ML20055C358
| ML20055C358 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0040, NUREG-0040-V13-N04, NUREG-40, NUREG-40-V13-N4, NUDOCS 9003070134 | |
| Download: ML20055C358 (91) | |
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i NUREG-0040 Vol.13, No. 4 l
Licensee Contractor l and Vendor Inspection
- Status Report Quarterly Report October 1989 - December 1989 U.S. Nuclear Regulatory Commission l
'iM..... )
l 9003070134 900131
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40 PDR
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Available from Superintendent of Documents U.S. Government Printing Offite Post Office Box 37082 Washington, D.C. 20013 7082 A yest's subscription consists of 4 issues for -
this publication.
Single copies of this publication are avallable from National Technical Information Service, Springfield, VA 22161
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Vol.13, No. 4
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Licensee Contractor and Vendor Inspection Status Report 1
Quarterly Report j
October 1989 - December 1989 i
Manuscript Completed: January 1990 Dite Published: January 1990 i
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Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 p'* **%
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l ABSTRACT This periodical covers the results of inspections performed by the NRC's Vendor inspection Branch that have been distributed to the inspected organization during the period from October 1989 through December 1989.
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TABLE OF CONTENTS PAGE Abstract.............................................................
iii Preface..............................................................
vii Reporting Format.....................................................
ix Index................................................................
xi Inspection Reports...................................................
1 Selected Bulletins and Information Notices Concerning Adequacy of Vendor Audits and Quality of Vendor Products.........................
79 Vendor Inspections Related to Reactor Plants.........................
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PREFACE A fundamental premise of the Nuclear Regulatory Commission's (NRC) licensing and inspection program is that licensees are responsible for the proper con-struction and safe and efficient operation of their nuclear power plants. The total goverranent-industry systeni for the inspection of commercial nuclear facilities has been designed to provide for multiple levels of inspection and verification. Licensees, contractors, and vendors each participate in a quality verification process in complience with requirements prescribed by the NRC's rules and regulations (Title 10 Code of Federal Regulations). The NRC performs an overview of the commercial nuclear industry by inspection to determine whether its requirements are being met by licensees and their contractors, while the major inspection effort is performed by the industry within the framework of ongoing quality verification programs.
The licensee is responsible for developing and maintaining a detailed quality assurance (QA) plan with implementing procedures pursuant to 10 CFR 50.
Through a system of planned and periodic audits and inspections, the licensee is responsible for assuring that suppliers, contractors and vendors also have suitable and appropriate quality programs that meet NRC requirements, guides, codes and standards.
The Vendor Inspection Branch (VIB) reviews and inspects nuclear steam system suppliers (NSSSs), architect engineering (AE) firms, suppliers of products and services, independent testing laboratories performing equipment qualification tests, and holders of NRC licenses (construction permit holders and operating licenses)invendor-relatedareas. These inspections are performed to assure that the root causes of reported vendor-related problems are determined and appropriate corrective actions are developed. The inspections also review the vendors' conformance with applicable NRC and industry quality requirements, the adequacy of licensees' oversight of their vendors, and that adequate interfaces exist between licensees and vendors.
The VIB inspection emphasis is placed on the quality and suitability of vendor products, licensee-vendor interface, environmental qualification of equipment, and review of equipment problems found during operation and their corrective action. When nonconformances with NRC requirements and regulations are found the inspected organization is required to take appropriate corrective action,
and to institute preventive measures to preclude recurrence.
When generic implications are identified, NRC assures that affected licensees are informed through vendor reporting or by NRC generic correspondence such as information notices and bulletins.
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The White Book is published quarterly and contains copies of all vendor inspec-tion reports issued during the calendar quarter for which it is published.
Each vendor inspection report lists the nuclear facilities to which the results are applicable thereby informing licensees and vendors of patential problems.
In addition, the affected Regional Offices are notified of any significant problem areas that may require special attention.
The White Book also contains a list of selected bulletins and information notices involving vendor issues.
Correspondence with contractors and vendors relative to inspection cata contained in the White Book is placed in the USNRC Public Document Room, located in Washington, D.C.
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REPORTING FORMAT ORGANIZATION:
COMPANY, DIVISION CITY, STATE REFORT INSPECTION INSPECTION NO.: Docket / Year / Sequence DATE:
ON-SITE HOURS:
1 CORRESPONDENCE ADDRESS:
Corporate Name Division ATTN:
Name/ Title Address i
City, State Zip Code i
ORGANIZATIONAL CONTACT:
Name/ Title TELEPHONE NUMBER:
Telephone Number
)
NUCLEAR INDUSTRY ACTIVITY: Description nf type of components, equipment, or services supplied.
ASSIGNED INSPECTOR:
Name/ Vendor Program Branch Section M
l OTHERINSPECTOR(S):
Name/ Vendor Program Branch Section APPROVED BY:
Name/ Chief - Section/ Vendor Program Branch M
INSPECTION BASES AND SCOPE:
A.
BASES:
Pertain to the inspection criteria that are applicable to the activity being inspected; i.e., 10 CFR Part 21 Appendix B to 10 CFR Part 50 and Safety Analysis Report or Topical Report comitments.
B.
SCOPE:
Sumarizes the specific areas that were reviewed, and/or identi-Tres plant systems, equipment or specific components that were inspected.
For reactive (identified problem) inspections, the scope summarizes the problem that caused the inspection to be perfomed.
PLANT SITE APPLICABILITY:
List plant name and docket numbers of licensed facilities for which equipment, services, or records were examined during the inspection.
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ORGANIZATION:
ORGANIZATION CITY, STATE REPORT INSPECTION NO.:
RESULTS:
PAGE 2 of 2 A.
VIOLATIONS:
Shown here are any inspection results determined to be in violation of Federal Regulations (such as 10 CFR Part 21) that are applicable to the organization being inspected.
B.
NONCONFORMANCES:
Shown here are any inspection results determined to be in nonconformance with applicable commitments to NRC requirements.
In addition to identifying the applicable NRC requirements, the specific industry codes and standards, company QA manual sections, or operating procedures which are used to implement these commitments may be referenced.
C.
UNRESOLVED ITEMS:
Shown here are inspection results about which more information is required in order to determine whether they are acceptable items or whether a violation or nonconfonnance may exist.
Such items will be resolved during subsequent inspections.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
This section is used to identify the status of previously identified violations, items of nonconformance, and/or unresolved items until they are closed by appropriate action.
For all such items, and if closed, include a brief statement coacerning action which closed the itern.
If this section is omitted, all previous inspection finding', have been closed.
E.
INSPECTION FINDINGi AND OTHER COMMENTS:
This section is used to provide significant informition concerning the inspection areas identified under
" Inspection Scope.'
included are such items as mitigating circumstances concerning a violat'on or nonconformance, or statements concerning the limitations or depth of inspection (sample size, type of review performed and special circumstaices or concerns identified for possible followup).
For reactive inspections, this section will be used to summarize the disposition or status of the condition of event which caused the inspection to be performed.
F.
PERSONS CONTACTED:
Typed, Name, Title
- present during exit meeting i
t SAMPLE PAGE (EXPLANATIONOFFORMATANDTERMIN0 LOGY) l x
l INDEX FACILITY REPORT NUMBER PAGE Target Rock Corporation 99900060/89-01 1
East Farmingdale, New York Combustion Engineering, Inc.
99900401/89-01 17 Windsor, Connecticut Westinghouse Electric Corporation 99900404/89-01 23-Nuclear and Advanced Technology Division Pittsburgh, Pennsylvania Rotork Controls, Inc.
99900839/89-01 32 Rochester, New York Whittaker Corporation 99901164/89-01 38 Simi Valley, Californie Ralph A. Hiller Company 99901170/89-01 48 Pittsburgh, Pennsylvania The Sheffer Corporation 99901171/89-01 63 Cincinnati, Ohio xi
INSPECTION N
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ORGANIZATION: TARGET ROCK CORPORATION LAST FARMINGDALE. NEW YORK REPORT INSPECTION INSFECTION NO.: 99900060/89-01 DATE: July 18-21, 1989 ON-SITE HOUR $:
30 CORRESPONDENCE ADDRESS:
Target Rock Corporation Mr. Richard Langseder Director of Engineering 1906 E. Broad Hollow Road East Farmingdale, New York 11735-0917 ORGANIZATIONAL CONTACT:
V. Liantonio TELEPHONE NUMBER:
(516)293-3800 Ext.523 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of solenoid operated valves.
ASSIGNED INSPECTOR:
/ t \\ ' '. is
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K. R. Naidu, Reactive Inspection Section No. 1, VIB Date OTHERINSPECTOR(S):
APPROVED BY:
M/
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J ITBaker, Chief, Reactive Inspection Section No.1, VIB ae INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR 50 Appendix B; 10 CFR Part 21.
B.
SCOPE: Review implementation of the quality assurance program in selected areas; corrective action taken on nonconformances identified in NRC inspection report No. 99900060/83-02; corrective action taken to resolve Part 21 items; and tests observed on a power operated relief
- valve, PLANT SITE APPLICABILITY: All plants with Target Rock Corporation solenoid valves 1
l ORGANIZATION: TAkGET ROCK CORPORATIOM EAST FARMINGDALE, NEW YORK REPORT INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 2 of 16 A.
VIOLATIONS:
No violations were identified during this inspection.
B.
NONCONFORMANCES:
Contrary to Criterion 11 of 10 CFR 50, Appendix B Target Rock Corporation (TRC) inadequately implemented their quality assurance program as evidenced by the following examples:
to Criterion XV of 10 CFR 50, Appendix B, nonconformance Contrary (NCR) were not initiated to document conditions adverse 1.
reports to quality in the following instances:
a.
An NCR was not initiated when a TRC Model No. 88 RR power operated relief valve (PORV) f ailed to meet the opening and closing times criteria specified in Consumers Power Company Technical Specification M1-LCA, ESS-Specification SP-MP-8306-002(Q).
(89-01-01) b.
An NCR was not initiated to document that two TRC Model 82-UV-001 valves failed to open on demand during hot functional tests at Watts Bar Unit i nuclear power station. This failure was reported to the NRC by Tennessee Valley Authority as a 10 CFR Part 21 item in a letter dated October 25, 1983.
(89-01-02) 2.
Contrary to Criterion XVI of 10 CFR 50, Appendix B, corrective action was not taken on one of the three nonconformances identifieo in NRC Inspection Report No. 99900060/83-02.
Furthermore, corrective actions ta ken to redesign and rework nonconforming items, including those reported as 10 CFR Part 21 items, were not documented and preserved in en auditable manner.
(89-01-03) 3.
Contrary to Criterion V of 10 CFR 50, Appendix B:
4.
A checklist used to document the results of the acceptance tests performed on July 19, 1989, on a PORV intended for the Palisades nuclear power plant, did not contain acceptance criteria to establish opening and closing times as specified in the technical specification.
(89-01-04) b.
Activities related to electrical solder joints were performed on Class IE wire harnesses without the benefit of a written procedure and inspections were not conducted prior to ship-ment, resulting in Washington Public Power Supply System (WPPSS) nuclear power plant Unit 2 receiving 17 safety-related 2
ORGANIZATION: TARGET ROCK CORPORATION EAST FARNINGDALE, NEW YORV REPORT INSPECTION l
NO.: 99900060/89-01 RESULTS:
PAGE 3 of 16 electrical wire harness replacement kits with defective solder joints. WPPSS reported this matter as a Part 21 item in a letter dated May 19, 1989.
(89-01-05) 4.
Contrary to Criterion VI of 10 CFR 50, Appendix B, General WeldProcedureSpecifications(GWPS)andJointWeldProcedure Specifications (JWPS)wereusedinproductionwelding without having valid approd signatures, including dates of approval, to indicate the GWPS and JWPS were reviewed and approved by individuals other than those who prepared them.
This item was previously identified as a nonconformance in Inspection Report No. 99900060/83-02. TRC responded to the nonconformance in their letter dated October 19, 1983, and stated that the GWPS and JWPS will be signed and dated.
In spite of this commitment, those procedures remained without valid signatures of approval and dates of approval until July 21, 1989, and were used in production welding during the period in between.
(89-01-06)
C.
UNRESOLVED ITEMS:
No unresolved items wera identified during this inspection.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
The status of the following nonconformances identified in NRC Inspection Report No. 99900060/83-02 was revieweo and determined to be as follows.
1.
(Closed) NONCONFORMANCE 83-02. Item A This nonconformance identified that contrary to Criterion V of i
10 CFR 50, Appendix B and para quality essurance manual (QAM) graphs 3.3.1 and 3.5.1 of the TRC
, selected paragraphs oescribing the number and distribution of the operation history card had been revised and implemented without the approval of the QA manager and acceptance by the Authorized Inspection Specialist.
Furthermore, the revision had not been distributed to all i
holders of controlled copies of the QAM.
A review of the QAM indicates that Revision 3 to Change Notice No. 8, which revised Section 7 of the QAM, was revised on October 15, 1983, in response to the nonconformance. The entire l
QAM has been subsequently revised and the current status is Revision 4.
TRC is currently in the process of revising their QAM in preparation for the renewal of their ASME certificstion.
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ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK
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REPORT INSPECTION NO.: 99900C60/89-01 RESULTS:
PAGE 4 of 16 1
2.
(Closed) NONCONFORMANCE 83-02 Item B I
This nonconformance identified that contrary to Criterion V of l
10 CFR 50, Appendix B; Welding Procedures TRP 11.200, Revision B and TRP 11.203, Addendum No. 3 used in production welding, had not been approved.
This was also contrary to paragraph 8.4.1 of the QAM and paragraph 6.1 of TRC procedure 001 2130.
l TRC, in a letter dated October 19, 1983, to the NRC outlining their corrective action to this nonconfornience, stated that it has now provided on the document the inhouse approval of the revision and that such approval is considered to be mandatory for document and control i
purposes. The inspector reviewed the GWPS and JWPS prepared prior to 1988 and determined that TRC failed to implement the above consnitments.
GWPS, JWPS, and revisions to JWPS prepared and implemented prior to 1988 were incomplete, without signatures and/or dates.
Subsequent to 1988, the Welding Engineer responsible for this activity, has pre-pared and approved several JWPS and revisions to the JWPS as evi-denced by his signatures on these documents. TRC, in response to the inspector's observation that the practice of preparation and approval of the JWPS by the same individual lacks the benefit of independent review, stated that in the future an individual other than the preparer will approve such procedures.
This nonconformance is considered closed and TRC's failure to implement the corrective action to update these procedures is identified as a nonconformance to 10 CFR 50, Appendix B, Criterion XVI, related to failure to implement the existing Quality Assurance program. Hefer to paragraph 4.b. of this report.
(Nonconformance
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89-01-03) l 3.
(Closed) NONCONFORMANCE 83-02 Item C This nonconformance identified that contrary to Criterion VII of 10 CFR 50, Appendix B, measures were not established to select and assess Q-Tei. Corporation, a contractor who was performing vendor audit services for TRC. TRC stated that the practice of using a contractor to perform vendor audits has been discontinued.
TRC stated that they now perform vendor audits themselves.
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P ORGANIZATION: TARGET ROCK CORPORATION LAST FARMINGDALE, NEW YORK
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REPORT INSPECTION 4
NO.: 99900060/89-01 RESULTS:
PAGE 5 of 16 E.
OTHER INSPECTION FINDINGS AND C0lFENTS:
1.
Review of Previously Reported 10 CFR Part 21 Items.
The inspector reviewed the corrective action taken by TRC to resolve the following 10 CFR Part 21 items identified during the 1983 - 1989 period.
a.
Combustion Engineering incorporated (CE) reported to the NRC problems in four TRC valves procured for use at the Palo Verde NuclearGeneratingStation(PVNGS). CE identified that two one-inch TRC Model 77L-001 and two two-inch TRC Model 77L-003 valves, which were received for the purpose of performing additional qualifications to the requirenants of HUREG-0588, were inspected prior to the tests.
The inspection identified incorrect valve assenblies and significant missing parts, which were subsequently corrected. During the seismic testing of the valves, CE identified problems such as valve position indicator failures, failure of the valve to open due to an electrical short in the solenoid leads, failure of the valve to close due to improper seating, and shorted electrical leads due to wear.
CE determined that the failures were related to vibratory damage, i
TRC evaluated the problem and determined that in the valves identified above, the problem was caused by the axial travel of the solenoid coil inside the solenoid housing because the solenoid assemblies were not potted.
TRC issued a Service Bulletin (SB) 8302 dated April 6, 1983, to'all their customers.
The SB provided instructions to inspect their valves to detect axial travel. The SB stated that TRC had a nodification kit available for use containing the necessary parts and l
instructions to eliminate the problem.
The NRC also evaluated the problem and issued Information Notice (IN) 85-49 attaching TRC SB B302 informing users of potential problems with certain models of TRC valves.
The IN stated that these models~of TRC valves failed during environ-mental qualification testing and that the analysis of the failure suggests that line vibration induced by hydrodynamic l
forces in the piping and other forms of nechanical vibration may cause loosening of the solenoid hold-down nut of those l
TRC solenoid valves with design features similar to TRC valve models tested. The action taken by TRC, i.e.,
potting the assemblies, is considered adequate for this item.
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ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK REPORT INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 6 of 16 b.
Arizona Public Service Company (APS), in a telephone conversation to the NRC Region V office, followed by an interin letter dated December 23, 1982, reported similar problems with other TRC valves. APS in a final report dated July 11, 1984, provided the following additional details on the anomalies:
1)
Incorrect valve assembly - An insulating washer was observed to be off-center and wedged in the land between tre pressure housing and the lower case of the Reed switch housing. This misalignment prevented pressure from the assembly nut being transmitted to the bottom of the solenoid housing and the lower 0-ring seal. The misalignment was corrected.
2)
Significant missing parts - Two 0-ring seals were observed to be missing on two valves and two 0-ring seals were missing on two additional valves. These discrepancies were also discovered prior to testing.
Valves, identified by CE, discussed in the above paragraph were included in the APS report. The APS currective action included modifying valves according to TRC SB 8302, obtaining missing parts and reas:,embling the valves. APS also replaced several TRC Model 77L-003 two-inch valves with valves manuf actured by VALCOR. Corrective action taken to resolve this deficiency appears to be adequate.
c.
On September 28, 1983, APS reported to the NRC that the external f actory calibration seals applied to TRC Model 76-Q-XXX valves were observed to be broken.
Subsequent testing of the valves by APS personnel determined that the valves failed performance testing due to excessive seat leakage. The tests were repeated by a TRC field representative utilizing a TRC test rig, which was equipped with an accumu-lator and used pure water. The APS test rig did not have an accumulator and used impure water.
The test iesults indicated that the valves failed because of foreign material contained in the test media used in the APS test rig. The foreign material is postulated to have caused surface indentations on the disc seating areas which prevented the valves from reseating properly, thus causing excess leakage.
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ORGANIZATION: TARGET ROCK CORP 0 Rail 0N EAST FARMINGDALE, NEW YORK REPORT INSPECTION N0.: 99900060/89-01 RESULTS:
PAGE 7 of 16 Two problems, one related to broken seals and the other related to excess seat leakage, were identified. A review of records relatedtoPurchaseOrder(PO) 10407-13-JM-691, which were available at TRC, indicated that the valves were shipped to APS after they were tested and a seal was applied at the top of the valve to prevent tempering with the pressure setting.
