ML20058M281
| ML20058M281 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/1990 |
| From: | Petrosino J, Vandenburgh C Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058M262 | List: |
| References | |
| REF-QA-99900871 NUDOCS 9008100036 | |
| Download: ML20058M281 (12) | |
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-ORGANIZATION: ELGAR CORPORATION SAN DIEGO, CAllFORNIA REPORT INSPECTION INSPECTION NO : 99900871/90-01 DATE: March 12-15, 1990 ON-SITE HOURS: 122 CORRESPONDENCE ADDRESS:
Elgar Corporation 9250 Brown Deer Road San Diego, California 92121 ORGANIZATIONAL CONTACT: Mr. T. Roth, QA Manager TELEPHONE NUMBER:
(619)450-0085 i
NUCLEAR INDUSTRY ACTIVITY: The Elgar Corporation (Elgar) manufactures electricalinverters,uninterruptiblepowersupplies(UPS)andassociated products.
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ASSIGNED INSPECTOR:
L <ta
/J -Si4 6
J 'J. F/f)/ Vendor Inspection Branch (VIB) gbsino,' Reactive Inspection Section No.
, ate (RIS/1 y
OTHER INSPECTORS:
M. R. Snodderly, USNRC, RIS-1:VIB W. E. Gunther, Brookhaven National Laboratory K.
ullivan, Brookhaven National Laboratory APIROVED B :
W 879O C. A..VanDenburgh, Section Chief, RI5-2, VIB ate INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and Appendix B to 10 CFR Part 50 B.
SCOPE: This inspection was conducted to: (1) evaluate a potentially L
reportable deviation that occurred at the San Onofre nuclear generating L
. station (SONGS) regarding an Elgar inverter low voltage shutdown setpoint l
issue, and (2) evaluate corrective actions regarding design control L
issues identified in previous NRC inspections at Elgar.
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. PLANT SITE APPLICABILITY: Clinton -(50-461); Comanche Peak (50-445/446);
Crystal River (50-302); Dresden (50-237/249); Fitzpatrick (50-333); Hatch l-(50-321/366); IndianPoint(50-286); Millstone (50-245/336/423); Monticello L
$0081@$99 C036 voogoy 999008 EMVELGAg PDC
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' ORGANIZATION: ELGAR CORPORATION SAN DIEGO, CALIFORNIA REPORT INSPECTION NO.: 9990087.1/90-01'.
RESULTS:
PAGE 2 of 12 PLANTSITEAPPLICABILITY(CON'T): (50-263);NineMilePoint(50-220/410);
Oconee(50-269/270/287);
RanchoSeco(50-312);RiverBendPalo Verde (50-528/529/530);(Perry 50-440); Point Beach.(50-266/302);
50-458 ; San Onofre (50-206/361/362); Seabrook (50-443);) South Texas (50-498/499 ;
St. Lucie (50-335/389); Vermont Yankee (50-271 ;.Vogtle (50-424/425); WPPSS (50-392);.
~Waterford(50-382);andYankeeRowe(50-029).
A.
VIOLATION:
Contrary to Section 21.21, " Notification of failure to comply or existence of.a defect," of 10 CFR Part 2 i 1.
Elgar' failed to adopt proceduret that are appropriate to provide for either evaluating ceviations or informing their customers of' the deviations in order that thnf.e customers could cause the deviations to be evaluated (90-01-01).
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'2.
Elgar failed to adequately evaluate or inform its customers of deviations that were identified in engineering change notices (ECNs) written to correct such items as errors, problems and deficiencies (90-01-02).
B.-
.NONCONFORMANCE:
1.
- Contrary to Criterion 11. " Quality Assurance Program," of
. Appendix B to 10 CFR Part-50, five out of six Elgar Service and Nuclear Department employees had not received a quality assurance-(QA)programindoctrination(90-01-03).
2.
Contrary to Criterion III
" Design Control," of Appendix-B to 10CFRPart50,Elgarfailedtocorrectlytranslateelectrical' i
wiring termination locations from the electrical schematic for a safety-related UPS supplied to the Texas Utilities'. Comanche PeakSteamElectricStation(90-01-04).
3.
Contrary to Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50:
a.
