ML20059L516
| ML20059L516 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/1988 |
| From: | Petrosino J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20059L434 | List: |
| References | |
| REF-QA-99901101 99901101-88-01, 99901101-88-1, NUDOCS 9009270069 | |
| Download: ML20059L516 (41) | |
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ORGANIZAT10h:
PLANNED MAINTENANCE SYSTEMS i
MOUNT VERNON, ILLINOIS REPORT INSPECTION INSPECTION NO.: 99901101/88-01 DATES: May 16-18, 1988 ON-SITE HOURS:
96 i
CORRESPONDENCE ADDRESS: Mr. Rodney C. Hanner Planned Maintenance Systems 1002-1004 Main Street Mount (ernon, Illinois 62864 j
DRGANIZATIONAL CONTACT: Mr. Rodney C. Hanner, President TELEPHONE NUMBER:
(618) 244-6700
)
N'JCLEAR INDUSTRY ACTIVITY:
PlannedMaintenanceSystems(PMS)advertisesas being a nuclear safety Class IE component supplier and provides testing services.
/
5SIGNEDINSPECTOR: p/1 h#W~
M/
/S sepr J.
IFtrosino ae active nspection Section 3THERINSPECTOR(S):
V. VanCleave, NRC/RIV T. Tinkel, Brookhaven National Laboratory K. Sullivan, Brookhaven National Laboratory APPROVED BY:
//W I
a Edward T. Baker'%
ate Section Chief, Reactive Inspection Section i
[NSPECTION BASES AND SCOPE:
4 BASES:
10 CFR Part 21 and Appendix B to 10 CFR Part 50.
3.
SCOPE: The inspection was performed to determine whether or not PMS is providing adequate control of its quality assurance program in regard to its verification and testing activities to substantiate that components /
systems were suitable for Class 1E system application.
- 'LANT SITE APPLICABIL11Y:
Unknown; therefore all sites applicable.
i.
9009270069 900913 PDR GA999 EMYPLANN 99901101 PMA l
r.
1 ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLINDIS i
REPORT INSPECTION
)
NO.: 99901101/88-01 RESULTS:
PAGE 2 of 41 A.
VIOLATIONS:
Contrary to Section 21.21, " Notification of failure to Comply or Existence of a Defect " and Section 21.31. " Procurement Documents."
J of 10 CFR Part 21:
1.
PMS has failed to adopt an appropriate 10 CFR Part 21 implemen-tation procedure in that it neither addresses the required PMS evaluation actions of a deviation nor provides for notifying the licensee or purchaser of the deviation so they may cause an evalu-ation to be perfomed (88-01-01);
2.
PMS did not perform any evaluations of its multiple failures to comply with contracturally required IEEE-323 performance require-ments for safety-related Class 1E designated equipment that it has supplied to nuclear plant facilities even though it was aware of its failure to comply and issued Certifi.:ates of Confor-mance (C of C) that indicated I'JE requirements. These issues would have been reportable to the NRC as 10 CFR Part 21 notifica-tion items (88-01-02);
3.
PMS failed to impose the 10 CFR Part 21 requirements on its pur-chase orders for Radiation Sterilizers (PMS job reference Nos, i
T-105andP-1010)andScherrerCalibrationServices(PMSjob reference No. P-1010) (88-01-03).
B.
NONCONFORMANLES:
1.
Contrary to Criterion 11. " Quality Assurance Program," of Appen-dix B to 10 CFR Part 50, Sections 2.2, 2.4, and 3.5 of ANSI /ASME N45.2.6-1978, " Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Pov;er Plants" and ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants:"
a.
PMS could not provide objective evidence that would indicate whether its three level 11 and III inspection personnel were certified to certain discipline activities and could not provide its basis used for the level 11 and 111certificationofqualifications(88-01-04);
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLINOIS l
REPORY INSPECTION NO.:
99901101/88-01 RESULTS:
PAGE 3 of 41 i
b.
PMS could not provide objective evidence to indicate that two out of its three inspectors had met the education and experience requirements at the time of their certification (88-01 05);
c.
PMS could not provide objective evidence that would indi-cate whether the lead auditor certification of Mr. Hanner was valid in regard to his participation in a minimum of five audits during t'.e three year period prior to his lead auditorcertificationforPMS(88-01-06);
d.
PMS could not provide objective evidence to indicate that Mr. Hanner's lead auditor qualification had received the required annual review since the initial July 1985 lead auditorcertification(88-01-07);and e.
PMS level Ill and level !! inspector resume records for Messers. Hanner and Riley each indicated a college degree (M.A. and A.A. res ectively) that was never earned or received (88-01-08.
2.
Contrary to Criterion !!I, " Design Control," of Appendix B to 10 CFR Part 50 and ANSI /ASME N45.2-1977, PMS failed to correctly and fully translate specifications and contractual Purchase Order (P.O.)
requirements into seismic test report requirements for subtier vendor IEEE-344 testing activities on PMS job numbers NY-1071, i
transformers-Fitzpatrick and TY 1043, Fuses-Browns Ferry (88-01-09).
3.
Contrary to Criterion VI!!, " Identification and Control of Materials, Parts, and Components," of Appendix B to 10 CFR Part 50, ANSI /ASME N45.2-1977 and IEEE-std. 323-1974, the identification and subsequent traceability of components procured by and tested by PMS for the New York Power Authorit 86-5700 could not w verified (88-01-10)y under Fitzpatrick P.O. No.
4.
Contrary to Criterion XI, " Test Control," of Appendix B to 10 CFR Part50andANSI/ASMEN45.2-1977(88-01-011):
a.
PMS has issued certifications of compliance which irdicate that some components meet various e,ualification standards without verifying that the certification basis (e.g., previous equipment qualification testing) is relevant and, as a minimum, envelopes the qualification requirements applicable to the current order.
Examples include:
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l ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLIN0IS REPORT INSPECTION NO.: 99901101/88-01 RESULTS:
PAGE 4 of 41 PMS Job No.
C of C/Date Lu s to..'- r Item i
T-1015 082986-2, 8/29/80 TVA Vertical Scale Ind.
i SM-1110 020588-2,2/12/88 SMUD Ind. Lamps SM-1114 021288-1,2/15/88 SMUD Relay w/ Switch b.
PMS could not provide objective evidence to a.tsure that each of the IEEE-std. 323-1974 test sequence requirements were followed for the PMS environmental qualification testing performed for the contact assembles on Public Service Electric and Gas P.J. No.
PI-127398, dated February 24, 1986 (PMS Ref. No. P-1010).
C.
UNRESOLVED ITEMS:
None.
D.. STATUS OF PREVIOUS INSPECTION FINDINGS:
None.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Entrance and Exit Meetings The NRC staff informed the PMS representative, Fr. Hanner, of the scope of the inspection during the entrance meeting on May 16, 1988 and sumarized several of the problems to Mr. Hanner on the evening of May 18, 1988 prior to the scheduled May 19, 1988 exit meeting. However, Mr. Hanner declined the formal exit meeting and-indicated he would prefer to wait for the transmittal of the inspec-tion report.
===2.
Background===
l A 10 CFR Part 21 report was transmitted to the NRC on April 1, 1988 by the Kansas Gas & Electric Company (KG&E) in regard to the validity of the objective evidence that was provided by PMS to substantiate its Class 1E Certificate of Compliance (C of C) for safety-related hardware that was provided by PMS for the KG&E Wolf Creek facility This issue was discussed in an April 26, 1988 NRC Information Notice, N. 88-19.
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f ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS l
MOUNT VERNON, ILLINOIS REPOR1 INSPECTION i
NO.:
99901101/88-01 RESULTS:
PAGE S of 41
{
3.
10 CFR Part 21 Requirements l
Section 21.21,
- Notification of Failure to Comply or Existence of a Defect. requires, in part, that each individual or other entity subject to the regulations in Part 21 adopt approt 'a te procedures to provide for evaluating deviations or informmg the licensee or purchaser of the deviation in order that the licensee or purchaser may cause the deviaticn to be evaluated (see Violations 88-01-01/02and03).
Contrary to this, the NRC inspector revealed that PMS has failed to comply with three aspect; of the 10 CFR Part 21 regulations:
a.
A review of the procedure that PMS has adopted indicates that PMS has not provided requirements for evaluating poten-tially reportable nonconfomances and problems. Furthermore.
PMS has not ensured that licensees or purchasers are notified of deviations so that licensees or purchasers may cause an evaluation to be performed.
b.