SpecifI-cally, an "In-Pocess Status Sheet" dated November 12, 1981, identifies the serial nunbers of the.12 valves (which are mentioned in the 10 CFR Part 21 submitted by APS) and reports that the valves were tested at TRC a_nd determined acceptable in the presence of a Bechtel inspector representing APS. The prob-lem with the broken seals was identified during the construction of the plant and it is presumed that the valves were disassenbled prior to welding, at which time the seals were broken, j
Regarding the second problem, TRC informed APS that the lack of an accumulator on the APS test rig and utilization of~ impure water during tests, permitting introduction of foreign particles, were the probable causes of the hammered peening effect on the disc areas which ultimately resulted in excess leakage. APS, in a final report to the NRC dated May 4,1984, concluded that the observed adverse condition was solely due to improper field test-ing and therefore-was not reportable unoer the requirements of 10 CFR Part 21 requirements. APS returned the defective valves to TRC. APS proposed to procure a new test rig, equipped with accumulators, to test their valves in the plant. The inspector concurs with APS that this matter is not a 10 CFR Part 21 item.
d.
Tennessee Valley Authority (TVA) reported to the NRC in a letter dated October 25, 1983, that during hot functional testing of the Watts Bar Unit I nuclear power plant two TRC Mod 4 1 S2 00-001 pressurizer' PORVs failed to open on demand.
Results of tests indicated that the valves would not open when the block valve was also open, which is the normal operating ccnfiguration. The PORV's respective pilot valves would open but the main disc remained closed because the piston rings for the main disc com-pressed and allowed leakage past the rings and into the pilot disc chamber. This leakage prevented the necessary pressure dectease in the pilot char;ber when the pilot disc opened, pre-venting the valve from opening because the valve's solenoid could not lift the main disc against the unbalanced force of a full pressure drop. The valves were returned to TRC for modification and testing.
TRC engineers analyzed this problem and determined that the piston ring needed a spring force underneath it to force the piston ring to expand.
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ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK i
i REPORT INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 8 of 16 l
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To implement this proposal, the piston ring grooves were j
machined deeper and a backup ring made of inconel X750 was placed behind the piston rings to provide the spring force to expand the 17-7PH piston rings. After modification, the valve was cycled a total of 1500 times at different 3
temperatures and pressures, including 500 times at operating 1
conditions of 2335 psig and 657 degrees Fahrenheit. - The valve operated satisfactorily and no anomalies were experienced. TRC stated that this valve was unique to Watts Bar and not applicable to other plants. Action taken by TRC to resolve this item is considered adequate. However, an NCR was not generated to identify the problem and the corrective actions, including the design change, were not documented in an auditable format. TRC's failure to generate an NCR is identified as a nonconformance to 10 CFR 50, Appendix B, Criterion XV.
(Nonconformance 89-01-02) e.
On May 10,1964, Standardized Nuclear Unit Power Plant Systems (SNUPPS), notified the NRC of a generic deficiency relating to improperly-rated field run cables used to connect Valcor supplied solenoid valves in class 1E applications which included TRC valves.
SNUPPS reported that cables qualified to withstand high temperature and adverse en<ironment were installed in the field to replace the previously installed cables.'
The inspector reviewed this matter and determined that this was a field problem and hence did not require TRC corrective
- action, f.
On January 29, 1986, TVA notified the NRC that the internal wiring in a solid-state control; system (SSCS) cabinet was damaged when a 120 Volt (V) ac potential-was applied to at least two different field input points of the cabinet.
The SSCS should have received a 48V input instead of the 120V-from the TRC valves.
The SSCS was designed to control the TRC valves and was intended to receive a 48V dc input from the TRC valves. TVA determined that TRC supplied a solenoid valve with an internal jumper which was not shown on their drawings and that TVA failed to specify the removal of several of the jumpers shown on the TRC valve drawings.
TVA stated that this deficiency was applicable only to the Bellefonte nuclear power plant, Unit 2.
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L ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE. HEW YORK REPORT INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 9 of 16 Records indicate that TRC supplied 28 Model 7700-038 valves to TVA in June 1980, in response to PO 77K3 - 820 230-1, dated 1977.
In a release dated June 26, 1980, TVA transmitted a wiring diagram for their Bellefonte plant (no drawing number) showing a wiring change for one valve only, identified as 3BWO22-NK-81.
In this diagram, the jumper between terminal 2 on terminal block (TB) 1 and terminal 1 on TB2 was deleted.
The corresponding cata sheet for all 28 valves was enclosed.
There was no specific indication on this data sheet that the jumper was to be deleted on one valve only. Other changes mentioned included:
changes in environmental conditions, time versus temperature graph, and an additional position indicator switch added at the end of travel. The valves were intended for the reactor coolant drains and vents, and miscel-laneous piping systems. The TRC standard design does n,,
include jumpers. TVA was the only customer who ordered alves with jumpers. TRC drawing 1 SMH - S-12 Revision 0, datx August 16, 1980, titled "1" Solenoid Operated Globe Valve Assembly Normally Closed," was generated during the procurement process after the TVA letter dated June 26, 1980. TRC informed the inspector that TVA was unable to identify the TRC serial number of the valves that had the jumpers.
Based on the above information and review of the documents, the inspector was unable to conclude that there was a deficiency in the TRC design review process that was generic and applicable to other plants, g.
On June 2, 1986, APS informed the NRC that during a review of the class IE qualification it was determined that two TRC solenoid valves supplied within the CE werk scope had qualifi-cation which addressed continuous energization at 135V dc. The review also identified 13 TRC valves, in the balance of plant scope of supply, that had docunientation for the solenoid coil in the normally de-energized condition.
The review concluded that these valves were all used in fail-safe design applications and their failure would not adversely affect the safety functions of the systems in which they were used.-
Based on the above informatiun and discussions with the TRC engineers, the inspector concurs with APS that this matter is not 4
considered a 10 CFR Part 21 item.
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ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK REPORT INSPECTION-110.:
99900060/89-01 RESULTS:
PAGE 10 of 16 h.
On October 22, 1987, Stone and Webster Engineering Corporation informed the NRC that during the-course of disassenbling a TRC modulating valve at the Beaver Valley Unit 2 nuclear power plant, a wooden dowel pin was found in place of the required stainless steel spiral pin. The function of the spiral pin was to prevent the rotation of the disc rod which is threaded-into the plunger.
Rotation of the rod could result in an increase or decrease to the valve stroke causing either excess leakage or reduced opening. The valve was reassembled using the proper spiral pin.
Disassembly and inspection of a duplicate valve, mcnufactured during the same period of-time as the deficient valve, identified no problems.
TheinspectorreviewedtheTRCFieldServiceReport(TFSR) for project 87ZO30 which docunents the service performed during May 14-16, 1987, at.the Beaver Valley nuclear power plant. The TFSR states that one modulating Model 83 0019 valve was unable to stroke from the closed position when energized. All other modes of operations were successful.
The valve was disassembled and inspected. The TRC service representative observed very heavy sediment deposits and concluded that this may have caused one piston ring to seize in its groove in the main disc. During the cleaning operation, it was observed that a wooden dowel pin had been used to pin the assenbly on the disc rod instead of a plunger spiral pin (roll pin). The roll pin is used to lock the plunger to the rod disc assenbly to permit the proper lift of the valve.
The plunger has four holes diametrically opposite to each other. The rod assembly has a slot above the threaded portion of it. The purpose of the roll pin is to lock the position of the rod disc assenbly to a pre-determined length. During the assembly of the valve, a wooden dowel may be used to temporarily lock the plunger to the rod disc assembly (during a trial and error process ) to verify the proper lift of the valve, because it is difficult to slide a roll pin in and out. The inspector could not determine from the documents examined and the discussions with the TRC personnel if the dowel pin was left in the valve at TRC or if it was left in place at Beaver Valley after some on-site
- service, i.
During May 1988, cracks were reported in the wire insulation and terminal blocks of TRC valves installed at the Shearon Harris Unit 1 and Robinson Unit 2 nuclear power plants.
10
ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK REPORT INSPECTION NO.: 95900060/89-01
.RESULTS:
PAGE 11 of 16 r
TRC informed the NC in a letter dated June 28, 1988, that TRC sent an information bulletin (SB 8801 dated May 18, 1988) informing all their customers that the position indication switch wires which bear the marking "Ristance Wire" may be susceptible to cracking when flexed during handling. TRC recommended replacement of the position indication switch if insulation cracking was observed.
This problem relates to cable leads of Reed switches mounted inside a splash-proof cover mounted on top of the valve. The purpose of the Reed switches is to respond to the position of the rod disc assembly)and indicate the status of the valve (i.e., o>en or closed. Tne Reed switch is a single pole, single tirow switch in a sealed enclosure with two silicone rubber insulated 20 American Wire Gauge (AWG) leads rated for 150 degrees Centigrade and 600 V and manufactured by the Belden Company. TRC, which was evaluating the problem, stated that the cracking problem was first observed at the River Bend nuclear power plant in 1983. TRC intensified their evaluation after receiving information on two additional failures at Shearon Harris and Robinson in May 1988. As a result, TRC issued Service Bulletin 8801, dated May 18, 1988, in which they requested customers to inspect their Reed switches and the lead wires by flexing through a 90-degree bend, close to the potting junction point and observe evidence of insulation cracking. TRC recommended their customers return switches with cracked insulation along with specifying the date of purchase, environmental conditions to which the switch was exposed, and any differences from those specified in the original P0. To correct this problem, TRC upgraded the Reed switch. The Reed switch con-tainer is spun over at the ends to provide better clamping of the insulation in the can. The silicor.e wire leads were replaced with 18 AWG Capton insulated wire manufactured by Champlain Cable Company, Winooski, Vermont, to meet Military Specification W 81381 and be capable of withstanding 752 j
degrees Fahrenheit, activating energy of 1.29mev, and 4 radiation damage threshold of 1XE9 Rads. The terminal block was also changed.
Based on the above, TRC has taken adequate corrective action to resolve this deficiency.
j.
On May 19, 1989, Washington Public Power Supply System (WPPSS) informed the NRC that actuator kits manufactured by TRC and supplied to WPPSS Unit 2 nuclear power plant contained defects, such as a cold solder condition, in addition to insufficient and failed solder joints. TRC evaluated the problem and determined 11
....-....i-.
.._1
l ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALF, NEW YORK REPORT INSPECTION HO.: 99900060/89-01 RESULTS:
PAGE 12 of 16 i
that the 17 assemblies ordered by WPPSS were retrofits and were required to satisfy urgent needs.
Due to the nature of j
the emergency, the actuator kits were soldered and assenbled by personnel other than the assembly test personnel, who i
i normally perform this activity. The actuator kit mentioned I
in the WPPSS 10 CFR Part 21 Report specifically refers to a retrofit relay assembly kit consisting of two double-pole, i
I l
double-throw relays, each connected to a single-pole,-
single-throw Reed switch to provide a load carrying capacity of 10 amps for the position indication circuitry. The two additional relays are necessary because the current carrying j
capacity of the Reed switch is limited to 3-amps. The defective kits were returned to TRC where they were reworked and returned to WPPSS. TRC determined that the WPPSS cold solder joint anomaly was a unique-isolated occurrence and i
therefore notification to other recipients of similar relay i
assemblies was not warranted.. TRC's corrective action included developing a solder procedure and informing field service, assembly and testing personnel that only persons qualified to the procedure were to perform soldering in the i
future. The inspector informed the TRC staff that soldering was performed in the past without the benefit of an approved soldering procedure and that performing a safety-related l
activity without a valid procedure was in nonconformance i
with 10 CFR 50, Appendix B Criterion V.
Refer to paragraph 4.c of this report.
(Nonconformance 89-01-05) l 2.
Observation of Activities, a.
Power Operated Relief Valve (PORV) Testing During the inspection, the in'spector observed a four-inch, 2500 pound stainless steel, TRC Model 88 RR PORV, suitable for operation at 700 degrees Fahrenheit and 2500 psig, being l
tested with saturated steam.
The valve is intended for.
l the Consumer Power Company for installation at the Palisades I
nuclear power plant. The valve was being subjected to i
engineering tests, including operability with steam at 665 degrees ano 2500 psig, and subcooled water tests with l-water at 300 degrees-and approximately 470 psig. The TRC i
l test facility is capable of producing 100,000 pounds of saturated steam per hour at 2500 psi and 663 degrees l
Fahrenheit. On July 19,1989,. the inspector observed three sets of measuren,ents being taken to determine the time taken to open and close the valve.
The valve opened in less than 2.00 seconds and closed in 0.5 seconds.
On the following day, the inspector witnessed similar tests being performed i
12
ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE. NEW YORK REPORT INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 13 of 16 with subcooled water.
For this test, the valve opened in less than 2.1 seconds and closed in less than 6.00 seconds. The relevant Specification SP-MP-8394-002 (Q), issued by Consumers Power Corporation (CPC), specifies the opening and closing times to be 0.2 seconds minimum and 2.0 seconds' maximum.
The inspector observed that the valve met the actuation times for saturated steam. conditions but not for subcooled water conditions. TRC informed the inspector the following day that the delay experienced to close the valve under subcooled temperatures was due to a rectifier assembly placed across the push button located at the test stand.
The rectifier was to protect the push button from voltage surges resulting from energizing the solenoid coil of the valve. The inspector observed that all instruments used to monitor the test were calibrated.
The inspector also observed two examples demonstrating unacceptable implementation of the TRC quality assurance program. One was that this specific valve had previously failed the performance test for closing and opening times and yet no nonconformance was written by TRC to document this condition. The engineering changes made to the valve before being retested were not documented.
Secondly, the checklist used to document the results of the test did not contoin the acceptance criteria, such as the maximum opening and closing times, specified in the CPC technical specifi-cation. Paragraph 4 of this report identifies these matters as examples of nonconformance to Criteria XV and V of 10 CFR 50, Appendix D.
(Nonconformances 89-01-01and04) b.
Observation Of Hydrostatic Tests The inspector observed hydrostatic tests being performed on a segment containing tWo TRC Model 79 AB-001 solenoid valves welded in series.
Two such spool assemblies were ordered by Technipipe Incorporation, Houston, Texas, for use at the-A.N. Vandellos (ANV) nuclear power plant located in Spain.
Each ASME Section III, Class 1 valve was to be supplied with an N-stamp, in compliance with ANV Specification S-0-220, which describes all the technical data, quality assurance requirements, and tests, which included electrical,-hydraulic, and functional tests. TRC Test Procedure 4974, dated March 6, 1989, was utilized and provided information on the valve and fixture preparation, the range and calibration of the pressure test gauges, the quality of the water to be used during the hydrostatic test, a hydrostatic pressure of 6050 13
'e ORGANIZATION: TARGET ROCK CORPORAT10N EAST FARMINGDALE, NEW YORK-REPORT -
INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 14 of 16 psig, an assembly seal weld test, satisf actory actuation of the valve (actuation time should be less than 10 seconds),
satisfactory position indication,. and satisfactory operation at normal and degraded voltage conditions.
Pressure gauges used during the hydostatic test were calibrated prior to the test.. The inspector identified no unacceptable findings in this area.-
3.
Review of Records.
The inspector reviewed-the records related to a valve shipped to APS
' Item 1 of APS P0 60149664 C/05 required TRC to supply a relief valve, S/N 14, Model 76 Q - 008, with a 0.375 inch orifice, with a one-inch nominal inlet and outict. The.following
' nformatiun was available in the review of this package:
i NV1 Certificate Holders Data Report for Safety and Saf ety_
a.
Relief Valves b.
Test report to indicate that on April 18, 1989, the valve successfully withstood 425 psig hydrostatic test pressure.for 10 minutes.
Seat leakage test, with Nitrogen medium at 113 psig, was measured c.
to be zero bubbles per minute, which was less than the accep-tance criteria of 20.
ti.
Gagging device test with Nitrogen medium at 231 psig for one minute resulted in no leakage.
e.
Operational test with Nitrogen medium, indicated the valve operated at 125 psig, plus or minus 3.8 psig,~ and reseated at 112.5 psig.
f.
Liquid Penetrant inspection report which identified no l
unacceptable observations, g.
Valve body thickness measurements.
h.
Welding reports.
Review of the above records identified no unacceptable findings.
14
ORGANIZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK REPORT INSPECTION NO.: 99900060/89-01 RESULTS:
PAGE 15 of 16 4.
Review of the TRC Quality Assurance Program.
The NRC inspector reviewed the implementation of the TRC quality assurance program in selected areas during the inspection and determined that the established program was being inadequately.
implemented in the following areas:
Criterion XV of 10 CFR 50, Appendix D'is inadequately addressed a.
in the TRC quality assurance manual (QAM) and consequently inadequately implemented.
The requirement to identify and document nonconformances was also inadequately described in the QAM. The inspector observed that nonconformance reports (NCR) were only written when the dimensional tolerances were not met and not written when technical specification requirements were violated. However, corrective action, such as design changes, were initiated to correct the problem.
Since an NCR was not generated to document the nonconformance, it was not possible to establish the sequence of corrective actions.
Specifically, the records on TRC's review and resolution to the 10 CFR Part 21 items were not auditable due to lack of NCRs.
(Nonconformances.
89-01-01 and 02) b.
Criterion XVI of 10 CFR 50, Appendix B is also inadequately addressed in the QAM. Since NCRs are seldom written, the.
corrective action taken to correct the nonconformances cannot be readily established without'the benefit of consultations with the cognizant engineers and reconstructing the events which occurred at that time.
In the case of the PORV supplied to CPC, design changes were made to the PORV because the valve did not meet the technical specifications. The inspector informed TRC personnel that the implementation of the QAM would have been considered acceptable if TRC had generated an NCR to document that the PORY did not meet the opening and closing times referenced in the CPC specification. The NCR should have referenced the evaluation of the failure, the Engineering Change Notice initiating the design change to modify the disc, the results of the subsequent retesting, and the final closure of the NCR should have indicated that corrective action was verified to be complete and adequate.
(Nonconformance 89-01-03)
Criterion V of 10 CFR 50, Appendix B, requires activities c.
affecting quality to be prescribed by dncumented' instructions, procedures, or drawings of a type appropriate to the cir-cumstances.
Contrary to this criteria, procedures had not been established to solder electrical connections.
15 l
l
ORGAHlZATION: TARGET ROCK CORPORATION EAST FARMINGDALE, NEW YORK REPORT INSFECTION NO.: 99900060/89-01 RESULTS:
PAGE 16 of 16 Furthermore, a' test procedure, which had been established specifically to test a PORY, did not contain the acceptance / rejection criteria prescribed-in the relevant technical specification.
(Nonconformances 89-01-04 and 05) d.
10 CFR 50, Appendix B, Criterion VI, requires measures to-be established to control documents such as instructions including changes, and_ requires that these instructions and changes be reviewed for adequacy and approved for release by authorized personnel.
Contrary to this requirement, there was no requirement in the QAM to sign and date procedures.
Several weld procedure specifications (WPS), prepared prior to 1988, remained without valid signatures and dates. WPSs developed after 1988 were prepared and approved by the same individual without the benefit of an independent review.
(Nonconfornance 89-01-06)
The inspector informed the TRC personnel that the above are examples of inadequate implementation of the TRC quality assurance program and id,'ntified all these matters as examples of a nonconfornance contrary to the requirements of Criterion 11 of 10 CFR 50, Appendix B.
F.
