ML20057C053
| ML20057C053 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1993 |
| From: | Cwalina G, Petrosino J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20057C049 | List: |
| References | |
| REF-QA-99900105 NUDOCS 9309270012 | |
| Download: ML20057C053 (13) | |
Text
.
U S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION Of REACTOR INSPECTION AND LICENSEE PERFORMANCE ORGANIZATION:
Fisher Controls International, incorporated (Fisher)
REPORT f40.
99900105/93-01 ORGANIZATIONAL Mr. Ken Carder, Manager, Quality Assurance CONTACT:
(515) 754-2500 CORRESPONDENCE 205 South Center Street ADDRESS:
Marshalltown, Iowa 50158 NUCLEAR INDUSTRY:
Designer, manufacturer and supplier of air and motor-operated control valve assemblies and valve accessories that meet the requirements of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code, Sections 111 and VIII, and also associated valve instruments and regulators.
July 12-15h993 INSPECTION CONDUCTED:
/
/I C3 INSPECTION TEAM LEADER:
sp Petrosino, Team Leader
' 'Date eactive Inspection Section 2 (RIS-2)
Vendor Inspection Branch (VIB)
OTHER INSPECTORS:
J. S. Winton, NRC, Materials and Chemical Engineering Branch P. L. Campbell, NRC, Mechanical Engineering Branch T. L.
inkel, Consultant APPROVED:
Im.,
7//73
'firegory A,./Cwalina, Chief, RIS-2: VIB
'Date Divisio'n zff Reactor inspection and Licensee Performance Office of Nuclear Reactor Regulation INSPECTION BASES:
10 CFR Part 21 and 10 CFR Part 50, Appendix B INSPECTION SCOPE:
To review and evaluate selected portions of the fisher quality assurance (QA) program, 10 CFR Part 21 program and to follow-up on a concern regarding some Fisher valve assembly seismic stress calculations.
PLANT SITE Numerous APPLICABillTY:
.l.
9309270012 930916 PDR GA999 ENVFICO 99900105 PDR
.. - ~
. =
4 1
INSPECTION
SUMMARY
1.1 Violations 1.1.1 Contrary to Section 21.21, " Notification of failure to comply or existence of a defect and its evaluation," of 10 CFR Part 21 (Part 21), Fisher failed to adopt appropriate procedures to effectively implement the provisions of Part 21.
Specifically, Section 15.5, " Reporting Defects and Noncompliance in Parts Components or Products Supplied in Accordance with the Provisions of Title 10. Chapter 1, Code of Federal Regulations - Energy Part 21," in fisher's Standard Quality Assurance Manual (SQAM), approved November 5, 1992, was not adequately established to ensure that deviations and failures to comply were appropriately dispositioned pursuant to the regulation.
(93-01-01) 1.1.2 Contrary to Section 21.6," Posting requirements," of Part 21, the NRC inspectors found that the Part 21 posting requirement option that Fisher chose and posted at its facilities did not adequately describe the Part 21 regulation nor the documents adopted to implement Part 21 (Section 15.5 of its SQAM).
(93-01-02) 1.2 Nnnconformances 1.2.1 Contrary to Criterion ll, " Quality Assurance Program," and Criterion X,
" Inspection," of Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and fuel Reprocessing Plants," of 10 CFR Part 50 (Appendix B), and Section 3.1. " Quality System," of Fisher's Standard Quality Assurance Manual (SQAM), approved November 5, 1992. Fisher's SQAM did not appear to adequately address or take into account the need for verification of quality by inspection and test by individuals other than those that performed the work activity Additionally, although Fisher's SQAM stated its quality program was designed to comply with the Appendix B requirements, Section 2, " Management Responsibility," of the SQAM only required the QA Manager to " implement a quality program in accordance to 150 9001 and QMI 25," and did not address Appendix B requirements.
(93-01-03) 1.2.2 Contrary to Criterion VI, " Document Control," of Appendix B, and Section 7. " Document Control," of the Fisher SQAM, Fisher f ailed to maintain the User's Manual for the SElSMIC4 Finite Element Analysis Program under formal document change control.
The version of the document in use by Fisher personnel did not contain any indication of the document revision, the effective date, or the approval authority.
(93-01-04) 1.3 Open items 1 3.1 Open item.
