ML20127N705
| ML20127N705 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1991 |
| From: | Moist R, Vandenburgh C Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20127N682 | List: |
| References | |
| REF-QA-99900707 NUDOCS 9302010039 | |
| Download: ML20127N705 (6) | |
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ORGANIZATION:
HEVI-DUTY / NELSON TULSA, OKLAHOMA REPORT NO.:
99900707/91-01 CORRESPONDENCE Eva Moses, Quality Assurance Supervisor ADDRESS:
Hovi-Duty / Nelson P.O.
Box 726 Tulsa, Oklahoma 74101 NUCLEAR INDUSTRY Provides heat tracing material for nuclear ACTIVITY:
safety-related applications INSPECTION November 5-6, 1991 CONDUCTED:
SUBMITTED:
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/O~3 'N handolph N. Moist Date j
Reactive Inspection Section No. 2 Vendor Inspection Branch W'W APPROVED:
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Chris A. VanDenbpfgh, Chief
Date Reactive Inspectron Section No. 2 Vendor Inspection Branch INSPECTION BASES:
10 CFR Part 21, 10 CFR Part 50, Appendix B INSPECTION SCOPE:
Follow-up to a Virginia Electric & Power Company (VEPCO) 10 CFR Part 21 notification regarding heat tracing material that Hevi-Duty / Nelson (Nelson) supplied to VEPCO and to determine the scope and breadth of Nelson's supply of safety-related material to licon-sees from 1984 to 1988.
PLANT SITE North Anna Power Station APPLICABILITY:
9302010039 930127 PDR GA999 EMVNELE 99900707 PDR 1
1 INSPECTION
SUMMARY
The inspection determined that Nelson submitted incorrect Cer-tificates of Conformance (COC) for boat tracing materials that did not meet the quality requirements for four Virginia Electric
& Power Company (VEPCO) purchase orders due to a breakdown in Nelson's quality assurance (QA) program.
The inspection iden-tified that Nelson had taken appropriate corrective actions for this deficiency and no longer supplied safety-related heat tracing material in accordance with Part 50, Appendix B, of Title 10 of the Code of Federal Regulations (10 CFR Part 50, Appen-dix B).
In addition, the inspection determined that Nelson provided the heat tracing material as safety-related to only one licensee (i.e., VEPCO) during the time frame that Nelson manufac-tured the product as safety-related material (i.e.,
1984 to 1988).
Accordingly, a Notice of Nonconformance was not issued for this occurrence.
2 INSPECTION FINDINGS AND OTHER COMMENTS 2.1 Rackcround Since its organization in 1937, the Nelson manufacturing plant has been located in Tulsa, Oklahoma.
Nelson developed, designed, and manufactured heat tracing systems from 1972 to 1978 at this facility.
The heat tracing systems included cabling, temperature controllers, and alarm cabinets.
Heat tracing systems are required to keep boric acids and caustics in water from crystal-lizing or precipitating out of solution in order to keep piping systems in a state to perform their intended functions.
Nelson has been supplying licensees with heat tracing systems since IJ74 and spare components such as heat tracing cables, splice kits, and end caps since 1984.
In 1974, the Stone and Webster Engineering Corporation, acting as a representative of VEPCO, procured heat tracing systems from Nelson for use in the North Anna Power Station.
Although Nelson could not provide the inspector with the original procurement specifications for this order, Nelson indicated that it had imposed the QA requirements of 10 CFR Part 50, Appendix B, on the original procurement specification.
2.2 VEPCO's 10 CFR Part 21 NotificaticB On August 12, 1988, VEPCO submitted a 10 CFR Part 21 notification to the NRC regarding the heat tracing material that Nelson had furnished to VEPCO.
This notification indicated that Nelson had supplied the heat tracing material as a commercial-grade item and had not manufactured the material in accordance with the require-ments of 10 CFR Part 50, Appendix B or 10 CFR Part 21, which were imposed in the VEPCO purchase orders.
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i During the NRC inspection, the QA supervisor stated that the General Signal Company (the owner of Nelson) suspended Nelson's 10 CFR Part 50, Appendix B, QA program in late 1985 because of I
economic concerns.
The QA supervisor thought that this event was documented by a letter from General Signal, but could not find the letter in Nelson's files.
Although the QA supervisor con-tacted General Signal's legal department to ask them for a copy of the letter, the letter could not be located.
Although Nelson could not document this event, Nelson did provide the NRC inspector two Nelson internal letters to the staff concerning this decision.
The first letter was dated April 30, 1982, and signed by the Marketing Vice President of Construction Products.
The second letter was dated August 4, 1988 (one day after the VEPCO supplier audit), and signed by the President of Nelson.
In the first letter, Nelson indicated that its standard response to any request for quotation for a nuclear project was to take extaption to any stated required qualification program.
This decision was based upon the many changes in the applicable standards that governed the qualification of products for nuclear applications and the ever-changing interpretations of' these standards by engineering firms and their clients.
In addition, the letter indicated that Nelson was previously able to treat most nuclear applications with a " broad brush", generalized approach.
However, costly experiences had proven that this approach was no longer acceptable.
In the second letter, Nelson's president stated that Nelson had refused to accept purchase orders which imposed the NRC require-ments outlined in 10 CFR Part 21 for the past several years.
