ML20043G652
| ML20043G652 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1990 |
| From: | Cwalina G, Naidu K Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20043G643 | List: |
| References | |
| REF-QA-99901178 99901178-90-01, NUDOCS 9006200529 | |
| Download: ML20043G652 (17) | |
Text
-.
l i
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOV1. MICHIGAN f
REPORT lhSPECTION INSPECTION J
NO.: 99901178/90-01 DATE: 1/29-2/1/90 ON-SITE HOURS: 81 CORRESPONDENCE ADDRESS:
T. Hutchins, President Automttic Valve Corporation j
41144 Vincenti Court
)
Novi, Michigan 48050-043S E
ORGANIZATIONAL CONTACT:
T. Hutchins TELEPHONE NUMBER:
313-474-6700
=
i NUCLEAR INDUSTRY ACTIVITY: Manufactures pneumatic control assemblies for safety-related valve actuators.
I
'bL Vlho ASSIGNED INSPECTOR:
K. R. Naidu, Reactive inspection Section No. 1 Date (RIS-1)
OTHERINSPECTOR(S):
H. L. Ornstein, Reactor Operations Analysis Branch, AEOD i
T.J. Carter, Events Assessment Branch, DOEA
/
(/'/!70 APPROVED BY:
G. Cwalina, Chief, Special Inspection Section, Date Vendor Inspection Branch INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and 10 CFR 50, Appendix B.
B.
SCOPE:
Review the implementation of the quality assurance program in selected areas, actions taken on previously reported failures at the Susquehanna and Hope Creek nuclear power plants and observe activities associated with the manufacture of pneumatic control assemblies.
PLANT SITE APPLICABILITY: All plants which utilize valve actuators with pneumatic control assemblies manufactured by Automatic Valve Corporation.
[9011702g%$ h jV 99 l
l
4 ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 2 of 17 A.
VIOLATIONS:
Contrary to Sections 21.21 and 21.51 of 10 CFR Part 21, Automatic Yalve Corporation (AVC) had neither developed nor implemented an adequate procedure to evaluate, document, and report deviations and defectsdetectedinthepneumaticcontrolassemblies(PCAs)manu-factured and supplied by AVC to nuclear power plants for 9se in safety-related applications.
Examples of such deviations not properly evaluated by AVC include lubricants, U-cup seals, and design changes.
(Violation 90-01-01) l D.
Nonconformance:
L l
Contrary to Criterion 11 of 10 CFR 50, Appendix B, AVC did not establish and implement an adequate quality assurance program as documented in their quality assurance manual (QAM), Revision B, dated July 13, 1989, as evidenced by the following:
l 1.
Contrary to Criterion 1 of 10 CFR 50, Appendix B, the authority I
and duties of persons performing activities related to quality in the manufacture of safety-related PCAs were not clearly established and delineated in writing.
(Nonconformance 90-01-02) 2.
Contrary to Criterion IV of 10 CFR 50, Appendix B, measures were not established by AVC to include the applicable quality requirements and 10 CFR Part 21 reporting requirements listed in safety-related purchase orders (P0s) received by them in their P0s issued to their subtier suppliers.
(Nonconformance 90-01-03) 3.
Contrary to Criterion Vil of 10 CFR 50, Appendix B, measures were not established to verify that documentary evidence, test reports, certificates of conformance, and certified material test reports received with purchased material met the P0 requirements. (Nonconformance 90-01-04)
C.
Unresolved item:
1.
AVC stated that the existing QAM is being revised to incorporate provisions for signatures and dates in assigned spaces in drawings to identify the individuals who drafted and verified the drawing instead of having the Computer Assisted Design machine print the initials of the individuals and the dates when the drafting and verification activities were performed. This
i ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI, MICilIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 3 of 17 matter was identified as an unresolved item in the Ralph l
A. Hiller (99901170/89-01) inspection report.
Pending review of the revised QAM, this matter is considered an unresolved item.
(Unresolveditem 90-01-05).
D.
DETAILS:
1.
Purpose.
This inspection was conducted to determine the adequacy of the implementation of the AVC quality assurance (QA) program relative to the manufacture of PCAs.
PCAs are subassemblies of pneumatic / hydraulic valve actuators and other types of valve actuators. The PCA, as a subassembly of a main steam isolation valve (MSIV) operator,directscompressedairtothetopor bottom of a piston inside the pneumatic cylinder of the MSIV operator, to close or open the MS!V. Actuation of the pneumatic cylinder is initiated by the motion of solenoid operated valves (50V).
