ML20055F732
| ML20055F732 | |
| Person / Time | |
|---|---|
| Issue date: | 06/21/1990 |
| From: | Matthews S, Vadenburgh C Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20055F726 | List: |
| References | |
| REF-QA-99900031 NUDOCS 9007190106 | |
| Download: ML20055F732 (31) | |
Text
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bRGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED
-PORTLAND. ORECON REPORT INSPECTION INSPECTION NO : 99900031/90-01 DATE:
February 5-8, 1990 ON-SITE HOURS:
170 CORRESPONDENCE ADDRESS:
Sulzer Bingham Puinps Incorporated Portland Pumps Division 2800 Northwest Front Avenue Post Office Box 10247 Portland, Oregon 97210 ORGANIZATIONAL CONTACT:
Wayne D. Thomas, Manager Corporate Quality Assurance TELEPHONE NUM3ER:
(503)226-5342 m
NUCLEAR INDUSTRY ACTIVITY: Centrifugal pumps used in safety-related nuclear power plant applications. The pumps are designed for use in several nuclear' l
plant systems such as injection coolant, feedwater, auxiliary feedwater, core spray,' nuclear service water, condenser circulation, and condensate booster pumps.
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n ASSIGNED INSPECTOR:
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Steven M. Matthews, ReactLve Inspection Section a
No. 1 OTHERINSPECTOR(S):
R. L. Cilimberg, NRC J. J. Petrosino, NRC M. R. Snodderly, NRC B.E.Scanoa,pC onsultantL kuko APPROVED BY:
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. /4=d =8%
Chris A. VanDenburgh~, Chief, Rea(,tive Inspection Section Date l
l Nn_ 1 Vandnr inenactinn Rranch (VfR)
INSPECTION BASES AND SCOP,E:
4 A.
BASES: ASME Code Section III, NCA-4000; 10 CFR Part 50, Appendix B; L
10 CFR Part 21; and the Sulzer Bingham Pumps, Inc. (SBPI) Quality l
Assurance Manual.
B.
SCOPE: To assess the design process, controls, and verification activities and performance based reviews of the quality program implementation in selected areas such as, control of procurement and special processes and relationship to recurring equipment operational problems identified in several nuclear power plants.
PLANT SITE APPLICABILITY: All plants with ToPI, formerly Bingham-Willamette I
Company (BWC) centrifugal pumps.
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B 99900031
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'0RGANIZATION:
SULZER BMGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO : 99900031/90-01 RESULTS:
PAGE 2 of 31 Av VIOLATIONS:
L 1.
Contrary to~ Section 21.21, " Notification of failure to comply or existence of a defect," of 10 CFR Part 21, several deviations were identified where SBPI did not perform the required evaluation of E
potential'y reportable conditions or did not notify the licensees or purchasers so they could cause an evaluation to be performed pursuant to the provisions of 10 CFR Part 21.
The inspection concluded that SBPI either failed to perform an adequate evaluation or failed to notify the purchaser so that they could cause an evaluation to be L
performed as required by 10 CFR Part 21.
a.
SBPI failed to adequately evaluate the impeller material failure L
at Diablo Canyon Nuclear Power Plant, Unit 2.
The pump impe11ers I
had abnormally deteriorated due to inadequate heat treatment which resulted in accelerated intergranular corrosion (IGC).
SBPI notified only Crystal River Unit 3 of the potential defect; L
eventhough, the same impeller material is in service in various nuclear power plant environments subject to IGC.
b.
SBPI failed to adequately evaluate a deviation or provide notifi-cation to all of the applicable nuclear power plants with a potential deviation regarding shaft sleeve material that was reported by SBPI pursuant to 10 CFR Part 21, on May 4,1988. The E
report related to environmentally induced intergranular stress corrosion cracking / hydrogen embrittlement (IGSCC/HE) of center and throttle shaft sleeves.
SBPI reported the deviation to Beaver Valley Power Station, Millstone Nuclear Power Station, PaloVerdeNuclearGeneratingStation(PVNGS)andSouthTexas ProjectElectricGeneratingStation(STPEGS).
However, SBPI failed to notify Catawba Nuclear Station (CNS), which subse-quently experienced a'similar failure of a shaft sleeve in January 1989, c.
SBPI failed to adequately evaluate a devation or )rovide notifi-cation to the applicable nuclear power plants wit 1 pumps subject to wear ring failures. SBPI informed Peach Bottom Atomic Power Station, Browns Ferry Nuclear Plant, Cooper Nuclear Station, Pilgrim Nuclear Power Station, and Vermont Yankee Nuclear Power Station regarding failed stainless impeller wear' rings. The initial failures occurred at Peach Bottom Atomic Power Station and Browns Ferry Nuclear Plant in Residual Heat Removal (RHR) system pumps.
The wear ring failures are the subject of NRC Information Notice No. 86-36.
Based upon metallurgical examinations performed on the o
1.
wear ring fracture surfaces, the licensee determined the presence of IGSCC. SBPI limited their evaluation to pumps used in only the
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. ORGANIZATION:: SULZER BINGHAM PUMPS.. INCORPORATED i
'n U.
PORTLAND,' OREGON i
REPORT INSPECTION-N0!: 99900031/90-01 RESULTS:
PAGE 3 of 31 RHR systems and did not consider the adequacy of the source supplying the wear ring material or uses of the failed material in other environments where an IGSCC mechanism exists.
l d.
SBPI did not adequaltely) evaluate deviations, routinely)rocessed as j-Technical' Bulletins (tbs, to determine whether or not tiey con-stituted a reportable condition pursuant to the provisions of 10 CFR Part 21.
Numerous tbs were reviewed wherein SBPI disposi-tions issues that were deviations, as defined in 10 CFR Part 21, without evaluating the deviations for reportability to licensees.
SBPI did not adequately evaluate these deviations or provide notification to the applicable licensees.
i
.e.
SBPI did not adequately evaluate incoming problem notifications from licensees to ensure that the deviations or defects were prop-erly evaluated for reportability as required by 10 CFR Part 21.
Problem notifications from licensees entered SBPI through one of two points of contact; the Field Services Engineer or the Pump Parts Order Manager.
Neither individual had received training in l
the program requirements for the evaluation and reportability of I'
deviations or defects under 10 CFR Part 21.
SBPI had not i
evaluated these potential deviations. (90-01-01)-
2.
Contrary to Section 21.31, " Procurement Documents " of 10 CFR Part 21, a review of documentation packages for overhaul of spare rotating ele-L ments for STPEGS and weld repairs to replacement impellers for Diablo l
Canyon' Nuclear Power Plant revealed that SBPI issued safety-related I
purchase orders (PO) to material manufacturers and suppliers and q
failed to invoke the requirements of 10 CFR Part 21.'(90-01-02) 3..-
Contrary to Section'21.21, " Notification of failure to comply or L
existence of a defect," of 10 CFR Part 21, SBPI Procedure A14.0,
" Procedure For Reporting Of Safety Related Noncompliance And Defects To Meet 10 CFR 21," Revision 6, dated January 26, 1990, did not contain adequate provisions to ensure that licensees were informed of deviations-that product deviations or defects were evaluated to determine if a substantial safety hazard existed and that adequate documentation of the reportability determination was produced and g
maintained in the evaluation package. (90-01-03) l i
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ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT-INSPECTION NO.:
99900031/90-01 RESULTS:
PAGE 4 of-31 B.
NONCONFORMANCES:
1.
Contrary to Criterion I, " Organization," of Appendix B to 10 CFR Part t
50, and Section 1.0, " Organization," of the SBPI Quality Assurance Manual (QAM) ASME Section Ill, Division 1, third issue, Revision No. 2, dated December 9,1988, and Section 3.1, " Organization," of Procedure No. H40.45, "Q. A. Program Supplement for Critical Safety-Related Non-ASME Code Part/ Components for Nuclear Facilities," (QAPS) Revision No. 4, dated September 20, 1989, SBPI failed to clearly establish and delineate in writing the authority and duties of persons and organiza-tions affecting the safety-related functions of the Field Engineering Organization. (90-01-04) 2.