Elgar failed to implement corrective actions for a previously identified nonconformance involving the failure to assure that the design change review process provided for an independent review of the-technical adequacy of the following 7.5 Kilo-volt ampere (KVA) and 25 KVA inverter design changes. This issue was previously identified as Nonconformance 88-01-03 in'NRC Inspection Report No.
99900871/88-01. The following ECN's were not reviewed for
Y DRGANIZATION:' ELGAR CORPORATION-
' SAN DIEGO, CALIFORNIA 7
. REPORT-INSPECTION NO.: 99900871/90-01.
RESULTS:
PAGE 3 of 12~
technical adequacy by someone other than the person who performed the work:
ECN 1104, ECN 1397, ECN 1473, ECN 1493, ECN 1499 ECN 1689, ECN 1796, ECN 1836, ECN 2212, ECN 3800, ECN 5988, and ECN 6216(90-01-05),
b.
Elgar= failed to establish measures to assure that component-related deficiencies which are identified by Elgar field service representatives at NRC licensed facilities are appropriately dispositioned within Elgar's QA program (90-01-06).
4.
Contrary to Criterion XVIII, " Audits " of Appendix B to I
10 CFR Part 50 Elgar neither established an internal-audit schedule nor pe,rformed any audits of its established QA program from June 1988 until March 1990(90-01-07).
C.
' UNRESOLVED AND OPEN ITEMS:
1.
Design Change Corrective Action During this inspection the inspectors determined that Elgar was L
serforming design change reviews of ECNs'regarding circuit i
ooards; however, Elgar had limited the reviews to the circuit L
board ECN's and had not considered other design changes in such as:
components,(SCRs),andheatsinks. transformers, chokes, silicon controlled rectifiers This area requires further review and evaluation and_is considered to be an Open Item, Number 90-01-08.
2..
Printed Circuit Board Terminal Strip Connectors i
The-inspectors reviewed a Comanche Peak Steam Electric Station (CPSES) Significant Deficiency Analysis Report, No. CP89-018, which identified' cracked solder joints on Elgar printed circuit (PC) board terminal strip connectors. The root cause of the-.
cracking could be from inappropriate CPSES personnel handling of the PC boards, inappropriate handling of the PC boards by Elgar manufacturing personnel, or both of these.
Elgar connitted to 1
L initiate a review of this matter to determine the actual root cause of the cracks and to inform applicable customers as necessary. This area requires further review and evaluation and is therefore considered to be an Open item, Number 90-01-09.
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V-L ORGANIZATION 8 ELGAR CORPORATION SAN DIEGO, CALIFORNIA REPORT INSPECTION '
NO.: 99900871/90-01 RESULTS:
PAGE 4 of 12 D.,
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
Nonconformance B.1 From 99900871/85-01 Closed
" Failure to Perform QA Program Indoctrination."
The corrective actions for this nonconformance did not adequately respond to the specific NRC concerns regarding indoctrination. A review of additional indoctrination records to evaluate whether Elgar's corrective actions were adequate to prevent recurrence were also found to be unsatisfactory. During this inspection an additional nonconformance was identified in this area. The item is closed and the issue will be followed by Nonconformance 90-01-04, 2.
Nonconformance B.2 From 99900871/85-01 Closed
" Failure to Assure That the Design Basis was Adequately Translated." The inspector concluded that the corrective actions
.regarding this design basis translation problem were satis-factory. The item is closed based on a review of engineering procedure changes and the issuance of a detail drawing of the fuse block shunt assembly which was issued in accordance with ECN 5910. The following procedures have been modified.in accordance with ECN 7410 as part of the corrective action:
- 1) EEP-1, " Engineering Release and Change Procedure."
- 2) EEP-2, " Engineering Change Request Procedure."
EEP-20, " Engineering Design Reviews."
560007-01, "ECN Flow Diagram."
60002-01, " Engineering Change Notice Procedure."
60003-01, " Change Control Board."
3.
Violation 88-01-01 Closed
" Failure to Specify SCR Torque Values." The inspector concluded that the corrective actions taken were satisfactory.
The item is closed based on Elgar providing its customers with the correct SCR replacement methods, including SCR torque requirements.
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ORGANIZATION:
ELGAR CORPORATION.
' SAN:DIEGO, CALIFORNIA REPORT INSPECTION NO.: 99900871/90-01'
-RESULTS:
'PAGE 5 of 12 4.
