ML19262B075
| ML19262B075 | |
| Person / Time | |
|---|---|
| Issue date: | 11/26/1979 |
| From: | Donna Anderson, Costello J, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19262B073 | List: |
| References | |
| REF-QA-99900505 99900505-79-4, NUDOCS 7912110516 | |
| Download: ML19262B075 (13) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900505/79-04 Program No. 51200 Company: Ebasco Services, Incorporated Two Rector Street New York, New York 10006 Inspection at: New York, New York and Lyndhurst, New Jersey L,spection Conducted: October 29-November 2, 1979 Inspectors:
u g,.:.
//[2 //79 J. R. Costello, Principal Inspector
' Date Program Evaluation Section Vendor Inspection Branch
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D. G. Anderson, Principal Inspector Date F ogram Evaluation Section Vendor Inspection Branch
//~J6~7f Approved by:
/
C. J.i g, Chief Date Program tvaluation Section Vendor Inspection Branch Summarv Inspection on October 29-November 2, 1979 (99900505/79-04)
Areas Inspected:
Implementation of Topical Report No. ETR-1001 in the areas of IE Bulletin 79-14, regional request for inspection, and follow-up on previous inspection findings. The inspection involved forty-six (46) inspector-hours en-site by two (2) USNRC inspectors.
Results:
In the three (3) areas inspected, no deviations or unresolved items were identified.
1532 140 7912110 8 / b i
2 DETAILS SECTION I (Prepared by J. R. Costello)
A.
Persons Contacted S. C. Boone, Supervisor Stress Analysis J. Chic, Lead Engineer Stress
- T. A. Cotter, Senior Quality Assurance Engineer, Auditing E. F. Ellison, Chief Vendor Quality Assurance D. D. Fiore, Project Engineer
- F. F. Ford, Supervising Quality Assurance Engineer M. S. Giniger, Assistant Project Engineer C. B. Hickey, Assistant Engineer Quality Assurance R. A. Keilbach, Senior Welding "agineer
- M. L. Mancini, Senior Supervising Engineer Piping Supports / Restraints S. Missailidis, Project Quality Assurance Engineer
- C. Murphy, Supervisor Project Files
- J. W. Phalen, Associate Engineer J. R. Ruimerman, Lead Engineer Support & Strain J. R. Santosuosso, Assistant Chief Engineer Mechanical / Nuclear Engineering
- L. J. Sas, Chief Engineer Mechanical / Nuclear Engineering G. W. Scarfo, Design Group Supervisor S. Sparacino, Supervising Quality Assurance Engineer F. E. Townsend, Project Quality Assurance Engineer
- Denotes those present at Exit Meetings.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 79-03): Failure to follow procedures for preparing General Arrangement Design Change Notices. All Design Change Notices lacking proper review have been re-examined and the appropriate signatures obtained. A memo has been isstad by the Ebasco Project Engineer at the Lyndhurst office requiring the participation of all project personnel in a training program describing the details of Ebasco procedure E-70 (Notification of Proposed Design Changes in General Arrangement Drawings).
In addition increased auditing of the implementation of procedure E-70 will be performed by the Quality Assurance Engineering Internal Audit Group.
2.
(Closed) Deviation (Report No. 79-03): QA records were corrected but were not signed and dated. All design change notices previously issued were re-examined and all required corrections or modifications have been documented in accordance with the Ebasco Quality Assurance Program. A memo from the Project Enginea-dated October 2, 1979, has been issued to all appropriate personnel calling attention to this kbb
3 requirement. Also, increased auditing of the implementation of this requirement will be performed by the Quality Assurance Engineering internal auditing group.
3.
(Closed) Deviation (Report No. 79-03): No procedure has been issued to authorize and prescribe the method of deviating project-related QA Programs from the Ebasco QA Program and project-related QA Program deviations have been issued. Ebasco Quality Program Procedure No. 5 entitled " Deviation Ebasco Project-Related Quality Assurance Programs From The Ebasco Nuclear Quality Assurance Program Manual" has been officially issued as Revision 0 dated 10/1/79.
Ebasco's Quality Program Coordinator h?s personnally evaluated the status of all QA procedures applicable
- .o the Ebasco Nuclear Quality Assurance Program and has determined tha: all are properly approved and issued (Program Procedure No. 5 was in draft form and was being used prior to this inspection finding). Also, to preclude future recurrences of this type, a memo has been issued by the Quality Program Coordinator dated October 8, 1979, stating that no Quality Program Procedures in draft form are to be used.
4.
