ML20058M219
| ML20058M219 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1993 |
| From: | Alexander S, Cwalina G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058M199 | List: |
| References | |
| REF-QA-99900912 NUDOCS 9312200201 | |
| Download: ML20058M219 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR INSPECTION AND LICENSEE PERFORMANCE-VENDOR INSPECTION BRANCH l
ORGANIZATION:
National Technical Systems, ' Incorporated DOCKET / REPORT NO.:
99900912/93-01 CORRESPONDENCE 533 Main Street-1 ADDRESS:
Acton, Massachusetts ORGANIZATIONAL Ms. Christine Briggs, Director of Quality'.
t CONTACT:
(508) 263-2933 NUCLEAR INDUSTRY Provides commercial grade dedication and equipment ACTIVITY:
qualification services and dedicated equipment for the i
commercial nuclear power industry INSPECTION CONDUCTED:
July 6-9, 1993 l
// RA f8 TEAM LEADER:
A w
S.D. Alexander', Team L'eader Datte Reactive Inspection Section 2 (RIS-2) i Vendor Inspection Branch (VIB)
OTHER INSPECTORS:
K.R. Naidu, RIS-2: VIB-A.M. D mmer, Plant Sys ems Branch APPROVAL:
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Gregor/C,4walina, Chief Date RIS-2, VI9', Division of Reactor Inspection and Licensee Performance INSPECTION BASES:
10 CFR Part 21'and to Appendix B 10 CFR Part 50
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INSPECTION SCOPE:
To evaluate activities related to commercial-dedication in general and specifically the commercial l
dedication of electrical switchgear manufactured _by Klockner-Moeller, Germany, and equipment qualification tests.
PLANT SITE Surry 1/2, (50-280, 50-281); LaSalle 1/2 (50-373, APPLICABILITY:
50-374); Prairie Island 1/2 (50-282, 50-306) l
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9312200201 931202 PDR GA999 EECNATTS
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99900912 ppR
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INSP[CTION
SUMMARY
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1.1 Violation Contrary to the requirements of 10 CFR 21.21(a), National Technical Systems, i
Incorporated (NTS) procedures, adopted pursuant to the regulation, (1) l required employees to report defects not within their ability to evaluate, (2) 4 1
did not require reporting'of deviations from technical procurement specifications (3) lacked certain provisions required by the July 1991 7
revision of the regulation. Contrary to Title 10 of the Code of Federal Reaulations, Part 21 (10 CFR Part 21), Section 21.6(b), the posted notice l
prescribed by the procedures lacked certain required information.
(93-01-01) 1.2 Nonconformance l
Contrary 1o the requirements of Criteria III, V and VII of Appendix B to 10 CFR Part 50, NTS-prepared procedures for dedication testing of K16ckner-r Moeller (K-M) molded-case circuit breakers for the~ North Anna Power Station did not properly incorporate design requirements because they did not specify i
a minimum duration for the full-load hold-in test, and there was evidence that the test was conducted for an inappropriately short time. (93-01-02) i 1.3 Unresolved Item Out-of-tolerance tripping of certain K-M overload relays was attributed to.
age.
The inspectors were not able to determine during this inspection the i
basis for the K-M revised trip time tolerances, nor what other installations might be af fected by relays with similar age / shelf-life-shifted performance i
characteristics. See Paragraph 3.5 of this report.
(93-01-03) i 1.4.
Open items 1.4.1 N15's and/or K-M's evaluation of performance anomalies of Z4-100/K-NA i
overload relays identified by NTS during testing and identification of any l
installations in harsh-environment, Class IE applications.
See Paragraph 3.8 l
of this report.
(93-01-04) i i
1.4.2 NTS's, Continental's and/or Spectrum Technology's evaluation of failures of Continental silicone rubber electrical cable during NTS's qualification testing and identification of installations of this cable in i
Class IE, harsh-environment applications.
