ML20028A966

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QA Program Insp Rept 99900505/82-03 on 820817-20.No Noncompliance Noted.Major Areas Inspected:Status of Previous Insp Findings,Including Allegations Re Unqualified Personnel in Civil Engineering Organization & 10CFR50.55(e) Rept
ML20028A966
Person / Time
Issue date: 09/30/1982
From: Costello J, Hale C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20028A961 List:
References
REF-QA-99900505 NUDOCS 8211290262
Download: ML20028A966 (11)


Text

-

r ORGANIZATION: ' EBASCO SERVICES, INC.

NEW YORK, NEW YORK REPORT INSPECTION INSPECTION NO-99900505/82-03 DATE(S):

8/17-20/82 ON-SITE HOURS:

27 CORRESPONDENCE ADDRESS: Ebasco Services, Inc.

ATTN:

B. E. Tenzer, Vice President Materials Engineering and Quality Assurance Two World Trade Center New York, New York 10048 ORGANIZATIONAL CONTACT:

B. R. Mazo, Chief, Quality Assurance Engir.eer TELEPHONE NUMBER:

(212) 839-2830 PRINCIPAL PRODUCT:

Architect Engineering Services NUCLEAR INDUSTRY ACTIVITY: The total effort committed to domestic nuclear activities is approximately 50% of a 5,000 person staff.

Major projects include Shearon Harris, Units 1 and 2; St. Lucie, Unit 2; Waterford, Unit 3; and WPPSS, Unit 3.

There are also modification / repair service contracts on 10 additional reactor units.

ASSIGNED INSPECTOR:

k k _ OMzlb 9/ n/82 J.

~Costello, Reactor Systems Section (.RSS)

Date OTHER INSPECTOR (S):

O. k b S Ide

$r C. % /I d 9/3o/62.

APPROVED BY:

C

. Hale, Chief, RSS U

Dats INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 50, Appendix B, and Topical Report No. ETR-1001 SCOPE: This inspection was made as a result of:

(1) an allegation concerning B.

unqualified personnel being used in Ebasco's civil engineering organization; (2) a 10 CFR Part 50.55(e) report covering the main / emergency feedwater system of Waterford, Unit 3; and (3) a potential 10 CFR Part 50.55(e)/10 CFR Part 21 report covering the Westinghouse /Ebasco design interface for the Shearon Harris nuclear plants.

PLANT SITE APPLICABILITY:

The contents of this report relate to the following Docket Nos.: 50-382, 50-400, and 50-401.

pEncygg ORMUgg(

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l 8211290262 821108 PDR GA999 EECEB AS 99900505 PDR

c ORGANIZATION: EBASCO SERVICES, INC.

'NEW YORK, NEW YORK REPORT INSPECTION N0: 99900505/82-03 RESULTS:

PAGE 2 of 5 A.

VIOLATIONS:

None B.

NONCONFORMANCES:

None C.

UNRESOLVED ITEMS:

None D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

The actions taken by Ebasco relative to the following items were not inspected during this inspection;and,therefore, they will remain open until a future inspection.

1.

(0 pen) Nonconformance (82-02): The control of as-built drawing revisions was not handled by the Waterford No. 3 Drawing Closecut Schedule as evidenced by the fact that the March 31, 1982, issue of the schedule did not show Design Change Notification DCN-MP-589 as outstanding against design drawing LOU-1564-G-195.

2.

(0 pen) Unresolved Item (82-02):

Certain safe shutdown analysis may not meet regulatory requirements in that they do not appear to be sufficiently detailed with respect to design assumptions, bases, sources of inputs, reference to plant physical arrangement drawings, analytical models, change control, and interpretation of results.

E.

OTHER FINDINGS OR COMMENTS:

1.

Allegation - An undated letter was received from an Ebasco employee which stated:

(1) the Division Chief of the Ebasco Civil Engineer-ing Design and Drafting Department at the Jericho, New York, facility had no formal engineering education in this country in civil and nuclear engineering; (2) he did not have a Professional Engineer License; and (3) two other members of the Division Chief's staff, a lead engineer and a principal engineer, were not qualified as professional engineers.

Concern was expressed that if the Division Chief, the key man who directs the engineering and design of power plants, and his staff are not qualified, there is a definite danger involved in the safety of the plant.

ORGdNIZATION: 'EBASCO SERVICES, INC.

NEW YORK, NEW YORK REPORT INSPECTION N0.:

99900505/82-03 RESULTS:

PAGE 3 of 5 The inspector reviewed the personnel records of the three individuals named in the allegation.

The personnel records showed that all three individuals had Bachelor Degrees in civil or architectural engineering from foreign universities in 1953, 1958, and 1960.

Two of the individuals had Master Degrees in civil engineering and the Division Chief had an MBA in business.

There was no evidence in the personnel files that these degrees had been verified by Ebasco before or since their employment; however, the Division Chief had 28 years of engineering experience,18 years of which was with Ebasco.

The other individuals had engineering experience of 21 years, 9 years of which was with Ebasco, and 22 years,12 years of which was with Ebasco. None of the individuals were registered as professional engineers.

