ML19242C667

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QA Program Insp Rept 99900311/79-01 on 790521-23. Noncompliance Noted:Calibr Frequency for Micrometers & Calipers Not on three-month Schedule & Inadequate Calibr Labeling
ML19242C667
Person / Time
Issue date: 06/14/1979
From: Agee J, Hunnicutt D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19242C634 List:
References
REF-QA-99900311 99900311-79-1, NUDOCS 7908130170
Download: ML19242C667 (11)


Text

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMEST REGION IV Report No. 99900311/79-01 Prograa No. 51400 Ceopany:

General Electric Company Switchgear Business Department Burlington Manufacturing Operations Agency Road, P. O. Box 4S8 Eurlington, Iowa 52601 Inspection Conducted: May 21-23, 1979 Inspectors:

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d Y/7jP J. R. Agee, Contractor Inspector, Vendor

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D. M. Hunnicutt, Chief, ComponentsSection II,

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Date Vendor Inspection Branch

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Approved by:

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D. M. Hunnicutt, Chief, ComponentsSection II,

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Dite Vendor Inspection Branch Su=marf Inspection cc May 21-23, 1979 (99900311/79-01)

Areas Inspected:

I plecentation of 10 CFR 50, Appendix B criteria, and applicable codes and standards including: quality assurance manual / program; custc=er centracts/ design control, control of measuring and test equipment; and inspection and test. The inspection involved forty-tvs (42) inspector-heurs on site by two (2) NRC inspectors.

Results:

In the four (4) areas inspected, no apparent deviations or unresolved items were identified in two (2) areas. The following deviations and unresolved item were identified in the remaining areas:

Deviations: Control of Measuring and Test Equipment - a total of four (4) instruments were not calib:sted within the required calibration cycle (See Notice of Deviation, Ite: A).

Three (3) pieces of equipcent subject to calibration were not adequately identified (See Notice of Deviation, Item B).

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2 Unresolved Item:

Customer Contracts / Design Control - certain switchgear products not yet fully qualified to meet Class 1E criteria are in a scheduled qualifica-tion test program (See paragraph C.3.c.).

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3 Details Section (Prepared by J. R. Agee and D. M. Hunnicutt)

A.

Persons Contacted J. N. Allen, Quality Assuracce Engineer P. A. Bertrand, Manager, Quality Assurance G. L Burlingame, Manager, Employee and Community Relations

  • G. L. Cederquist, Manager, Power Vac Marketing C. W. Clark, Manager, Medium Voltage Engineering
  • H. D. Culley, General Manager, Power Systems Management Department, Philadelphia, Pennsylvania J. D. Lambert, Manager, Shop Operations
  • R. J. Moffa, Manager, Manufacturing Projects D. O. Nichols, Manager, Materials L. E. Schilling, Manager, Burlington Plant, Accounting B. J. Shaffer, Manager, Manufacturing Engineering W. C. Stalcup, Manager, Burlington Manufacturing Operation
  • Attended the exit meet tng only. All others attended both the entrance and exit meetings.

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B.

Quality Assurance Manual / Program 1.

Objectives The objectives of this area of the inspection were to ve'rify that the:

a.

QA Manaal had been maintained current as c:mmitted.

b.

Program had been implemented in such areas as auditing, traiaing, receiving inspection, and cocconformances.

2.

Method of Accceplishment The preceding objectives were accomplished by:

a.

Review of the following sections of the QA Manual:

(1)

A-5, Organization (2)

A-4, Quality Audits (3)

A-3, Training (4)

C-4, Receiving Inspection (5)

E-1, Control of Nonconforming Material

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4 (6) Quality Assurance Provision, Quality Control, No. 2-85.1400 (7)

C-2, Quality Control Approval of Raw Material Supplies b.

Discussion with plant management 7ersonnel concerning organi-zational changes, specifically concerning the Quality Assurance organizations whose functions formerly reported to a line organization, but which currently report directly to the Plant Manager.

A staff membe has been designated the authority and responsibility for auditing plant critical areas and functions with findings to be reported directly to the Plant Manager.

c.

Review of the QA department audit fi'_es which revealed that audits had been conducted in the manufacturing inspection, testing, and quality functions throughout thc plant. Detailed inspection of the Fabrication Area files revealed that audits had been conducted in this area to applicable QAIs (Quality Assurance Instructions) on the following dates: March 15, 1979; March 12, 1979; October 30, 1978; August 8-9, 1978; and May 2 1978.