See Paragraph 3.9 of this report (93-01-05) 1.4.3 NTS's and/or Static 0-Rings's (SOR's) evaluation of test failures at i
NTS of an 50R pressure switch and a temperature switch and identifiaction of i
installations of these types of switches in Class IE, harsh-environment i
applications. See Paragraph 3.10 of this report.
(93-01-06) t 2
STATUS OF PREVIOUS INSPECTION FINDINGS There were no outstanding items from any previous inspections.
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3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Entrance and Exit Meetinos On July 6,1993, during the entrance meeting, the Nuclear Regulatory Commission (NRC) inspectors discussed the scope of the inspection and the areas to be reviewed with the Director of Quality. On July 9, 1993, during j
the exit meeting, the inspectors discussed their conclusions with NTS staff i
identified in Section 4 of this report.
3.2 10 CFR Part 21 Review f
3.2.1 Review of Procedures j
The inspectors reviewed the effective revisions of NTS procedures (Section V i
l of the NIS Quality Assurance Manual and Quality Assurance Procedure QAP-1),
i adopted pursuant to 10 CFR 21.21 and found that they would not, as written, ensure proper evaluation of deviations and reporting of defects or substantial safety hazard-related failures to comply.
The procedures' required employees to report " defects that could create a substantial safety hazard in a. nuclear i
power plant," a determination employees could not be expected to make; yet, the procedures did not specifically require reporting deviations from technical procurement specifications and had not been updated to include -
t certain provisions required by the version of 10 CFR Part 21 that became effective October 29, 1991, which had instituted substantial changes in l
evaluation and reporting requirements.
In addition, the NTS posted notice, pursuant to 10 CFR 21.6 prescribed by QAM Section V, did not state where the l
procedures (specifically QAP-1) could be viewed, nor did it give the name (or i
l title) of the person to whom reports should be made. This is designated Violation 93-01-01.
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i Although a provision for informing affected licensees or purchasers of deviations in basic components supplied to them (when the vendor determines it cannot perform the requisite evaluation) was not explicitly included in NTS procedures, such a provision is no longer specifically required by the current version of Part 21 to be included in procedures adopted to implement the l
I regulation.
In addition, no instances were identified in which NTS did not properly disposition deviations of which they were aware.
Nevertheless, NTS i
stated that they would consider the prudence of including such a provision, particularly since the determination that NTS cannot evaluate the deviation i
for the creation of a substantial safety hazard is most often the case.
The inspectors also noted that there were some inconsistencies between the two procedures relating to Part 21 in the chain of reporting and handling of reports of problems from employees.
NTS stated that they intended to review this situation and consider consolidating the two procedures to avoid further confusion. Subsequent to the inspection, the inspector reviewed a draft revision to QAP-1 and, in conjunction with NTS's answers to certain questions about it by telephone, found that it addressed the principal concerns.
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3.2.2 Review of 10 CFR Part 21 Records The inspectors reviewed selected NTS records pertaining to nonconformances, or other documented problems, and determined that they were handled as deviations j
when appropriate and the affected licensees or purchasers were notified in j
accordance with the regulations and NTS procedures. Associated NTS records l
appeared to be in compliance with the regulation in terms of completeness and retention.
3.3 Review of Electrical Switchaear Dedication Virginia Electric Power Company (VEPCo) prepared and issued Specification SUP-0014, Revision 1 and Addenda 1, 2, and 3, dated August 6,1991, and February 7 and June 12, 1992, respectively, for motor control centers (MCCs) intended for its Surry nuclear power plant.
In response to this bid, K-M (USA, Inc.) submitted a quotation, which VEPCo evaluated and determined acceptable. VEPCo issued purchase order (PO) BNT-380110, dated March 19, 1992, to K-M for the supply of the MCCs.
l The MCCs contained various quantities of 480-Vac, National Electrical Manufacturer's Association (NEMA) sizes 1 and 2, full-voltage, reversing starters, full-voltage non-reversing starters, and molded-case circuit breakers (MCCBs). NTS was contracted by K-M to perform (or be responsible for i
the performance of) the dedication and qualification of the MCCBs.
