ML20148M725
| ML20148M725 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1988 |
| From: | Baker E, Petrosino J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20148M621 | List: |
| References | |
| REF-QA-99900779 NUDOCS 8801280346 | |
| Download: ML20148M725 (24) | |
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLINOIS REPORT INSPECTION INSPECTION NO.: 99900779/87-01 DATE: 11/16-20/87 ON-SITE HOURS: 172 CORRESPONDENCE ADDRESS: Hutherm International Incorporated 1 ATTN: Mr. L. Hinson, President 501 South lith Street Mount Vernon, Illinois 62864 ORGANIZATIONAL CONTACT: Mr. Ronald Heifner - QA Manager TELEPHONE NUMBER: (618) 244-6000 l NUCLEAR INDUSTRY ACTIVITY: Nuthenn International Incorporated (NI) fabricates, designs, tests and qualifies electrical devices and control systems for both commercial and military nuclear facilities. Approximately 98 percent of NI's i business is nuclear related.
M ASSIGNED INSPECTOR: nw ! //88 Date
/J. MInspettion Pe/fdsino,~ Prodram Section Development and Reactive (PDRIS) i OTHER IN5PECTOR(S): R. Poist, NRC/NRR T. Tinkel, BNL APPROVED BY: (c U 7g E. T. Baker,' Acting Chief, PDRIS, Vendor Inspection Branch Date {
INSPECTION BASES AND SCOPE:
A. BASES: Appendix B to 10 CFR Part 50, and 10 CFR Part 21.
B. SCOPE: Follow-up to allegations concerning alleged NI disregard of the NRC QA program requirements in regard to its execution of quality activities.
PLANT SITE APPLICABILITY: Bellefonte(50-438/439); Braidwood (50-456/457);
Browns Ferry (50-259/260/296); Byron (50-455); Clinton (50-461); Diablo Canyon (50-323/275); Dresden (50-237/249); LaSalle (50-373/374); Limerick (50-352/
353); Nine Mile Point (50-220/410); Oyster Creek (50-219); Peach Bottom (50-277/278); Perry (50-440); Quad Cities (50-254/265); (continued on next page) 8801280346 880125 00j p E
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT -
INSPECTION en . oconn77o/n7-n1 RESULTS: PAGE 2 of 24 PLANTSITEAPPLICABILITY(continued): RiverBend(50-458);Se 328); Susquehanna (50-387/388); Three Mile Island (50-289/320)quoyah
- Watts Bar (50-327/
(50-390/391); and Zion (50-295/304).
A. VIOLATIONS:
None.
B. NONCONFORMANCES:
- 1. Contrary to Criterion II, "Quality Assurance Program," of Aptendix B to 10 CFR Part 50, and Section 2 of the NI QA manual (QAM):
- a. Section 10 of the QAM does not prohibit a person from inspec-ting their own work;
- b. Section 10 of the QAM does not require QA inspection and monitoring activities in NI's equipment testing facility; and
- c. NI has not established procedures to control its periodic use ofrentedmeasuringandtestequipment(M&TE).
- 2. Contrary to Criterion III, "Design Control," and Criterion VI, "Document Control," of Appendix B to 10 CFR Part 50; Sections 3.0, 4.0, and 5.0 of NI's QAM and NI QAP #3.0.00:
- a. NI "Qualification Pesults Index" (QRI) forms, which are used as specific hardware instruction riders to NI's generic functional and test procedures that delineate design parameters for testing, do not indicate that an independent technical review was performed. Additionally, QRI's do not correctly and/or fully translate the design requirements into test parameters and quality standards;
- b. Equipment qualification procedures and functional test proce-dures did not indicate that an independent review was performed to verify technical adequacy; and
- c. In the pre-1986 time period the engineering manager d'id not perfom the required design verification activity for several design drawings.
'.' I ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS j REPORT INSPECTION wn . ooonn770/A7_n1 RESULTS: PAGE 3 of 24
- 3. Contrary to Criterion X, "Inspection," of Appendix B to 10 CFR Part 50, NI is not providing adequate QA inspection / verification control of quality related activities as follows:
- a. NI has failed to implement the QA inspection or monitoring d program for its equipment testing facility;
- b. NI management allows the same technician who performed equipment test activities to inspect his/her own work and sign the "QA inspector approval" block; and
- c. NI management allowed the equipment test facility supervisor to sign the "QA Approval" block for testing results that were performed by his technicians,
- 4. Contrary to Criterion XI, "Test Control," of Appendix B to 10 CFR Part 50, NRC observations of equipment tests and record reviews indicate that NI is neither adequately controlling nor effectively monitoring its safety-related activities that are being performed in its equipment test facility.
- 5. Contrary to Criterion XVII "Quality Assurance Records," of Appendix B to 10 CFR Part 50, adequate records were not in evidence to indicate personnel qualification for several past and present NI employees.
The following NI employee files [ identified by employee initials]
were found to be either incomplete, incorrect, or indeterminate as to the relevant experience and/or education: HB, CG, GW, SS, DW, GJ, SDJ, LH and PB.