None of the job requirements for the positions held by these individuals require professional engineering registration.

The Design and Drafting Department is not the key function in design, as all of their work is reviewed and approved by the lead civil engineer, and any design document that must be sealed is reviewed and approved by a registered professional engineer. With these individuals' length of work experience and the subsequent review of their work by others, the inspector does not consider this a safety matter of any consequence, and considers this item closed.

2.

Potential 10 CFR Part 50.55(e)/10 CFR Part 21 Report - A concern developed that comunication between Ebasco and Westinghouse on design changes had not been fully effective and could affect design work.

Preliminary investigations indicated that differences might exist between the Ebasco design inputs used by Westinghouse in their original calculations and the current Ebasco designs which have undergone changes.

As a result of this concern, Carolina Power & Light Company notified Region II of the NRC on May 21, 1981, that this concern was potentially reportable under 10 CFR Part 50.55(e) and 10 CFR Part 21.

In order to determine the extent of this problem, improve the method of comunicating changes, reconcile any potential mismatch, and assure coordination of future design changes, the following steps we teken by Westinghouse and Ebasco:

a.

Westinghouse generated a list of Ebasco documents used in their design /a.'alysis efforts. This list was reviewed by Ebasco.

ORGANIZATION: EBASCO SERVICES, INC.

NEW YORK, NEW YORK REPORT INSPECTION NO.:

99900505/82-03 RESULTS:

PAGE 4 of 5 b.

Ebasco generated a list of Westinghouse documents in conjunction with those documents identified on the Ebasco Manufacturing Drawing Review and Control (EMORAC) list which were used for design.

This list was reviewed by Westinghouse.

c.

Ebasco generated a list of Ebasco drawings used by Westinghouse for design / analysis, d.

Ebasco assisted Westinghouse in identifying changes in previous drawing revisions by providing Westinghouse with all available Design Change Notices (DCN).

)

e.

Ebasco changed their procedures and will identify changes in l

future revisions of interface drawings by providing Westinghouse with a copy of applicable DCN's.

f.

As work progresses, Westinghouse provides a listing of Ebasco inputs used in Westinghouse design for Ebasco's review and confirmation.

l A reanalysis was completed of the DCN's which described system-related i

l piping changes that could impact proof-of-design calculations.

With one minor exception which was not safety-related, this reanalysis l

concluded that the DCN's which were reviewed had no significant impact on system performance.

As a result, Carolina Power & Light has now con-cluded that this potential deficiency was not reportable.

The resultant upgrading of the EMDRAC system now assures that Westinghouse will be notified on any DCN that affects an interface document as soon as it is written, rather than waiting until it is incorporated into the interface drawing.

I I

The inspector reviewed the generic aspects of this problem and l

found that the conditions of the Westinghouse /Ebasco design l

interface which pertained to the Carolina Power & Light Company /

l Shearon Harris project did not pertain to the Combustion Engineering /Ebasco design interface that affects the other Ebasco projects. The Combustion Engineering /Ebasco design interface requires that any proposed design change to an interface document be approved by Cc-bustion Engineering before it is approved by Ebasco.

No nonconformances or unresolved items were identified in this area of inspection.

i l

1

ORGANIZATION:

EBASCO SERVICES, INC.

NEW YORK, NEW YORK REPORT INSPECTION NO.:

99900505/82-03 RESULTS:

PAGE 5 of 5 3.

10 CFR Part 50.55(e) Report - Louisiana Power & Light Company notified Region IV of a potential design deficiency regarding the ability of the plant protection system to detect and respond adequately to a break in the feedwater system piping inside containment.

Ebasco identified the problem when they were making changes to the Emergency Feedwater Instrumentation.

A review of the Main and Emergency Feedwater System revealed that if a pipe break occurs in the feedwater line inside containment (between tne containment penetra-tion and either check valve 2FW-V825A or 2FW-V826B), the Emergency Feedwater System may not perform as intended.

To assure that the Emergency Feedwater System will perform as intended, it was proposed that the intervals of check valves 2FW-V825A and 2FW-V8268 be removed. This action would enable the steam generator instrumentation to detect and respond to a feedwater break anywhere inside containment. However, upon an Emergency Feedwater Actuation Signal, these modifications could result in the loss of inventory from the intact steam generator through the break via a cross-connection in the Emergency Feedwater System.

To alleviate this, a check valve will be added downstream of each emergency feedwater flow transmitter.

This action will be completed and a final report issued to Region IV by September 30, 1982.

In reviewing the sequence of events that led to this modification, 1

specific problems in the design process could not be identified.

The valves were installed approximately 9 years ago and at that time j

l the only line break analyses considered inside containment were at i

the nozzles of the steam generator.

Further, the feedwater line could classify as a super pipe in which case no action would be required.

No nonconformances or unresolved items were identified in this area of inspection.

l l

l PERSONS CONTACTED Company

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Dates Avsv14 11-2 c.1982 Docket / Report No. S99 0 ofd(/82-03 Inspector

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