ML20247J898
| ML20247J898 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1989 |
| From: | Baker E, Robert Pettis Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247J846 | List: |
| References | |
| REF-QA-99900505 NUDOCS 8904050114 | |
| Download: ML20247J898 (15) | |
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' ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION INSPECTION N0.: 99900505/89-01 DATE: January 23-27, 1989 ON-SITE HOURS: 42 CORRESPONDENCE ADDRESS: Mr. Cnarles R. Healy, Director Quality Assurance Ebasco Services Incorporated Two World Trade Center New York, New York 10048 ORGANIZATIONAL C0llTACT: Mr. Sal Sparacino, Manager, QA Engineering TELEPHONE NUMBER:
(212)839-2457 NUCLEAR INDUSTRY ACTIVITY:
Design, procurement, and quality assurance activities for several nuclear projects.
ASSIGNED INSPECTOR:
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(
R.'L. Pettis, Jr., Reactive IMspection Date Section No. 1, Vendor Inspection Branch OTHERINSPECTOR(S):
T. Tinkel, Consultant APPROVED BY:
US
[
23 E. Baker, Chief, Reactive Inspection Section No. 1, VIB Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B, Ebasco Topical Report ETR-1001 i
"fEcTear Quality Assurance Program Manual," and 10 CFR Part 21.
l B.
SCOPE:
Follow-up inspection to review records, procedures and interview I
personnel regarding Ebasco's SteamElectricStation(SES)procurementactivitiesattheWaterford3 during the period 1981-1983.
PLANT SITE APPLICABILITY: Waterford3SES(50-382).
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99900505
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'0 ORGANIZATION: EBASCO SERVICES INCORPORATED 4
NEW YORK, NEW YORK REPORT IHSPECTION N0.: 99900505/89-01 RESULTS:
PAGE 2 of 15
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A.
VICLATION:
Contrary to Section 21.31 of 10 CFR Part 21. Ebasco Services Incorporated placed two purchase orders (P0s), WP3-13587 and WP3-137680 for safety-related electrical material for Waterford 3 SES without specifying the requirements of 10 CFR 21 on the purchase order to the supplier (89-01-01)..
This is classified as a Severity Level IV violation (Supplement VII).
B.
NONCONFORMANCE:
Contrary to Ebasco Services Incorporated Procedure No. ASP-1-5, Issue "E," dated April 20, 1978, " Quality Assurance Evaluation of Suppliers,"
Ebasco placed 35 safety-related P0s with the Gismo Company without the supplier being on Ebasco's Approved Suppliers List (89-01-02).
C.
UNRESOLVED ITEM:
The NRC inspector was unable to review supplier evaluations performed by Ebasco New York Quality Assurance p'ersonnel for suppliers previously rejected by Ebasco but later approved and placed on Ebasco's Approved Suppliers List (89-01-03).
D.
STATUS OF PREVIOUS INSPECT 10tl FINDINGS:
Not Applicable E.
INSPECTION FINDINGS AND OTHER C0t1MENTS:
The inspection was performed as a follow-up to an, earlier inspection performed at Ebasco, New York (NRC Inspection Report No. 99900505/88-01),
which was prompted by a complaint of discrimination filed with the Depart-ment of Ldsor (DOL) by a former Ebasco employee and referred to the NRC.
The compla nt alleges that Ebasco had violated 10 CFR 50, Appendix B, and its internni procedures in the evaluation and approval of certain material and camponent suppliers for the Waterford 3 SES. Specifically, the alleger claims that certain suppliers were found unsatisfactory for supplying safety-related components and materials in the 1981-83 time frame.
- Further, the alleger claims, because Ebasco had already placed P0s with these suppliers and any delays'could impact unfavorably on the Waterford 3 SES construction schedule, Ebasco sent other auditorc (unqualified) to evaluate these suppliers who subsequently found them to be satisfactory.