As is further discussed in Sections 2.6 and 2.7 below, during the 1986 and 1988 NRC inspections the NRC inspectors identified some concerns regarding the manner in which Fisher controlled its finished part receipt area and receipt inspection activities.
Although Fisher stated to the,
NRC staff in its January 10, 1989, NRC Inspection Report response letter that it had performed corrective action, the team did not discuss or verify whether This item will be reviewed F
fisher's corrective action was satisfactory.
during a future NRC inspection.
(93-01-05) 1.3.2 Open item.
The NRC inspection team identified a few licensee problems with fisher's equipment, in which the licensee documentation of the problem indicated that fisher was contacted about the problem.
However, the team found that the fisher Marshalltown, Iowa nuclear QA, engineering and contract h
staffs were not cognizant of the problems.
For example, NRC Licensee Event Report (LER)89-003, from the Baltimore Gas and Electric Company's (BG&E)
Calvert Cliffs station indicated that it had contacted a Fisher representative l
for information regarding maintenance procedures for a positioner pedestal gasket that had failed unexpectedly.
However, fisher Marshalltown was not aware of the problem.
LER 91-004 from Millstone Unit 3, that is discussed below in Section 3.6, indicated that Fisher was contacted about the adequacy of a procedure that Millstone had used in tightening a T-ring, because the T-Ring was damaged during the activity.
However, Fisher Marshalltown was also aware of this problem.
Fisher is considering a modification in its not relationship with its field representatives concerning nuclear customers, in which fisher is also considering implementing a communications program, nuclear customer problems that are related to field representatives will also This item will be be required to be transmitted to Fisher Marshalltown.
reviewed during a future NRC inspection.
(93-01-06) 1.3.3 Open Item.
During the inspectors' review of Open Item 88-01-05, a concern was identified regarding different versions or revisions of Fisher valve assembly instruction / specification sheets that discuss valve stem It was perceived that fisher nuclear customers may not be aware of packing.
Fisher's official position on use of packing in nuclear valves because a review of fisher instruction manuals appeared to indicate a lack of consistency and uniformity in addressing the installation of non-original During discussions with Fisher staff, it was identified that some packing.
nuclear customers may be installing replacement packing materials that differ This and may have a higher stem f riction than, the original packing.
- from, "Potentially issue was briefly mentioned in NRC Information Notice (IN) 88-94, Undersized Valve Actuators." Therefore, the team was concerned that nuclear customers might be confused by the guidance or lack of guidance with respect to inst alling dif f erent packing.
This item will be reviewed during a future NPC inspection.
(93-01-07) 2 STAlUS 0,f PREVIOUS INSPECTION flNDINGS 2.1 illnsedl Nonconformance 88-01-01 Contrary to Eriterion X11. " Control of Measuring and Test Equipment," of B. three measuring and test equipment (M&TE) items inspected were out Appendix The
'on according to the M&TE calibration history record cards.
of calibr-< tors reviewed examples of the fisher corrective action documents and NM inM f ound them t o satisf actorily address the concern.
\\
l l
i 2.2 (Closed) Nonconformance 88-01-02 Contrary to Criterion X11, of Appendix B, one M&TE calibration history record could not be found by Fisher for flow-rate test device number (RB-104.
Fisher I
found the record after the inspection was completed and provided a copy to the NRC staff for review.
The NRC inspectors found the Fisher explanation and associated record to satisfactorily address the concern.
l1 8
2.3 (Closed) Nonconformance 88-01-03 Contrary to Criterion X11, of Appendix B, Fisher calibration irocedure 2H3 did not specify acceptance / rejection criteria for calibrating torque wrenches.
[I The NRC inspectors found the Fisher explanation and associated records to l
satisf actorily address the concern.
1 2.4 (Closed) Nonconformance 88-01-04 Contrary to Criterion X11, of Appendix B, the Fisher program for controlling its M&TE tools and instruments did not require that " calibration due date" stickers be af fixed to individual personnel's personal tools and the program did not ensure that only calibrated equipment was available for use in j
Fisher's work activity areas.
The NRC inspectors reviewed the revisions made to Fisher Manufacturing Procedure (FMP) 2H2 and found that it satisfactorily i
I addressed the concern.