Also, audits had been conducted in the following areas:

"inished Process, May 2, 1979; Program audit, April 26, 1979; QA S stem, April 23, 1979; and QA i

Manual, Sections B-2, B-3, August 28, 1978.

d.

Review of training records for management personnel whose activities affect qualities. These records revealed that each member had received additional training at the corporate training facilities in such areas as professional development and education, total quality control, productibility engineering, basic reliability, quality control, process ccatrol, and quality control engineering.

e.

Review of the training records for the quality assurance engineer (QAE) and process control engineers (PCEs).

These records revealed the QAE was qualified to ANSI N45.2.23 as an auditor.

The PCEs had educational backgrounds, specific on-the-jcb process and quality training and qualit'f training courses leading to qualifica-tion to ANSI N45.2.23.

f.

Review of receiving inspection praa. ices for incoming materials and determined that activities were completed in cc=pliance with i=plemented procedures. The NRC inspector traced typical electrical materials and related documentation from receiving through receiving inspection to st.orage and withdrawal to aanufacturing areas.

Control of the caterial is maintained by use of electronic data retrieval systems with terminals located at receiving, stockroca, warehouse, cacufacturing and adainistrative areas where instantaneous accountability of the caterials can be verified or processed to succeeding storage or use areas.

g.

Verified that nonconforming items are identified, segregated and stored in controlled areas. Use of the data retrieval system with 0,,; }

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5 efficiently located terminals permits early identity of nonconforming materials, minimizes storage time, and expedites disposition of the materials.

3.

Findings a.

Within this area of the inspection, no deviations or unresolved items were identified.

b.

Comments Related to Internal Audit Findings In contrast to the QAI which states audit findings must be responded to within ten (10) days, several internal audit findings from the audits identified in paragraph 2.c above, had not been responded to within the required ten (10) day period. The Company practice to cope with this type incident is to reeudit the quality function identified. The QA auditor's method for determining when to reaudit the finding is to retain the audit finding folder, as a reminder, until an appropriate time arrives to conduct the reaudit. While this practice does not violate specific QA Manual, QAI or 10 C'3, Appendix B criteria, it appears to be a cumbersome method for conducting reaudits and appears to be contrary to the intent of Criterion XVI of 10 CFR 50, Appendix B which states in part, ".

deffciencies, deviations... are promptly identified and corrected."

C.

Customer Contracts / Design Control 1.

Objectives The objectives of this area of the inspection were to verify that:

a.

Criteria f rom customer specifications had been adequately addressed including quality assurance requirements and applicable codes and standards.

b.

Design concepts had been adequatel. reviewed and approved in compliance with approved and established-procadures.

c.

Cocponents and equipaent desigaed for Class IE applications had been functionallv tested to meet custoaer specifications and referenced codes and standards.

2.

Methods of Acccmolishment The preceding objectives were accomplished by:

a.

Review of customer contract Requisition No. 311-06659, Order No.

9645-E-009.4 (January 10, 1978), and S0 Nos. 909103 and 909104 for 7200 V M/C Switchgear (Power /Vac).

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6 b.

Review of the Technical Specification (TS) 9645-E-009.4 which requires compliance to QA Specification No. 9645-G-QA-1, Revision 4, and Technical Specification for Seismic of Class LE Electrical Equipment No. 9645-E-091.0, Revision 3.

TS 9645-E-009.4 states in part,

. the equipment shall perform in accordance with the standards including but not limited to:

ANSI C37.09

- 1969Property "ANSI code" (as page type) with input value "ANSI C37.09</br></br>- 1969" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. C37.09A

- 1970 C37.90

- 1971 C37.9

- 1971 C37.90

- 1970 C37.20

- 1969, including revisicas of 1970, 1972, and 1974 C57.13

- 1968 N45.2.2

- 1972 IEEE 279

- 1971 323

- 1974 384

- 1974 NEMA CC-1

- 1975 EI

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- 1966 IPCEA-S-61-4C2 - 1973..."

";' '; 'All equipmeat shall be qualified in accordance with the provisions of IEEE No. 323."

Discussions with Quality Assurance and Engineering management c.

personnel regarding design, fabrication, functional, testing and qualification testing of metalclad, vertical lif t, Power /Vac switchgear products.

d.

Review of Ccspany correspendence letter 2904, dated March 13, 1973, entitled, " Power /Vac Test Report" which states in part, ".

While the Power /Vac design did perform excellently... the follcwing design changes are vital for Class 1E Power /Vac Nuclear Requisitions Review of Company letter 2906, dated October IS,1978, entitled, e.