'0 ORGANIZATION: E.BASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/89-01 RESULTS:
PAGE 3 of 15 To determine the validity of the above allegations, an NRC inspection 4
was performed at the Ebasco New York office in August 1988 to review the pertinent records and related procedures, immediately prior to the inspection, the NRC inspectors met with the alleger to identify more clearly the specific records and areas of concern. The results of this inspection are documented in NRC Inspection Report No. 99900505/88-01, dated September 28, 1988.
As a result, it was further determined by the NRC that an additional inspection be performed at the Waterford 3 SES to review Ebasco's i
procurement documents generated during this period in order to determine l
the safety-related significance, if any, associated with the alleger's j
concerns since these documents were not available during the August 1988 l
inspection. This report documents that review.
l 1.
Review of the Ebasco New York and Waterford 3 SES Approved Suppliers Lists (ASL)
It was alleged that Ebasco maintained a " supplementary Approved Supplier List (ASL)," known as the "Waterford 3 list," that included suppliers who could not be app' roved due to the lack of a 10 CFR 50, Appendix B quality assurance program.
However, due to the exigencies of the construction schedule, these suppliers were nevertheless utilized to provide safety-related components and materials for the katerford 3 SES project.
Background
The NRC inspectors revicwed the Ebasco files on-site that contained the list of approved suppliers used for the Waterford 3 SES project.
It was veterminca that Ebasco maintained two. separate lists for the reason toat suppliers contained on the Waterford 3 SES project list were unique to the project, and that the cost incurred by Ebasco to audit these suppliers would not be shared by other Ebasco projects.
The NRC inspectors reviewed both ASLs covering the period 1978-1984 and determined that suppliers utilized for safety-related materials at Waterford 3 SES were, with several exceptions noted, qualified to be included on Ebasco's ASL. The Ebasco New York ASLs and supple-ments reviewed were as follows: December 31, 1981; Harch 31, 1982; May 3, 1982; June 1, 1982; July 19, 1982; August 16, 1982; September 30, 1982; December 30, 1982; February 1, 1933; March 31, 1983; June 30, 1983; August 1, 1983; September 30, 1983; and December 30, 1983. The Ebasco Waterford 3 SES ASLs reviewed were
l ORGANIZATION 4:
EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/89-01 RESULTS:
PAGE 4 of 15 as follows:
January 6,1982; June 3,1982; November 22, 1982; j
March 9, 1983; June 17, 1983; September 8, 1983; and December 15, 1983.
Safety-related suppliers are those suppliers deemed capable by Ebasco to provide permanent plant material and equipment in accordance with the guidelines established by the Ebasco Licensing Department to be ASME Code Class 1, 2, 3, Seismic, or Electrical Class 1E. Nonsafety-related applies to all other permanent plant items.
According to Paragraph 7.1.3 of Ebasco Procedure No. QAP-9, Revi-sion 1, dated September 29, 1978, " Quality Assurance Vendor Evalua-tions," qualified suppliers are placed on the ASL by an Ebasco review of their Quality Assurance (QA) Program. An initial or pre-award i
audit is then conducted for those first time suppliers placed on the ASL, with a follow-up audit performed three years later, as deter-mined by the Ebasco Vendor Evaluation Group Leader. Suppliers included on the ASL, according to Paragraph 10.1.1, are those whose documented quality program and facility are considered " Satisfactory" in accordance with Ebasco Procedure No. QAP-9, Paragraph 7.7.1 and therefore authorized to receive a nuclear safety-related P0. At i
the end of the suppliers periodic audit date, the supplier must l
be reaudited or dropped from t'he ASL.
i It was noted that not all suppliers listed on the Ebasco Waterford 3 SES ASL were required to implement or maintain a full 10 CFR 50, Appendix B QA program.
In some cases, the quality requirements applicable to an order were defined in a procurement specification that was referenced in the basic P0 to a supplier. The range of i
l supplier quality programs required by these procurement I
specifications varied from some that were very limited to some that essentially required a complete 10 CFR 50, Appendix B program.
