IR 05000498/1986012

Insp Repts 50-498/86-12 & 50-499/86-12 on 860414-18.Const Appraisal Team (Cat) Potential Enforcement Actions (Peas) 1,2,3,5 & 6 Reaffirmed W/Mods & Cat PEAs 4 & 7 Withdrawn

ML20206N284
Person / Time
Site:	South Texas
Issue date:	07/15/1986
From:	Bess J, Constable G, Garrison D, Clay Johnson, Renee Taylor, Tomlinson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206N272	List: IR 05000498/1986012 ML20206N266
References
50-498-86-12, 50-499-86-12, NUDOCS 8608260206
Download: ML20206N284 (19)

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APPENDIX U.S. NUCLEAR R.EGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/86-12 Construction Permits: CPPR-128 50-499/86-12 CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company P. O. Box 1/00 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection At: Matagorda County, Texas Inspection Conducted: April 14-18, 1986

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Inspectors: / / f4u!M/ / f7 E R.' G.~ Taylpr~, Reactor Inspector (Team Leader) Ohte/ ~

Project Section C, Reactor Projects Branch

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E.' Bess ~, Reactor Inspector, Engineering d

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7 b Section, Reactor Safety Branch l ff/ /17lFA

.' LY Garfi~ son, Resident Inspector, Project ITatf ~ '

Sectiorf C, Reactor Projects Branch

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W C. E' Johr on, Senior Resident Inspector Sf7b ()hty Project Section C, Reactor Projects Branch 8608260206 860820

{DR ADOCK 05000498 PDR

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2-M 75TX 1/D.' P.' Toml/ns6n, Reactor Inspector Odte/ ~

Engineefing Section, Reactor Safety Branch Approved: .

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0 6 . C4nstaoie, Chief, Project Section C

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Reactor Projects Branch Inspection Summary Inspection Conducted April 14-18, 1986 (Report 50-498/86-12; 50-499/86-12)

Areas Inspected: Special, announced inspection consisting of a followup to the Construction Appraisal Team Potential Enforcement Actions (CAT-PEAS), the licensee response to the CAT PEAS dated April 2,1986, and the findings contained in NRC Inspection Report 50-498/85-24; 50-499/85-2 Results: CAT PEAS 4 and 7 are withdraw CAT PEAS 1, 2, 3, 5, and 6 were generally reaffirmed with certain modification '

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DETAILS This report relates to the findings of a special Region IV inspection conducted

.during the. period of April 14-18, 1986, for the purpose of evaluating the licensee's response to the. Construction Appraisal Team (CAT) inspection-conducted dt. ring the period of October 21 through November 22, 1985. The licensee'.s response to the CAT report was dated April 2,1986, and received by Region IV on April _7, 1986. The Region IV team was tasked to: (1) review those-items where the licensee requested a reconsideration of the CAT" findings, (2) examine those areas where the licensee provided additional information which' appeared to change the CAT findings without specifically requesting a full reconsideration, and (3) evaluate the initial ~ corrective > actions,for'those~

items for which the licensee provided additional information that" supported the CAT finding ..

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Background  ; _

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,~ n At the CAT exit meeting neld on November 22,1985,"HL&P's Senior Manag' ement' on" -

hearing the preliminary CAT findings comitted to take whatever actions were, necessary to fully identify and correct the underlying. problems identified by -

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the CAT tea ,

On January 10, 1986, HL&PinalettertotheRsgionalAdmbistrator,NRC Region IV, described their initial assessment of the problem areas and their planned corrective actions. These corrective actions _ included: Significantly increasing HL&P management presence on site, Stream lining the contractor organizations, 3. _ Adding and/or replacing key project personnel, Increasing the training of craftsmen and quality control inspectors, and

- Establishing a better system for holding craft supervision responsible for quality as well as quantity of work complete These corrective actions were discussed further on March 27, 1986, et an enforcement conference in NRC Region IV (meeting summary and list of attendees attached). A specific detailed response by HL&P to the CAT findings was submitted to the Regional Administrator NRC Region IV on April 2, 1986. The thoroughness of these corrective actions will be further assessed during followup inspections; however, HL&Ps overall response to the CAT findings can be characterized as prompt and extensive, involving direct senior management attention and a major commitment of resources. The following has been organized

to parallel the CAT report, Appendix B, Potential Enforcement Findings. In some instances, the licensee in his response has addressed specific sentences of the CAT findings. Where this has occurred, reference to the licensee response paragraph will be noted by (XXX) following the PEA identifie . .

i 4 Potential Enforcement Action 1 PEA 1.a (1.a): The licensee has responded to each of the comma-separated