Accordingly, NTS purchased an additional representative MCC and used it as a seismic test specimen. VEPCo required the switchgear to be qualified to meet i
the following standards of the Institute of Electrical and Electronic Engineers (IEEE):
IEEE-323-1983, " Qualifying Class IE Equipment for Nuclear Power Generating Stations" IEEE 344-1975, " Recommended Practice for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Statior.s" IEEE 383-1974, " Standard for Type Test of Class IE Electrical Cables, Field Splices and Connections for Nuclear Generating Stations."
VEPCo Specification SUP-0014 specified:
1 Electrical components should be new and should not be purchased from vendors listed in NRC Information Notice 88-46.
Environmental conditions, such as ambient temperature, pressure, and radiation in the turbine building and the emergency switchgear room, where the MCCs were to be installed.
The envelope for the operating-basis earthquake (OBE) and the safe-a shutdown earthquake (SSE) and required the MCCs to be qualified for the seismic environment by testing only.
F Quality assurance and reporting requirements to meet 10 CFR Part 50,
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Appendix B, and 10 CFR Part 21, respectively.
K-M issued P0 107466 of May 8, 1992, to NTS to prepare a test plan to dedicate the switchgear and to perform the seismic tests required to qualify the switchgear to IEEE 344-1975.
In the P0, K-M stipulated the following:
All material / services are to be in accordance with NTS QAM Revision 2 and should be included in a certificate of conformance (CoC).
Meet portions of 10 CFR Part 50, Appendix B, and 10 CFR Part 21, where applicable.
At the end of the qualification, NTS was to provide a CoC certifying that the switchgear was qualified to IEEE-323-1983 and IEEE 344-1975.
NTS prepared Test Procedure 60041-93N, " Test Procedure for the Qualification Testing of Series 200 Motor Control Centers," to dedicate and seismically qualify commercial grade MCCs for use in safety-related applications at VEPCo's North Anna Power Station (NAPS).
The test plan specified the sequence of the activities and the party (K-M or NTS) responsible for performing them.
It established the following critical characteristics w'th acceptance criteria to provide assurance that the items received were the items specified, that the items would perform their intended function, and that the supplied items were equivalent to the sacrificial test items.
manufacturer's markings (K-M) weight visual configuration dielectric withstand voltage operability fuse test (NTS) breaker 300-percent time test
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breaker instantaneous trip contact resistance contactor pick-up and drop-out voltage overload 300-percent rated current time test The records indicated that seismic testing was conducted in accordance with the guidelines provided in IEEE 344-1975 and enveloped the parameters provided in VEPCo's Specification SUP-0014. NTS established the qualification testing levels using composite (horizontal and vertical) peak accelerations derived by constructing a single OBE-level and a single SSE-level required response spectrum, within the limitations of the seismic simulator.
NTS performed the mild environment analysis of VEPCo's turbine building and emergency switchgear room environmental conditions in accordance with IEEE 323-1983.
K-M performed receipt inspection and acceptance and baseline functional testing except for contact resistance, fuse and circuit breaker testing below 125 amperes (A).
NTS, mostly through its subcontractor, AC Electric Company (ACE), performed these and all the remaining tests.
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However, the requirements to test circuit breakers specified in item 1 of
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section 7.7 of TP 60041-93N and the associated acceptance criteria were not completely adequate to demonstrate operability under all design basis conditions as required by the P0.
For safety-related load breakers, operability is generally recognized to include the safety function of providing and maintaining (absent overload, fault, or other required trip conditions) reliable power for starting and running of the load.
