance of a biased self-investigation, the Safeteam engaged the services of an experienced consultant organization to conduct an independent third party evaluation of these allegations. The final report of this investigation, on file with the Safeteam, was found to be comprehensive and impartial. The independent investigation found that the allegations of Safeteam mismanagement could not be substantiated and that "the cause of the concerns was the disgruntlement of the terminated Safeteam investigator and his desire to discredit the safeteam investigator coordinator."

The NRC inspector reviewed the personnel records of the individual and noted that he had received a formal notification on February 13, 1985, that his job performance was less that satisfactory. This notification and several non-job related incidents resulted in his dismissal on April 1, 1985. During his termination interview he was given an addressed and prestamped " concern form" on which he originally stated his allegations of mismanagement. The Safeteam, in an effort to gain more information, unsuccessfully attempted to contact the individual by mail on April 23, July 25, August 1, and September 6, 1985. In addition, the Safeteam attempted, via certified mail, to contact the individual on September 5, 198 The NRC inspector, as stated, also attempted to contact the individual by telephone on several occasicns, all unsuccessfu In addition to reviewing the personnel records for this individual, the NRC inspector reviewed the independent third party investigation

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-10-report of these allegations. The report addressed each of the specific concerns in detail and drew conclusions for each from the information gathered. The investigation appears to have been conducted in a thorough and professional manne ,

Based upon the NRC review of the third-party investigation and the inability of the NRC and the Safeteam to reestablish contact with this individual, Allegation 4-85-A-080 is close . Pipe Supports Records Review

, Records Review The NRC inspector reviewed 15 pipe support traveler packages in the j

FiMS vault. During this review of pipe support records, the NRC

inspector observed several discrepancies.

j (1) Some FMIRs for some of the supports listed welders who appeared to have performed work on the support but were not identified on

.l the MPDC.

) (2) Some FMIR material reference numbers (heat numbers) were not documented on the MPDC as required by procedure, j By procedure it is not required to maintain FMIRs in the records,

however, it is required by QCP-9.1 for the QC supervisor to assure, during final review, that the WPS, welder ID, and material reference

! number, recorded on the FMIRs contained in the weld package, are also i documented on the MPDC. These discrepancies appear to be in

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violation of procedure QCP- i i

The records reviewed by the NRC inspector indicated a procedural i problem and not a hardware problem, since all required information i

had been retained but not fully transferred from record to recor Documents Reviewed

. EW-1129-HL5003 . EW-1114-HL5007

. EW-1329-HL5003 . EW-1229-HL5003 i . EW-1114-HL5001 . EU-1330-HL5003

! . EW-1107-HL5003 . EW-1229-HL5005

) . EW-1114-HL5003 . EW-1107-HL5008 1 . EW-1113-HL5001 . EW-1113-HL5001 j . EW-1114-HF5002 . EW-1129-HL5001 i . EW-1130-HL5002 . EW-1130-HL5003 I

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--&-r------p-w- m e w -y -g-ym,ww9-i--**r-WmFPWM-1-W-er'tr-M~wwf*1N T*FP -*-* **- "

Mtww2FT'TM'**"-*'-**"PP- -MW'-4- -' " * T'CCm-*'t

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. EW-1114-HF5006 . EW-1130-HL5001

. EW-1130-HL5003 . EW-1113-HF5006

. EW-1130-HL5006 . EW-1113-HF5003 Welders Qualification and Filler Material Certification The NRC inspector reviewed approximately 16 welder's qualification All welders listed on the support packages were qualified to make the welds. The weld filler materials were also found to be certified in accordance with requirement No discrepancies were observe . Reactor Coolant Pressure Boundary Piping Procedure /Soecification Review (QA Review)

The NRC inspector reviewed various procedures and specifications related to the RC loop. Westinghouse has Engineering Specifications (ES). Design Specifications (DS), General Specifications (GS) and Process Specifications (PS) governing RC loop activitie Bechtel has specifications and Ebasco has procedures used in conjunction with the Bechtel specification. Ebasco's procedure /

specification are not separate for just the RC loop, they cover all Class 1, 2, and 3 piping erection and field fabricatio The FSAR, Table 3.2.A-1 and related site specifications list applicable Codes and standards that the RC loop is fabricated and installed to Westinghouse ES, GS, and PS specifications are incor-parated into the vendors procedures, and also the site specific procedures by Bechtel and Ebasc Appropriate and adequate procedures have been established for the specific activities below:

. Procurement

. Receipt Inspection

. Storage Requirements

. flaterial, Welding, and Installation

. Fabrication

. Cleaning and Pressure Testing

. Coating

. Applicable Codes It appears that technical requirements referenced in the FSAR associated with the reactor coolant pressure boundary piping have been adequately addressed or referenced in the construction specification, drawings and procedure .. - _

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-12-Documents reviewed are listed below:

Bechtel/Ebasco

. Specification 5A010PS002, Revision 7, " Specification for Piping

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Erection and Field Fabrication," dated August 21, 1985

. Specification 4LO20PS01000, Revision 5, " Specification for Fabrication of ASME Section III Piping 2 1/2-inches and

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Larger," dated September 6,198 .