Violation'2.b. From 99900871/88-01
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Closed
" Failed to Perform Required Evaluations." The. inspector ~
concluded that Elgar' did not perform adequate corrective actions in response to the previous violation identified in NRC Inspection Report Number 99900871/88-01, regarding the' failure to perform evaluations of deviations pursuant to 10 CFR Part 21.
During this inspection an addit'onal violation was. identified in this area. The previous violat cn is closed and this issue will be followed by Violation 90-01-02.
5..
Unresolved. Item 88-01-06 Closed
" Notification of End Users." During NRC Inspection Number 99900871/88-01, the inspectors identified numerous ECN's that were written because of design errors and modifications which had the potential to adversely affect the operability of l
safety-related electrical inverters.
Consequently, this inspection included a review of this area and a new violation I
was identified. Therefore, Unresolved Item 88-01-06 is closed and this issue will be followed by Violation 90-01-02.
.6.
Unresolved Item 88-01-07 l.
~ Closed "IC Sockets, (ECN 1680)," During NRC Inspection Number l
II9M671/88-01, the inspectors identified a concern regarding the seismic qualification of installed. inverters because of modifications to the associated printed' circuit boards. During p
this inspection, the inspectors concluded that Elgar did not-L perform an adequate evaluation of ECN 1680; consequently, ECN '
L 1680 was used as an example in Violation 90-01-02.
This issue will be followed in' Violation 90-01-02; therefore, Unresolved Item 88-01-07 is closed.
l E.
INSPECTION FINDINGS AND OTHER COMMENTS:
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Entrance and Exit Meetings The-NRC staff infonned the Elgar representatives of the scope of the inspection during the entrance meeting on March 12, 1990, and summarized the inspection findings and concerns during the exit meeting conducted on March 15, 1990.
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ORGANIZATION: ELGAR CORPORATION ~
SAN DIEGO, CAllFORNIA' REPORT-INSPECTION NO.: 99900871/90-01 RESULTS:
PAGE 6 of 12 e
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2.
10 CFR Part 21 Procedure The NRC inspector reviewed Procedure Number 10005-01, " Evaluation and Reporting of Defects and Noncompliance Pursuant to 10 CFR Part 21," dated September 19, 1985. The inspector concluded that
'the procedure did not adequately implement 10 CFR Part 21 because the procedure incorrectly used the definitions of " defect" and j!
" deviation" throughout the procedure and required individual employees to determine whether a problem can create a
" substantial safety hazard" prior to an evaluation. Violation 90-01-01 was identified in this area.
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3.
Design Change Corrective Action l
The NRC inspection team reviewed the corrective actions performed i
in response to NRC Inso::ction-Reports 99900871/88-01 and 85-01.
Violation 88-01-01 anJ Nonconformance 88-01-03 identified that Elgar had not considtred the possible effect of design changes and errors on its 7.5 KVA and 25 KVA vital electrical inverters-that are currently. in o The main concern was that Elgar'peration at end-user facilities.
i s customers were not informed of the errors or design changes nor did Elgar evaluate the impact on
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particular NRC licensee applications. Elgar informed the NRC in its response dated September 9,~1988, that it would complete its corrective actions for this violation no later than September 9, 1989.
However.during this inspection, the inspectors identified several examples where Elgar failed to perform satisfactory corrective action for Violation 88-01-01.
In some cases, Elgar evaluated problems and determined that the issue could be potentially generic and should be transmitted to the customer s
because Elgar did not have enough specific knowledge regarding applications at the licensee to fully evaluate the issue.
However, Elgar did not always carry through with the evaluation's conclusions; consequently, the applicable customers were not informed.
In other cases, Elgar had knowledge of the design errors, but failed to either perform an evaluation or inform the customers. As a result of the inspectors review of this matter, Violation 90-01-02 was identified.
The following examples are design changes and errors that were not adequately evaluated or transmitted tc Elgar's customers as required by 10 CFR Part 21:
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'ORGANIZAT10N:1-ELCAR CORPORATION SAN DIEGO,. CALIFORNIA a.
REPORT.