Contrary to Criterion II, " Quality Assurance Program," of Appendix B to 10 CFR Part 50, and Section 1.0, " Organization," of the SBPI QAM and Section 3.1, " Organization," of Procedure No. H40.45 SBPI failed to ade-quately indoctrinate and train'8 of 15 personnel who are performing activities affecting quality in the QAM and QAPS requirements. This is a l-repeat of Nonconformances B.6, and B.10, identified by the NRC during the last inspection and documented in Inspection Report 99900031/84-01,and l
also addressed in Section D.11 of this inspection report. (90-01-20 L
3.
Contrary to Criterion Ill, " Design Control," of Appendix B to 10 CFR Part 50, and Section 3.0, " Design Control," of the SBPI QAM and Section 3.3, " Design Control," of Procedure No. H40.45:
a.
SBPI failed to document design changes for 7 of 11 safety-related '
impellers for STPEGS on a Design Change Request (DCR) or an Engineering Change Notice (ECN), as required by the QAM and QAPS, and could not 3roduce an engineering evaluation to support the i
design bases c1ange increasing the flow capacity and material l
changes.(90-01-05) r b.
SBPI failed to document design changes for eight safety-related feedwater pump rotors for STPEGS on DCRs or the Contract Specific MaterialList(CSML).
SBPI also could not produce an engineering evaluation to support the design basis change in material for shaft sleeves or provide the stress calculations for the revised keyway design. (90-01-06) c.
SBPI failed to control revisions to the keyway designs for shaft sleeve Drawing B-33912E-X and throttle shaft sleeve Drawing B-33906E-X for safety-related Repair Order (RO) NP-1229, as verified by the inspectors using the controlled Drawing B-33912,
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, ORGANIZATION 8 SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 5 of 31 Revision.F, dated December 28, 1988. -Additionally, R0 NP-1229, incorporated the recommended design changes in Technical Bulletin (TB) No. 79, but the design changes were not reflected on a Design Control Sheet (DCS) by'a DCR or ECN as required. An engineering evaluation to support these design bases changes was not provided for review by the inspectors..(90-01-07) d.
The Manufacturing Engineering Department failed M control the design program tapes for numerically controlled (dC) manufacturing machines. NRC inspectors observed a machinist editing an NC design program tape for one safety-related part in order to machine a diffetsnt safety-related part that did not have an NC program tape without the. authorization of the NC Programming Department.
(90-01-08) e.
The Design Engineering Department could not produce a Design Report (DR)orotherevidencethatthedesignbaseshadbeenverifiedafter changing from a separate wear ring design to an integral wear ring-designedimpelleronpumpsusedinResidualHeatRemoval(RHR) systems.(90-01-09) f..
The Design Engineering Department failed to document design changes on the bill of material via en ECN for model CVIC type safety-related pump impellers supplied to Peach Bottom Atomic PowerStation.(90-01-10) 9 SBPI failed to perform an adequate review for suitability of the right angle gear box on a model VLTM type pump supplied to the Surry Power Station and used as a basic component in a safety-related application. (90-01-11) h.
SBPI failed to adequately document and implement programmatic controls of the required design engineering interfaces within design activities, and between design groups and manufacturing.
Several of the nonconformances identified in paragraphs B.3.a.,
through h., above are symptomatic of inadequate interface descriptions and control. (90-01-12) 1.
The Design Engineering Department failed to specify. the acceptance-criteria for inspections and test for the Colmonoy No. 6, hardfacing process for shaft sleeves per Drawing B-20541, Revision B, used on model CVIC type pumps in RHR systems. (90-01-13)
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. ORGANIZATION:' SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON l
REPORT INSPECTION NO.:
99900031/90-01 RESULTS:
PAGE 6 of 31 4.
Contiary to Criterion IV, " Procurement Document. Control " of Appendix B to 11 CFR Part 50, and Section 4.0, " Procurement Document Control,"
of the BPI QAM:
a.
SBPI ordered heat treating services from Beaver Heat' Treating i
Corporation (BHT) without specifying on the P0s the heat treating requirements or procedures that otherwise control the quality of services requested. (90-01-14) b.
SBPl. failed to determine that BHT did not have quality procedures forevaluatingdeviationsandinformingSBPl.(90-01-17) 5.
Contrary to Criterion V, " Instructions, Procedures, and Drawings," of' Appendix B to 10 CFR Part 50, and Section 5.0, " Instructions, Procedures, and Drawings," of the SBPI QAM, and Section 3.5,
" Instructions, Procedures, and-Drawings," of Procedure No. H40.45:
a.
.SBPI did not provide instructions or procedures to assure satisfac-tory accomplishment of activities affecting quality of safety-related items in the following arees:
no guidance existed to define theinitiationandutilizationofTechnicalBulletins(TB);the Engineering Design Manual does not list the E-29, " Supplemental Statements List," used to apply engineering requirements; and TB E31.39 obviates the requirements of MSS-SP-55, for visual inspec-tionofcastings.(90-01-21) b.
SBPI had not' required the use of documented procedures by BHT to
'a perform heat treating of safety-related items. This is a repeat of Nonconformances B.2, B.3, B.4, and B.5, identified by NRC during the previous inspection documented in Inspection Report 99900031/84-01,'and also addressed in Section D. of this report.
(90-01-16) 6.
Contrary to Criterion IX, " Control of Special Processes," of Appendix B to 10 CFR Part 50, and Section 9.0, " Control of Manufacturing," of the SBPI QAM, and Section 3.9, " Control of Special Processes," of L
Procedure No. H40.45:
l-1 l'
a.
SBPI failed to determine that BHT did not have measures estab-i:
lished to assure that the quench rate for solution annealed, austenitic stainless steel, safety-related items were accomplished L
in accordance with the materiai specification or other special requirements necessary to meet the intended application.
(90-01-15)
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ORGANIZATION: -SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT.
INSPECTION
-NO.: 99900031/90-01 RESULTS:
PAGE 7 of 31-b.
The Project Engineering Department failed to specify on DR
- No. 96934, the specific welding procedure for welded repairs on safety-related impe11ers for Diablo Canyon Nuclear Power Plant.
(90-01-18) c.
SBPI failed to document the quench rate that qualifed the heat treatment portion of the welding qualification for procedure AS-1,-
used to repair safety-related impellers for Diablo Canyon Nuclear Power Plant. (90-01-19) h 7.
Contrary to Criterion Xill, " Handling, Storage and Shipping," of l
Appendix.B to 10 CFR Part 50, and Section 13.0," Handling, Storage, L
Shipping, and Preservation," of the SBPI QAM, and Section 3.13. " Handling, Storage and Shipping," of Procedure No. H40.45 stainless steel, safety-related pump shafts were stored on angle iron racks without protective-pads, thread protection, or blocking between shafts. (90-01-22)
L 8.-
Contrary to Criterion XV, " Nonconforming Materials, Parts, or Components,"
of Appendix B to 10 CFR Part 50, SBPI failed to describe in the SBPI QAM or QAPS the function and responsibility of the Material Review Board, i
The Material Review Board approved the disposition of safety-related shaft sleeves.-(90-01-23)
C.
UNRESOLVED ITEMS:
1.
An attempt was made to review the S3P1 log of procurements for components purchased from outside the organization.
However, discussions with the Purchasing Department personnel revealed that SBPI did not have a control-led. listing of all cutside purchases.
Instead, the Purchasing Depart-L ment maintained a list of all P0 numbers and the purchasing agent or other persons author,ized to procure items.
An agent would sign out for a 4
series of P0s(typically about 10 P0s). The NRC inspectors reviewed the H
agents records of P0s issued in 1989, and observed that the name of tne l
vendor was not recorded in all cases.
It was not clear from the records L
reviewed how agents verified that a vendor was on the approved vendors list prior to issuing a P0. The NRC inspectors concluded that this area will be evaluated in more detail on a future inspection. This issue is there-foreanunresolveditem.(90-01-24)
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_ ORGANIZATION:
SULZER BINGHAM PUMPS. INCORPORATED PORTLAND, OREGON 4
REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 8 of 31 2.
The NRC inspectors noted several concerns relating to Criterion VII,
" Control of Purchased Material, Equipment and Services," and Criterion XVill, " Audits," based on observed methodologies of the Purchasing Department and the lack of personnel indoctrination and training.
These areas will be evaluated in more detail on a future inspection. This issue is therefore an unresolved item. (90-01-25)
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. -
(CLOSED) Violation A.1 (84-01)
Contrary to 10 CFR 21.31, a review of documentation packages for 8 reworked shaf ts revealed that 15 BWC P0s did not specify that 10 CFR Part 21, would a pply.
