ML19340E812
| ML19340E812 | |
| Person / Time | |
|---|---|
| Issue date: | 11/19/1980 |
| From: | Costello J, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19340E809 | List: |
| References | |
| REF-QA-99900505 NUDOCS 8101150851 | |
| Download: ML19340E812 (11) | |
Text
O U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900505/80-03 Program No.
51200 Company:
Ebasco Services, Incorporated Two World Trade Center New York, New York 10048 Inspection at:
New York, New York Inspection Conducted:
October 20-24, 1980 Inspectors:
- b. h b6//a n/,+/v, J.fRj Costello, Principal Inspectcr Uate Program Evaluation Section VeTidor Inspection Branch
,b
, t-J.M.Joyison,Contractoflnspector Date Program Evaluation Section Ve Inspec+
n B anch Approved by:
)
__D d
C. J.'hple, Chief, Program Evaluation Section Oate Vendor Inspection Branch Summary Inspection on October 20-24, 1980 (99900505/80-03)
Areas Insoected:
Implementation of Topical Report No. ETR-1001 in the areas-of action on previous inspection findings, and followup on regional requests.
The inspection involved forty-two (42) inspector-hours on-site by two (2) USNRC inspectors.
Results:
In the two (2) areas inspected no deviations or unresolved items were identified.
8101150 %
2 DETAILS (Prepared by J. R. Costello and J. M. Johnson)
A.
Persons Contacted G. E. Attarian, Lead Electrical Engineer E. H. Chan, Lead Engineer Nuclear Steam Supply System P. C. Citera, Supervisor Vendor Quality Assurance J. T. Grillo, i.ead Electrical Engineer Y. C. Jain, Valve Contract Engineer R. B. Kosinski, Quality Assurance Audit coordinator R. Lloyd, Quality Assurance Engineer S. MacNaughton, Quality Assurance Engineer "J. F. Marek, Quality Assurance Auditor W. C. Definger, Supervisor Vendor Quality Assurance C. A. Peart, Valve Contract Engineer E. Powerman, Engineer T. Rock, Group Supervisor Design B. G. Schonbach, Lead Piping Engineer B. M. Schut: bank, Supervising Electrical Engineer
- S. Sparacino, Supervisor Quality Assurance Engineering "R. F. Williams, Supervisor Quality Assurance Engineering
- M. K. Yates, Engineering Manager E. Z. Zuchman, Project Engineer
" Denotes those present at exit interview.
B.
Action on Previous Insoection Findings L
(Closed) Deviatign Geport 80-01):
Contrary to Ebasco Topical Report trR-1001, suppliers have not been required in all cases to furnish a detailed fabrication sequence showing required tests and inspec-tions.
A revision to paragraph 4.1.1 of Section QA-II-5 of the Topical Report has been submitted to the Nuclear Regulatory Commission for review.
This revision waives the submittal of a fabrication sequence when manufacture is essentially simple and straight forward or when testing could be pri-marily used to establish the acceptability of a product.
In the contracts referenced in report No. 80-01, the suppliers nave furnished detailed fabrication sequences showing required tests and inspections.
2.
(Closed) Deviation (Report 80-01):
Contrary to Ebasco Topical Report ETR-1001 on the SNP 3/5 project, personnel other than the Project Quality Assurance Engineer are obtaining review and comments on procedures.
The WPPSS Project related Topical Report ETR-1001 has been modified in the WPPSS Manual of Procedures, Volume 2 to include a reference to Section QA-II-5 which states, "The Ebasco lead Discipline Engineer shall be responsible for the coordination of all review functions associated with supplier special process procedures."
3 3.
(Closed) Deviation (Report 80-02):
One of the IE Bulletin 79-14 orocedures developed for St. Lucie Plant, Unit 1, was inadequate and was not approved until work was virtually completed.
As the work on the St. Lucie Plant was essentially complete, Ebasco did not revise this procedure.
To prevent future occurrences of this type on IE Bulletin work, Ebasco will apply the formal "Ebasco IE Compliance Support Program," dated December 20, 1979.
This program requires the identification of all implementing procedures which will govern the task.
4.
(Closed) Deviation (Report 80-02):
Damping values used in seismic analysis for the as-built safety-related piping system for St. Lucie Plant, Unit 1, did not use the values provided in the SAR.
The adoption of the 2% damping instead of the 0.5% was prompted by NRC Regulatory Guide 1.61.
Ebasco has adequate procedures for reporting SAR change requests and should have reported this one.
To prevent recurrence, Ebasco has scheduled increased auditing of the pertinent procedures and has instituted a training program covering the imple-mentation of all Engineering Procedures referred to in its Tropical Report.
5.
(0 pen) Unresolved Item (80-01):
It is not clear wnether the PSAR commitments to ANSI daughter standards and/or the Gray Book for two (2) projects requires passing these commitments on to vendors either by incorporation or reference in the purchasa order, when applicable
+
to the vendor scope of work.