Item 1 of i
this section of the test plan translated this requirement as "Each breaker shall be cycled from off-on-off, into a test load equal to the AC current rating of the breaker." The acceptance criterion for this requirement was:
"Each breaker shall be capable of making and breaking its rated current without damage to the item occurring. The breaker shall not' trip." However, this test requirement did not provide assurance that the breaker would remain i
closed for the required operating time of any loads for which it was to be used. The acceptance criterion for this function recommended by National Clectrical Manufacturers Association (NEMA) Standard Publication AB 4-1991 governing field verification of MCC breakers, wh.ich is the most recognized industry standard, is that, absent trippable conditions, the MCCB, in an i
enclosure in 25 *C ambient temperature, should carry 100-percent rated current for at least 1 or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, depending on rating.
i lhere was no requirement specifically stated in the NTS test plan for the MCCBs to be subjected to full-load hold-in tests for an appropriate. amount of time.
Since this is a relatively routine test, the NRC inspectors made inquiries to determine whether the test was conducted for an appropriate time despite the lack of a specific requirement to do so.
However, according to the test facility (AC Electric), the test was apparently conducted for no more than a few minutes. Hence the critical characteristic of full-load hold-in capability was not verified. This constituted a nonconformance with respect to 10 CFR Part 50, Appendix B, because (1) the procedure prescribing an activity affecting quality was not appropriate to the circumstances as required by Criterion V, (2) a design basis requirement was not properly translated into design c.^put documents (instructions, procedures, and drawings) as required by Criterion III, and (3) contrary to Criterion VII, the i
purchaser did not ensure that all requirements of the procurement documents (i.e., this design specification) were met. This is designated Nonconformance 93-01-02.
In response to this finding, NTS reviewed the circumstances and made a prompt evaluation of the safety significance of this issue, which constituted a deviation from technical procurement specifications.
NTS's evaluation was as f ollows: ACE performed testing for NTS on these 200, 250, and 350-A MCCBs.
These larger MCCBs were used as the main breakers in the MCCs that K-M supplied to VEPCo with NTS's dedication.
In all cases, the main breakers were oversized to supply current to individual MCC starter cubicles.
For example, a 200-A main breaker was the protection for three breakers, specifically two 50-A breakers and one 33-A breaker. Therefore, the maximum total ~ current draw these breakers could be expected to have at 100-percent rated load would be 133 A.
However, the two 50-A breakers were for a 20-HP motor and a 25-HP motor, and the single 33-A breaker was for a 10-HP motor. The total expected load for this system would be 75 A.
This 75-A load is only 38-percent of full,
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4 load on the 200-A main breaker. Other MCCs were analyzed similarly.
In no case were the expected combined loads above 38-percent of the main breaker rated current.
Although, on the basis of this information, NTS acknowledged that the-MCCBs' hold-in capability had not been demonstrated in the generally accepted manner, NTS concluded that there were no immediate safety concerns (i.e., the deviation would not at present create a substantial safety hazard).
- However, in view of the possibility of the licensee adding future loads, NTS committed to inform the licensee of the deviation and to correct its procedures for future work. No other projects were found to be affected.
3.4 Observation of Activities in Proaress 3.4.1 Receipt Inspection The inspectors observed receipt inspection being conducted on a KLF-type, 120-V, 60-Hz, 5-A, Style 290E481A09 relay supplied by ASEA Brown Boveri in i
response to NTS P0 34307A. Jeamont Schneider Industries of France had issued j
PO YAll3189 to NTS for the supply of the above as a safety grade relay. The NTS inspector placed the package in the receipt inspection staging area, i
opened the shipping carton, and removed the relay from it.
The NTS inspector then verified that the name plate details were the same as the one in the P0 and that the relay did not sustain visible shipping damage and documented his findings in the designated receipt inspection report. The NTS inspector prepared a hold tag to indicate that other tests had to be conducted on these j
components and transferred the relay to the room where other components are stored to await further tests or inspections.
l 3.4.2 Dedication Activities The inspectors observed an NTS technician perform tests on terminal blocks (tbs) manufactured by General Electric for CEGELEC Automation Company (formerly known as Comsip, Incorporated).