The following events, which prompted this inspection, were reviewed.
a.
On October 11, 1989, a faulty S0V in an AVC PCA caused one MSIV to inadvertantly close during power operation at the Peach Bottom nuclear power station.
The faulty 50V was 1
replaced. Disassembly and examination of the faulty 50V indicated that a spring had been inserted upside down, b.
On February 24, 1987, one MSIV failed to close at the Hope l
Creek nuclear power station due to a faulty SOV. General Electric Nuclear Energy (GENE), San Jose, California, the supplier of the MSlY operator examined the failed S0V.
GENE, in a letter (GP-87-032), dated May 7, 1987, informed Hope Creek that "the cause of failure appears to have been the accidental inclusion of a foreign material, probably a loose seal, in the solenoid cavity between the plunger and the upper orifice."
c.
On July 5,1986, an outboard MSIV failed a quarterly exer-cise test at the Susquehanna Unit I nuclear power plant.
The failure was caused by the use of Houghton H-620 type lubricant which corroded the unanodized aluminum housing of the PCA.
m
- a z
/
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 4 of 17 d.
On December 10, 1986, several MSIVs failed a monthly func-tional closure test at the Susquehanna Unit 2 nuclear power plant. It was reported that the failure was caused by the use of Houghton H-620 type lubricant which corroded the unanodized aluminum housing of the PCA.
2.
Background Information on AVC AVC manufactures general purpose, industrial pneumatic and vacuum service valves.
The PCAs manufactured by AVC for nuclear power plants are for safety-related applications and are less than 7 percent of the total sales volume. Documents at AVC indicate that initially AVC received P0s to supply PCAs exclusivel the Nuclear Energy Division of General Liectric Company (y from GENE),
San Jose, California.
However, for the last 5 to 6 years, AVC also has accepted safety-related P0s directly from licensees.
Shipping documents indicate that AVC ships PCAs to either the facility where the valve actuators are manufactured (for installation and test as an integral actuator unit), or directly to the nuclear power plant. AVC also furnishes spare parts for PCAs supplied by them, l
3.
Review of Implementation of 10 CFR Part 21 Requirements The inspectors reviewed the AVC's program for implementing 10 CFR Part 21 (Procedure D372-071289), and observed that copies I
of 10 CFR Part 21, Sectitm 223(b) of the Atomic Energy Act, and Section 206 of the Ene m Reorganization Act were posted.
The inspectors determiner Odt Procedure D372-071289 was inadequate to fully implement Sections 21.21 and 21.51 of 10 CFR Part 21, dated August 21, 1987. AVC did not have an adequate procedure for evaluating deviations and maintaining such records.
The inspectors identified three areas related to the use of suitable lubricants, design changes requiring the supply of appropriate tools, and the use of U-cup seals in 3-and 4-way valves, which required AVC's evaluation under Part 21. These items are discussed in the following paragraphs. (Violation 90-01-01).
l l
a.
Review of Problems With Lubricants l
The inspectors examined the problems related to the use of Houghton H-620 and Super-0-lube type lubricants in PCAs installed in safety-related applications as discussed below:
l
+.,
~
.v_
l ORGANIZATION: A0 0MATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 5 of 17 (1) Pennsylvania Power and Light Company (PP&L), the licensee for the Susquehannna nuclear power plants Units 1 and 2, in a letter, dated December 30, 1985, to AVC, requested AVC's position regarding lubrication of 0-rings in the PCAs for MSIV actuators-for Susquehanna. PP&L's letter noted resersations expressed by AVC regarding the use of Houghton H-620.
Their letter also noted that AVC had reservations with a Wyle qualification test result because Wyle encountered problems with the use of Super 0-lube during the tests.
(2)
In response to the above, AVC, in a letter dated January 29, 1986, to PP&L, stated that since 1972 they had not encoun-tered any failures with Super 0-lube other than the one Observed during the Wyle qualification test. Wyle Nuclear Environmental Qualification Test Report 17514-1, dated March 14,1985, documents the results of the qualification test performed on AVC PCAs to meet IEEE 323-1974, IEEE 344-1975 and IEEE 382-1980 for Tennessee Valley Authority and Light Company (Limerick)y (Fermi 2), Pennsylvania Power (TVA),DetroitEdisonCompan
, and the Commonwealth Edison Company (Dresden and Quad Cities). The Wyle Test Report noted that Super-0-Lube was not qualified for use in AVC PCAs because Super-0-lube solidified during the tests.
l l
The Wyle report attributed AVC valve qualification failures to " excessive amounts" of Super-0-lube applied The Parker Company (Parker) port, page xviii, item 15).
to the valves (Wyle test re
, the "manuf acturer" of Super-0-lube, notified Wyle that Super-0-lube starts to solidify at 1.0 megarad.