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portions of the findings contained in the CAT report. In the first portion of the sentence, the CAT indicated they found that the licensee could not provide a design baseline wiring drawing for the NSSS supplied motor operated valve The licensee in their response dated April 2,1986, indicated that only two of the valves supplied as replacement unitt for Unit 2 caused any real confusio The licensee stated during discussions with the NRC inspector that he had determined from vendor /NSSS documentation received with the valves that the operator vendor (Limitorque) had incorporated an NSSS design change into the operators that had not at the time of the CAT inspection been incorporated into the_ Westinghouse drawings. In all other cases the licensee had been able to identify the NSSS design baseline for the valve operators, albeit with considerable expenditure of time. The NRC inspector reviewed data in this area and verified that the licensee's claim appeared to be factua PEA 1.a (1.b): The second portion of the CAT statement indicated that the AE had made design changes that were not provided to the NSSS vendor for review and incorporation into their drawings. The licensee responded that the AE drawings are the controlling drawings for construction and~further that these drawings are not different than the NSSS drawings in any functional aspec Since this was the case, the licensee did not see the need to provide Westinghouse with drawings or for Westinghouse to incorporate the' AE ~ changes

. into their drawings. The NRC inspector discussed the response with AE representatives and reviewed a number of elementary wiring diagramscgenerated i

by Westinghouse and the AE for the same valves. It was shown that the Westinghouse drawing convention placed all of the various operator switches, interconnecting terminal boards, and motor terminals within a dashed line box on the drawing. The AE convention used a series chain drawing convention where the various operator devices are placed in the chains in their logical electrical position whereas the Westinghouse convention places them in the physical location position. In each of the parallel drawings reviewed, the device numbers of the Westinghouse drawing were utilized in exactly the same functional manner in the AE drawings. The NRC inspector questioned how Westinghouse could generate an engineering change to-their supplied valves without knowledge of the AE convention since the point-to-point wiring may be changed within the two conventions. The AE representatives stated that each NSSS change is received by the AE, converted into the AE convention. The change is then issued to the field as a Configuration Control Package containing specific work instructions such as remove or add jumpers supplemented with terminal identification data by which the field will make the changes. The NRC inspector concluded that since the AE had made no functional change in the way a valve operator should perform, the licensee position was acceptabl PEA 1.a (1.c): The third portion of the CAT statement was that the licensee Wds unable to correlate the actual wiring in valve operators with design documents. The licensee's response indicated the CAT observation resulted from

- errors made by an AE engineer in generating a Configuration Control Packag Discussions with the AE representatives indicated the specific package was . __ _ -. _ _ _ _ _ _ . ___ ._ _ _ __ __

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CCP-0243 which is partially borne out by page II-20 of the CAT report. Review

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of- the package revealed that the originating engineer had overlooked a note on the only drawing (a generic type) referenced in the package that clearly stated that the wiring depicted on the drawing did not necessarily show the actual wiring in specific valve operators and instructed that the user should refer to

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specific drawings for each valve. Review of the CCP referenced generic drawing versus the specific valve drawing indicated that the generic drawing had

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originally covered all of the valves in the NSSS scope of supply and indicated what is known as a " limit controlled open" and " torque controlled close" operation. Review of selected specific drawings however indicated that some valves had been changed by Westinghouse and included in the Bechtel control drawings to limit controlled open/ limit controlled closed. Westinghouse had reworked a group of valves at nearly every Westinghouse reactor site because of a Part 21 report that certain valves in high pressure systems would not close under torque control and that Westinghouse had sent teams to the sites to make the change which basically involved installation and removal of jumper wiring in the valve operators. This occurred in late 1981 or early 1982. In essence, when the engineer originating CCP-0243 overlooked the note, he was requiring that wiring be changed that had already been changed 4 to 5 years ago. Such an error (no valve specific drawings used to develope instructions in the CCP)

should not have been overlooked in an effective design review. The AE representative was in agreement with this vie Conclusion (PEA 1.a)

Based on the new information received and reviewed, the NRC staff has concluded that PEA 1.a does not represent a breakdown in the interface communications between the NSSS vendor and the AE. The failure of the design review process appears to be an example of a failure to meet the design review requirements of Criterion III of Appendix PEA 1.b: Based upon the licensee's response and the followup inspection by the NRC staff, it appears that all necessary information was communicated to the AE but was subsequently overlooked in the generation of fabrication instructions which take the form of isometric drawings. The licensee stated that design reviews had been performed but that the vendor requirements were overlooke The NRC staff does not now consider this finding to be an interface issue as originally thought but rather a failure to properly consider appropriate design input data in the design review proces _

The NRC inspector also evaluated the relative importance of the -failure of the design review pro _ cess in regard to operational safety. The annubar sensing elements are installed in the essential cooling water system and are described . -

in FSAR 7.B as Category II (type D) instruments,.these instruments are safety-related; however, they provide no safety' related signals that activate

