ML20058C665
| ML20058C665 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1990 |
| From: | Brach E, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19324J230 | List: |
| References | |
| REF-QA-99901173 99901173-90-01, 99901173-90-1, NUDOCS 9011020162 | |
| Download: ML20058C665 (8) | |
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ORGANIZATION: SACM DIESEL MULHOUSE, FRANCE e
REPORT INSPECTION INSPECTION N0.:99901173/90-01 DATE: July 30-31, 1990 ON-SITE HOURS: 32 CORRESPONDENCE ADDRESS: Mr. L. Defline, General Manager SACM Diesel 1 rue de la Fonderie 68054 Mulhouse France i
p ORGANIZATIONAL CONTACT: Mr. F. W. Donnelly, Jr., Vice President l
U. S. Representative, Houston, Texas)
TELEPHONE NUMBER:
713) 526-6797 i
NUCLEAR INDUSTRY AC'IVITY: Manufactures diesel emergency generating sets ASSIGNED INSPECTOR:-
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Uldis Potapovs Chief,1 Reactive Inspection Date Section1,ienerInspectionBranch(VIB)
OTHERINSPECTOR(S):
E. W. Brach, Chief,VIB APPROVED BY:
t/
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O9O E. W. Rfach, Chief, VIB ate INSPECTION BASES.AND SCOPE:
A.
BASES:
SCOPE: Review of activities related to the manufacture of diesel emergency Mnerators for Northern States Power Company's Prairie Island Nuclear, Generating Plant.
PLANT SITE APPLICABILITY: PrairieIsland, Units 1and2(50-282/50-306) 90y 02 o/62X/V y-
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x ORGAN 1'ZATION: SACM DIESEL MULHOUSE, FFMCE c-I REPORT INSPECTION NO.: 99901173/90-01 RESULTS:
PAGE 2 of B l
A.
VIOLATIONS:
l None-6 B.
NONCONFORMANCES:
Contrary to the requirements of Criteria V of 10 CFR 50, Appendix B and SACH Procedure QP-162, SACM failed to issue audit reports and to request vendor responses within the specified time intervals (90-01-01)
C.
UNRESOLVED ITEMS:
None D.
Status of Previous Inspection Findings l
1.
(Closed)Nonconformance 89-01-01 Contrary to the requirements of Criterion VII of 10 CFR 50, Appendix B, SACM issued purchase orders to two vendors for safety-related equipment without assuring that these vendors were capable of manufacturing the equipment in conformance with the procurement occurents. Specifically, Societe Campair Luchard and CIAT were contracted to supply components in compliance with the American Society of Mechanical Engineers (ASME) Code when neither company was accredited by ASME. Additionally, CIAT did not have an SACM-approved QA manual and was not a qualified vendor.
As a part of the corrective action Societe Compair Luchard was k
- qualified by:SACM with a condition that they receive =their ASME
.Section VIII accreditation prior to manufacturing any components.
During the inspection, the inspectors verified that the company was surveyed by ASME and received ASME "U stamp" accreditation on January 24, 1990.
SACM received CIAT's QA Manual and conducted a QA audit at that company on November 8-9, 1989.
Based on this audit and subsequent source surveillance activities, CIAT was found acceptable and placed on the SACM's qualified vendor list.'(See Section E.2) The purchase L
specification to CIAT was modified to delete ASME Code requirements and specified instead that the equipment involved (lube oil heat exchanger) be manufactured according to Manufacturer's Standards for on-engine equipment.
Based on these actions Nonconformance 89-01-01 is considered closed.
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ORGANIZATION: SACM DIESEL o
MULHOUSE, FRANCE REPORT INSPECTION NO.: 99901173/90-01 RESULTS:
PAGE 3 of 8 2.
(Closed) Nonconformance 89-01-02 Contrary to criterion 111 of 10 CFR 50, Appendix B, the Quality Plan for lube oil heat exchangers did not clearly specify L
that welding was to conform with Section IX of the ASME Code as required by the technical specifications for this equipment.
L Corrective actions included revision of Technical Specification i.
DLT 15.04.1275 to remove the requirements that welding conform to ASME Code and modification of Quality Plan 620.0/01 to l
reference AQUAP as the applicable welding standard. These actions are consistent with corrective actions to Nonconformance p
89-01-01 discussed above.
Based on these actions, Nonconformance 89-01-02 is considered closed.
i 3.
(Closed)Nonconformance 89-01-03 Contrary to criterion VII of 10 CFR 50, Appendix B, SACM accepted solenoid valves from Eugen Seitz AG based on the vendor's certification of satisfactory functional and leak test results without assessing the vendor's control of these activities.