- 6. Contrary to Criterion XVIII, "Audits," of 10 CFR Part 50, NI manage- I ment allowed the last two QA department annual audits to be led by a QA inspector that has direct QA responsibilities. The report numbers are QA-86-AE, dated 12/23/86, and QA-85, dated 12/06/85.
C. OPEN/ UNRESOLVED ITEMS:
Several aspects of the allegation and associated issues were not fully reviewed or evaluated due to the NRC inspection team time constraints.
Therefore, the following items will be classified as open items pending subsequent NRC or vendor actions:
Personnel Qualification (See Section E.4.a)
Correct Performance of Testing (See Section E.4.b)
Radiation Testing Failures of Devices (See Section E.4.c)
(4 Procurement and Receipt Inspection Control (See Section E.4.f)
(5 Quality Assurance Procedures / Instructions (See Section E.15) l
ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION wn - ooonn770/A7 01 RESULTS: PAGE 4 of 24 (6) Audits (See Section E.4.g)
(7) 10 CFR Part 21 Potentially Reportable Items (Associated Allegation Aspect)
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
Neither reviewed nor discussed.
E. INSPECTION FINDINGS AND OTHER COMMENTS:
- 1. Entrance and Exit Meetings The NRC inspection team informed NI management of the scope of the inspection during the November 16, 1987 entrance meeting, and summa-rized the inspection findings, observations, and NRC staff concerns during the exit meeting on November 20, 1987.
- 2. Nutherm Management Commitments The Nutherm management staff recognized its QA program weaknesses after the NRC inspection team started to identify problem areas, and stopped all of its safety-related activities in order to assure its QA program implementation was valid. Even though NI was not obligated to the Commission to take corrective action until after it received this report, NI voluntarily committed to stop its current work, review its procedures and instructions that control its current activities, revise the documents as required, and ensure that the required independent technical adequacy reviews are performed. The NRC staff believes that this approach is appropriate for the circum-stances.
- 3. Background This inspection was conducted to examine allegations that have been received by the NRC staff with respect to the method in which NI implements its nuclear quality related activities. The specific areas of concern that were communicated to NRC staff members include the following: (a)personnelqualifications,(b) correct mance of testing and inadequate / incomplete procedures, (c)perfor-correct-ive action of test deviations, (d) recording of raw test data, (e) adequate translation of design bases, (f) procurement / receipt inspection control, and (g) external audits.
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.- - l ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION wn . 000n0774/A7-01 RESULTS: PAGE 5 of 24 :
- 4. Review of Allegations 1
The NRC inspection team observed functional and equipment qualifica- '
tion tests that were being performed by NI personnel, reviewed NRC licensee purchase order packages, personnel education / qualification d records, hardware qualification / test result records, internal audit I reports, program implementing procedures / instructions, design draw-ings/ specifications, and other associated documents. The inspectors also conducted interviews with NI personnel at various levels to gain an understanding of how the daily NI quality activities were l carried out.
Not every aspect of the allegation was reviewed due to the inspec-tion team time constraints; however, for each aspect of the allega-tion that was reviewed, the results are described below,
- a. Personnel Qualifications:
Allegation Aspect: (1) Personnel with no technical background were given the responsibility to write technical procedures, plans, and reports; (2) would falsify information; and (3) func-tional testing was not performed by qualified personnel.
Inspection Finding:
(1) It was detennined that NI would typically allow non- l technical personnel, such as secretaries, to write technical procedures and reports. It should be noted that l this practice is not necessarily incorrect, provided that ,
a technically competent and qualified person performs a l review for technical adequacy of the document. However, l it was revealed that NI's procedures and instructions that were written by non-technical personnel did not always receive technical review and a proval (Nonconfor-mance B.2 was identified in this area .
(2) The efforts of the NRC inspection team did not reveal d any evidence that would substantiate this allegation i aspect; (3) Functional testing was not specifically reviewed to deter-mine whether or not qualified personnel were performing the tests in the past; however, current QA inspectors and lab technicians appear to have adequate qualification to perform their job functions. A review of NI's personnel files and QA files indicated that, in all cases, NI has i
ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION wn - ocorn770/R7-01 RESULTS: PAGE 6 of 24 not maintained adequate employee files that provide ev1-dence of the qualifications of personnel to perform their job activities affecting quality. (Nonconfomance B.5 was identified in this area.) Therefore, this will require a further review.
Based on the above data, this allegation aspect is partially substantiated, and additional reviews will be performed during a future inspection.
- b. Correct Perfomance of Testing:
Allegation Aspect: (1) Actual testing sequence of numerous projectswerenotperformedinthecorrectsequence;(2) test-ing procedures were inadequate; (3) thermal aging tests include sloppy record keeping, humidity levels are documented on reports but not in testing records, test time period duration was based on weak link activation energy methodology without determining the lowest activation energy, and devices were not sent out for thermal gravimetric analysis (TGA); and (4) seismic and design basis event testing contained deviations.
Inspection Finding:
(1) A review of seven equipment qualification packages indicated that their tests were performed in the correct sequence; (2) An overall problem with NI's technical procedures and instructions was identified. The inspection revealed that many of the NI procedures were written by non-technical personnel or by personnel that did not have documented and/or applicable experience to perform their job function. This methodology would be adequate if the QA program requirement for an independent "technical review for adequacy" had been performed by qualified personnel. However, the majority of the NI technical procedures were "approved" by the QA manager, instead of the engineering manager as required; (3) This area was not reviewed in enough detail to determine whether or not NI is maintaining control.