2.5 (Closed) Open item 88-01-05 The Fisher staff contacted the NRC on June 8, 1988, to discuss actuator sizing l
calculational methods regarding rotary shaf t and sliding stem friction forces and licensee replacement of originally supplied stem packing materials with different types of stem packing.
As a result of the NRC staff technical review that was performed with the assistance of Fisher engineering personnel in 1988, the NRC isst.d Information Notice (IN) 88-94, "Potentially Undersized Valve Actuators." NRC IN 90-21, 'i stential f ailure of Motor-Operated Butterfly Valves to Operate Because Valve Seat Friction Was Underestimated,"
additionally discussed the Fisher concern identified in IN 88-94.
As a result of the discussions that were held during the 1988 NRC inspection, fisher i
developed enhanced actuator sizing methodologies and mathematical equations.
Further, fisher informed all of its North American field representatives of i
the scope of the problem and provided its suggested corrective action methods f or its representatives to carry out for any licensee installed valve assemblies The NRC inspectors determined that the above action satisf actorily addressed the concern and additionally identified the problem to NRC licensee facilities for their review and action as necessary.
2.6 (Closed) Open item 88-01-06 The NPC inspectors identified potential problems in the manner in which Fisher was controlling its receipt inspection areas during the 1988 inspection (0 pen item 88-01-06) and the team previously identified different receipt inspection concerns during the 1986 NRC inspection (Nonconformance 86-01-03) at the fisher facility.
The Fisher response to this item in its January 10, 1989,,
letter to the NRC stated that it would implement a " Nuclear Safety Related Inspection System" for the receipt inspection area.
However, the inspection team was not able to appropriately discuss or to verify that Fisher's corrective action was satisfactory.
Open Item 88-01-06 is closed and this receipt inspection concern will be followed by Open item 93-01-05 above.
2.7 (Closed) Nonconformance 86-01-03 Contrary to Criterion V, " Instructions, Procedures, and Drawings," of 2l Appendix B, Fisher failed to establish procedures and instructions for quantitative or qualitative acceptance criteria in its finished parts receiving area inspection activities. This nonconformance will be closed in conjunction with the closure of Open item 88-01-06 and the applicable concerns will be followed by Open item 93-01-05 above.
4 3
INSPECTION FINDINGS AND OTHER COMMENTS 3.1 fntrance and Exit Meetinas During the entrance meeting on July 12, 1993, the NRC inspectors discussed the scope of the inspection, outlined areas of concern, and established interfaces with fisher's management and staff. At the conclusion of the inspection on July 15.1993, the inspectors summarized their findings and concerns, and Fisher's management and staff acknowledged this information.
3.2 10 CFR Part 21 Proaram 3.2.1 10 CFR Part 21 Procedure.
The NRC inspection team reviewed the program that fisher established and executed to implement the provisions of Title 10 of the Code of Federal Reaulations, Part 21 (Part 21), to evaluate its effectiveness and adequacy.
The inspectors found the procedures that fisher had established for compliance with Part 21 to be encompassed in Section 16,
" Nonconforming Materials and items," of its Nuclear Quality Assurance Manual (NOAM), Revision 3 dated August 5, 1992, and Section 16, " Nonconforming Materials and items," of its SQAM. The team performed a comparison of the two procedures in the QA manuals and determined that the Part 21 procedures were almost identical to each other.
The inspectors, therefore, performed a detailed review of one of the procedures that was contained in Fisher's SQAM to determine its adequacy and effectiveness.
The team found that the procedure addressed the majority of the Part 21 requi rement s..
However, some weaknesses were identified and a few aspects of Part 21 were not addressed in the procedure.
The Part 21 procedure appeared to indicate that there was only one source of potential deviations and that was within Fisher's manufacturing and fabrication areas.
Fisher's Part 21 procedure is incorporated in Section 15, " Control of Nonconforming Product,"
of the SOAM, That section described the processing of nonconforming materials and items and required that all nonconforming material from machine operators, assemblers or inspectors be identified, as appropriate, with a reject tag, deviation report or a scrap loss report, and that all nonconforming material be processed in accordance with Section 15 of the SOAM.
Further. Section 15.5.5.3, " Initial identification of Potential Problems,"
i states that "a suspected deviation may be identified by any source," and that
"]f [the Manager of QA) determines that the possibility exists that basic components may have a deviation, he immediately orders shipments to be stopped and initiates an investigation." However, although the SQAM Section stated that a suspected deviation may be identified by any source, the inspectors noted that the SQAM implies that deviations in the manuf acturing/ assembly process areas are the only source in which deviations are identified.