As a part of the corrective actions, SACM performed a quality program implementation audit at Eugen Seitz AG on December 8, 1989. During this audit, SACM staff witnessed the testing of similar solenoid valves and found Seitz testing
_ procedures / performance acceptable.
Seitz providd SACM with a Certificate of Conformance certifying that the valves previously supplied for the NSP order have successfully
. passed testing according to the same Seitz procedures as witnessed by SACM.
Additionally SACM has implemented a comprehensive audit program of all suppliers whose products have been previously accepted based on satisfactory performance history.
Based on these actions Nonconformance 89-01-03 is considered closed.
4.
(Closed)Nonconformance 89-01-04 Contrary to Criterion V of 10 CFR 50, Appendix B, guidance was not available to identify the specific characteristics and sample size to be verified during receiving inspection of piston pins.
ORGANIZATION: SACM DIESEL MULHOUSE, FRANCE REPORT INSPECTION NO.: 99901173/90-01 RESULTS:
PAGE 4 of 8 As a part of SACM's corrective action, Technical Specification DLTD 14.9.1, Revision A was issued on November 6, 1989 clarifying the technical and quality assurance requirements for the piston pins.
The necessary inspections for these items were procedurally defined in Procedure QP-045, Reception Control for Purchased Products, dated February 14, 1990, with specific acceptance criteria prescribed
.in QCR 202.2/100 (Piston Pins), dated January 19, 1990.. The sample size.is described in Tables QC 1263 through 1268 which are referenced in QP-045 and are based on Military Standard 105D.
Additionally, specific receiving inspection procedures and acceptance criteria have been established for 39 different items.
Based on these actions,.lonconformance 89-01-04 is considered closed..
E.
Inspection findings and other enmments 1.
J_nspection scope The inspection scope included a review of SACM's actions to correct nonconformances which were identified during the last NRC' inspection (October 1989) and continued examination of SACM's'QA program implementation effectiveness in selected areas.
l A brief presentation describing SACM's history, organization-l and activities as they related to the nuclear industry as.well as
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a tour of the manufacturing facilities were also included in the inspection scope. SACM's corrective actions were verified l
L through record review, observation of ongoing activities and interviews with appropriate personnel and determined to be responsive to the identified nonconformances as noted in Section D of this report.
l.
Additional reviews were focused on SACM's control of purchased material including programs for establishing and maintaining a list of approved vendors, vendor audits and identifying and dispositioning nonconforming conditions.
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a ORGANIZATION:
SACM DIESEL MULHOUSE, FRANCE REPORT INSPECTION 1
NO.: 99901173/90-01 RESULTS:
PAGE 5 of 8 2.
Audits The SACM QA program is described in the Quality Assurance Manual, QA-067GB, dated May 17, 1990. Set. tion 2 of this document describes the program for audit, review and approval of vendors and placement of vendors on the Approved Vendor List (AVL). Procedure QP-162 (January 1989) describes the program for conducting vendor audits.
The inspectors selected eight vendors from the AVL for review of SACM's audit reports, findings and the disposition of findings.
Review of the audit reports and associated working papers indicated that the scope and depth of the SACM audits were C
appropriate. For at least one vendor, CIAT, there was extensive interaction between SACM and CIAT after the audit to discuss findings, corrective actions and additional SACM source surveillances.
QP-162 states in Section 4.3 that SACM will issue audit reports within 30 days of the completion of audits. Further, Section 4.4.1 states that the vendor will be requested to respond to the audit findings within 30 days of the receipt of the audit report.
The following table summarizes the disposition of reports / findings from the eight vendor audits selected for review during this inspection.
Audit Date of Report Date Response Vendor Completed Report to Vendor Requested 1.
CIAT 11/09/89 04/06/90 07/27/90 11/90 2.
Mahle 01/31/90 05 30/90 06/26/90 12/90 3.
ABB 11/22/89 4.
X0 MAX 07/05/90 5.
Seitz 12/08/89 6.
Poppe &
Potthoff 11/28/89 (1) 7.
Schneider 02/22/90 04/20/90 04/20/90 30 days 8.
Westinghouse 02/16/90 03/09/90 03/09/90 30 days (1). Report not completed.
(2). Audit less than 30 days old at time of HRC inspecton.
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ORGANIZATION: SACM DIESEL MULHOUSE, FRANCE REPORT INSPECTION NO.: 99901173/90-01 RESULTS:
PAGE 6 of 8 The above table shows that audit reports are yet to be written for ABB, Seitz, and Poppe and Pottoff and that these audits were conducted 7-8 months prior to the NRC inspection.