TRC PERSONS CONTACTED:
Name Title
- R. Langseder Director of Engineering
- J. Bocchi Manager of Sales and Service
- T. D. Crowley Product Support Manager
- V. Liantonio Manager, Applications Engineering
- E. Bajada Manager, Quality Assurance K. Wenzel Manager, Parts and Service E. Reichelt Welding Engineer R. Rudden QA Supervisor
- Attended exit meeting G.
EXIT MEETING:
The inspector met with individuals identified in Section F, and discussed the scope and findings of the inspection.
16
ORGANIZATION: COMBUSTION ENGINEERING, INC.
POWER SYSTEMS GROUP klf NntnD _ 00) WFOTTrifT REPORT INSPECTION INSPECTION NO.: 99900401/89-01 DATE: Hay 22-25. 1989 ON-SITE HOURS: 24 CORRESPONDENCE ADDRESS: Mr. Walter D. Mawhinney, Vice President Nuclear Quality Systems Combustion Engineering, Inc.
Power Systems Group 1000 Prospect Hill Road Windsor, Connecticut 06095 ORGANIZATIONAL CONTACT:
Steven A. Toelle, Manager, Operating Reactor Licensing TELEPHONE NUMBER:
(203) 285-5213 NUCLEAR INDUSTRY ACTIVITY: Combustion Engineering, Inc. (CE) has had NSSS contracts for 16 domestic reactors, and has support service contracts for i
approximately 40 reactors worldwide.
ASSIGNED INSPECTOR:
8+9 R. C. Wilson, Senior Reactor Engineer, Reactive ae InspectionSectionNo.2,(RIS-2) Vendor OTHERINSPECTOR(S):
/
APPROVED BY:
h A 7-AF 9-UE9 U. Potapovs, Chief, RIS:2, Vendor Inspection Branch E
INSPECTION BASES AND SCOPE:
A.
BASES: 10 CFR Part 21 and Part 50.
B.
SCOPE:
1.
Review engineering and procurement records for thermocouple cable seals for safety-related applications.
2.
Review 10 CFR Part 21 notification, dated April 20, 1989, concerning control element assembly slippage.
PLANT SITE APPLICABILITY: PaloVerde1,2,and3(docket 50-528,529,530);
Turkey Point 3 and 4 (50-250, 251); South Texas 1 and 2 (50-498, 499); Salem 1and2(50-272,311); Indian Point 2(50-247);WNP-3(50-508).
17
ORGANIZATION: COMBUSTION ENGINEERING, INC.
WINDSOR, CONNECTICUT REPORT INSPECTION NO.: 99900401/89-01 RESULTS:
PAGE 2 of 6 A.
VIOLATIONS:
None B.
NONCONFORMANCES:
i None C.
UNRESOLVED ITEMS:
Control of procurement activities, see report paragraph E.1 (89-01-01).
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
Not applicable.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Thermocouple cable end seals The first topic addressed in this inspection was hermetic seals for cable assemblies used in two safety-related systems supplied by CE, core exit thermocouple (CET) and reactor vessel level monitoring (RVLM) systems. Both systems use' multiple lengths of metal jacketed, mineral insulated cable with threaded electrical-connectors. The cable assemblies are fabricated for CE by Electronic Resources Division of Whittaker Corporation.
l Either the cable ends or the cable-connector junctions must be hermetically sealed to prevent moisture contact with'the cable's silicon dioxide ceramic insulation and resultant degradation of insulation resistance. Procurementcriteria[includingspecifi-cations, drawings, and purchase order (PO) requirements] for the i
following P0s from CE to Whittaker were reviewed:
Plant P0 Date Palo Verde 1 9170287-14273 03/26/81 l
Palo Verde 2 9170288-14373 03/26/81 l
Palo Verde 3 9170289-14473 03/26/81 Palo Verde 1 9271857-14273 09/10/82 Palo Verde 2 9271858-14373
.09/10/82 Palo Verde 3 9271859-14473 09/10/82 i
18
= - -
ORGANIZATION: COMBUSTION ENGINEERING, INC.
WlhDSOR, CONNECTICUT REPORT INSPECTION H0.: 99900401/89-01 RESULTS:
PAGE 3 of 6 Plant P0 Date Turkey Point 3 9270855-16081 04/28/82 Turkey Point 4 9270854-16081 04/28/82 Turkey Point 4 9270282-16081 02/13/84 South Texas 1 9471519-4884 08/27/84 South Texas 2 9471520-4884 08/27/84 Salem 1 9770018-71186 01/15/87 Salem 2 9770019-71186 01/15/87 Indian Point 2 9874769-D9421 05/23/88 CE engineering personnel were interviewed concerning both generic matters and these specific procurements.
Each CE P0 invoked 10 CFR Part 21.
Each order also applied CE's " Quality Assurance Requirements for Suppliers of Nuclear Safety-Related (CE Quality Class 1) Items and Services," Specification WQC-11.1 Revision D, dated October 4, 1974, Quality Class 1 was 1
specified.
Each P0 also applied specification 00000-FEA-6102,
" Engineering Specification for In-Core Instrumentation Intercon-necting Cable Assemblies," Revision 04, dated January 15, 1982.
Each P0 also invoked a CE assembly drawing providing plant-specific information such as quantity and length of cable assemblies, connector suppliers and types, and connector pin assignments.
Originally CE supplied all of the connectors to Whittake'r, as specified in paragraph 2.3.1 of Specification 6102 Revision 4.
No credit was taken for connector hermetic seal capabilities.
Paragraph 4.2.5 of Specification 6102,-Revision 4 specifies that j
the encs of each cable shall be. hermetically sealed to prevent moisture absorption, prior to connector attachment.
In 1984 CE documented environmental qualification of thermocouple cable assemblies using Whittaker-manufactured connectors; see NRC Inspection Report No. 99900401/88-01, dated January 1, 1989 for discussion. The new Whittaker connectors replaced Litton-Veam connectors in most instances. G&H Technology Corporation connectors continue to be used for the RVLM disc'onnect. nearest the reactor and in some cases Swagelok connectors (not assembled by Whittaker) i are used for connection to CET sensors. CE personnel explained that connectors manufactured by Whittaker provide an adequate hermetic seal for the cable, and a separate cable end seal is not required.
19
i I
ORGANIZATION:
C0llbuSTION ENGINEERING, INC.
g l
WINDSOR, CONNECTICUT i
REPORT IHSPECTION NO : 99900401/89-01 RESULTS:
PAGE 4 of 6 Typical recent Whittaker Acceptance Test Procedures (such as ATP i
16-26-00712 for the Inoian Point 2 P0 9874769-D9421, covering bridge HI cable P/N 16-26-00712-S, S/N 00001 -- data taken l
October 13,1988) cover helium leak testing only after connector attachment. This reflects the hermetic seal capability of the Whittaker connectors now used. Of the P0s reviewed by the inspec-tor, only the 1984 Turkey Point 4 order recognized the conflict -
l between Specification 6102, Revision 4 and post-1984 actual practice. Technical Change Request (TCR) No. 9470282-2, dated March 13,1984, to P0 940282-16081 states that Specification 6102, Revision 4 paragraph 2.3.1 should be changed to read as follows:
"The connectors used to terminate the ends of the cable specified in this specification and applicable drawings shall be purchaser supplied if not provided by the supplier." However, even the Turkey Point 4 order did not relax the requirement of specification paragraph 4.2.5 for separate cable end seals.
Failure to update Specification 6102, Revision 4 thus caused two types of conflicts in P0s involving Whittaker-manufactured connectors.
First, paragraph 2.3.1 conflicted with-the CE assembly dr6 wing referenced in the P0 regarding the source of connectors.
Second, paragraphs 2.3.1 and 4.2.5 conflicted with what both CE and Whittaker intended for both connector types and cable leak test requirements. The affected P0s reviewed by the-inspector are Turkey Point 4 (1984, leak test only), South Texas 1 and 2, Salem 1 and 2, and Indian Point 2.
While no corrective action is required for the hardware shipped to these facilities, l
CE advised that these discrepancies are being addressed in a specification revision currently in progress, and had been noted l
in an internal QA audit.
The inspector questioned CE engineering regarding the use of shrink tubing and potting materials for either hermetic or environmental seals in CET and RVLM systems. Neither type of seal material is used for either purpose in CE-supplied systems built by Whittaker.
Both are used in various applications to restrict. motion, provide strain relief, fill voids to prevent moisture collection, and the like.
The inspector questioned CE concerning their audits of Whittaker.
The CE Quality Operations Department has audited Whittaker in 1983, 1984, 1986, 1987, and twice in 1988. Whittaker was t-20
ORGANIZATION:
COMBUSTION EhGINEERING, TNC.
WINDSOR, CONNECTICUT h
REPORT INSPECTION NO.: 99900401/89-01 RESULTS:
PAGE 5 of 6 I
removed from CE's Approved Suppliers List in 1988, and CE has
~
subsequently performed 100 percent source inspection of all arts.
Whittaker recently appointed a new Quality Assurance p(QA) manager and CE is reviewing a revision of Whittaker's QA manual.
l The inspector noted another instance of apparent Whittaker QA nonconformances in the CE files reviewed:
a CE letter referred to connectors built (and shipped) to an unapproved drawing.
i CE's control of procurement activities will be carried as an g
Unresolved item to be addressed in a future NRC inspection.
In the interim an NRC inspection of Whittaker is planned which will provide additional information on the subject.
(99900401/89-01-01) 2.
Part 21 Notification on Control Elements Assembly (CEA) Slippage On April 20, 1989, CE submitted a 10 CFR Part 21 notification concerning slippage of two CEAs in different groups in Palo Verde 1.
The inspector interviewed CE engineering personnel and reviewed a CE Nuclear Safety Committee review memo dated April 21, 1989.
In conjunction with the licensee, Arizona Nuclear Power 1
Project (ANPP), CE developed an explanation for the event.
I The event is believed to be restricted to plants using the four coil CE drive motor (CEDM) design unique to the three Palo Verde units and WNP-3 (which is not yet operating).
During assembly the insulation of the lower lift coil lead wires is believed to be damaged by an inside thread as the wires are fed through a l
hole.
The threads are subsequently covered by a nipple, preven-ting further abrasion of the insulation.
The lower lift coil is unique to the four coil CEDM, and is the only coil believed to move during rod motion.
Intermittent shorting of the damaged coil lead wires to the nipple is believed to be the source of electrical noise that adversely affects the rod control system.
Evidence supporting this hypothesis includes a plant history of intermittent ground faults and evidence of damage including arcing in two lower lift coils removed from Palo Verde 2.
Each of the 88 rods in a CE core has a three diode controller l
fed by a 240 volt three phase bus conunon to all 88 rods.
Each l
phase has a zero cross detector that senses when the phase l
1 1
21 l
=
F ORGANIZATION: COMBUSTION ENGINEERING, INC.
WINDSOR, CONNECTICUT REPORT INSPECTIO'l NO.: 99900401/89-01 RESULTS:
PAGE 6.of 6 voltage crosses zero and triggers gate circuits for the diode controllers. Adjustable celays in the gate. circuits for each individual roc control the actual dc voltage applied to the CEDM coils. Since the noise caused by intermittent shorting of a defective lift coil is introduced into the common three phase bus, the rod with the lowest CRDM voltage based on'.the gate i
circuit delay adjustments is most likely to be affected by noise anywhere.in the power system. Thus in addition to possible slippage of the rod experiencing intermittent short circuits, one or more additional rods without regard for group assignments could also slip. Testing by CE with low-resistance ground paths supports this explanation.
The analysis described above indicates that an intermittent fault in the lower lif t coil can cause the af fected rod to slip and can cause slippage of one or more additional rods. Although similar rod control systems are used in other plants, the four coil CEDM design appears to be a necessary contribute and that design is used only at Palo Verde and WNP-3.
Final resolution of the problem depends on further analysis and testing by ANPP and CE. The inspector concluded-that analysis to date supported the 10 CFR Part 21 report in restricting the probable scope to Palo Verde and WhP-3.
F.
PERSONS CONTACTED
+W. A. Goodwin, Director, Technical Services and Products
- A. E. Scherer, Director, Nuclear Licensing
- +S. A. Toelle, Manager Nuclear Licensing
- +J. M. Betancourt, Senior. Consultant, Licensing
- +J. M. Burger, Manager, Reactor Mechanical Systems M. J. Linden, Senior Engineer, Reactor Mechanical Systems
+R. J. Fitzgerald, Director, Quality 0perations S. L. Mara, Senior Engineer, Quality Operations
- C. W. Ruoss, Manager, Mechanical Engineering and Technology e-
- W. R. Hudnell, Task Manager (CEDM Control)
- Attended entrance meeting on May 22, 1989
+ Attended exit meeting on May 25, 1989 1
22
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION INSPECTION NO.: 99900404/89-01 DATE: June 28-29, 1989 OH-SITE HOURS: 34 CORRESPONDENCE ADDRESS: Westinghouse Electric Corporation Nuclear and Advanced Technology Division ATTN: Mr. Carlo L. Caso, General Manager Post Office Box 355 Pittsburgh, Pennsylvania 15230 ORGANIZATIONAL CONTACT: Mr. David Alsing, Manager, Quality Assurance TELEPHONE NUMBER:
(412)256-6028 NUCLEAR INDUSTRY ACTIVITY: Westinghouse provides nuclear steam system and other components and services for nuclear power plants.
1 A
l i,
/
ASSIGNED INSPECTOR:
fus
/, /jms 8 L' 9/
Jotepp(J. PetTosino, Reactive Inspection Section - Aate' Ho. 1 RIS-1)
OTHERINSPECTOR(S):
J. A. Gavula, NRC Region III, Division of Reactor Safety
, / C
'Z..'. -
.M., / [/
APPROVED BY: _
M f
E. T. Baker, Chief, RIS-1, Vendor Inspection Branch ate INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and Appendix B to 10 CFR Part 50.
B.
SCOPE: This inspection was conducted as a result of piping systems at ECook and Prairie Island that were found to be outside of their safety analysis report design limits due to incorrect weights and centers of gravity for Copes-Vulcan (CV) valves that were supplied by Westinghouse.
PLANT SITE APPLICABILITY: All Westinghouse Plants 23
ORGANIZATION: WESTlHGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 2 of 9 A.
POTENTIAL ENFORCEMENT FINDINGS:
Contrary to Section 21.21, " Notification of f ailure to comply or 1.
existence of a defect," of 10 CFR Part 21 Westinghouse has failed to adopt and implement appropriate procedures to ensure that each customer of Westinghouse safety-related components or services is g
notified of deviations in those instances where Westinghouse cannot perform a complete evaluation (89-01-01).
Contrary to Section 21.51, " Maintenance of Records", of 10 CFR 2.
Part 21, Westinghouse has failed to maintain records sufficient to assure compliance with Part 21 requirements (89-01-02).
i B.
NONCONFORMANCES:
None 1
C.
UNRESOLVED /0 PEN ITEMS:
i None.
D.
PREVIOUS INSPECTION FlHDINGS:
l Not reviewed during this inspection.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Entrance and Exit Meetings The scope of this unannounced NRC inspection was discussed with the Westinghouse representatives during an entrance meeting on June 28, 1989. The inspectors' findings regarding Vestinghouse's failure to notify its customers of potentially reportable deviations was discussed, as was the inspectors' perception of the root cause of the problem. Additionally, the inspectors obtained the Westinghouse commitments listed below, which were subsequently reiterated to the NRC by Westinghouse personnel during a July 7, 1989 telephone conversation between Mr. Rupprecht of Westinghouse and Mr. Petrosino of NRC, Westinghouse will identify all CV valve assembly drawings a.
and identification numbers that have been supplied by Westinghouse as safety-related, b.
Westinghouse will determine the correct weight and center of gravity information for all CV valve assembly drawings.
24
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION N0.: 99900404/89-01 RESULTS:
PAGE 3 of 9 c.
Westinghouse will notify each applicable customer of any errors and delineate the errors regardless of whether or not the corrections have been previously supplied to the customers.
d.
After customer notification, Westinghouse will provide whatever customer assistance is necessary.
l e.
Westinghouse will discuss their corrective action plans with NRC staff to ensure staff acceptance of their actions, i
f.
Westinghouse will perform a detailed study of what happened
{
in order to prevent recurrence.
2.
Copes-Vulcan Valve Weight and Center-of-Grevity Issue 1
The NRC concern was identified in part during a 1988 Northern States Power Company (NSP) engineering review by NRC Region III personnel regarding the applicability of the seismic issues dis-cussed in NRC Bulletin 79-14. During NSP's Prairie Island engineering review of its seismic piping system analyses, design basis information for one specific CV valve could not be found.
As a result, the engineering consultant, Fluor Daniel (F-D),
requested the valve design information from CV.
Prior to F-D receiving the valve design information from CV, the original design basis documents were found by F-D, who compared the i
information to the original seismic analyses input and found the data to be consistent. However, after receiving and reviewing the new CV design information, F-D noted that it contained dif-ferent, nonconservative valve assembly weights and center-of-:
i gravity (CG) data.
As an example, the original small bore CV valve assembly information showed a specific valve assembly weight to be 170 pounds and its CG to be just above 5 inches 1
from the datum point. Conversely, the 'new CV valve assembly j
information indicated the same valve to weigh 240 pounds and have a CG of 19 inches from the datum point.
The new CV supplied weights and CG data-were then inserted into the original stress calculation at Prairie Island. As a result i
of the new analyses, several Prairie Island piping system stresses were found to exceed the Final Safety Analysis Report (FSAR) requirements.
In one instance stresses increased from approximately 31,000 psi to approximately 161,000 psi.
25
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 4 of 9 In a June 21, 1988 NSP letter to W, TS-88-096, NSP identified approximately 15 W valve identification numbers and associated drawings to W.
tee NSP letter queried W on the validity of the weights and Benters-of-gravity and whetEer this is'a 10 CFR Part 21 issue, since en NSP reanalysis did determine certain lines to be stressed beyond the Prairie Island Updated Safety Analysis Report (USAR) limits. W res)onded back to NSP in a July 8, 1988 letter, NSP-80-176, thai it and concluded that the valve weight and center-of-gravity changes did not create any safety concerns within the scope of the W piping analysis work. Additionally the W letter states, that determination of whether there are any 10 CFR Fart 21 issues related to B0P piping analysis would be dependent on their evaluation.
It is noted that the 15 BOP valves had not previously been identified to NSP by W as having incorrect weights and cgs, nor is there any record which indicates that the 15 CV valves identified by NSP were evaluated by W_ pursuant to Part 21.
During an NRC inspection at CV, it was revealed that Westinghouse originally became aware of the problem around October / November-1979 and visited the CV facility to discuss the circumstances of the issue. The meeting minutes were documented on a Westinghouse Trip / Conference Report, VG-TR-027, dated November 28, 1979. Under the heading of " Weight /CG of D-100 Actuator, Bechtel Question," the following minutes were stated as follows on the Westinghouse report:
" Inadvertently the Copes sales agent in Alabama received a request to check out some weights on Copes Vulcan valves.
This request was transmitted to Copes Sales - a. sales rep, that does not handle W contracts. Drawings were reviewed and then center of gravities [CG] were checked and'due to some errors, drawings were revised and directly submitted to Bechtel. This caused some embarrassment to Westinghouse as Bechtel contacted Westinghouse, advised them they had received uncontrolled (not officially submitted by Westing-house) updated drawings and asked for a review on all-drawings containing D-100 actuators. Westinghouse then emphatically informed Copes [that] any verbal or physical transmittal of information of this type must be funneled through Westin house. Currently on the Bechtel Letter there are forty-two 42) drawings-inquestion.