NRC discussionf and document reviews with PMS, licensees, and certain manufacturers before, during and subseasent to the inspection, determined that PMS issued C of C's stating that they had complied with the applicable purchase order require-ments even though they had not performed the required actions. As an example, the PMS president was asked how many times they had actually perfomed non-harsh IEEE-std. 323 testing to provide a basis for the PMS C of C statements that the components are qualified as Class 1E. The PMS presi-dent replied that PMS has only performed the non-harsh IEEE-std. 323 verification activities on two occasions. There-fore, the PMS failure represents a departure from the requirements included on a procurement document and would be reportable under 10 CFR Part 21.
l c.
PMS could not provide objective evidence that they invoked 10 CFR Part 21 for purchase orders placed with the following sub-contractors who supplied support services to PMS for qualifica-tion testing of s6fety-related components:
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLINOIS REPORT INSPECTION NO.: 99901101/88-01 RESULTS:
PAGE 6 of 4) i Subcontractor Service PMS Ref. No.
U:
Radiation Sterilizers Specimen Irradiation T-1015 Radiation Sterilizers Specimen Irradiation P-1010 Scherrer Calibration P-1010 4.
PMS Personnel Qualification Inconsistencies ANS!/ASME N45.2.6-1978, " Qualifications of Inspection. Examination, and Testing Personnel for Nuclear Power Plants" and ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" requires, in part, that the capabilities of candidates will be initially determined by an evaluation of the candidates education, experience, training, t
test results or demonstration of capabilities, and his qualifica-tion will be certified in writing including:
level of capabili-ties, activities certified to perform, basis used for certifica-tion including records of education, experience, and training.
Prospective lead auditors will have participated in a minimum of five quality assurance audits within a period of time not to exceed three years prior to the date of qualification and that he will pass an examination to evaluate his comprehension and abilities. Additionally, lead auditor proficiency records will be maintained and reviewed annually to maintain auditor qualifications.
Contrary to this numerous inconsistencies were revealed by the inspection team, in regard to the qualifications and certifica-tions of the three PMS technical personnel, specifically (noncon-formances 88-01-04/05/06/07/and 08 were identified in this area):
a.
Three out of the three PMS inspector / auditor qualification files did not indicate the type of activities (i.e., electrical, welding, instrumentation, and control) that each individual was qualified for, the basis for certification ard it could not be determined whether the individuals were qualified at the time l
of their certification, specifically:
(1) Rodney Hanner, PMS President.
The records for Mr.
Hanner were reviewed.
The following coments apply:
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I ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS i
MOUNT YERNON, ILLINOIS l
REPORT INSPECTION NO.: 99901101/88-01 RESULTS:
PAGE 7 of 41 i
.s.
l (a) Mr. Hanner ~as certified to be a Level 111 on August 20, 1986.
Mr. Hanner's certification was approved by Mr. Roger Riley, a Level 111. The certification does not identify the activities he is certified to perform.
Further, the basis for the certification is not evident, i
(b) Mr. Hanner's resume indicates that Mr. Hanner has a B.S. from Elmhurst College (1974) and a M.A.
from Webster University (1978).
Based on informa-tion provided by Mr. Hanner, and verification with Elmhurst College, Mr. Hanner's B.S. is in a
~
non-technical business area. However, Webster College has no record that he earned a Masters Degree, contrary to his resume.
(c) The resume states that from March 17, 1969 until March 17, 1973, Mr. Hanner served on a nuclear powered aircraft carrier and was in charge. of preventive maintenance of the ship's four engine rooms. Other infomation in Mr. Hanner's file (a Navy personnel evaluation fom) indicates that he l
served on the USS INDEPENDENCE CVA 62 during this, period. However, based on personal knowledge of the inspectors this ship is conventional ra W r than nuclear powered.. Thus, this tour of duty wo.id pro-vide operational steam engineering experience but no experience in nuclear or reactor engineering, as would i
be suggested by the resume.
(2) Roger Riley, Chief Engineer (QA Manager also).
i The records for Mr. Riley were reviewed and the follow-ing apply:
(a) Mr. Riley's resud indica ~tes that Mr. Riley earned an A.A. Degree from Rend Lake College.
However, verification with Rend Lake College indicates that the school has no record that Mr.
Riley earned an Associates Degree.
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT YERNON, ILLINDIS REPORT INSPECTION NO.:
99901101/88-01 RESULTS:
PAGE 8 of 41 ie resume did not provide dates that could be used to determine the amount of time associated with any particular employment experience.
(c) The objective quality evidence in Mr. Riley's e
file is insufficient to substantiate that the minimum education and experience requirements for Level 111 in ANSI N45.2.6 paragraph 3.5.3 were met when he was certified on August 20, 1986.
(3) Bill Roberts, QA Manager.
The records for Mr. Roberts I
were received and the following apply:
(a) Mr. Roberts was certified to be a Level !! on August 20, 1986 by Mr. Rodney Hanner, a Level Ill. The certification does not identify the activities he is certified to perform.
- Further, the basis for the certification is not evident.
(b) The resume indicates that his involvement with nuclear quality assurance is limited mainly to his work with PMS since July 1985.
(c) The objective quality evidence in Mr. Robert's file is insufficient to substantiate that the minimum education and experience requirements for Level 11 in 1451 N45.2.6 paragraph 3.5.2 were met when he was certified on August 20, 1986.
b.
Discussions with Mr. Hanner determined that he was the certified lead auditor for PMS; however, a document review determined that Mr. Hanner's lead auditor certification basis and requalification actions appear to be inadequate, as follows:
(1) The certificate states that Mr. Hanner was certified by Mr. B.E. Roberts; however, Mr. Roberts qualification to perform this activity could not be determined.
(2) Mr. Hanner participated in five audits under supervi-sion when he was employed at Factory Mutual Engineering.
Based on Mr. Hanner's resume, he was employed at
o-1 ORGAN 11AT10N: PLANNED MAINTENANCE SYSTEMS MOUNT VERNDN, ILLINOIS 1
REP 0kT INSPECTION i
NO.: 99901101/88-01 RESULTS:
PAGE 9 of 41 Factory Mutual Liniited from March 17, 1973 until July 1 1976. This experience does not' satisfy the requirement of ANSI N45.2.23 paragraph 2.3.4.
This paragraph requires a prospective lead auditor to participate in a minimum of five QA sudits within a period of time not to exceed three years prior to the date of r
qualification.
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(3) There was no objective quality evidence in the records that demonstrates that Mr. Hanner maintained his pro-
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ficiency as a lead auditor as required by ANSI N45.2.23 paragraph 3.2.
(4) PMS procedure Q-111285 paragraph 5.0 requires lead auditors to be recertified each July. There was no information in Mr. Hanner's records stating that he was recertified in either July 1986 or July 1987.
5.
Design Control Criterion III
" Design Control," of Appendix B to 10 CFR Part 50 requires, in part, that the design basis for systems and compon-ents'be correctly translated into specifications a:M ANSI N45.2-1977 requires that all applicable design requirements, regula-tory requirements, codes and standards be correctly translated into procedures, drawings or instructions, and that deviations r
from design requirements or quality standards be identified, documented and controlled.
Contrary to this, a detailed review of several PMS ' orders revealed numerous problems where PMS failed to correctly or fully translate and perform the required actions (nonconformance B8-01-09 was identified in this area). Examples are as follows:
(a) A review of procurement documents relating to.PMS Project No. NY1071 found them to impose the following requirements:
Section 1.2 of Fluor Engineers Specification E-783 states:
" Wall mcunting brackets furnished with the transformer shall be oesigned to meet the seismic qual-ifications of this specification and shall be used in the qualification testing."
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUKT VERNON, ILLINDIS REPOP.T INSPECTION NO.:
99901101/88 01 RESULTS:
PAGE 10 of 41 I
Section 3.1.'. of the Fluor Engineers Specification e
E-783 states:
"The equipment shall be designed such i
that it may be supported directly to the concrete wall without requiring any additional structural framework (other than the wall mounting brackets furnished with transformer) to support it. The transformer shall be tested utilizing the wall mounting brackets furnished i
with it."
Coutt dry to these procurement documentation requirements, a review of PMS seismic data (Wyle Lab Seismic Qualifica-i tion Test Report No. 48492-1, dated February 19,1987) found the transformer to be seismically tested on a floor mounted test fixture without the required brackets.
In addition, seismic test data of the transformer wall mount-ing bracket could not be located and the mounting brackets were not included in the specimen description and mounting listing (Section 5.1) of the Wyle Test Report.