The Nuclear Regulatory Commission (NRC) inspectors determined that SBPI's corrective actions taken to prevent recurrence were inadequate. These correc-tive actions involved additional training of the repair center personnel on writing P0s and additional training of the quality assurance personnel on reviewing P0s.
Violation 90-01-02, identifies additional examples where SBPI issued safety-related P0s to material manufacturers and suppliers and failed to invoke the requirements of 10 CFR Part 21. This previous inspection finding will now'be tracked under Violation 90-01-02.
2.
(CLOSED)'NonconQr,mge 8.1 (84-01)
Contrary to Criterion V of 10 CFR 50, Appendix B. Sections 10.2.3.1 and 10.2.3.3 of the QAM and Section 9.6.1 of SNT-TC-1A, a review of qualification records for seven Level 11 examiners revealed that records for six examiners i
did not contain a statement showing completion of training in accordance with BWC's Procedure No. H29.6.
)
The NRC inspectors reviewed '.ne qualification records for nondestructive examination personnel and determined that the records contained acceptable statement indicating completion of training in accordance with the applicable SBPI procedure.
3.
(OPEN) Nonconformance B.2 (84.01)
. Contrary to Criterion V of 10 CFR 50, Appendix B, and Procedure No. E12.7.0, Manual No. 23, assigned to the Manager Quality Assurance
.I contained deleted specifications which were not in the index and did not contain current specifications which were listed in the index.
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f O'RGANIZAi10N:
SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON pummemp.
zRT INSPECTION
- 59900031/90-01 RESULTS:
PAGE 9 of 31 The NRC inspectors. determined that the corrective actions taken to prevent recurrence were inadequate. These corrective actions involved assigning permanent responsibility for the maintenance of the documents to the Quality Assurance Manager.
Nonconformance 90-01-21 identifies examples where SBPI failed to provide adequate instructions or procedures to assure satifactory i
accomplishment of activities affecting the quality of safety-related items.
l 4.
(OPEN) Nonconformance B.3 (84-01) i Contrary to Criterion V of 10 CFR 50, Appendix B, and Sections 3.2 and 4.3 of Procedure No. H30.5, a review of P0s for material and services for the l
10 pump shafts indicated that P0s were not reviewed and approved by the QA l
Engineer.
. The NRC inspectors determined that the corrective actions taken to prevent i
recurrence were inadequate. These corrective actions involved additional training of the BWC Repair Center personnel.
Nonconformances 90-01-16 and 90-01-21 identify examples where SBPI failed to provide adequate instructions or procedures to assure satisfactory accomplishment of activities affecting the quality of safety-related items.
5.
(OPEN) Nonconformance B.4 (84-01)
Contrary to Criterion V of 10 CFR 50, Appendix B, and Subsection NCA-4134.6, of Section III, ASME Code, a rrview of four manuals from the QA, Purchasing, l.
Production Control and Manufr.cturing, and Engineering Departments revealed that measures did not exist to control the preparation, issuance, and disposition of individua'. Specifications or procedures.
The NRC inspectors htermined that the corrective actions taken to prevent recurrence were in adequate. These corrective actions involved auditing of each departments procedure list which identifies and controls procedures i
applicable to the nuclear quality program.
Nonconformances 90-01-16 and 90-01-21 identify examples where SBPI failed to provide adequate instructions or. procedures to assure satisfactory accomplishment of activities affecting the quality of safety-related items.
6.
(OPEN) Nonconformance B.5 (84.01)
Contrary to Criterion V of 10 CFR 50, Appendix B, and Subsections NCA-4134.5, and NCA-4134.9, of Section III, ASME Code, a review of P0s for the rework of nuclear pump shafts indicated that the P0s did not identify or reference a procedure for the chrome plating operation and that the P0s did not identify or reference a procedure for the heat treating operation.
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ORGANIZATION:
SULZER BINGHAM PUMPS, INC0P.PORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 10 of 31 The NRC inspectors noted that SBPI did not propose any corrective actions to prevent recurrence of this nonconformance.
Recurring material problems I
have been directly attributed to inadequate or uncontrolled heat treating that continues to be performed without adequate procedures.
Nonconformances 90-01-16 and 90-01-21 identify examples where SBPI failed to provide adequate instructions or procedures to assure satisfactory accomplishment of activi-l ties affecting the quality of safety-related items.
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7.
(OPEN) Nonconformance B.6 (84.01)
Contrary to Criterion V of 10 CFR 50, Appendix B and Sections 1.3.2 and l
1.3.5 of the QAM, records were not available to indicate that an indoctrination session was given for the Quality Assurance Manager and a Quality Assurance Document Control Clerk.
The NRC inspectors determined that the corrective actions taken to prevent recurrence regarding indoctrination and training of personnel was inadequate l
as evidenced by Nonconformance 90-01-20 which finds other inadequacies regarding documentation of indoctrination and training.
8.
(CLOSED) Nonconformance B.7 (84.01)
Contrary to Criterion V of 10 CFR 50, Appendix B and Procedure No. H31.21.1, a review of P0s and Approved Vendor Lis;s (AVL) revealed that Paragraph 6.0,
" Class 11 Quality Program Requirements" of Procedure No. H31.27, was not specified on several P0s.
The NRC inspectors determined that the methods of stipulating quality require-ments on P0s and the designation of quality classifications of vendors on the AVL had been revised several times since identifying this finding.
Paragraph 6.0, " Class 11 Quality Program Requirements," is not part of the cur-rent issue of Procedure No. H31.27.1, Revision 45, dated January 31, 1990.
The current program is adequate; therefore, this item is considered closed.
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9.
(CLOSED) Nonconformance B.8 (84-01)
L Contrary to Criterion V of 10 CFR 50, Appendix B and Section 4.1, of Procedure No. H31.27.3, a review of vendor audits and auditor quali-fications indicated that the auditor was not certified as a lead auditor l
until'after conducting the audit.
The NRC inspectors determined that: vendor audits are currently performed by lead auditors certified in accordance with ANSI N45.2.23.
However, other concerns were raised regarding the adequacy and completeness of the vendor's I
audits which are discussed in Nonconformances 90-01-14 and 90-01-17.
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,E 0RGANIZAT10N:
SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 11 of 31 10.
(OPEN) Nonconformance B.9 (84-01)
Contrary to Criterion V of 10 CFR 50, Appendix B and Section 5.3.2, of Procedure No. A14.0, BWC obtained information about a defective auxiliary-feedwater pump wear ring, but did not submit the written notification to the NRC until November 8, 1983.
The NRC inspectors determined that the corrective action to prevent recur-rence, which was an awareness by the Quality Assurance Manager to provide written notification of deviations to licensees, was inadequate.
Violation 90-01-01 identifies several examples where SBPI either failed to perform an adequate evaluation or failed to notify the purchaser so that they could cause an evaluation to be performed as required by 10 CFR Part 21.
11.
(OPEN) Nonconformance B.10 (84-01)
Contrary to Criterion V of 10 CFR 50, Appendix B, Procedure No. H31.29, Sections 2.4 and 5.0 of ANSI /ASME H45.2.6, and Section 2.1, of Procedure No. H29.1, a review of qualification records for dimensional inspectors revealed the absence of certification for the Dimensional Inspection Foreman.
The NRC inspectors determined that the corrective actions taken to prevent recurrence regarding indoctrination and training of personnel were inadequate as evidenced by Nonconformance 90-01-20 which identifies other inadequacies regarding documentation of indoctrination and training.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.0 EntranceanjExitMeetings The NRC-inspectors informed SBPI management and staff of the scope of inspection, outlined areas of-concern assigned to each team member, participated in a plant tour, and established working interfaces for each team member during the entrance meeting en February 5,1990. On February 8,1990, the NRC inspectors summarized the inspection findings, observations, and concerns to SBPI senior management during the exit meeting.
2.0 Background
The previous NRC inspection of SBPI, formerly Bingham-Willamete Company (BWC),
was in October 1984, and documented in Inspection Report No. 99900031/84-01.