(0 pen) Deviation (Report No. 77-03): A significant number of "Q" designated project documents have not as yet reached the duplicate controlled file.
In Ebasco's letter of response dated April 28, 1978, the estimated completion date for this effort was stated as August 1978. This estimated cocpletion date was changed to December 31, 1979, in Ebasco's letter of response (March 1, 1979) to Inspection Report No. 79-01.
The inspector reviewed the present status of this effort and found that the duplicate files will be up-to-date within two (2) months. This was a very large scale effort as there was no duplicate file when it started and the duplicate file contains both "Q" and "Non-Q" records. The duplicate record file is being established on micro film and aperture cards and is being maintained in a controlled environment.
5.
(Closed) Unresolved Item (Report No. 79-02):
It does not appear that the programmatic re-evaluation of the supplier / contractor quality assurance program and facilities described in the Ebasco Topical Report No. ETR-1001 is in compliance with the requirements of 10 CFR 50, Appendix B, Criterion VII. Present practice is for the Chief Quality Assurance Engineer to analyze the Trend Analysis Reports and the Vendor Quality Assurance Representative Reports to determine the time frame for periodic re-evaluation of vendors. The Trend Analysis Report which is published semiannually makes specific recommendations for periodic re-evaluation of vendors.
In no case shall facility re-audit (re-evaluation) exceed three years. A vendor performance system is now in the process of being implemented which provides a print out of vendor performance including dates of previous facility audits and recommended dates for future facility audits 1532 142
4 C.
Follow-up On Post Weld Heat Treatment of Nozzles for Containment Valve Chambers 1.
Objectives The objectives of this area of inspection were to answer the following questions raised by the failure of Graver Energy Systems, Inc., to post weld heat treat the nozzles for the containment valve chambers for Shearon Harris Nuclear Power Plant Units 1 and 2.
a.
Was the purchase specifica'. ion defective?
b.
Did Graver Energy Systems, Inc., deviate from the specification?
Did Ebasco's system for control of procured material identify c.
this requirement?
d.
Are other Ebasco projects subject to this problem?
e.
What corrective / preventive action has Ebasco take.n?
2.
Method of Accomplishment The preceding objectives were accomplished by examination of the following documents:
a.
P.O. NY 435003 and P.O. NY 435004 to Graver Energy Systems, Inc., (Graver) covering containment liner, air locks, and hatch.
b.
Specification CAR-SH-AS-1, Revision 9, Containment Liner, Air Locks and Hatch.
c.
Quality Compliance Plan For Vendors, Manufacturers er Contractors (Graver, Valve Chambers).
d.
Job plan for fabrication of valve chambers and roof plates.
Letter from L. V. Thierwechter, Project Manager Ebasco, to R. K.
e.
Cothern, Principal Project Engineer Carolina Power and Light, dated August 27, 1979,
Subject:
Shearon Harris Nuclear Power Plant Post-weld Heat Treatment of Valve Chamber Welds - P.O. NY 435003 Potentially Reportable Incident.
f.
Deviation / Noncompliance Evaluation Report No. 2 dated August 23, 1979 - Deviation
Title:
Post Weld Heat Treatment of Valve Chamber Welds - date c r discovery July 19, 1979, date of occurrence - un-known.
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5 (1) Licensing Evaluation and Safety Implication of Potentially Reportable Incident-Post Weld Heat Treatment of Valve Cham-ber Welds.
(2) Materials Engineering Evaluation of Potentially Reportable Incident-Post Weld Heat Treatment of Valve Chamber Welds.
(3) Engineering Evaluation of Potentially Reportable Incident-Post Weld Heat Treatment of Valve Chamber Welds.
g.
Letter from G.M. Ault, Program Manager Graver Energy Systems, Inc.,
to L. V. Thierwechter, Project Manager Ebasco, dated July 11, 1978.
This letter was in response to an Ebasco request for post weld heat treat records on the nozzles for the containment valve cham-bers. Graver stated they did not believe this was required and did not do any post weld heat treatment.
h.
Letter from L. V. Thierwechter, Project Manager Ebasco, to R. K.
Cothern, Principal Project Engineer Carolina Power and Light, dated August 22, 1978. This letter notified Carolina Power and Light that Graver Energy Systems, Inc., did not post weld beat treat the nozzles for the containment valve chambers. This letter also stated that Ebasco was in the process of evaluating this defi-ciency.
i.
Ebasco memorandum from Keilbach to Missailidis dated July 25, 1979. This memorandum stated the following.
