ML20150F103

Notice of Violation from Insp on 790221-23

ML20150F103
Person / Time
Site:	South Texas
Issue date:	03/13/1979
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20150F101	List: ML20150F098 ML20150F103 ML20150F106
References
50-498-79-03, 50-498-79-3, 50-499-79-03, 50-499-79-3, NUDOCS 7905010379
Download: ML20150F103 (1)

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, 50-498/79-03 50-499/79-03

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l Appendix A NOTICE OF VIOLATION i Based on the results of the NRC inspection conducted on February 21-23, i; 1979, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Construction Pemits c No. CPPR-128 and 129 as indicated below:

1 Failure to Follow Procedures for Storage of Material -

- 10 CFR Part 50, Appendix B, Criterion V requires that activities

- affecting quality shall be accomplished in accordance with e

ins'tructions, procedures, or drawings.

Brown and Root Procedure CCP-3, "Prepour Activities," and

e Westinghouse Manual, "NSSS Component Receiving and Storage Criteria," require that

1. Stainless steel material must not be in contact with carbon steel.

2. All materials will be stored elevated off the ground.

Contrary to the above

l' During inspection of storage areas on February 21, 1979, the IE

- inspector observed:

1. A carbon steel band securing a 29" ID pipe assembly (identified

'i as loop 3 RV/SG, SN13945) to its shipping skid was in contact

'j with the stainlesr, steel pipe.

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Reinforcing steel stored in a laydown area near the Unit 1 2.

Reactor Containment Building was in contact with the ground.

This is an infraction.

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. t 384 Inspection Sumary_: .

50-498/79-03; 50-499/79-03) s 21-23,'1979 (Report No.

t Inspection on FebruaryRoutine, unannounced inspection of construction activities Areas Inspected:

i. including observation of storage and maintenance of materials for Unit h and 2; review of a reported 50.55(e) item; and review of previous ins

) findings.

The inspection involved sixty-three inspector-hours by three NRC .

s l inspectors.Of the three areas inspected, one apparent item of noncompliance Results:

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' wasidentifiedinonearea(infraction-failuretofollowproceduresfor -

storage of material - paragraph 3).

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. 1 DETAILS 335

1. Persons Contacted

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[ Principal Licensee Employees

• T. R. Alford, Site Manager

• T. D. Stanley, Project QA Supervisor

• L. D. Wilson, Site QA Supervisor -

- *D. G. Long, Lead Engineer

• T. J. Jordan, Lead Engineer

• M. H. Smith, Plant QA Supervisor S. R. Smith, QA Specialist C. L. Grosso, Associate Engineer M. M. Johnson, Senior Engineer

• M. S. Monteith, QA Technician

• *W. Moya, Construction Engineer Other Personnel

• J. R. Monroe, Construction Project Manager, Brown & Root (B&R)

• G. T. Warnick, Site QA Manager, B&R

- *D. B. Shumway, QC Supervisor, B&R l

B. D. Pointer, Engineering Concrete Technologist, B&R l

G. R. Murphy, Assistant Project Engineer, B&R J. Hamilton, Preventive Maintenance Supervisor, B&R L. Torres, Area Electrical Engineer, B&R F. Mancuso. Electrical Technician, B&R W. Leslie, Site Representative. Westinghouse The IE inspector also interviewed other licensee and contractor employees including members of the QA/QC and engineering '

staffs.

• denotes those attending the exit interview.

2. Licensee Action on Previous Inspection Findings (0 pen) Infraction (50-498/78-16-2; 50-499/78-16-2): Failure to Provide Acceptance Criteria for Megger Testing of Class IE Motors.

Procedure A040KPECP-2, Rev. O, January 8,1979, "Meggering," pro-vides the required acceptance criteria for the meggering of Class IE equipment. This item will remain open pending review of recur-rence control documentation for actions specified in HL&P response letter of February 14, 1979.

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. Failure to (0 pen) Infraction (50-498/78-16-3; 50-499/78-16-3): )

. Follow Approved Procedures for QC Surveillance Procedure A040KPMCP-3, of Maintenance Rev. 4, November 21, on)

Class IE Equipment. .

! 1978, " Handling, Storage, Installation and Maintenance of Pema-nent Nuclear Equipment," now more specifically defines A the re-

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I quirements for QC surveillance of maintenance during storage.

review of the maintenance records for Class IE equipment is bei

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. This item will remain open pending review of t documentation for actions specified in HL&P response letter of February 14, 1979.

