IR 05000498/1987070

Insp Repts 50-498/87-70 & 50-499/87-70 on 871019-1120. Violations Noted.Major Areas Inspected:Mgt of QA Activities, QA Insp of Performance,Component Cooling Water HX & Spent Fuel Storage Racks

ML20237D448
Person / Time
Site:	South Texas
Issue date:	12/11/1987
From:	Constable G, Garrison D, Clay Johnson, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237D427	List: IR 05000498/1987070 IR 07100019/2011020 ML20237D425
References
50-498-87-70, 50-499-87-70, NUDOCS 8712230275
Download: ML20237D448 (11)

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[s APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/87-70 Operating License: NPF-71 50-499/87-70 Construction Permit: CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P.O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 (STP)

Inspection At: STP, Matagorda County, Texas Inspection Conducted: October 19 through November 20, 1987 Inspectors: ,/lahv j;t/p/r7 C.~E. Johpson, Senior Resident Inspector Ddth

/V Project Section D, Division of Reactor Projects

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/ /Abt 54 Da'th O . L.Secti D Garfison, D, Division Resident Inspector, of Reactor Projects Project

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hi)~lt;ah/ //blfY or, Reactor Inspector, Project Datd A R.G.Tay)D,DivisionofReactorProjects Sectioh

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Approved: _ -

' Nonstable, Chief, Project Section D Division of Reactor Projects

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l 8712230275 871217 PDR ADOCK 05000498 0 DCD ( _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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- Inspection Summary 3

1 Inspection Conducted October 19 through November 20, 1987 (Report 50-498/87-70;

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50-499/87-70)

Areas Inspected: Routine, unannounced inspection including site tours, licensee management of quality assurance activities, in-depth quality assurance inspection of performance, component cooling water heat exchanger, spent fuel storage racks, and followup on allegation Results: Within the six areas inspected, two violations (performing work without approved drawings, paragraph 4.b and failure to translate design requirements, paragraph 6.a) were identifie .

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-3-DETAILS Persons Contacted'

F rincipal Licensee Employees

• J. T. Westermeier, Project Manager J. Geige", Nuclear Assurance Manager

• T. J. Jordan, Project Quality Manager

• J. Phelps, Project Compliance Supervisor

• D. R. Keating, Quality Engineering Manager

- *S. D. Phillips, Project Compliance Engineer Bechtel Power Corporation (Bechtel)

• D. Bryan, Construction Manager

• L. Hurst, Project Quality Assurance Manager

• R. Miller, Quality' Assurance Supervisor

• R. Medina, Lead QA Engineer

• Herman, Quality Assurance Engineer Ebasco Service Inc. (Ebasco)

• D. White, Project Manager

• A. M. Cutrona, Quality Project Site Manager

• Harold Melton, Quality Control Supervisor

• Able, Quality Control Manager P. Phelon, QC Structural Supervisor P. Soderstrom, Field Engineer Westinghouse D. Bokesch, Quality Control Supervisor U. S. Patel, Site Engineer In addition to the above, the NRC inspectors also held discussions with other members of the HL&P, Bechtel, Westinghouse, and Ebasco staff * Denotes those individuals attending the exit interview conducted on November 23, 198 . Site Tour The NRC inspectors made frequent tours of the Unit 2 reactor containment building (RCB), fuel handling building (FHB), mechanical and electrical auxiliary building (MEAB), isolation valve cubicles (IVC), diesel generator building (DGB), warehouses and laydown areas. The site tours were made during normal working hours, on backshift and weekend ,

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-4-l Licensee Management of Quality Assurance (QA) Activities

' An inspection and review of the overall quality assurance program was performed in order to assess the effectiveness and management of the program in relation to the licensee, design engineer, constructor and nuclear steam supply system (NSSS) vendo QA Program A review of each organization's quality program indicated that a base topical report had been submitted to and approved by the NRC. From this report a group of procedure manuals has been generated to fulfill the commitments in the topical reports. It was found that each organization has generated procedures to cover the areas of QA, quality control (QC),