Section 3.1.5 of Fluor Specification E-783 states in part:
"The equipment and its conjonents shall be sub-jected to thermal, humidity, vibration, and radiation aging for their design life, prior to seismic testing 1
program."
r Contrary to this requirement PMS could not provide any objective evidence needed to demonstrate that the equipment had been subjected to such testing.
Section 3.1.7 of Fluor Specification E-783 states:
"The damping for the equipment shall be assumed to be one-psrcent unless a larger value of the damping may be just4fied by the seller by tests and approval is obta ned from the buyer."
Contrary to this requirement, a review of the Wyle Lab Seismic lest Report found all testing to be performed at a damping if five-percent. A justification for the larger value of damping by PMS or approval by Fitzpatrick Nuclear Plant was not included in the documentation reviewed.
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ORGANIZATION:
PLANNED MAINTEP,ANCE SYSTEMS MOUNT YERNON, ILLINOIS l
t REPORT INSPECTION NO.:
99901101/86 01 RESULTS:
PAGE 11 of 41 l
Section 3.1.9 of the Fluor Specification required a 1
test frequency range of 0.5 to 100 HZ. Section S.3 of the Wyle Lab Seismic Test Report indicates e tested i
frequency range of 1 to 100 HZ. At the time of this audit. PMS could_not provide a justification for the difference between the specified frequency range and the actual tested frequency range.
l Section 3.2.2 of Fluor Specification E-783 imposed the requirement of testing the transformer under no load and full load (nameplate KVA) conditions, and addi-tionally required the monitoring of input voltage and output voltage, current and KVA during the seismic test-ing pro:edures. At the time of this audit PMS could not provide any documented evidence needed to verify that such electrical testing ano monitoring had actually been performed.
1he apparent deviations from the Fitzpatrick Procurement Docu-ments, discussed above, were discussed with Mr. R. Hanner of PMS at the time of this audit. During this discussion, Mr. Hanner stated that, contrary to the PMS C of C issued to the James A.
Fitzpatrick Power Plant (PMS C of C No. CC 012287-1) which states that all material' furnished under this contract is in accordance uth the requirements of the Purchase Order / Contract, including Specification E-783, the seismic testing perfonned on the delivered equipment was, in fact, not performed in accordance with Fluur Specification E-783.
(b) A review of documentation relating to PMS Project No.
TV-1043 to supply the Browns Ferry facility with an i
indefinite quantity of the ATM-15 fuses in accordance with P.O. Number 86PLM-839060 identified the following deviation:
Appendix A to TVA P.O. LB-839060, " Environmental Qualification Requirements Class IE Materials and Equipment in a Mild Environment," was found to state that since the environment is considered mild, the equipment does not have to be subjected to the full aging requirenents to place it in its end of life condition (equivalent to 40 years) prior to seismic testing as stated in IEEE-std. 323-1974 when the vendor provides documentations stating that there is l
4 ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT YERNON, ILLINDIS i
REPORT INSPECTION NO.: 99901101/88-01 RESVLTS:
PAGE 12 of 41
)
4%Adl no age-related degradation of the non-metallics that could affect the functional capability of the equipment.
Section 5.3, " Qualification by Analysis of IEEE-Std. 323-1974" states in part:
"The data used to support the qualification of equipment by analysis shall be pertinent to the application and in an auditable fom."
l Section 8.2 of the PMS Equipment Environmental Qual-ification Report (PMS Report No. QR-080686 Rev. 0) states that PMS has perfomed an analysis which deter-I min 9d that there is no age-related degradation of the i
non-metallies that could affect the functional capa-bility of the equipment and as a result of this analysis, no testing for radiation, thermal aging or e*chanical aging is required.
Contrary to 3e above PMS could not provide objective evidence to substantiate its statement that an analysis had been performed.
Furthermore, this deviation was discussed with Mr. Hanner of PMS during tha audit. At that time, Mr.
Hanner stated that the analysis was. tually an " engineering judgement" on his part and a documented analysis had not been perfomed.
6.
Identification and Control of Me ;erials. Parts, and Components Criterion Vill, " Identification and Control of Materials, Parts.
and Components," of Appendix B to 10 CFR Part 50 requires, in part, that measures will be established to maintain identifica-tion of items. ANSI N45.2-1977 requires the program to provide traceability and amplifies the Appendix B requirements.
Contrary to these requirements. PMS has not adequately maintained the required controls as identified in several customer packages (nonconformance 88-01-10 was identified in this area). As an example, the identification and subsequent traceability of components tested by and procured from PMS by Fitzpatrick Nuclear Power Plant under Fitzpatrick P.O. 86-5790 could not be verified.
Specifically, the review of PMS QA documents relating to PMS Pro-ject No. NY 1071 (Fitzpatrick P.O. 86-5790) identified the following:
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLIN015 REPORT INSPECTION NO.: 99901101/88-01 RESULTS:
PAGE 13 of 41 i
The Fitzpatrick P.O. Specification (Requisition 2955-3, dated October 31,1986) imposed the following requirements:
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Item Quantity Description 1
2 Transformer, dry type, 115' C rise, 25 KVA, single phase, 600v primary, 120/240v secondary connected for 120v output, 60HZ, 2-5 percent capacity teps below rated l
primary voltage, indoor /out-I door construction, complete l
with wall mounting brackets.
G.E. Co. Type QM or approved equal.
Furnish in accordance with Specification E-763.
Class 1E, ANSI N45-2.2 Package Level B.
Tags:
"PT-71ACA6" TT-71ACB6
2 2
Distribution panelboard, rated 600V ac, 1-phase. 3 wire connected for 120VAC single phase distribution, 225A copper bus braced for 14,000 A RMS symetrical, with main lugs at top, sur-face mount er.c;osure with 22 inch wide x 5 J/4 inch deep box, complete with door, door hardware, and circuit card holder.
Full copper ground bus and equipment ground lug.
Equipped with twenty 1-pole, twenty ampere thermal-magnetic molded case circuit breakers, rated 600 W.C. and 10,000 A RMS symetrical interrupting capacity at 120V ac.
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i 0RGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT YERNON, ILLINOIS
-REPORT INSPECTION
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NO.: 99901101/88-01 RESULTS:
PAGE 14 of 41 Item Ouantity Description Panelboard and breakers shall be f
fully factory assembled.
G.E.
Co. Type NLAB or approved equal panelboard with Type THQB or approved equc1 circuit breakers.
Furnish in accordance with Specification E-783. Class IE, ANSI N45.2.2 Package Level B.
Tags:
(1)"71ACA6" (1) "71ACB6" i
A review of the PMS C of C (C of C No. CC-012287-1, Rev. O.
dated January 22,1987), found the C of C to identify the Fitzpatrick components Ly the following tag numbers:
Item No.
De scription Quantity Tag No.
l 1
Transformer, dry tape, 115"C 2
T-1071-1 l
rise, 25KVA single phase, T-1071-2 600V primary, 120/140 V L
secondary.
G.E. Type QM l
2 Distribution Panelboard.
2 DP-1071-3 600V AC, single phase, 3 DP-1071-4 wire, G.E. type NLAB panel-board and THQB circuit breakers.
At the time of the inspection, PMS could not provide any additional documentation to assure that an adequate correlation could be established between the differing tag numbers.
In aodition, Section 5.1 (Speciiic description and Mounting) of the Seismic Qualification Test Report (Wyle Laboratories Report No.
48493-1) was found to provide the following description of the
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tested specimens:
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ORGANIZATION:
PLAliNED MAINTENANrE SYSTEMS MOUNT VERNON, ILLINDIS i
REPORT INSPECTION NO.:
99901101/88-01 RESULTS:
PAGE 15 of 41 l
Tested Specimen No.
Description I
(10)
Transfonner, manufactured by General l
Electric, Model No. 9T 23 B 2671, 15.5" W x 14.75" D x 25" H, 4 mount-1 ing bolts 1/2"-13, floor-mounted test fixture.
(11)
Electric Switch Junction Box, manu-factured by General Electric, Catalog Wo. 8643, AQF302MTX and AF435, 20" W x 6" D x 43.5" H, 4 mounting bolts 3/8"-16, i
wall mount test fixture.
i As shown above, the review identified e difference between the 1
tag numbers specified by the Fitzpatrick purchase order and those tag numbers stated on the PMS C of C.
In addition, the use of any such tagging practice could not be verified by 6 review of the Wyle Laboratories Seismic Qualification Test Rep
't.
The Wyle Report was found to identify the tested com-pone.its primarily by model and/or catalog numbers.