Since that time, several recurring equipment operational problems have been
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ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION s
NO.: 99900031/90-01 RESULTS:
PAGE 12 of 31 l
identified 'in nuclear power plants which use SBPI centrifugal pumps in safety-related systems. The most notable problems have been (a) environmentally induced intergranular stress corrosion cracking / hydrogen emerbrittlement (IGSCC/HE) of the shaft sleeve material at STPEGS, PVNGS and CNS, (b) inade-quate solution anealing of impellers at Diablo Canyon Nuclear Power Plant p'
and Crystal River Unit 3 (CR3), and (c) intergranular corrosion (IGC) of wear rings at Peach Bottom Atomic Power Station, and Browns Ferry Nuclear Plant.
1 SBPI had recently experienced significant organizational changes in key l.
positions, such as the President and the Corporate Quality Assurance Manager I
of SBPl. The new President and Chief Executive Officer for SBPI is Dr. Ulrich Bolleter, who is also the Manager of Engineering for the Pump Division, Plant Technology Group, Sulzer Brothers Limited, Winterthur, Switzerland (parent company of SBPI). Dr. Bolleter attended the entrance meeting and conveyed the importance of this inspection to SBPI senior manage-ment in view of the recent organizational changes.
He pledged his cooperation, and that of his staff's, as well as prompt attention to the findings and observations of the NRC inspection team.
3.0 Inspection of 10 CFR Part 21. Requirements 3.1 Evaluation and Notification of Deviations The inspectors reviewed SBPI's implementation of 10 CFR 21, Section 21.21,
" Notification of Failure to Comply or Existence of a Defect," and identified five examples where SBPI was aware of deviations in designed components that could contribute to exceeding a safety limit, as defined in the technical specifications of a licensee, and either did not perform an adequate evaluation as required, performed an incomplete evaluation, or failed to notify all applicable licensees of the deviation. These examples are individually discussed in Sections 3.1.1 through 3.1.5 below. As a result, Violation 90-01-01 was identified in this area of inspection.
3.1.1 Impeller Failures In October 1988. Diablo Canyon NSclear Power Plant, Unit 2 issued Licensee Event Report (LER)88-029, notifying the NRC in accordance with 10 CFR Part 21.21, of abnormal deterioration of safety-related auxiliary salt water p(ump impellers due to inadequate heat treatment and failure of the vendor SBPI) to control special processes.
Based upon metallurgical analysis per-formed on the impeller material, the licensee determined that the ASTM A-296, Grade CF-8M cast stainless steel did not receive adequate solution annealing heat treatment which resulted in accelerated IGC.
The NRC inspectors determined from interviews with SBPI staff that the impel-lers had been cast by a company known as Hanford; which is no longer in busi-ness. A review of P0s issued to Hanford for safety-related castings revealed
t ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 13 of 31 j
that specific requirements for the solution annealing heat treatment were not L
specified by SBPI.
Even though the ASTM A-296 specification requires solution annealing, the specification did not provide sufficient guidance to perform the solution annealing.
The specific details required to perform an adequate solution annealing, to achieve the desired material properties, must be speci-fied by SBPI. This review determined that all ASTM A-296, Grade CF-8M material supplied to SBPI by Hanford was indeterminate with regard to adequate solution annealing. The abnormal deterioration of this material at Diablo Canyon Nuclear Power Plant indicates that the Hanford supplied material may be susceptible to accelerated IGC.
SBPI staff was not able to provide an evalua-tion of this deviation, but advised the NRC inspectors that only service conditions with impellers in saltwater were considered. Therefore, SBPI L
notified only Crystal River Unit 3 of this potential defect. The SBPI staff stated that inadequately solution annealed ASTM A-296, Grade CF-8M material, supplied by Hanford, is currently in service in various nuclear power plant environments subjected to accelerated IGC mechanism. SBPI had not notified these facilities of this matter. A 10 CFR Part 21 report would have resulted
-if SBPI had adequately evaluated the deviation.
The replacement impellers supplied to Diablo Canyon Nuclear Power Plant were cast for SBPI by a company known as Roemer; also, now out of business.
Roemer supplied ASTM A-743, material procured on SBPI P0s that also did not specify L
the requirements for the solution annealing and again the material specifi-cation lacked sufficient detail to perform an adequate solution annealing.
LER NO.88-029, Revision 1, issued by Diablo Canyon Nuclear Power Plant in January 1990, stated that special testing had been performed to determine the heat treated condition of the replacement impellers and the results were inconclusive. SBPI had not performed an evaluation to determine the adequacy of the solution annealing of the replacement material.
During the course of thi' inspection, the NRC inspectors were provided three s
different lists of nuclear power plants with SBPI pumps.
The lists were provided by separate SBPI organizations. Each list reflected different data and varied widely in their completeness and accuracy. SBPI staff indicated that the pump lists were collected and maintained separately by organizations or individuals depending on the needs of the group or person collecting the data.- The NRC inspectors determined that SBPI could not substantiate, with a reasonably degree of accuracy, which nuclear plants had pumps or the service l-environment and safety-related systems in which they were installed. However, I
these lists were used as the bases to bound critical aspects of the SBPI deviation evaluations. This practice produced evaluation results which may be incomplete.
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PAGE 14 of 31 l-(
l 3.1.2 Shaft Sleeve Failures In February and March _of 1988, STPEGS Unit I and PVNGS Unit 1 experienced failures of shaf t sleeves as reported in LERs88-032 and 88-013, respectively.
The root cause of the shaft sleeve failures was determined to be stress cor-rosion cracking, hydrogen embrittlement, or both; and that the cracking was l
intergranular. The shaft sleeves were made of AISI-420, chromium stainless steel, hardened to 450-525 HB, and shrunk-fit and keyed to the shaf t.
Both failures occurred in auxiliary feedwater pumps.
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-The NRC ins)ectors determined that SBPI has made at least three changes regarding _ siaf t sleeve materials documented in tbs as follows:
Technical
' Bulletins Date.
Change E31.18 January 6,1976 to AISI-440A E31.73 June 19, 1989 to AISI-420
- E31.79 June 27, 1988 to AISI-410 SBPI did not have a documented engineering evaluation to support these material changes to the original design basis.
(SeeNonconformance 90-01-07.)
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l SBPI issued a 10 CFR Part 21, notification to the NRC regarding shaft sleeve l
failures on May 4, 1988. The notice recognized that the problems were caused by IGSCC/HE mechanism directly affecting the AISI-420, wrought stainless material supplied on the center and throttle shaft sleeves.
However, the eva-l' luation was' limited to only pumps in auxiliary feedwater systems and did not' consider all applications of the AISI-420 material. The SBPI notice further limited the applicable nuclear plants to Beaver Valley Power Station, Mill-stone Nuclear-Power Station, PVNGS, and STPEGS.
- The 10 CFR Part 21 notice issued by SBPI, dated May 4,1988, did not adequ-ately address all applicable nuclear plants or the final stage shaft sleeve and should not have been limited to only auxiliary feedwater system pump-applications.
SBPI did not adequately evaluate this deviation for reporta-bility under 10 CFR Part 21.
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~* Applies to only auxiliary feedwater pumps in nuclear power plants.
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PAGE 15 of 31 On March 30, 1989, CNS Unit I reported in LER No.89-007 that an AISI-420 final stage shaft sleeve failed in an auxiliary feedwater pump. The LER indi-cated that the pump failure was due to stress corrosion cracking at the key-slot of the final stage shaft sleeve. The failure was evidenced by the pre-sence of oxides at the fracture origin that indicated the flaw had existed for sometime prior to failure.
SBPI staff was not aware of this failure at the time of this inspection, because NRC regulations did not require that vendors be notified of problems experienced by licensees.
3.1.3 Wear Ring failures L
The NRC issued Information Notice No. 86-36:
" Failures of RHR Pump Motors and Pump Internals" on May 20, 1986, to alert licensees, in part, of failures of pump impeller wear rings at Peach Bottom Atomic Power Station Unit 3, and l
Browns Ferry Nuclear Plant Units 1, 2, and 3.
The wear ring provides a wear surface for the pump impeller and were made of ASTM A-182, Grade F6, 410 stain-less steel with a Rockwell C hardness of 33-39, press fitted to the impe11ers and attached with eight dowel pins. Metallurgical examinations of the wear ring fracture surfaces indicated the presence of IGSCC.