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any of the Engineered Safety Features of the facility that are needed-to 4 respond to a design basis accident nor are there any technical specification operability requirements for these instruments. The principal aspect of the annubar element installation that is considered safety-related is the .

maintenance of the pressure boundary integrity of the systen into which each is installed. Upon inquiry, the annubar vendor has stated to the licensee that

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much larger tolerances than originally specified only have the effect of changing the accuracy of the instrument in terms of measuring liquid flow rate in the system in which it is installed. The manufacturer has established the maximum bounds of the deviation from his recommended installation tolerances and the licensee has stated in his response that he has corrected several instrument installations to conform to the new boundary. The overall change in accuracy is from 1 percent measurement accuracy to a 3 percent accuracy which is deemed acceptable for the application of the device Conclusion (PEA 1.b)

The NRC inspector has found that the CAT finding is technically valid, however, the contributing cause appears to be a failure on the part of the AE to properly consider available design input information by either the original design engineer or the design reviewer and was not a failure in the interface ccmmunication between the vendor and the AE. This item then is an example of a failure to meet the Criterion III requirement relative to design control measure rather than requirements pertaining to interface controls. The specific issue has low safety significance because the sensing function of the flow element, while providing useful information to the plant operators, are not required for safe shutdown of the reacto Potential Enforcement Action 2 PEA 2.a: The Construction Appraisal Team stated "that the licensee could not provide calculations or documented engineering judgement to substantiate the design adequacy of the addition of four bays structural steel detailed on the November 5,1984, revision of Bechtel drawing No. 3M01-0-S-4043."

The licensee's response indicated that calculations were performed by B&R and accepted by Bechtel for the four bays of structural steel shown on the November 5,1984, revision of Bechtel drawing No. 3M01-9-S-4043. The licensee also stated that other modifications introduced by Revision 1 of the drawing were minor and accepted by evaluation based on a review of the original B&R calculations. This evaluation was documented by the engineer's signature on the drawing revision. Review by the NRC inspector indicated that B&R calculations were available and that Bechtel had reviewed and accepted these calculations for the four bays in concern. These calculations were not easily retrievable at the time of the CAT inspection. Minor changes had been mad Discussion with Bechtel engineering and review of design drawings indicated to the NRC inspector that the existing B&R calculations were used in the engineering evaluation to justify the minor changes. Review of Engineering Design Procedure 4.46, Revision 8, indicates that an engineer's signature on the drawing documents his review and approval of an engineering check for conformance of drawings to design calculation Conclusion (PEA 2.a)

The licensee's response was substantiated by the NRC inspector, therefore, PEA 2.a. is withdraw .

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PEA 2.b: The Construction Appraisal Team stated in PEA 2.b. that "six field change requests (Nos. BC-01202, CC-03426, CC-04949, CC-04461, BS-1-0194, and BS-1-0235) and one drawing change notice (No. 7) were modified upon incorporation into the design drawings without being adequately reviewed, approved, and documented to reflect changes in technical content or scope."

The NRC inspector reviewed the issues identified by CAT and the response submitted by the licensee for each field change request noted in the NO Examination of FCR BC-01202, FCR CC-04949, and FCN BC-1-0235 substantiated the CAT findings. However, it must be noted that FCN BS-1-0235 is the only field change that indicates an example of a modification upon incorporation into the design drawings without being adequately reviewed. FCR CC-04949 and FCN BS-1-0235 were drafting errors which were minor and appear to be isolated cases. These three field change requests are considered a failure to follow procedur Examination of FCR CC-03426, DCN No. 7, and FCR CC-04461 revealed that these field changes were not modified upon incorporation into the design drawings without being adequately reviewed and approved. These FCR's were generated against a Category "9" drawing which designates applicability to both Units 1 and 2. These FCR's are then reviewed at incorporation by Engineering for applicability of change to Unit No. 2. This is somewhat of a standard engineering design practice even though there are advantages and some disadvantages. However, this violates no regulatory requirement. Therefore, these field change notices do not constitute a violation. Examination of FCN BS-1-0194 indicated that this FCN was a clarification problem and does not constitute a violation of HRC requirement Conclusion (PEA 2.b)

Three of six examples did not involve violations of regulatory requirement The three remaining examples involved minor errors, two of which are failure to follow drafting procedure Potentiol-Enforcement Action 3 PEA 3.b (1.b undersized Welds): The NRC CAT inspectors identified several deficiencies in vendor supplied components including undersized fillet welds in tanks and heat exchangers. These undersized welds have been verified by the licensee and documented on Nonconformance Reports (NCR) for individual dispositio ;- e In May 1985, the licensee acknowledged receipt of NRC Infortnation Notice (IN) 85-33 in which several vendors were identified as having supplied components with undersized fillet welds to other construction, sites. _ HL&P licensing fon<arded this IN to HL&P engineering for an evaluation ~ of ~

applicabilit Engineering, after determining that the IN was, applicable, recomended that a reinspection program be instituted for components -received from the named vendors and the suppliers of similar equipment. Although the cognizant engineering and inspection personnel were made aware of this IN, no specific reinspection activities were initiated pending the issuance of

