ML20005E979
| ML20005E979 | |
| Person / Time | |
|---|---|
| Issue date: | 02/24/1989 |
| From: | Jeffrey Jacobson, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20005E972 | List: |
| References | |
| REF-QA-99901011 99901011-88-01, 99901011-88-1, NUDOCS 9001120128 | |
| Download: ML20005E979 (6) | |
Text
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_4-ORGAlllZAT10ti: TELEMECANIQUE,INC.
WESTHillSTER,11ARYLAND kEPORT' INSPECTION INSPECTION t
tiO. : 99901011/88-01 DATE: 12/14-15/88 Oll-SITE HOURS:
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CORRESPONDENCE ADDRESS: Mr. M. Fenneteau Quhlity Assurance Manager 4
Telemecanique, Inc.
2002 Bethel Road Westminster, Maryland 21157-1 ORGA!112AT10NAL CONTACT: Joe Destefonu TELEPHONE NUMBER:
301 876-2214 NUCLEAR INDUSTRY ACTIVITY:-
Telemecanique, Inc.,- manufactures and provides replaceuent coniponents for motor control centers used in nuclear power, plants.
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L ASSIGilED INSPECTORT 2-oao 2-2445 J. B. Jacobson' Yeac"ive' Inspection Section No. 2 Date-(RIS-2)
OTHER. INSPECTOR (5):
APPROVED BY:
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Oldis Potapovs, Section Chief EIS-2, Vendor Inspection Date Branch It!SPECTION BASES AND SCOPE:
A.
BASES: Appendix B to 10 CFR Part 50 and 10 CFR Part 21.
B.
SCOPE: The inspection was conducted to review activities relative to TeTemecanique's supply of replacenent molded case circuit breakers to the l-
. nuclear industry.
i PLAllT SITE APPLICABILITY: All nuclcar plants using Telemecanique motor coritrol centers.
9001120128 900105 PDR QA999 EMVTEMEC 99901011 PDC i
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REPORT INSPECTION NO.: 99901011/88 RESULTS:
PAGE 2_of 6-
'A.=
VIOLATIONS:
None
-B.
NONCONFORMANCES:
Contrary to. Criterion V of Appendix B to 10 CFR Part 50 and Telemechaniques's Quality Assurance procedures 4.0, Telemecanique has not implemented measures as necessary to ensure that certificates Lof conformance (C of C's)Jare received from subvendors before material
-is dedicated and-released by Telemecanique. Additionally the originator of-the C of C's has not been audited by Telemecanique as necessary-to verify'the validity of the C of C's.
(88-01-01)
C.
STATUS OF PREVIOUS litSPECTION FINDINGS:
Not reviewed during'this inspection.
D.
OTHER:FINDilt65 AND COMMENTS:
-1.
During the inspection, a review was conducted of Telemecanique's supply of molded case circuit breakers to the nuclear industry.
All circuit breakers sold by Telemecanique to the nuclear industry are procured commercial _ grade from Siemens Energy and Automation, Inc. (Siemens) and then dedicated by Telemecanique for -safety-related service. All-breakers are procured direct from Siemens and are supplied from Siemens' Belle Fontaine, Ohio distribution f acility. No instance of Telemecanique procuring breakers from distributors or from other than Siemens was noted during tne inspection.
Quality Assurance Procedure (QAP) 4.0 delineates the purchase procedures to be used for procurement of all nuclear grade material.
QAP 4.0, also includes a table which lists the particular industry standards to be invoked for particular types of components (i.e.,
HEMA AB1, UL 489 for molded case breakers). Breakers are normally ordered from Siemens on a per job basis and generally are not stocked at Telemecanique. A C of C is required from Siemens for all breakers to be dedicated for safety-related applications.
Upon receipt at Telemecanique the breakers undergo a receipt inspection in accordance with QAP 10.0 which requires a visual inspection and documentation review. This inspection is performed
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"' ' a ORGANIZATIONi TELEMECANIQUE,INC.