The RHR pumps are model CVIC type. BWC records indicated that model CVIC type pumps used in RHR systems were also installed at Cooper Nuclear Station, Pilgrim Nuclear Power Station, and Vermont Yankee Nuclear Power Station. The information provided to the NRC for Information Notice No. 86-36 by SBPI considered only model CVIC type pumps in RHR systems and did not evaluate CVIC model pumps in other safety-related systems or other model pumps using the same material which were also susceptible to the IGSCC mechanism.
SBPI did not have a documented engineering evaluation of this deviation, but advised the NRC inspectors that only model CVIC type pumps in RHR systems were 1
considered. SBPI did not consider the adequacy.of the source of the wear ring material or the other type pumps and services where ASTM A-183, Grade F6, material is used and subject to the IGSCC mechanism. A 10 CFR Part 21 report, addressing all applications of the material, would have resulted if SBPI had adequately evaluated the failure of the impeller wear rings.
3.1.4 SBPI Technical Bulletins The inspection team reviewed several safety-related Engineering Department tbs to (a) determine the source and type of incidents which prompted the tbs to i
be written, (b) determine the TB distribution (i.e., whether the tbs are inter--
L nel to SBPI or whether they are also distributed to customers), and (c) review the disposition of any deviations that may be potentially reportable. The NRC review determined that tbs were not routinely distributed to its customers.
SBPI used the TB information internally in the Engineering, Manufacturing and Marketing Department. Additionally, SBPI was dispositioning issues that were
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, ORGANIZATION: SULZER BINGHAM PUMPS, 1HCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 16 of 31 deviations as defined in 10 CFR Part 21 without performing the required eyeludo tion or customer notification of the deviation. Examples of the tbs reviewed
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are provided below:
a.
TB E31.6, " Sleeve / Ball Bearing Design," Revision 1, dated July ll, 1974, stated, in part, re orring field problems with the ball thrust bearing of sleeve journal / ball thrust assemblies were suspected to be caused by excessively high axial thrusts. To solve these problems it was essential to measure the magnitude of these thrusts and design a portable thrust measuring device to be used on pumps in the field and shop. The data obtained was considered most useful and had previously never been avail-able.
It clearly showed that the problems were caused by either one or more of the following: axial static thrust loads, high pulsating axial thrust loads, and high unstable axial thrust loads.
This TB discusses design problems with pumps which were intended to oper--
ate continuously over the full performance curve, but due to pulsating thrust loads or hydraulic instabilities produced variations in pressure with the consequent pulsating thrust values. These issues were not evalu-ated by SBPI for potential reportability and the records did not indicate that the TB was distributed to licensees to cause an evaluation to be performed.
b.
TB E31.7, " Journal Bearing /011 Ring Test," Revision 0, dated March 1 1974, stated,inpart,thatdesignconcernsexistedregardingjournal bearing length / diameter (L/D) ratio and a single ring versus the standard double ring lubrication. The temperature and vibration of the outboard standard journal bearing and a modified bearing with a smaller L/D ratio had been observed in conjunction with the required performance test. The modified journal' bearing.ran cooler than the standard journal bearing and the vibration was less. This report stated it was for general informa-tion only, and in no way indicated that SBPI was proceeding to redesign the journal bearings.
It did show that on pumps with recurring journal bearing problems or where there was a lack of bearing cooling that consideration should be given to this design concept. The NRC inspectors concluded that TB E31.7, identified potential design problems regarding the adequacy of journal bearings on pumps used in safety-related applications.
c.
TB E31.10 " Nozzle Loads - CVA," Revision 1, dated April 18, 1974, provided maximum allowable nozzle loads for CVA and CVDS type pumps.
The loads were expressed in the form of maximum component forces and moments (i.e., forces and moments in defined directions) together with l
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PAGE 17 of 31 maximum resultant forces and moments in any direction. Other tbs that raised concerns over the maxiiaum allowable nozz le loads were:
TB E31.12,
" Nozzle Loads - HSB, MSC, MSD, and MSD-D " TB f.31.13. " Nozzle Loads -
HS,HSA,andCD(SideNozzlesOnly)(w"TBE31.14."Nozzlewad;-CP},
CP-D, and CD Heavy Duty Feed Pumps ith Base Pin and Alignment Key i
and TB E31.37, " Nozzle Loads:
VCR, VTR, VCM, and VTM Pumps."
This information may be required by licensees to satisfy the requirements for seismic piping stress analysis and "as-built" reconciliations.
d.
TBE31.18,"ChromiumStainlessSteelWearParts}" Revision 1, dated January 6, 1976, stated that this directive (TB replaced E20.30 and the basic recommendations of E20.30 were retained with addition 61 infor-l mation or recomendations added to various sections.
Persistent galling problems with pumps fitted with chrome wear parts have required changing the part material specifications to AISI-440A, (17 percent chromium) l which is.a superior material for wear parts.
L This TD appears to be the initial documentation of a persistent pump L
design weakness regarding wear rings and shaft sleeves experienced by numerous licensees.
Subsequently, tbs E31.73 and.79 were issued which further discusses this issue.
l TB.E31 73, " Chrome Wear Parts " Revision 0, dated June 19, 1984,-changed chrome vear parts of 450-525 BH from AISI-440A spuncast to AISI-420.
The TB indicated that this e,;..ied to all new pump orders, parts orders, and the Repair Cenbrs.
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TB E31.79, " Wear Part Replacements in Nuclear Auxiliary Feed Multistage Pumps, Type MSD," Revision 0, dated June 27, 1988, stated that the pur-pose was to identify, the causes of cracked shaft sleeves found in some of the referenced pumps and to establish corrective action.
(The sleeves involved were AISI-420 wrought material tempered to 450-525 BH and l~
required changing rotating wear component materials to AISI-410 wrought material with a 250-300BH.)
3.1'.5. Problem Notices from Licensees / Customers SBPI did not have a program to control, disposition, or evaluate for potential reportability of the incoming problems from nuclear customers. Discussions with the Field Services Supervisor and the Pump Parts Order Manager determined-that incoming nuclear customer problems entered SBPI in two areas; the Pump Parts Department and the Field Services Department. SBPI staff in charge of each department advised the NRC inspectors that they had not received indoctrination and training in the QAM and 10 CFR Part 21 requirements for the evaluation and reportability of these deviations or defects. The NRC t
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PAGE 18 of 31 inspectors determined that these two areas were the only points of contact l
for incoming nuclear customer problems.
This condition indicates that problems identified and reported by nuclear customers, that are potentially reportable pursuant to 10 CFR Part 21, may never be evaluated or controlled l
according to the SBPI quality program.
3.2 Procurement Documents Incorporation of 10 CFR Part 21 The inspectors reviewed SBPI's implementation of Section 21.31, " Procurement Documents," of 10 CFR Part 21 and found two examples where SBPI P0s to manufac-l turers and suppliers of safety-related matvials did not specify that 10 CFR Part 21 would apply. As a result, Violation 90-1-02 was identified in this area of inspection, a.
On May 11 1987, STPEGS placed P0 No. 14926-BF-36227 to provide a new safety-related spare rotating element for the auxiliary feedwater pump that could provide a 4.3 percent increased head pressure at 600 gpm.
STPEGS invoked the requirements of 10 CFR Part 21 and Appendix B to 10 CFR Part 50 on the P0. SBPI issued R0 P-1029 to satisfy the P0. R0 P-1029 changed 7 of the 11 impe11ers. On June 10, 1537, 3 of 7 impellers were withdrawn from stock. These l
threeimpe11erswerepurchasedfromPEDManufacturingLtd.(PED)on P0 No. 1 201290. Although PED was on SBPIs Approved Venders List
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(AVL), SBPI did not invoke the requirements of 10 CFR Part 21 and Appendix B to 10 CFR Part 50 on the safety-related order to PED.
b.
The NRC inspectors reviewed P0s for weld electrode filler materials used to perform welded repairs to safety related parts. Welded repairs were observed to safety-related pump impe11ers for Diablo Canyon Nuclear Power Plant. Two different P0s were used tr procure the weld electrode filler materials. The inspectors reviewed SBPIs P0 No. 630648 to Action Arc, Inc., for ARCOs 316L-16,1/8" diameter electrode, AWS A 5.4/ASME SFA 5.4, ASME Section 111 material and P0 No. 630372 to Air Products for OERLIKON 308L-16, 1/8" diameter electrode, AWS A 5.4/ASME SFA 5.4, ASME Section 11, Part C.