Another weakness that was identified concerned a 60 day investigation of a
" suspected Deviation" that was allowed to be performed af ter the " discovery" date.
The team found that, at the end of Fisher's 60 day investigation, the SOAM required Fisher to notify its customers if Fisher determined on the basis I
of an evaluation that there could be a defect.
The purpose of this customer contact was stated to be for the purpose of "asking the customer" if it wishes to participate in "the evaluation." The team explained to Fisher that the 60 day period is f or the purpose of performing an evaluation of an identified deviation and not for determining whether a deviation existed.
The inspectors also explained to Fisher staff that, if a deviation was identified and Fisher did not have the capability to perform an evaluation to determine whether a defect existed that related to a substantial safety hazard, fisher is required to inform the customer of the deviation within five days of discovery so that the customer may cause the deviation to be evaluated.
Further, the team found that " discovery" was not defined and two other definitions, " evaluation" and " operating," were not accurately or completely defined in Fisher's Part 21 procedure.
The team also identified two potential deviations that the team discussed with Fisher that appeared to be examples in which the applicability of customer identified deviations to 10 CFR Part 21 was not readily apparent to Fisher because of its Part 21 procedure l
weaknesses.
These two potential deviations are as follows:
3.2.1.1 Woodruff Keys. On September 24 and 28, 1987, the Diablo Canyon nuclear power plant ordered safety-related Woodruff keys on Pacific Gas and Electric (PG&E) purchase order (PO) numbers 011745 and 011747, respectively.
In a letter dated October 26, 1990, PG&E notified Fisher of deficiencies in the Woodruf f key material that was provided initially as safety-related in September 1987 and as commercial grade items (CGis) in subsequent PG&E procurements.
PG&E indicated to Fisher that it had received suspect keys and had previously informed their local Fisher representative.
Fisher responded to PG5f in a December 13, 1990, letter that it had checked its stock at the Marshalltown, Iowa site and found no suspect material in the stock that they had labeled high strength.
Fisher also indicated that it was the correct material f or the Woodruf f keys ordered by Diablo Canyon.
Fisher further indicated that it did not know how a substandard Woodruff key was installed in the valve.
The team noted that the issue which precipitated the correspondence between PG&E and fisher was discussed in an April 3,1990, PG&E Licensee Event Report (LER)90-008.
The LER indicated that its Unit 2 residual heat removal (RHR) heat exchanger bypass valve was not capable of being positioned to control flow due to failure of the Woodruff key connecting.the valve shaft to the actuator arm.
Subsequent evaluation concluded that the minimum Technical
~6-i
Specification required flow for an RHR train could not have been guaranteed had the key been installed and subsequently failed in another of several similar RHR valves.
The root cause was determined to be improper vendor Subsequently, Diablo Canyon identified additional supplied key material.
substandard keys and informed Fisher of these events as recently as June 1993.
However, it appeared that after Fisher responded to PG&E on the 1990 matter, no further action regarding Part 21 potential applicability or any review for generic considera' ion was performed.
It The team discussed this matter with the Fisher representatives while they were in the process of investigating this more recent report.
It appears that when Diablo Canyon ordered commercial grace Woodruff keys instead of safety-related l:
keys, the stock came from Fisher's authorized Memphis, Tennessee distribution At the time of this inspection, none of the stock at the Memphis center.
distribution center was checked for problems.
However, subsequent to the inspection, on approxin..tely August 16, 1993, the Fisher QA Manager informed the team leader that Fishcr had identified some low-strength Woodruff keys that were commingled with the Memphis distribution center's high-streng*h Woodruff key material. The stock was purged of the low-strength keys. The team concluded that Fisher did not appropriately review this matter in 1990, when it was first identified.to Fisher by PG&E, to determine whett.er other customers could be affected.
Diaphraam Cover Toraue Value. On June 10, 1992, a feedwater (FW) 3.2.].2 alarm (Steam Generator (S/G) 2C Level Deviation) was received on the "C" loop steam generator at the Byron nuclear generating station. Initial attempts to stabilize S/G level were successful; however, the "C" loop S/G FW valve The subsequently f ailed closed, and a manual reactor trip was initiated.
cause of this event was the failure of the valve operator diaphragm.