Parker also notified Detroit Edison (Fermi 2) in a letter dated October 25, 1985, that Super-0-lube starts to solidify, but at 1.9 megarads. The AVC letter also noted that during the I
above Wyle test Super-0-lube had solidified, not only in AVC-supplied SOVs, but also in the 2, 3-and 4-way valves that are installed in PCAs. The 3-and 4-way valves did remain operable during the tests even though they contained Super-0-lube which was degraded. As a result of the f ailure of the S0Vs with Super-0-lube, L
and subsequent successful testing of Houghton H-620, I
Wyle recommended the use of Houghton H-620 lubricant.
The records reviewed did not indicate that Wyle verified the compatibility of Houghton H-620 lubricant with
4 ORGANIZATION: AU10MATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 6 of 17 unanodized aluminum alloy components used in AVC PCAs.
AVC also noted that GENE had qualified Super-0-Lube for nuclear service.
In conclusion, this letter stated that AVC's position on lubricants was to provide either Super-0-lube, as specified by GENE, or Houghton H-620, i
as reconnended by the Wyle Test Report.
(3) On May 28, 1986, AVC issued a Lubrication Specification (Procedure D328 052886, Revision 0) for Houghton H-620 type lubricant which stated that H-620 was rated " Noncom-patible" witn unanodized aluminum by E. F. Houghton and Company, the manufacturer of H-620; and that H-620 was "to be used ONLY when specified by the customer."
(4) On May 29, 1986, AVC issued a Lubrication Specifications (Parker " Super-0-Lube"), Procedure D329-052986, Revision 0 to indicate that drawings and manuals which refer to lubrication document D329-052986 are to have all specified parts covered with a light coat of " Super-0-lube."
(5) On June 20, 1986 AVC revised their lubricant specifi-cationsfor"nuclearpowervalves"(D329-052986, i
Revision 1).
It stated that unless specifically stated on the customer's purchase order, all valves for nucicar power service would be lubricated with Super-0-lube; that the only acceptable substitute was Houghton H-620; and that "It is the customer's responsibility to use the correct lubricant, per their plant specifications for all valve maintenance." More l
iniportantly, AVC's lubrication specification had the same caution note as the aforementioned May 28, 1986, lubrication document which noted that Houghton H-620 l
was rated noncompatible with unanodized aluminum by the lubricant manufacturer and that it was "to be used L
l ONLY when specified by the customer." This permission to use Houghton H-620 as an alternative lubricant was removed in Revision 2 to D329-052986, dated December 24, 1986.
(6) AVC certified for PP&L PO 6-07802-1 on June 30, 1986, that AVC manufactured eight assemblies each of 2, 3 L
and 4-way valves lubricated with Houghton H-620. This information also appeared on AVC Invoice Number 74374, dated aune 30, 1986. AVC lubricated the valves in the l
f e
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 7 of 17 Susquehanna PCAs with Houghton H-620 (June 30, 1986),
subsequent to their knowing of the lubricant's noncom-patibility with their valves (May 28,1986). The use i
of Houghton H-620 was specified in the licensee's i
purchase order.
(7) On December 10, 1986, after installing the above-procured ei PCAs on MSIVs, PP&L experienced comon-mode failures of the AVC PCAs for all 16 MSIVs at Susquehanna Unit 2.
The Houghton H-620 lubricant corroded the unanodized aluminum manifolds in the PCAs. The common mode failures of the AVC PCAs did not occur during a design basis accident and it did not result in the compromise of the public health and saf.ty. The failures were reported to INP0.
1 Subsequently, on February 3, 1987, AVC provided PP&L with a cost effective method for repairing or replacing the MSIV PCAs which had " corrosion problems caused by Houghton H-620 lubricant."
(8)
In a letter dated December 19, 1986, with copies to Commonwealth Edison and PP&L, AVC notified the NRC Region 111 office of the corrosion problems experienced at the Susquehanna without expressly mentioning 10 CFR Part 21, and stated that PCAs for Commonwealth Edison Company's Quad Cities plants were also lubricated with I
the same H-620 lubricant.