A response has been received from NRC/HQ indicating that when a project PSAR has committed to the ANSI daughter standards and/or the Gray Book, these should be passed on through the purchase order to suppliers of i
major or complex safety-related itecs by reference or inclusion of applicaole requirements.
For items not major or complex, judgemental factors indicate the applicability and determine the need to pass on the daughter standards.
Ebasco is performing further review to deter-mine which major complex safety related procurements still under active contract did not impose the daughter standard requirements (although committed to in the respective PSAR).
Requirements of the daughter standards will be added by change order.
This will be further inspected during the next regular inspection.
l 6.
(Closed) Followup Item (80-01):
It was abserved that the Ebsco Valve and Specialties List for WPPSS showed tne 8 Main Steam Safety Relief l
Valves as nonactive whereas the technical specification 3240-90 and the purchase order correctly identified the valves as active and imcased RG-1.48.
The Ebasco Valve and Specialties List for WFPSS I
has been corrected and reissued.
The previous issue had a typing l
e rror.^
i l
l k
4 7.
(0 pen) Followuo Item (80-01):
Determine the status and final disposition of PSAR Change Requests Nos. 83 and 84 for 1!PPSS which indicate adoption of a new QA program to replace ETR-1001 (which was adopted on PSAR Change Request No. 50) and the original QA program described in the PSAR.
8.
(0 pen) Followup Item (80-01):
Determine why procedure E-77 titled "Section Identification and Documentation of Design Inputs" is not listed in the Topical as a quality-affecting implementing procedure.
Also, why procedure E-77 does not reference E-52 titled " Coordination of NSSS Interfaces" or list codes, standards and regulatory require-ments (including applicable issue and/or addenda) per ANSI N45.2.11, Section 3.2.
C.
Followuo on Regional Reouests In this area of inspection three (3) regional requests relating to deficiencies or potential deficiencies were reviewed and evaluated by the inspector.
Each regional request is broken down into three (3) sections entitled " Objectives", " Method of Accomplishment," and " Findings," The regional requests are as follows:
1.
Containment Penetration Wires Broken Florida Power and Light Company reported to Region II that approxi-mately twenty instrumentation wire terminals have been broken on containment penetration for St. Lucie Unit 2.
Design and pro-curement were done by Ebasco.
Manufacture was done by Conax.
a.
Objectives (1) Determine responsibility for broken instrunentation wire terminals.
(2) Determine the cause or reason for the defective instru-mentation wire terminals.
(3) Jetermine if the QA program requirements have been violated.
(4) Evaluate the generic implications of the problem.
b.
Method of Accomolishment The preceding objectives were accomplished by discussions with Ebasco personnel and an examination of:
(1) Nanconformance Report NCR 1142E from FP&L - Terminals on wire numbers C3-9-2, -3,
-4,
-7, -8, and C3-22-4 cracked at bend.
5 (2) Ebasco Report, entitled, " Analysis of Ring Tongue Connectors Installed on Terminal Boards within Conax Electrical Penetrations supplied to St. Lucie Plant No. 2."
(3) Vendor Quality Assurance Report, entitled, " Electrical Equipment Report No. 29," dated June 25, 1979, which released the C7 cenetration.
c.
Findings (1) Cracked connectors were discovered by the Construction organization at the site when the penetrations were being installed.
There were a total of 41 electrical penetra-tions of wnich 20 had terminal blocks similar to those on which the cracks were identified.
A 100% check of all penetrations with similar terminal blocks was initiated.
In this check 11,940 connectors were examined.
The results showea 22 cracked connectors on penetration C3 and 1 cracked connector on penetration C7.
(2) The 41 electrical penetrations were manufactured by Conax and were put in storage at Conax in June 1975 due to schedule delays.
Ebasco was responsible for design, purchase and quality control of penetrations.
In May 1979 Conax received a purchase order to modify penetrations C3 and C7 to add 512/C *AWG feedthrus.
(3) Cracked connectors were limited to penetrations C3 and C7 both of which had conductor feedthru modules added at the Conax factory.
The additional feedthru modules were added to penetration assembly C3 first which had 22 cracked connectors.
The assembly methods were subsequently improved and refined for accomplishing similar work on unit C7 which only had 1 cracked connector.
To add the extra feedthrus, the original and new connectors had to be moved extensively.
In addition, the *8 AWG solid conductors have minimum flexi'ility which placed considerable stress on the ring o
tongue connectors when the connectors were moved.
(4) After the penetrations had been reworked they were put through a full electrical test which was witnessed by Ebasco and penetrations C3 and C7 passed.
This test included primary and secondary leakage checks, pressure check, continuity check, dialectric strength check, insulation resistance, and conductor resistance tests.