(4) Ibidem.
Based on the above data, this allegation aspect is sub-stantiated in part. Additional reviews will be per-formed in this area during a future NRC inspection.
I I l . .
1 i ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED l MOUNT VERNON, ILLIN0IS REPORT INSPECTION un - ooonn774/R7-01 RESULTS: PAGE 7 of 24 j
- c. Corrective Action of Test Deviations: !
Allegation Aspect: Radiation testing failures of devices such 1 as: thermal cutouts, relays, switches, humidity transmitters, heating elements, auxiliary contacts, and temperature control- -
1ers have repeatedly failed without NI corrective action. f, Inspection Finding: The radiation testing program was not I reviewed; therefore, this allegation aspect is indeterminate and will be reviewed during a future NRC inspection.
- d. Raw Data Recording:
Allegation Aspect: " ...in many cases raw test data is unavail-able to review since the raw data was not required for many reports and the projects were not reviewed by clientele QA inspectors."
Inspection Finding: The inspection team reviewed the raw data aspect in three areas; thermal aging, design basis events, and l rrechanical aging. Seven EQ report packages were reviewed and l the raw data [ circular and strip chart records] were found for J all seven. However, in the mechanical aging area, it was ;
determined that the technicians are not recording the raw test data as required after each cycle (Nonconfonnance B.4 was identified in this area).
Based on the above data, this allegation aspect is partially I substantiated. )
- e. Inadequate Translation of Design Bases:
Allegation Aspect: " ...The testing procedures were inade-quate...some parts that require a three phase load were only tested singe phase... engineering made a guess on how many hours the devices should be thermally aged... fasteners were nottorqued...[ personnel]performedtestswithnotechnical testing procedures, EQ plans and reports...."
4 Inspection Findings: The NRC inspectors initial observations of l NI personnel performing hardware testing activities determined l that technical inconsistencies in its testing methods were 1 obvious. Discussions with NI Technicians and a review of the procedures and instructions that were established to control the activities determined that an incorrplete and/or inappropriate translation of the design bases was performed in many cases.
The incomplete or inadequate design translation problems were l
1 l
l ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION wn . aconn770/A7-01 RESULTS: PAGE 8 of 24 further compounded because it was also revealed that an indepen-dent review and/or approval was not perfomed in many cases to ensure the technical adequacy of the documents (Nonconformances B.2 and B.4 were identified in these areas).
Based on the above data, this allegation aspect is substan-tiated in part.
- f. Procurement and Receipt Inspection Control: l Allegation Aspect: " ... Questionable batchlot qualification methodology basis...with no traceability back to the manufac- ,
turer's specific batchlot. Some cases of buying from separate l distributors at different times and using the same old !
batchlot numbers...." !
This allegation aspect has not been reviewed during this inspec- I tion and will be reviewed during a future NRC inspection. )
- g. Audits:
Allegation Aspect: " ... Check into the external audits per-formed by the quality assurance department."
Inspection Finding: This aspect was not reviewed during this inspection and will be reviewed during a future NRC inspection.
- 5. Conclusions Concerning Allegations l Based on the partial substantiation of several allegation aspects, discussed in E.4 above, the NRC staff concludes that the concerns about the method in which NI has controlled its nuclear quality related activities are valid, and the staff has concerns in regard l to the basis of N!'s safety-related component Certificates of Con- l formance for previously supplied equipment.
- 6. 0A Program Establishment The inspectors determined by a QA manual (QAM) review that NI's OA program establishirent in the QAM appears to be basically adequate with the exception of the nonconformance in B.1 above. However,
i ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION WA -
000nn770/n7-01 RESULTS: PAGE 9 of 24 this does not exclude the possibility of other deviations that may be in NI's QAM, and as discussed with NI management, an NI review should be performed.
Discussion: At the time of the inspection, it was determined that Class 1E activities at Nuthem are categorized into one of two general areas; production activities, which generally require the assembly of qualified components into a completed unit such as a motor control center, and the second is the equipment qualification test facility where individual components are tested for compliance with environmental or class 1E requirements.
Production units were found to be inspected and tested by quality assurance technicians who are independent of organizations responsible for the work and report directly to the q~uality assurance manager. Equipment facility test activities, however, were found to be performed by technicians who work directly under and report to the test lab manager. The same technicians are also responsible for the QA verification of work performed (noncon-formance B.1 and 8.3 were identified here). Although this obvious anomaly with Criterion X of Appendix B exists, these activities were found to be in conformance with the Nutherm QAM which does not specifically address itself to nonproduction activities (Non-conformance B.1 above).
- 7. Desian Control The NRC inspection team review of the areas of transferring tech-nical specifications and parameters into procedures and instruc-tions (design translation) and the document review and approval cycle indicated a QA program breakdown in regard to its implementa-tion (Nonconformance B.2 was identified in this area).