(9) On February 10, 1987 AVC notified Detroit Edison (Fermi 2) and TVA (Browns Ferry) of the problems which had been experienced with Houghton H-620 lubricant (pitting and corrosion)atSusquehanna.
The inspectors determined that contrary to 10 CFR Part 21.21(a)(1), AVC supplied PCAs to PP&L lubricated with Houghton H-620 without informing the licensee of the existence of a deviation. As described in Section A above, the inspectors determined that AVC did not have i
adequate procedures for the review, documentation and reporting required under 10 CFR Part 21. AVC did not have records to indicate that AVC:
(1) adequately l
evaluated the advice of E. F. Houghton and Company regarding the corrosive properties of Houghton H-620 l
lubricant, (2) warned PP&L of the same, and (3) re-frained from using the lubricant in PCAs furnished to PP&L. This matter is addressed in Violation 90-01-01.
+-
i 1+.
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESUCS:
PAGE 8 of 17 b.
Review of Improper Tool Use AVC changed the 50V design during the period 1984 through 1985. The revised design changed the base of the solenoid guide tube which screws into a threaded cavity. This design
- change removed a hexagonal head nut from the 50V tube collar. The change required the use of a spanner wrench with two nipples to tighten or loosen the 50V tube in the cavity during assembly or disassembly of the 50V. AVC incorporated changes into the instructions, but only provided the revised instructions and the spanner wrench to
+
l.
customers who ordered complete PCAs. AVC did not provide the revised instruction and the correct tool to customers who ordered spare SOVs or 50V kits. The use of pliers or vise grips as~ prescribed in AVC's previous instructions could lead to damage and malfunction of the new SOVs. A SOV h
which failed at the Hope Creek nuclear power plant on l
February 24, 1987, also sustained damage which appeared to l
have been caused by the use of vise grips or pliers. The NRC issued Information Notice 90-11, " Maintenance Deficiency 1
Associated with Solenoid-0perated Valves" on February 28, 1990, to alert all nuclear utilities of this problem. The inspectors determined that AVC did not evaluate the results of their own inspection report, which documented the observed damage to the 50Y, in sufficient depth to ascertain that the root cause of the damage could have been from using vise grips or pliers as described in previous AVC instructions.
Other utilities using the "new" S0Vs without proper tools or instructions could also damage the S0Vs and cause subsequent failure of safety-related equipment. An adequate AVC evaluation should have determined that the design change, l
including revised instructions and a spanner wrench, was not communicated along with the supply spare S0Vs or SOV kits.
I On February 2,1990, as a result of the NRC inspection, AVC informed the NRC of this matter as a potential 10 CFR Part 21 item. This matter is another example of a violation of 10 CFR Part 21 evaluation and reporting requirements discussed in Violation 90-01-01.
c.
Review of U-Cup Seals The Wyle Test Report (17514-1, Paragraph 6 on page xvi) states that qualification of 4-way valves with U-cup seals in AVC PCAs cannot be justified. The 4-way valves contain
1 e
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOV1, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 9 of 17 booster pistons which are fitted with U-cup seals. The booster pistons on 4-way valves are not safety-related.
Their primary function is to maintain the MSIV in an open position on decreasing or loss of pneumatic pressure.
Failure of the U-cup seals would contribute to the failure which would of the 4-way valve to change state on consnand,f ailure to subsequently cause failure of the MSly. This change state was demonstrated by a similarly functioning 3-way valve (containing U-cups) when it stuck in its energized position and failed to return to its deenergized position on command. Wyle replaced the U-cup seals with Viton 0-rings in 4-way and 3-way valves and tested the PCAs satisfactorily.
The inspectors deter'nined that AVC supplied the following nuclear power plants with safety-related PCAs containing 4-way valves with U-cup seal design:
Ple.nt Four-way Valve Made from PCA Drawing Hope Creek C-5140-200 Barstock C-5140-375 Fermi C-5140-200 Barstock C-5140-300 Limerick 1 C-5140-200 Barstock C-5140-325 Limerick 2 C.5140-414 Casting C-5140-330 The inspectors were unable to find records to indicate that AVC evaluated the failure of the U-cup seals reported by Wyle to determine the root cause and the suitability of their continued use at the four plants listed above.
This is another example of a violation of Section 21.51 of 10 CFR Part 21 records requirements discussed in Violation 90-01-01.
4.