It takes approxi-mately three ( ) hours to review a' drawing and check C.G.,
which is a total of three (3) solid weeks of drafting time.
26
- ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 5 of 9 At the present time on drawings reviewed by Copes the weights were in the 110% as required by Westinghouse.
1 However, C.G., worse case condition, some were out four (4) l inches.
Copes [is] to review the 42 drawings and try to complete and advise Westinghouse'of results by 12-31-79.
L. Ezekoye to supply complete list of all drawings involved by 1-31-80."
The Copes-Vulcan representatives stated that when they became aware of the problem they immediately corrected all of the valve assembly drawings that were applicable to open purchase orders and corrected the CV in-house drawings where the purchase orders had already been closed. The inspectors determined that W documented.its disposition of the matter in its internal memo, NS-RAW-272, dated November 25, i
1980, " Minutes of the April 22, 1980 meeting of the Safety Review Committee [SRC]." The disposition of the issue on the SRC meeting l
minutes was identified as 10-80-159 and stated in part:
j q
"Since identification of the initial valve problem (NRC I&E Bulletin 79-04, " Incorrect weights for Swing Check Valves Manufactured by Velan Corporation,") Westinghouse has car-ried on a program of monitoring valve weights. As a result of a customer's request for information for use in respond-ing to NRC I&E Bulletin 79-14 on reconciliation of us-built conditions it was found that the discrepancies exist between information found on the asbuilt drawings and actual valve weights and centers of gravity for approximately 40 Copes Vulcan Valves. Discrepancies in weight are generally small with only 5 valves being overweight by more than 20%.
Centers of gravity vary from 8 to 12 inches. The discrepancies resulted from errors in the calculational techniques used by Copes Vulcan at the time. The errors in the calculational techniques have been corrected and the new techniques verified by actual tests.
It was pointed out that this error involved on3y Copes Vulcan valves.
For those plants in which the original analysis was in Westinghouse scope, l
we are reanalyzing, and will inform customers of any design 4
modifications recommended.
SRC voted unanimously that the item was not a safety issue but that a status report update (as part of Westinghouse's ongoing effort related to NRC Bulletin 79-04) be transmitted to the NRC.
They [SRC] voted four to two in favor of' notification of affected customers prior to NRC notification (Esselman and Kaleagainst). Affected customers were notified in writing on April 30, 1980."
27
lI l
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA-REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 6 of 9 W identified this CV issue to the NRC in a W letter to.the NRC, NS-TMA-2236, dated April 24, 1980, regardin[NRCBulletin79-04,
" Incorrect Weights for Swing Check Valves Manufactured by Velan Engineering Corporation."
It is noted that W characterized the CV issue to the NRC staff as small discrepancies which have been corrected, verified by testing, and something which W customers would be notified of if any overstress conditions arose. The letter also states that W has informed all of its utility customers of the discrepancy. The W 1etter states, in part:
...in conjunction with an applicants request for information, it has come to our attention that discrepancies exist in the weight and location of the center of gravity for certain Copes-Vulcan valves. Upon receipt of this information Westinghouse initiated an investigation of this issue as an adjunct to our on-going program to monitor valve weight... The purpose of this letter is to provide the staff with a status report on this investigation.
The valves are three inch and under, air-operated valves. To date, approximately 40....
valves have been identified with discrepancies between infor-mation... drawings and actual valve weights and centers of gravity.
In general, the discrepancies in... Weights are small with only 5 valves being overweight by more the 20%..
centers of gravity, discrepancies generally varied from 8 to 12 inches....
This error has recently been corrected and the new [CV) techniques verified by actual tests.
Subsequent to obtaining the revised valve weight and center of gravity information, Westinghouse performed piping reanalyzes for a-system in Westinghouse scope with one of the Copes-Vulcan valves. The results from this one analysis confirm the previous conclusion... that reanalyzed stresses are below the allowable limit.
Reanalyses are underway for those systems for which the original analysis was in Westinghouse scope in which other... Copes-Vulcan valves are installed. Should any-overstress conditions exist, the customers will be informed and design modifications recommended.... Westinghouse has informed all of our utility customers of the existence of this discrepancy...."
This W 1etter was signed by T. H. Anderson, Manager, Nuclear Safety Department.
The NRC inspectors requested that W provide its justification and rationale for the above dispositioli in the required " evaluations" format. However, W could not retrieve its evaluation for the CV l
28
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 7 of 9 issue disposition. The NRC inspectors also requestea that W providethemwithanyrelevantdocumentsthatcouldhelpexplain exactly how W had handled this issue pursuant to 10 CFR Part 21.
The documenti provided to the NRC inspectors that were relevant to the required W evaluation activities did not indicate an adequate evaluation wai performed or appropriate notifications were made.
In conclusion, the Copes-Vulcan valve assembly weight and center-of-gravity issue was incorrectly charactertzed to the NRC by W, and W failed to notify all of its affected customers.
These failures are potential enforcement findings (89-01-01).
3.
Pacific Pump Weight Issue During this inspection, the NRC team members met with members of a joint licensee audit team which was simultaneously inspecting the Westinghouse Monroeville facilities. The licensee team consisted of corporate end. site engineering and qualit personnel from Pacific Gas and Electric Company (PG&E)y assurance and Southern California Edison Company (SCE). During discussions between the two teams it was revealed that the licensee team identified several potential findings and some appeared to be similar to the above noted apparent violation.
For example, one licensee identified issue involved incorrect safety injection (SI)pumpweightsthatwereprovidedtoPG&E'sDiabloCany(W)and on facility by Westinghouse. Discussions with Westinghouse licensee personnel have identified the following information:
(1) W supplied PG&E four Pacific Pump Company pumps with WestTnghouse motors and associated drawings for PG&E's SI system application; (2) The associated drawings identified that the pumps weighed 2,070 pounds (1bs) and were for non-nuclear
" auxiliary pumps," instead of the nuclear safety injection pump; (3) The weight of the Pacific pumps that were supplied by W was actually 3,650 lbs.; (4) PG&E querried W on whether the puiiip weight deviation had generic implications. W responded back to 4
PG&E in a January 20, 1989 letter, No. NS-0 PES-Il 89-042, that no generic issue exists regarding other utilities; (5) The typical W scope of analysis work regarding SI pumps appears to not Include the actual floor mounting details at a licensee facility.
Therefore, W would not be cognizant of all of the details of specific licensees' applications; and (6) It appears that at least three other facilities could have received the incorrect data:
D.C. Cook, Indian Point 2 & 3, and Zion.
29
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH. PENNSYLVANIA REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 8 of 9 This is another example of W failure to inform customers of deviations that cannot be c3mpletely evaluated by W and con-tributed to potential enforcement finding 89-01-01, 4.
Westinghouse Potential Issue Files AreviewoftheWpotentialissue(PI) files 80-00137,89-001, and ID 80-156 was performed by the inspector. The W PI files supposedly represent the " evaluation" that is required pursuant to 10 CFR Part 21. Discussions with W personnel were conducted in conjunction with the review to clarify or resolve issues.
Based on a review of the P1 files and discussions with the W Manager of Regulatory and Legislative Affairs, it appears teat the W P1 files are a record of the disposition of some deviations, but typically do not state the justification or rationale for the disposition. When the inspector asked where the 10 CFR Part 21 evaluation was located he was told that there is no central or I
specific location for the evaluetion to be filed.
Instead, the Part 21 evaluation could be located in the licensee project file, engineering files or other location. W does not maintain any central file for its Part 21 evaluations to assure the maintenance of records required under Section 21.51.
The Part 21 definition for " Evaluation" states:
"means the process accomplished by or for a licensee to determine whether a particular deviation could create a substantial safety hazard". Based on W H
inability to provide documented evaluations, including justifica-tion for disposition of deviations, the inspector could not deter-mine whether W adequately accomplished the Part 21 evaluation for the issues ad3ressed in these files. This also raises a generic concern regarding W ability to retrieve documentation of Part 21 evaluations. This inability to provide documentation to demon-strate adequate evaluations were performed is a potential enforcement finding (89-01-02).
i J
30
]
.i; ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA 3
REPORT INSPECTION NO.: 99900404/89-01 RESULTS:
PAGE 9 of 9 L
F.
PERSONS CONTACTED:
I D. Alsing W
QA Manager S. Rupprecht W
Licensing Manager, Operations J. McAdoo R
Safety Department Asst. Ngr.
R. Wiesemann W
Regulatory and Legislative Mgr.
l R. Tajc R
QA Engineer M. Zegar R
Auxiliary Equipment Engineer H. Abromovitz U
Product Asst. Mgr.:
A. Young PGE QA Departnent S. Skidmore PGE QA Department D. Taggart PGE QA Department i
1 i
l i
31 i.
ORGANIZATION: ROTORK CONTROLS, INCORPORATED ROCHESTER, NEW YORK REPORT INSPECTION INSPECTION NO.: 99900839/89-01 DATE:
September 12-13, 1989 ON-SITE HOURS:
17 CORRESPONDENCE ADDRESS:
Rotork Controls, Incorporated J
19 Jet View Drive Rochester, New York 14624 ORGANIZATIONAL CONTACT: Mr. Doug May.la, QA Manager TELEPHONE NUMBER:
(716) 328.550 NUCLEAR INDUSTRY ACTIVITY: Electric and hydraulic actuators for valves.
ASSIGNED INSPECTOR:
O&
a #f Uward T. Baket, Reactive Inspection Section No. I ae OTHERINSPECTOR(S):
APPROVED BY:
kd h w
,t/C
/c d5 E. William Brach A ief, Vendor Inspection Branch E
INSPECTION BASES AND SCOPE:
A.
BASES: Appendix B to 10 CFR 50, 10 CFR 21 B.
SCOPE: Review QA program elements applicable to design control, procurement, and dedication of commercial grade items.
l PLANT SITE APPLICABILITY: Fitzpatrick (50-333) l 33 i
I ORGANIZATION: ROTORK CONTROLS, It!CORPORATED
[
ROCHESTER, NEW YORK
.l REPORT INSPECTION NO.: 99900839/89-01 RESULTS:
PAGE 2 of 6 A.
VIOLATION:
None.
B.
NONCONFORMANCES:
1.
Contrary to Criterion III of Appendix B to 10 CFR 50 and Paragraphs 4.2 and 4.2.1 of Section 3 of Rotork's QA Manual, on j
Anchor Darling Valve Company Purchase Order (PO) G-1942 and Revision 1 to the P0, Rotork personnel failed to route Nonstandard Product Request Forms 916 and 1087 to the QA Manager for review and approval.
(89-01-01) i 2.
Contrary to Criterion III of Appendix'E to 10 CFR 50 and List of Parts, LOP 050, Rotork used 3/8" diameter,1" sockethead capscrews.-
purchased consnercial grade-to hold down thrust rings without verifying that the capscrews-met the 70 tons / square inch requirement listedonLOP050fortheitem(Item 69).
(89-01-02) 3.
Contrary to Criterion IV of Appendix B to 10 CFR 50 and Paragraph 5 of ANSI N45.2., Paragraph 3.4 of Appendix A to Section 7 of Rotork's QA manual does not require that suppliers to Rotork pass QA requirements down to their suppliers under any circunstance.
(89-01-03) 4.
Contrary to Criterion IV of Appendix B to 10 CFR 50 and t
Paragraph 3.6 of Section 4.0 of Rotork's QA Manual, two P0s to ASCO for solenoid valves qualified to IEEE-323 and 344 were not approved by the QA manager and did not include appropriate QA requirenents.
(89-01-04) 5.
Contrary to Criterion V of Appendix B to 10 CFR 50,.Rotork had no documented instruction or procedures on how items returned from customers were to be handled, resulting in replacement ASCO solenoid valves being ordered without appropriate QA
..1 requirements.
C.
UNRESOLVED ITEMS:
During the inspection, Rotork's Part 21 procedure was reviewed and the inspector reviewed the changes which were made to the procedure as a result of a previous NRC inspection and guidance. The procedure described-the actions to be.taken when a defect was determined te exist, i.e., report it to the NRC. However the revised procedure did not cover actions to be taken when a deviation exists that Rotork 34 l
ORGANIZATION; ROTORK CONTROLS, THCORPORATED ROCHESTER, NEW YORK REPORT INSPECTION NO.:
99900839/89-01 RESULTS:
PAGE 3 of 6 cannot perform the evaluation to determine if the deviation could create a subttontial safety hazard, i.e., report the deviation to their custoner.
In discussing these concerns with Rotork's QA Manager, he informed the inspector that the current Part 21 procedure was rewritten during the last NRC inspection and was found acceptable as rewritten.
It is recognized that NRC comments on the procedure l
inadequacies during the previous inspection were inadequate or incomplete. As a result this issue is categorized as an Unresolved Issue, 89-01-06, and corrective action will be reviewed during a future inspection.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
There were no findings during the previous inspection.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Entronce and Exit Meetings i
The NRC staff informed Rotork's managenent representatives of the scope of the inspection during the entrance meeting on September 12, 1989, and summarized the inspection findings and observations during the exit meeting on September 13, 1989.
2.
QA Program Rotork has a single QA program written to meet' Appendix B and ANSI N45.2, which is applied to their three actuator lines, the nuclear qualified electric motor driven A-series, the 1
quarter-turn electric motor driven AQ-series, and the pnuematic P-series. Suppliers to Rotork may be qualified by audit, review of the supplier's QA manual, or historical performance.
a.
Design Control According to Rotork's QA Manual, anyone can suggest a product modification through the product nodification system. The inspector reviewed the modifications listed in the Engineering Design Mods Report Log for the period 1984 to present. Two modifications were selected for detailed review. The modifications had been evaluated for affect on 1
the actuator's qualification and found not to affect qualification. The appropriate parties had reviewed and approved the modifications.
35
ORGANIZAT10ll: ROTORK CONTROLS, INRORPORATED ROCHESTER, liEW YORK P.EPORT INSPECTION NO.: 99900839/89-01 RESULTS:
PAGE 4 of 6 During discussions with Rotork personnel concerning the sources of parts for the valve actuators, it was determined that all parts for the nuclear outlified electric o)erators are ordered from Rotork Limited, Bath, England, wit 1 the exception of fasteners, which are procured locally from a supply house. When asked which fasteners are considered critical to the functioning of the operator, Rotork's Er.gineering l'anager stated nnly the 3/8" diameter,1" long sockethead capscrews that hold down the thrust ring are considered critical. When asked for a copy of a PO for the f asteners, Rotork personnel provided a PO to Rochester Screw
& Bolt Company that included this fastener which was ordered comercial grade. When the inspector asked to see the design requirements for the copscrew, Rotork personnel provided List of Parts, LOP 050. The capscrew was listed as Item 69 and described as a 3/8" x 1" UNC sockethead capscrew, 70 tons / square inch tensile strength. When questioned by the inspector, Rotork personnel stated that no action was taken to assure that the capstrews purchased as comercial grade met the tensile strength requirement. This was identified as Nonconformance 89-01-02.
b.
Procurement Document Control The inspector's review of the QA Manual revealed that Rotork's Supplier Quality Assurance Policy, Appendix A to Section 7 of the QA Manual, did not require Rotork's suppliers to pass applicable QA requirements down to subtier suppliers. This was identified as Nonconformance 89-01-03, c.
Control of Purchased Material Equipment and Services Rotork's QA Manual allows suppliers to be qualified based on product quality historyl. audits, or review and approval of the suppliers' QA manua For all purchased material, Rotork maintains a computerized data file, by supplier and part number, on thc c,uality of items supplied.
For all items produced domestically under a Rotork part number, Retork performs a receipt inspect of all dimensions and drawing notes on a sample of parts received. The sample size is based on a Mil-Std-105D single sampling plan.
Every three months the QA department calculates a Vendor Rating based on the number of parts supplied and the number accepted. The rating is mailed to the vendor and includes 36 e
I ORGANIZATIOD ROTORK CONTROLS,1HCORPORATED ROCHESTER, NEW YORK
~
REPORT INSPECTION NO.: 99900839/89-01 RESULTS:
PAGE 5 of 6 a request for corrective action for a rating of 4 percent or greater rejected parts.
If a corrpany has a reject rate of 5 percent or greater for three consecutive quarters, the company is removed from the approved suppliers list.
For the nuclear qualified line, there are only two qualified vendors, Rotork, Ltd. and Carboline Company, the paint manufacturer..Both companies are audited on a three year cycle and Rotork tracks the quality history of the parts received.
Products from these two companies are accepted r
based on Certificates of Conformance.
d.
Control of Returned Equipment In reviewing the QA Manual the inspector noted that control of equipnent returned for repair, replacenent, or any other reason was not covered by the QA Manual. Rotark personnel i
explained that all returns are handled by the service department. However, there are no written instructions or procedures covering the service department's activities.
This findit.g is identified as Nonconformance 89-01-05.
All returns are listed in a log book, Service Request / Returned Material Request Log.
The inspector selected 13 packages for review. Of the 13 packages selected for review, only 2 were for actuators for nuclear power plants, and of those 2, 1 had a discrepancy.
SE-4820 was written to modify a pnuematic actuator ordereq by Anchor Darling, P0 G-1942 and Revision 1, for use at the Fitzpatrick nuclear plant on a feedwater nonreturn checkvalve.
Part of the modification involved changing out two ASCO solenoid valves for the same I
model valve, but with 6-foot leads.
The modification was t
documented on Nonstandard Product Request Form 1087, dated March 16, 1989.
PO 32079 was placed with ASCO on May 9, 1989 as a comnercial grade order.
The inspector reviewed Anchor Darling's order to Rotork and noted that the P0 required the ASCO solenoid valves be certified to IEEE-323 and 344. The inspector then asked to see the paperwork for the original actuator. The inspector reviewed Nonstandard Product Form 916 and Rotork's original P0 to ASCO, P0 30878, dated September 8, 1988. This P0 was also a commercial grade order. Additional review of the nonstandard product forms and the P0s revealed that the QA Manager had not reviewed or approved any of them. The failure to have QA review the nonstandard product forms resulted in Nonconformance 89-01-03 and the failure to includa appropriate QA requirenents 37
l ORGANIZATION: ROTORK CONTROLS, INCORPORATED l
ROCHESTER, NEW YORK REPORT INSPECTION NO.: 99900839/89-01 RESULTS:
PAGE 6 of 6 in the P0s to ASCO and have the QA Manager review the P0s resulted in Nonconformance 89-01-04. Rotork took prompt corrective action and issued a modification to the PO to ASCO, requiring the valves be nanuf actured under ASCO's QA program.
The revised P0s were reviewed by the QA Manager.
F.
PERSONS CONTACTED:
Robert Arnold, President Daniel Brown, Manufacturing Manager Doug Matla, QA Manager Mark Saltzer, Purchasing Manager Fredric Washburn, Engineering Manager a
5 All parties listed above ettended the exit neeting, 38
1 ORGANIZATION: WHITTAKER CORPORATION SIMI VALLEY. CALIFORNIA l
REPORT INSPECTION INSPECTION NO.: 99901164/69-01 DATE: June 20Q2,1989 ON-SITE HOURS: 22 4
CORRESPONDENCE ADDRESS: Mr. Timothy E. Conver. President Electronic Resources Division i
Whittaker Corporetion 1955 N. Surveyor Avenue Simi Valley, California 91063 i
ORGANIZATIONAL CONTACT: Mr. Fred P. Rudek, Mar,oger Quality TELEPHONE NUMBER:
(805) 584-410')
i
.-rg e NUCLEAR INDUSTRY ACTIVITY: Manufactures meta 14hathed cable and connector assemblies for numerous Combustion Engineering (CE) core exit thermocouple and reactor vessel level monitoring systems, end for General Liectric in-core nuclear instruments.