Examples of suppliers with whom Ebasco used a pro-curement specification to define supplier QA program requirements included: Appleton Electric, Wheatland Tube, Picoma Industries, Conduit Pipe Products, Crouse Hinds Company, Gismo Company, and the 0. Z. Gedney Company. All suppliers were included on the Waterford 3 SES " Supplemental" ASL and were scheduled for reaudit in early 1983.
In each case, P0s reviewed were for safety-related electrical material (i.e., galvanized rigid steel conduit, fittings, couplings and related interface material) and were placed by Ebasco during the 1978-1984 period time frame. Those P0s referenced Ebasco project specifications which in-turn referenced the QA requirements in accordance with Ebasco Speci-fication 860-80, "QA Requirements for Suppliers of Safety-Related
ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION N0.: 99900505/89-01 RESULTS:
PAGE 5 of 15 Equipment and Services," or Specification 860-72, " Quality Control Requirements for Suppliers of Equipment and Services." Project specifications referenced for the P0s reviewed were as follows:
LOV-1564.065,.066,.068,.124F,.249A,.249D,.249R,.270, and
.403.
Specification 860-72 outlines the QA requirements (which resemble a 10 CFR 50, Appendix B program) for nonsafety-related applications and then invokes 10 CFR 50, Appendix B, for all safety-related applications, whereas 860-80 imposes'the requirements of 10 CFR 50, Appendix B, and 10 CFR Part 21.
In five of the nine LOU Specifications referenced, either 860-80, or 860-72 specifications were imposed with the balance referencing only a paragraph requiring the supplier to submit a controlled copy of his Quality Control (QC) manual with his bid for Ebasco review. Prior to contract award, a review of the supplier's facility would be performed by Ebasco to evaluate the supplier's quality program.
Ebasco's acceptance of a " Limited QA" program for suppliers mentioned above raised concerns with the alleger that Ebasco was approving suppliers without their having a full 10 CFR 50, Appendix B, QA program.
It should be noted that suppliers not equipped to handle a full 10 CFR 50, Appendix B, QA program, due tothenatureoftheitembeing)suppliedtoWaterford3SES (i.e., galvanized rigid conduit were required to have a " limited" QA program incorporating only those items of Appendix B applicable to the product furnished.
In addition, Ebasco invoked by specifi-cation various technical and quality requirements (codes, standards, receipt inspection, tests, etc.) necessary to achieve compliance with the intent of Appendix B.
This methodology is discussed in the Introduction to 10 CFR 50, Appendix B which states, "the pertinent requirements of this appendix apply to all activities affecting the safety-related functions of those stuctures, systems, and components."
In addition, Criterion II, " Quality Assurance Program," states that the program shall provide control to an extent consistent with their importance to safety.
Therefore, the " Limited QA" program applied to these suppliers in the late 1970 time frame appeared to meet applicable regulatory requirements considering the relative safety significance of the material purchased. The NRC inspectors did not review each supplier's QA file to determine the extent that their QA program complied with the applicable portions of Appendix B.
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'0 ORGANIZATION:
EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION I
N0.: 99900505/89-01 RESULTS:
PAGE 6 of 15 l
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l It was noted during the inspection that 35 safety-related P0s were placed by Ebasco with the Gismo Company for various electrical interface material without the supplier's appearing on the ASL.
These P0s were placed during the period May 1978 through June
'980.
A review of Ebasco's ASLs also indicated that Gismo appeared on the ASL prior to and after the time period referenced. As a result, Nonconformance 89-01-02 was identified during this part of the inspection.
2.