Byron contacted fisher and found out that Fisher Engineering had changed the diaphragm casing torque value for the 16" air-operated valve ( A0V) Flow Control Valve f rom toe original torque value of 20-40 f t-lbs to a torque value The failure of the diaphragm was caused by inadequate of 48-50 ft-lbs.
sealing of the diaphragm cover due to an elongation of the diaphragm bolt holes.
Fisher indicated that this was due to inadequate torquing of the diaphragm cover bolts by the Byron facility.
it was found that Fisher Controls did not recognize the generic
- However, implications of the problem and f ailed to adequately evaluate the failure for applicability to other nuclear customers that were supplied with the same type Fisher changed the torque value in the instruction manual for of component s.
this valve approximately 6 months later, but did not recognize that the modified torque value could represent a deviation in the initial operating specified in the original vendor specification and parameters that werE instruction manuals of other customers nor did they adequately consider within their Part 21 program that other customers could be sub.iect to the same type Fisher stated to the team that they considered the change in the of failures.
instruction manual to be a routine change; therefore, it did not inform customers of the revised torque values in the diaphragm casing torque value.
Subsequent to this inspection, on approximately August 16, 1993, the fisher QA inf ormed the NRC staff that it would inform applicable customers of Manager the increased torque value change.
The team concluded that the procedures Fisher had established would adequately ensure that deviations found in Fisher's manufacturing and fabrication, activities would be appropriately idcntified and entered into the Part 21 procedure process.
However, it was concluded that the Part 21 procedures did not adequately ensure that the deviations would be dispositioned within the current Part 21 time limits and did not ensure that other sources of potential deviat ions would. be recognized and appropriately dispositioned by Fisher.
It appeared that tie weaknesses in Fisher's procedure contributed to the failure of Fisher to appropriately disposition these deviations in accordance with Part 21 and to inform its customers.
Violation 93-01-01 was identified in t
this area.
ll 3.2.2 Part 21 Postina. The NRC inspectors observed that the required Part 21 posting was adequately displayed by Fisher in its facilities and performed a review to determine its adequacy.
Fisher chose to post Section 206 of the Energy Reorganization Act of 1974, and a notice which describes Part 21 and procedures adopted to implement Part 21, including the name of the individual to whom reports may be made, and states where they may be examined.
The team found that the posting did not adequately describe Part 21 and did not adequately describe Fisher's procedure / documents that were adopted to i
I implement Part 21.
Violation 93-01-02 was identified in this area.
3.3 Fisher Standard 0A Manual During the team's review of Fisher's SQAM, some inconsistencies were noted regarding the establishment of the individual sections of the QA manual when compared with the overall intent of the QA manual. The March 20, 1992,
" General Policy and Authority Statement," stated, in part, that "The Quality i
Assurance Program described in this Manual shall be used for manufacturing standard products and products with special customer requirements.
This program is in compliance with 10 CFR Part 50 - Appendix B, 10 CFR Part 21, ANSI f445.2 and 150 9001. " Additionally, it was found that Section 3.1, l
" Quality System," of fisher's SQAM, stated, in part:
This manual delineates the responsibilities for the preparation and f
implementation of a pl an of activities which shall assure and control the quality of those
- items, parts, or components manufactured by FCS [ Fisher Control s System Business Unit]-
j Marshalltown Division.
The quality program has been designed to j
comply with the requirements of 10CFR Part 50, Appendix B, ANSI N45.2, and 150 9001-1987 and implement the requirements of 10 CFR Part 21. This manual is supplemented by various Quality Management Procedures (QMP),
Engineering Standards (ES),
and Fisher I
Manuf acturing Procedures (FMP) which describe in more detail the activities, responsibilities, and actions required by the Manual.
i The fisher staff stated that its SQAM used FMP 2K27, " System for Processing Nuclear Saf ety Related Orders," Revision 3, issued June 5,1990, in conjunction with its SQAM to ensure that its safety-related non-pressure boundary parts were controlled in accordance with Appendix B.
FMP 2K27 was l
P identified to the team as being fisher's " dedication" procedure that was used to dedicate CGls or non-pressure boundary parts at the end of the manufacturing, test and fabrication process.