Sales are divided roughly oyn11y between nuclear and aerospace applications, although the nucitar application was developed only within the last ten years.
r ASSIGNED INSPECTOR:
R.C. Wilson,SeniorReactTr'Y6Miieer ae Reactive Inspection Section Not, 2 (RIS-2),VendorInspectionBranch OTHERINSPECTOR(S):
g APPROVED BY:
bd
[sh -+ M
' SMD Uldis Potapovs, Chieft Reactive Inspection Section No. 2 Date (RIS-2),VendorInspectionBranch i
l INSPECTION BASES AND SCOPE:
A.
BASES: 10 CFR Parts 21 and 50 B.
SCOPE: This inspection was made as a result of an allegation concerning TaTof adequate quality assurance at Whittaker, including improper use of-silicone material in place of hermetic seals, in safety-related cable and connector assemblies for nuclear power plants.
PLANT SITE APPLICABILITY: Numerous 39
ORGANIZATION: WHITTAKER CORPORATION SIMI VALLEY. CALIFORNIA REPORT INSPECTION NO.: 99901164/89 01 RESULTS:
PAGE 2 of 10 A.
VIOLATIONS:
None B.
NONCONFORlW CES:
None C.
UNRESOLVED ITEllS:
None D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
None. This was the first NRC inspection of this facility.
E.
INSPECTION FINDINGS AND OTilER COMMENTS:
1.
Allegation Scope The allegation consists of two parts, both related to the nanufacture of cable and connector assemblies supplied for safety-related applications in nuclear power plants. The concerns are as follows:
a.
It was 611eged that a silicone sealant was used iniproperly and without the knowledge of customers, principally Combustion Engineering, Incorporated (CE),priortoSeptember1988.
b.
It was alleged that Quality Assurance (QA) for the manuf acture of the assemblies was inadequate.
These two concerns were conveyed to Whittaker and were addressed during this inspection.
To obtain relevant information concerning customer requirements, a previous inspection was conducted at CE on May 22-25, 1989 as documented in Inspection Report 999000401/89-01, 2.
Use of Silicone Sealant by Whittaker The inspector initially understood this allegation concern to relate to the cable end seal discussed in section E.1 of Inspection report 99900401/89-01.
Information provided by Whittaker redirected the concern to address a silicone 40 1
ORGANIZATION: KHITTAKER CORPORATION l
SIMI YALLEY, CALIFORNIA REPORT INSPECTION NO.: 99901164/89-01 RESULTS:
PAGE 3 of 10 l
coating applied to the ceramic bead inserts in the connector design manufactured from 1984 to 1988.
The product under discussion consists primarily of ceramic insulated, metal-jacketed multi-conductor electrical cables l
with connectors at both ends.
Further description including applications is addressed in the inspection report cited above.
Prior to 1984, CE provided Whittaker with connectors from another manufacturer for assembly to the Whittaker cables.
In 1988 Whittaker began manufacturing a new connector design which does not use the silicone sealant.
The design
~
introduced in 1984 included a metal header plate with holes for the electrical contacts.
Each contact pin was surrounded by a small ceramic bead.
The assembly was oven-fired to fuse the ceramic and produce ceramic to metal hermetic seals. Depending on tolerances on the pin and hole diameters, header thickness, and quantity of ceramic, the molten ceramic could slightly under-or over-fill the annular gaps. The resultant meniscus could result in cracks in the surface glaze near its edge. The cracks could affect both leak tightness and electrical insulation resistance. The deficiency was detected by an insulation resistance (IR) test on the connector prior to its assembly to cable.
The inspector reviewed production control route cards for 181 connectors to assess IR test failure rates.
Interviews with experienced production, manufacturing, quality, and engineering personnel did not produce o consensus regarding the percentage of connectors that f ailed the IR test or any trend in. that percentage.
1 The personnel interviewed stated that for connectors that failed the IR test, a silicone fluid coating was applied to the insulators, followed by an oven baking. The personnel stated that if the connector passed the second IR test it was accepted; if not it was scrapped.
For the production control route cards reviewed by the inspector, all of the silicone treated connectors (slightly less than 10 percent of the total) passed the second IR test.
The treatment process is straightforward.
One manager stated that although not called out in procedures, it was considered a " standard rework,"
but its use was subject to approval by a manufacturing engineer.
41
ORGANIZATION: WHITTAKER CORPORATION SIMI VALLEY, CALIFORNIA REPORT INSPECTION NO.: 99901164/89-01 RESULTS:
PAGE 4 of 10 The silicone fluid used by Whittaker is described in the manufacturer's product sheet as a water-repellant coating.
Whittaker has used such products for 20 years, as evidenced by a 1969 manufacturing process specification for a similar coating, written to meet a Navy department specification.
The same coating is covered by a 1982 Whittaker manufacturing process specification for treating machined ceramic parts used as filler blocks in the assemblies provided to CE; in that application the machining removes surface glaze, and the silicone treatment is used for cleaning and to provide a final surface conditioning. The silicone fluid and solvent addressed by the 1982 specification is the same as was subsequently used on the multiple-bead connector headers.
Manufacturing procedures did not formally address the silicone coating for connector headers until April 20, 1987 when a new manufacturing process specification was issued.
Prior to that time procedures did not address the header coating, nor did they address whether or why it would be applied. The only documentation of its use appears to be hand-written addi-tions on the otherwise typed production control soute cards.
Whittaker management personnel explained that the division strongly relied on proprietary protection for its products for many years. Both military and civilian customers have agreed that the customer controls the product down to the top assembly level, ano Whittaker controls below that level.
Information provided to customers normally consisted of the following:
top level assembly drawing, weld schedules and tance test procedures and data, and rework samples, accep(This statement appears to be consistent with procedures.
files reviewed by the inspector at CE.)
Preparation of the 1987 coating specification appears to be an early step in improving internal process controls at Whittaker. The May 1988 CE audit clearly added impetus to that effort. Whittaker provided the inspector with a copy of a September 1988 specification control drawing that was submitted to and approved by an aerospace customer covering silicone treatment of connector header seals; this was cited as an example of a policy change toward providing more information to customers. The silicone treatment is not employed with the new single bead header connector design now supplied to CE.
42 l
i ORGANIZATION: WHITTAKER CORPORATION SIMI VALLEY, CALIFORNIA l
REPORT INSPECTION NO.: 99901164/89-01 RESULTS:
PAGE 5 of 10 f
With respect to 10 CFR 50.49 environmental qualification of t
theoriginal(1984-87) Whittaker connector design, CE's I
qualification basis was addressed in an earlier Inspection Report 99900401/88-01 dated January 10, 1989. The qualification basis appears acceptable subject to the l
question of whether the qualification test specimens had received the silicone ticatmer.t. Whittaker personnel were unable to locate appropriate records; the search is complicated by a 1987 relocation. There is no basis for concluding that the test specimen connector headers had received the treatment, although it is possible, based on present knowledge. The possibility that treated connectors may represent an EQ concern does appear remote, for the following reasons:
a.
Both CE qualification test programs, as well as Whittaker's recent testing of cable / connector assemblies for boiling water reactors, included machined ceran.ic blocks that were treated, and there is no evidence of poor electrical perforraance by those
- blocks, b.
The headers form only secondary seals in mated connectors, as would be of interest dering plant operation, c.
Protective caps with 0-rings and lanyards are provided to discourage moisture ingress when the connectors are not mated.
d.
The silicone dioxide cable insulation is relatively insensitive to humidity, unlike other ceramic cable insul6 tion. Whittaker personnel stated that it does i
not hydrolyze, and loses only about i to one decade of l
insulation resistance per year in ambient humidity if the cable end is completely open, e
I e.
The multiple bead connectors are no longer being I
manufactured for nuclear use.
Another seal concern raised by the alleger involves repair of connectors by drilling, then plugging, holes in their sides.
The inspector believes that this concern is the same as a problem cited in Inspection Report 99900401/89-01 at the end of section E.1, and the two will be addressed jointly.
43
+
,v-
ORGANIZATION: WHITTAKER CORPORATION SIMI VALLEY. Cid.lFORNI A REPORT INSPECTION N0.: 99901164/89-01 RESULTS:
PAGE 6 of 10 A November 13, 1987 CE letter to Whittaker on Purchase Order (PO) 9770018-71186 refers to five connectors supplied without a crimp sleeve for the ground contact, unlike 19 others that were specified as identical, all under CE PO 9770018-71186. Whittaker contract records show that most of the connectors were manufactured and certified by both Whittaker ano CE prior to the initial submittal of the drawing to CE.
Sone significant dates are as follows:
March 5,1987 - Whittaker internal release of drawing 16-99-008000 June 4,1987 - Whittaker test and inspection records and C of C June 11, 1987 - CE Certificate of Equipment signed by engineering and quality control " based upon source surveillance being performed at the vendor's facility" June 15, 1987 - First submittal to CE of drawing 16-99-00800 Following conditional CE approval, Revision A was made and was approved by CE on July 9, 1987. Of the 24 connectors shipped, 19 were built to Revision 0 and 5 to Revision A; the 2 differ in ground connection method.
Upon discovery of the different connector types by the third party to whom they were shipped, Whittaker prepared a Rework y
Procedure dated February 11, 1988 which was approved via a Technical Change Request to CE. The rework procedure was reviewed and discussed with the Whittaker manufacturing engineer who suptrvised connector assen.bly at the time of rework.
It involved drilling an access hole through the side of the connector body, inserting a solder cup and tMaded stainless steel rod, replacing potting material, and welding and blending the rod to the connector body. The potting material performed no sealing function; it filled void space to support wires.
The reworked connectors appear to be satisfactory. However, it is clear that Whittaker manufactured ano shipped connectors to an unapproveo orawing, and CE approveo the shipment; evidently neither acted further until they were informed by a third party that two different types of connectors were delivered.
Summarizing the silicone treatment concern, the NRC inspector concludes the following:
a.
An unknown quantity of connectors, possibly dozens, was supplied by Whittaker to CE with a silicone fluid treatment 44
. = -
ORGANIZATION 8 WHITTAKER CORPORATION SIMI VALLEY, CALIFORNIA REPORT INSPECTION NO.: 99901164/89-01 RESULTS:
PAGE 7 of 10 applied to the connector header insulators. Written
)
procedures did not address when or how to apply the treatment until April 1987.
The treatment improved performance with respect to two procurement specification parameters, leakage and electrical insulation resistance, i
b.
The treatnent was not used on the relatively small number j
of nuclear safety-related connectors supplied to General Electric Company, and is no longer used in the manufacture of any nuclear safety-related connectors, c.
The treatment is not believed to constitute a nuclear safety concern for reasons stated above, d.
Information gathered during investigation of the silicone
)
sealant concern clearly demonstrates that both Whittaker and CE failed to satisfy Quality Assurance concerns related to this equipment. This subject is addressed in the next I
section of the inspection repott.
l 3.
Adequacy of Whittaker Quality Assurance l
In detailing this concern, the alleger stated that during the first nine months of 1988 certain process specifications and workmanship standards were not available on the production floor, and that manufacture was accomplished to drawings handmarked by engineering to reflect customer order information. TheNRCinspectordeterminedatCE(seeinspection
-l l
report 99900401/89-01) that CE audits of of Whittaker in May and September of 1988 had revealed similar concerns, and CE and Whittaker had initiated actions to address the concerns.
khittaker quality assurance personnel told the ARC inspector l
that sone components were built to drawings marked ano signed by the project engineer, but that final inspection was performed only to approved drawings, and items could not leave the area without an approved Engineering Change Order. Whittaker management personnel also stated to the NRC inspector that documentation had been "not truly acequate," and that documentation was " poor." Reliance was ultimately placed on production personnel to ensure that nianufacturing operations were correctly performed, in turn, experienced assembly personnel stated that any deviation had to be approved by-someone not on the production floor (engineering, manufacturing engineering,orprojectengineering).
Assembly personnel also commented that they sometimes made notes to themselves on drawings.
45
ORGANIZATICh: WHITTAKER CORPORATION SIMI VALLEY, CALIFORNIA REPORT INSPECTION NO.: 99901164/89-01 RESULTS:
PAGE 8 of 10 Both the alleger and the 1988 CE audits noted that sales work orders were used to impart purchase order requirements to production, serving as the final inspection checklist.
Whittaker relocated from Burbank to Simi Valley, California --
about 30 miles -- in the spring of 1987. The move complicated access to some records. For example, during the NRC inspection a box of production route cards covering early 1987 could not be located, although adequate alternate information was provided to the inspector. -The relocation was obviously another complicating factor in records control.
Whittaker management stated that the company has always been straightforward with customers in informing them that the basic processes are Whittaker's and are not subject to customer controls.
In the case of the silicone fluid treatment, apparently CE was not made aware of the existence of the process until 6fter the new single bead header connector design made the process no longer applicable to CE contracts.
All of the CE P0s reviewed by the inspector invoke Revision D of CE Specification 00000-WQC-11.1, " Supplier Quality Control Program Specification for Quality Class 1 Equipment or Services" dated October 4, 1974. This specification for Quality Class 1 equipment covers much of the scope of Appendix D, but it provides CE with options concerning the extent of oversight applied to Whittaker.
Insofar as CE did not review the processes and methods by which Whittaker manufactured equipment, deficiencies in those processes and nethods were not identified by CE.
Even though CE may have elected not to address manufacturing processes, at least until 1987 or 1988, it is nonetheless clear that Whittaker's failure to have a procedure covering the silicone fluid treatment constitutes a nonconformance to section 6.5.1 to of the CE quality specification, which requires that activities af fecting quality must be controlled by written procedure.
Shipment of the connectors under PO 9770018-71186 without drawing approval is a nonconformance to Section 4.1.1.1 of the CE quality specification, which requires a vendor program that essures quality throughout all areas of contract performance. This is an anomaly for which Whittaker had no explanation.
46
i ORGANIZATION: FHITTAKER CORPORATION I
SIMI VALLEY, CALIF 0Rh!A REPORT INSPECTION N0.: 99901164/89-01 RESULTS:
PAGE 9 of 10 L
t The ongoing activities by Whittaker and CE appear to be l
correcting the deficiencies in Whittaker's quality program.
Several changes were noted as examples of quality improvenents:
L a revised set of controlled manufacturing procedures for i
connectors; computerized standard routing lists with specific references to applicable procedures; computerized sales order
+
descriptions providing all department with summaries of contract requirements; the Quality Assurance manual revisions being i
reviewed by CE; and reorganization so that the Quality Assurance Manager now reports to the division president.
1 Suncarizing the concern with respect to the adequacy of Whittaker's Quality Assurance, the NRC inspector concludes that deficiencies existed, most significantly with respect to the following:
a.
Lack of a procedure covering silicone fluid treatment of a
connector headers prior to April 1987.
b.
Shipment of connectors under PO 9770018-71186 without drawing approval in 1987.
These deficiencies are primarily historical in nature, and are considered to not have resulted in shipment of equipment that constitutes a nuclear safety concern. Numerous improvements in quality assurance have been noted since the CE audit in May 1988 and the NRC will continue to monitor Whittaker's and CE's actions in this regard.
l l
l l
~
47
ORGANIZATION: WHITTAKER CORPORATION SIMI VALLEY, CALIFORNIA F,EPORT INSPECTION NO.: 99901164/89-01 RESULTS:
PAGE 10 of 10 F.
PERSONS CONTACTED:-
- +T. E. Conver, President
- +R. H. Mauldin, Vice President, Engineering
- +R. Snyct.r, Vice President, Customer Service Operations
- +F. P. Rudek, Manager Quality
- +H. E. Simpson, Program Maneger
- +J. Sobelman, Manager, Manuf acturing Engineering
- +T. S. Whitehead, Manager, Manufacturing
- +G. P. Casey, Manager, Finance; Contract Administration
- +R. Lolley, Manager, Field Service and Training
- +J. MacLean, Manager, Materiels
+J. Torres, Supervisor, RF and HJTC Manufacture
- +J. Thomsen, Supervisor, QA Test
+J. Denny, Manuf acturing Engineer, Hernetics
+R. Cortez, QA Inspection D. Carle, QA Inspection
- 1. Reinhart, Connector Assenbly
- +C. Reinhart, Project Engineer
- +A. Harootion, Project Engineer
- +K. Wilson, Engineering Tech Staff
- +R. Couser, Senior QA Engineer
+F. Roy, Engineer (Patel Engineering, Contractor)
- otte.nded entrance neeting
+ attended exit meeting 48
i ORGANIZATION: RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANIA REPORT INSPECTION INSPECTION i
NO.: 99901170/89-01 DATE: September 5-8, 1989 ON-SITE HOURS:
54 CORRESPONDENCE ADDRESS: Ralph A. Hiller Company l
Mr. J. R. Hiller, President l
l 951 Killarney Drive
)
Pittsburgh, Pennsylvania 15234 i
ORGANIZATIONAL CONTACT: Mr. Michael Meketa TELEPHONE NUMBER:
(412)882-5300 NUCLEAR INDUSTRY ACTIVITY: Supplier of electrically operated pneumatic-hydraulic valve actuators ASSIGNED INSPECTOR:
\\Moh II 2 8 K. R. Naidu, Reactive Inspection Section No. I ate OTHERINSPECTOR(S):
H. M. Wescott U F '[
APPROVED BY:
/
Av ET T. Bater, ChTUT, RIS-1, Vendor Inspection Branch ae INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR 50 Appendix B and 10 CFR Part 21 B.
SCOPE: Review of implementation of the quality assurance program in selected areas; quality assurance records for valve actuators, observation of storage facilities PLANT SITE APPLICABILITY: All plants utilizing R. A. Hiller actuators 49
ORGANIZATION: RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 2 of 15 A.
VIOLATIONS:
Contrary to Paragraph 21.21 of 10 CFR Part 21, R. A. Hiller Company (RAH) did not establish and implement a procedure to evaluate deviations in the valve actuators supplied to nuclear power plants or inform the purchaser of the deviation in order that the purchaser may cause the deviation to be evaluated.
(Violation 89-01-01)
B.
HONCONFORMANCE:
Contrary to Criterion 11 of 10 CFR 50, Appendix B, RAH did not establish an adequate quality assurance program as documented in their quality assurance manual.(QAM), Revision G, dated December 6, 1988, as evidenced l
by the following examples:
1.
Contrary to Criterion 1 of 10 CFR 50, Appendix B, the authority and duties of currently employed persons performing activities affecting safety-related functions of components were not clearly established and delineated in writing.
Furthermore, a current organizational chart was not available.
(Nonconformance 89-01-02) 2.
Contrary to Criterion 111 of 10 CFR 50, Appendix B, and paragraph 5.4.1 of the RAH QAM, the Engineering / Quality Assurance Manager performs dual functions of reviewing design changes in his capacity as Engineering Manager and approving the same engineering changes as Quality Assurance Manager, thus compromising the independence of verifications. (Honconformance 89-01-03) 3.