Purchase Order Review - 10 CFR Part 21 During the NRC review of safety-related P0s generated by Ebasco, it was observed that the majority of the P0s invoked the require-ments of 10 CFR 21 on the supplier. However, two P0s failed to specify that Part 21 applied:
P0 WP3-137680, dated December 15, 1983, to Appleton Electric and WP3-13587, dated December 4, 1983, to Crouse Hinds (both for safety-related electrical interface material). As a result, Violation 89-01-01 was identified during this part of the inspection.
3.
Review of Ebasco Performed Supplier Evaluations l
In a letter dated March 8, 1983 from Mr. M. Brooks (Ebasco Site) to Mr. R. Williams (Ebasco, New York), it was discussed that several " key" suppliers of safety-related electrical material, i
soon due for reaudit have been rejected by New York Quality Assurance due to the suppliers' inability to comply with 10 CFR 50, Appendix B requirements. The suppliers referenced were the following: Conduit Pipe Products, Picoma Industries, Wheatland Tube Company, 0. 2. Gedney Company, Crouse Hinds Company, Electromark. Dismo, and Appleton Electric.
A review of the Ebasco Waterford 3 SES ASL, dated December 15, 1983 indicated that all eight suppliers were included on the ASL. The basis for placing these suppliers on the ASL was supplier audits performed by Ebasco New York auditors during the period March - May 1983.
As a result, these suppliers were deemed satisfactory and were placed on the ASL despite earlier rejection of these suppliers, i
The NRC inspectors were unable to review the Ebasco audits performed since the files are located at Ebasco's New York office.
As a result, Unrosolved Item 89-01-03 was identified and will be reviewed during a future inspection at Ebasco New York.
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1 ORGANIZATION:
EBASCO SERVICES litCORPORATED NEW YORK, NEW YORK REPORT INSPECTI0li NO.: 99900505/89-01 RESULTS:
PAGE 7 of 15 4.
Review of the Rotohammer Company Information obtained by the NRC during the August 1988 inspection of Ebasco indicated that safety-related valve stem extension material was purchased from the Rotohammer Company who, at the time, was not an approved supplier.
In addition, this breakdown was viewed by an Ebasco employee as being reportable to the NRC under the provisions of 10 CFR 21; however, the nonconformance reports generated by Ebasco
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indicated "not reportable."
In order to review this concern, the following Ebasco documentation was reviewed by the inspectors:
a.
Purchase Order NY 403568. This was the initial Ebasco PO l
placed with Rotohammer on January 11, 1977. A review of j
this purchase order indicated the following:
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l (1) The P0 was placed for various quantities of valve stem extension equipment which was classified as i
nonsafety-related.
l (2) The P0 invoked Ebasco st. edification LOU-1564.124, Revision 2, dated January 11, 1977. This specification applies to valve stem extensions for non-nuclear seismic and non-seismic valves. Paragraph 5 addresses seismic considera-tions and states that seismic I valves shall be considered non-nuclear, nonsafety, but shall be seismically supported.
The specification also invokes Ebasco specification 860-72,
" Quality Control Requirements for Suppliers of Equipment and Services," which states that this document covers quality control requirements applicable to suppliers of equipment and their subvendors.
In addition, 860-72 states that for safety-related material and services, the vendor's quality control program shcIl also meet the requirements of 10 CFR 50, Appendix B.
(3)
Fourteen supplements were issued against the initial P0 by Ebasco New York (Supplement 1, dated May 11, 1977 and Sup-plement 14, dated May 3, 1984). None of these supplements identified the material as safety-related, b.
Ebasco Nonconformance Reports (NCRs) W3-3828, W3-3930, and W3-3995 were reviewed which were generated against material ordered under Ebasco P0 NY 403568.
'0 ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/89-01 RESULTS:
PAGE 8 of 15 I
(1) NCR W3-3828, dated May 19, 1982. A review of this NCR indicated the material was shipped to Waterford in 11 separate lots and each documented by a separate Material Receiving Report (MRR). The description of.the nonconformance stated that all material was manufactured and supplied by Rotohansner and received between March 20, 1981 to May 19, 1982, during which time Rotohammer was not an approved supplier since their qualification i
expired in March 1980. The temporary disposition of the material was for Ebasco QC to confirm that the material was in an acceptable status at the time of issue and then to process the material on a conditior.a1 i
l release basis.