NTS specified the tests for dedicating the tbs in Procedure 28637-92-N-7, " Receipt Inspection and Baseline Functional Dedication Test Procedure For General Electric Terminal Block."
3.4.3 Storage Room The inspectors observed that access to the storage area was limited to authorized individuals. Nonconformance tags had been affixed to components stored in a separate rack that had not met acceptance criteria specified in l
the, relevant test plan.
Components on which inspections had not been l
completed were identified with hold tags.
Commercial grade components, purchased by NTS for dedication, were separated from components supplied by customers for dedication by NTS.
3.5 Review of Nonconformance Reoorts (NCRs1 The inspectors reviewed several selected receipt testing NCRs associated with items in the segregated nonconforming item area in the storage room. The NCRs reviewed (all dated July 1, 1993) pertained to Commonwealth Edison Company i
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i (CECO) PO 346 358, dated July 31, 1992, to NTS Acton for some safety-related, 480-V, K-M contactors, and overload relays.
NCR 93-56 documented that several type ZO-0.68/K-NA overload relays
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tripped outside the specified 23-second maximum trip time with 3 times its nominal current applied. Upon consulting K-M, the manufacturer advised NTS to use +/- 20-percent tolerance. With the revised acceptance criteria, all but one tripped within limits.
NCR 93-57 documented that some type ZO-2.1/K-NA overload relays tripped I
outside the specified maximum trip time of 28 seconds with 3 times nominal current applied.
K-M advised increasing the retest specification from 28 to 40 seconds, at which point, all but two passed.
NCR 93-58 documented that several type ZO-6.6/K-NA overload relays tripped outside the specified maximum trip time of 23 seconds at 300-percent nominal current. All but one tripped in time with a K-M revised maximum trip time of 45 seconds.
j NCRs 93-61, 62-64, and 65 documented that several type Z2-16/K-NA, i
Z2-40/K-NA, 22-24/K-NA, and Z2-II/K-NA overload relays tripped late. At the time of the inspection, NTS was awaiting revised trip times.
According to the assigned NTS project manager, K-M attributed the late tripping to the units being older models that may have been in storage for an extended period of time. The NTS project manager stated that he had notified CECO of the test results and the revised values of the trip times so that the delayed trip times could be factored into the relay coordination.
The inspectors, not being aware of any particular or commonly known shelf-life (or i
mild environment in-service aging) limitations on these types of overload relays, were concerned about their use in other applications, possibly with less testing where the nominal performance specifications were being relied upon. The inspectors were not able to determine during this inspection what the basis was for the K-M revised trip time tolerances, nor what other installations might be affected by relays with age / shelf-life-shifted performance characteristics. Therefore, this issue is designated Unresolved Item 93-01-03.
j 3.6 Additional Dedication Packaoe Review Northern States Power Company (NSP) issued P0 E189950 dated December 8, 1992, to NTS for various models and quantities of 600-V rated MCCBs, non-reversing starters, and overload relays manufactured by K-M.
NTS issued P0 33918A dated i
february 10, 1993, to K-H to supply the quantities required by NSP. To justify qualification by similarity, NTS ordered additional circuit breakers to be used as test specimens to represent the breaker population that was to be shipped. NTS performed baseline functional testing on the sacrificial test specimens before and after seismic testing. The results of post-seismic functional testing were used to confirm the post-seismic operability of the test specimens. NTS used the results to verify equivalency of the items that were being supplied.
NTS was to verify the following critical ch,7cteristics of the production items as applicable using Method 1 (as it is called in.