Contrary to Criterion VI of 10 CFR 50, Appendix B, and paragraph 5.4.1 of the RAH QAM, the current drawing format does not have an " Approved" block in the lower right hand corner for the QA signature as indicated in Exhibit 4-2.
A "QA" stamp is affixed to the drawing in which the QA representative signs and dates the drawing to denote his review and approval..(Nonconformance 89-01-04) 4.
Contrary to Criterion XIII of.10 CFR 50, Appendix B, and paragraph 7.4.1 of the RAH QAM, safety-related stock parts are stored in an area which is not segregated.
(Nonconformance 89-01-05)
C.
UNRESOLVED ITEMS:
No unresolved items were identified during this inspection.
50
l ORGANIZATION:
RALPH Ao HILLER COMPANY PITTSBURGH, PENNSYLVANIA j
1 REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 3 of 15 i
D.
DETAILS:
1.
Purpose This inspection was conducted to determine the adequacy of the implementation of the RAH quality assurance (QA) program relative to the manufacture of actuators. The inspection was prompted by j
a notification from Commonwealth Edison Company (CECO) on June 19, 1989, to the NRC that during a product QA program audit of RAH, l
their auditors identified several deficiencies related to material traceability. The RAH actuators operate the main steam isolation I
valves (MSIVs) installed at the LaSalle County nuclear power plant.
The MSIVs were manufactured by Rockwell Manufacturing Company, which is currently kncwn as Edwards Valve Company, 2.
Background Information on RAH a.
Introduction RAH is a distributor of air actuators manufactured by The ShefferCorporation(TSC),locatedinCincinnati, Ohio.
In the early 1970's, RAH developed, engineered, and marketed
)
l an actuator to operate valves,-specifically MSIVs. The i
concept led to the development of sophisticated hydraulic, pneumatic, and electrically operated pneumatic-hydraulic valve actuators. The actuators are manufactured and tested at TSC in Cincinnati.
RAH provides the application engineer-
]
ing oversight, procures and dedicates the additional parts, such as solenoid operated valves (S0Vs), multiple-way air valves, and accumulators required to complete the assembly of the actuators.
RAH supplied actuators to various valve manufacturers for a variety of applications,- principally MSIVs. The RAH actuators were qualified either individually or as an integral component of the valve on which it was mounted to the requirements of Institute of Electric and ElectronicEngineers(IEEE) Standards 323,IEEE-344,and IEEE-382.
RAH stated that they independently qualified SA series valve actuators to the requirements of the above I
standards.
1 b.
Other services provided by RAH RAH stated that they furnish engineering services, including dedicated parts, to modify actuators manufactured by their competitors previously installed on MSIVs.
51
ORGANIZATION:
RALPH A. HILLER COMPANY P1TTSCURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 4 of 15 RAH stated that they supply actuators to replace existing actuators, provide services and material to refurbish installed actuators, and provide spare replacements for actuators originally supplied by them.
c.
Performance of RAH actuators Actuators supplied by RAH and installed on MSIVs enable operators of nuclear power plants to close, open, or exercise the M51Vs from the control room. Also, the reactor protection system logic can initiate a signal to the actuator to close the MSIVs when adverse operating conditions in light water Electrical power p(ower reactors are sensed by the logic.normally 120 Volts AC) and air pres are essential for the valve actuators to operate the MSIVs.
To date no specific failures have been experienced with RAH actuators.
However, problems have been experienced with electric SOVs assembled on the actuators and hydraulic oil used in them. These are discussed in the following:
(1). GEServiceInformationletter(SIL)No.329, dated June 1980, recommended the use of SF 1147 type hy-draulic fluid, which is known to withstand radiation and high temperature without deterioration.
(2). NRCInformationNotice(IN)82-25informedusersofa potential problem pertaining to RAH actuators which could prevent air-operated isolation valves from going to their fail-safe condition when the instrument air header (supplying air to the actuators) was slowly depressurized.
(3).
IN 88-43 informed users of a series of ASCO type S0Vs failures which resulted in MSIV operating problems.
The SOVs are installed on RAH operators.
(4). GE SIL No 481, dated February 14, 1989, informed users that due to the improper functioning of ASCO type dual S0Vs installed on RAH MSIV actuators, the MSIVs may not close after the receipt of signal to do so.
(5).
IN 89-66 alerted users to problems related to elastomers used inside ASCO NP 8323A20E type SOVs which may affect the oot.rability of MSIVs or similarly designed components.
The SOVs are installed on RAH actuators.
52
i ORGANIZATION; RALPH A. HILLER COMPANY PITTSBtJRCH, PENNSYLVANIA REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 5 of 15 j
=
(6).
In addition to the above documents, RAH stated that during refurbishing activities performed on actuators, they observed deterioration of the chrome plating inside the pneumatic cylinder due to moisture in the air supply.
3.
Review of Purchase Order for Duane Arnold Energy Center (DAEC)
The inspectors reviewed purchase order (PO) 205-89D-869, dated July 18, 1989, issued by General Electric Company (GE) to RAH to l
initiate advance engineering services to improve the performance of MSIVs installed at DAEC. RAH stated that GE supplied the original MSIVs which were manufactured by Rockwell Manufacturing Company and. fitted with RAH actuators. The MSIVs were reportedly experiencing problems related to successful completion of integrated leak rate tests.
Furthermore, the actuators were required to be upgraded to meet the environmental qualification requirements of NUREG 0588.
The above mentioned PO was to be followed by a PO to design, manufacture, test and ship eight RAH Model SA-A101 type actuators. The PO required RAH to supply the following :
a.
Actuators with control assemblies environmentally qualified to the requirements of NUREG-0588, Category 1.
1 b.
Quick disconnect cables to accommodate NAMCO limit switch connections.
The inspectors determined that six drawings which had been prepared I
by TSC are being currently reviewed by RAH. TSC prepared the static pressure rating calculations utilizing formulas from American National Standards Institute B 9310-1969, reaffirmed in 1976, for the pressure retaining components, such as, 5" bore hydraulic cylinder 20" bore pneumatic cylinder (including the cylinder head and cap),, tie rods, and tie rod nuts. These calculations were l
reviewed and approved by the RAH QA Engineer as indicated by his signature on the design documents.
4.
Review of the Components Supplied by RAH for the Hope Creek Actuators a.
Background
Valve actuators for the Hope Creek nuclear power plant ware originally supplied by the SP Manufacturing Corporation (SP),
Cleveland, Ohio, and were installed on MSIVs manufactured by Atwood and Morrill Company, Massachusetts.
53
ORGANIZATION:
RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO..
99901170/09-01 RESULTS:
PAGE 6 of 15 During 1984, GE issued a P0 to RAH to modify the actuators.
The modification consisted of replacing the pneumatic-hydraulic portion of the valve actuator with one designed by RAH and manufactured at TSC.
All the sealing surfaces were modified c - - -
to accormodate RAH seal designs.
The air manifold to this actuator was designed and manufactureo by Automatic Valve Company (AVC), Novi, Michigan, a sub-tier vendor of SP.
The RAH valve actuators currently being supplied to Hope Creek have the AVC manifolds.
=
b.
Review of the current GE P0 GE issued P0 205-89 D844, dated July 3, 1989, to RAH to design, manufacture, test, and supply four SA-A102 model pneumatic-hydraulic actuators intended to replace the existing modified actuators installed on the Hope Creek MSlVs.
RAH was required to assemble the air nenifold assemblies furnished by AVC.
The P0 required the actuators to be qualified to meet the requirements of IEEE-323-74 and 344-75 based on GE phase 111 Equipment Qualification Tests.
The standard GE QA requirements were required to be implemented. The items procured were considered safety-related and RAH was required to comply with the reporting requirements of 10 CFR Port 21.
RAH was to provide a list of the differences between Models SA-A076 and SA-A102 and to provide justification to apply the environmental qualification test results on Model SA-A076 to Model SA-A102 actuators.
RAH was required to provide a set of drawings, parts list, and an instruction manual for SA-A102 actuators for GE review and approval. The inspectors observed that RAH has reviewed and ap7 roved a complete set of 6 drawings prepared by TSC.
RAF has approved the list of materials developed by TSC.
=
c.
Review of the components supplied by RAH The components procured by RAH, Pittsburgh, and supplied to TSC, Cincinnati, Ohio, for assembly 01, the actuators nanufac-tured by TSC for use at Hope Creek included the following:
(1).
Four PCCMS-1600-SU-X0740 (MS-1600) flow control valves manuf actured by Parker Fluid Power Company (Parker),
E;y.la, Ohio.
Each actuator is fitted with one MS-1600 flow control valve to regulate the speed of the actuator extension.
54
ORGANIZATION: RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.:
99901170/89-01 RESULTS:
PAGE 7 of 15 (2).
FourPCCMS-800-SU20-X0742(MS-800)flowcontrolvalves also manufactured by Parker. Each actuator is fitted with one MS-800 flow control valve to regulate the speed of the actuator retractien.
(3). Hydraulic fluid manufactured by Harwick, Akron, Ohio.
SF1147 type hydraulic fluid is used in the hydraulic cylinder which operates in tendem with the pneumatic cylinder of the RAH pneumatic-hydraulic valve actuator, d.
Components provided by GE to assemble Hope Creek actuators.
GE procured the pneumatic control assembly to operate the pneumatic portion of the RAH pneumatic-hydraulic actuator f rom Automatic Valve Company ( AVC), Novi, Michigan.
RAH stated that GE instructed AVC to deliver the assenblies directly to TSC. This unique agreement arranged by GE was intended to retain the previously qualified portion of the pneumatic control assembly supplied to Hope Creek.
No adverse findings were identified in the above area at RAH. The inspectors witnessed the assembly and test of the Hope Creek actuators at TSC in Cincinnati during an inspection on September 12-15, 1989, the results of which are documented in Inspection Report 99901171/89-01.
5.
Review of Commonwealth Edison Company (CECO) PO i
The inspectors also reviewed CECO P0 No. 321957, dated August 25, 1988, to RAH for four actuators, Model SA-A022, for LaSalle County Station to be installed on the MSIVs manufactured by Rockwell International, 26-inch angle globe valves. These actuators were required to be duplicates of the originally sup-plied actuators. The P0 specified the documentation requirements such as, quality) assurance documents and certificates ofconformance (CoC, and The inspectors further reviewed RAH CoC, dated October 28, 1988, to CECO. The CoC referenced P0 No. 321957 and stated that the actuators supplied were in accordance with the requirements of CECO's P0. The CoC further certified that the actuators net the requirements of Specification RAL-GE-003, Revision 0, and were supplied in accordance with RAH QA Manual, Revision D, dated February 13, 1985, incorporating an addendum from CECO, dated ~
55 i
1
ORGANIZAT10N:
RALPH A. HILLER COMPANY PITTSBURCH, PENNSYLVANIA REPCRT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE D of 15 May 13,1985, and were tested in accordance with El-SA-A022.
The aodendum from CECO listed some additional requirements which RAH had to fulfill as a result of a " desk top" audit CECO per-formed on RAH. Discussion with an RAH representative established that all documents to substantiate the CoC were supplied to CECO.
6.
Review of Refurbishing Activities Supplied to Carolina Power &
Light (CPL)
The inspectors reviewed CPL P0 No. 537402M-BT-01, dated October 9, 1987, and CPL Requisition No. 7E0509, to RAH for actuators intended for installation at the Brunswick nuclear power plant.
This PO was.for the rework of three SA-A075 type pneumatic-hydraulic actuators identified with serial numbers 1169294, 1113521, and 1113328.
The P0 specified that in addition to the actuator with new parts (parts of the actuator controls were to be replaced rework, certain i.e., electrical). Attachment I to this P0 required that the actuator assemblies and individual components be qualified to meet the requirements of IEEE 344-1975, IEEE 323-1974, and IEEE 382-1980. Attachment 11 specified the QA requirements to be met and also stated that this PO was subject to the provisions of 10 CFR Part 21 reporting requirements.
The inspectors reviewed copies of documentation provided with the above reworked actuator assemblies. The documentation package consisted of an Inspection / Rework Report describing the damaged parts found and probable cause of damage, 000 for the components replaced by TSC and RAH, leak test reports, certification of Viton elastomer seals, including cure dates, to indicate the longevity of the Viton elastomer components; and a CoC certifying that devices supplied by their subtier suppliers were traceable to their appropriate test reports.
7.
Review of RAH Procured Components In addition to items listed in paragraph 4c, RAH typically procures various components, stores them at RAH facilities in Pittsburgh, and supplies them to TSC for specific P0s during the assembly of the actuators.
The components procured by RAH include the following:
a.
Electricsolenoidoperatedvalves(SOVs)
RAH purchases NP 8320A185V and HP 8323A20V type SOVs from Automatic Switch Company (ASCO), Florham, New Jersey. The above mentioned ASCO SOVs, which are insta11ei on the RAH actuators to control the directional movement of the actuators, are known to have successfully withstood the environmental 56
ORGANIZATION: RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANVA
]
f REPORT INSPECTION NO.: 99901170/89-01 RESVLTS:
PAGE 9 of 15 qualification requirements of IEEE 323 and 344.
RAH issued P0s to Continental Sales & Engineering, a distributor of ASCO SOVs; ASCO ships the SOVs directly to RAH. Typically, RAH purchases ASCO SOVs in lots of 50, performs receipt inspections, and stores them until they are required for a i
specific job. Since ASCO furnishes CoCs for the SOVs supplied, RAH do.s not perform additional tests and dedication.
b.
Quick disconnect cable connectors RAH purchases these connectors from Namco. These types of connectors have been qualified to the requirements of IEEE 323 and 34s by Namco. The connectors have a pin connector on one side and cables (pig tails) on the other side, which are ter-minated on a terminal block inside a junction box. The pin connector is intended for quick connection in the field to Namco limit switches installed on the MSIV. Namco provides CoCs for the quick disconnects.
RAH stated that they performed audits on Namco in the past to verify that their quality assurance program meets the requirements of ANSI N-45.2 and that no adverse findings were identified. The inspectors did not review these audits during this inspection.
c.
Terminal Blocks RAH purchases Buchanan and Weidmueller terminal blocks.
Weidmueller provides a typical CoC with a disclaimer for reporting 10 CFR Part 21 deficiencies. They claim that since they are not aware of the final locations where their i
terminal blocks are installed, they cannot evaluate the deficiencies. However, they stated that they would co-operate in investigations related to failures of their terminal blocks.
It should be noted that Weidmue11er's practice of supplying a CoC attesting to the qualification of their terminal blocks and disclaiming responsibility for reporting under Part 21 is not acceptable to the NRC staff.
Similarly, Buchanan also sup)1ies CoCs with their terminal blocks.
RAH verifies that tie terminal blocks received con-form to the relevant drawings. These terminal blocks are installed inside a junction box mounted on the actuator where the cables from 50Vs and Namco quick disconnects are termi-nated.
RAH stated that they performed audits on Buchanan in the past to verify that their quality assurance program comply with the requirements of ANSI N-45.2.
The inspectors did not review the audits performed on Buchanan.
Results of a RAH audit on Weidmueller are documented in paragraph 9.C.3.
57
~
ORGANIZATION: RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 10 of 15 d.
Air control valves manufactured by C. A. Norgren (CAN)
RAH procures 3-way aluminum cast body air control selector valves with 3/4", 1", and 1 1/4" ports manufactured by CAN, located in Littleton, Colorado, as commercial grade items.
The main function of this valve is to direct air into the pneumatic cylinder (by the movement of a poppet) to open or close the MSIV. The valve is manufactured commercially by CAN to a proprietary drawing controlled by RAH. A note on the drawing requires CAN to provide full size prints to RAH if any revisions are made to this drawing. RAH dedicates these valves by performing the following:
(1).
Verify the correct model number of the valve.
(2).
Identify any visual damage which may have occurred during shipment.
(3). Thereceiptof"CertificationofTest"(C0T)fromCAN.
RAH in a letter dated June 20, 1989, to CAN requested them to revise the COT to read " Certificate of Conformance."
A typical COT stated the valve model number, identified a unique traceable serial number of the valve supplied, provided the hydrostatic test procedure used to test the valves to detect leaks in the valve, and that the dimensions were inspected to the pertinent detailed drawing retained at CAN. The RAH QA engineer stated that he witnesses the inspections and tests performed on selected valves by CAN during periodic audits performed by him, usually once in three years. Additionally, the accuracy of the overall dimensions of the valve are also verified during the assembly for the performance testing of the entire actuator. The inspectors reviewed the CAN test procedure identified as IR 183, Revision D, and deter-mined that it contained adequate acceptance / rejection criteria to detect porosity in the aluminum bocy and parts.
8.
Review of Documentation on Actuators Supplied to Grand Gulf Nuclear Power Plant (Grand Gulf)
The review of these documents was prompted by a Grand Gulf Significant Event Report (SER) dated August 18, 1989, informing the NRC that ASCO Model NP 8323A20E type SOVs, installed on RAH actuators could prevent the proper operation of the MSIVs. The SER stated that an investigation into the failure of the inboard MSIV 58 l
i 1
ORGANIZATION 8 RALPH A0 HILLER COMPANY PITTSBURGH, PENNSYLVANIA l
REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 11 of 15 associated with a plant scram on August 14, 1989, revealed that the 50V seal material had come apart and that a piece was lodged in the SOV's internals impeding the flow of air through the valve.
This prevented proper closure of the MSIV until such time when the i
seal material was dislodged. This review was conducted to determine if RAH supplied NP 8323A20E Type ASCO SOVs to Grand Gulf. The inspectors reviewed the following documents and determined that RAH did not supply NP 8323A20E type SOVs to Grand Gulf.
i Atwood and Morrill issued P0 AM 25010, dated April 28, 1975 to RAH for the supply of 40 pneumatic-hydraulic actuators with a stroke of 14" to operate 28" and 26" MSIVs and 16 actuators with a stroke of.12" to operate 24" MSIVs.
The P0 required the use of Viton seats throughout and did not )ermit the use of Teflon.
The actuators were to meet various tecinical specifications including GE Valve Actuators Specification No. 21A3530, Revision 0; GE MSIV Specification 21A9506, Revision 2; and GE Quality Require-ments Specification 21A8793, Revision 1.
RAH records indicate that the ASCO SOVs used on the Grand Gulf SA-A039 type actuators were from a lot purchased in 1975.
RAH P0 H0 382-5, dated January 29, 1975, issued to Continental Sales, Pittsburgh, re-quested the supply of 56 3-way direct acting HTX832320V type ASCO dual solenoid valves and 56 HTX8320A20V type single solenoid valves. The remaining S0Vs were installed on SA-A033 and SA-A034 type actuators supplied to the Koshaug (Taiwan) and Perry nuclear power plants respectively.
GE issued P0 205-86K662 dated August 4, 1986 to RAH to revise the Grand Gulf " Maintenance and Instruction Manual" to reflect f
the substitution of NP8323A20E type ASCO dual solenoid valves.
l RAH informed the inspectors that they revised the Instruction Manual but did not supply any re)lacement SOVs. ASCO Brochure V5972R1, dated 1981, indicates tlat SOVs with an E suffix on the model number have Ethylene Propylene Diene Monomer type elastomer seats for oil-free instrument air service. SOVs with a V suffix on the model number have Viton elastomer seats for non-oil-free instrument air service.
It was not within the scope of this 4
inspection to determine when the solenoids with ethylene propylene -
elastomers were installed on the RAH actuators at Grand Gulf.