Discussion: Contrary to Criterion III of Appendix B to 10 CFR 50, Section 4 of ANSI N45.2-1977, Section 3 and 5 of the NI QAM, Revision 0, dated June 18, 1986 and Section 4 of the NI QAM, Revision 4, dated January 30, 1985, Nutherm procedures and instructions, in general, were found to lack an adequate trans-lation of required test parameters and specifications into the procedures, and often lacked an independent verification of design requirements for adequacy,
- a. Due to the wide variations possible for a specific type of component, Nutherm has developed the use of Generic Procedures.
The generic test procedures were found to be accompanied by a
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l ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLINOIS REPORT INSPECTION Un . 000nn774/R7.n1 RESULTS: PAGE 10 of 24 1
l qualification result index (QRI) instruction form which is prepared to define the test requirements and parameters for the specific type of component to be tested. For the majority of cases reviewed, however, the QRI instruction form was found to lack sufficient detail. For example, the QRI for Nutherm Project -
No. BPC-2475 was found to require the cycle aging test to be I performed in accordance with Nutherm Procedure No. 9.7.10.10, Revision 3, "Operational Aging of Pushbutton and Selector ;
Switches." This procedure states that the technician is to I perform the test at a load equivalent to "rated current at nom-inal voltage." However, neither the procedure nor the QRI instruction stated the specific value for rated current.
Based on discussions with Nutherm personnel it was identified that the specific values are obtained through the technicians' interpretation of the manufacturer's data sheets for the parti- l cular device being tested and typically are not delineated or l transferred onto the procedures and instructions by the cogni-zant engineers. Numerous examples were identified, some of which are as follows:
QRI No./Date Prepared by/ Title Approved by/ Title Hardware (1) #1494, 12/85 SDJ/ Design Engineer BE/QA Eng. Rotary fGPU-1759 (Eng.) Switch (2)f1495,12/85 SDJ/ Design Eng. BE/QA Eng. Control GPU-1759 Switch (3)#1403,10/85 SS/Eng. LH/Vice President Switch ;
- NMP-1841 l (4)#1467,3/86 PB/EQ Secretary None Selector
- NMP-1841 (Secy.) Switch (5)#1759,1/86 SDJ/ Design Eng. None Control
- GPU-1759 Switch l
(6)#1514,12/85 GH/ Metallurgist None Rotary l
- GPU-1759 Switch I (7)#1529,1/86 PB/EQ Secy. None Thyrite fGPU-1897 Protector (8)#1526,1/86 GH/ Metallurgist and None Current AE/EQ Secy. Alarm 1
1 1
! ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLINOIS REPCRT INSPECTION kn - o00nn774/97 01 RESULTS: PAGE 11 of 24 QRI No./Date Prepared by/ Title Approved by/ Title Hardware (9)#1570,3/86 SDJ/ Design Eng. None Signal
- 1759-63 Isolator (10)f1540,1/86 DW/ Technical Asst. None OSA Relay;
- FPL-1676
- b. A review of EQ and functional test procedures revealed numerous examples where a technical review of the procedure by an inde-pendent, qualified reviewer, had not been perfomed. Specific examples, identified during the review, include the followir;:
Procedure Title /No. Prepared by/ Title _ Approved by/ Title (1) Operations Aging for PB/EQ Secy. RH/QAMansger(Mgr.)
Thyrite Protector, i9.7.10.30, 5/86 (2) Baseline test for PB/EQ Secy. RH/QA Mgr.
Cycle Duration of Thyrite Protector,
- 9.7.10.29,5/86 (3) Baseline Testirg of LH/Prt.sident RH/QA Mgr.
Solitech Controllers, I
- 9.7.10.22,12/85 l (4) Mechanical Cycle MAM/QA Assistant RH/QA Mgr.
Aging of Airflow Switches, #9.7.10.17, 11/8F (5) Baseline Testing of MAM/QA Assistant RH/QA Mgr.
Disconnect Switches, i I
f9.7.10.6, 11/85 (6) Operational Aging of PB/EQ Secy. RH/QA Mgr.
Push Button, Selector Switches, #9.7.10.10, 4/86
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- l. ,
ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION Mn . QQQnn77Q/A7 n1 RESULTS: PAGE 12 of 24 Procedure Title /No. Prepared by/ Title Approved by/ Title (7) Function Test for AC HB/ Project Mgr. RH/QA Mgr.
Transformer, #9.7.10.39, 3/86 (8) Baseline Testing for SDJ/ Design Eng. RH/QA Mgr.
Voltage Relays, #9.7.10.26, 1/86 (9) Functional Testing for BE/QA Eng. RH/QA Mgr.
Temperature Controllers,
- 7.2.07, 2/85 (10) Functional Testing on SDJ/ Design Eng. RH/QA Mgr.
Analog and Digital Meters, #7.2.0.6, 3/86 (11) Functional Testing of SDJ/ Design Eng. RH/QA Mgr.
Solitech Solid State Power Controllers.
- 7.2.13, 10/86 In addition to the generic functional and environmental qualifi-cation test procedures listed above, the majority of job-specific QRI instruction forms reviewed were also found to lack an independent technical review. Examples of these include:
QRI-NTL Number Nutherm Project No. Rev. Date 1494 GPU-1759 0 12/23/85 1495 GPU-1759 0 12/23/85 1403 NMP-1841 0 10/29/85 1467 NMP-1841 1 03/05/86 1496 GPU-1759 0 01/20/86 .