"(A/E)/(Facility) Requisitica 311-06659, I/S No. 10, dated October 9, 1978, IEEE 323 Qualificatica Report (Custccer) Transmittal VDT-73/2463," which contains an enclosure entitled, " Qualification Report for Power /Vac Metalclad Switchgear Furnished en Requisitier 311-06639 for (Utility Site) Recirculating Pump Trip Ccatrol,"

approved and dated July 24, 1978.

f.

Review of Design Instruction No. DI-150.000, First Issue d.ted October 12, 1973, entitled, " Nuclear Class 1E (Safety Related)

Applications of Switchgear Asse=blies."

g.

Review of Design Instruction No. DI-191.001, Issue No. 2, dated October 25, 1975, entitled, " Seismic Design Instruction."

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Review of eight (8) single documents entitled, " Report of Test."

These documents were further identified as Report No. RT and Req. No. 706-602-3024 for Vacuum Metalclad with Power /Vac Circuit Breakers. These documents identify electrical test data of the following types of electrical tests that were conducted on the Power /

Vac circuit breakers:

(1) dielectric impulse (2) power frequency withstand test (3) corona test (4) radio influence voltage test i.

Review of the following drawings for Requision No. 9645-E-009.4-1 including:

(1) 0147D9244, Revision 1, August 16, 1978.

(2) 0147D9245, Revision 1, August 16, 1978.

These drawings for Metalclad Power /Vac switchgear were approved by the' customer for release for manufacturing.

j.

Review of customer requisition 366-14471 and S0 No. 909111 for Metalclad Power /Vac Switchgear. Also, review of Architect Engineer Technical Specification 300-03-A3, dated.3pril 15, 1974, which had been reviewed and approved by the related utility ccapany for seismic qualification testing of the switchgear manufactured by the S0 No. 909111.

3.

Findings a.

Deviations None.

b.

Cocments (1) The Power /Vac Metalclad Switchgear for Requisition 311-06659 (paragraph 2.e above) has been manufactured and shipped to the utility site with certified production test reports; however, final qualification of the equipment to pertinent IEEE standards for Class 1E applications is not complete since certain integral cocponents, specifically Class IE relays, have not been fully qualification tested to the required IEEE standards. The qualification report for this equipment states that the test program for the integral cceponents is scheduled for completion in late 1979.

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8 (2) The Power /Vac Metalclad Switchgear, Unit 102, Compartment B-001, Breaker-01 (paragraph j above) had been manufactured and was located in the final inspection and test area on the date of this inspection, May 23, 1979.

The switchgear was in final checkout for shipment to the designated test site for seismic testing under electrical load conditions.

Certain integral components that have been radiation aged will be installed for total test and evaluation.

The Power /Vac switchgear will be returned to the Burlington Plant for further re-evaluation and disposition following the seismic qualification test.

c.

Unresc1ved Items Certain switchgear products identified in paragraphs 3.b.(1) and (2) above, have not been fully qualified per documentation reviewed and/or by final qualification testing; however, the equipment is in a scheduled qualific? tion test program. The status of final qualification will be inspected during a subsequent inspection.

D.

Control of Measuring and Test Equipment 1.

Objectives The objectives of this area of the inspection were to verify that:

a.

A system has been established and is maintained to assure that tools, gages, instruments, and other measuring devices or materials used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accura:y within specified limits.

b.

Calibration records are maintained for each instrument and these records include the following information:

(1) Accuracy required and calibration results (2) Location for use (3) Calibration history (4) Calibration intervals and dates due (5) Person or agency performing all calibrations (6) Serial number or other identification for each standard used to perform the calibration (7) Name or acaber of the applicable calibration procedure O

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9 (8) Environmental conditions used during calibration (9) Equipment recall schedules 2.

Methou 4 Accomplishment The preceding objectives were accomplished by:

a.

Review of Switchgear Business Department (SED), Quality Assurance Instructions (QAI) No. 8.1, " Control of Mechanical Measuring Instruments," Revision 3, dated June 7, 1976.

This instruction states the requirements for the periodic calibra-tion check on mechanical measuring instruments. Measurement and control is accomplished through use of various types of inspection gages, jigs, and fixtures, b.

Review of SBD QAI No. 8.1.1, Revision 0, dated November 28, 1978,

" Test and Inspection Traceability Record."

This instruction provides a documented procedure for the trace-ability record of test and inspection equipment used for final acceptance prior to shipment.