The data package contained TSC CoCs, which certified that each actuator successfully passed the tests prescribed in TSC Engineering Specification El-1028. Tests results indicated the following:
a.
The hydraulic cylinder withstood 5000 psig test pressure for one minute without any visible leaks.
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REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 12 of 15 b.
The pneumatic cylinder withstood 50 psig test pressure for 5 minutes without any visible leakage, c.
The hydrostatic accumulator withstood 1500 psig test pressure without any visible damage.
d.
Basic actuator leakage at 156.5 psig test pressure was less than the permissible leakage of 0.3 standard cubic feet per hour (SCFH).
e.
Internal leakage of the complete actuator, including air control circuit manifold, when subjected to 120 psig was l
1ess than the permissible 0.5 SCFH.
1 f.
External leakage test of the complete actuator, including air control circuit manifold, when subjected to 120 psig indicated no leakage, g.
Extension time test.
h.
Retraction speed test.
i.
Extend speed control test, j.
Exercise circuit test.
k.
Breakaway pressure test.
1.
Cycle test.
9.
Review of Audits The inspectors reviewed the audits performed by nuclear power plant representatives on RAH, audits performed by RAH on their vendors, and one audit performed on RAH by an independent auditor, a.
Review of audits performed by nuclear power plant representatives l
(1). The inspectors reviewed a Quality Assurance Audit l
Report 0-89-213, dated June 20, 1989, performed by CECO on RAH. This audit concerned four MISV actuators supplied to LaSalle County Station per CECO P0 321957.
The audit identified 11 findings. The audit was ex-tended to TSC in Cincinnati where several more findings were documented. The audit resulted in RAH being 60
l ORGANIZATION: RALPH Ao HILLER COMPANY PITTSBURGH, PENNSYLVANIA j
REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 13 of 15 i
1 I
removed from CECOs Approved Bidders List. RAH addressed l
all the 11 findings.
i l
(2). The inspectors reviewed Iowa Electric Light and Power Company's audit of RAH Company, Audit Report No. V-88-48, l
dated October 21, 1988.
This audit was performed on September 21-23, 1988 and contained three findings and two observations. These items were subsequently resolved.
(3). The inspectors reviewed an audit performed by Cleveland Electric Illuminating Company identified as No.
PY "Q"504621. The audit was performed on October 20-22, 1987. There were no adverse findings.
b.
Review of audits performed by an Independent Auditor on RAH.
RAH authorized an external auditor to perform an audit on RAH on August 7, 1988. The inspectors reviewed this audit report dated August 28, 1988.
The external auditor was a certified lead auditor and a QA consultant.
The external auditor had reviewed the RAH company QA manual prior to the audit. The auditor utilized a checklist using ANSI N-45.2 and appropriate daughter standards. The audit concluded that tie RAH Company QA program was well integrated into the supply of valve actuators and associated spare parts and was generally acceptable, c.
Audits performed by RAH on their vendors (1). The inspectors reviewed audit No. VHI-136-14 performed on May 12-13,1987, on behalf of RAH, by Gilbert / Commonwealth Engineers / Consultants, on Automatic Switch Company (ASCO).
There were no audit findings requiring a response.
(2). The inspectors reviewed RAH vendor audit of C.A. Norgren Company who supplies pneumatic control valves to RAH.
This audit was identified as vendor audit No. 87-01, dated June 29-30, 1987. The audit noted two findings j
and three observations which were subsequently resolved l
to the satisfaction of RAH.
l (3).
The inspectors reviewed RAH audit No. 86-02 of Weidmueller Terminations dated February 20, 1986, and Audit No. 89-01, I
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PITTStVRGH, PENNSYLVANIA j
1 REPORT INSPECTIOS.
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PAGE 14 of 15 1
dated January 30-31, 1989. These audits were performed utilizing appropriate requirements of ANSI N-45.2.
The inspectors determined that the audits performed by RAH were complete and acceptable.
10.
Review of Ralph A. Hiller (RAH) QA Manual The inspectors reviewed the RAH QA Manual (QAM), Revision G dated December 6, 1988, which consists of seven sections to meet the requirements of ANSI 45.2-1977 with appropriate daughter standards; and 10 CFR 50, Appendix D as applicable to the manufacture.of actuators for service in nuclear power plants.
The inspectors determined the following; j
a.
The organization chart in the QAM does not represent the j
staff currently employed at RAH and does not describe the 1
authority and duties of persons currently performing
]
activities affecting the design approval, procurement, and 1
storage of components to be assembled on the valve actuators.
RAH representatives stated that the QAM is in the process i
of being revised. The inspectors informed RAH that failure to describe the authority and duties of persons performing safety-related activities is contrary to the requirements of 10 CFR 50, Appendix B, Criterion I.
(Nonconformance l
89-01-02) 3 l
b.
Paragraph 5.4.2 of the RAH QAM Section 5.0, Design Control, states, in part, "The Engineering /QA Manager shall ensure that any design change resulting from his and/or the customer's review of the design is documented via the EngineeringChangeRequestForm(seeexhibit5-2)...the j
change authorization must be provided by the Engineering /QA' Manager...."
1 "Upon completion of the change the design drawings shall be returned to the Engineering /QA Manager for review. After reviewing the drawings, the Engineering /QA Manager shall indicate this approval by signing the revision box on the orawing...." Exhibit 5-2 provides for two separate individuals with " Engineering Authority" and " Quality Assurance Authority" to sign and date the Engineering Change Request in two different places. With the current arrangement, one individual, with the title Engineering / Quality Assurance Engineering Manager, is permitted to sign in both places, first as an Engineering Manager and second as a j
j 62 1
ORGANIZATION: RALPH A. HILLER COMPANY PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99901170/89-01 RESULTS:
PAGE 15 of 15 Quality Assurance Manager. The inspectors informed RAH representatives that such an arrangement compromises the independence of reviews and is in nonconformance with 10 CFR 50, Appendix B, Criterion III, " Design Control."
(Nonconformance 89-01-03) c.
The inspectors reviewed several recent design drawings of safety-related valve actu6 tors and determined that the individuals involved in the preparation and verification of the drawings are TSC personnel located in Cincinnati, Ohio.
The signatures of these individuals were in the RAH title block in the lower right hand corner.
However, there was no " Approved" block in the title block for the RAH QA person to sign his neme as indicated in paragraph 5.A.1 and illus-trated in Exhibit 4-2 of the RAH QAM.
Instead, a "QA" stamp was affixed to the drawing and the QA Manager signed in the assigned space to denote his review and approval. The in-spectors informed RAH that the above practice deviated from the RAH QAM and as such is a nonconformance.
(Nonconformance 89-01-04) d.
During the tour of the facilities, the inspectors observed that the safety-related " stock" parts were stored in an area which was not segregated. The RAH QAM in paragraph 7.4.1 states in part, "...The receiver identifies all incoming
" stock" parts or equipment with proper part number and locates the " stock" part in a segregated area according to the part number and manufacturer." The inspectors observed that all the " stock" parts were identified with the proper part number tags. The inspectors informed RAH that the storage of safety-related material was not in accor& nce with the QAM.
(Nonconformance 89-01-05)
E.
EXIT INTERVIEW:
The inspectors met with individuals identified in Section F, discussed the scope and findings at the conclusion of the inspection.
F.
PERSONS CCNTACTED:
J. R. Hiller President M. Mekata QA Manager R. A. DeMarki Executive Vice President D. W. Borcik Project Manager
- J. Nanci Sales Manager
- Denotes i;dividual not present at exit interview on September 8, 1989 63
ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO-REPORT INSPECTION INSPECTION NO.: 99901171/89-01 DATE: September 12-15, 1989 ON-SITE HOURS:
54 CORRESPONDENCE ADDRESS: The Sheffer Corporation 6990 Cornell Road Cincinnati, Ohio 45242 ORGANIZATIONAL CONTACT:
E. Brown TELEPHONE NUMBER:
(513)793-2770 1
I NUCLEAR INDUSTRY ACTIVITY: Manufacturer of valve actuators i
i f
ASSIGNED INSPECTOR:
6Lt A
- i[88!
K. R. Naidu, Reactive Inspection Section No. 1, VIB Date OTHERINSPECTOR(S):
H. Wescott, VIB APPROVED BY:
- M Dk E. T. Baker, Chief, Reactive Inspection Section No. 1, VI te 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 and observe activities related to the manufacture, assembly, and test of pneumatic-hydraulic valve actuators intended for installation at the Hope Creek nuclear power plant.
PLANT SITE APPLICABILITY: All plants which utilize valve actuators supplied by R. A. Hiller Company, Pittsburgh, Pennsylvania.
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l ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 2 of 14 A.
VIOLATIONS:
I 1.
Contrary to Section 21.6 of 10 CFR Part 21, The Sheffer Corporation (TSC) did not post current copies of 10 CFR Part 21 regulations, or Section 206 of the Energy Reorganization Act of 1974.
(Violation 89-01-01) 2.
Contrary to Section 21.21 of 10 CFR Part 21, TSC had not developed appropriate procedures to evaluate and report deviations or defects detected in valve actuators manufactured and supplied to nuclear power plants.
(Violation 89-01-02)
I B.
NONCONFORMANCES:.
1 Contrary to Criterion II of 10 CFR 50, Appendix B, TSC did not establish an adequate quality assurance program as documented in their quality assurance manual (QAM), Revision 1, dated February 22, 1983, as evidenced by the following examples:
1.
Contrary to Criterion I of 10 CFR 50, Appendix B, the authority and duties of persons performing activities related to quality in J
the manufacture of safety-related components were not clearly es-tablished and delineated in writing.
Furthermore, a current organizational chart was not available.
(Nonconformance 89-01-03) 2.
Contrary to Criterion V.II of 10 CFR 50, Appendix B, measures were not established to verify that documentary evidence, such as l
Certified Material Test Reports received with purchased material, was complete, traceable, and acceptable. (Nonconformance 89.01-04) 1 3.
Contrary to Criterion VIII of 10 CFR 50, Appendix B, and paragraph 4.1 of Section B cf the TSC QAM, TSC personnel were indicating acceptable in-process inspection results by marking the wcrk. piece rather than completing the appropriate sheet or ticket.
(Nonconformance 89-01-05) 4.
Contrary to Criterion XV of 10 CFR 50, Appendix B, and paragra)h l
3.2 of Section C of the TSC QAM, a Quality Control. Inspection Report was not initiated when the threads on one of the eight holes in an end plate for a valve actuator were galled.
(Nonconformance 89-01-06) 5.
Contrary to Criterion IV of 10 CFR 50, Appendix B, the TSC QAM does not require that the quality assurance requirements received j
with the customer purchase order be imposed in turn on their 66
ORGANIZATION: ' THE SHEFFER CORPORATION CINCINNATI, OHIO REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 3 of 14 subvendors for the supply of materials. Consequently TSC issued purchase orders to distributors and subvendors without invoking all the qu611ty requirements imposed on TSC.
(Nonconformance 89-01-07) 6.
Contrary to Criterion XII of 10 CFR 50, Appendix D, and the recommendation of Ametek, Mansfield & Green, the manufacturer of the deadweight tester used to calibrate pressure gages, TSC did not calibrate the deadweight tester annually.
Instead, the initial calibration interval was extended for several years without technical justification.. (Nonconformance 89-01-08)
C.
UNRESOLVED ITEMS:
One unresolved item is identified in paragraph 3.f.2.
This item relates to the use of drawings and procedures by Automatic Valve Company (AVC). The drawings and procedures were not approved by General Electric Company (GE) as required by GE's P0. GE procured four pneumatic control assemblies from AVC for installation on actuators intended for the Hope Creek nuclear power plant. This unresolved item will be reviewed during a separate inspection at GE, San Jose, California.
D.
DETAILS:
1.
Background Information a.
General Information TSC, located in Cincinnati, Ohio, specializes in the manufacture of actuators, commercially known as cylinders.
A typical cylinder has an inlet and outlet port to admit air to operate a piston inside the cylinder.
The piston rod, which extends outside the cylinder, strokes the valve.
R. A. Hiller Company (RAH), Pittsburgh, Pennsylvania, is a distributor of TSC products.
RAH provided the application engineering to develop the cylinders into a sophisticated, electrically operated, pneumatic-hydraulic actuator capable of being operated remotely. To achieve this performance, RAH provides the design input and procures the additional components required for this purpose and supplies them to TSC. TSC is a vendor to RAH. RAH supplied various types of valve actuators to valve manufacturers, including American Warming, Anchor Darling, Atwood and Morrill, Kerotest, Pacific Valves, William Powell, Rockwell/ Edwards, and Velan.
In addition to these types of valve actuators, I
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ORGANIZATION: THE SHEFFER CORPORATION CINCINNAT1,>0H10 REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 4 of 14 TSC also manufactures actuators which are extensively used in the commercial operations.
For actuators intended for nuclear power plants, TSC provides RAH the calculations, materials list, and design drawings necessary to assemble actuators to perform functions specified in the technical specifications. The final assembly and acceptance tests are performed at TSC to verify that the valve actuators meet the technical specifications, b.
Raw material used by TSC The raw material procured by TSC for the manufacture of-actuators includes steel plates conforming to ASTM-A-36, chrome-plated AISI-C 1050 rods, cylinders conforming to, 4
AISI C1018-1035 or C1035-1045, and non-metallic elastomer seals and gaskets. The characteristics of the steel are stencilled along the length in many cases and the suppliers provide Certified Mill Test Reports (CMTRs). TSC does not i
transfer the heat code numbers to maintain the traceability of the material throughout the entire machining process. All the actuator components are painted with a coat of paint, specified in the individual P0, prior to shipment.
c.
Exclusive arrangement with RAH Due to an exclusive business-arrangement with RAH, TSC does i
not directly provide actuators, spares, or refurbishing activities to nuclear power plants, valve manufacturers, or i
other suppliers to nuclear power plants. All business is conducted through RAH, the prime contractor. All actuators returned from nuclear power plants are sent to TSC which disassembles, inspects, and documents the as-received condition of the actuators.
d.
Problems identified in the past To date no specific failures have been identified with the valve actuators manufactured by TSC. However, solenoid operated valves assembled on the actuators and hydraulic oil used in the actuators have been the subject of problems and are discussed in the following documents:
68 I
ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO i
REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 5 of 14 (1) GE Service Information Letter (SIL) No. 329 dated June 1980, recommended the use of SF 1147 type hydraulic fluid which is known to withstand heat and radiction I
without deletarious effects.
(2) NRCInformationNotice(IN)82-25informedusersofa potential problem with RAH actuators which could prevent fail safe closure of air operated isolation valves from going to their fail safe condition when the instrument air header (supplying air to the actuators) was slowly-depressurized.
(3)
IN 88-43 discussed the failures of ASCO type solenoid operatedvalves(SOVs)(assembledonRAHactuators) which resulted in MSIV operating problems at the Perry Nuclear Power Station.
(4) GE SIL No. 481, dated February 14, 1989, informed users 1
of improper functioning of ASCO type SOVs installed on
~l MSIV actuators manufactured by RAH.
(5) IN 89-66 alerted users to problems related to elastomers
{
used inside ASCO type S0Vs (assembled on RAH actuators) which may affect the operability of MSIVs or similarly designed components.
(6) TSC Service Manager stated that he observed deterioration of the chrome inside the pneumatic cylinders during the disassembly of pneumatic-hydraulic MSIV actuators re-turned from nuclear power plants. He stated that impu-rities in the station air supply were the principal-culprits.
Since the air inside the actuator stagnates for extended periods of time during the operation of the plant, impurities such as moisture condense on the chrome plating inside the pneumatic cylinder and cause pitting on the chrome. The elastomer seal rings on the pneumatic piston are damaged when they move over the pitted surfaces.
2.
Review of the TSC Quality Assurance Program The inspectors reviewed the current TSC quality assurance manual (QAM), Revision 1, dated February 22, 1983, and determined that the program states that it meets the requirements of MIL-1-45208A.
However, the quality assurance program described in the QAM did not meet the requirements of 10 CFR 50, Appendix B, Criterion II, in the following areas:
69 i
i
i ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 6 of 14 a.
A current organization chart including description of the authority and duties of persons and organizations performing _
activities affecting quality was not available during the inspection. The inspectors informed TSC personnel that the above was a nonconformance.
(Nonconformance 89-01-03) j b.
A review of the provisions related to assurance that purchased material. equipment and services conform to the procurement documents, indicateo that the acceptance / rejection criteria foracceptingCertifiedMaterialTestReports(CMTRs)and Certificates of Conformance (CoC) were not clearly described.
As a result, CMTRs supplied by the Central Steel and Wire 1
Company, the steel supplier, were accepted, even though some of them were not signed and dated.
Furthermore, TSC had not previously verified that the distributor had back-up documents -
for the CMTRs traceable to the steel mill where the steel l
was produced.
(See paragraph 3b of this report for additional details). The inspectors-informed the TSC staff that inadequate 4
review of documentary evidence which substantiates that the i
purchased material conforms to procurement requirements was a nonconformance.
(Nonconformance 89-01-04) c.
TSC, in Section B of the QA Manual,-describes the in-process inspections performed on machined parts. The inspectors observed QC inspectors performing inspections on machined parts and documenting their acceptance on the piece itself with a pen. This signature is invariably erased during the i
next machining process. -Paragraph 4.1 of Section B of the l
TSC QA Manual, requires the use of Material Control Trip Tickets and Green Move Tickets to identify acceptable mate-rial as it moves from one operation to another. These Material Control Trip Tickets and Green Move Tickets have provisions for-QC inspectors to document the_ results of their inspections during the various manufacturing steps. However, the NRC inspectors ebserved that neither Material Control Trip Tickets nor Green Move Tickets were being used during j
the manufacture of components for safety-related actuators l
intended for Hope Creek. The TSC staff stated that they would consider implementing a traveller to document inspec-l tion if required by RAH. The NRC inspectors informed TSC
~
staff that the their inspectors were not complying with paragraph 4.1 of the TSC QAM.
d.
During the manufacture of components for Hope Creek, the threads on one of the eight holes of an end plate was deter-mined to be galled. The end plate was for the pneumatic cylinder.
Normally, TSC would scrap.the end plate and obtain l
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ORGANfZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO REPORT INSPECTION N0.: 99901171/89-01 RESULTS:
PAGE 7 of 14 a new plate from the vendor.
However, due to the urgency, TSC obtained concurrence from GE to use an insert. During the tapping operations, the tap galled two or three threads 1
in one of the eight holes of an end plate of a valve actuator, serial No. 1329757. With the verbal consent of GE, TSC enlarged the hole and inserted a helicoil. GE documented this deviation in their Deviation Disposition Request (DDR) 31975.
The DDR was included in the quality records for the Hope Creek actuators. The inspectors informed TSC that fail-ure to implement the requirements stated in paragraph 3.2 of Section C of the TSC QAM, by not initiating a Quality l
Control Inspection Record to document the deviation, was a nonconformance.
(Nonconformance 89-01-06) e.
TSC does not convey the quality requirements imposed in the customer P0s to their distributors and subvendors. The cus-tomer P0s require TSC to have and maintain a quality assurance q
program meeting the requirements of ANSI 45.2-1977 or 10 CFR 50-Appendix B; compliance to the reporting requirements of-10 CFR Part 21; supply steel meeting industry standards; and supply elastomers and seal material capable of withstanding adverse environmental conditions without deleterious effects. The TSC P0s required certificates of compliance (CoC) from their dis-tributors and subvendors. TSC does not audit their subvendors periodically to establish that the subvendors implement accept-able quality assurance programs which enable them to manufac-ture components of consistent quality or that they possess documentation to support their Cots. One nonconformonce is identified in this area.