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documentation stating the scope of inspection. HL&P engineering has stated that other matters were determined to be more in need of immediate attention and that the actions required by IN 85-33 could be accomplished at a later dat Because of the CAT inspectors findings IN 85-33 was given higher priority and construction inspection plan (CIP) 2.2-66 was immediately generate CIP 2.2-66 required the reinspection of all pressure retaining nozzle fillet welds on tanks and/or heat exchangers supplied by five specific vendors as well as a sample inspection of tanks and/or heat exchangers supplied by all other site suppliers. This inspection was approximately 2/3 complete with a total of 473 welds having been inspected. Of this total, 249 welds were found to be acceptable and 224 have been rejected and documented on NCR's for individual evaluation and dispositio It is noted that the reinspection program associated with IN 85-33 had not been implemented at the time of the CAT inspection, it was, however, in the planning stages and was scheduled to be accomplished at a later dat Conclusion (PEA 3.b-1.b Undersized Weld)

Based upon the NRC inspectors evaluation of the above information this item remains a violation since the components had been inspected, accepted and installed and if it had not been for IN' 85-33, would have remained so without any further evaluatio PEA 3.b (1.b-Radiographs)

The NRC CAT inspectors identified several deficiencies in radiographs for vendor supplied components. The deficiencies included radiographs which did not have the required weld and film quality. The CAT inspection included the examination of more than 4000 radiographs with three types of deficiencies-noted. As each of the three examples involved a different condition, each condition was evaluated and is addressed here separatel Example No. 1: Linear indications were found in the backing ring welds in the demineralizer tank (SN 37740) and cation bed demineralizer (SN 37430). The Westinghouse fabrication drawings for these vessels contained standard welding symbols for the internal backing ring ends to be joined with full penetration welds. This was assumed from the absence of a weld dimension' adjacent to the butt weld symbol for the backing ring joints. It was agreed by the CAT inspectors and the licensee liaison representative that the linear indications on the radiographs were the result of partial penetration welds in the backing rings and were not indicative of defects in the pressure retaining vessel weld ,

Both backing ring welds were documented on separate NCR's and forwarded to Westinghouse for evaluation and disposition. Westinghouse engineers determined, by a review of the ASME Code,Section III, Subsection 1ND, that a

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full penetration weld cf the backing ring ends is not required and that it is not a requirement that this weld be radiographed. The NRC inspector reviewed

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the subject radiographs and noted that the end gaps of the backing rings appeared to be less than 1/32" and was therefore not able to mask any rejectable indications in these areas. The NRC inspector also noted that in both cases the end gap indications caused by the partial penetration welds became very faint in the areas of the vessel weld roots. This is indicative of root pass penetration into the backing ring thereby reducing the unwelded cross section of the backing ring join It must be noted, however that the backing rings and their partial penetration welds serve no structural function. The backing ring is used to allow the vessel shell-to-head full penetration weld to be made entirely from the outside of the vessel. Westinghouse engineering has evaluated both cases and has recommended a "use-as-is" disposition for both NCR AN-03028 and NCR AN-03029 which focument these conditions. Since the governing Code requires evaluation 01 all linear indications, which was not done for two of four backing ring welds involved, the deficiency noted by CAT was valid. It appears however that this finding was an isolated case involving no safety issue and the licensee's actions are considered appropriate to the circumstance Example No. 2: Yellowing film was found in the record packages for a 16" surge line, the pressure relief tank, and the volume control tank. The licensee liaison representative initiated standard deficiency report (SDR) H-192 to cause Westinghouse engineering to evaluate and provide disposition for eac A licensee and NRC review of the data package for the 16" surge ~ line revealed that a design change had deleted this section of pipe and that retention of the film was unnecessary. This is not a violatio A licensee and NRC review of the data package for. the. pressure relief tank revealed that this vessel was constructed by Richmond Engineering Company (RECO) for Westinghouse in accordance with the ASME Code,Section VII This is a nonsafety-related tank according to Table 3.2 of the FSAR and thus not within the purview of Appendix B. The licensee's response statement for this item was, however, found to be in error. The response stated that an independent Level III had reviewed this film and found that although there was

" slight discoloration" the film was still within site quality requirements. A subsequent review by the licensee liaison representative and the NRC inspector found that the film cited by the CAT inspectors was badly discolored and considered by both individuals to be beyond interpretation, it was deduced that the data package number was in error when the earlier retrieval was made and that the independent level III was presented the wrong film for revie Although this is not a safety-related item, as stated above, the licensee has verbally agreed to have this weld re-radiographed and the acceptable quality film filed in the record packag A licensee representative and the NRC inspector reviewed the data package for the volume control tank and found that one radiograph in a weld package did exhibit yellowing. The licensee response to this item stated that an independent level III reviewed the record package for this weld and determined that, although one radiograph was yellowed, sufficient coverage was provided by the adjacent overlapping radiographs to assure acceptable weld quality. The NRC inspector was easily able to overlap three radiographs by properly