INSPECTION NO.: 99900871/90-01 RESULTS:
PAGE 7 of 12 L
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ECN 2413, dated January 5,1981, "Line Regulator Control H
Driver." This ECN was issued in 1981 to correct a design-deficiency that resulted in the improper installation of four semiconductor devices on the line regulator control j
driver circuit board. Devices having reference drawing-designations of Q2, Q5, Q8 and Q11 were found to have their terminal leads installed in incorrect locations on the subject circuit boards. An Elgar Services Department Action Report (Number 8084000), dated March 25, 1988, identified 1
that Elgar service representatives found a circuit board at the River' Bend facility in spare stock which contained the same deficiencies as those identified in ECN 2413 by Elgar in 1981. Elgar could not provide evidence that it had notified any of its customers regarding this potentially reportable deviation. The inspectors concluded that Elgar failed to adequately evaluate the scope of the problem, implement corrective action to ensure that all present and future boards would be correct, and to inform applicable customers of the deviation.
b.
ECN 2572, dated January 1,1982, " Lamp Board Assembly."
1 This ECN involved interference between the front panel of l
7.5 KVA inverters and the adjacent lamp board assembly terminal block.
Elgar resolved the problem by modifying the
. t circuit board mcunting hardware for.all future applications, but failed to inform its past customers of the problem so that they could cause an evaluation to be performed and modify their equipment as necessary, c.
ECN 3751, dated May 19, 1983. " Driver Logic Board," Drawing 5490001-01. This board was found to have numerous-ECNs-written against it including a change implemented to address.
fuse blowing problems. The ECN evaluation recommended that all future boards be upgraded to the latest revision.
However, all' applicable customers were not informed of this problem and its solution.
-d.
ECN 4532, date unknown, " Static Switch Drive Board." This ECH changed the electrical capacitance value and voltage rating of a capacitor mounted on the board. The evaluation concluded that all boards should be upgraded to the new ECN modification (Revision J) due to recurring problems.
However, all applicable customers were not informed of this design concern and the modification to prevent possible loss of inverter function.
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0RGANIZATION:c ELGAR CORPORATION.
1 SAN DIEGO, CALIFORNIA REPORT' INSPECTION NO.: 99900871/90-01 RESULTS:
PAGE 8 of 12-e.
ECN 5322, dated May 7, 1985, " Lamp Board Assembly." This ECN identified a design deficiency in lamp board assemblies involving electrical shorting problems with the circuit boards associated with terminal block leads. The electrical short circuit problem in the terminal blocks can result in a failure of the assembly.
Elgar did perform corrective i
actions regarding this matter which included the installa-tion of additional mounting hardware on the terminal board.
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However, Elgar failed to inform its customers of the specific problem. problem and corrective action to resolve the O
'f.
ECN 5570, dated August 15, 1985, "DC to DC Converter Board,"
Drawing.549008-01.
This ECN changed fuse F1 from a h
quick-blow type to a' slow-blow type to correct a problem which caused the inverter to lose its capability to operate i
during certain electrical current in-rush transients. The ECN' evaluation concluded that all PC boards should be upgraded to meet the requirements of the ECN modification 1
(RevisionF).
However, all applicable customers were not informed of this design weakness and the action to resolve the problem.
g.
ECN 7095, dated February 1, 1989, "One Phase 3-Bridge Logic j
Board." This ECN involved design translation errors that resulted in the incorrect termination of certain integrated circuit (IC) logic gate terminals on the subject circuit j
board. This logic board is used on all:Elgar 25 KVA.
inverter units. Each logic board uses six of the multiple pin IC's. The design error resulted in internal logic board short circuit currents'that produce significantly elevated levels of IC operating temperatures and possible premature permeative logic board failure. The ability of'the IC components to perform their. intended design function under adverse conditions is dependent upon the specific licensee applications for each of the inverters. The inspectors concluded that the additional level of the thermal stress
-imposed on the IC logic board under operating conditions -
would significantly limit expected life. The inspectors identified that Elgar notified all of its applicable customers with the exception of Duke Power. During the 7
inspection, Elgar committed to inform Duke Power of this E
. issue.
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ORGANIZATION: ELGAR CORPURATION-1
' SAN DIEGO, CAllFORNIA REPORT INedECTION 3
- y NO.