(Nonconformance 89-01-07) 3.
Review of Activities Related to Hope Creek Actuators a.
The inspectors reviewed the TSC internal order A0W 22936, which was generated to reflect the requirements of RAH P0 1068-9, dated August 30, 1989. The RAH P0 reflected the technical i
requirements of GE P0 205-89 D 844, dated July 3,1989, to RAH to design, manufacture, test, and supply four SA-A102 Model pneumatic-hydraulic actuators. These actuators were intended to replace the existing MSIV actuators.
In addition to the above, GE purchased " Pneumatic Control Assemblies" (PCA), manufactured and supplied by Automatic Valve Company.
(AVC), Novi, Michigan, intended for installation on the RAH actuators. The GE P0 required the actuators to meet the qualification requirements of IEEE-323-74 and 344-75.
i 71 i
1
ORGANIZATION: THE SHEFFER CORPORATION CIMCINNATI, OHIO REPORT-INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 8 of 14 AVC shipped the PCAs to TSC with a GE Product Quality Certificate (PQC).
PQC No. 81 555 stated that four PCAs iden-tified as MPL-21-F002/F023 were manufactured by AVC under-a i
controlled quality assurance program and are in conformance with GE P0 205-89D 861. This portion of-the certificate was i
signed by AVC's Quality Control Supervisor.
Below this state-ment, there was a GE Quality Assurance representative's endorsement to the effect that the supporting evidence for the supplier's certification was reviewed and that no product nonconformances were found.-
b.
To verify the _ documentation relative to the naterial purchased I
-by TSC, the inspectors reviewed the Certified Material Test-
-l Reports (CMTRs)-provided by Central Steel and Wire Company, (CSWC), Cincinnati, Ohio, the distributor of the steel mate-a rial used in the valve actuators. TSC required CSWC to provide material with CoCs. The review identified the-following:
i (1) A CMTR dated September 7, 1989, from Nelsen Steel Company, Franklin Park, Illinois, provided the chemical i
and physical test results for 0.5" diameter AISI C-1144
-l rod.
It identified the heat number as 611LO91 and stated-that the rod was manufactured by Bethlehein Steel Company.
i This CMTR was not dated and a rubber stamped signature was-affixed to the CMTR instead of an actual signature.
l l
(2) A CMTR from Fort Howard Steel Company, Green Bay, Wisconsin, provided the chemical test results for 1.25" diameter CL144 round steel identified with heat number 24486.
(3) A CMTR from Fort Howard Steel Company, Green Bay, Wisconsin, provided the chemical test results for three bundles of 1.5"x2.5" C 11L17 type flat steel, heat numbers T 6909 and T 6742.
(4) A CMTR from Industrial Hard Chrome, Limited,- Elk Grove Vill 3ge, Illinois, documented the test results for'2.5" diameter industrial hard chrome plated bars, heat nunber 8878581. The CMTR stated that the material was hardened 0.05 inches to 0.09 inches deep, 50 to 60 Rockwell C.
For items 2, 3 and 4, CSWC personnel were unable to trace the material supplied to the steel mill where-the saterial was produced.
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ORCANIZATION8 THE SHEFFER CORPORATION CINCINNATI, OHIO i
REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 9 of 14 c.
The inspectors' reviewed a typical TSC P0 to procure elastomer material. TSC issues the P0 to the local distributor and requires the material to be supplieo directly to TSC with Cots. The inspectors determined that TSC did not impose the quality requirements required by their customer purchase order on their subvendors f or the supply of elastomers and gaskets.
For instance, TSC issued P0 150675, dated September 5, 1989, to Southern Ohio Steel Company (SOSC) to supply seal material.
The TSC P0 did not contain any of the quality assurance re-quirements imposed by their customer's P0. The TSC P0 required SOSC to supply various seal material such as:
(1) Sixteen pieces of Polypak tube B, 2.5" inner diameter (ID) x 3" outside diameter (00) x 3/8" depth, Parker compound V 42 6695 flurocarbon Viton 0 rings with cure date and material certificates. This material is used for rod seals.
(2) Four pieces of Parbak 3.25" ID x 3.5" OD x 1/16" thick, size 236, Viton back-up rings for the piston rod back-up ring.
(3) Eight pieces of 3.125" 1D x 3.5" OD x 3/16 cross section Quad 0-rings manufactured from Minnesota Rubber Compound 514 AD Flurocarbon Viton. The 0-ring provides a seal in the accumulator. The top of the accumulator piston is pressurized with nitrogen to allow for expansion of the hydraulic fluid due to temperature changes.
The inspectors informed TSC representatives that the quality assurance requirements contained in the customer P0 were not, in turn, imposed on their subvendors to provide assurance that the material supplied meets the applicable industry standards and is readily traceable to production lots to establish the cure dates and radiation resistance requirements (Nonconformance 89-01-07) t 4.
Observation of the Assembly of Hope Creek Actuators a.
Assembly of the actuators The in',pectors observed the partial assembly of a Hope Creek a ctu a'.or.
This included assembly of the hydraulic tube, con-necting the piston to the piston rod, attaching the piston seals to the piston, and attaching the pneumatic bottom cap.
After the hydraulic cylinder was assembled, the unit was tested for leaks as described in paragraph 4b. The partial assembly was degreased and painted. After curing the paint 73
ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI,-OHIO i
REPORT INSPECTION i
NO.: 99901171/89-01 RESULTS:
PAGE 10 of 14 overnight, the assembly was completed. The inspectors were not able to witness the complete assembly of the actuator, b.
Observation of tests on Hope Creek actuators
]
The inspectors observed'the tests performed on the pneumatic and hydraulic cylinders to verify that they do not leak.
Each side of the piston in the pneumatic-cylinder was subjected to'120 psig air pressure and a commercially available bubble solution was applied to visually detect leaks. No leaks were detected.
Each side of the piston in
.l the hydraulic cylinder was subjected to 5000' psig-hydraulic pressure and.similarly tested for leaks. No leaks were observed. A test procedure approved by RAH was used during the test. Representatives from GE San Jose and Hope Creek witnessed the pressure tests.
The minimum air pressure required to extend and retract the piston was measured to be 0.7 psig. The inspectors observed that the pressure gauges used during the test had been calibrated.
5.
Review of Documents Supplied by Automatic Valve Company (AVC)-
a.
Background-AVC supplied to TSC four PCAs in response to a GE P0 to AVC.
The PCAs were to be assenbled on the RAH actuators. A GE-QC representative, who was present at TSC on September 14 o
and 15, 1989, informed the NRC inspectors that he witnessed the acceptance tests on the PCAs at AVC in Michigan, b.
Review of drawings supplied by AVC with the PCAs The inspector reviewed the following AVC drawings:
(1) B 6930-075 - Solenoid Manifold Assembly B 6930-070 - Solenoid Manifold Assembly B 4988-060 - Junction Box Assembly C 5140-375 - Manifold Assembly (3 sheets)
- 5) C 6752 - Special 2-way Poppet valve with VitonSeals(2 sheets)
In the columns of Drawings 1, 2, and 3, reserved for the signatures of the individuals who prepared and approved the respective drawing, the initials of the individual 74
ORGANIZATION: THE SHEFFER CORPORATION CINCINNAT1, OH10 REPORT INSPECTION N0.: 99901171/89-01 RESULTS:
PAGE 11 of 14 j
who drafted the drawing were printed and not signed; the column reserved for the person who checked the drawing-was neither signed nor dated.
Drawing C 5140-375,_ Revision A, was a modification to Drawing C 5140-020, Revision C, which was originally sup-plied to Hope Creek. The modification was necessary to accommodate the RAH actuator. A new machined-4-way air control valve replaced the originally supplied 4-way i
cast valve. AVC made this modification because leaks were detected on the cast valve. The inspectors reviewed Drawings C 5140-200 for the 4-way valve with Viton seals and C 5140-8H for the 3-way valve with Viton seals. The qualified life of the Viton seals is 5 years.
A Hope Creek EQ engineer, who was present at TSC during the assembly and test of the actuators, stated that a program is in place at Hope Creek to replace the seals during every maintenance outage to maintain the environmentally qualified life of the actuator.
The above mentioned drawings did not have any evidence, such as a GE approval stamp, to denote that these draw-i ings were reviewed and approved.
Such a review and ap-proval is required by GE's Quality Assurance Require-ment 1 for Materials Services Quality, Revision 7, dated June 28, 1989. Paragraph 2.2.1 of the.above docu-ment states "unless authorized by the Buyer and specifi-cally controlled by Seller's QA program, fabrication, and/or work affected by a document subject to Buyer's approval shall not be started until the applicable pro-cedures, drawings, or design data have been approved or approved with comments by the Buyer."
Paragraph 2.2.2 states "all procedures, drawings, and/or other submittals required for approval and/or information shall be identified in documentation provided by the Buyer."
3 The use of unapproved drawings and procedures by AVC is v
considered an unresolved item and will be reviewed at GE.
c.
List of documents supplied by AVC The list of quality control documents applicable to PCAs 4
supplied by AVC (without MSIV opening speed control) included the following:
75
ORGANIZATION 8 THE SHEFFER CORPORATION.
CINCINNATI, OHIO.
REPORT INSPECTION L
NO.: 99901171/89-01 RESULTS:
PAGE 12 of 14 l
(1) Checklist and certification for MSIV PCAs without opening speed controls.
l (2) Generic Terminology listing the terms utilized by l
AVC to aid in determining the proper description of products and services.
(3) Cylinder leak test D-CN 4148A, dated August 16, 1989, to assure the integrity of the seals in the MSIV cylinder prior to the installation of the MSIV control panel.
(4) Checklist and certification for MSIV-pneumatic control panels.
(5) Installation instructions for MSIV pneumatic manifolds without opening speed control.
6.
Review of Material Returned from Brunswick Nuclear Power Plant The TSC internal work order A0W-15480, dated June.7,1989, acknowl-edged RAH P0 HA-1048-9, dated May 31, 1989, to rebuild two SA-A075 tandem actuators.
These actuators were previously supplied to ac-i tuate MSIVs at Brunswick. TSC receiving record, dated May 23, 1989, acknowledges the receipt of two SA-A075 tube actuators identifiedL i
with serial numbers 1113333 and 1113334.
Discussions with the TSC service manager indicated that-the actuators were received without the air package.
It is the normal practice for TSC to dishssemble actuators and degrease the components prior to visual inspections.
The degreased parts are inspected for the following attributes:
a.
Damage to the chrome plating and the threads on. piston rods, b.
Condition of the inside diameter of the ' cylinder and l
outside ciameters of the piston and rod. These dimensions are critical because they are moving parts and any damage, such as rust pits caused by moisture in the air supply system or condensation will cause the seals to leak.
l The TSC Service Manager prepares a " Cylinder Repair Work Sheet"~
l listing all the components needed to rebuild the cylinder. The l
inspectors reviewed sheet 3 of TSC Drawing SA-A075, titled, "20"/5" l
Core 3" Rod Tandem Cylinder with Accumulator," and sheet 4 of Draw-l ing SA-A075 titled, " Air Control Circuit Assembly," and observed I
that all the components necessary to refurbish the units were high-lighted. The TSC Service Manager informed the inspectors that a 1
76
ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 13 of 14 recurring problem observed in the pneumatic-hydraulic MSIV actuators is pitting on the chrome inside the hydraulic cylinder due to mois-i ture in the air supply system. The inspectors observed that mate-rial returned from nuclear power plants was neither adequately identified with tags nor stored in-a segregated area. The inspec-tors informed TSC personnel that it would be considered good house-keeping practices to identify and segregate material returned from nuclear power plants.
7.
Review of Calibration Records The inspectors selectively reviewed pressure gauge calibration records to establish the current calibration date and verify that the standard used for calibration was traceable to the National Bureau of Standards (NDS). The calibrotion record for a Marshalltown pressure gauge, No. 120988, indicated that the gauge was calibrated on July 28, 1989, by Temperature Pressure Flow Products in compli-ance with MIL Standard 45662 and with a standard traceable to NBS.
The inspectors reviewed the certificate of inspection for Starret/
Webber rectangular steel calibration blocks, Serial No. 42567, which was certified by Quality Techniques, Inc. on June 17, 1985, and traceable to NBS.
The inspectors also reviewed calibration records for type AA test pressure gauge, FTC-120, manufactured by Halicoid, and two United States (U.S.) pressure gauges identified as FTC-131 and FTC-133. These gauges were calibrated with a dead weight tester which was calibrated by Ametek, Mansfield & Green Division, Bolon, Ohio. The certificate of calibration, traceable to NBS, certified that the dead weight tester was calibrated on November 25, 1981, with a recomended recertification date of November 25, 1982.
A TSC office memorandum, dated August 4, 1987, stated that the dead weight tester was received in November 1981 and that the tester remained in storage until put into service in July 1985. The memorandum stated that the dead weight tester was due for calibra-tion in November 1995 in accordance with Engineering Instruction EI-1175 and did not provide any justification for not following the manufacturer's recommendation for annual calibration.
k Ametek, Mansfield & Green recommended an annual recalibration of the dead weight tester, which has not been performed to date.
TSC extended the recalibration until November 1995 without a technical justification. The calibration of the pressure gauges using the dead weight tester is indeterminate. This item is considered to be a Nonconformance (89-01-08).
77
ORGANIZATION: THE SHEFFER CORPORATION CINCINNATI, OHIO REPORT INSPECTION NO.: 99901171/89-01 RESULTS:
PAGE 14 of 14 4
i F.
EXIT INTERVIEW:
The inspectors net with persons identified in Section G and discussed the 3
scope and findings of the inspection.
j G.
PERSONS CONTACTED:
The Sheffer Corporation R. Warner, President
- E. Brown, Quality Control Manager
- D. Selke, Engineering Manager
- D. O'Neill, Project Engineer i
C. Skorupa, Calibration Specialist R. Stesch, Service Manager R. A. Hiller Company, Pittsburgh, Pennsylvania
- M. Meketa, Quality Assurance Manager General Electric Nuclear Energy Company, San Jose, California
- J. F. Kikel, Senior Quality Control Representative Hope Creek, Nuclear-Power Plant, New Jersey l
- M. Williams, Equipment Qualification Engineer 1
- Denotes the individuals who attended the exit meeting on September 15, 1989.
i 78
.Selecteo Bulletins and Information Notices Concerning Adequacy of Vendor Audits anc Quality of Vendor Products ISSUED 1.
Information Notice No. 89-45, METALCLAD, LOW-V0TAGE POWER Supplement 2:
CIRCUIT BREAKERS REFURBISHED WITH SUBSTANDARD PARTS 2.
Information Notice No. 89-56, QUESTIONABLE CERTIFICATION OF Supplement 1:
MATERIAL SUPPLIED T0 THE DEFENSE DEPARTMENT BY NUCLEAR SUPPLIERS 3.
Information Notice No. 89-59, SUPPLIERS OF POTENTIALLY-Supplement 1:
MISREPRESENTED FASTENERS l
4.
POSSIBLE INDICATIONS OF MISREPRESENTED VENDOR PRODUCTS 5.
FALSIFICATION OF-WELDER QUALIFICATIONS FOR CONTRACTOR EMPLOYEES i
i 4
79 l
_U
VENDOR INSPECTIONS RELATED TO REACTOR PLANTS i F I i P l-S l S 1 T l l
1 I I N l A I A 1 0 1 U 1 1
I T ! D ! L L
.U l' 9 1 l
1 PLANTS
! Z I I O I E i T I K1 l
l i P A l 1 M 1 H : E I 1
1 A ! N : V 1 Y I 1
1 T i
! E 1
- T I I
1 l R P l R 1 l-E 1 P j
i i I ! O I D 1 l X l O 1 l
VENDORS l C : I I E 1 A !I :
l 1
t l K l N i 1 S 1 N i l
i i
i T 1 1
I l T I l
l l
1 1
l l 2 i 1
l j._____________.___...__._____;__.;___;_..._;___;___;___;___;
i l Combustion Engineering l
l X ! X 1 Xi X i X !
l l
1 l
l l
1 j -._;___; _ ;
- Ralph A.
Hiller Co.
!All plants with R.A.
Hillerl 1
valve actuators i
- .__ ; _._j __ ;
a l Rotork Controls, Inc.
1 X l
1 i
l i
1 i
I l
l l
1 l
1 j._..._ _._... _..
j l Target Rock Corp.
1 All plants with l
l Target Rock valves i
1 The Sheffer Co.
lAll plants with R.A.
Hillerl l
valve actuators l
4 1 Westinghouse Electric All Westinghouse plants 1 l
l l
I 1
I Whittaker Corp.
I Numerous I
i i
i I
81
NRC tomu 335 U.S. NUCLE AR CtEGUL ATORY COMMISSION
- 1. REPORT NUMBER kacb1102.
kmters IO vY' A
nou m BIBLIOGRAPHIC DATA SHEET isaa,mtruer,om on u e revers *>
s 14URL.G-0040 2, MLE AND SUBMLE Vol. 13, fio. 4 Licensee Contractor and Vendor Inspection Status Report 3
DATE REPORT PUBLISHED Quarterly Report l
October 1989 - December 1989 January 1990 4, FIN OR GRANT NUMBE R S. AUTHORtS)
- 6. TYPE OF REPORT Quarterly
- 1. PE 8lOD COV E R E D tincousow Ostess.
October - December 1989
- 8. PERF ORMI,N,,,G,.OR.G.A,NIZ AT ION - N AM E AND ADDR ESS Ist NRC. provede Oeisiaoa. Off ce or Reeson (1.3. Nvcher Reputercer Comm8 mon. and md*6r's 808'f88. 8' contrKror. #
Division of Reactor Inspection and Safeguards Office of fluclear Reactor' Regulation U.S. fluclear Regulatory Commission Washington, DC 20555
- 9. SP,ONSORING OR, G ANIZ ATlON - N AME AND ADDR ESS ist NRC. tvor %me ss eaan~;ir onsrutor. provme NRC Owsuon. Orfwe er Rosen. V5. Neckor A*suretory Commssuon, c
on M& sling gddres%
Same as 8, above L
1
- 10. SUPPLEMENT ARY NOTES
- 11. ABST R ACT (200 wore or seur This periodical covers the results of inspections performed by the llRC's Vendor
-Inspection Branch that have been distributed to the inspected organizations during the period from October 1989 through December 1989.
.i I
i
- 12. K E Y WORDS/DESCR:PT ORS ttat norm or parews tast entl emse r*weeraeri m tocereas tae neoart.s IJ. AV A8ba8'481 Y 61 Al t Mt NI Vendor inspection Unlimited
,.,, c,,,,, c,,,,, n c.,,o, ith,s Petel Unclassified ttaas Neoortl Unclassified
- 16. NUMBER OF PAGES I
- 16. PRICE NRC FORM 335 (? 89i i
UNITED STATES NUCLEAR REZ,ULAT@RY COMMISSION "SYaYNit's'N'S'"
WASHINGTON, D.C. 20666
"[*
OFFICIAL BUSINESS PENALTY FOR PRIVATE USE,4300 120555139531 1 1ANINV US NRC-0ADfi OIV'FOIA & DUBLICATIONS SVCS TPS PDR-NUREG P-223 WASHINGTON OC 20555' i
l i