Prior to the inspection, the team leader was informed by the Fisher QA Manager that a June 1993 NUPlc audit of fisner identified that fisher's FMP 2K27 procedure appeared to contain weaknesses that would question the adequacy of the procedure to be used for the dedication of CGis.
The team agreed with the NUPlc conclusion, based upon a limited review of the procedure.
Since NUPlC's report will adequately prompt corrective action from fisher, the NRC staff will not address FMP 2K27 in any detail.
lhe team reviewed several recent NRC licensee procurement packages in which
(
the licensees ordered pressure and non-pressure boundary safety-related parts.
The majority of the licensee purchase orders (PO) imposed Appendix B and Part 21 for the non-pressure boundary parts. The team found that the applicable Fisher certificates of compliance (CoC) stated that, "These items were processed to a Quality Assurance Program that meets 10CFR50 Appendix B and complies with 10CfR21." The team reviewed the QA program process controls that were delineated in the SQAM to determine the adequacy of the program prior to verifying the adequacy of the implementation.
The team found several f undament al weaknesses that, when viewed in conjunction with NUPlC's concern regarding FMP 2K27, questioned whether fisher's process controls for non-code safety-related part s conf orm to Appendix B.
for example, although Criterion X, " Inspection," of Appendix B requires that activities af fecting quality of the components be inspected by individuals other than those who performed the activity being inspected, the SQAM allowed the same people who performed the work to also inspect their own work.
Another weakness identified was that Section 2, " Management Responsibility,"
of the SQAM only required the QA Manager to " implement and maintain a quality l
program in conformance to 150 9001 and QMI 25."
The team concluded that, although the 50AM had certain elements of a quality program that would generally meet the requirements of Appendix B, the SQAM was found to contain weaknesses that would not be in compliance with Appendix B.
Nonconfornance 93-01-03 was identified in this area.
3.4 Computer Code Users Manual During a review of the valve bonnet seismic holt stress analysis concern that is discussed below, the team identified a concern with the computer code user's manual.
The team noted that the version of the computer code user's manual for fisher's SEl5MIC4 " finite Element Analysis Program" did not appear to be under formal document change control.
The version of the document that was used by Fisher personnel during the NRC inspection did not contain any indication of the document revision, the effective date, or the approval authority.
The team reviewed Section 7, " Document Control," of fisher's SOAM and found that it stated, in part, that "the responsibilities for the preparation. review, approval and distribution of documents shall be in accordance with lable 7.1.lA."
Table 7.1.lA, " Persons Responsible for Original Documents and Revisions," required that engineering documentation be prepared by engineering staff; be reviewed by product / project engineering or engineering management; and be approved by engineering management This issue is further discussed in Section 3.5 below. Nonconformance 93-01-04 was identified in this area.
3.5 Seismic Bolt Stress Analysis On January 6,1993, the Westinghouse Electric Corporation (WEC) sent a letter to Fisher advising them that WEC had identified discrepancies in some of the seismic stress analysis reports performed by Fisher for Fisher supplied valve assemblies.
Consequently, Fisher contacted the NRC staff to inform them that, although it had determined that none of the WEC analyses discrepancies exceeded the allowable stresses, it was currently in the process of reviewing all other customers stress analyses that may have been affected.
The seismic stress analysis in these reports was originally performed by Fisher using its proprietary SEISMIC 4 finite element computer program which was implemented in 1979.
WEL stated that it had discovered an apparent discrepancy in several of fisher's seismic reports that could lead to an incorrect body-to-bonnet bolt result from the stress calculation.
The applicable seismic stress reports were transmitted to WEC in June 1982 for WEC Purchase Order (PO) 546-CCF-178370-XN.
The reports addressed air-operated valve assemblies and the analyses were performed using Fisher's Engineering Standard (ES) 117.
The reports covered 15 valves and involved nine different specification sheets.
The discrepancy involved the specification of the bolt circle plane for the input to Fisher's SEISMIC 4 computer program, which performs the seismic analysis to ES 117.
The specific item questioned was whether the sign used f or the Z direction referenced to the bolt circle plane should be negative (-)
or positive (4).
The Fisher Nuclear Qualification Team reviewed the WEC letter and concluded that an innet error was made in some of the ES 117 SEISM]C4 analysis program calculations for valves included in the WEC order.
Therefore, fisher commenced an engineering staff review.