Neither P0 imposed quality program requirements or specified that 10 CFR Part El applied, even though SBPI invoked specifi-cations unique to the nuclear industry whica in turn required SBPI to L
invoke 10 CFR Part 21 requirements.
In addition two other P0s, Nos, l
611708 and 611286, forweldelectrodesintendedIoruseinweldedrepairs to nuclear safety-related parts did not impose quality program require-meats or specify that 10 CFR Part 21 applied.
The Quality Assurance staff advised the NRC inspectors that SBPI did not have a program to dedicate commercial-grade items.
The policy of SBPI
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PAGE 19 of 31 was to procure the items for basic components as a safety-related item from subvendors without the need to dedicate the items.
SBPI did not dedicate the aforementioned items.
3.3 10 CFR Part 21 Frocedures Implementation TheinspectorsreviewedSBPIProcedureA14.0,"ProcedureforReportingof Safety Related Noncomplian:e and Defects to Meet 10 CFR Part 21 Revision 6 dated January 26, 1990, and determined that paragraph 5.1 did not ensure that licensees or purchasers were informed of deviations so they could cause the deviation to be evaluated, regardless of contractual requirements.
In addition, paragraphs 3.3 and 3.5 did not ensure that licensees or purchasers product deviations and noncompliances were evaluated to determine whether a particular deviation could creete a substantial safety hazard.
And finally, paragraph 3.4 did not ensure that the SBPI basis for determining 4
reportability, including the scope of the problem, was adequately documented and maintained. As a result, Violation 90-01-03 was identified in this area l
of inspection.
1 4.0 EesignActivitiesandDesignBasesControl This area of the inspection focused on SBPI's quality assurance program in the design process and the controls and verification activities used to assure the adequacy of the design bases of pumps and pump parts.
4.1 Design Organization Authority and Duties The organization chart which describes the reporting chain and interfaces for the Field Engineering Department was maintained on a restricted-access computer and was not available to the engineering staff level personnel.
Additionally, the Field Engineering Department did not appear on the organiza-tienal charts in the SBPI QAM.
The Field Engineering Department interfaces with NRC licensees to solve operational problems and performs other activities affecting the safety-related function of pumps.
Criterion 1, " Organization,"
of Appendix B to 10 CFR Part 50 requires that the authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components shall be clearly established and delineated in writing. As a result, Nonconformance 90-01-04 was identified in this area of inspection.
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PAGE 20 of 31 4.2 Design Batos Documentation and Control This area of the inspection focused on the engineering and design activities of SBPl. Specific evaluations were made to determine the adequacy and control of the design bases for safety-related items. The inspection identified the following examples where SBPI did not adequately control the design bases, a.
TheNRCinspectorsreviewedtheContractSpecificMaterialList(CSML) for Sales Order 1A134/1A141 which supplied eight auxiliary feedwater pumps to STPEGS. The Model MSD pumps were manufactured to the require-ments of a ASME Code Section III, Class 3 component. The CSML stated that the center shaft sleeve (item number 214) was made of AISI-440A, 450 525 HB, and described on Drawing B-33912. On May 11, 1987, STPEGS placed P0 14926-BF-36227 to provide a new spare rotating element for an auxiliary feedwater pump that could provide a 4.3 percent increased head at 600 gpm. STPEGS invoked the requirements of 10 CFR Part 21 l
and Appendix B to 10 CFR Part 50 on the P0.
SBPI issued R0 P-1029 which changed 7 of the 11 impellers.
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TB No. 73, Revision 0, dated June 19, 1984, recommended changing i
chrome wear parts such as the shaft sleeve from AISI-440A to AISI-420. The justification for this change was that AISI-440A was less ductile and susceptible to thermal shock and misuse, in accordance with TB No. 73, the impeller wear rings, hub wear rings, center shaft sleevet, and throttle sleeves were changed from AISi-440A to AISI-420. The material change were included on the CSML but were not documented on the DCS by a DCR or an ECN; nor could an i
evaluation to justify the design change be provided by SBPI for review as required by Section 3.9, of the SBPI QAM and Section 3.3,
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of the SBPI QAPS. As a result, Nonconformance 90-01-05 was ldentified in this area of inspection, b.
On May 6, 198B, STPEGS issued P0 14926-BF-44754 to refurbish eight auxiliary feedwater pump rotors.
SBPI initiated Repair Order P-1229.
The repair was necessary because the AISI-420 shaf t sleeve had failed due to IGSCC/HE. This failure was reported in LER 88-32.
TB No. 79, Revision 0, dated June 27, 1988, addressed the intergranular cracking
- problem, it recommended changing the center shaft sleeve and other rotating parts from AISI-420 to AISI-410 for nuclear service auxiliary feedwater pumps, however, this change was not documented on a DCS or the original CSML. An evaluation to support the design basis
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PAGE 21 of 31 change was not available for review. T8 No. 79, stated that a contributing factor to the failure of the shaft sleeve was high stress concentrations in the keyway of 118,000 psi. The maximum tensile stress could be reduced to 58,000 psi if the interference fit was l
increased (loosened) by.001", and by providing a larger keyway radius. The inspectors asked to review the calculations used to support these design changes, but none were available. As a result.
Nonconformance 90-01 06 was identified in this area of inspection.
On May 13, 1988, SBPI initiated R0 NP-1229 to alleviate the shaft sleeve problem.
The shaft sleeve's drive keyway was revised to provideacornerradiusof.030",(+.010".000") as recommended by TB No. 79.
The repair referenced a center shaft sleeve Drawing i
No. B-33912 E-X and a throttle shaft sleeve Drawing No. B-33906 E-X.
Each drawing contained handwritten instructions. The revision description block for Revision X was handwritten and initialed by a SBPI staff member on June 3, 1988, but the approval block was not completed.
The revision incorporated dimensional changes, added a radius to the keyway corners, and removed the woodruff cutter notes.
The inspectors asked for a control copy of Drawing No. B-33912. The drawing provided was Revision F dated December 28, 1988, and did not reflect the changes described in Revision E-X.
R0 NP-1229 incorporated all of the recommendations made in TB No. 79. These design changes were not reflected on a DCS by a DCR or an ECN, nor could an engineering analysis to support these changes to the design bases be provided for review. As a result, Nonconformance 90-01-07 was identified in this area of inspection, c.
While on a shop tour, an NRC inspector observed a machinist using a numerically controlled (NC) machine.
The machinist was manufacturing a part according to ' Drawing D26049 Revision A, but the design program tape controlling the machine was D26034. Revision A.
The machinist said that a program tape did not exist for 026049, Revision A, but a program tape did exist for a similar part, Draw *n which the machinist edited (modified the program)g D26034 Revision A, to make the part in accordance with Drawing D26049. Revision A.
When the NRC inspectors i
asked a representative of the Manufacturing Engineering Department about machinist editing design program tapes, he said that the machinist had been told verbally not to edit tapes and that if a tape needed to be edited to contact a programer. The representative referenced an undated memorandum from the Head of Programming to the NC Programing Department. The memorandum addressed the problem of 4
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PAGE 22 of 31 mediinist editing program tapes without the knowledge or control of the Programming Department. The memorandum stated that "The current situation in the shop in regards to programming is totally unacceptable... The other objectives that we are undertaking will help eliminate problems in the future only if our attention to detail and our goal of unedited shop tapes is achieved." Nonconformance 90-01-08 was identified in this area of inspection.
d.
Subsequent to the failures of impeller wear rings on RHR pumps, as described in Information Notice No. 86-39, dated May 20, 19B6, SBPI recommended and supplied redesigned integrally-cast wear rings on mo' CVIC pumps used in the RHR system.
This included the redesigned ir
,lers for the Peach Bottom Atomic Power Station plant under order BL s45660 as replacements for impe11ers supplied as part of the initial General Electric order No. 270683/90. No DR, as required by SBPI QAM, Section 3, or other evidence that the design basis for the integral wear ring impe11ers had been verified was available.
l As a result, Nonconformance 90-01-09 was identified in this area of inspection.
I e.
SBPI QAM Section 3, requires that changed design documents be added to the Bill of Material via an ECN.