. Ebasco speci-fication CAR-SH-AS-1 specifies that valve chambers shall be designed, fabricated, and erected in accordance with ASME Section III, Subsection NE, Winter 1971 addenda. ASME Section III, Win-ter 19 1 addenda, NE-4322 requires postweld heat treatment of the weld joining the 30" sleeves to the valve chambers.
3.
Findings a.
The purchase specification was adequate and was not defective.
However, the specification was written in general terms and did not pin point where specific portions of the code were to be used or how to interpret that section of code that pertained to post weld heat treatment of nozzles. Ebasco purchase specification CAR-SH-AS-1 specified that valve chambers shall be designed, fabricated and erected in accordance with ASME Code Section III, Subsection NE, Winter 1971 Addenda as applicable.
b.
Graver Energy Systems, Inc., (Graver) deviated from the specifi-cation but did not believe that section NE-4322 required them to post weld heat treat the nozzles. There has been some mis-interpretation of this section, but ASME has issued an inter-pretation which iterates what is presently stated in the 1532 144
6 first part of paragraph NE-4322 (b), i.e., "All doors nozzles, opening frames and similar welded construction shall be pre-assembled into a portion of the shell plate or plates and post-weld heat treated as complete subassemblies for welding into the shell.
c.
Ebasco's Quality Compliance Plan for surveillance of Graver's manufacturing operations covering the welding of the nozzles to the valve chambers did not have a requirement for checking post weld heat treatment. The Quality Compliance Plan was made up from the Job Plan for Fabrication of Valve Chambers furnished to Ebasco by Graver. This Job Plan did not call for any post weld heat treatment. Discussions with the Quality Assurance (QA) Engineer responsible for the Quality Compliance Plan and examination of the Quality Compliance Plan and Job Plan for Fabrication of Valve Chambers disclosed that the QA Engineer does not attempt to verify that all applicable portions of the codes on all design requirements are included in the Quality Compliance Plan. The main emphasis in the Quality Compliance Plans is to assure that the vendor is following his manufac-turing plan or sequence of manufacturing operations. The specific design requirements are spelled out in vendor drawings, specifications or job plans for fabrication and if they are omitted it is difficult for a QA Engineer to determine this.
This present practice would suggest that Ebasco Quality Compliance plans should be reviewed by Ebasco design and/or materials engineers to assure that all design requirements are being con-sidered in the manufacturing operation.
d.
Other Ebasco projects are subject to this problem. The problem was discovered when the Ebasco material engineer asked for the records on post weld heat treatment from Graver and was told there was no records because they did not postweld heat treat the nozzles for the containment valve chambers.
This deficiency affected Shearon Harris Nuclear Power Plant Units 1 and 2.
The valve chambers had been delivered and were already embedded in concrete. An evaluation by Ebasco Licensing, Materials Engine-ering and Engineering determined this was not a reportable in-cident and the material could be used-as-is.
The evaluation came up with the following determination:
"The purpose of performing a post weld heat treatment is to minimize any residual stresses caused by the welding operation. Since the nozzle to shell welds are normally high stress points, the code felt that this operation would provide added assurance of weld integrity. However, the valve chamber is only a secondary containment boundary (PSAR Sect. 6.3.4 page 6.3-2) and therefore, is not directly connected to the containment atmosphere.
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-.. ~
7 This valve chamber completely encloses the pump line and isolation valve. The valve chamber is sealed from the containment atmosphere by closure plates welded directly to the sump lines at one end and the containment penetration sleeves at the other end. Thus failure of the primary containment pressure boundary must occur in order for the valve chamber to be exposed to the containment atmosphere.
All valve chambers were shop pressure tested to 70 p.s.i.g.
even thouah the design pressure is only 45 p.s.i.g.
Thus any problems in the welds joining the nozzles to the valve chamber would have been discovered during the shop pressure test."
Thus while the as built condition is satisfactory in this case and would be for any previous plants built to the same standards, Ebasco intends to meet the requirements for post weld heat treat on all future plants.
Ebasco's contract with Graver has been terminated and the valve chambers for Shearon Harris Nuclear Plant Units 3 and 4 will be fabricated by Chicago Bridge and Iron (CB&I). The require-ment for checking post weld heat treatment will be incorporated into the Quality Compliance Plan for valve chambers at CB&I.
e.
Ebasco has analyzed the risk of this deficiency and has shown that it is not a serious risk.
It is possible that this requirement for post weld heat treatment could be eliminated for this type of valve chamber. However, the danger of missing similar requirements in other specifications needs to be reviewed.