It was noted during the inspection that as a result of an NRC finding on a previous inspection (see Items D.1 and D.3), SACM had initiated a significant effort in late 1989 to audit all safety-related vendors in a short time period.
The above table is only a sample i
of audits conducted by SACM as a result of this action; however, the lateness in completing the reports exceeds general reasonableness for timely completion of audit reports and exceeds the specific instructions in SACM implementing Procedure QP-162 for issuing reports.
Further the audit reports forwarded to CIAT and Mahle requested the vendors to respond to the audit findings 4-6 months after issuance of the report. This also is not consistent with SACM Procedure QP-162 which states that the vendor's response will be requested within 30 days. SACM's failure to follow the procedures contained in QP-162, for conducting audits, has.been identified as a nonconformance with theirqualityprogram(Nonconformance 90-01-01).
3.
Approved Vendors List The NRC inspectors also reviewed the SACM program for placing vendors on the AVL.
Procedure QP-046 describes this process and states that placement of a vendor on the AVL requires both a review by SACM of the vendor's quality program and a technical evaluation and prototype testing of the vendor's product. The inspectors noted that although the procedure was not detailed in describing the prototype testing and technical evaluation of the vendor's product performed by SACM, the process implemented by SACM to qualify the vendor through the. prototype testing and evaluation appeared adequate. The inspectors also noted that the November 1989 audit of CIAT identified 13 audit findings. This audit resulted in extensive interactions between SACM and CIAT and source surveillance inspections by SACM at CIAT in January 1990.
It appears that although CIAT remained on the SACM AVL, SACM took appropriate action to establish the acceptability of CIAT products.
It was also noted that on May 5,1990, the SACM QA manual was revised to reference the guidelines of EPRI-NP-5652 for the procurement and dedication of items from vendors which do not comply with the requirements of 10 CFR 50 Appendix B or 10 CFR 21.
r ORGAN'IZATION: SACM DIESEL MULHOUSE, FRANCE REPORT INSPECTION NO.: 99901173/90-01 RESULTS:
PAGE 7 of 8 4.
N_onconformances Corrective Actions Nonconforming materials, parts or components and corrective and preventative actions are addressed in Sections 3.1.8 and 3.1.9 of SACM's QA manual (QA067GB).
A nonconformance is defined as a deviation from contractually specified requirements.
All nonconformances are required to be documented in a Defect Report.
All Defect Reports are transmitted to the QA Department for performance trend analysis.
For nonconformances where the
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solutionisobvious(correction, rejection),theDefectReportis prepared and the disposition decision is made directly in the
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shop.
In more complex cases, the disposition is made by the L
Quality Commission which includes representatives from the Quality Control Department, Design Department and specialists, if required. The Quality Control Department representative is l
responsible for assuring that all phases of the corrective actions are carried out and the selected solutions are properly applied.
Forty-nine nonconformances had been identified on the NSP contract.
The inspectors reviewed the Defect Reports and related records and interviewed appropriate personnel to assess the adequacy of program implementation in this area.
A significant nonconforming material report written on this project involved extensive weld repair to the cast iron-cylinder block to eliminate surface pits. The repair procedure was l
comprehensive and specified appropriate procedures for the critical operations including welding and heat treating. The L
inspectors requested and were shown procedure and perfonnance qualification records for welding in accordance with the o
ll specifiedprocedure(WPS301). The records were complete and s
l-accurate and showed that a welder identified Mth symbol S9 had been qualified to weld in accordance with this procedure. The inspectors observed that the repair records did r.9t show that l
this particular welder had actually performed the veld repair; however, SACM stated that this welder is the only pt.rson used at L
SACM for performing this type of welding procedure.
The disposition ai ? close-out documentation of other non-conformances review n during this inspection were generally complete and appropriat and in accordance with the applicable program requirements.
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ORGANIZATION:
SACM DIESEL MULHOUSE, FRANCE REPORT INSPECTION NO.: 99901173/90-01 RESULTS:
PAGE 8 of 8 5.
PERSONS CONTACTED F. Donnelly, Vice President SACM (Houston)
Bernard DeCrouy Chat el, Vice President, Power Generation, SACM P. Erhart, Deputy Vice President, Nuclear and Special Projects Jean-Claude Stutter, Representative Diesel Power Plants, SACM J. Germain, Manager, Quality and Survey Dept. SACM D. Dietrich, Manager Quality Assurance, SACM J. Perrin, Manager, Quality Control, SACM H. Birner, Project Manager, SACM T Sitek, Power Supply Quality Assurance, NSP R. Arthurs, Quality Assurance, Fluor Daniel J. Mackley, Project Manager, Fluor Daniel l
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