- 99900871/90-01
.9ESULTS:
.PAGE 9.of 12 g
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ECN 7266, dated July 11, 1989, " Overload Sense Board." This 1
ECN identified that the input to'two'PC board pins-will not work because of a missing common " return trace."
The ECN required all customers using UPS Model 253-1-109.to be notified.. However, Elgar failed.to notify their. customers of the problem.
1.
ECN 7283, dated July 25, 1989, " Charger Logic PC' Board."
-This ECN corrected a schematic error which Elgar concluded 1
was of minimal importance. However, Elgar did not have L-specific knowledge regarding the application of the inverter-l to conclude whether or not it could adversely affect a p
particular licensee.
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ECN 7492, dated February 6,1990, " Overload Sens'e Board." This-ECN corrected a schematic error found by'Elgar.
Elgar's y
review stated that there was no effect to the' licensee.
L However, Elgar did not have knowledge of the licensee's L
specific application-of the particular inverte.' nor did i
Elgar know whether the problem could have generic-implications.
During this inspection, Elgar committed to perform evaluations of these ECNs and to notify any applicable customers so that:those customers can~ cause a 10 CFR Part 21 evaluation to be performed.
4.
Indoctrination of Personnel ApreviousNRCinspection(NRCInspectionReportNumber
.99900871/85-01) identified a nonconformance regarding a fa'. lure to indoctrinate all personnel involved in safety-related activities..In response to this nonconformance, Elgar,tated in y
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a letter dated January 24, 1986, that it would perform indoctrination and training classes for its purchasinr,, customer t
service, and nuclear division personnel, including managers, design engineers, draftsmen, contract administrators, and clerks.
A review of the indoctrination records and discussions with Elgar's staff identified that only 13 purchasing and QA personnel had received indoctrination, and that no Customer Service.or lo Nuclear Division personnel had received the required indoctrina-tion training sessions. Additionally, the inspectors identified that a Nuclear Field Service Representative, the QA Manager, the Nuclear Administrator, the Customer Service Manager and the l
l; Engineering Service Manager had not received the QA program L
indoctrination.
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'0RGANIZATIONr ELGAR' CORPORATION SAN DIEGO, CALIFORNIA-
-. REPORT INSPECTION NO :- 99900871/90-01 RESULTS:
PAGE 10 of 12 Additionally, the inspectors reviewed the Elgar QA manual (QAM) regarding the established requirements for quality program-indoctrination. Section 19, " Training," of the Elgar QAM requires, in part, that a record of the-training and.indoctrina-tion for new employees will be completed and that indoctrination, training and qualification of transferred and/or promoted-employees will be updated accordingly.
W. hen applicable, the key engineering, technical, quality and support personnel record for training and indoctrination will be com Forma,isusedforproduction(manual)pleted.. Training record, personnel,'and Form B is used for non-manual personnel.
All personnel performing activities affecting quality, including engineering, production, quality assurance, test, purchasing and-customer service were required to receive indoctrination.
However,areviewofformAandFormBbytheinsgectorsrevealed that Form A delineated " Indoctrination Completed, but Form B merely listed a "Sununary of Technical Experience" and did not document or require non-manual employee's to receive indoctrination.
The inspectors identified that Section 10 of the QAM requires QA indoctrination for manual employees but did not specifically require it for non-manual employees. -The inspector concluded that the Elgar-QAM did not clearly delineate the requirenants of-
' Appendix B to 10 CFR Part 50; therefore, Nonconformance 90-01-03 was identified in this area.
5.
Translation of Design Prior to this inspection, the inspection team reviewed-0 pen Item-Number 50-455/8917-04 which was identified during an inspection at the CPSES facility in NRC Inspection Report Number 50-445/89-17.
0 pen Item 445/8917-04, addressed inverter pre-operational testing problems regarding difficulties encountered during the performance of a CPSES pre-operational test )rocedure. "118 Volt Class 1E AC Inverters." ;During this test, t1e shift test engineer found an indicating lamp that failed to indicate low battery voltage.
Troubleshooting revealed that the inverter had been incorrectly wired.
The NRC inspectors reviewed the electrical schematic, Drawing Number 528-428-61 Revision F, and the wiring list, Drawing Number 628-428-50 Revision M, for UPS 103-1-132 and found they did not agree. As a result of the NRC inspector's review, Elgar's engineering personnel initiated an ECN to correct the wire list. Elgar stated that the incorrect wiring was limited to the CPSES facility because only one licensee was supplied with UPS Model 103-1-132.