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WESTitlNSTER, MARYLAND:
REPORT. -
IHSPECTION N0.: '99901011/88-01 RESULTS:
PAGE 3 of 6 on samples only, in accordance with Military Standard 105D.
Af ter receipt inspection, all breakers to be' dedicated for safety-related applications are tested in accordance with -
QAP 11.0. -QAP 11.0 requires an overload test at 300% of rated current and also an instantaneous check as described in flEMA AB2.
In addition, a continuity and a five cycle mechanical check are performed.
2.
Supplier Review in order to' determine whether Telemecanique might have procured any breakers from companies other than original manufacturers, a computer generated list of all Telemecanique suppliers dating back to 1985 was requested. This list was reviewed and was not found to contain any companies suspected of supplying potentially defective refurbished equipment.
3.
Purchase-Order-Review In order to confirm the implementation of the Telemecanique prucurement process, purchase order (P0) RS 0005437 from Houston Power and Light to Telemecanique for 3 ITE Gould HE3B090 molded case circuit breakers was reviewed. The P0 invoked 10 CFR Port 21, 10 CFR 50 Appendix B, and Telemecanique's quality assurance program and procedures. Telemecanique procured the subject breakers from Siemens via P0 27735. Telemecanique ordered the breakers commercial grade and specified that the breakers must meet design and test requirements of NEMA-ABl. The Telemecanique purchase order also asked for a C of C.
Upon receipt at Telemecanique the breaker was recei.ot inspected and subjected to an overload test in accordance with HEMA AB2. A thermal trip test was performed at 300% current (270 amps) and an instantaneous trip test was performed at approxi-mately 900% - 1000% current (812 - 1000 amps). The breaker trip times were found to be within the limits established by NEMA AB2.
During review of this documentation it was noted that a C of C had not been received frou Siemens for these breakers.
Furthermore, the receipt inspection sheet for this order did not indicate that the C of C was missing even though this was supposed to be checked for in accordance with QAP 10.3.
Upon interviewing the receipt inspection persunnel it was discovered that the C of C's often do not accompany the circuit breakers received from Siemens and therefore, this was not an unusual occurrence. Upon further review it could not be determined at what point in the
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l]i ORGANIZATION: TELEMECANIQUE,114C.
WESTMINSTER, MARYLAND REPORT INSPECTION.
'N0.:
99901011/88 RESULTS:
PAGE-4 of 6 Telemecanique process documentation is checked. As evidenced by this order, it does not appear a method exists at Telemecanique for holding material until all required documentation is received and reviewed. Nonconformance 88-01-01 is cited in Section B of this report as a result of this finding.
In addition to the above order, PO 514834 from Kansas Gas and Electric to Telemecanique for 2 ITE Gould HE3B100 molded case circuit breakers was reviewed. The P0 invoked IEEE 323, Bechtel specification 10466-E-018, 10 CFR Part 50, Appendix B, and 10 CFR=
Part 21.
In addition the P0 required the instantaneous trip setting to be 1000 amps minimum. This setting would allow even a greater margin than the published trip curves for this breaker which indi-cated a 1200 amp minimum setting.
Telenecanique ordered the subject breakers from Siemens via P0 S22428 and also asked for the 1000 amp minimum trip. Upon receipt at Telemecanique the breakers were tested and found not to be in~accordance with the 1000 amp trip requirement. Additional breukers were ordered and these also would not meet the 1000 amp requirement. The breakers exhibited trip values in the 900 amp range below the 1000 amp minimum requirement. Upon discovering that the breakers would-not meet the 1000 amp requirement, Teleme-canique informed Kansas Gus and Electric who in turn revised their purchase order deleting the 1000 amp requirements.
It is unclear why the breakers tested did not meet the published trip curves which would indicate a minimum trip value of 1200 amps.