American Society of Mechanical Engineers (ASME) commitments, and administrative functions. Each manual that was reviewed by the NRC inspector had been reviewed and approved by appropriate QA licensee personnel; and each procedure within the manuals had been approved through its current revisio It was fourid that the organizational structure was outlined where necessary and that responsibilities for reviews, inspections, aedits, and management of the program were delineate Portions of QA manuals were reviewed for consistency, relationship to the overall program and effectiveness of the quality progra In each program, it was found that the quality functions were managed independently of other functions; that major program changes were submitted to the NRC in accordance with 10 CFR 50.54(a)(3); reviews and scheduled audits were' detailed and in critical areas; and trend analyses were performed and included management revie It is to be noted that the entire licensee QA organization, including corporate management personnel, are now physically located on the project site; this aspect appears to enhance the overall program in that management is directly involved on a day to day basis and problem areas are dealt with in a more expeditious manne Interviews were held independently with the managers responsible for quality and each company project manager in order to verify that lines of communication were established; that duties and responsibilities were clear; and that the quality program / project management interfaces were established and workin The licensee QA program for audits was reviewed and found to be functioning as required. Included in the review were four auditor qualifications to American National Standards Institute (ANSI) 45.2.23 standards and nine randomly selected audits of various aspects of the contractor, engineer, and NSSS vendor programs. The licensee QA program appears to be adequately staffed with experienced personnel. Reviews by quality personnel were evident in the areas of design, procurement, engineering, procedures, trending and overview of contractor programs including nonconformance _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ . _ _ _ - - _ .___ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - - _ _ - _ - _ _ - _ - - _ _ _

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-5-The QA program includes detailed requirements in the area of procurement, including the review of requisitions for quality requirements; source selection; auditing and qualifying of vendors; purchase order review and receiving inspections. Supplier control is maintained through a system of vendor audits performed by the licensee and enginee Review of the overall QA program, indicate that the licensee program .for quality is being effectively implemente No violations or deviations were note . In-Depth QA Inspection of Performance Structural Steel The purpose of this inspection was to determine whether the QA/QC program is functioning in a construction activity in a manner to erasure that requirements and commitments are being me The NRC inspector selected two civil structural items for inspection to determine if site work is being performed in accordance with NRC requirements, implementing procedures and Final Safety Analysis Report (FSAR) commitment Field Drawings and Quality Procedures The NRC inspector selected installation drawings for the control room ceiling structural members at. elevation 45'-6" and the DGB fan support platform at elevation 74'-1 3/4". The drawings used were the most recent revisions used for inspection / installation. This was verified by the field document control center computer. The NRC inspector also reviewed two Standard Site Procedures (SSP) and one specification. It was determine that the quality procedures adequately describe critical points and methods of installation as well as hold point Documents reviewed were:

Drawings Procedures 3001-9-S-5009, Revision 6 SSP ll, " Fabrication, Erection and Bolt-Up of Structural 3001-9-5-5010, Revision 7- Steel," Revision 2 j l

3M01-9-S-34002, Revision 8 SSP 16, " General Structural-Welding Requirements," J Revision 3 Field Inspection The NRC inspector performed an inspection of the "B" bay DGB fan support platform at elevation 74'-1 3/4" and the control room ceiling .

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i-6-plan at elevation 45'-6" in Unit 2. Structural members examined in the control room ceiling were at the following locations; 8'-6" west of column line E between column line 20 through column line 22; and 13' east of column line E and 17'-10 1/2" south of column line 2 The inspection consisted of the examination of st*uctural members for correct type, size, fasteners, location, erection and as-built condition in accordance with the design drawings and field change requests (FCR). During this inspection, there was one discrepancy identified in the control room ceiling plan. This involved a Class 9 penetration cover plate welded to a Class 3 structural channel membe It was found that the addi' 'an of the nonsafety cover plate had been accomplished after QC acceptance of the Safety Class 3 member. This is permitted by procedures provided that the design drawing is followe The design drawing illustrated a detail that did not match the as-built condition. The licensee then informed the NRC inspector that FCR BC-0-2780 was used to perform the wor The NRC inspector noticed that the as-built condition did not match the FCR eithe It was determine by the NRC inspector that construction craft welded these members without an approved design drawing or detai SSP 16, Revision 3, paragraph 4.3.3 states that "the craft supervii.or and/or discipline field engineer shall be responsible to ensure that the latest design drawings and amendments are used to perform work."