6 (5) The inspecion plan for the reworked C3 and C7 penetrations was essentially the same as the original plan for fabrication and assembly.
In the case of Ebasce it was identical.
Ebasco's inspection plan for the reworked C3 and C7 did not cover any examination of the in-process rework operations, but covered the final acceptance test at which time the penetrations were enclosed and the ring connectors were not visible for examination of surface defects.
(6) From the above discussions it is apparent that this is not a generic problem but is limited to a special rework case.
(7) Present QA practice is to inspect reworked parts, comoonents or assemblie.e to the same requirements as the original.
Ebasco recognizes tnat this practice needs to be amended to require special inspection plans for extensive or difficult rework operators.
(8) No deviations or unresolved items were identified in this area of inspection.
2.
Condensate Storace Tank Water Level Dedication Florida Power and Light Company reported to Region II that a nozzle was added in error to the piping located inside the condensate storage tank for St. Lucie Unit 2.
This piping is the suction leg for the condensate transfer pump and would have permitted the water to be removed below the dedicated water level.
The tank was designed by Ebasco and fabricated by CS&I.
a.
Objectives (1) Determine who was responsible for the error.
(2) Determine if any preventative measures can be or have been applied to this problem.
(3) Determine the cause or reason for the nozzle addition to the piping located inside the condensate storage tank.
(4) Determine if the QA program requirements have been violated.
(5) Evaluate the generic implications of the problem.
b.
. Method of Accomolishment The preceding objectives were accomplished by discussions with Ebasco personnel and an examination of:
7 (1) Specification FLO-2998-759 Refueling Water, Condensate Storage and Ofesel Oil Storage Tanks, Revision 4 dated June 11, 1975.
(2) Specification Study, Report Routing Sheet - 1st routing 6/8/76, 2nd routing 6/11/76.
(3) Sketch SK-2998-M-530(R13), Condensate Storage Tank.
(4) Design Change Notice DCN 513.895, St. Lucie Unit 2.
(5)
Letter FP&L to Ebasco dated August 11, 19F0, subject:
Condensate Storage Tank.
(6) Letter Ebasco to FP&L dated August 18, 1980, subject:
St. Lucie Unit 2 Condensate Storage Tank Nozzle, c.
Findings (1) During a general review of documents by the FP&L start-up group, an error was discovered in the design of the Concensate Storage Tank (CST).
The condensate transfer pump suction nozzle at the end of line number 8-C-76 was extended to the bottom of the tank by mistake such that the dedicated water level of the tank was violated.
(2) The above mentioned error, unless corrected, posed the following safety problem.
Although a safety-related leve:
switch is provided that would alarm in the control room alerting the operator that the tank is nearly empty, the CST could have drained to a very low water level through this ifne via the suction nozzle to the condensate transfer pump or the gravity feed line to the condenser hotwell, thereby violating the dedicated water level / volume requirement.
(3) The Unit 2 CST is a seismic Category I, tornado protected structure with nominal volume of 400,000 gallons.
A volume of 150,400 gallons of water is dedicated to meet the Unit 2 hot-standby and cooldown requirements througn the use of the Auxiliary Feedwater System.
Since the Unit 1 CST is not tornado
8 protected, a crosstie between the Unit 1 and Unit 2 tanks is also provided.
Therefore an additional volume of 150,400 gallons is reserved for Unit 1 in the Unit 2 CST in the unlikely event that the Unit 1 CST is lost during a tornado.
Hence a dedicated water volume of 300,800 gallons is to be main-tained in the Unit 2 CST to meet the Unit 1 and Unit 2 supply requirements for plant cooldown.
The additional volume in the CST is utilized as makeup watcr to the Unit 2 condenser hotwell as well as to collect the excess condenser hotwell water inventory during normal operation.
The connection between the CST and hotwell is via the condensate transfer pump /
gravity feed line.
In order that a water supply of 300, 800 gallons be maintained during normal operation, the nozzles which connect to the plants nonsafety secondary system are placed above the level of the dedicated water volume.
(4) The design error, attributable to Ebasco, occurred on sketch SK-2998-M-530 in Note 5 which states, " Entrance Elbow and 4" x 4" Vortex Plate 4" above bottom of Tank on nozzle Nos. 2, 4 & 5."
Nozzle 2 should not have been included in the note.
The sketch also showed a downcomer with the suction intake 4" above the bottcm of the tank.
This sketch went through a independent design review when the tank. specification was reviewed and was not detected.
The CST was built by CB&I according to Ebasco specifications.
(5) Design Change Notification OCN 513.895 was issued September 8, 1980, to correct this problem.
This DCN stated, " cut and remove downcomer and downcomer supports associated with Nozzle 2 (shown on attached pages.
4 ana 5 of Condensate Storage Tank) per attached instructions. Delete Nozzle 2 from note 5 of SK-2998-M-530 Revision 13 May 8, 1980."