The recommended disposition was to I
requalify the supplier, review past history from March 1980 to June 1982 to determine any negative trends, and l
to obtain Certificates of Compliance (CoC) to the l
specifications. The NCR also indicated that the item l
was not reportable under either 10 CFR 50.55(e) or 10 l
CFR 21. The NRC inspectors requested documentation to i
support the basis fo,r the item being considered "not reportable;" however, documentation could not be produced by LP&L representatives during the inspection.
The NRC inspector reviewed the nature of the nonconformance and concluded that, although the material had been procured as nonsafety-related, Rotohamer material is used to operate valves from a l
retrote location via a mechanical linkage arrangement I
which utilizes a yoke and universal type joint. A further review of the application indicated valves were primarily loc 3ted outside of primary containment and served a passive function.
(2) NCR W3-3930, dated June 21, 1982. This material was supplied in three separate lots, and each documented by a separate MRR.
The description of the nonconformance stated that safety class material received on MRRs 204245, 205234, and 206028 was from an unapproved supplier.
The deportability block on the NCR was marked "not reportable."
(3) NCR W3-3995, dated June 24, 1982. This material was supplied in one lot and documented by Ebasco on MRR No. 200817.
The nature of the nonconforming condition
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ORGANIZATION:
EBASCO SERVICES INCORPORATED l
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PAGE 9 of 15 was again that Rotohammer was an unapproved supplier.
The supplier provided a CoC, dated June 11, 1982 (for MRRNo.206817), verifying compliance to Ebasco specification LOU 1564.124F and the P0.
As a result, Ebasco's decision that the nonconformances discussed in NCRs W3-3828. W3-3930, and W3-3995 were not reportable under 10 CFR 50.55(e) or 10 CFR 21, although not formally documented, appeared to be consistent with the potential safety significance of the item.
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c.
Documentation for PO WP3-8515
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(1) P0 WP3-8515. This PO was placed with Rotohammer by the Ebasco Waterford 3 SES on April 8, 1982. A review indicated that the P0 was for valve stem extension gear boxes and universal joints and was ordered as safety-related.
The order required a CoC stating that the materials supplied l
were equal to or better than material supplied on the originalorcer(NY 403568), and the provisions of 10 CFR 21 were specified. The Rotohammer CoC, dated April 20, 1982, I
stated conformance to Ebasco specification LOU 1564.124F and P0 WP3-8515.
(2) NCR W3-3754. This NCR was issued on May 5, 1982 due to Rotohammer not being an approved supplier and recommended reviewing their past history from March 1980 to June 1982 to determine any negative trends, and to obtain a CoC to the design specification.
The NCR disposition evaluation stated Rotohammer was reaudited and found to be satisfactory per Ebasco letter E823/298, cated June:28, 1982. As stated reviously, the deportability Llock on the NCR was checked p'not reportable" and the documented basis for such a state-ment was not available during the inspection.
1 (3) Ebasco memo, dated May 18, 1982. A memo from J. Gutierrez IEbasco (A Site Supervisor) to R. Hyme (Ebasco QA New York) discussing NCRs W3-3745 and W3-3754 was reviewed during the inspection. This memo stated that Rotohanner was initially evaluated and was considered to be an acceptable supplier; however, for some unknown reason, Rotohammer was not reaudited at the end of their three year qualification period.
Recommended action was to reaudit Rotohammer and l
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.ORGA0iZATION:EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/89-01 RESULTS:
PAGE 10 of 15 4
to ensure that appropriate personnel responsible for review and approval of P0s are retrained on the procedures. As a result, Ebasco Material Receipt Inspection Report (MRIR)
No. 82-03654 was issued on August 12, 1982 to accept the material which had been receipt inspected on MRR No. 204352.