This was not accomplished. This is considered a violation (499/8770-01).

c. Quality Control (QC)

(1) QC Inspection Reports The NRC inspector reviewed completed QC inspection re;: orts (IR)

of the structural members described in the previous paragraphs to determine if the original installation work was being properly documented and deficiencies were being ideatified in accordance with site procedures. Review of the structural irs for the control room ceiling and diesel generator fan support platform indicate that deficiencies were submittcd by QC inspectors and that these deficiencies received croper corrective action. irs also reflect that work and work control were adequat QC inspection / surveillance coverage of the safety-related structural steel activities appears to adequat irs reviewed are as follows:

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Diesel Generator "B" Bay Control Room Ceiling 2-5514 QE2-0137 QE2-0009 2-5513 2-5511 01331B 2-5512 2-4531 2-02949 QE2-0136 2-4545 018718 QE2-0138 2-5433 (2) QC Inspectors The NRC' inspector had several discussions with QC inspectors to determine if they were knowledgeable of the structural steel mapping program; also if they were knowledgeable of other inspection attributes and governing procedures. These discussions indicated that QC personnel in the structural area were well traine Discussion with structural craftsmen and foremen indicated that they were knowledgeable of the work procedures use Nonconformance Reports (NCRs)

The NRC inspector reviewed NCRs related to the structural steel activity inspecte The NCRs reviewed were properly prepared and channeled through the appropriate approvals. Examination of the NCRs and the hardware affected indicated that appropriate corrective action was taken and complete '

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NCRs reviewed were CC-03917, CC-04290, and CC-0 P? Audits The NRC inspector reviewed audit report No. S67-701 and the response to i The audit reflected valid concerns and deficiencies identified by HL&P Q This audit identified some weaknesses in the contractor's QA/QC program for mapping activities in the structural steel area. The response to the audit was adequate and is to be implemented throughout the completion of Unit 2 structural steel mapping activitie One violation was identified in paragraph 4.b. abov No deviations were identifie . Component Cooling Water (CCW) He'at Exchangers During a routine backshift tour of Unit 2 construction activities, the NRC inspector observed work being performed on the three CCW heat exchangers.

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-8-l There were two stages of work observed; the first was the expansion of the stiffener rod to Titanium tube and tube sheet; the second stage was the plugging activity which consisted of installing the Pop-A-Plug. Work was being accomplished in accordance to installation instructions and monitored by the license No violations ~or deviations were identifie . Spent Fuel Storage Racks

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An inspection of the Unit 2 spent fuel storage racks was performed in order to assess the program for construction, installation and inspection. The four racks inspected were of the 4X4 arrangement and located in the reactor building pool, Proctdures The NRC inspector reviewed the following documents during the inspection:

. Design Specification - W-DS-52, Revision 2 and W-DS-63, Revision 0

. Equipment Specification - W-953264, Revision 1

. Installation Procedure - W-2463A82, Revision 3

. Mechanical Work Package - 2fH01E8005

. Westinghouse Drawings - 6127E35, sheets 1, 2, and 3, Revision 3

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6119E71, sheets 1, 2, and 3, Revision 4

. Pittsburgh-De Moines Drawing El, Revision B  ;

. 'HL&P QC Procedure - SSP 51, Revision 1 It was found that the documents included requirements for storage, rjgging, location and orientation, checks for levelness, alignment clearances and final aligr, ment using a test fixture which simulates a fuel bundle. Other supporting documents such as warehouse l requisitions and correspondence were also examine j i Work Observation l During the inspection, the NRC inspector questioned Westinghouse engineering on the meaning of the instructions for tightening the fasteners which secure the fuel racks to the floor. The instructions state "Using a torquing wrench on the torquing tool, snug the nut on the embedment stud by torquing to 25-foot pounds +5-foot pound ,

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With the wrench pulled tight on the nut, turn the disk, Item 13, Drawing 1451E31 clockwise until the first scribe line clockwise is directly under the edge of the wrench furthest from the holder, then turn the nut on the embedment stud until the edge of the wrench, furthest from the holder, is directly over the second scribe line, clockwise on the disk, after spring back from rotational deflection."

The NRC inspector observed this procedure being performed and noted that the torque value did not exceed 30 foot pounds. Westinghouse engineering informed the inspector after the inspection that the design torque on the fasteners should be 1100-foot pound After review of the Unit 1 and 2 installation work packages, it is concluded that the fasteners in both units are improperly torque This is considered a.. violation (498;499/8770-02).