Review of the AVC Quality Assurance Program The inspectors reviewed the AVC quality (QAM) D244-42480, assurance program documented in Quality Assurance Manual
, Revision B, dated July 13, 1989. The Policy Section of the manual states that AVC will provide products meeting the requirements of 10 CFR 50, Appendix B.
AVC stated that this manual is currently being revised. The inspectors examined the provisions'of the QAM, including its implementation in selected areas. The results of the review are documented in the following paragraphs.
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOV1 MICHIGAN REPORT INSPECTION NO.:
99901178/90-01 RESULTS:
PAGE 10 of 17 5.
Organization The QAM did not adequately establish the authority and duties of individuals performing safety-related activities. The inspectors informed AVC that failure to establish and delineate in writing the authority and duties of individuals performing activities affec-ting the manufacture of safety-related components is a nonconformance to Criterion I of 10 CFR 50, Appendix B.
(Nonconformance 90-01-02) 6.
Design Control The QAM references Change Notice Form (CNF) D151-3575 for con-trolling changes in designs. The purpose of this CHF is to ensure design additions, changes, and deletions at AVC are accomplished accurately, consistently and efficiently (according to the QAM). The inspectors verified the implementation of CNF D151-3575 and determined that changes were adequately documented when procedures and design changes were revised. The inspectors observedthatAVCusesComputerAssistedDesign(CAD) machines to generate drawings. The CAD machine is programed to print the initials of individuals in the assigned spaces to denote the individuals who drafted and checked the respective drawing.
Similarly the CAD machine is programmed to print the date when the activities were accomplished. The inspectors informed AVC that in the absence of valid signatures, one cannot establish when and by whom the drafting and checking activities were performed. AVC acknowledged the observation and stated that they will establish provisions in the revision to the QAM for individuals to sign and date in the assigned spaces to denote when and by whom the activities were performed.
This ' natter is considered an unresolved item.
(Unresolveditem 90-01-05) 7.
Procurement Document Control Section 4 of the QAM references Procedures 0119-81674 and 0118-81674 entitled " Customer Purchase Order" and " Supplier Purchase Orders," respectively. The former procedure is L
intended to ensure that customer P0s are processed in an accurate, consistent, and timely manner; it neither addresses acknowledgement of the quality and regulatory requirements nor requires the translation of these requirements into AVC P0s to subtier vendors. The latter procedure is intended to ensure l
that parts procured are inspected, identified, handled, and stored in an accurate and consistent manner. The procedure l
neither requires AVC tu impose the quality and regulatory
~U ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION c
N0.: 99901178/90-01 RESULTS:
PAGE 11 of 17 requirements specified in P0s to AVC in AVC P0s issued to their vendors nor describes controls in place to otherwise establish necessary product quality. The inspectors reviewed several AVC P0s to their vendors and determined that AVC did not establish and implement the requirements of 10 CFR S0, Appendix B, Criterion IV to translate the quality and regulatory requirements received in various purchase orders issued to AVC into AVC P0s to subtier suppliers.
(Nonconformance 90-01-03)
This matter is also discussed in paragraph 9 of this report.
8.
Control of Purchased Material. Equipment and Services The current AVC QAM references Procedures D118-81674 Revision K, dated December 28, 1989, to address the control of purchased material, equipment and services. The stated purpose of this procedure is to ensure that parts are inspected, identified, handled, and stored in an accurate, consistent and efficient manner.
To ascertain if adequate measures were established to e
assure that purchased material, equipment and services, whether purchased directly or through contractors and subcontractors conform to procurement documents, the inspectors reviewed the certifications received in response to AVC P0s to procure components and services. The inspectors determined that AVC had not audited the manufacturer or otherwise verified the accuracy of certifications or assured the traceability of purchased material for assembly in safety-related PCAs in the following cases:
a.
AVC procured electrically operated SOVs from Snap-tite incorporated (Snap-tite), Erie, Pennsylvania. Snap-tite manufactures S0Vs to meet AVC design drawings. AVC P0s to Snap-tite do not require Snap-tite to implement a quality assurance program during the manufacture of the S0Vs to ensure consistency and reliability of performance to assure that they meet the quality requirements of IEEE-323 and IEEE-344. Until the time of this inspection, AVC had not audited the manufacturing facilities of Snap-tite. Documents reviewed by the inspectors incicate that Snap-tite purchases the electrical coils for SOVs from two subtier suppliers - Five Star and Quality Coil. After the coil is inserted in the SOV and sealed with potting compeand, the identity of the coil supplier cannot be determineJ.