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i Electric Power Research Institute (EPRI) Report NP-5652, special tests and inspections, or EPRI Method 2, commercial grade supplier' survey):
manufacturer's markings (Method 1) visual configuration examination (Method 1) design control (Method 2) physical dimension verification (Method 2)
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item weight (Method 1) i dielectric withstand voltage (Method 1) a 300-percent overload time test (Method 1) (thermal-mag only) l l
contact resistance (Method 1) contact pick-up and dropout voltage (Method 1) l a
contactor current test (Method 1) instantaneous trip testing (Method 1) rated current capability (Method 1) l NTS conducted the dedication in the following sequence:
f receipt inspection and acceptance testing f
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baseline functional testing t
seismic testing post seismic functional testing certificate of compliance and test report j
l The team reviewed the records pertaining to this P0 and observed a discrepancy in the documentation. A note in line item 2 of Section 7.1.3 of NTS Test Procedure 60174-93N stated: "This test [ thermal time delay overload trip] is l
l not performed on circuit breakers item 9 through 13 of Section 3.0."
- However, a single K-M NZMH6-63/ZM6-60-500-0BI-CNA-type circuit breaker equipped with I
adjustable instantaneous magnetic trip only was listed to be tested for response to thermal overload. The line item note was supposed to have stated:
"This test is not being performed on circuit breakers item 1 and items 9 through 13 of Section 3.0."
Review of the test records indicated that, appropriately, only the instantaneous trip test and not a thermal overload test was performed on this breaker. Although NTS personnel had discovered this error and documented it in a deviation report, it appears that it had not J
been corrected in the final report as a result of an oversight. NTS committed to inform the rustomer and issue a correction to the final report. This discrepancy did not materially impact activities affecting quality and, therefore, was not considered a nonconformance.
3.7 Eauipment Oualification Procedural Review NTS Standard Operating Procedures (S0Ps) SOP-El, "LOCA/HELB Testing"; SOP-E2, "LOCA System Operation"; SOP-N1, " Irradiation Exposure of Nuclear Safety-Related Test Components"; and SOP-N2, " Accelerated Thermal Aging Arrhenius Method" were reviewed. No problems were identified.
3.8 Oualification of K16ckner-Moeller Overload Relays j
i NTS Job 28702-92N was for the dedication of commercial grade K-M Z4-100/K-NA overload relays for harsh-environment, safety-related service at LaSalle -
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County Station pursuant to Commonwealth Edison PO 338098 dated April 17, 1991.
I The P0 invoked 10 CFR Part 21 and required certification to the NTS QA program. Qualification type testing was performed on six of the relays after dedication in accordance with IEEE 323-1974 and IEEE 344-1975, including 4
baseline functional testing, radiation aging, material analysis to determine l
activation energy, thermal aging, mechanical aging, seismic testing, and l
exposure to a simulated harsh environment.
In response to this order NTS issued P0 29166 to Kent Industries for 25 K-M overload relays. The NTS P0 required that relays be manufactured from the same material batch lot, having the same date code, thus ensuring material traceability. When NTS received the relays, it performed receiving inspection and baseline functional testing. The critical characteristics were verified by special tests and inspections, including part numbers, dimensions, l
insulation resistance, dielectric withstand, and trip characteristics.
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Material similarity and traceability were checked by date code.
Anomalies that occurred during testing were documented and reported to the customer.
Relay S/N 006, aged to a 10-year equivalent, tripped when the
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simulated accident profile was descending from the first peak.
The relay was reset when the temperature reached 104 *F.
The cause of the tripping was not determined. Another anomaly was that the relays did not carry the required 66 A (-1.5 A, H A) because of power line variances from the local utility.
Current and voltage were monitored every 5 minutes and adjusted to compensate i
for the variations. The test time was extended to compensate for the repair of a test chamber steam leak and also to account for NTS's difficulties in maintaining required temperature and humidity according to recalculations by the customer's architect / engineering firm, Sargent & Lundy. All anomalies were documented and were reported to the customer.
Although all other specimens eventually met all other acceptance criteria, the report did not make conclusions regarding the qualification of the relays.