The Bill of Material. list for order l
270683/90 for model CVic pump impe11ers supplied to Peach Bottom Atomic Power Station did not identify ECNs, but listed, for example, Cross Section l
L Layout Drawing Z-6233.
Drawing Z-6233 dated May 2, 1968, showed a separ-l atewearringonthepumpimpellerdifferentfromtheimpe11erssupplied to Peach Bottom Atomic Power Station with integrally cast wear rings.
r As a result, Nonconformance 90-01-10 was identified in this area of inspection.
f.
SBPI did not have a. procedure for dedicating commercial-grade items for safety-related use. However, SBPI engineering personnel advised the inspectors that the right angle gear box, part of a model VLTH pump for the Surry Power Station, was purchased commercially and supplied as a basic component. As a result, Nonconformance 90-01-11 was identified in this area of inspection.
I g.
Design interfaces within the various SBPI engineering / design activities and between the SBPI engineering / design groups and the Manufacturing Department were found to be weak and ineffective. Examples included:
l (1) The Design Control, Section 3, of the QAM, paragraph 3.3.2,
" Internal Interfaces" did not require that design engineers l
obtain concurrence from the materials, special process, or hydraulic engineering specialists when specifying materials, welding, nondestructive examinations, or parameters affecting fluid flow.
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PAGE 23 of 31 (2) The NRC inspectors observed that the keyway design on shaft sleeve Drawing B-0541, Revision B, could be machined between 0.855 to 0.871
)
inches, as permitted by the design tolerances. The key machined to Drawing A 37959. Revision C, would not fit because of the toler-i ance stack-up.
Under procedure H 31.2, Revision P.1, March 6, 1989, only "Use As Is" (and repairs to ASME Code ite..) require enginee-ring approval. Under these conditic.: :r.d interfaces, the Manuf ac-turing Department could prescribe the key to keyway fit without engineering involvement under the category of " rework."
(3) Section 3. " Design Control," of the SBPI QAM did not adequately addresstheDesignEngineeringDepartment'sInteractionwiththepump i
manufacturing activities.
Interface activities that were it.cking t
descriptive controls and weaknesses involved the Design Engineering i
Department's:
(a) input and review of Work Packages to consider the suitability of special processes, (b) establishment of quality i
standards and acceptance criteria for special processes and tests (c) evaluation of accessibility for bot 1 initial (manufacturingandinspection)andinservice(maintenance) inspection of pumps and major pump components, and (d) responsibilities for input into the disposition of nonconformances.
The inspectors concluded that these weaknesses and lack of descriptive programmatic controls contributed significantly to the overall problems identified in SBPIs design control program. As a result, Nonconformance 90-01-12 was identified in this area of inspection, h.
SBPI Procedure H40.45, "QA Program Supplement for Critical Safety Related Non-ASME Code Parts / Components for Nuclear Facilities" and associated quality requirements Q06 and Q11 did not provide for i
quality controls commensurate with potential safety consequences i
caused by the failure of pum) components.
For example, model CVIC
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pump (usedinRHRsystems)staftsleevesDrawingB-20541,RevisionB, were not classified as critical items and therefore did not receive the appropriate level of verification inspections after a special process.
The sleeve design utilizes a hard material (Colmonoy No. 6) overlay on the outer surface. The process for overlay was defined by E-29, Engineering Requirement No. H06, which provided control of only the hardface thickness. There were no inspections and no acceptance criteria specified to verify and accept the process results, l
As a result Nonconformance 90-01-13 was identified in this area of inspection.
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PAGE 24 of 31 5.0 Control of Special Processes The NRC W pection team followed up on concerns that were raised regarding the heat treatments of safety-related parts fabrication and heat treatments that were applied to repaired safety-related parts. The latter concern involved a review of the weld repair practices at SBPl. These two areas, heat treating and welding, are described separately as follows:
5.1 Heat Treating SBPI subcontracted solution annealing heat treating of austenitic stainless steel safety-related parts as well as other safety-related heat treatments toBeaverHeatTreatingCorporation(BHT).
Solution annealing is required to prevent carbide precipitation and minimize intergranular corrosion of the type that occurred to the impellers in salt water pumps at Diablo Canyon Nuclear Power Plant. The NRC inspectors visited the BHT facilities to determine if SBPI was adequately controlling the quality of heat treatments, a.
A review of P0s indicated that SBPI had ordered material to be heat treated without imposing written specifications or instructions for these special processes.
SBPI PO 71246 dated March 10, 1988, required BHT to perform a solution anneal of impeller 104-127-436 composed of CF-3M material.
SBPI did not specify the heat treatment procedure to be used.
BHT's corresponding shop order, dated March 3, 1988, indicated that the impeller was solution annealed at 1900*F for 15 minutes and quenched in air. SBPI had not evaluated the acceptability of annealing with an air quench process. As a result, Nonconformance 90-01-14 was identified in this area of inspection.
b.
SBPI P0 202344 dated. October 4, 1988, required BHT to perform a solution annealing of a safety-related stuffina box composed of CF-8M material in accordance with ASTM A-743. BHT so?cified solution annealing at 1900'F minimum for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> followed by water quenching.
BHT shop order dated October 5, 1988, indicated that the part was solution annealed at 1950'F for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and quenched in water. SBPI did not specify the quench rate and BHT had not performed any test or established measures to determine the quench rate. SBPI had not evaluated the acceptability of solution annealing with an uncontrolled water quench rate.
The NRC inspector determined that the Roller Rail No. 1 Furnace at BHT was used to solution anneal safety-related material for SBPI when water quenching was required. This furnace appeared to be capable of solution p.
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PAGE 25 of 31 annealing austenitic steinless steil and had water quenching facilities which recirculate the quenching water to a cooling tower for rapid heat removal. The Managcr of Quality f.ontrol, BHT, did not know the quench rate of the equipment. Therefore, the quench rate for all material heat treated by BHT for SBPI was not known. As a result these materials may be subject to accelerated intergranular corrosion (IGC) in safety-related service.
The annealing section, page 408, of the " Heat Treater's Guide" published by the American Society for Metals in June 1982, and reprinted in May 1987, provides information on heat treating steels.
The guide suggests the following procedure:
" Cool rapidly from annealing temperature; no more than 3 minutes to black color. Section size determines quenching medium: water for heavy sections, air blast for intermediate sizes, and still air for thin sections. Observe that carbides can precipitate at grain boundaries, when parts are cooled too slowly between 800 and 1650'F i
(425' to 890'C)."
l The quench rate at BHT was not controlled within these or any other para-l l
meters and consequently was unknown. As a result, Nonconformance 90-01-15 was ientified in this area of inspection, t
c.
The NRC inspector dttermined by discussion with the Manager of Quality l
Control that BHT did not have written procedures to control heat treating of safety-related material for SBPl.
The heat treat operators at BHT performed heat treating in accordance with verbal instructions or as his experienced indicates if the work was done on the weekend.
As a result, Nonconformance 90-01-16 was identified in this area of inspection.
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The NRC inspector determined by discussion with the Manager of Quality Control that BHT did not have quality procedures to provide for evalua.
tion of deviations or informing the licensee of deviations.
SBPI required BHT to meet the requirements of 10 CFR Part 21 and 10 CFR Part 50, Appendix B; however, SBPI failed to verify that the BHT QA program comp-t lied with those requirements for safety-related P0s. As a result, l
Nonconformance 90-01-17 was identified in this area of iaspection.
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s ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED i
PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90 01 RESULTS:
PAGE 26 of 31 S.2 Welding SBPI performed welded repairs to ASME Code items and non-ASME Code safety-related items. Some of these welded repairs required postweld heat treating (PWHT). Welding Procedure Specifications (WPS) and Procedure Qualification Records (PQR) were performed and qualified in accordance with ASME Code,Section IX, " Welding and Brazing Qualifications" by the SBPI Materials and Welding Engineer. TheWelder/WeldingOperator/PerformanceQualification(WPQ) were also performed and qualified in accordance with ASME Code,Section IX, but were the responsibility of the Quality Assurance Manager, Portland Pump Division of SBPl.
a.