In addition, Nelson would no longer provide material in accordance with the QA requirements of 10 CFR Part 50, Appendix B, and that all products supplied to the utility market (regardless of nuclear or fossil fuel application) would be of commercial-grade quality.
The NRC inspector noted that these letters were only distributed internally and were not provided to Nelson's cus-tomers.
Nelson also provided the NRC inspector a copy of a VEPCO " Request for Quotation," dated May 22, 1986, which stated that the heat tracing material was to be furnished as nuclear safety-related and in accordance with the QA program approved by VEPCO.
Nel-son's response to VEPCO on June 3, 1986, took exception to the paragraph referring to nuclear safety-related.
The response stated that all the materials that Nelson supplied were industry-grade materials and would not be furnished as nuclear-qualified.
Despite these disclaimers, Nelson accepted the VEPCO purchase order without any revisions.
Additional information regarding why Nelson erroneously accepted these purchase orders without revision and the corrective action Nelson took to preclude a 3
t recurrence of this problem are discussed in Section 2 J of this inspection report.
In a letter to VEFOO on August 8, 1988, Nelson responded to VEPCO's concerns regarding the 10 CFR Part 21 notification.
This response recommended that the heat tracing system at North Anna be reclassified as a non-safety-related system.
Nelson made this recommendation in accordance with the recommendations of the Institute of Electrical and Electronic Engineers (IEEE) Standard 622-1979, "A Recommended Practice for the Design and Installation of Electric Pipe Heating Systems for Nuclear Power Generating Systems."
The foreword of IEEE Standard 622-1979 states that:
"The recommendation for not classifying electric pipe heating systems as Class 1E is based on station operat-ing criteria.
In its investigation of electric pipe heating systems for critical process piping, the work-ing group could find no evidence that a properly designed system would come under a Class 1E classification for proper performance."
Despite these recommendations, the NRC inspector noted that the 10 CFR Part 21 notification from North Anna indicated that all of the safety-related heat tracing systems could not be reclassified as non-safety-related.
Therefore, the inspector concluded that there was some safety significance related to Nelson's failure to manufacture the material in accordance with the Appendix B qual-ity assurance requirements.
2.3 Procurement Document Control The NRC inspector interviewed several personnel to determine the manner in which Nelson received, processed, and distributed purchase orders, including the clerk who processed the VEPCO purchase orders from 1986 and the manager of customer services who was responsible for training those clerks.
The inspector also reviewed the manner in which the quality requirements of purchase order were passed on to Nelson's QA department for procurements.
The customer services department received both written and verbal purchase orders.
Clerks checked the applicable blocks on a quality plan form that listed the technical and quality require-ments.
The quality plan form did not address the specific QA requirements for nuclear safety-related material such as 10 CFR Part 50, Appendix B, or the reporting requirements for basic components addressed in 10 CFR Part 21.
Because the quality plan form did not recognize and the clerks were not aware of the meaning or content of these nuclear-unique requirements, this information was not translated onto the quality plan form.
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NRC inspector also identified that the cestomer services depart-ment furnished the quality plan form to tne QA department without l
attaching the customer's purchase order.
The Nelson QA plan for procurements required that a Na? son COC be furnished with each shipment.
Before signing the COC, Nelson's QA supervisor verified that Nelson completed a certified test report and an inspection report to support the COC.
No further action was taken by the QA department to verify the accuracy of the quality plan form before a COC was issued.
Before 1987, some COCs were signed by the QA supervisor at Nelson's manufacturing plant located in Homer, Louisiana.
However, the heat tracing cable was manufactured and tested at the plant in tulsa, Oklahoma, before the material was shipped to the Homer plant.
The NRC inspector verified that the procurement file for the VEPCO procurements contained a certified test report and an inspection report.
Nevertheless, the inspector concluded that an inadequate QA program caused Nelson to submit the incorrect COC to VEPCO and resulted in providing heat tracing material that failed to meet the original purchase order requirements.
This failure occurred because the customer service clerks had not been properly trained to the meaning of 10 CFR Part 21 or 10 CFR Part 50, Appendix B; the quality plan form was inadequate; and the QA department failed to ensure that the customer's purchase order was correctly transcribed.
As corrective action for one of the findings of the VEPCO audit conducted on August 1-3, 1988, Nelson changed their QA procedures to require that each purchase order be submitted to the QA department for review and that each such purchase order have the quality plan attached.
2.4 Other Licensee Procurements The NRC inspector reviewed customer lists and purchase order logs completed from 1984 to 1988 (the approximate date on which Nelson terminated their Appendix B QA program) to determine if other nuclear licensees had purchased safety-related material from Nelson in a similar manner.
Although the purchase orders indi-cated that licensees had purchased the heat tracing material as commercial-grade items, there was only one instance where the material was requested or provided as safety-related material.
This instance was the VEPCo purchase described in section 2.2 of this inspection report.
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3 PERSONNEL CONTACTED E.-Moses,; Quality Assurance Supervisor--
S.-Hocker,;-Heater Product Group.
-S.
Talbot, Manager of Marketing Service Group.
D. Brown,_ Manager;of Engineering Attended both the entrance and exit meetings-of November 5-and 6,-1991-L' s
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