No problems were identified with NTS's conduct of this test program that were not adequately resolved.
However, questions remain regarding NTS's and/or j
K-M's evaluation of the reported performance anomalies and also regarding i
possible installations of these overload relays in harsh-environment, Class lE applications.
This issue is being pursued under Open Item 93-01-04.
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3.9 Continental Cables NTS Job 28889-92N was for the qualification of Continental silicone rubber-insulated cables for safety-related service in a harsh environment. The purchase order from Spectrum Technologies invoked 10 CFR Part 21.
NTS performed baseline testing, thermal aging, and functional tests before sending the specimen cables to Isomedix for radiation aging. The cables underwent accelerated thermal aging to simulate a 40-year service life at 120 *F ambient temperature with 49 *F heat rise based on calculations by Spectrum Technologies.
Isomedix used a Cobalt-60 source to irradiate the cables with j
230 Mrads at a rate of less than 1 Mrad per hour.
Functional performance requirements of the cables were defined as continuity, insulation resistance, and dielectric withstand. They were verified after i i
thermal aging and after radiation aging. All samples were acceptable after thermal aging but failed the post-radiation functional tests.
During recoiling of the samples, the inner silicone insulation cracked.
The silicone insulation of the 2/0 AWG cable cracked and separated, exposing the conductor.
This cable was not immersed in water nor subjected to the 2200 Vac. All other cables had greater than 5-milliamp leakage current in the immersion dielectric withstand test. The accident simulation was not performed because the cables had already failed.
The results were documented and reported to the customer.
No problems were identified with NTS's conduct of this test program. However, questions remain regarding NTS's and/or Spectrum's evaluation of the failures and possible installations of this cable in Class IE, harsh-environment applications. This issue is being pursued under Open Item 93-01-05.
3.10 SOR Pressure. Vacuum, and Temperature Switches NTS Job 60162-93N was for the qualification testing of 10 different types of pressure, vacuum, and temperature switches made by SOR, Inc. (formerly
" Static-0-Ring"), for harsh environment safety-related service.
SOR performed thermal and radiation aging portions of the qualification testing.
P0 52362 was for NTS to perform seismic, high-energy line break (HELB), loss-of-coolant l
accident (LOCA), and functional testing in accordance with SOR test plan 9058-101. The PD imposed the NTS 10 CFR 50, Appendix B, quality program and 10 CFR Part 21, with notification to SOR and the NRC.
NTS performed the specified portions of a type test in accordance with IEEE 323-1974 and IEEE 344-1975.
The switches were required to function during and after the adverse environment tests.
Four pressure and two vacuum switches under went a LOCA test. They were l
periodically actuated during and after the LOCA simulation (profile similar to IEEE 323, Appendix A) and voltage, current, actuation pressure, insulation resistance, contact resistance, and switch housing internal pressure were recorded. The set points, dead bands, and repeatability were attained for the pressure and vacuum switches by cycling the switches three times from 0 psi to the increasing set point and back to O psi.
A group of two pressure switches, two vacuum switches, and six temperature switches were exposed to the HELB tests. During the first HELB test, pressure l
and vacuum switch actuation were checked at each pressure / temperature level of l
the profile.
However, the temperature switches were not tested for operability during the HELB profiles. After each HELB test, functional tests were performed on all switches. The set points, dead bands, repeatability, insulation resistance, and contact resistance of the pressure, vacuum, and temperature switches were checked. All of the post-HELB 1 functional test results were consistent with pre-test data.
During a second HELB test, switch actuation was checked at the 350 *F level and the 275 *F level. The set point, dead band, repeatability, insulation resistance, contact resistance, and dielectric withstand voltage were tested following the second HELB test.
