ML20023C510
| ML20023C510 | |
| Person / Time | |
|---|---|
| Site: | North Anna, Midland |
| Issue date: | 05/06/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 22183, 82-09-#4, 82-9-#4, MCAR-60, NUDOCS 8305170391 | |
| Download: ML20023C510 (9) | |
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Consumers Power i Presil - Projects, Engineering and Construction General officos: 1945 West Pernali Road, Jackson, MI 49201 * (517) 788-0453 May 6, 1983 82-09 #4 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT -
DOCKET NOS 50-329 AND 50-330 QUALITY PROGRAM AND MANUFACTURING DEFICIENCIES AT VICT0REEN, INC.
FILE:
0.4.9.65 SERIAL: 22183
Reference:
J W Cook letters to J G Keppler, Same
Subject:
(1) Serial 19074, dated October 15, 1982 (2) Serial 20651, dated December 30, 1982 (3) Serial 20726, dated March 9, 1983 The referenced letters were interim 50.55(e) reports concerning quality program and manufacturing deficiencies affecting radiation monitoring equipment being supplied by Victorcen. This letter is our final report on this subject.
The enclosure to this letter provides an analysis of the deficiency and the corrective actions that were taken with regard to this matter.
WRB/lr
Attachment:
Bechtel MCAR-60, Final Report, dated April 22, 1983 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant 8305170391 830506 PDR ADOCK 05000339 S
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OC0483-0035A-MP01 M7
Ssrini 22183 2
82-09 #4 CC: CBechhoefer, ASLB Panel FPCowan, ASLB Panel JHarbour, ASLB Panel AS&L Appeal Panel MMCherry, Esq MSinclair BStamiris CRStephens, USNRC WDPaton, Esq, USNRC FJKelley, Esq. Attorney General SHFreeman, Esq. Asst Attorney General WHMarshall GJMerritt, Esq TNK&J INP0 Records Center OC0483-0035A-MP01
Bechtel Associates Professional Corporation Ii288g ii2819 ganaaement Corrective Action Report (NCAR)
SUBJECT:
MCAR 60 (issued September 17, 1982)
FINAL REPORT DATE:
April 22, 1983 PROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Description of Deficiency Approximately 80% of the Midland radiation monitoring system electronic modules (Class 1E and non-Class 1E) manufactured by Victoreen, Inc. of Cleveland, Ohio, and reviewed by project personnel were found to be nonconforming due to workmanship problems because they did not meet the approved Victoreen Standard Operating Procedure (SOP) 500.002.
Four of the 12 Class 1E radiation monitors were reviewed at the Midland jobsite and were found to have similar nonconforming conditions.
The majority of nonconforming conditions are in the area of soldered connections. The soldered connections were found to have the following deficiencies:
a.
Insufficient soldering b.
Excessive soldering c.
Cold solder joints d.
Excessive heat Capacitor body enamel protruding into the plated-through holes e.
f.
Diode bodies partially embedded in solder g.
Flux not cleaned from boards Other deficiencies observed were occurrences of circuit board delamination (measling), contamination on wire v.ap connectors, duplicate serial numbers on like modules, lifted circuit foil, excessive insulation removal from jumper wires, and components no'. properly attached mechanically.
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l Bechtel Associates Professional Corporation li2888 li2879 MCA,30 Final Report Page 2 Historical Backaround and Summarr of Investimation During the second week of August 1982, eight of the electronic modules were inspected at the vendor's shop by project supplier quality i
personnel. Numerous occurrences of poor workmanship (rejectable in accordance with Victoreen 80p 500.002) were encountered and all electronic modules in the Victoreen plant were rejected for use in the Midland plant.
Between September 1 and 13, 1982, MpQAD and Bechtel supplier quality assembled a team of experienced individuals who went to Victoreen to i
quantify the workmanship problems. The team reviewed 877 modules, of i
which 730 were found to be nonconforming.