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orienting the lead station marker images in such a manner that full coverage of the area of interest was achieved without the use of the yellowed' film. Sin::e adequate coverage was proven, this is not a violatio The NRC inspector noted from the original film interpretation sheets that all the above radiographs were produced in 197 Small holes were evident on opposite ends of each of the affected radiographs indicating that these were manually processed rather than developed by a machine. The nature of the stains and discoloration is characteristic of those resulting from an improper water-wash following the developing and fix baths. The actual color change in the film emulsion is a very slow transition and probably occurred years after the exposures were made, developed, interpreted, and filed. Because there were only three instances of discoloration noted during the examination of more than 4000 radiographs these are considered to be isolated incidents and are not indicative of a records deterioration trend. Based upon the NRC inspectors evaluation of the above information and his review of the radiographs, this

. matter has no safety significance and the licensee's action appears to be appropriat Example No. 3: The NRC CAT inspectors, during a review of vendor supplied radiographs, noted that the attendant records for one fabricated cylinder indicated that retake shots were required for certain areas. No retake shots could be located. The film and records for a second cylinder revealed a linear indication for which no explanation or repair radiographs could be locate A further search by the licensee of vendor records revealed that the two cylinders in question were manufactured for use as piping spool pieces to be field-fabricated in accordance with ANSI Standard B31.1. Radiography was performed on the longitudinal seams of these cylinders and the film fonvarded to the licensee for "information only" as ANSI B31.1 does not require that these welds be radiographed. The NRC inspector and the licensee NDE Level III reexamined the radiograph exhibiting the linear indication and agreed that this -

indication was produced by a minor surface anomaly that would not be detrimental to the integrity of the longitudinal seam weld. Correspondence from the manufacturer, Southwest Fabricating and Welding Company, states that these two cylinders were used to produce piping spools used in the condensate polishing demineralizer system. The STP FSAR states'that this is an ANSI B3 system and is classified as nuclear nonsafety (NNS) and therefore not within the scope of Appendix Conclusion 3.b (1.b-Radiographs)

This, portion of PEA 3.b is withdrawn since two of the three examples discussed pertained to non-safety related components not within the purview of Appendix B and the third example was found to be isolated and having-no effect ,

on safet PEA 3.b (1.b-Miscellaneous) Page II-17 of the CAT report stated, in part, that Bechtel specification 3E159E30012 required each tenninal block to have no less than 12 points. Contrary to this requirement, several cubicles of the 4160 KV switchgear contained less than 12 point terminals as specifie , . ,

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The licensee stated that a Supplier Deviation Request (SDR)*had been written t,y the vendor and approved by engineering (in 1979) to allow the use of 8-point terminal blocks. The NRC inspector reviewed Brown & Root

.(SDR) dated January 31, 1979, which allowed the substitution of 8 point terminal blocks for 12 point terminal blocks. The licensee statement is substantiated. No violation was identifie . Page II-17 of the CAT report stated, in part, that Bechtel specification required terminal strips to be located a minimum of 8-inches away from cable entrances to allow for stripping and bending.of incoming cables. It was observed that several switchgear cubicles did not meet this requirement. The licensee stated that the requirement quoted above was required during the manufacture of the switchgear to assure adequate space for field routing of cables and to accommodate any future modification Following the receipt of the equipment, a configuration control package (CCP) 0M-M-EM-0038 was issued to utilize the empty space. The NRC inspector reviewed drawing 4121-01107 BGU which showed various modifications including the addition of terminal blocks to the switchgear cubicles after delivery. Therefore, the licensee statement is substantiated and no violation could be identifie . Page II-14 of the CAT report states, in part, that Bechtel ,

specification 3E319ES1040 requires motors under 250 horsepower (HP) rating to have vendor installed terminal lugs on the motor leads. The following fans motors were identified as not having terminal lugs on the motor leads: (1) FN 014, (2) FN 016, and (3) FN 002.-

The licensee stated that the fan motors were shipped with, but separated ,

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from the air handling units which were inspected but apparently the motors were not. The requirement for the vendor to install the lugs appears to be a commercial consideration rather than quality requirement since lugs would have had to be installed in order to connect the motor to a powe source. The licensee issued nonconfonnance reports (NCRs) BE-03334 and BE-03335 to install lugs on motor leads of the referenced fan motors. The referenced NCRs have been implemented. The matter has no safety significance but is considered to be a violation of NRC requirements since the QA program should have caused identification of the specificaticn nonconformanc . Page11-14oftheCATreportstates,inpart,thattheB$chtel specification requires motors undgr 250 horsepgwer (HP) rating to have an insulationratingofClassF(135C)orH(150C). The nameplate and vendor manual ~ for the reactor makeup water pump motor identifiedUas 3R271NPA101A indicated the motor insulation is only Class B (110 C). -