None of the PMS QA documentation reviewed, however, includin i
to its subvendor (G.E.) (PMS P.O. No. P-1222861)g the PMS P.O.
were found to incorporate the use of such model numbers as a means of identification.
In an efiort to verify the traceability of the components, the reviewer requested a copy of the PMS P.O. to Wyle Laboratories.
In response to this request, Mr. R. Hanner of PMS stated that contrary to instructions contained in the PMS P.O. to G.E. Supply Co.,
the units were actually shipped directly from G.E. Supply Co. to Wyle Laboratories for testing. According to Mr. Hanner, PMS did not perform either an incoming inspection or qualification testing to IEEE 323-1974.
In addition, Mr. Hanner stated that PMS could not provide any further documentation to demonstrate traceability.
7.
Test Control Criterion XI, " Test Control," of Apper. dix B to 10 CFR Part 50 requires, in part, that a test program be established to assure that all testing required to demonstrate that systems and com-ponents will perform satisfactorily in service is identified and i
performed in accordance with written test procedures which s
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ORGANIZATION:
PLANNED MAINTENANCE JYSTEMS MOUN1 VERNON, ILLIN015 REPORT INSPECTION h0.:
99901101/88-01 RESULTS:
PASE 16 of 41 incorporate the requirements and acceptance limits contained in i
applicable oesign documents. Test results will be documented and evaluated to assure that test requirenents have been satisfied.
ANSI N45.2-1977 requires, in part, that regardless of the degree of standardization or similarity to proven designs, the applica-bility of standardized or previously proven designs, with respect to neeting pertinent design requirement, will be verified for each spplication.
Contrary to the above, it was found that in the majority of cases PMS could not provide adequate objective evidence to indicate that they were performing the required IEEE-std. 323 actions. A Public Service Electric and Gas purchase order for contact assemblies (No.
PI-127398) was used as an example (nonconformance 88-01-11 was iden-tified in this area). Additionally, it has been revealed that PMS has issued C of C's without performing adequate reviews in all cases to verify the basis of certification (e.g., previous equipment quali-fication testing) is relevant, valid and as a minimum, envelopes the qualification requirements applicable to the order.
Various customer purchase order documentation files were reviewed to determine whether or not PMS was idequately implementing its QA program requirement in this area.
It was concluded that PMS is not adequately implementing its test program requirements and furthermore, PMS is issuing C of C's that do not have an adequate basis for issuance.
Numerous inconsistences were noted in the PMS customer documenta-i tion files. The following is a sunnary of some of these pack-ages which are sorted by the PMS customer identification number.
In many cases, documentation in the files was not adequate to clearly understand what activities had taken place. This created a need to ask Mr. Hanner many questions for amplification and clarification, a.
T-1003 (TVA-Watts Bar). The documentation file for T-1003 was reviewed.
A summary of information in the file and any additional amplifying information is presented below:
(1) TVA contract 86K LB-838192, dated December 19, 1985, was reviewed.
Information in the contract includes:
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS MOUNT YERNON, !!!,1N0!S q
REPORT INSPECTION h0.: 99901101/88-01 RESULTS:
PAGE 17 of 41 (a)
Items ordered:
200indicatirglamps(red), type EZC, Style No. 449D187G13 by Westinghouse, 200 indicating lamps (green), type EZC, Style No.
449D187G23 by Westinghouse.
(b) The lamps were identified as Class IE and 10 CFR Part 21 was invoked.
Lamps of the same typa wri procured by TVA on a previous contract 82K J9-830535.
Based on a discussion t'.th Mr. Hr w the supplier for this previous contract was NUTHERM, and the lamps were tested and qualitt.
by NUTHERM on this contract.
j (c) The contract invokes TVA QA specification SS-E18.11.03 and a technical requirement that the lamps supplied by PMS must be 9enerically the same as those supplied on the previous contract.
The specification defines generically as the same.
l including materials, assembly, and operation of the item.
I (2) PMS bid proposal, dated November 18, 1985, was reviewed.
Information in the bid proposal includes:
(a) PMS advised TVA that a 100-percent full functional i
test on all items would be performed using PMS procedure E-111485. The procedure was submitted to TVA in the bid proposal.
(b) The PMS procedure provides for a visual inspec-tion, a mechanical inspection using a catalog technical sheet for Type EZC lamps, and a 15-second electrical actuation test.
(3) PMSP.O.(P-120285-2) to Fairmont Supply, dated December 19, 1985, was reviewed.
Information in the purchase order includes:
7 (a)
Items Ordered:
200indicatinglamps(red)withbuilt-in resistor, type EZC, style 4490187G13 by Westinghouse.
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MOUNT VERNON, ILLINOIS REPORT INSPECTION NO.: 99901101/88 01 RESULTS:
FAGE 18 of 41 j
4 200indicatinglamps(green)withbuilt-in I
resistor, type EZC, style 449D187G23 by Westinghouse.
(b) The P.O. states that all items e n subject to a 100-percent incoming inspection.
(4) A Westinghouse C of C, dated January 4, 1986, was f
reviewed. The certificate was on letterhead from Westinghouse Electric Corporation, Power Systems, Relay Instrument Division, Coral Springs, Florida.
Other infonnation on the certificate includes:
t (a) The certificate is titled:
CERTIFICATE OF CONFOR-MANCE(P.O.SpecifiedInstruments).
(b) The referenced P.O. is (PMS) P-120285-2 and the referenced Westinghouse G.O. number is 164317.
(c) The certificate certifies 200 red lamps (440187G13)and200greenlamps(449D187G23)to F
be in compliance with the order and certifies that the articles are free of mercury contamination.
(d) The block in the second paragraph stating "sub-stantiatingrecords(15)(isnot) attached"was not complete on the copy in the file.
(e) The certificate had form number QAP ho.82-036 at the bottom and was signed by Mr. Paul Schmidt, QA Inspector.
(Si PMS C of Cs (no number), dated January 28, 31, and March 25, 1986, were reviewe6. The certificates certify that the items are in conformance with the order and are free of mercury.
The certificates are signed by Messers B. Roberts QA Manager and R. Hanner, President.
(6) Other docurents found in this file include packing lists and PMS inspection report forms.
1
l ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS j
MOUNT VIRNON, ILLIN0IS REPORT INSPECTION i
NO.: 99901101/88-01 RESULTS:
PAGE 19 of 41
)
(7) The Westinghouse C of C mentioned above was reviewed with Mr. Hanner.
(a) The inspectors noted that the certi'icate is dated January 4,1986 and certifies 400 lamps.
Yet, the Westinghouse par. king lists e.cicate some of the lamps were not shipped to EMS until after the k nuary 4 date.
Mr. Henner was asked if he could explain why some of the lamps were apparently cer-tified prior to being shipped from Westinghouse.
He indicated he did not know the reason.
(b) The inspectors noted that the certificate references 4
a PMS P.O. number. However, the lamps were actually i
ordered from Westinghouse through Faimont. Mr.
Hanner stated he could not explain why the PNS P.O.
t was referenced instead of a P.O. from Faimont.
i (c)
In response to a question from the inspectors, Mr.
Hanner stated that the Westinghouse certificate was used as the basis for certifying the items were i
mercury-free prior to receipt at PMS.
p (d)
It was detemined af ter the inspection by the NRC that Mr. Hanner had fabricated the Westinghouse C of C using a Westinghouse blank fom that he had l
obtained. This was subsequently verified with West-inghouse - Coral Springs.
(8) Mr. Hanner was asked to explain the basis for the PMS.
certification that the lamps supplied by PMS were generically the same as those supplied on the previous contract. Mr. Hanner stated that PMS considers the part number to be the, key to this detemination.
According to Mr. Hanne'r, PMS considers that if they supply a part with the same part number, then they are supplying the same part. Additionally, Mr. Hanner noted that the receipt inspection and 100-percent functional test specified in PMS procedures E-111485 provided additional assurance for this certification.
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ORGAN 11AT10N:
PLANNED MAINTENANCE SYSTEMS
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' MOUNT VERN9N, ILLINOIS "d6 PORT INSPECTION m
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PACE 20'of 41
.t This item is-discussed in more detail in Section E.8 of the report.
L b.
P-1010 PSE&G - Hope Creek. The documentation package for
- A 10 was reviewed. A sunnary of information found in the file and any additional smplifying information is presented below.
(1) PSE&G P.O. P1-127398, dated February 24, 1986, was reviewed.