The ES 117 analysis calculations for these valves were all run the same day in June 1982, by the same person, and were all included on the same certification sheet, dated June 9. 1982.
No determination could be made as to why the incorrect sign was used for the bolt direction vector for the above valve assemblies.
It is probable that the input error was made in the first SEISMIC 4 analysis model used for this group of valves and then replicated for succeeding SEISMIC 4 analyses of similar constructions.
It is noted that the correct input sign was used for the SEISMIC 4 analyses of other valve assemblies, done by the same person at about the same time in June 1982.
lhe data input files for all SEISMIC 4 analyses done for sliding stem valves supplied to WEC were reviewed and only one other instance of an incorrect bolting direction vector was found.
This case affected four valves with a certification dated 14 May 1985 for Carolina Power & Light, Shearon Harris Unit 1. for WEC P0 546-CCJ-178260-BN/CN. This analysis was done by a dif ferent person.
The input files for the affected WEC analyses were corrected and the STlSMIC4 analysis program was rerun.
The recalculated bolt stresses were higher, but in no case did the new results exceed the original i
P allowable stress limits.
Thus, the bolting used for these valves is still adequate.
The same SEISMIC 4 input error may be present in the bolting analysis for non-Westinghouse orders and the potential exists that some of the corrected bolt stresses could exceed allowable limits.
The team reviewed a fisher letter, dated February 24, 1993, and noted that it forwarded the revised Fisher seismic analyses and seismic certifications to WEC.
The letter also indicated that Fisher has made improvements in the program checking process to prevent such problems in the future.
The fisher review activity indicated that its investigation of all SEISMIC 4 analyses for U.S. customers had been completed and no cases were found in which recalculated stresses exceeded the allowable limits. A total of 1,101 SEISMIC 4 analyses were reviewed and 295 (27%) were identified as suspicious.
The check was performed by Fisher using a computer program to scan all SEISMl(4 analysis input files.
The scan was developed to specifically search for a variety of errors related to the beam-cut vector di ection problem. The 295 suspicious analyses were evaluated in which 17 were resubmitted to WEC; 204 did not contain any errors or contained minor errors that did not decrease the margin; 15 indicated that the margin was decreased to some degree, but the allowable stress was not exceeded (non-WEC P0s); and 59 were for non-domestic power plants.
For the 15 (non-WEC) analyses with errors that decreased the margin, 2 were for South Carolina Electric & Gas (V.C. Summer) and 13 were for the Bechtel Power Corporation (SNUPPS).
Initial NRC team discussions with Fisher indicated that its conclusion was that it was unnecessary 1o advise customers in those cases in wt ich the margin decreased without exceeding the allowable.
The NRC inspectors postulated that some occasions could develop in which those customers decide tr rely on this margin to justify a modification or i eplacement (e.g., future replacement of bolts with lower strength materials).
Therefore, the team stated that it may be prudent to advise these customers that their seismic analysis for the particular valves contain errors which reduce the available margin between the actual bolt stress and the allowable bolt stress.
The team noted that Fisher's methodology was in compliance with the regulations.
As a result of discussions with the NRC team, Fisher committed to advise Bechtel and South Carolina Electric & Gas about those cases in which the seismic analysis bolt stress margin decreased.
Subsequent NRC staff discussions in August 1993 with Fisher indicated that the V.C. Summer analysis may not have a concern.
The team also reviewed and compared the version of the SE]SMIC4 User's Manual that was in effect at the time of the WEC PO valve analysis with the current version of the manual.
The team noted that page 26 in the October 17, 1980.
version of the SEISM]C4 User's Manual provided instructions for creating the input file for a bolted joint circle configuration (card No. 11).
Columns 11 and 12 of this version were used to define the direction of the bolt axis (i.e., Vector V1) relative to the global coordinate system for variable 1 Bli P( 2 ).
Page 35 of the current SEISMIC 4 User's Manual provided the same information for columns 11 and 12 for card No. 11 as the original version.
except that a note had been added that stated:
" Direction of vector VI should be toward the element containing the associated beam cut letter.
VI should be parallel to the bolt axis."
However, the team did not find any revision number. ef fective date or approval authority on the document which would indicate approval of this modification.