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Thelicenseestatedthatthemotorssuppliedunderk.O. 35-1197-4122/8122~

were certified to be in compliance with the. insulation required in the original specification; i.e., Class B; however, the vendor actually' as a ' -

practice supplies the higher grade. The vendor has confirmed that the correct insulation was supplied and the nameplates, equipment data sheets and equipment data sheets were being corrected to reflect the class:of insulation actually installed. TheNRCinspectorreviewedllettersfrom~th .

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Siemens-Allis, Inc., dated December 11, 1985, and the Hayward Tyler Pump Company confirming that the motors supplied to the South Texas Project, were built with approved Class F insulation. Nonconformance Report (NCR)

No. SE-03362 has been implemented to exchange the nameplates on the motors. Field change request FCR-BE-01100 has been implemented to correct the vendor documentation. The licensee's statements has been substantiated but remains a violation since the QA program did not cause identification of the deficienc ~

Conclusion (PEA 3.b-I.b-Miscellaneous)

Based on the evaluations above, that portion of PEA 3.b related to fan motor termination lugs and improper motor insulation class remain as violations Criterion VII of Appendix Potential Enforcement Action 4 During a review of radiography performed by component suppliers, the NRC CAT inspectors requested that the radiographs for three components be provided for examination. This could not be done as the licensee was unable to locate the radiographs onsite and could not readily determine whereJthey were being stored. The CAT inspectors were concerned because the licensee should have-available evidence that components supplied by vendors were of acceptable quality before installatio In some cases, HL&P had not been able to provide the requested information before the end of the four-week inspection. While there is no specific regulatory requirement that defines timeliness with regard to retrieval of information, it was felt that the needed information should have been more readily availabl Questions concerning this item arose when the CAT inspectors made a general request for radiographs produced by a specific vendor. Without a review of purchase orders it could not be determined if radiography was required or where the radiographs were being stored. In cases where the CAT inspectors requested the radiographs for a specific component or piece of hardware, it was determined from a review of component document packages if radiography was required and where the film was stored. If onsite, these were provided in a timely manner and if offsite were obtained as expediously as possibl The licensee response stated that the CAT inspectors requested the radiographs for three component cooling water (CCW) heat exchangers. It was later determined that these radiographs were being stored at the manufacturers facility as permitted by the ASME Code,Section III, paragraph NA 491 Following an extensive review of the purchase orders for these and similar components the licensee determined that, although there is no specific requirement, a listing of the retention responsibility and storage locations for all vendor supplied radiographs would be beneficial to the project. This tabulation is currently being prepared through a comprehensive review of purchase order Requests are being made of all vendors who are storing radiographic records that these records be forwarded to the licensee for permanent retention in a single location. The licensee feels that this will not only streamline the retrieval process but will eliminate the possibility of records loss as a result of some suppliers going out of busines .

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Conclusion (PEA 4)

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In the absence of a regulatory requirement this item is' withdrawn.. The CAT inspectors comments, however, are seen by the licensee as a system improvement ~

and will be fully implemented by August 31, 198 ~

Potential Enforcement Acticn 5 ,

The CAT findings in the area of traceability and control of fasteners can be sumarized as follows: Items of mechanical equipment where high-strength bolting (A-325, A-490 and A-193) was specified were found to have the incorrect type of bolting,

- or that low-strength bolting had been randomly substituted. QC; inspections at the vendor level and in the field failed to uniformly verify correct boltin ,

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assembly, frequently supplied marked and unmarked low-strength bolting even though the specifications required A-307 low-strength bolts which

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should be marked with the bolt manufacturer's identification. QC inspections at the vendor level and in the field also failed to detect this deviatio . Project specifications had allowed use of bolting identified in methods other than that required by A-307 for application in raceway installations. In some instances completely unidentified cadmium plate bolting was also used. The use of such bolting spread to installation activities where no such authorization existed without QC detectio The licensee has responded to these findings by stating that: They will verify by review of purchase orders and an appropriate field inspection that vendor supplied installed equipment has the correct fasteners installed as required by the purchase order. This effort will initially covered 10 percent of the equipment but has been expande . They have changed the specification for non-ASME bolting (which includes electrical equipment) to allow substitution of black zinc chromate coated low strength bolting wherever A-307 was previously required and that his installation / inspection procedure has been changed accordingly. The licensee contended that essentially any comercially available low strength bolting would meet the strength requirements of A-307 whether purchased to the requirement of A307 or not. This contention was based on inspection findings at other nuclear power facilities and tests performed to resolve the issue. The NRC inspectors at the inspection entrance interview questioned the commonality of supply of material to STP and that supplied to the other facilities. The licensee's contention, relative to the quality of his purchased low strength bolts, has been verified by a test of 60 bolts chosen at random to cover the full range of sizes and surface finishes used at STP. The tests were conducted at the