All cognizant personnel have been alerted to check this require-ment on future fabrication of valve chambers and in particular on Shearon Harris Nuclear Plant Units 3 and 4.
The Chief Quality Assurance Engineer is reviewing this matter and intends to issue a memo in the near future covering the matter.
D.
Exit Interview Two exit interviews were conducted with management representatives during this inspection. The first exit interview was conducted on October 30, 1979, where Mr. Anderson summarized the results of the inspection covering follow-up on IE Bulletin 79-14.
The second exit interview was conducted on November 2, 1979, where Mr. Costello
~.,, -. - - - - - ~ ~
- ~ ~ - - - -
- - - - - - - - - 1532 146
E summarized the results of inspections covering follow-up on post weld heat treatment of containment valve chamber welds and follow-up on previous inspection findings.
In addition to the individuals indicated by an asterisk in the Details Sections, those in attendance at both exit interviews were:
B. R. Mazo, Chief Quality Assurance Engineer B. E. Tenzer, Director Materials Engineering and Quality Assurance W. R. Weinberger, Supervisor Quality Assurance Engineering R. F. Williams, Supervising Engineer Quality Assurance The inspectors summarized the scope and findings of the inspections for those present at the interview. Hanagement representatives acknow-ledged the statements of the inspectors.
1532 147
9 DETAILS SECTION II (Prepared by D. G. Anderson)
A.
Persons Contacted S. C. Boone, Supervising Engineer
- T. A. Cotter, Senior Quality Assurance Engineer G. C. Hwang, Senior Engineer
- M. L. Mancini, Senior Supervising Engineer J. R. Santosuosso, Assistant Chief Mechanical-Nuclear Engineer
- L. J. Sas, Chief Mechanical-Nuclear Engineer
- Denotes those present at the exit interview.
B.
Followup on I.E.Bulletin 79-14 1.
Objectives This was a special inspection related to the follow-up of activities being conducted at the New York offices of EBASCO Services, Inc.,
which have resulted from the issuance of IE Bulletin 79-14 (Seismic Analysis for As-Built Safety-Related Piping Systems). The inspection consisted of two (2) phases:
a.
Phase 1 The objectives of this phase of the inspection were to determine the following:
(1) The licensees that are inspecting systems to the latest drawings and comparing the results with the seismic analysis input used.
(2) The number of people that will be comparing the marked-up drawings with the seismic analysis input, a general descrip-tion of their qualifications, and the schedule for these activities.
(3) The guidelines that will be used to identify the noncon-formances of the marked-up drawings to the seismic analysis input used.
(4) The identification of units where eccentric nasses have been modeled.
b.
Phase II The objectives of this phase of the inspection were to deter-mine that:
1532 l48
10 (1) The IE Bulletin 79-14 activities are being conducted in a documented, planned and systematic manner.
(2) The inputs to the seismic analysis for this system can be readily identified.
(3)
Identified nonconformances are analyzed and the results properly documented.
(4) Personnel conducting these activities have received indoctrination and training.
2.
Method of Accomplishment a.
Phase I The preceding Phase I objectives were accomplished by discus-sions between the inspector and EBASCO representatives, with the following activities identified:
(1) EBASCO has contracts for 79-14 inspections and analyses for the following licensees:
(a) Millstone Unit 1, Northeast Utilities Service Company (b)
St. Lucie, Unit 1, Florida Power and Light Company (c)
H. B. Robinson, Unit 2, Carolina Power and Light Company l
(d) Surry, Unit 2, Virginia Electric Power Company w
(2) These activities are identified in Corporate Procedure, l
l EBASCO IE/ Directive Compliance Support Program Plan and Procedures.
(3) Depending on the scope identified in the contract, the number of personnel assigned to activities related to 79-14 will vary. Millstone Unit I which is in the early stages of activity and for which NUSCO is assuming more responsibility has approximately twenty (20) EBASCO per-sonnel assigned to the site and another five (5) personnel performing analyses at the New York office. On the other hand, Surry Unit 2 has approximately sixty (60) EBASCO personnel assigned to the site and another fifty-six (56) performing drafting and analyses at the Jericho office.
(4) The activities to be performed by EBASCO include a walk-through inspection of Category 1 piping in the plant and 1532 le
Y 11
}
t to either markup the existing isometrics or provide as-im
[d built sketches for the pipe stress reanalysis effort.