Discussions with fisher indicated
.that the note was apparently added to the earlier version of the SEISMIC 4 User's Manual to eliminate some confusion that existed about assigning the proper sign to the vectors for the bolt stress analysis.
However, the team noted that the current SElSMIC4 User's Manual is no longer maintained using formal revision control as was the case for the earlier version of the manual.
The team considered that lack of formal document control for the SEISMIC 4 User's Manual to be inconsistent with the requirements of Appendix B (see l
Nonconformance 93-01-04 and Section 3.4 above).
The team also found during the inspection of this activity that fisher had recently developed a computer check program for the seismic analyses calculations.
This checker program will examine SEISMIC 4 input files for a variety of potential errors related to the bolt coordinate vector (VI) direction.
The program examines the correct designation of the variable i
IBTYP(2).
The program checks for seven potential error conditions and Fisher indicated that the check program worked so well that they have decided to incorporate the check program into the SEISMIC 4 analysis computer code so that future analyses will automatically be scanned for the type of errors found and identified to Fisher by WEC.
The team concluded that Fisher's corrective action on this identified deviation was satisfactorily dispositioned and no concerns were identified other than those discussed above.
t 3.6 But t erfly Valve T-Rino Concern i
The team identified that the Millstone Nuclear Power Plant Unit 3 identified to the NRL in LER 91-004 that a fisher valve internal T-Ring was damaged because of excessive tightening of the T-Ring adjusting set screws during valve seat adjustment. The licensee indicated that the procedure used was consistent with the fisher recommendations. The team brought this issue to fisher's attention during the inspection to discuss potential generic implications.
The team discussed the adequacy of the procedure and the expected life of the elastome material.
i The team discussed the type of information that should be in the instruction manual when compared with the information contained in fisher's qualification test report s, such as 1-Ring elastomer usable life.
When fisher takes a commercial valve and qualifies it for Class IE use they provide a qualification test report to the licensee.
It was found that fisher typically sends the instruction manual that applies to the valve with the qualification report ; however, it was found that no mention of the elastomer's usable life is stated in the instruction manual.
Instead, the qualified life is stated in the qualification report where fisher recommends replacing the T-Ring every four years.
This information is not in the maintenance instruction manual for the 1-Ring.
The team was concerned that the 4-year usable life of the elastomer may not have been addressed in some licensees' maintenance procedures because many maintenance procedures are based on vendors' specification sheets and vendor instruction or maintenance manuals,,not on qualification test reports.
This practice could cause a problem because iIsher's instruction manual, as a stand alone document, does not provide the.
T 9
information ner;;;:ry for fully understanding the operation of the valve in a nuclear env..onment.
The team noted that Fisher's initial position was that its responsibility ends with documenting its test and engineering results and that since the usable life was in the qualification report no further action was necessary.
Prior to the exit meeting, Fisher staff informed the team that it was considering a new Fisher internal program that would keep all nuclear customers apprised of design and component enhancements for increased reliability and operability.
Subsequently, on August 13, 1993, Fisher informed the NRC staff that it had developed the " Fisher Information Notice" (FIN) to be used to keep its customers apprised of technical information related to operability and reliability of its products, such as the usable life of the T-Ring.
4.0 PERSONN[L CONTACTED Paul Abens 3
Applications Engineering Plant Manager, Marshalltown Craig Anderson i
Ken Carder 2
Manager, Quality Assurance Charles Colwell 2
Manager, Nuclear /LSC Team John Dresser 2
Senior Engineer Specialist Ron Duimstra 2
Manager, Quality Control Richard Eberhart Engineering Specialist Larry Fleetwood 3
Account Manager, Intl. Pwr.
Paul Gassman 3
FCI Staff Gary L. Hauser 3
Director, Manufacturing FCS Gary Icenogle 3
Manager, Rotary Eng. Operations M. Kenneth Johnson 2
Senior Engineering Specialist floyd D. Jury 2
Manager, Engineering Projects Larry Metz 2
QA Documentation Analyst Julie A. Moran 3
Business Director, FCS Pwr. Ind.
Phil Stafford 3
Manager, Finance & Info. Systems David Stanze 2
Engineering Specialist E. Roger Stevens 1
FCI Staff David A. Suk 3
FCI Staff Attended the entrance meeting on July 12, 1993 1
2 Attended the entrance and exit meetings 3
Attended the exit meeting on July 16, 1993