1524 GPU-1759 0 12/26/85 (7 1529 GPU-1897 0 01/21/86 (8 1526 GPU-017 0 01/07/86 (9 1570 GPU-1759 0 03/06/86
.- .- . . . . . . .~ .
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ORGANIZATION: NUTHERM ' INTERNATIONAL INCORPORATED ,
MOUNT VERNON, ILLIN0IS j l
REPORT INSPECTION wn . coonn770/A7 01 RESULTS: PAGe 13 of 24
- c. Section 3 of the NI QA Manual, "Design Control." states, in i part: that "The Quality Assurance Manager shall be responsible l for verifying the implementation of an effective Design Control l program, when applicable...The Project Engineer (s) assigned the responsibility for a specific project shall be accountable for ensuring that the requirements of this section are implemented, when applicable..." and "The Engineering Manager shall be responsible for ensuring that the appropriate technical aspects l are perfonned and that designers, engineers, analysts and l verifiers are in conformance with this Design Control program, i when applicable." ,
1 Section 4 of NI quality assurance procedure (QAP) 3.0.00, j Revision 0, 1, and 2, states, in part:
.. 0nce the Project Manager has completed submittal drawings in accordance with Procedures 3.1.00, 3.1.01, 3.1.02, 3.3.00, he shall submit them to the Engineering Manager for approval. The Engineering l Manager shall review for technical acceptability of the design, compliance to the specification and purchase order, and for I compliance to procedures." NI QAP 3.0.00, Revision 1, dated !
July 9, 1986 and QAP 3.0.00, Revision 0, dated February 16, 1985 were reviewed. These revisions also require the NI Engineering Manager to approve drawings.
Drawings were randomly selected from the master drawing file located in ti.9 Engineering Department. A review was performed of selected drawings dating from 1983-1986 to identify engineering personnel involved in preparing, reviewi.;g and approving the drawings. NI personnel use initials to signify preparation, review and approval. Examples of the titles of the below identified personnel can be seen in 7 a and 7.b above. The following drawing information Was obtained during review of these drawings:
NI NI DRAWN BY ENG. ENG.
REF. NO. DWG NO. (DATE) REVIEW (DATE) APPROVAL (DATE)
NPP-2069 7023-56977-53 CTA (5/28/86) SD 6/24/86) DES (6/24/86
- GPU-1759 7023-56767-53 JEB 10/29/85) SD 11/11/85) SS (11/12/85 GPU-1759 7023-56742-53 JEB 10/9/85 SD 10/10/85) LH (10/10/85 C-1167 7013-55219-53 GAW 12/9/83 SD 1/6/84) TLS (1/9/84)
- C-1167 7013-55215-53 GAW 12/9/83 SD 12/13/83) GT(12/13/83)
- BE-1214 5001-54983-43 JDS 4/25/83 SD 4/27/83 DJ (4/27/83)
PSE-2185 5001-57018-33 CTA 7/21/86 SD 8/13/86 DES (8/14/86)
ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION Nn - 40400774/R7-Oi RESULTS: pAGE 14 of 24
.NI NI DRAWN BY ENG. ENG.
REF. NO. DWG NO. (DATE) REVIEW (DATE) APPROVAL (DATE)
PGE-1762 4033-57009-33 HEE (7/11/86 HB (7/11/86 DES (7/11/86)
- GPU-2169 7023-56994-33 CTA(8/21/86 SD (8/21/86 HB(8/21/86)
GPU-1759 7023-56749-33 DRM (9/26/85 SD (9/26/85 LH (10/7/85)
GPU-1712 4033-56717-33 DRM(11/21/85) DS(1/31/86 DES (1/31/86)
A review of names, initials and responsibilities of engineering department individuals involved in preparation, review, and approval of the above mentioned drawings indicated that none of the drawings identified above by an asterisk (*) were approved by the Engineering Department Manager. The highest level of Engineering Department personnel involved wi;h review and approval of these particular drawings was Project Manager.
Some drawings in the customer order files (NI Reference No.)
were examined during a brief general review of purchase order documentation. The following information was obtained during review of these drawings.
NI NI DRAWN BY ENG. ENG.
REF. NO. DWG NO. (DATE) REVIEW (DATE) APPROVAL (DATE)
FEl 1868 7023-56414-23 DRM 2/1/86) SD 2/3/86) DES (2/4/86 FEI 1868 7023-56400-33 JEB 10/7/85) SD LH(12/6/85 FEI 1868 7023-06420-33 JEB 10/30/85) SD 10/9/85))
10/30/85 LH (12/6/85 FE! 1868 7023-56401-33 CTA 1/13/86) SD(1/14/86) DES (1/14/86)
The drawing identified above by an asterisk (*) was not approved by the Engineering Department Manager. The level of the Engineering Department personnel involved with the review and approval of this drawing was Project Manager.