EBASCO would then verify the as-built design adequacy of the seismic supports to meet the loads generated by the f'
current design stress calculations, including recalcu-pjg Q[jg lation of the stress loads of any seismic supports found to be in nonconformance with the design hanger pipe loca-tions. EBASCO would provide design modifications for any pa; seismic supports found to be under the design load and pro-vide new designs for any seismic supports found to be mis-sing from design locations or as required in the recalcu-L lation of the pipe stress loads. Nonconformances identi-M fied at the site are dispositioned at EBASCO according to the following procedures:
(a) Millstone Unit 1, EEPC-S-007, IE 79-14 Two Day Non-conformance Evaluation Procedure, (Draf t Form).
I' (b) Surry Unit 2, EEPC-Q02, Field Information and Field Change Requests, 8/31/79; EEPC-008, Teo (2) Day hg, Reporting on 79-14, 9/21/79.
[I,T ps+..
(c) The inspector reviewed the following as-built iso-
,J
?! d?
metrics for nonconformances identified :- the rite. te,-
- 'd assure that reanalysis meets stress re;"irerent
- :.
lil ISO-VI-6, Containment Cooling Service Water from Heat ig.g Exchanger, 5/22/68. Millstone Unit 1.
Q Pf' ISO-VI-5, Containment Cooling Service Water from k
Anchor Point #1, 5/24/68, pp p
(d) The inspector reviewed the following calculations M
related to reanalysis a' the nonconformances iden-
-7 D.-
tified:
h, -:-
Calculation //327, Containment Cooling-Review report for Millstone Unit 1, 10/26/79.
h,h
%try b.
Phase II The inspector reviewed the following documents to assure that the Phase II objectives a re being accomplished:
[I bc?
(1) For the Surry Ur.it 2 activities related to IE Bulletin 79-14, 4.y the following procedures assure that these activities are g.,
conducted, documented, and planned in a systematic manner:
d-N (a) EBASCO Sorry Unit 2 Site Procedure Manual and Project M
.h Procedur<.s Manual.
. d.
O 47 W
1532 150 3
te dt
12 (b) Project Procedures:
EEPC-001, Instructions for Analysis and Evaluation of Pipe Stress Analysis (KUPIPE) 8/24/79.
EEPC-002, Field Information and Field Change Requests 8/31/79.
EEPC-003, Evaluation of Supports / Restraints 8/29/79.
EEPC-004, STRUDL Procedure (Supports / Restraints) 9/11/79.
EEPC-008, T:fo (2) Day Reporting on 79-14, 9/21/79.
EEPC-009, Stress Evaluation on 79-14, 9/21/79.
EEPC-010, Generation of AS-Built Drawings (under preparation).
EEPC-000, Company Procedures Applicable to the Surry Unit 2 Project, 9/10/79. References EBASCO Engine-ering procedures and Quality Assurance procedures applicable to Surry Unit 2 activities related to 79-02, 79-14, activities on Surry Unit 2.
(2) For the Millstone Unit 1 site, the following procedures are being implemented:
(a) 79-1-44, Field Inspection Procedure for IE Bulletin 79-14, 9/5/79.
(b) EEPC-S-001, Development of As-Built Piping Systems,
8/28/79.
EEPC-S-002, As-Built Support / Restraints Sketch Markup and Generation, 8/28/79.
EEPC-S-007, IE 79-14, Two Day Nonconformance Evalu-ation Procedure, (under Preparation).
(3) Contract commitments are identified in the following documents:
P.O. #495487, Furnish Engineering and Technical Services to Reply to IE Bulletin 79-14, 8/14/79.
1532 151
13 KUSCO Quality Assurance Specification 4-01-B, Requirements for an Engineer and Constructor's Quality Assurance Pro-gram, 7/8/76.
(4)
Input to Computer Program PIPESTRESS2010 was identified on the following marked up isometric drawings:
(a)
ISO-IV-3, Millstone Unit 1 Condensate from I.P.
Heaters to Reactor Feed Pumps, 8/3/67.
(b) E-2362-IC-28, Condensate-Reactor Feed Pump Discharge Piping to Header.
(Fabrication isometric drawing, 6/10/69, which was corrected 9/5/79.)
3.
Findings There were no deviations or um r olved items identified on either of the projects reviewed during this inspection.
a.
Followup Items Identified on the Millstone Unit 1 Project The inspector noted that even though activities related to IE Bulletin 79-14 have begun recently (Purchase Order, 8/14/79),
program requirements and procedures have not been defined in enough detail to provide a design traceability from items identified at the site to final analysis at EBASCO/New York.
The inspector notified EBASCO management that this item will be re-inspected during a future inspection to assure that procedures describe in detail each element of the activities related to 79-14 on the Millstone project.
i t
i l
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