Additionally, it is unclear why Kansas Gas and Electric invoked and then deleted a seemingly important performance characteristic.
Following completion of the inspection, Kansas Gas and-Electric was contacted concerning this issue and it was determined that an engineering evaluation had been performed on the subject breakers.
4.
Subvendor Audits A review was conducted of a commercial audit of the Siemens' Spartanburg facility performed jointly by Telemecanique and United Engineers on November 20, 1985. The results of the audit indicated Siemens had a quality assurance program in place, but several deficiencies were noted in the areas of procurement sources, training / qualification, control of measuring and test equipment, and QC inspection.
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REPORT INSPECTION I
NO.: 99901011/88-01 RESULTS:
PAGE 5 of 6 I
It should be noted that in June of 1988 Siemens moved their manufacturing facility from Spartanburg, South Carolina to Wilmington, North Carolina. The Wilmington f acility has not been audited by Telemecanique.
Failure to perform sufficient t
audits to the verify validity of C of C's was cited in nonconformance 88-01-01.
5.
Design Control A review was conducted of Telemecanique's program for maintaining design control of breakers supplied as replacements for those originally seismically and environmentally qualified as part of Telemecanique provided motor control centers. Although Telemecanique does not concur or approve design changes made by Siemens, Telemecanique has asked for and receives information u
L pertaining to all significant design changes. This information is provided annually by Siemens to Telemecanique. -QAP 3.5 h
requires that Telemecanique annually send letters requesting design cliange information to all vendors that supply components used in Telemecanique qualified equipment. Although the large majority of changes made to Siemens breakers have been reported to Telemecanique, information pertaining to changes made on several specific breaker styles is still-outstanding.
Information pertaining to changes made on the following breaker styles has been l
requested by Telemecanique, but has yet to have been provided by Siemens:
TYPE YEARS l-BQ Frame Panel Breaker 71-83 EE,EH,EF, Fraue; One, and Two Pole Only 71-84 L
QJ (255 amp) Frame 82-85 Telemecanique has instituted a policy not to sell any of the above type breakers for qualified applications until the missing design l'
change information is received, i
l The design control file for type HE molded case breakers was reviewed during the inspection. The file contained information describing all changes that had been made by Siemens to this type of breaker from 1971 through June of 1988.
Information in the l
file indicated that numerous changes had been made to several parts of the breaker. The changes included material changes, dimensional changes, and other potentially significant changes.
All changes were evaluated by a Telemecanique qualification
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- T ELEMECAtllQUE, - INC.
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WESTulNSTER,-MARYLAND REPORT
-lNSPECTION
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99901011/08 RESULTS:
PAGE 6 of 6.
engineer for their effect on seismic or environmental qualification.
New materials were analyzed for radiation effects and found to have radiation degradotion thresholds wc11 above the qualification levels of the breakers. Materials were also analyzed for aging effects using Arrhenius methodology. All changes were found by Telemecanique not to have adversely af fected either seismic or environmental qualification.
In sunmary, the Telemecanique evaluations'were found~to be thorough, well documented, and of sound engineering, basis.
In addition to the HE breaker file, a review was conducted of Telemecaniques analysis of a change made to A20, A22, A82 and A83 motor starters supplied by Telemecanique's sister plant in Westminster, Maryland. The change concerned the. addition of a trip indicator which could be degraded if exposed to radiation 7
levels in excess of 1 X 10 rads.
As a result of this change, a letter was written from engineering to quality assurance restricting the use of ghis device in any application qualified for in excess of 1 X 10 rads.
V.
EXIT MEETlHG:
Folicwing completion of the inspection an exit meeting was held. The following people were in attendance:
NAME AFFILIATION Jeff Jacobson, U.S.H.R.C.
doc Destefano, Quality Assurance Engineer Telemecanique, Inc.
Micheal Fennteau, Quality Assurance Manager Telemecanique,,Inc.
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