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Reporting of n

(Closed) Deviation (50-498/78-17-A; 50-499/78-17-A):

i Cadwelder Qualification Inspection and Test Results by Level I i

Inspector.

The IE inspector was informed that Cadwelder qualifi-

v. cation inspection and test The IE results inspector werefile reviewed reviewed No. A820QR and corrected a

! of January 19, 1979.

E which contained Cadwelder Qualification Reports The IE and observed R

the reports had been signed by Level thatII QC inspe If i

'E . stated that all lead inspectors are responsible to assure

,f QA records documenting inspection and/or test results are ev ated and reported by Level II personnel.

[ resolved.

( In-place (0 pen) Unresolved Item (50-498/78-18; 50-499/78-18):Th Storage of Equipment.

enclosure had been erected around the two Charging Pumps and y Positive Displacement Pump located in the Unit 1 Mechanica y

F Electrical Auxiliary building. dry and appeared to afford ad af equipment, M: 14, 1979,

i. The IE inspector reviewed a B&R memo, dated February 4 which stated that construction engineering personnel were re r

and correcting all safety related WMC/ERC l

c as well as "accep'ed as uncorrected"Task force cards. activities lf7 efforts are expecte: to be completed by March 28,1979. The

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memo also stated that a procedure delineating safety related w

house and in-place maintenance(seeparagraph4.afor requirements is being pre

,' is expected to be issued in April 1979.

related findings) l-

• This item will remain open pending completion of actions d

f. in the B&R memo of February 14,1979.

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3. Site Tour The IE inspectors walked through various areas

! keeping and equipment storage.

During the tour through the Level D laydown storage area, the I inspector observed that a carbon steel band securing a 29" ID assembly (identified as loop 3 RV/SG, RustSN13945) stains from the to its shipp was in contact with the stai.nless steel pipe.This is contrary to the requirem "

band were observed on the pipe.

of Westinghouse Manual ~, "NSSS Component Receiving ih which states that stainless steel material must no

- carbon steel.

During the tour in the vicinity of the Unit 1 Reactor Containme I

!;. Building, the IE inspector observed several instances where re

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forcing steel in'a laydown area was in contact with the earth a

.l i one instance where vehicle traffic hadThis caused displacement is contrary to o which partially covered the reinforcing steel. Proced be stored elevated off the ground.

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. The IE inspector informed the licensee that the above items are co sidered to be two examples of an item of noncompliance with th

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requirements of Criterion V of Appendix B to 10 CFR 50.

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4. Electrical Components and Systems _

] a. Review of procedures and Records _

The IE inspector reviewed the following procedures and re 6 pertaining to the receiving and storage of Class IE cab

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electrical equipment:

21,1978, " Handling, Storage, A040KPMCP-3, Rev. 4. NovemberInstallation and M o Equipment" A040KPECP-2, Rev. O, January 8,1979, "Meggering"

, 35-1197-4046, 35-1197-4067 and l

Purchase Orders (P.O.) No.

35-1197-4058 701, 701 A, 336, ReceivingInspectionReports(RIR)No.336A,11 947,1940,1941 and Nonconfonnance Reports (NCR) No. SG SE 1137 l

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388 Maintenance Records (WMC and ERC) for motors 2R171NPA101A and B, 2R161NPA101C and THXCIAPCS-02 i All of.the above procedures and records were found to conform

, I, with the requirements of 10 CFR 50, Appendix B and ANSI 45.2.2 5 with the exception of the maintenance records. The IE inspector identified several areas where the maintenance being performed

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,g did not agree with the manufacturer's recomendation as required by MCP-3, paragraph 3.1.2.2. The IE inspector was informed by 1, the licensee representative that these discrepancies had previ-l ously been recognized by them and this matter was an unresolved

.; item documented in NRC Inspection Report 78-18. The IE inspector reviewed B&R memo ST-BC-HS-02346, dated February 14, 1979, j " Storage and Maintenance of Equipment." B&R now has a complete review of all maintenance and storage requirements for all equipment in progress. This review is to be completed and all

,i corrective action implemented by April 30, 1979.

This item of concern wi11 be considered as a part of the unre-Jl solved item relating to storage of pennanent plant equipment documented in NRC Inspection Report 78-18.

b. Storage of Class IE Equipment j., The IE inspector inspected areas of electrical equipment storage j'

in the warehouse, laydown yard and in place. The cable tray and cable storage areas and warehouse storage areas were clean and all material inspected was properly identified and separated j,. as required. The Residual Heat Removal (RHR) pump Motors were O found to be wet. 'The IE inspector was infonned that NCR SE 1137 h had been written against these motors on February 13, 1979. The disposition of the NCR was still being reviewed by B&R engineering.