Infonnation in the P.O. includes:
(a)
Items ordered:
Vendor seismic and environmental qualification, mcuing contact - 0156C1500-663-02, stationary contact 015601250-700-01.
(b) The P.O. invoked 10 CFR Part 21,10 CFR Part 50,
' Appendix B, IEEE-323 (milo,t, and IEEE-344 (harsh).
(2) fMS employed subcontractor services to support some-portions of the required test program.
(a) The P.O. documer.tation from PMS to the subvendors was not in the documentation file and could not be l~
located by PMS. Thus, the technical and quality requirements invoked by PMS on these subcontrac-tors could'not be established.
Further, it could nct be established whether.PMS invoked 10 CFR Part 21 for the services.
Examples L
of subcontractor services include:
P.O. from PMS to Radiation Sterilizers for specimen irradiation (reference:
L
!l-P.O. from PMS to Scherrer for calibration of an oscilloscope. '(reference;
' EQ Report QR-020787).
i (b) A PMS memo to File, dated February 10, 1986, o
?
indicated PMS leased testing facilities for the l
performance of some of the test program. ADRL (name unknown) facilities were used to conduct l
l 9
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- 0RGANIZATIONi. PLANNED MAINTENANCE ~ SYSTEMS l
MOUNT VERNON,'!LLINOIS REPOR1' INSPECTION NP.:
99901101/88-01.
RESULTS:
PAGE 21 of 41 thernal aging testing and General Radiator facilities were used for vibration testing. The-memo states that these companies did not have a "ormal quality assurance program in place. Conse-q 7tly, the therwel aging testing was performed by Mr. Hanner and Mr. Riley and the vibration test-ing was perforned by Mr. Riley.
Information found in Mr. Riley's personnel file was net sufficient to determine his qualifications for performing the vibration testing at General Radiator. This matter was discussed with Mr. Hanner. He stated that, although it is not specifically documented, Mr. Riley worked with this equipment for a number.
of years during his employment at General Padiator.
j (3) PMS EQ report QR-020786 was-reviewed. This report doew.
ments the environmental and seismic qualification testing for this order.
(a) The report did not'contain information or data that would indicate that the test sequence used for the PMS test program was in compliance with test sequence requirements specified in IEEE-323 para-graph'6.3.2 For example, there is no-documentation that would subs *antie.te that equipment. operations were checked for the fo11 ewing condit, ions:
Initial inspection te r avide a normal con-dition data base for comparison with more highly t
stressed conditions.
Performance and electrical characteristics given in the equipment specifications during extreme test conditions.
' Exposure to simuleted design basis event.
Exposure to the simulated post accident conditions.
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E ORGANIZATION: PLANNED MAINTENAN'E SYSTEMS
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MOUNT VERNON, ILLINOIS 99001101/08-01 PAGE 22 of 41
.(b) The Arrhenius Methodology thermt1 aging calcula-tions in the report require the identification of.
limiting material activation energies. The PMS basis for the selection of activation energy values documented in the report.was not found in the report or any other PMS documentation. This item was discussed with Mr. Hsnner.
He stated that et one time PMS had a chart that listed various activation energies for materials, and he suspected that.the chart was used for this calcula-tion..Mr. Hanner further stated that he no longer knew ths. location of the chart.
(c) Neither the report nor the documentation file contained any test data.(e.g., time temperature.
data, humidity data) for the thermal aging tests. This item was discussed with Mr. Hanner,-
l e
and he indicated that he did not have any other
~'
documentation for this testing.
(d) PMS based their seismic certification of the
- com, ents on a report of prior seismic testing pert eed by.Wyle Laboratories and the additional vibrauon. testing performed by PMS using General Radiator facilities. A PSE&G internal memo dated n
February 4,1986 to Bil! Robe:rts [PMS] stated that the contact assembly had been.previously seismically qualified using the Wyle testing.
L This memo also.forwerded seismic: inputs for the~
-l components'to PMS.
L (4) PMS C of C CC-020786 Rev. O and 1, dated February 7, p
1986 was reviewed. The certificate cartifieo the quali-fication of the contact asssmblies to'IEEE-323-1974 and IEEE-344-1975. 'The certificate states the basis ir type testing simulating a 5-year service,11fe. Signa-tures include:
Prepared by: Mr. Robert Riley, Reviewed l..
by:
Mr. Bill Roberts, and Approved by: 1r. R. C.
Hanner.
c.
T-101S (TVA - Sequoyah). The documentation file for T-1015 i
was reviewed. A sumary of information found in the "ile and any additional or ampHfying information is presented
'l below:
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS LHOUNT VERNON, ILLINDIS REPORT INSPECTION NO.: 99901101/88-01.
RESULTS:
PAGE 23:of 41 L
l (1) TVA Contract 86 PLC-838656, dated March 25, 1986, was reviewed.
Information in the contract includes:
(a)
Items ordered:
2 - vertical scale indicators.
type VX-252 by Westinghouse.
(b) Data sheet SE-0493 SH 1 R0 attached to the contract indicates this model indicator is the same as an indicator currently in service which was supplied on contract 91934.
(c) The contract invokes the following TVA specifi-t cations:
SS-E18.10.01.R1, Environmental Qualification of Safety-Related Electrical Equipment.
SS-E18.11.02.R2, Quality Assurance Requirements for Safety-Related (non-ASME-III) Equipnent..
SS-E18.12.01.RO, Seismic Requirements for Electrical and I&C Equipment ~.
(2) The PMS bid proposal, dated March 5, 1986, was reviewed.
Information in the bid process iaciudes:
(a) A technical sheet for the type VX-252 indicators is-included.
The technical sheet states that the type 252 indicator was specifically design?d for nuclear power plants and, among other things, the indicators pass the seismic qualification tes~,
under IEEE-344 1975.
(b) PMS states t:
reque:'ed items have been pre-quali-s fied to Class IE standards.
'i (c) The bid package contains a completed but unsigned Westinghouse C of C for two VX-252 Westinghouse vertical indicators:
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w ORGANIZATION:
PLANNED MAINTENANCE' SYSTEMS MOUNT VERNON, ILLIN01S
,fNO.:
REPORT INSPECTION 99901101/88-01 RESULTS:
'PAGE 24 of 41 j
The certificate is on Westinghouse Electric Corporation, Power Systems, Relay Instru-a ment Division Coral Springs, FL letterhead.
j The certificate is entitled: SAFETY CLASS IE EQUIPMENT, Certificate of Conformance, j
(P.O. Specified Instruments).
t The cert 191cate references P.O. (PMS) 030686-1 and is dated March 5, 1986.
The certificate certifies that articles are in conformance with the requirements of the L
order and that the articles are mercury-free.
j The~ certificate states the items are qualifi-fied for nuclear safety Class IE applications
~
. and a complete - mrt [will be) available two to four weeks placing the orde The signature u.uck is blank, and there is no form number in the bottom left-hand Corner.
(3) PMS P.O. 032686, dated March 26, 1986 to-Fairmont Supply _was reviewed.
.(a) The document orders eignt VX-252 vertical scale indicators to be in accordance with data sheets (attached-to the P.O.).
West-inghouse C of.C's are specified for the order.
10 CFR Part 21 is invoked.
(b) The subject P.O. was forwarded to Fairmont Supply by a PMS letter dated March 26, 1986.
Among other things, the PMS letter states.
o that PMS is basically looking for a C of C which is Westinghouse form QAP 82-036.
1 (4) PMS C of C CC-082986-2, dated August 29, 1986, was reviewed. The certificate certifies the West-inghouse vertical scale indicators are identical in form, fit, and function as units previously
-ORGANIZATION: ' PLANNED MAINTENANCE SYSTEMS MOUNT.VERNON, ILLINDIS REPORT INSPECTION NO.: 99901101/88-01 RESULTS:
PAGE 25 of 41 qualified by Westinghouse and supplied under contract 91934.
The document also certifies that the indicators are in accordance with IEEE-323 1974 and IEEE-344-1975.
(5) A HESCO letter, dated September 19, 1986, to PMS was reviewed and indicated that WESCO supplied l
Crompton indicators in lieu of Westinghouse ver-L tical scale indicators to PMS. The letter states h
that the Crompton and Westinghouse indicators are k
identical in fonn, fit, and function. The letter notes, for example, that WESCO has supplied Crompton units to Comonwealth Edison to replace existing Westinghouse indicators.
(6) A 'TVA letter, dated December 12, 1986, indicated that the generic Westinghouse C-of C supplied by PMS is not acceptable and that terng would be required to qualify the indicatces.
