ML16342B848
| ML16342B848 | |
| Person / Time | |
|---|---|
| Issue date: | 01/15/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML16342B847 | List: |
| References | |
| REF-QA-99900772 NUDOCS 9202030051 | |
| Download: ML16342B848 (10) | |
Text
Enclosure 1
NOTICE OF NONCONFORMANCE NEI Peebles Electric Products, Inc.
Cleveland, Ohio Docket No. 99900772 During an inspection conducted at the facility of NEI Peebles-Electric Products, Inc.
(P-EP) in Cleveland; Ohio, August 5
through 9, 1991, the U.S. Nuclear Regulatory Commission (NRC) inspection team determined that certain activities were not conducted in accordance with NRC requirements, which were contractually imposed on P-EP by purchase orders from NRC licensees.
The NRC has classified these
- items, as set forth
- below, as nonconformances to the requirements in Appendix B to Title 10, of-the Code of Federal Re ulations, Part 50 (10 CFR Part 50),
imposed on P-EP by purchase order contracts with NRC licensees and by P-EP's "Quality Assurance Manual No. 100,"
(QAM-100), revision dated November 1,
1984.
A.
Criterion III, "Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to ensure that applicable regulatory requirements and the design bases are correctly translated into specifications,
- drawings, procedures, and instructions and that design changes shall be subject to design control measures commensurate with those applied to the original design.
American National Standards Institute (ANSI) N45.2.11, "Quality Assurance Requirements for the Design of Nuclear Power-Plants" (1974),
endorsed in NRC Regulatory Guide 1.64, "Quality Assurance Requirements for the Design of Nuclear Power Plants" (Revision 2, June 1976),
and imposed on P-EP by Pacific Gas and Electric Company's (PG&E's) purchase order for the new (No. 2-3) emergency diesel generator (EDG) set for the Diablo Canyon Nuclear Power Plant Unit 2 (DCNPP2) requires, in part, that (1) measures shall be applied to verify the adequacy of the design; (2) design verification shall be performed by competent organizations other than those who performed the original design; (3) the results of the design verification efforts shall be clearly documented and auditable against the verification.methods; and (4) where changes to previously verified designs have been
- made, design verification shall be required for the
- changes, including, evaluation of the effect's of those changes on the overall design.
A,
Contrary to these requirements, in Section 3, "Design Control," of QAM-100, P-EP failed to (1) establish adequate measures to control changes in design, materials, and manufacturing processes commensurate with those controls applied to the original design or (2) provide for performing design verifications of the changes in design, materials, and maqufacturing processes.
P-EP, in its design-basis reconciliation and verification of changes that affect.the design of PG&E's 1990 generator to the design basis for the original 1969 generator, failed to demonstrate (1) that the changes in the design were controlled commensurate with the design controls applied to the original design and (2) that the original design basis had been correctly translated into revised specifications,
- drawings, procedures, and instructions.
PG&E's purchase order required that the new generator for DCNPP2 be identical (i.e., like-for-like) to DCNPP's five existing operating generators (original 1969 design basis) and its 1986 spare generator.
'However, P-EP's design-basis reconciliation and verification of the design changes for PG&E's generator were documented and verified only to the 1984 timeframe; when the Cleveland manufacturing facility was closed.
- Thus, P-EP did not perform an adequate design-basis re'conciliation or verification of the generator's design changes to ensure the adequacy of the design, and the effects of those changes on the generator's overall design (Nonconf ormance 99900772/91-01-01)
Criterion III, "Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that measures be established.for the identification and control of design interfaces and for coordination among participating design organizations.
These measures shall include the establishment of procedures among participating design organizations for the review,
- approval, release, distribution, and revision of design documents involving design interfaces.
ANSI N45.2.11-1974, imposed on P-EP in PG&E's PO for the generator requires, in part, (1) that the external interfaces between organizations performing work affecting quality of design shall be identified in writing and shall include those organizations providing criteria, designs, specifications, and technical direction; (2) that the responsibilities of organizations shalg be defined and documented in sufficient detail to cover the preparation,
- review, and approval of design documents involving design interfaces; (3) that systematic methods shall be established for communicating needed design information across external design interfaces, including changes to the design
J
information as work progresses; and (4) that design information transmitted from one organization to another shall be documented in specifications,
- drawings, or other controlled documents that are uniquely identified and issued by authorized persons.