]
The material was accepted by Ebasco site QC.-
d.
Documentation for P0 WP3-8653 This P0 was placed with Rotohammer by Ebasco site personnel on April 28, 1982. The order was for a valve stem extension yoke 1
adaptor and was ordered safety-related with 10 CFR 21 invoked.
A CoC was required and received on April 30, 1982 certifying that the material was equal to or better than that supp(lied on P0 NY 403568. Again, as in the past, an NCR was issued NCR W3-3745, dated April 30,1982) stating that Rotohammer was not listed on the Ebasco ASL, and therefore not an approved supplier. Tempo-rary disposition included vibroetching the material to show identification and maintain traceability prior to conditional release which was requested on Log No.82-078 and issued on May 18, 1982. The document cited NCR W3-3745 and stated that the material was required to support project start-up requirements with the approval based on the completion of the vibroetching.
Ebasco MRIR No. 82-01875 was issued on May 21, 1982 and the material conditionally accepted by Ebasco site QC.
e.
Approved Supplier Status Based on a review of the ASLs and other related documentation, the NRC inspectors confirmed that Rotohammer was not an approved supplier from March 1980 to June 1982.
LP&L computer data bases ZBS and PKG were queried in an attempt to independently identify which safety-related P0s were issued to Rotohammer during this period. A review of this data indicated that P0 WP3-9146, dated July 1,1982, was the next P0 issued to Rotohammer af ter the issuance of WP3-8653 on April 28, 1982.
Based en a review of other information, WP3-9146 was issued to Rotohammer after they were qualified as an a3 proved supplier.
A number of additional P0s were issued, but tie sequential number of the orders indi-cates they would have been issued after WP3-9146.
It was noted that P0 WP3-9146 was subsequently renumbered as WP3-9146A by a P0 supplement. This was done because another PO with the same
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' ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/89-01 RESULTS:
PAGE 11 of 15 WP3-9146 number was inadvertently issued to Capital Valve and Fittings. This review confirmed that Ebasco completely identi-fied all Rotohammer material (P0s WP3-8515 and 8653) ordered or received during the affected period when they were not an approved supplier.
f.
Classification of Rotohammer Material as Safety-Related The NRC inspectors interviewed several LP&L personnel in an
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attempt to better understand the~ application and safety signifi-
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cance of material ordered on the affected P0s. LP&L personnel stated that the apparent reason that Rotohammer valve stem extension material was ordered safety-related by Ebasco was because of an administrative procurement definition which stated that equipment attached to safety-related valves should also be procured as safety-related. They also stated that valves with Rotohammer stem extensions are utilized outside primary contain-ment and furthermore primarily have a passive function, in most cases, the valve stem extensions are used to allow the valves to be operated from a more convenient remote location.
In some cases, the location is in a lower radiation area thus providing reduced radiation exposure during operation.
From a safety standpoint, it appears that this material would not normally be ordered as safety-related since the valves are passive and could still be operated locally in the event of a failure of the Rotohammer renote operator linkage.
As a result, the purchase of this material from an unapproved supplier, although a procedural nonconformance, may not constitute a reportable condition to the NRC under the provisions of 10 CFR 21.
Since this condition was self-identified internally by Ebasco and proper corrective action was taken by Ebasco to satisfactorily disposition the material, a nonconformance to Ebasco procedures was not identified during this part of the inspection. The Ebasco reaudit of Rotohammer in June 1982 reviewed Rotohammer's QA program and its implementation for the period of March 1980 to June 1982, the period during which material was received by LP&L, but for which Rotohammer was not on the Approved Suppliers List.
5.