(7) PMS EQ report EEQP-071087, dated October 15, 1987, was reviewed. This is the report of
-testing performed by PMS to qualify equipment being supplied to TVA on four different contracts:
Contract No.-
Power Plant Equipment 86PLF-838450 Browns Ferry Vertical Scale' Indicators 86PLC-838656 Sequoyah Vertical Scale Indicators
'86KLD-839051 Bellefonte DC Contactor 86PLB-838855 Browns Ferry Precision Power Retistor (a).The seismic ' ualification was based on q
testing performed by Wyle Laboratories and reported in Wyle report 48863-1, dated June 24, 1987. The report states that the work was done in accordance with a QA program meeting ANSI N45.2 and 10 CFR Part 50 with 10 CFR Part 21 applied.
PMS P.O. 061007 to Wyle for tha work was not in the documenta-tion file and could not be located by PMS for a
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ORGANIZATION:
PLANNED MAINTENANCE SYSTEMS l
.I MOUNT VERNON, ILLINDIS t
REPORT INSPECTION NO.:. 99901101/88-01 RESULTS:
PAGE 26 of 41 t
review.
The Wyle report indicates that the vertical indicator tested by Wyle was a Crompton.
(b) The thermal aging testing for the qualifica-l tion was perfomed by PMS. Time temperature l
charts attached to the EQ report show that a temperature of 235'F was maintained during the test.
It is noted that these charts appear to be misdated by one day starting wit the fourth day of the test, Monday.
L February 2, 1987. However, the charts would i
still indicate that 235'F was maintained for l
the remainder of the calculated minimum accele-rated aging time of 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br />. No data was found that would identify the humidity level I
maintained during.the testing. A C of C from r
t I
Radiation Steril12ers indicates that'they l
irradiated various test ~ specimens that included a Crompton 128-10 vertical indicator.
It is l
noted that the word "Crompton" and "128-10" H
were filled in subsequent to the initial issue of the document. This change is initialed by lL RCH and dated October 15 1987. The-PMS P.O.
to Radic tion Sterilizers was not in the file and could not be located by PMS for review.
Thus, the quality requirements invoked by PMS~
for the work could not be established.
Further, it could not be established whether 10 CFR Part 21 was invoked.
(c) Based on the PMS test and inspection fom attached to the EQ report, the serial iden-tification number of the vertical scale 1
indicator inspected for the test program was L
071586. However, no specific reference to L
this nointer was found in either the body of E
the EG report or the Wyle seismic test report.
(8) ACromptoninstrumentorderconfirmation(undated) to PMS was reviewed. The docurnent confirms the order of eight Crompton model 128, ANSI C39.1,
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ORGANIZATION:
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REPORT INSPECTION l
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RESULTS:
PAGE 27 of 41 9
instruments. -The document refers to customer order number DS 5105-7182.
(9) A Crompton C of C.(undated) w.s reviewed. This document does not explicitly _-identify the items being certified, but it does refer to WESCO DS order 5105-7178. The last digit in this order-L number does not match the order number for the Crompton document mentioned in the preceding paragraph. This document certifies.the referenced-items to be in accord 6nce with ANSI C39.1-1981.
L The document was signed by Mr. 1. A. Crane, Mod-Center and Marketing Manager.
t (10) A TVA letter of February 17, 1988 was reviewed.
The subject of the letter was vertical scale indicators for Sequoyah, Contract 86PLC-838656.
This letter acknowledges receipt of various PMS documents and provides coments on Rev. A of PMS qualification report.EEQP-071087.- The lette'r notes that Rev. A of the report reflects the fact that the vertical scale indicators that were tested and supplied on the contract were Crompton-128-10 instead of Westinghouse VX-252.
(11) PMS C of C CC-082986-2,- dated March 24, 1988, was reviewed. This document certifies that the Crompton vertical scale indicators supplied under this' con-tract are identical in form, fit, and function as units previously qualified by Westinghouse under TVA contract 91934. The document certifies the instrument in accordance with IEEE-323-1974 and IEEE-344-1975.
. (12) TVA order T-1015 was discussed with Mr. Hanner.
(a) He acknowledged that PMS did supply Crompton rather than Westinghouse vertical-scale 1
indicators, and that PMS initially issued e C of C for Westinghouse indicators. Mr.
Hanner went on to say that it really did not make any difference because TVA cancelled 9
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0RGANIZATION:i~ PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLINOIS
' REPORT.
INSPECTION
.NO.:
99901101/88-01 RESULTS:
PAGE 2G of 41 l}
this order around mid-1987. The BNL technical representative noted that correspondence was initiated by both PMS and TVA after mid-1987 and this correspondence suggested the order was still active. Mr. Hanner r :Mnted that i
as'far as he was concerned, the oroer was L
' cancelled. He also said he did not know the i
location of the two indicators for Sequoyah.
(b) The inspectors asked to see the laboratory equipment used by PMS for the accelerated l.
thermal aging testf og. 1r. Hanner stated the 1
oven was.previously :ocated in their facility L
but.that it was remeved after the testing and h
was now not availabla for inspection.
i (c) During this discussion, W. Manner stated L
that of the four originel TVA orders for l
Class 1E equipment, Ph5 only delivered Class IE equipment for one order. The other three equipment orders were Other cancelled or downgraded to delivery of commercial grade l
material.
L d.
SM-1072 (SMUD - Rancho Seco). The documentation file for SM-1072 was reviewed.
A summary of information found in the file and any additional or amplifying information is presented below:
i (1) SMUD P.O. RS 92009, dated December 5, 1986, was reviewed.
Information in the P.O. includes:
(a)
Items ordered:
20 - auxiliary relays, B
Westinghouse type AR, CAT No. AR440AR (b) The P.O. invokes IEEE-323 and states that similar relays were supplied under contract 8258, Westinghouse order No. SFJ-55893.
(c) The P.O. states that Westinghouse had per-formed seismic testing per IEEE-344-1975 under SMUD contract 8258 and a Westinghouse 4
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PLANNED MAINTENANCE SYSTEMS MOUNT VERNON, ILLINOIS REPORT:
INSPECTION t
.h0.:
99901101/88-01 RESULTS:
PAGE 29 of 41 1
t seismic certification report. The P.O.
requires PMS to supp.') a Westinghouse certi-ficate of conformance stating that the relays 1
will meet these requirements.
(d) 10 CFR Part 21 and ANSI C37.9 are invoked.
(2) PMS P.O. (P-121286-1) to WESCO, dated December 12, 1986 and Rev. I dated December 29, 1986 were reviewed.
(a)
Items ordered:
20 - auxiliary relays West-L inghoJse type AR, CAT No. AR440AR identified as Class IE.
(b) The P.O. invokes 10 CFR Part 21 and receipt inspection.
1 (c) A Westinghouse C of C, dated December 15, 1986, l
for PMS P.O. P-121286-1 and another dated.
L December 29, 1986 for PMS PO'P-121286-1, Rev.
I were reviewed.
The certificates were on letterhead from Westinghouse Electric Corpora-tion -Power Systems, Relay Instrument Division.
Other information in the certificates ir.cludes:
\\-
l~
'(a) The certificate is entitled:
SAFETY CLASS 1E EQUIPMENT CERTIFICATE OF COM-PLIANCE (P.O. Specified Instruments)
(b) The certificate certifies 20 relays, l-style AR 440AR.
(c) The certificate certifies that articles are in conformance with the order, that l
the equipment supplied is in accordar,:e with requirements called out in PMS purchase order P-121206-1 and the Vendor Quality Assurance Checklist.
U (d) There is not a QC control form number in the lower left-hand corner. The certifi-cate is signed by I. Crowe, Q.A. (Note:
Signature somewhat difficult to read).
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PLANNED MAINTENANCE--SYSTEMS
' MOUNT VERNON, ILLINOIS.
-REPORT INSPECTION NO.:. 99901101/88-01 RJ.SULTS:
PAGE 30 of 41 j
(4) As discussed in E.7.a.(7)(d) above, it was I
verified that.the Westinghouse C of C for the 20 AR 440 relavs was also fabricated by Mr.
4 Hanner. A copy of this C of C was inspected by Westinghouse.and found to by a counterfeit C of C.
(S) PMS C of C CC-121886, dated December 18, 1985, was reviewed.
This document certifies that items are in conformance with the order and a
are free of mercury. The document states the following codes and standards apply:
ANSI'C37.9 10 CFR Part 21.E.
ANSI N45.1 (Apparent typographical error) 10 CFR Part 50, Appendix B t.
L The certificate was signed by Mr. B.E. Roberts.