For example, during the Equipment Qualification of 'CAs in 1984, Wyle supplied
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI MICHIGAN INSPECTION REPORT PAGE 12 of 17 N
NO.: 99901178/90-01 RESULTS:
Snap-tite with three failed 50V coil assemblies with a request to provide information on the manufacturer of the coils.
In response to the request, Snap-tite, in a letter dated November 8, 1984, informed Wyle that they "cannot be l-certain as to which of our two major coil suppliers made these coils." Receipt inspections at AVC verify that resis-tances of the 50V coils received are within the specified
'y such as opera-acceptance limits; other characteristics,(which power plants bility of the enils at degraded voltages are susceptible to) and insulation resistance are not verified.
Each S0V assembly, as illustrated in AVC drawings 6910-010 and 6910-020 for the 120-volt AC and the 125-volt DC SOVs respectively, consists of components specified below:
(1) One nut made of cold rolled steel and zinc plated.
(2) One 125-volt DC (or 120-volt AC) coil and housing l
assembly. The housing was to be manufactured from Standard American Equivalent 1010 cold rolled steel 4
with black oakite paint. The 50V coil is wound with special magnet wire conforming to American National Standards Institute Class M35. The 50V coil leads are to be 22 inches long with silicone insulation and rated for 150-degree Centigrade temperature.
Norcast-type compound was to be used to pot the coil in the housing.
I (3) One plunger guide made from 430 F-and 304-Type stainless steel.
(4) One compensating plunger and spring assembly consisting of a plunger manufactured from 430 F-Type stainless steel with a Viton ring and a 302-Type stainless steel return spring.
(5) One Viton 0-ring.
AVC could not demonstrate that the components in the L
SOVs conformed to the above specifications and are therefore qualified to meet IEEE 323 and 344 standards.
AVC does not perform an operability test.
Such a test may have identified whether the 50V supplied to Peach Bottom (paragraph la) was assembled correctly or with the spring upside down.
L L
~
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 13 of 17 b.
AVC procures Viton (elastomer) 0-rings from Zatkoff Company (adistributor),FarmingtonHills, Michigan. AVC P0s to Zatkoff require Viton 0-rings to be manufactured from DuPont's E60C or 3M's Fluorel 2174 base polymer, with cure dates not to exceed 12 months from the date of shipment.
Zatkoff provides a Certificate of Conformance (CoC) that the Viton 0-rings are manufactured from either DuPont's E60C or 3M's Fluorel number 2174 and specifies cure dates of the 0-rings. The inspectors determined that AVC had not, at the time of the inspection, independently verified the accuracy of any CoC. The inspectors reviewed a typical certificate provided by Parker Hannifin Corporation, 0-ring Division, Lexington, Kentucky, the manuf acture of 0-rings to Zatkoff. A certificate, dated April 25, 1985, stated that Parker can certify that their compounds V-747-75 (black) and V884-75 (brown) are each made of either DuPont's E60C or 3M's Fluorel 2174 base polymer and both meet MIL-R-83248, Type 1, Class l'.
The inspectors informed AVC that*if a generic deficiency is identified in the Viton 0-rings, it would not be possible to trace it back to the manufacturer in the absence of the identity of the polymer base from which the 0-rings were manufactured.
c.
Similarly AVC procured " poppet seals" with CoCs from the Minnesota Rubber Company.
The inspectors reviewed a CoC l
from Minnesota Rubber, dated May 20, 1986.
The CoC stated that 550 poppet seals, Part Number 6717007A, were made with a 514AD type compound from either DuPont's E60C or 3M's Fluorel 2174 base polymer and that the cure date was in the 2nd quarter of 1986.
d.
Copper and Brass Sales, a distributor, provided a certificate, dated April 2, 1986, to AVC for PO 43696 providing the tensile strength values and chemical composition for 2024-T351 type aluminum plate and certified l'
that the aluminum supplied conformed to Federal Specification QQ-A250/4E. The certificate did not indicate the mill which provided the aluminum or include the test resJlts.
The inspectors informed AVC that the above examples indicate instances where AVC did not establish measures to verify that the purchased material met the procurement documents specifi-l cations. This matter is a nonconformance to 10 CFR Part 50, 1
Appendix B, Criterion Vll.
(Nonconformance 90-01-04)
ORGANIZATION: AUTOMATIC VALVE CORPORATION
~
NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 14 of 17 9.