Temperature and pressure were too low for a period of 60 minutes, but the test was extended for 60 minutes to account for 1
the temperature anomaly. All pressure and vacuum switches, with the exception 1 m
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of pressure switch S/N 92-6-7018, operated properly. The set point, dead band L
and repeatability for this switch could not be accurately recorded, apparently due to diaphragm leakage and it was returned to SOR for evaluation. All temperature switches operated properly in the functional tests with the exception of one temperature switch that indicated approximately 1-mA leakage current at 900 Vac in the dielectric withstand test, other switches having no leakage during the 1-minute test. An anomaly occurred during seismic testing that was evaluated and determined not to be a failure of the switch. All anomalies were documented and reported to the customer.
NTS provided no conclusions on the qualification status of the switches.
i No problems were identified with NTS's conduct of this test program. However, questions remain regarding NTS's or 50R's evaluation of the f ailures and regarding possible installations of the two types of failed switches in Class IE, harsh-environment applications. This issue is being pursued under Open i
l Item 93-01-06.
l 3.11 NTS-Conducted Audits and Commercial Grade. Surveys The inspectors reviewed several reports of audits including Diezotronics, Inc., and GE Computer Services which appeared satisfactory. The inspectors also reviewed reports of several commercial grade surveys conducted by NTS and identified strengths and also a weakness in two of the surveys. According to the report of the survey, conducted June 28-29, 1992, of Material Testing Laboratories (Norfolk, Virginia), NTS Report NTS/ CGS-92-022, dated August 21, 1992, NTS specifically witnessed all chemical analyses on two NTS jobs, semi-quantitative analysis on certain NTS wedges, and hardness testing on another NTS job. This was a good, item-and critical-characteristic-specific survey.
Although some surveys were excellent, others for services were not specific i
about the type of calibration or service being procured.
For example, another test lab subcontractor of NTS, Henry Souther Laboratories, has about eight different test capabilities, but the survey report did not specify which tests or if all tests were approved. This was more of a QA capability audit rather i
than a testing capability survey.
Also, the survey of AC Electric did not address specifics of what AC Electric was contracted to do, other than verify they use NTS procedures. The NRC inspectors found some variability among surveys done by different NTS surveyors.
Discussions with NTS on this issue addressed the ways in which somewhat more detailed procedural guidance might improve standardization and consistency in the quality of surveys.
j 3.12 Review of NUPIC Audit of NTS J
In order to assess NTS's dispositioning of externally identified problems, the inspectors reviewed the report of an audit of NTS by a joint utility team under the auspices of the Nuclear Products Issues Council (NUPIC), conducted March 31 through April 4,1992, identified as PSE&G [Public Service Electric and Gas - the lead utility] Report B00-253-92, dated April 24, 1992. The audit was to verify compliance with 10 CFR Part 50, Appendix B, 10 CFR Part 21, ANSI N45.2, and EPRI Report NP-5652 NTS was found to be in compliance with NUPIC's so-called Performance Based Checklist (Rev. 2). There were two findings, but they did not affect QA program implementation or products.
NTS responded, describing its corrective actions on May 20, 1992, and its actions. -
(
were found acceptable by the lead audit organization according to a PSE&G letter dated June 10, 1992. Also, the audit report contained three-observations (suggestions for improvement), one of which was significant: NTS did not correlate (document) critical characteristics to intended safety functions although the report stated that NTS adequately dedicated the item.
The inspectors noted that the NUPIC report indicated review and approval of NTS's external audits, but it did not address commercial grade surveys by NTS; although surveys are heavily relied upon by NTS for. dedication.
4 PERSONNEL CONTACTED N.J. Fredkin, Jr., Vice President, Nuclear Services William C. McGinnis, Vice President,-Northeast Division
- + Christine C. Briggs, Director of Quality
- + Michael P. Saniuk, Manager of Nuclear Services
- + James Dozier, Assistant Quality Assurance Manager
+ James Gaudette, Operations Manager R.A. Everett, Project Engineer Paul Leonard, Project Manager
+
indicates those present at the entrance meeting on July 6, 1993.
indicates those present at the exit meeting on July 9, 1993.