Review of the J. C. White Company During the NRC inspection at Ebasco in August 1988, additional questions concerning the activities which led LP&L to issue a Significant Construction Deficiency (SCD) Report to the NRC was
v ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO : 99900505/89-01 RESULTS:
PAGE 12 of 15 reviewed. The J. C. White Company manufactures material known as " TUBE TRACKS" and related hardware used by Waterford 3 SES to house and support instrumentation of both safety and nonsafety-related tubing. The P0s reviewed were designated as safety-related with 10 CFR 21 specified and Ebasco specification 860-78 which identifies the QA requirements for nuclear safety-related items and services. This specification requires the supplier to have a documented QA program which complies with the requirements of 10 CFR 50, Appendix B.
In addition, certi-fica +1on supporting the mater 41's rill test reports and certi-fiction of the material's chemical and physical specifications were also required from the supplier. Two P0s to J. C. White were reviewed by the NRC inspectors (WP3-2646, dated June 8, 1979 and WP3-2953, dated August 24,1979).
In both cases the material was procured safety-related with 10 CFR 21 specified. The material ordered comprised various tube track components such as yoke clamps and fasteners.
The P0sspecified that the material for the angles, channels, flat steel sections, and fittings be ASTM A-569 and/or A-570 and bot dipped. galvanized in accorde.nce with ASTM A-123.
Solid stain-less steel tube clamps were specified to be 304 stainless to ASTM A-479, while the yoke and bundla clamps were specified to be 304 stainless to ASTM A-240. During the process, additional supplements to the original P0 were issued by Ebasco changing the previous material specifications and downgrading the previous P0 to nonsafety-related.
In addition, a later supplement to P0 WP3-2646, Ebasco reclassified the material again as nonsafety-related. A similar series of events occurred for P0 WP3-2953 also. An explanation for this inconsistency could not be provided by LP&L during the inspection.
J. C. White provided certification for material ordered, however, could not in all cases provided certification documenting the mill test reports, as required by the P0. This lack of certification led to concerns about the chemical and physical properties of some of the tube track material and also the affect this may have on seismic performance. As a result, NCR WP3-2749 was issued on June 10, 1981 and was forwarded to LP&L on July 21, 1981 by Ebasco as potentially reportable incident No. 49. Ebasco QA report LOV-4294 evaluated NCR W3-2749 for deportability and concluded it was reportable under 10 CFR 50.55(e) and that, until reviewed further, the physical material properties of both ASTM A-569 and A-570 are questionable due to the fact that J. C.
White's ccality program, conditionally accepted by Ebasco on i
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' ORGANIZATION: EBASCO SERVICES INCORPORATED hF.W YORK, NEW YORK REPORT U
INSPECTION NO.: 99900505/89-01 RESULTS:
PAGE 13 of 15 August 15, 1978, was not being implemented by J. C. White for the manufacture of tube track and channel for the following P0s:
WP3-1608, 2646, 2953, 4464, and 5829.
The recommended disposition was to review J. C. White and it's subvendor's documentation for compliance with ASTM A-569 and A-570 and to evaluate chemical properties and requirements for acceptability of material.
In addition, the NCR stated that an Ebasco audit of J. C. White on May 22, 1981 noted that tube track material was not manufactured in accordance with 10 CFR 50, Appendix B, as required by the P0 referencing Ebasco specification 860-78 which specifies the requirements of Appendix B.
This condition eventually led LP&L to issue SCD Report No. 35 to the NRC. The final report was issued on August 29, 1983.
On December 22, 1981, Ebasco performed a follow-up QA audit of J. C. White which was documented in Ebasco letter E654/589, dated January 8,1982. This letter stated that J. C. White's corrective actions to the May and July audits were found satisfactory and was signed by the Ebasco Vendor Evaluation Group Leader.
Ebasco initiated a Design Chance Notice (DCN) to the Waterford 3 con-struction drawings on Lj 4, 1982 (DCN-NYC-IC-833), including Revisions 1 and 2, dated August 19, 1982. These DCNs changed drawings to establish maximum cantilever support spans for the tube track material which presumably would not violate maximum stresses in the material based upon Waterford 3 SES receiving the 1 east conservative material specification (i.e., ASTM A-569).