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Southwestern Laboratories and were in part observed by an NRC inspecto Review of the test data indicates that all of the samples exceeded the minimum tensile strength required by ASTM-307, and all met the chemical properties required. Statistical analysis has indicated a very low '

probability that any given bolt will not meet tne minimum requirements of ASTM-307 and the sample size provides a 95% confidence that the sample is representative of the population. Although of minimal safety consequence, the fact remains that at the time of the CAT inspection, the licensee had failed to implement his comitment to Criterion VIII of Appendix B in regard to non-ASME bolting. Since appropriate corrective action on this matter has been taken, no further response to this violation is require Conclusion (PEA 5): The licensee actions identified above should satisfactorily resolve the JAT findings when completed. The licensee, at the time of the CAT insp':ction was, however, in violation of NRC requirements. The Region IV inspectors determined that violation involving mechanical equipment was more appropriately classified as a violation of Appendix B, Criterion VII than Criterion VIII. The portion of the finding involving low strength bolting was considered to be a violation of Criterion VII Potential Enforcement Action 6 >

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The NRC CAT team stated, in part, (Section 11.B.4.b) that the licensee

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inspection program was ineffective in that numerous deficiencies were -

identified with the installation of QC accepted instrumentation and instrument tubin Conclusion (PEA 6.a) -

The NRC CAT team findings were substantiated. Violations to 10 CFR.50

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Appendix B and STP QAP Section 10.0 did exist at the time.of the CAT, team

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Even though the licensee stated that it was determined that'one inspector was

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involved in the inspections and acceptance of the tubed instrument installation identified in the CAT team report, the NRC inspector determined that serious weaknesses existed in procedures and training of personnel in this are However, the corrective actions and the results achieved by the licensee should preclude recurrence of deficiencies identified by the CAT tea Subitem CAT reported that 10 of 12 mechanical equipment items inspected were found not to conform to installation requirenient Reference to Table III-5 of the CAT report indicated each of deficient equipment items had from 1 to 6 specific deficiencies. The licensee in his response to the CAT report asked for reconsideration on 3 of the specific deficiencies. After review of the request

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I for reconsideration, the NRC inspector determined that reconsideration was appropriate for the three specific deficiencies; however, the remaining deficiencies continued to substantiate the overall CAT finding. - ; .-

PEA The NRC CAT team in part stated that the licensee's inspection program was ineffective in that strap bolts on 8 of the 28 conduit-runs. inspected did no exhibit the required torque seal. Reinspections for torque had not been accomplished following rework of QC accepted conduit installation ,

The licensee stated that although a reinspection for torque had not been completed following rework, the reinspections had not been performed because construction had not completed the reinspection documentation and presented it to QC for inspection. This progression of the documentation and inspections follows the established procedural requirements. The required torque seal or documentation existed on all but 2 bolts on the 28 conduit runs which consisted of approximately 430 bolts. Nonconformance Report (NCR) CE0-3213 was issued and implemented to have the 2 bolts for conduit AIXEZAR102 support No. 1613259 retorqued and seale Conclusion (PEA 6.g)

The licensee statement was substantiated. The deficiency is considered to be an isolated incident and the licensee's action appears appropriate to the circumstance Potential Notice of Violation 7, Radiography - Corrective Action The NRC CAT inspectors stated that the licensee's corrective actions were inadequate in that the balance of plant (B0P) suppliers of NDE radiographs and documentation were not included in the corrective actions taken after some radiographs for the reactor vessel head were discovered to be missing in May 198 The licensee's response stated the missing reactor vessel head film was located at the Westinghouse subvendor's facility. These were forwarded to the licensee and are presently filed in the site records center. As a result of this mislocation of film, a 100 percent review of all radiographs supplied to STP under NSSS contracts was performed. The licensee's response stated that action was initiated in May 1985. In July 1985, licensee consideration was given to expanding this review action to include the 80P suppliers. The licensee decided that there was insufficient evidence of a problem to warrant expansion of the review to include B0P suppliers. This decision was based on the fact that approximately 7000 radiographs had been reviewed and accounted for at the time and only minor random deficiencies were noted. As of March 1986, the status of approximately 80,000 radiographs has been accounted for by the licensee with a resultant deficiency rate of 0.4 percent. The NRC inspectors review of the licensee's findings indicates that this low number of deficiencies consists of minor conditions that do not reflect adversely on the quality of the welds or components radiographed. The NRC remains concerned

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that the B0P suppliers' were not considered during the corrective action program until the CAT inspection. identified the issues discussed in the CAT- report.