The current NI Engineering Department Manager (DES) has been in this position since early 1986. He has a BSEE and is a registered Professional Engineer (P.E.). All drawings selected for review which were issued since ha was appointed to this position were found to be approved by him with only the above noted exception. The engineering manager indicated that in some cases, (re: Dwg. #5023-57401-53 [WHC-2607]), he
~~
ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION No.- 900nn770/A7-01 RESULTS: PAGE 15 of 24 personally perfoms the design work if he decides he is most qualified. In these cases, he typically submits the design drawings for review and approval to his superior, Mr. L. Hinson -
President of N!.
- 8. Inspection Activities The NRC inspection team observations, reviews of test result foms, and review of the NI QAM indicates that QA has not been adequately assuring the quality of the' work activities in its EQ and functional lab testing facility, with the exception of its annual QA audit of the facility. In addition, it was detemined that N!'s lab techni-cians that perfom the testing are not prohibited from approving their own test results.
Discussion: The NRC inspectors determined by discussions, and obser-vations that QA has not assured that the quality activities that are perfonned in the lab facility are verified [where and when necessary] "...by individuals other than those who performed the activity being inspected...," or, if disadvantageous, prvvide indirect control by methods such as monitoring processing methods, equipment, and personnel (Nonconfomance B.1 and B.3 were identified inthisarea).
- a. NI has not implemented its program for the inspection or moni-toring of activities affecting quality for any of the work activities that are performed in its testing laboratory, except for its annually scheduled QA audit;
- b. Discussions with HI lab personnel and a review of several of N!'s current typical "functional test result" (FTR) forms that had their associated tests completed and were signed off as being verified by QA, revealed that management is allowing the lab technician that perfomed the work to sign off the fonn
[ test results] and use the "QA approval" block for their sig-nature. Therefore, a review of a completed form indicates that QA review and approval was performed; and
- c. Discussions with NI personnel and a review of FTR records indicate that on the previous FTR revision, the test labcratory supervisor was using the "QA approval" block for his signature, indicating that a QA approval had been ebtained.
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION N0_. Q4000770/87-01 RESULTS: PAGE 16 of 24 Component qualification testing performed at Nutherm was found to be categorized into either functional testing or mechanical aging testing with test data recorded on specific forms which relate to the type of test conducted. The previous revision of NI's mechanical aging test result forms were found to require signoff by both the technician and a quality assurance inspector; the current functional test fom, however, only requires signoff by a quality assurance inspector. For all functional test forms reviewed, the QA inspector was the same person who performed the work. Subsequent dise.asions indicated that the practice of the lab technician who perfomed the work signing the block designated as "QA inspector approval" is the allowable NI practice. Ir addition, during a review of the pre-vious revision of a mechanical aging test record for NI job #1841, it was noted that the typical form had two signoff blocks, one for QA approval and one for the lab technician signoff. In this example, the person who signed in the "QA approval" block was actually the testing lab manager (Nonconformance 8.3 was idantified in this area). ,
- 9. Test Control The inspection team reviewed documentation packages to determine if EQ reports had been prepared, testing phases were performed in the proper sequence, raw data was in evidence for design basis event (DBE), thermal aging and mechanical aging, thermal gravimetric analysis (TGA), and other attributes. -In addition, the inspection team reviewed documents and observed testing activities that were currently being performed.
Environmental Qualification: Five purchase orders (PO) were ran-domly selected by the NRC inspector from NI's computer generated listing. It was determined by the inspector that all five P0's were safety-related, had Part 21 and Appendix B to 10 CFR Part 50 imposed. Also, an EQ report had been prepared for each P0. It was detemined that the EQ testing was for a mild environment for the selected P0's. The inspector selected seven EQ reports. Five of the EQ reports represented equipment which was tested for mild environment and the other two were selected from NI's EQ report file and represented equipment which was tested for harsh environ- '
ment. After ieviewing the P0's, it was detemined that the l requirements of IEEE 323-1974 were imposed. The testing sequence '
of all seven programs were performed in accordance with P0 require-ments. NI provided the necessary raw data for the design basis event and thermal aging. The inspector did not perform a detailed technical review of this data. The weak link materials and associated activation energies were discussed in each EQ report.
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i ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLINOIS REPORT INSPECTION wn - coonn770/A7-01 RESULTS: PAGE 17 of 24 NI performs numerous generic qualification tests of equipment. '
One EQ report (BPC-2023) was reviewed and evaluated in detail.
The equipment tested was a Microswitch selector switch, a Micro- l switch heavy duty oiltight indicator, and Ohmite resistors. The temperature requirement was 235 degrees F for 30 minutes duration q and then 100 degrees F for 3 days. The requirements were imposed by specification S023-505-5. Devices tested were of the same con-struction as those supplied. The Ey documentation had three evalu-ations recorded which indicated the materials of the tested speci- )
mens were of the same construction as the supplied equipment. The testing sequence was verified by reviewing the test specimen work order which showed the tests and dates the tests were perfomed. )
Review of the functional test data sheets showed that the dates i tested matched with the dates on the work order. The functional l test data sheets required two measurements to be recorded, however, only one measurement was recorded (Nonconformance B.4 was identi-fied in this area).