Review of Purchase Orders (P0s) Issued by AVC The inspectors reviewed the following P0s issued by AVC for components to be assembled in safety-related PCAs and determined that AVC did not convey 10 CFR Part 21 requirements to subtier vendors :
a.
AVC issued P0 No. 49378, dated August 17, 1989, to Snap-(tite incorporated Erie, Pennsylvania, for the supply of 30 125 Volt DC) SOVs manufactured to AVC drawing 6910-020. AVC also issued PO No. 49667 dated December 12, 1989 to Snap-tite for the supply of 120 volts ac 60 Hz SOVs manufactured to meet AVC drawing 5910-010. Both P0s required a CoC certifying that the SOVs met the P0 requirements. Review of the above AVC P0s indicates that AVC did not convey the 10 CFR Part 21 requirements to their subtier vendors. AVC does not audit Snap-tite to establish or verify the quality and acceptability of the SOVs. The inspectors could not determine from the documents available at AVC if Snap-tite implements a quality assurance program during the manufacture of SOVs. The inspectors determined that Snap-tite purchases solenoid coils from two subtier suppliers. After the solenoid coil is potted in the 50V assembly, Snap-tite cannot establish the traceability of the coil to the subtier coil supplier.
b.
AVC issued PO No. 48853, dated June 22, 1989, to S&C Tool &
Manufacturing Company, Telegraph Road, Detroit, Michigan for the supply of pistons manufactured to meet AVC Drawing 5140-005 and 74 bushings to meet AVC Drawing 2195. AVC purchased the steel from a distributor with certified material test reports (CMTRs) and supplied the steel to the above company to manufacture the pistons and bushings. The P0 required the manufacturer to use the raw material (provided to them by AVC) to manufacture the items to the drawings (supplied to them by AVC) specified in the P0.
c.
AVC issued P0 No. 48935, dated August 1,1987, to L. F. Dale -
Precision Machining company (LFDPM), Farmington, Michigan, to supply four manifolds to meet AVC Drawing 5140-010 and one manifold to meet AVC Drawing 5158-010. AVC provided the aluminum which was purchased by AVC with CMTRs from a distributor. The PO required LFDPM to use the raw material supplied to them by AVC to manufacture the manifolds.
e T
~
i ORGANIZATION: AUTOMATIC VALVE CORPORATION l
NOVI, MICHIGAN
~ ~.
REPORT INSPECIIOk l
NO.: 99901178/90-01 RESULTS:
PAGE 15 of 17 d.
AVC issued P0 No. 48989, dated July 28, 1989, to Assured 1
Manufacturing, Madison Heights, Michigan to supply 27 manifolcs to AVC Drawing C6930-010. AVC provided the raw material purchased by AVC with CMTRs from a distributor.
l The PO required Assured Manufacturing to machine the manifolds from the_ raw material supplied to them.
i e.
AVC issued P0 No. 49300, dated October 30, 1989, to R.
l Zatkoff, a distributor, to supply Viton 0-rings to meet AVC part No-0914-008A. The PO required a CoC from Zatkoff certifying that Viton 0-rings were either made from Dupont E60C or 3M's Fluorel 2174 base polymer with cure dates not to exceed 12 months from the date of shipment.
The inspectors informed AVC that AVC did not establish adequate measures to convey the quality requirements and 10 CFR Part 21 evaluation ar.d reporting requirements imposed on AVC in various P0s issued to them by GENE and other licensees to their subtier vendors in the above examples.
The inspectors informed AVC staff that failure to include applicable regulatory and quality requirements in the AVC P0s is in nonconformance with 10 CFR 50, Appendix B, Criterion IV.
(Nonconformance 90-01-03) j
- 10. Document Control AVC utilizes Procedure D151-3575, Revision J, dated December 29, 1989, to ensure that additions, changes, and deletions to documents 1
are done accurately, consistently and efficiently. The inspectors reviewed the implementation of this procedure and determined that AVC adequately controlled the revisions to procedures and drawings.
However, the inspectors identified a problem inherent with the methodology adopted by AVC in allocating part numbers (drawings numbers) to sub-components. During a review of procurement documents related to GENE and the Commonwealth Edison Company (CECO),theinspectorsobservedthattheidentificationnumberof a component was being changed. The inspectors obtained copies of 1
the AVC Nuclear Parts Lis.t (from the Master Number Book) and the procedures list. The inspectors determined that AVC maintains an up-to-date list of all parts and drawings / procedures used to control the components manufactured in-house and the parts provided by subtier vendors. AVC issues a new number to a component when the component is modified slightly, instead of I
issuing a revision to the original part number.