Nonconformance 90-01-04 was identified in this area for Elgar's failure to previously open an ECN before the NRC inspection.
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0RGANIZATIONs. ELGAR CORPORATION-
' SAN DIEGO, CALIFORNIA a
REPORT INSPECTION:
NO.: 99900871/90-01
.RESULTS:
PAGE 11 of 12 j
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6.:
Previous' Corrective Action Comitments As a result of previous-NRC inspection findings' detailed in
(
. Inspection Reports 99900871/85-01 and 88-01 Elgar committed to perform activities to correct the identified findings.
Therefore,:the inspectors reviewed Elgar's corrective action for.
these findings. The. inspectors identified that the corrective-
. actions were not effectively performed in some cases and were not -
performed at all regarding 12 ECNs that were identified in Section 2.a of Appendix B to NRC Inspection Report Number 99900871/88-01, Nonconformance 88-01-03. As discussed in Inspection. Report Number 999000871/88-01, these 12 ECNs were found to have been prepared, reviewed and approved by the same 4
Elgar employee. The inspectors identified that Figar failed to implement' corrective action to review the ECNs for technical.
l adequacy by someone other than the person who performed'the work.
The ECNs that were not reviewed by someone other than'the person who prepared them are: ECN 1104, ECN 1397, ECN 1473~, ECN 1493 ECN 1499, ECN 1689. ECN 1796, ECH 1836, ECN 2212, ECN 3800, i
ECN 5988 and ECN 6216. The inspectors concluded that Elgar did not perform adequate corrective action to address-this previously identified nonconformance. Therefore Nonconformance 90-01-05 was identified in this area.
7.
On-Site Customer Service The inspectors conducted discussions with Elgar personnel regarding how they comply with Appendix B'to-10 CFR Part 50 and Part 21 during on-site customer services. Elgar stated that they had not established any specific procedures to address their work activities at-licensee facilities because they usually work under a licensee's QA program..The inspectors also reviewed and
-discussed in detail the following Elgar Service Action Requests (SARs):
a.
SAR 80848000, dated March 25, 1988, " Troubleshoot and Assist In Repair of 50 KVA PLC On Site," for the River Bend nuclear station.
b.
SAR 8055800, dated February 24, 1988, " Assist In Trouble-shooting on UPS Problem and Cause of Failure," for South Texas Project nuclear station.
The inspectors concluded that Elgar had not established any procedures or measures to ensure that identified nonconformances, problems, defects or deviations are controlled in accordance with
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1 ORGANIZATION:
ELGAR CORPORATION-SAN DIEGO, CALIFORNIA
- REPORT INSPECTION
~ NO.: 99900871/90-01 RESULTS:
PAGE 12 of 12 e
5 its QA manual.
For example, SAR 80848000(RiverBend) identified-that Elgar had previously supplied two defective spare parts to River Bend; however, Elgar failed to perform any corrective l
action for this deficiency. -Therefore, Nonconformance 90-01-06 was identified in this area.
- 8..
Audits Nonconformance 88-01-04 identified in NRC Inspection Report Number 99900871/88-01, identified that Elgar QA personnel were auditing their own department activities. This practice did not-meet the requirements of Appendix B to 10 CFR Part 50 and involved the lack of independence of the former QA Manager and-other QA personnel who performed audits of certain QA Department functions.- During the inspectors review of the corrective actions taken in response to NRC Inspection Report Number 99900871/88-01, the inspectors identified that Elgar had not taken any corrective action for this matter. Additionally, Elgar failed to establish an audit plan or to conduct audits between June 1988 to March 1990. Therefore, Nonconformance 90-01-07 was identified in this area, i
F.
PERSONS CONTACTED:
T. Erickson*
Vice President.
T. Roth*
Quality Assurance Manager J. Turitto*
Quality. Supervisor H. Mac Alain*
Nuclear Engineer R. Parris1*
. Services Representative D
G. Sta)p Engineering Services Manager 4
D. Wintle*
Nuclear Administrator A. Salazar*
Customer Service Manager
- Attended exit meeting o
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