Two TGA reports were reviewed to determine if NI subcontracts material analyses for equipment when materials are not known. As an example, TGA-004, dated February 6,1986, was an analysis per-fomed by Owens Corning for a General Electric indicator and a Master Specialists illuminated switch. TGA-001 report dated May 29,
. 1985 was an analysis perfomed by Carelco Laboratories for a General Electric motor. NI indicated that prior to 1984 no TGA analysis was performed. During the NRC inspectors' review of QA procedure 9.7.6,03, dated October 2, 1986, "Procedure for Issuing an Equip-ment Qualification Procedure or Report," it wn noted that this procedure was not adequate in that it did not eference IEEE-323 (1974), which shows the minimum documentation neeaed in a EQ file.
The procedure did not show a step by step method of fomulating i the EQ report.
Other Tests: In regard to other test lab activities, it was con-cluded that NI is not adequately controlling safety-related acti-vities that are being perfomed in its equipment test lab facility /
(see nonconformance B.4 above). The basis for the nonconformance is discussed below:
During a test lab walk through a technician was observed to test undervoltage relays for NI project No. TVA-2605, at a load current of 2.5 times less than the iequired load. The technician was asked to demonstrate how the required level of rated load current was determined since this value was not specifically stated within the test instructions or procedure.
The technician submitted for review a copy of the manufacturer's 1
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION wn - ooonn774/A7-01 RESULTS: PAGE 18 of 24 data sheet for the relay under test and stated that the non-inductive load current and voltage used for the test was derived from a table of values located on the data sheet. The inspectors' review of this data sheet, however, found that the voltage and current ratings listed in the table were for inductive load and should have been increased by a factor 2.5 for non-inductive load applications.
In addition, Criterion XI requires, in part, that all testing required be performed in accordance with written test procedures.
Contrary to this, a lab technician was observed to perform Environmental Qualification Test Procedure Number 9.7.10.10, Revision 3, dated April 22, 1986 for Nuthem Project Number BPC-2475, without adhering to the procedural requirements.
Specific examples include the following:
Step 4.1 of the procedure was found to require the use of an adjustable input power source but such a power source was not utilized; Step 4.2 of the procedure specifies the use of an adjustable l load bank capable of rated current and nominal voltage )
including resistive and inductive loads. The test setup, however, was found to contain only resistive loading capability in lieu of the required inductive load; Step 5.1 of the procedure requires one contact of the device under test to be tested at rated inductive load. Contrary to this requirement, only a resistive load was being used; and Steps 5.5 through 5.7 of this procedure were found to require the technician to record raw data values of voltage and current j following each cycle of the contactor. Contrary to this state-ment, it was observed during the performance of the tests that ,
the voltage and current values were not being documented as I required by the procedure. The procedure referenced above l requires 6000 cycles of the contactor and a record maintained of voltage and current indications following each cycle.
During the perfomance of the procedure, however, the technician was observed to record voltage and current indica-tions only twice and stated that it was considered a nomal practice. In addition, to a lack of data recording, it was also observed that such parameters are not typically monitored during the perfomance of the test (Nonconformance B.4 was identified in this area).
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS 1
i REPORT INSPECTION Nn - QQQnD774/A7-01 RESULTS: PAGE 19 of 24 1 l
- 10. Personnel Records j An attempt was made to review the education and experience of selected NI personnel involved with quality-related activities in regard to writing procedures, instructions, translation of design, q technical adequacy review / approval, and similar documents that -
require varying degrees of various qualifications. Most of the QA training files were reviewed to derive a qualification profile for individuals. However, the infonnation contained in the QA files :
varied from individual to individual. For example, resumes were l evident for some individuals, while some files had no educational ;
or background information. However, the payroll files did contain !
additional educational and background information that were used and ;
considered as QA records by the inspection team. The NRC inspection i team also noted that even when both the payroll and QA files were used some of the combined personnal files were found to be either !
l incomplete, incorrect or indeten.iinate. The initials of the appli-cable personnel files that require updating include: HB, CG, GW, SS, DW, GJ, SDJ, LH, ano PB (Nonconformance 8.5 was identified in thisarea). )
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- 11. Audits The inspection team did not review the area of internal or external audits to any depth. However, it was noted that NI management has allowed the use of a QA inspector as the lead auditor on the QA department audits (Nonconformance B.6 was identified in this area).
- 12. Measurino and Test Equipment (M&TE)
The NRC inspectors reviewed the applicable NI QAM sec-ion, QAP 12.4.00, "Calibration frequency," and inspected various M&TE equip-ment c.;d logs. Various H&TE were found in the lab, receipt inspec-tio1, and shop areas. These M&TE were inspected for M&TE control numbers and for current calibration. The M&TE inspected are as follows: q l
NI SER. CAL. CAL. CAL. l ITEM CON. NO. NO. DATE DUE BY l Laboratory !
Partlow Temp. Rec. NI-149 599385 1/14/87 1/14/88 ISL Corp. I Partlow Temp. Rec. NI-153 6275522 6/17/87 6/17/88 ISL Corp. I Beckman Multimeter NI-148 30621038 11/6/87 11/6/88 ISL Corp.
Watlow Temp. Control NI-312 Tag No. 2 9/17/87 9/17/88 GE Evans l
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLINOIS REPORT INSPECTION wn - ooonn770/97-n1 RESULTS: pAGE 20 of 24 NI SER. CAL, CAL. CAL.