(6) PMS C of C CC-1218866-1 Rev. 1, dated December 19, 1986 was. reviewed. This docu-ment is'similar to the one discussed in (5) above except:
L (a) The document-includes ANS N45.2.2 level B.
(b) The PMS document also states the qualified life and replacement schedule is five years. Additionally. the document' states-the relays are identical to relays pro-vided to SMUD under West,inghouse order No. SFU-55893. Relay tag numbers 210-1 to 20 are recorded. The certificate.is signed-by Mr. B.E. Robe.ats.
i (c)
It is noted that the copy in the file contained some hand written comments, one of which added IEEE-344 to the list of codes and standards. Mr. Hanner 4
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_ ~...
]
o LORGANIIATION:
PLANNED MAINTENANCE SYSTEMS
. MOUNT-VERNON.-ILLINOIS REPORT
-INSPECTION NO.: 99901101/88 RESULTS:
PAGE 31 of 41 stated this was e marked-up copy of the PMS C of C that was returned from SMUD.
(7) SMUD ord.er SM-1072 was discussed with Mr.
- Hanner, y
(a) The inspectors asked Mr.-Hanner to explain the basis used by PMS to certify these relays to IEEE-323-1974. He said PMS cer-tified on the basis of infonnation contained in the SMUD purchase o. der.
(b) The inspectors asked Mr. Hanner to identify.
the basis for certifying to ANSI C37.90.
Mr. Hanner stated he could not recall the standard and did not know the basis used by PMS.
(c) Mr. Hanner ended this discussion by stating that all these questions were not important because SMUD cancelled p
the order to PMS for the relays.
o e.
SM-1110 (SMUD - Rancho Seco).
The' documentation pack-age for SM-1110 was reviewed. - A sumary of infornation t'
found in the file and any additional amplifying inior-mation is presented below:
(1) SMUD P.O. RQ-88-03-15102 with revision 1, dated March 9, 1988 was reviewed.
Infonnation in the P.O. includes:
E l:
(a)
Items ordered:
1 - indicating lamp, type EZC, style 4,49D187G23 with EQ documentation.
l (b) 10 CFR Part 21 is invoked, unless the supplier j
provides material identified as comerciel g
grade. A QA program approved by SMUD is required.
(c) The part is to be supplied without configu-ration change.
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-INSPECTION N O..: 99901101/88-01 RESULTS:
PAGE 32 of 41 (2) PMS C of C CC-020588-2 Rev.1, dated Fel.*uary I?,
1988 was reviewed. The document certifies:
(a) The material' supplied is Class IE and was processed in accordance witn the PMS QA program.
_7 (b) The item supplied is as called for in th-P.O. and no substitutions were made.
(c) The item meets the requirements of IEEE-323-1974 and IEEE-344-1975.
(d) The document was signed by Mr. Roger Riley and Mr. Rodney Hanner.
l (3) PMS Test and Inspection Form TI-020588-1 was reviewed.
item 2 of this report provides for a review of the TVA EQ report for cross reference.
-Accordirg to Mr. Hanner, this is apparently the qualification report for the same lamps that were p
supplied and qualified for TVA by NUTHERM. This item was initialed on the form by RCH on L
February 5,1988 under the column headed "results L
accepted."
.(4) SMUD order SM-1110 was-discussed with Mr. Hanner.
g (a) The inspectors asked Mr. Hanner to explain the o
basis for the certification to IEEE-323 and l
He stated the certification was' based ll on the TVA report. The inspectors asked to see the.TVA report. Mr.'Hanner stated he did not have the report.
Further, Mr. Hanner stated.
he never obtained the report for review, even though hi initials on~the. test and inspection.
form mentioned in (3) above indicates'other-wise.
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L (b) The inspectors askad Mr. Hanner to explain how 1
PMS determined that the lamp they provided on this order was the same as the lamps previously supplied and cualified by NUTHERM for TVA.
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l ed his earlier statement that L
Mr. Hanner r<
PMS considers tne parts are the same, if the parts have the same part number. This metter is' discussed in more detail in Section E.8 of this report.-
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SM-1111 (SMUD - Rancho Seco). The documentation file 1
for SM-Illl was reviewed.
A summary of information found in the file and ~any additional or amplifying information is presented below:
(1) SMUD P.O. RQ-88-05-15387, dated January 11, 1988, was reviewed.
Information in the P.O. include :
j (a)
Items ordered:
2 - Master Specialities backlighted pushbuttons, PN 051-24884-005
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with qualification.
(b) The P.O. invokes:
QA program approved by'SMUD 10 CFR Part 21
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Items must be same kind as previously environmentally qualified.
IEEE-323:and IEEE-344.
(2) PMS P.O. 011388-1, dated January 13, 1988 to Master Specialities was reviewed.
(a)
Items ordered:
2 - Master Specialities PN 851-24884-005'with qualification report and C of C.
J (b) The order identified the material as commercial grade subject to receipt j
inspection by FMS.
(3) A review of the PMS-Approved Vendor List (AVL)
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PAGE 34 of 41 showed Master Specialities was not on the list at.
the time the P.O. was placed.
However, they were added to the list by Mr. Hanner on May 10,1988.
1 The inspectors asked what basis was used for adding.
Master Specialities to the AVL. He stated that
I just added them to the list."
(4) This package was not inspected any further after Mr. Hanner advised that PMS had not yet received the pushbuttons from Master Specialities.-
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SM-1114 (SMUD - Rancho Seco). The documentation file for SM-1114 w6s reviewed. A sunimary of infomation found in the file and any additional or amplifying information is-presented below:
(1) SMUD P.O. RQ-88-03-27844, dated February. 12, 1988, i
was reviewed.
(a)
Items ordered:
1 - Agastat time delay relay.
equipped with one auxiliary switch contact.
PN E7012AB002L. The items to be supplied are items that have been environmentally qualified, a
Replacement must be of the same kind (same material, model, functional properties, etc).
(b) The P.O.-invokes:
10 CFR Part 21 and QA program approveo by SMUD, IEEE-323 and 344,.
Certification that the seismic quali-fication of.the switch enveloped the seismic qualification'of the;Agastat relay as qualified by testing documented in AMERACE Corp. test report ES-1000, Rev. A.
Certification that addition of the
. switch to the relay does not-impact the seismic qualification of the relay.
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ORGANIZATION:
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PAGE 35 of 41 (2) The P.O. from PMS to the subvendor supplying the material was not in the. file and could not be located at PMS for review.
(3) SMUD Receiving Discrepancy Report dated February 13, 1988 was reviewed. This document. identifies defi-ciencies in the receipted material.
Deficiencies noted indicate:
(a) The C of C did not indicate conformance for seismic qualification per AMERACE T.R.
ES-1000, Rev. A.
(b) The C of C did no+. contain a statement that I
the additional switch does not impact the seismic qualification of the relay.
(c) No environmental qu611fication test reports were received.
/4) PMS letter to SMUD, dated February IS, 1988, was reviewed. This letter responds to the SMUD receipt inspection deficiencies and forwards Rev.
1 of the C of C.
(5) PMS C of C CC-021288-1, Rev.1, dated February 15, 1988 was reviewed. This document:
l (a)
Identified the equipment as Class 1E and
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l-certified the equipment was processed in accordance with the requirements of the SMUD P.O. which included AMERACE Test Report 3
ES-1000, Rev. A.
(b) The equipment..as been qualified in accor-dance with the requirements of'IEEE-323-1974 and IEEE-344-1975..The additional auxiliary switch (suffix 'L') does not affect-the seis-mic qualification of the Agastat relay.
j (c) No environmental qualification test reports-
-were received.
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PAGE 36 of 41 (d) The document was signed by Messers. Roger Riley and Rod Hanner.
(6) Subsequent to the initial delivery.of the Agastat relay ar.1 auxili3ry switch, PMS. submitted various components to Wyls Laboratory for seismic testing. The Agastat relay and auxiliary switch.
were among the items submitted for testing.
Wyle report 49281-1, dated April 12, 1988, documents the testing.
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(a) PMS P.O. P-032888-1 to Wyle for the testing was not in the file and could not be located at PMS for review.,
(' j According to Mr. Hanner, the test fixture o
1 L
e and equipment submitted to Wyle was-the same j
L test fixture observed during the initial NRC L
inspection team tour of the facility. Mr.
Hanner stated he initiated this seismic testing to obtain additional assurance that the equipment was: satisfactory.
Inspection team observations of the test fixture revealed.