A full-scope audit of the supplier's quality assurance (QA) program performed on September 8 through 10, 1982, at Victoreen's facility revealed that there are deficiencies in the execution of its QA program (12 of the 19 audit elements were identified as deficient). On September 23, 1982, a sample inspection of workmanship on 4 of the 12 Class IE radiation monitors shipped to the Midland jobsite was conducted. Nonconforming workmanship was found in all four monitors.
i Analysis of Safety Impilcation i
There were approximately 1,500 nonconforming conditions found in the four Class 1E monitors inspected at the jobsite. This represents j
approximately 35 deficiencies / module. The Class 1E monitors had been conditionally shipped to the jobsite because their qualification was not complete. It is probable that during qualification testing, one or more of the deficiencies would have been uncovered. However, had the deficiencies not been discovered and corrected, it is possible that the nonconforming workmanship could have resulted in a reduction of the predicted reliable life expectancy of the equipment, resulting in a loss of operability.
The Class 1E monitors are designed in a manner such that loss of power or failure of certain components will result in an alarm condition.
However, due to the large number of nonconformances, the types of l
failures and results thereof cannot be analyzed.
It is considered probable that one or more of the nonconforming conditions could have adversely affected one or more of the Class 1E radiation monitors, i
thereby preventing the monitor from performing its safety-related function.
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n Bechtel Associates Professional Corporation Ii2879 BCAR 60 Final Report Page 3 Probable Cause The cause of the poor workmanship appears to be a breakdown of the supplier's QA program, which resulted from an apparent deesphasis of the quality program following a shift in senior management and frequent changes in QA personnel. The following significant deficiencies in the supplier's QA program were noted:
a.
Victoreen rewrote and implemented a new QA manual without prior approval from Bechtel.
b.
Victoreen conducted inadequate in-process inspection.
c.
Victoreen's QA department failed to review test and inspection documents as required by its SOPS.
d.
Victoreen's QA department failed to review its formal purchase orders and also were delinquent in performing required evaluation of its suppliers, e.
Some of Victoreen's SOPS did not have the required formal sign-off by its engineering, manufacturing, and QA organizations.
f.
Victoreen had used several tools / instruments which were not currently recorded in its calibration systems, g.
Victoreen conducted inadequate employee training.
The deficiencies in soldering in the Class 1E modules at the jobsite were not detected before shipment because printed circuit boards are not normally inspected by Bechtel supplier quality for soldering workmanship. The procedures submitted by the vendor for soldering were conside ed satisfactory and were similar to standard industry practices.
Because we have not had a history of deficiencies in this area and because it was determined through previous audits, including the September 23 through 25, 1981 audit, that the vendor appeared to be following its procedures, extraordinary inspection efforts in this area j
were not deemed necessary.
Corrective Action The actions noted below have been or are being taken to correct the deficiencies in the Class 1E monitors and completely resolve any safety concerns addressed in this report.
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Bechtel Associates Professional Corporation li2879 Iu.288B,e,,g, Final Esport page 4 1.
Failure by Victoreen to submit its revised QA program (Revision 7, QA manual and Sops) to Bechtel for review and approval resulted in Bechtel issuing a stop-work order on June 8, 1982. Subsequently, the QA program was submitted by Victoreen, was reviewed and commented on by Bechtel, and ultimately received Bechtel approval. Following the approval, Bechtel lifted the stop-work order on June 18, 1982. No Class 1E equipment was shipped during this period.
4 2.
A stop-further process for inspection and testing activities and a restriction on shipment was placed on all Class 1E equipment on September 10, 1982, as a result of the September 8 through 10, 1982, audit.
3.
On September 23, 1982 MPQAD overinspected a sample of 4 of 12 Class 1E monitors t. hat had been shipped to the jobsite during August 1982. In the four monitors overinspected, approximately 1,500 nonconforming conditions were identified as described in the Analysis of Safety Implication section. These nonconforming conditions are also identified on Consumers Power Company Nonconformance Report M-01-9-2-129.
Hold tags were applied to all 12 Class 1E monitors.
On September 30, 1982, Bechtel project personnel and Victoreen personnel again went to Midland to further investigate the deficiencies. Victoreen concurred with the nonconformances.