(6) This problem is not generic, but was the iesult of a unica inter-relationship oetween Units 1 and 2.
(7) The Ebasco quality assurance program procedures are adequate in this area of design, and do not appear to have been violated.
This error appears to nave occurred due to the unusual sharing of the Unit 2 CST with Unit 1.
(8) No deviations or unresolved items were identified in this area of inspection.
t
s 9
3.
Potential Deficiencies in Design Verification anc Control of Design Intuts Region IV was informed that potential deficiencies in design verification and control of design inputs could exist on Ebasco designed nuclear facil-ities.
This information was furnished by the Office of International Programs of NRC as a result o* an audit by a foreign utility on design verification activities performed by Ebasco for a foreign nuclear facility.
a.
Objectives (1) Determine if the same quality assurance program is used by Ebasco in the design of foreign and domestic nuclear power plants.
(2) Determine if deficiencies exist in the quality assurance program for Ebasco design of domestic nuclear power plants in the areas of design verification and control of design inputs.
(3) Determ!ne the cause or reason for the alleged deficiencies in design verification and control of design inputs for the Ebasco designed foreign nuclear power piant.
(4) Determine if the QA program requirements have been violated.
b.
Method of Accomolishment (1) Section QA
-4, Revision 1, Nuclear Quality Assurance Program, entitled, " Design Control."
(2) Section QA-II-1, Revision 1, Nuclear Quality Assurance Program Manual, entitled, "Instruc-tions Procedures and Drawings."
(3) Company Procedure No. E-76, 1/20/80, " Guidelines For Design Verification."
(4) Company Procedure No. E-77,12/20/79, " Selection, Identification and Documentation of Design Inputs."
10 (5) Orawing Ncs. G107700-8, G130601-8 thru G130610-8, G324900-8 thru G325400-8, and G352100-8 thru G352400-8.
(6)
Specification Nos. 3240-501, 3240-90, 3240-410, 3240-53, 3240-53, and 87N-76Tb.
(7) Calculation No. 06.18.01-2, Pipe Schedule For RCS and SI Piping.
(8) Design Specification Check-off List for ASME Section III Code Class 1, 2, 3 and MC Components.
(9) WPP55 345 Occument: tion Review Requirements.
(10)
Letter Ferrari to McCarthy/ Hare, June 3, 1974, subject:
WPPSS Nuclear Project No. 3 applicable Criteria for Design Development of General Arrangement and Flow Diagrams.
c.
Findings (1) The inspector did not review the QA program procedures of the foreign nulcear power plant, but was informed by Ebasco personnel that they are similar to those used for domestic nuclear power plants.
(2) The inspector was informed that Ebasco has responded to the audit conducted by the foreign facility on design verification activities.
In this response Ebasco has indicated they can give the foreign utility the additional information and documentation they have requested and have established a price for furnishing it.
(3)
Ebasco replaced the first architect engineerning firm (AE) responsible for the design of this foreign nuclear power plant.
They did not attempt to go back and verify the designs of the first AE and were not furnished the design verifications performed by the first AE.
Some of this information is proprietary and could best be verified by the foreign utility who issued the contract.
(4)
In the audit performed by the foreign utility specificity was frequently brought up in discussions.
The foreign utility was interested in being able to go to their records and be able to determine exactly what design inputs were used and what methodology was used to verify the design.
Ebasco's present procedurs; do not require the indeoendent verifier to document the step by step activities he uses to verify a design.
However, a check sheet is used to assure the main points are considered and a signature or initials are required as evidence of the completion of the design review.
,-r
11 (5)
It is not the practice of Ebasco to verify that suocontractors correctly parform design verifica-tion on " design and build" contracts.
The foreign utility expressed interest in having some evidence in their records of how a suocontractor's design verifications were accomplished.
(6) Procedural deficiencies discussed in the foreign utility audit focussed on a lack of specificity and perhaps deficiencies in some of the procedures used on the foreign power plant design.
- However, one of the deficiencies discussed pertained to verifying calculations by the " alternate calcula-tion" method.
Alternate calculations are rarely used by Ebasco to verify calculations in their nuclear power plant design.
(7) A review of the procedures used by Ebasco for domestic power plant design, plus an examination of their imole-mentation did not disclose that any QA program requirements have been violated.
(8) No deviations or unresolved items were identified in this area of inspection.
D.
Exit Interview A meeting was conducted with management representatives of the conclusion of the inspection on October 24, 1980.
In addition to the individuals indicated by an asterisk in the Details Section, those in attendance were:
J. Gushue, Project Quality Assurance Engineer B. E. Tenzer, Vice President, Materials Engineering and Quality Assurance The inspector summarized the scope and findings of the inspection for those present at the meeting.
Management representatives acknowlecged the statements of the inspector.