The work installation was inspected on four different occasions; those being setting, leveling, bolting and final tightening and fuel bundle drag tes The craft were utilizing the instructions,within the work package for installing each unit. The instructions were complete and clear and special tools were provided for setting the racks and installing spherical nuts and washers to the floor embedments. A quality inspector was observed witnessing inspection hold points for the work activitie The leveling tools, application of Neolube lubricant, nut and washer cesign, torque wrenches and special tools and their use were verified as being in compliance with the design and installation requirement The work traveller package, which will be part of the final documentation, was inspected and found to be complet The work and inspections were performed in the proper sequence The foreman, craft, quality inspectors, and field engineer were interviewed and it was determined that in each case they were knowledgeable of their responsibilities and duties in the work effor One violation was identified in paragraph 6.b. abov No deviations were identifie . Allegation Followup Technically Closed (Allegation 4-87-A-0079): The NRC received a handwritten, unsigned and undated letter alleging that a certain named Ebasco employee was incompetent. The letter did not contain any supplemental information that would assist in identifying the named individual. The handwriting in the letter was such that there were three possible spellings of the last name. The NRC inspector reviewed the personnel files of all nonmanual personnel (those not hired through the union) and computer listings of all manual personnel employed on the

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project from 1982 when Ebasco began work on the project to the present time. Upon learning that some Bechtel employees had been working for Ebasco and might have been confused for an Ebasco employee, the NRC inspector also reviewed comparable listings provided by Bechtel. None of the files or listings contained any of possible spellings of the last name, which when coupled with the first name, matched the name provided in the lette This allegation can not be further evaluated without additional information and is therefore considered close Technically Closed (Allegation RIV-87-A-0059): The alleger charged in an anonymous letter that the licensee has been covering up the real cause of corrosion in miles of prefabricated open small bore piping that has been allowed to stand with some water inside and in the weather for 10 year The alleger indicated that microbiologically induced corrosion (MIC) was being blamed for the corrosion when that was not the real cause. Small bore piping by industry definition is piping that is 2.5 inches and smaller in diameter. Such piping is usually fabricated into piping runs by use of fittings which allow the pipe to be inserted into the fitting and secured by a fillet weld to create a strong, leak-tight joint. Past NRC inspections of installed piping have identified no corrosion problem The portion of the allegation related to corrosion was referred to the licensee for investigation by SAFETEAM. The NRC inspector reviewed the SAFETEAM investigative report and supporting data during this inspectio The SAFETEAM investigation was found to have been based on walkdowns of installed small bore piping, review of current storage practices for piping which largely focused on storage of bulk new pipe since only a very few fabricated spools remain stored, and interviews with engineers familiar with corrosion, including the MIC issue. SAFETEAM concluded that the allegation was unsubstantiated because:

. There is no evidence of corrosive attack on installed pip . Site procedures for storage of piping materials are being followe . Safety-related small bore piping is nearly all stainless steel and is highly resistant to corrosive attack under normal outdoor storage conditions even if small amounts of water are allowed to accumulate in i Based on site history and available technical information on the subject, MIC only attacks stainless steel in the heat-affected zone adjacent to a weld. The heat affected zone inside of a pipe fillet welded on the outside is very narrow and almost nonexistent since the weld only penetrates into the outer surface of the pip There has been no evidence of MIC attack under such circumstances on STP pipin While the NRC inspector generally agreed with the SAFETEAM finding, it was pointed out that they had overlooked the part of the allegation that the pipe was old (10 years) and was stored for a long period of time which tended to make the observation of current storage practices immaterial and to not properly focus the walkdowns. In responding to the suggestion,

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fabricated at least a thousand spools of small bore piping between 1976 and 1980 when work was stopped under a NRC Show Cause Orde These spools were for the most part stored in outdoor laydown yards until as late as 1985. The SAFETEAM was able to establish that 30 spools were scrapped because they had not been ASME stamped by B&R, another 616 were either scrapped or sold as surplus bulk pipe. A Bechtel generated computer listing showed that 339 B&R fabricated spools were installed but only ore is safety-related. This spool was examined and it showed no evidence of corrosive attac During the course of the SAFETEAM investigation, the previously anonymous alleger contacted Region IV personnel via telephone. The alleger offered that his concern focused on stainless steel pipe and further offered the name of a witness who was said to be able to corroborate the alleger's information. When contacted by Region IV personnel, the witness indicated that the allegation was groundless since the stored spools had been properly capped which would have kept water ou Based on the SAFETEAM investigation, which appears to have been thorough when finished, NRC inspection experience in the piping area at the South Texas Project, and the lack of any corroborating information, the NRC ins;)ector concluded that without more specific information as what spools the alleger is concerned with, the allegation must be considered unsubstantiate . Exit Interview The NRC inspectors met with the licensee (denoted in paragraph 1) on November 23, 1987, and summarized the scope and findings of this inspectio __--__ _--_ _ __ _ _-