Bechtel met with Victoreen on October 27 and December 2 and 8, 1982, to discuss corrective actions required for the monitors. On January 6, 1983, a meeting was held between Victoreen, Consumers power Company, and Bechtel. During this meeting, it was decided that all of the electronics modules for the class 1E monitors at the jobsite and at Victoreen's facility would be replaced with new modules built by Victoreen in accordance with the approved 50ps.
This action is scheduled for completion by March 31, 1984.
4.
Bechtel supplier quality met with Victoreen on September 24, 1982, to establish corrective action and completion dates to resolve Victoreen QA program deficiencies. Subsequent meetings were held on October 4, 5 and 28 and November 18, 1982, to monitor the status of the corrective actions.
At Victoreen's request, Bechtel performed a full-scope audit January 19 through 20, 1983, to determine if Victoreen had satisfactorily resolved the deficiencies identified in the 0231u
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Bechtel Associates ProfessionalCorporation
,l.i2879 MCAR 60 Final Report Page 5 September 8 through 10, 1982, audit. The January 19 through 20, 1983, audit revealed that Victoreen corrected 7 of the 12 deficient quality elements identified in the september audit. This audit identified nonconformances in three other quality elements that were previously found acceptable.
Based on improvements in Victoreen's quality program and verbal commitments from Victoreen's new president and QA manager, the stop-further-process restriction for inspection and testing activities was lifted. On March 21 through 23, and April 11 through 14, 1983, Bechtel reaudited the eight deficient quality elements. At that time, Victoreen had satisfactorily resolved all but one of the findings. The remaining audit finding is against Quality Element IV, procurement document control. Victoreen failed to ensure that its subsupplier followed its welding procedure. The specific finding was not against the Midland order; however, Victoreen is investigating j
all of its procurement documents to ensure that none have a similar problem. Victoreen will complete its investigation by April 29, 1983, and Bechtel will perform a reaudit the week of May 1, 1983.
The hold-on-shipment restriction will remain in effect until Victoreen satisfactorily resolves the remaining audit finding.
5.
One hundred percent inspection of all Class 1E equipment by Bechtel supplier quality, with an overinspection by MPQAD, will be performed. Additional supplier quality personnel have been assigned to this order and all supplier quality personnel inspecting this equipment have or will receive prior additional training in inspection of printed circuit boards.
Reportability Based on the safety implication analysis of this report, the described deficiency is considered reportable in accordance with the Code of Federal Regulations, 10 CFR 50.55(e). Consumers Power Company reported the deficiency to the NRC on September 17, 1982.
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i V Bechtel Associa tep((qfessional Corporation i2888 MCAR 60 Final Report Page 6 Submitted by: G."Singh control Systems Group Supervisor Approved by: M _/- E.M. Hughes Project Engineer Concurrence b ur LI M .A. O' Hare Control Systems Chief Engineeri ,3 concurrence by: E.H. Smith Engineering Manager Concurrence by: [ M.A. Dietrich Project Quality 9f0 Assurance Engineer GS/JDB/sunc(J) 0231u ...--.....-.,-..-~~..~---.m-rr.----v,-~~-~---~~-
Attachme t 2. ION to J.A. Ruts';rs SCHEDULE FOR li2888 Ii2879 MCAR 60 CORRECTIVE ACTIONS Scheduled Completion l Responsible Oraanization Task Date Bechtel engineering Issue MR 7220-J-244 to include 04/29/83 new Class 1E modules. Bechtel procurement Issue purchase order for 05/06/83 above. Victoreen Manufacture Class IE modules. 01/07/84 Victoreen Test Class 1E modules. 01/21/84 Victoreen Replace existing modules 02/10/84 with new class 1E modules (requires Bechtel approval). Victoreen Perform calibration. 02/24/84 Victoreen Perform functional test. 03/02/84 Bechtel engineering Review and approve test 03/23/84 results. Yletoreen Ship Class 1E monitors 03/31/84 ( 1017e . -.. _. _. ~......... - -,,..,.. -.. _ _. _.-.__,._._..,....m..,........._ _ _ _. _ _ _ - _ _ _ _ ,}}