! RHR motors B and C are out of tolerance on megger reading due to i the moisture. The licensee infonned the IE inspector that the

- dispostion of the NCR would include both maintenance required to dry out the motor insulation and preventative measures to keep the motors dry in the future. This is also included in the review of storage and maintenance being conducted by B&R per B&R memo ST-BC-HS-02346, dated February 14, 1979. .

No items of noncompliance or deviations were identified.

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0 389 5.

Review of Items Reported Under 50.55(_eL)

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The IE inspector reviewed the status of act 20, 1978.

g (RC8) shell initially reported to the NRC on October ij

• Brown and Root has issued Technical Referenc '

C. Bldg.1 Shell Lift 15. Investigation andR 2C801CQ002-E, "R.

l investigation and repair of the void areas.

l' sounding, and visual examination of holes using i f fiber optics w ;

the primary methods used to determine the extent a unacceptable areas.

grout into the voids through holes drilled in the polar craneTh brackets and the containment liner.

le i? - Mastcrflow 814 cable grout with a 28-day s

?l being made for grouting *

>i she IE inspector observed preparations including injection of water 0 and into 1850 and flushing of voids in the 7 orientations. A work i 'i areas of crane brackets at 170

?n I platform was erected on the top of the da RC8 wall a location.

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an injection pump, an ice water batcher, a supply of ic supply of grout. Work platfonns at the bracket areas

! .i approximately ten personnel.provided access to the are

,- and grout injections.

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! .. No items of noncompliance or deviations were identified.

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Review of NSSS Storage Procedures _

i. 6.

The IE inspector reviewed the shipping, handling During this and stora b dures as prepared by Westinghouse for NSSS equipment.

inspection, procedures were reviewed for the f these reactor ve The d.

maintenance records for the required peri Section 2-5 of the manual iil "NSSS

.. components were also inspected. ld Component Receiving and Storage Criteria," states tha dimensional inspection of the lower reactor vessel intern be perfonned at the beginningIf there of the hor followed

. to have been performed in accordance with ld be the same pro

• by another inspection efter two more months of storage.

h Westinghouse were no dimensional changes, the inspection frequency cou j

extended to a longer period with the concurrence of t e

' Site Manager and the cognizant Core Support engineer.

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ji 1 During this inspection, it was detemined that the equip -

on April 14, 1978. The first follow-up inspection occurred on June 7,1978, or after an interval of almost two months.. Subsequent i inspections were performed on August 31, 1978, and December 10, 197

with the next inspection scheduled to be on March 10, 1978. The p Westinghouse Site Manager'was unaware of this extended inspectionAfter c

interval and had not concurred with the extension.

i informed of this inconsistency in inspection dates and noting'that

'i there were no significant changes in the dimensions, the Westinghouse r g: Site Manager verbally acknowledged that he would issue to HL&P a letter waiving the requirement' for the one month reinspection as

, ;', allowed by Section 2-5.

Since no damage to the equipment was experienced and the subsequent I inspections have been performed as stated, this will be considered .

as an unresolved item pending issuance of the above waiver.

i During this review of the "NSSS Component Receiving and Storage

.,. Criteria" manual, the IE inspector noted that Section 3.3 for the reactor vessel, including head and closure hardware, contained Under thecri-

'? teria only for short-term storage (less than six months).

7 heading for long-term storage (greater than six months), it is stated that, "At the present time these procedures are being developed.

' G( l Supplemental sheets will be issued covering receipt and periodic in-

' :- spection requirements." This equipment was received on site July 6,

.;.' 1978, and has been maintained in accordance withthe theequipment short-term Since willstorage instructions for the succeeding seven months.

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remain in storage for an estimated three additional months, long-tem g' storage requirements should be defined or the acce the vendor.

This item will be considered unresolved pending review

,E of long-tem storage requirements.

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'i 7. Unresolved Items o

I Unresolved items are matters about which more information is required i

in order to ascertain whether they are acceptable items, itens of Two unresolved items disclosed during noncompliance, or deviations.

' the inspection are discussed in paragraph 6. .

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8. Exit Interview The IE inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 23, 1979. The IE inspectors sumarized the purpose and the scope of the inspection and the findings. A licensee representative

acknowledged the statements of the IE inspectors concerning the item of noncompliance and the unresolved items.

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