The NRC inspectors reviewed DR No. 96934 for the welded repair of defect areas on nuclear safety-related impellers of ASTM A-744 Grade CF-3M identified as item No 1780348, SRN No. 1, 2, and 3 Drawing No. D-11059 for Diablo Can Revision C 90-01-02) yon Nuclear Power Plant and discussed in Section E.3.2(Violation of this report. The DR was dispositioned by I
the Project Engineer, without review or interaction with other manufac-i turingactivities(seeNonconformance 90-01-12). The DR stated, " weld repair defect areas per AS-1 or AS-3."
A review of the AS-1 WPSs revealed that nine versiuns are available for use by manufacturing as follows:
SOLUTION WPSs REVISION DATE PWHT ANNEAL AS-1 0
11/27/79 yes yes AS-1 1
6/2/81 yes yes AS-1 2
6/1/82 no yes AS-1 3
8/22/86 no yes AS-1(20) 1 10/30/87 no no l
I AS-1 4
12/4/89 no yes AS-IR 5
9/21/78 yes yes AS-1R 6
9/27/79 yes yes AS-1R 8
10/19/81 yes yes The Engineering Department did not adequately specify the WPS to be used in order to assure that proper weldability, PWHT, and solution annealing requirements were met. As a result, Nonconformance 90-01-18 was identified in this area of inspection.
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,' dRGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 27 of 31 b.
A review of the supporting PQRs for the AS-1 WPSs determined that PQR No. AS-1-4, VSA1, specifies water quench for the solution anneal PWHT but did not specify the temperature range (quench rate) as required by paragraph QW-407.1(b)(2), of ASME Code,Section IX. As a result, Nonconformance 90-01-19 was identified in this area of inspection.
6.0 Indoctrination and Training The NRC inspectors reviewed the corrective action for Nonconformances B.6 and B.10, which were identified in NRC Inspection Report 99900031/84-01, and deter-mined that the actions taken by SBPI are inadequate. During this inspection, the NRC inspectors reviewed the indoctrination and training records for 15 SBPI personnel and determined that 8 of 15 did not have records available that document indoctrination and training in the quality assurance program for the scope of their job responsibilities.
For example, during an interview with the Field Service Supervisor, the inspectors determined that he had not received indoctrination or training in the quality assurance program, with the exception of a discussion with the former Quality Assurance Manager in 1988 regarding a 10 CFR Part 21 report being processed by the Quality Assurance Manager. The Field Services Super-visor functions as the interface with all NRC licensees regarding problems and complaints. Thus, knowledge of 10 CFR Part 21,10 CFR Part 50 Appendix e and theASMECodewouldbeessentialinordertomeettheintentofNRCregulations.
,l The records of indoctrination and training for the Tool Room Supervisor were not available.
Further, the inspectors noted that the Tool Room Supervisor had a limited knowledge of the regulations and requirements to be imposed on P0s for safety-related materials. The SBPI QAM requires that indoctrination be performed by each Operation Manager.
However, the conditions observed during the inspection indicated that the indoctrination and training program wts inadequately implemented. Nonconformance 90-01-20 was identified in this area of inspection and Nonconformances B.6 and B.10 were previously identified and documented in Inspection Report 99900031/84-01, remain OPEN, as discussed in Section D 11 of this report.
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7.0 Instructions and Procedures The NRC inspectors reviewed the following instructions and procedures during the course of this inspection:
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t ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 28 of 31 1
DOCUMENT NO.
TITLE REVISION DATE N/A SBPI QA Manual 3rd issue.
12/09/88 Revision 2 E 31.0 Index to Technical Bulletins N/A 01/02/90 E 1.0 Index to Engineering Design Revision 5 01/11/83 Manual E 29 SBPI B11-E29 Report N/A 08/28/89 H 40.45 SBPI Procedure "QA Program Revision 4 09/20/89 Supplement for Critical Safety Related Non-ASME Code Parts /
Components for Nuclear Facilities" H 31.2 SSPI Procedure " Instructions Revision 21 03/06/89 for Prephration, Disposition and Approval of Discrepancy Reports N/A Ltr SBPI (Gordon Parks) to N/A 05/21/86 GE advising of CVIC Wear Ring Design Change Proposal H 32.27.1 Approved Vendor.s 1.ist -
Revision 45 01/31/90 Class I and Class 11 Vendors A 14.0 Procedure for Reporting of Revision 6 01/26/90 Safety Related Noncompliance and Defects to Meet 10 CFR Part 21 A 17.0 Sulzer Bingham Order Pro-Revision 0 03/13/89 cessing for Parts Requiring Documentation H 31.26 Guidelines for Quality Revision 5 08/28/87 Assurance Review of Customers Purchase / Order / Technical Specifications
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' ORGANIZATION:
SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 29 of 31 DOCUMENT NO.
TITLE REVISION DATE H 31.27 Vendor Control - Classifi-Revision 11 11/22/88 cation and Qualification I
E 31.39 Visual Casting Inspection Revision 0 07/28/78 Standard MSS-SPSS This review revealed three examples where activities affecting quality were not adequately prescribed to assure satisfactory accomplishment.
Specifically:
a.
SBPI published a list of internal engineering position papers, identified as the Index to Technical Bulletins E 31.0, Revision dated January 2,1990.
SBPI did not provide a formal guidance document to define the initiation and utilization of these tbs.
b.
The Index to the Engineering Design Manual, Revision 5, dated January 11, 1983, did not list E-29, " Supplemental Statements List," which were used to apply engineering requirements to shop work orders and purchase orders.
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Visual inspection of castings may be invoked by E-29. Engineering Requirement No. E14, citing specification MSS-SP-55.
- However, TB E31.39 interpreted MSS-SP-55 requirements at variance with the specification and obviated the visual inspection requirements.
As a result, Nonconformance 90-01-21 was identified in this area of inspection.
8.0 Control of Materials' I
s, Pr:Ston-ground pump shafts with finished surfaces were stored in direct contact with the angle iron racks without pads.
Shafts were also stored to0 ether on the same rack with unprotected threads and in contact with each other without adequate blocking.
Items noted included: MSD 6 stage shaft, CD single stage shafts, and a BVCM shaft.
The BVCM shaft is being manufactured for nuclear safety-related use. These storage and handling conditions did not comply with Section 13.0 of the QAM or Section 3.13 of the QAPS. As a result, Nonconformance 90-01-22 was identified in this area of inspection.
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Discrepancy Report No.10054, Shop Order No N-7179, for a shaft sleeve carries a note for a Material Review Board to disposition the nonconformance.
Neither the SBPI QAM, nor the procedure H40.45 described the functions of a Material Review Board to disposition nonconforming items. As a result, Nonconformance 90-01-23 was identified in this area of inspection.
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ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON s
REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 30 of 31 F.
PERSONNEL CONTACTED:
- Ulrich Bo11eter, Ph.D Chief Executive Officer, Sulzer Bingham o
Pumps, Inc. and Manager of Engineering, Pump Division, Sulzer Brothers Limited, Switzerland
- Willy Stucki Acting Plant Manager, Portland Pump Division, SBPI and Manager Quality Assurance, Pump Division, Sulzer Brothers Limited Switzerland
- Thomas R. Morton Vice-President of Engineering, SBPI
- Wayne D. Thomas Manager Design Engineering and Corporate Quality Assurance Manager, SBPI f* Robert T. Grant Manager Corporate Parts Department, SBPI f* Jim Bohlman Design Engineer, SBPI
- Dennis Ward Manufacturing and Materials Manager, c
SBPI f* Joe L. Wood Quality Assurance Manager, Portland Pump Division, SB91 Kent H. Crossley Materials ana Welding Engineer Ronald G. Neland Order Manager, Pump Parts Department Jack Taylor Purchasing Gordon Parks Supervisor, Field Services Robert Faulkner '
Quality Engineer Warren McKinney Quality Engineer Robert Maddock SeniorProjectEngineer(Computer Control)
D. T. Richfield Purchasing Roger Hamilton Purchasing em-<
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ORGANIZATION: SULZER BINGHAM PUMPS, INCORPORATED PORTLAND, OREGON REPORT INSPECTION NO.: 99900031/90-01 RESULTS:
PAGE 31 of 31 PersonnelContacted(con't)
Cheryl Moyer Purchasing Howard Harkem, Jr.
Supervisor Teol Room, Special Products Mike Lehew Manufacturing Engineering William J. Lee Manager of Quality Control, Beaver Heat Treating Corporation 4
- Present during the entrance meeting
- Present during the exit meeting l
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