Contrary to these requirements, in Section 3 "Design Control," of QAM-1~0, P-EP failed to establish adequate measures to control the design interface between it and its sister organization, Peebles'lectrical Machines (PEM) of Edinburgh, Sco'tland, that consisted of the review, approval,
- release, distribution, and revision of design documents affected by their design interface.
P-EP failed to demonstrate that the results of PEM's design translation activities were equivalent to the design requirements specified by P-EP.
P-EP provided its design drawings and specifications to PEM because PEM manufactures P-EP's generators.
PEM's engineering organization translated P-EP's design specifications into its own PEM specifications,
- drawings, procedures, and instructions.
The documents produced by PEM were not reviewed or approved by P-EP before use, and PEM-initiated design 'changes that were not controlled by documented procedure until December
- 1990, when PEM issued Departmental Procedure No. DP03A004, "Processing of Eng'ineering Change," well after the design activities for PG&E's generator were completed.
Although P-EP performed equivalency evaluations of PEM's procedures and material specifications used to fabricate and assemble PG&E's generator, P-EP did not adequately document (1) the'ritical requirements or acceptance criteria compared during the equivalency evaluation and (2) the results of the equivalency evaluation or other bases to support P-EP's conclusion that PEM's procedures and specifications were equivalent (Noncon formance 99900772/91-01-02)
Criterion III, "Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that measures be established for the selection and review for suitability of application of materials,
- parts, equipment, and processes that are essential to the safety-related functions of the component.
Criterion VII, "Control of Purchased Material,.Equipment, and Services,"
of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to ensure that purchased
- material, equipment, and services conform to the procurement documents and include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the supplier, inspection at the supplier
- source, and examination of products upon delivery.
I k
- requires, in part, that design inputs (1) shall be identified, documented, and their selection reviewed and approved and (2) shall, be specified and provide a consistent basis for making design decisions, accomplishing design verification measures, and evaluating design changes.
Contrary to these requiremeats, in Section 3, "Design Control," and Section 7, "Control of Purchased Materials, Equipment, and Services," of QAM-100, P-EP failed to establish adequate measures to provide for the selection and review for suitability of the application for materials,
- parts, and equipment that were procured as commercial grade items and were essential to the generator's ability to perform its intended design and safety-related function.
P-EP failed to adequately verify the properties or attributes of certain materials,"parts, and equipment that were utilized in the fabrication and assembly of PG&E's generator and that also directly affect the generator's ability to perform its intended design and safety-related function.
Specifically, P-EP,failed to ensure the suitability (1) of the stator coil's resistance temperature detectors, slip rings, adhesives, and mounting sleeve.
insulator for the slip rings and (2) of the materials,
- parts, and equipment PEM procured (Nonconformance 99900772/91-01-03).
Criterion V, "Instructions, Procedures, and Drawings," of Appendix B to 10 CFR Part 50, requires, in part, (1) that
'easures be established to ensure that activities affecting quality be prescribed by documented instructions,
'rocedures, or drawings; (2) that activities affecting quality be accomplished in accordance with these instructions, procedures, and drawings; and (3) that these instructions, procedures, and drawings include quantitative or qualitative acceptance criteria for.determining that important activities have been satis factorily accomplished.
Contrary to these requirements, in Section 5, "Instructions, Procedures, and Drawings," of QAM-100, P-EP failed to establish adequate measures to ensure (1) that all of the activities affecting quality were prescribed by documented instructions, procedures, or drawings and (2).that the instructions, procedures, and drawings include quantitative or qualitative acceptance criteria for determining that important activities were satisfactorily'ccomplished.
h
P-EP failed to demonstrate that the activities affecting quality (1) to fit the dovetail rotor pole assemblies to the rotor spider assembly, (2) 'to perform the brazing required to fabricate the rotor spider assembly, and (3) to perform brazed joint spliced-connections in the field coil winding were documented or accomplished in accordance with.
instructions, procedures, or drawings that contained quantitative or qualitative acceptance.e criteria and were equivalent to those specified by P-EP (Nonconformance 99900772/91-01-04).
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Dated at Rockville, Maryland, this 15th day of January 1992.