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Conclusion (PEA 7)

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. Based upon.the NRC inspector's evaluation of the above inforvation, this item e -is withdraw Inspection Report 50-498/85-24; 50-499/85-21 Potential Violations: The

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1 referenced inspection report discussed two potent i al violations. Because of

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their similarity to some of CAT Potential Enforcement Actions and because they were identified in about the same time period it was _ determined that they

'- should be considered as reinforcing the CAT findings. The Region IV team,

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during.this inspection, performed an evaluation of these items in much the same

,f v way as that for the CAT items even though they had not been formally responded 4 to by _the licensee.' ~ The first of these items,-as discussed in paragraph 6 of

the referenced report, related to a failure on the part of the AE to include 5 each orifices in instrumentation piping connected to the reactor system ,

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Based _upon the report, discussions with the NRC inspector who identified the problem, and discussions with AE representatives, it is clear that the-necessary information was provided to the AE by the NSSS vendor to have caused

, the orifices to have been installed. It appears that through a series of misinterpretations and errors of omission, the NSSS requirement for the-

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crifices ultimately disappeared from higher level drawings and was not included l in'the' field installation isometric drawings. It appears,- based on discussions

with AE personnel, that the AE piping system designers and design review l personnel failed to consider and/or were unaware of all of the pertinent and i available design input' data which included the NSSS Piping and Instrumentation

' Diagram for the reactor coolant system which has long reflected the requirement

- for the orifices. Again as a matter of perspective, the licensee notified the

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NRC oft a "potentially reportable" 10 CFR 50.55(e) item regarding this issue .

l after it was identified by the NRC staff. - The licensee ' subsequently reported F

that the_ small break LOCA analysis included in-the FSAR enveloped the orifice

+ size created by the instrument piping without the additional restriction of the

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required smaller- orifices. NRC inspectors agreed that this was the case;

}," therefore, there is little safety significance with respect to this specific issue. .The second item involved issuance of nonconformance reports and hold

Ltags relating to the-first issue. This matter was not further evaluated.

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Conclusion: Although of low safety significance, the small orifices _were deemed to be a requirement by the NSSS vendor and appropriate information was

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provided to the AE. The AE then failed to implement the requirement in his

installation drawings and design reviewer failed to detect the, omission. sThis

item is considered as another example related to CAT PEA 2. The issue of the lack of nonconformance reporting and tagging is considered to be a violation of

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10 CFR 50, Appendix B, Criterion XVI.

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Exit Interview No exit interview was hel i

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i ATTACHMF.NT EETING SUMMARY OF ENFORCEMENT CONFERENCE As a result of the NRC Construction Appraisal Team (CAT) Inspection (report issued February 5,1986), an enforcement conference was held with Houston Lighting and Power on March 27, 1986, to discuss the findings. During the meetino (attendance list attached), HL&P presented their preliminary response to the CAT findings and described changes in their organization and methods of doing business which were geared to implement permanent overall improvements in the quality of work at STP. The major topics of the meeting were as follows: Promptcorrectiveaction(general) Heightened contractor attention to detail Timely reductions of reject rate Changes and improvements to HL&P contractors' mana'gement organization Specific issues discussed: Pressurizer orifice lines Motor operated valves Structural steel . Bolting Inspection Overall corrective actions During the meeting, HL&P representatives notified the NRC Staff that they were preparing a response to the CAT report which would be forwarded to the NR In that response, HL&P planned to request reconsideration of certain CAT findings based on information not available during the CAT inspection. At the conclusion of the meeting, the NRC staff described the enforcement options available to the NRC and the meeting was adjourne ,

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ENFORCEMENT CONFERENCE ATTENDEES MARCH 27, 1986 NAME AFFILIATION POSITION J. H. Goldberg HL&P Group Vice President-Nuclear J. T. Westermeier HL&P Project Manager J. E. Geiger HL&P . Manager, Nuclear Assurance

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M. Wisenburg HL&P Manager, Nuclear Licensing R. F. Heishman NRC, IE Chief, Reactor Construction Branch M. W.-Peranich NRC, IE Chief, Construction Programs, CAT Section E. H. Johnson NRC, RIV Director,- Division of Reactor Safety and Projects J. E. Gagliardo NRC, RIV Chief, Reactor Projects Branch G. L. Constable

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NRC, RIV Chief, Reactor Projects Branch C D. A. Powers NRC, RIV Enforcement Officer C. E. Johnson NRC, RIV Senior Resident Inspector - STP B. A. Breslau NRC, RIV Project Engineer D. P. Tomlinson NRC, RIV Reactor Inspector D. L. Garrison NRC, RIV Resident Inspector - STP D. R. Carpenter NRC, RIV Resident Inspector - STP

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