In order to provide a technical resolution that would be satisfactory for material that was already installed in the plant as well as material that was available for installation, an extensive material test program was initiated by Ebasco to determine the chemical and physical properties of the tube track material that had been supplied.
Results from these tests were used to justify the use of the tube track material for any of the designed applications, including seismic.
This was documented in NCR W3-6599 issued on July 26, 1983 and provides background information relative to the material certification concerns originally identified in NCR W3-2749. The NCR stated that an independent laboratory (Lucius Pitkin) performed testing on tube track fittings and found carbon levels as high as
.21 percent while ASTM A-569 specifies a maximum carbon content of.15 percent. The evaluation of the high carbon condition
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PAGE 14 of 15 indicated that due to the application of the fittings and with the existing material being weldable, the higher carbon content j
was acceptable. Attachment 1 to the flCR (memo to J. DeBruin to j
W. Yaeger, dated March 17,1983) stated that materials application i
engineering (Ebasco) had been working on a program to upgrade J. C. White tube track fittings so that they can be used for Seismic 1 applications. The memo further indicated that 315 J. C. White fittings would be shipped to Pitkin Laboratories for verifica-tion of both chemical and physical material properties.
I to the NCR (memo from L. Patrick to J. DeBruin, l
dated May 5,1983) discussed the results of the Pitkin Laboratory testing of the J. C. White fittings.
In summary, the memo concluded that based on the data obtained from this testing, including an evaluation of the service and load requirements for the applications, the tube track material could be used to support the Waterford 3 instrumentation tubing systems satisfactorily.
j i
A '.986 Tube Track catalog was reviewed during the inspection to b(nter understand products supplied commercially by J. C. White.
Tl e review indicated that with the exception of solid stainless siscer clamps, the items identified in the catalog were manufactured with commercial grade materials (e.g., 18-8 stainless and carbon j
steel).
It appears that the main technical difference between j
the items listed in the catalog and the itrms listed in the j
Ebasco P0s is that Ebasco invoked a material upgrade by specifying l
ASTM materials for manufacturing certain items instead of allowing commercial grade materials to be used during manufacturing.
As a result of the llRC review of concerns raised with the J. C. White Company's QA program, it appears that the concerns identified were satisfactorily resolved based upon Ebasco reaudits and adequate cor-rective action taken by Ebasco, J. C. White, and LP&L.
v
'0 ORGANIZATION: EBASCO SERVICES INCORPORATED NEW YORK, NEW YORK REPORT INSPECTION NO.: 99900505/89-01 RESULTS:
PAGE 15 of 15 F.
PERSONS CONTACTED:
Louisiana Power and Light
- L. W. Laughlin, Licensing
- N. S. Carns, Plant Manager
- J. J. Zabritski, Operations QA Mariager
- L. F. Lubinski, Procurement Representative
- M. A. Triggs, Nuclear Records Manager l
- L. L. Bass
- G. M. Davis, Events Analysis Manager
- P. V. Prasankumar, Assistant Plant Manager l
- J. E. Howard, Procurement Programs Manager
- D. V. Gallodoro, Procurement Engineer J. R. McGaha D. Gilley, Maintenance Engineer R. Bennet QA Supervisor j
T. Gerre-i, QA Manager J. Slegt.
Nuclear Safety Review Manager W. Morgan, QA Audit Supervisor NRC l
l
- Robert L. Pettis, Jr., Senior Reactor Engineer, NRC f!* Terrence L. Tinkel, NRC Consultant 6
W. F. Smith, NRC Senior Resident Inspector, Waterford 3 E. William Brach, Chief, Vendor Inspection Branch, NRC
- T. R. Staker, NRC Resident Inspector, Waterford 3
' Attended entrance meeting
- Attended exit meeting
-. _ _ _ _ _ _