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Review of SBD, QAI No. 8.1.8, Revision 1, dated September 13, 1976,

" Calibration Instructions for Test Equipment."

This instruction is used in conjunction with the "QC Operating Procedure of the Burlington Plant for Control of Electrical Measuring Instruments."

d.

Review of SBD, QAI No. 3.2, Revisica 1, dated November 13, 1974,

" Storage, Identification, Selection, and Set-up of Crimping Heads for application of Wire Terminals."

e.

Review of SED, QA! No. 3.2.1, Revision 2, dated Ncve:aber 11, 1975, "Calioration Procedures Micrcmeters and Calipers."

f.

Review of SBD, QAI No. 3.2.2, %vinon 0, dated May 10, 1974,

" Calibration Procedures Height Gage."

This procedure covers the accuracy checks of the height gages and related dial indicators.

g.

Review of SED, QAI No. 8.2.3, Revision 0, dated August 31, 1977,

" Control of Electrical Measaring Instruments."

This instruction states the requirements for the periodic calibra-tion check of electrical measuring instruments, h.

Review of SBD, QAI No. 8.2.5, Revision 1, dated Noveaber 10, 1976,

" Calibration Check of Torque Wrenches."

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Review of SBD, QAI No. 8.2.11, Revision 0, dated October 12, 1977,

" Process Controlling Instrumentation Calibration Procedure."

j.

Review of the Master Lists that established the frequencies of calibration.

k.

Verification of calibration status of randcoly selected instruments, tools, gages, and surface plates.

(Examples: both of the surface plates; two (2) of approximately twenty (20) CD micrometers; seven (7) of approximately thirty (30) instruments; five (5) of approxi-mately thirty (30) torque wrenches; one (1) of approximately five (5) dial calipers; and the working set of height gages).

1.

Review of instrument calibration record files located in the receiving inspection area.

Inspection of randomly selected instruments in the receiving m.

inspection area and in the switchgear frame assembly area.

3.

Findings a.

Deviations See Notice of Deviation, Items A and B.

b.

Unresolved Items None.

E.

Inspection and Test 1.

Cbjectives The objectives of this area of the inspection were to verify that:

Procedares have been implemented for inspection of the progressive a.

stages of the manufacture and assembly of switchgear prcducts.

b.

Procedures have been implemented for production testing of switcngear products at appropriate stages.

c.

Inspection and test personnel are separate and independent of manufacturing organizations.

2.

Method of Accomplishment The preceding objectives were accomplished by:

a.

Review of Quality Ass.rance Manual, Section D-2, In Process 'nd.

Final Inspection Test, dated May 24, 1978.

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11 b.

Review of the following Quality Assurance Instructions:

(1) 6.1.22, Inspection of Breaker Compartments - Vertical Lift Metalclad Equipment, Revision 0, April 16, 1974.

(2) 6.1.33, Test Procedures - Vertical Lift 4.16 KV Metalclad, Revision 1, April 29, 1977.

(3) 6.1.37, Final Assembly Inspection Metalclad Vertical Lift Switchgear, Revision 4, November 10, 1976.

(4) 6.4.2, Final Assembly Inspection Power /Vac Metalclad Switch-gear, Revision 0, September 9, 1977.

c.

Inspectica of assembly, inspection, and test practices for the vertical lift and pcwer/vac switchgear and determined that on an audit basis one (1) of each five (5) compartments assembled cust be signed off by the inspector.

Review of the 6.1.32-A Vertical Lif t Pre-Gage-Assembly Check List for several breaker compartments under assembly and verified that each had been inspected and signed off, as required. Reviewed test procedures and final test status of a typical vertical lif t 4.16 KV Metalclad project and verified that electrical test sheet and test "fixem items" had been completed, stamped, and signed off by the tester in accordance with QAI 6.1.33.

Reviewed the final assembly of a Power /Vac metalclad switchgear SO No. 909111 and verified that frame assemb1v, weld positions, cccponent installations, structural changes, wiring installaticas, and identifications were in agreement with the final assembly station drawings.

3.

Findings Within this area of the inspection, no deviations or unresolved items were identified.

F.

Exit Interview The inspectors ret with management representatives /dencted in paragarph A, above) at the conclusion of the inspection en May 23, 1979, at the Eurlington Plant. The inspectors summarize' the scope and findings of the inspectica involving the follow Eng subjects:

Quality Assuranct Manual / Program Custcmer Contract. / Design Control 1

Control of Measuri2g and Test Equipment Inspection and Test.

The canagement representatives had no ecmments in response to the items discussed by the inspectors.

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