=i b
that the part number on the Agastat relay that -
R was tested was 7012AB002L.
However..the per-
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l' manent part number had been covered with a.
1 label and the part number on the label was E7012AB002L. This latter number is the part number ordered by SMUD in P.O. RQ-88-03-27844 and this part number also appears in the list of material tested and documented ~in Wyle L.
report T.R. No. 49281-1.
Based on a comparison l-of the. numbers on the. label, relay, and Wyle h
test report, it appears that Wyle did not:
verify the actual manufacturer's part number; instead, Wyle used the number on the label'for its test report.
(7) SMUD order SM-1114 'was discussed with Mr. Hanner.
(a) The inspectors asked Mr. Hanner to identify the basis for seismic certification to IEEE-344 as well as the additional seismic certification required because of the auxiliary switch.
Mr.
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PAGE 37.of 41
'l Hanner stated PMS based their certification on 1
the AMERACE qualification report ES-1000, Rev.
A.
However, Mr. Hanner also stated PMS did-H not have the report and had not reviewed the report. As far as the auxiliary switch impacting the seismic qualification of the relay, Mr. Hanner stated the switch only weighed 1.5 ounces ind that based on his H
experience, this would riot ' affect the relay's seismic qualification. He stated PMS did not perform any formal analysis.
He said that he considered his earlier judgment to l
be accurate.
The inspectors noted that this conclusion appeared to be premature-because some of the equipment, including the Agastat relay, exhibited contact chatter during the Wyle seismic testing,'and the acceptability of the contact chatter needs to be analyzed l
during an engineering evaluation.
(b) The inspectors asked Mr. Hanner to identify 'the basis for certification to IEEE-323. He L
reiterated a statement that he had made earlier to another NRC team member. His understanding is that if a harsh environment is not s >ecified, i
~
then the qualification of an item to IE EE-344 was sufficient in itself to also certify to IEE.5323. This item is discussed in more detail 1
Tiilection E.8 of this report.
(c) Mr. Hanner was asked if he could explain the significance of the prefix "E" in the-Agastat part number identificction. He said that he-really did not know, but that it might have something to'do with the nuclear qualifica-tion status of the part. The inspectors indi-cated that this was, in fact, the case.
(d) Mr. Hanner war asked to identify the source of the seismic spectrum for the OBE and SSE that were supplied to Wyle Laboratories for the. seismic testing of the test fixture that included the Agastat relay and switch.
He-stated that the seismic spectrum data was taken from a SMUD specification GS-015,
" Seismic Qualification Requirements for
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PAGE-38 of 41 Class 1E Controls and Instrumentation Devices" that was supplied by SMUD on a
' previous order. Mr. Hanner said he did not know whether the seismic spectrum data supplied to Wyle was at least as severe as that used for the qualification documented in AMERACE Report ES-1000, Rev. A.
d h.
Review of Additional Documentation Files.
(1)-Duringthecourseoftheinspection,the following additional customer order documentation-i files were reviewed.
Infornation in the files suggested that the orders never progressed past the customer solicitation and PMS proposal stage; however, hardware may have been supplied to the
-licensees listed below or other unnamed licensees:
r PMS REF. NO.
CUSTOMER IP-1040 Illinois Power
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WP-1068 Wisconsin Electric VE-1065 VEPCO I
8P-1091-Bechtel Power (?)
y GEN-8 Portland GE OP-1039-
-Omaha Public Service S-1037/1038
.SMUD S-1064 Not recorded SM-1090 Not recorded SM-1117 SMUD (2) The following documentation file was reviewed and determined to be a commercial grade order-L PMS REF. NO.
CUSTOMER
(
Certificates of Compliance (C of C)
(a) During the course of the PMS P.O. documentation review, the inspectors asked the PMS president, Mr. Hanner, to summarize how many times PMS has actually conducted environmental (non-seismic) qualification testing to provide a basis for the PMS C of C statements that Class IE components meet the requirements of IEEE-323 1 The PMS president _ replied that PMS had only performed-D f
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PAGE-39 of 41 1
environmental (non-seismic) testing on two occasions. One test program was performed in response to PSE&G P.O. P1-127398, dated February 24, 1986'(PMS N0. P-1010). This PSE&G order was for j
qualification of a contact assembly. The other test program was perfomed to qualify parts being supplied to TVA on four different contracts. These TVA contracts included:
PMS No.
CONTRACT No.
PLANT ITEM
.T-1005 86PLF-838450 Browns Ferr -
Vertical Scale Indicator
-T-1015 86PLC-838656 Sequoyaii Vertical Scale Indicator T-1046 86KLD-839051' Bellefonte DC Contactor T-1036 86PLB-838855 Browns Ferry Precision Power Resistor k
(b) During-various discussions Mr. Hanner discussed his under-standing of the extent of his obligations for certifying compliance with:!EEE-323.. Mr. Hanner stated his under-standingL s that performance of seismic testint under i
l IEEE-344 enveloped the requirements in IEEE-322 for mild environments. Thus, his position was that if he satisfied l_
requirements for certifying qualification in accordance j _
with IEEE-344, he could automatically certify qualifica-l; tion for IEEE-323, for mild environments. The inspectors L
stated that the requirements in IEEE-323 and 344 are separate i
L and distinct and that-qualification to IEEE-344, by itself, l,
is not sufficient to certify qualification to IEEE-323.
(c) Mr. Hannar stated he also understood that if some other organization had qualified a part in accordance with a standard such as IEEE-323 or IEEE-344, he could use this qualification as a basis for supplying the same parts and certifying them by similarity. The inspectors acknowledged m
that this approach could be-an acceptable method of qualifi-cation per paragraph 5.4 of IEEE-323 providing the new parts are the same as the parts previously qualified and providing that the specified environmental conditions for the new parts-are the same (or less severe) than the environmental r.onditions used for the initial qualification. However, the inspectors stated they did not understand how PMS could supply a meaningful C of C~using this approach to qualification without assuring that the parts are the same and without performing a techt.ical evaluation of the new part environmental conditions compared to the original qualification.
Further, the inspectors did not understand how PMS could be performing meaningful evaluations l
without reviewing the original part qualification reports.
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(d) During various discussions, Mr. Hanner discussed the PMS basis for certifying that replacement ~ parts are similar to parts supplied and qualified at some earlier date. He i
stated _PMS considers that part number identification pro-vides sufficient control. Therefore, Mr. Hanner believes PMS can certify parts as being similar if they have the same part number. The inspectors noted that this is a concern because there is really " assurance that every manufacturer will assign a new part numoer when changes are made that may be considered insignificans by the manufacturer, but may, in fact, affect the. nuclear safety qualification status that the manufacturer knows nothing about.
9.
PMS Purchase Order Placement with Subcontractors 1
(a); The inspectors asked Mr. Hanner if he could explain why PMS P.O. documentation to suppliers is missing in so many cases.
Mr. Hanner stated that many PMS orders are actually placed by 1
phone.
In some cases, there is no fonnel documentation of the i
i telephone order.
In other cases, a PM! P.O.' document'is pre-pared-and filed. Copies of written P.O. are not.always for-warded to tha baontractors.
(b) The inspectors asked n a PMS could assure that necessary tech-nical, quality -and wher applicable 10 CFR Part 21 requirements
.are being carried out by their supplier if written P.O.'s are not used. Mr. Hanner did not directly answer the question, l
However, he stated:
j (1) Placing P.O. by telephone'is a common way of doing business.
(2) Most of the_ parts purchased by PMS are simple, and can be identified by name and part number. These parts do not renuire additional explanation of requirements.
- 10. Measuring and Test Equipmeat (MTE) l No MTE was present in the PMS facility, except for a small vibra-tion table. that had not been initially placed in service. Mr.
Hanner also stated that the oven equipment that was_ located at PMS to conduct a thermal aging test was subsequently removed and not available for inspection.
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- 11. PMS Personnel On a number of occasions during the course of the inspection, the inspection team determined that it would be beneficial to discuss items with Mr. Riley. Mr.-Hanner stated that Mr. Rile knew the NRC team was inspecting PMS, but that he (Mr. Riley) y L
had decided not to talk to the members of the NRC team. Mr.
Riley was. listed as.the :hief engineer for PMS and more recently l-was also given the title of QA Manager after Mr. Roberts
[
resigned from the PMS 0;ganization..
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- 12. PMS Personnel Contacted
[
Mr. R. Hanner Mr. R. Riley **
l Mr. B. E. Roberts **
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Interviews were conducted after the inspection and were not L
conducted at the PMS facility.
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