For example, a letter dated February 4,1985,, to GENE stated that AVC originally l
1
ORGANIZATION: AUT0KATIC VALVE CORPORATION NOVI, MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 16 of 17 identified a 4-way valve as C5140-4H; kits to rework the viive were identified as K-C5140-4H.
Subsequently, the kit and its identification number were changsd; the kit number bhame number (from C5140-4H) y, AVC changed the valve identification K-5497-1H.
Consequentl to C5497-1H to match the identification of the old valve with parts from the now kit.
Because the new kit (withmodifiedcomponents)isnotqualified,thenew(reworked) valve will also be unqualified.
However, since the old valve was qualified,AVCwasassumingthe(reworked)valvewasalso qualified and so was the kit.
The inspectors observed another instance of an uncertain qualifi-cation process for a S0Y supplied by AVC. A letter, dated' December 29, 1988, from AVC to CECO, indicates that SOVs with nonreplaceable poppet seals were replaced with SOVs having replaceable poppet seals. A letter, dated August 16, 1987, from l
AVC to GENE indicates that a PCA with the original nonreplaceable poppet seals was qualified by GENE for use on valves manufactured by the Target Rock Corporation (the manufacturer of main steam j
relief valves) and installed at CECO plants during the 1975 time j
frame. AVC stated that Wyle Laboratories qualified replace-able poppet seals during the qualification of a 3-way valve.
Thus, the original valve with the rep'ed, and qualified on the laceable poppet seals was considered by AVC to still-be qualifi basis of the Wyle qualifications.
- 11. Review of Audits i
The inspectors reviewed the following audits of AVC performed by licensees and GENE:
a.
Pennsylvania Power & Light (PP&L) performed an audit (Audit Report 88-075) on February 16, 1989, of AVC.
PP&L determined i
l that AVC's program, as currently implemented, does not meet the requirements of 10 CFR 50, Appendix B or ANSI N45.2-1977.
PP&L identified one audit finding (88-0751) which essentially states-that AVC's quality program does not properly dedicate commercial-grade items per 10 CFR Part 21 for use as a basic component in' nuclear power plants.
In response to this finding, AVC established a dedicated area to store components for assembly 1
in safety-related PCAs.
The NRC inspection team explained to AVC j
the intent of commercial-grade dedication. AVC acknowledged
]
to the NRC inspectors that the action taken in response to the above PP&L finding was inadequate to address commercial-grade dedication and that additional measures would be j
established.
L j, _
ORGANIZATION: AUTOMATIC VALVE CORPORATION NOVI. MICHIGAN REPORT INSPECTION NO.: 99901178/90-01 RESULTS:
PAGE 17 of 17 b.
Iowa Electric Light and Power Company, the licensee for the Duane Arnold nuclear power plant, cond.-ted an audit on May 11, 1989 and identified four audit findings ar.J two observations.
The findings related to:
(1) The authority and duties of individuals performing quality related activities were neither discussed nor defined in the QA manual.
(2) AVC does not have a program in place to audit or evaluate their subtier vendors.
i (3) AVC did not provide a formal training program for individuals assigned to QA/QC activities.
I (4) AVC has neither an internal audit program nor a lead auditor to perform audits.
1 The audit observations also identified CoCs and QA/QC procedures not being microfilmed and the lack of a formal corrective action program.
a AVC responded to the eudit in a letter dated July 17, 1989, and outlined the corrective action taken to resolve the audit. findings.
c.
GPU Nuclear Corporation, the licensee for the Oyster Creek nuclear power plant performed an audit on December 10, 1987 and identified one adverse finding relating to lack of objective evidence that thread ring and plain plug gages were calibrated.
AVC responded to the audit finding on January 8,~ 1989, stating that AVC revised Procedure D-308-1885 to provide provisions to record calibration dates for all major measuring equipment and that they had sent the measuring gages to a calibration agency.
E.
EXIT INTERVIEW:
The inspectors met with the individuals listed in Section F and discussed the scope and findings of the inspection.
j F.
PERSONS CONTACTED:
- T. Hutchins, President
- D. Swinton, Manager, Engineering L. Stone, Purchasing Agent R. Belcher, Assembly Builder B. Robson, Assembly Builder
- Denotes that the individuals were present at the exit interview.
-