. QCP-9.1, Revision 6, " Weld Inspection ASME," dated October 4, 198 Westinghouse

. G-678864, Revision 4, "RC Centrifugally Cast Pipe, ASME i Section III, Class 1, Safety Class I," dated May 16, 1975

. G-678864, Revision 4, "RC Cast Fittings, ASME Section III,

Class 1, Safety Class 1," dated February 26, 1975

. G-678843, Revision 3, "RC Piping Shop Fabrication, ASME III, Class 1, Safety Class 1," dated June 24, 1975 No violations or deviations were identifie Reactor Coolant Pressure Boundary Piping Work Observation, Units 1 and 2

The NRC inspector observed completed work and partially completed work on Unit I RC loop 4 and portions of the pressurizer surge lin Using the design / installation drawings the NRC inspector verified general orientation and configuration, components, thermowells and component parts, serial number and heat code. By direct observation,

the work on loop 4 RC boundary piping, except welding and NDE i activities, are being accomplished in accordance with licensee drawings / procedures. During the observation of the RC loop, Unit 1, the NRC inspector noticed some modification taking place. Discussions with Westinghouse indicated that the modification is the elimination of the RTD bypass. FCN #TGXM 10611A gives details of this modifi-cation. Unit 1 RC loop is approximately 97% complete. The NRC inspector observed work in Unit 2 RC loop. The reactor coolant j

pump / reactor vessel (cold leg) and the steam generator / reactor vessel

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(hot legs) sections are installed on all four loop The steam generator /RC pump crossover legs are not installed on any of the

! loops in Unit 2 at this time. Work appears to be in accordance to

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plan No discrepancies were observed during the observatio I e f u

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-13-Documents reviewed are listed below:

Westinghouse Drawings 1218E54, sht 1 of 2, Revision 3 1218E54, sht 2 of 2, Revision 3 1080211, Revision 8 Q-6214-TGX, sht 10, Revision 6 Q-6214-TGX, sht 11, Revision 5 Q-6214-TGX, sht 12, Revision 5 Q-6214-TGX, sht 13, Revision 5 Q-6214-TGX, sht 14, Revision 5 No violations or deviations were identifie c. Reactor Coolant Pressure Boundary Piping Records Review Receipt Inspection and Material Certification The NRC inspector reviewed 11 data packages and 5 receiving inspection reports pertaining to the reactor coolant loop piping and accessorie Records reviewed confirms that required material characteristics, non-destructive tests, and other specification requirements were me Installation Records The NRC inspector selected all inspection records generated for Unit 1, loop 4 RC piping and 4 weld packages from Unit 2, loops 1 and 3. Only one weld package for Unit 2 was available for review. The other packages were in process or final revie There were approximately 8 field welds related to RC loop Unit 1, loop 4. The NRC inspector reviewed 6 of the weld packages. The two welds which were not reviewed, FW 30 and FW 31. FW 30 was still in process and FW 31 had an NCR #FP00082 against it. The remaining records reviewed indicated that the selected components were installed as specified, and that the required inspections were performe The NRC inspector also reviewed the implementation of Bechtel phase "A" program pertaining to the RC loop. This program was initiated by Bechtel to identify all deficient and open items by Brown & Root, lhe deficient or outstanding open items were listed on a phase "A" punch list. The NRC inspector reviewed the remaining field weld packages for incomplete or outstanding open items left by Brown &

Root to determine if Bechtel's phase "A" punch list identified these open items and addressed each. It was determined by the NRC inspector that each outstanding open item was addressed on the Bechtel's phase "A" punch list.

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The records adequately documented the current status of nonconformance report The records were ledgible but were not entirely easily retrievable. Overall the records are being properly stored and identifie No violations or deviations were identified.

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Documents Reviewed Data Packages # Recieving Inspection Records

. 0005 REC #2455

. 0587 RIR #2464

. 0609 RIR #5527

. 0642 RIR #1027

. 1043 RIR #2391

. 0007

. 1320

. 0015

. 0017

. 0018 i . 0016

! RC Loop 4 (Unit 1) RC Loop 1 & 3 (Unit 2)

, . FW 25, 26, 27, 28 . FW 0018 l & 29 . FW 0017 (in process)

! . FW 0003 (in process)

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. NCR 6018 . FW 0004 (in process)

. NCR 3628

. NCR 3604

. NCR 3695

. NCR 0209 7. Exit Interview l The NRC inspector met with licensee representatives (denoted in paragraph 1) on November 26, 1985, and summarized the scope and findings of the inspectio L l