ML20136E470
| ML20136E470 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1985 |
| From: | Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Erhardt J TELEMECANIQUE, INC. |
| References | |
| REF-QA-99901011 NUDOCS 8601070028 | |
| Download: ML20136E470 (4) | |
Text
- o g UNITED STATES E" e. NUCLEAR REGULATORY COMMISSION
$ WASHINGTON, D. C. 20555 o '*
- December 31, 1985 Docket No. 99901011/84-01 Telemechanique, Incorporated ATTN: Mr. J. V. Erhardt Vice President Engineering Control Operation 2002 Bethel Road Westminister, Maryland 21157 Gentlemen:
Thank you for your letters dated May 15, 1985 and July 23, 1985, responding to the noncompliances identified in our Inspection Report 99900279/84-01.
Please note that we assigned a new docket number to correspond with your recent change of name and ownership.
Your response to the nonconformances is unacceptable. Owners of nuclear power plants and their representatives audit you for compliance with 10 CFR 50 Appendix B to assure that the Motor Control Centers supplied by you meet all applicable technical and quality requirements. During these audits, they assess the effectiveness of your control of contractors and subcontractors by reviewing purchase orders issued to your subvendors for compliance with all the technical and quality requirements imposed on you. We disagree with your interpretation of the applicability of 10 CFR Part 21 and 10 CFR 50 Appendix B requirements to your subvendors. You have failed to convey the quality requirements imposed on you to your subcontractors. Please note that the definition in 10 CFR Part 21, Section 21.3, of a commercial grade item states that it is not part of a basic component until after dedication. Dedication involves adequate evaluation of the item for safety-related purposes which includes a determination that it will meet appropriate technical and seismic requirements. Also, the quality program
'of suppliers of commercial grade or off-the-shelf itens for use in safety-related applications must meet the intent of pertinent requirements of 10 CFR 50 Appendix B in order to inaintain the qualification of previously tested equipment or you, as the purchaser and dedicator, must test and inspect each item to assure that each item will meet the technical and seismic requirements. Although you have stated that "Siemens-Allis chose to maintain a quality assurance program considered adequate to assure compliance to the industry standards for their products," the following examples would indicate that this method of assuring quality has been ineffective.
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i Telemechanique, Inc. December 31, 1985
- 1. Pioblems Noted at Nuclear Power Plants
- a. Seabrook Nuclear Power Station (SNPS) informed the NRC in a letter dated May 17, 1982, that all three poles of molded case,100 ampere Frames, E2, E4, F6, HE4 and HE6 circuit breakers, manufactured by Siemens-Allis, Bellefontaine, Ohio, failed to simultaneously close when switched from "0FF' to "0N" position.
- b. During an inspection conducted at SNPS in November 1984, our inspectors determined that SNPS identified several nonconforming conditions in Motor Control Centers (MCCs) manufactured by you. These inspection results substantiate our position that the tests performed by you on the assembled MCCs are inadequate,
- c. Shearon Harris NLclear Power Plant (SHNPP) reported to the NRC on January 22, 1985, that binding was experienced in the two-speed starter mechanical interlocks which prevent low speed operation of fan coolers.
It was stated that due to variations in tolerance, the vertical interlock installed between the tie contactor and the corresponding starter was binding, preventing the full transfer between the high and low speed. In an attempt to go from high speed to low speed the low speed contactor would be prevented from closing, and would prevent the motors from performing their safety function of driving fan cooler units that are needed to provide de-humidification and air-mixing of the containment atmosphere.
Callaway Nuclear Power Plant reported similar problems in size 5, two-speed starters for Containment Cooling Fan Motors on April 10, 1984.
- d. Recently, NRC inspectors reviewed a purchase order N-29326, dated March 18, 1985, issued by Portland General Electric Company (PGE) for the supply of 4 class 1E JL-3-T225 circuit breaker trip units. The ITE catalogue indicates that the JL-3-T225 unit is equipped with both 225 ampere thermal overloads and 2000 ampere instantaneous overcurrent elements. Even though the purchase order was addressed to ITE, you supplied the trip units along with a certificate of conformance (C0C) stating that the trip units meet the published technical trip data.
When PGE tested these trip units, they discovered that the thermal overcurrent trip elements were not installed in the trip units. It appears that your dedication process for upgrading commercial grade items to nuclear grade is inadeouate or nonexistent.
t Telemechanique, Inc. December 31, 1985
- 2. Problems Noted at the Vendor Facilities
- a. ITE - Imperial, who originally manufactured molded case circuit breakers and qualified one of the circuit breakers in the early 1970s, implemented a quality assurance program complying with 10 CFR 50 Appendix B to assure that all subsequent circuit breakers produced would meet or exceed the performance and quality of the original circuit breakers. The circuit breaker manufacturing facility has changed ownership twice since then.
However, as stated in your letter dated May 15, 1985, Siemens-Allis does not implement a quality assurance program complying to 10 CFR 50 Appendix B and, therefore, cannot assure that the performance and quality of the circuit breakers will meet or exceed the original requirements.
- b. The molded case circuit breakers, installed in the motor control centers supplied by you, are required to trip when instantaneous overcurrents are sensed within the time published in the time-current s curves. Power plants are required to periodically verify that the circuit breakers meet the time-current characteristics to assure the integrity of the relay coordination necessary to meet General Design Criteria 18 and 21 of 10 CFR 50 Appendix A. Single failure criteria may be jeopardized if circuit breakers installed in MCCs fail to trip within the stipulated time.
- c. The published data indicate that the circuit breakers are capable of interrupting current in the magnitude of 12,000 amperes which is much more than the maximum instantaneous magnetic trip of 1000 amperes for sizes40-100 ampere frame breakers. It therefore does not appear that circuit breakers would be damaged during an upper instantaneous trip limit verification.
In view of the above examples, we do not agree with your stated position that the quality control measures you have implemented are adequate.
Please notify us, in writing, of the steps you intend to take to correct the nonconformances identified in our report 85-01.
Sincerely, i' 4. w Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement
- j Telemechanique, Inc. December 31, 1985 Diartribution:
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