ITEM CON. NO. NO. DATE DUE BY Laboratory Fluke Multimeter NI-302 39410124 2/2/87 2/2/88 ISL Corp.
Fluke Ameter NI-304 ---
6/10/87 6/10/88 ISL Corp.
Torque Wrench NI-322 ---
11/24/86 11/24/87 GE Evans Multi-Amp Cur. Source NI-330 46381-001/1 5/30/87 5/30/88 Multi-Amp Multi-Amp Ameter - None MNC-2666 7/22/87 7/22/88 Multi-Amp (rented)
Watlow Temp. Cont. NI-311 Tag No. 3 9/18/87 9/18/88 GE Evans Beckman Multimeter NI-131 10727022 6/22/87 6/22/88 ISL Corp.
Leeds & Northrop Temp. NI-161 860670871 3/4/87 3/4/88 NI Rec. -586-08 Analogic Temp. Indic. NI-157 3002695 6/15/87 6/15/88 ISL Corp.
B&K "0" Scope NI-315 10859 10/5/87 10/88 NI Receipt Inspec.
Continuity Meter .NI-159 5080131 9/15/87 9/15/88 ISL Corp.
Fluke Multimeter NI-133 3340111 9/15/87 9/15/88 ISL Corp.
Shop Hypot NI-101 3195 7/24/87 7/24/88 ISL Corp.
Meg-chek NI-103 3351 8/11/87 8/11/88 ISL Corp.
Torque Wrench HI-323 129277 11/26/86 11/26/87 GE Evans The November 17, 1987 M&TE computer printout data base was reviewed and the following were noted:
NI-103. The calibration date on the instrument label was August 11, 1987. The calibration date in the data base was July 25, 1986.
NI-158. The data base indicates this item is in service and required calibration on September 26, 1987. Upon investigation the item could not be located. The technician responsible for calibration indicated this item had been removed from service because it failed calibration during its last calibration service.
NI-313. The data base indicates this item is in service and required calibration on August 28, 1987. The instrument was located in the shop and was marked with a REFERENCE USE ONLY tag.
ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS REPORT INSPECTION No - 4Q400770/R7-01 RESULTS: pAGE 21 of 24 NI-315. The calibration date on the instrument label was October 5, 1987. The calibration date in the data base was October 1, 1986.
The rented ameter (Ser. No. MNC-2666) found in the laboratory was not listed in the M&TE computer data base. Discussions with QA Manager confirmed that NI does not include rented items in the controlled M&TE program, even though this rented M&TE can be used for activities affecting quality (Nonconformance B.5 was identified in thisarea).
- 13. Control of Purchased Material, Ecuipment, and Services The NRC inspectors briefly reviewed a number of NI purchase orders.
However, the brief review only indicated that N1 does procure some material directly as nuclear safety-related. However, most material purchased by NI is comercial grade. NI then dedicates the comercial grade material for use in nuclear Class 1E safety-related equipment delivered to their customers. Activities such as receipt j inspection, environmental qualification, and final testing of )
completed assemblies are employed by NI as a basis for comercial :
grade material dedication. The following are examples of NI purchase orders for comercial grade material:
P0 P0 Receipt NA Date Item Grade Insp. Invoked GPU-1759-09 1/23/86 Fuses / Fuse Blocks Com. Yes GPU-1759-08 10/15/85 Rotary Relay Com. Yes GPU-1759-07 10/15/85 Resistor Com. Yes GPU-1759-10 11/8/85 Rotary Relay Com. Ycs GPU-2573 Various Various Com. Yes Selected NI purchase orders for M&TE calibration services were reviewed. The vendor's qualification status was ascertained by checking the Approved Vendors List (AVL) in effect at the time of purchase order issue. A summary follows:
P0 P0 Quality 10CFR21 Qualified
& Date , Vendor Req. Invoked Vendor 3849 10/29/87 Indus. Ser. Lab. 10CFR50 Yes Yes(Per9/15/87 AVL) 3821 8/25/87 GE Evans 10CFR50 Yes Yes (Per 6/4/87 AVL) 3772 5/7/87 Multi-Amp 10CFR50 Yes Yes (Per 3/13/87 AVL) 3693 1/13/87 Indus. Ser. Lab. 10CFR50 Yes Yes(Per1/13/87 AVL)
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- ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLIN0IS
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REPORT INSPECTION wn . ooonn770/g7.nl RESULTS- PAGE 22 of 24
- a. Purchase order GPU 2573-04 dated May 26, 1987 to Electroswitch was reviewed. Items 3, 4, and 5 on this purchase order were ;
identified as nuclear safety-related and 10 CFR 50, Appendix B i and 10 CFR 21 were both invoked. The AVL dated May 15, 1987 listed Electroswitch as a comercial rather than a nuclear c vendor. Additional review and discussion with the QA Manager revealed documentation that showed that the QA Manager upgraded Electroswitch to a nuclear supplier on May 7, 1987, but the status code on the AVL was not changed. As a matter of additional note, the status code had not been changed as of the September 1987 issue of the AVL.
- b. A number of receipt inspection records for selected purchase orders were reviewed. In general, receipt inspection consists of identifying material through verification of part numbers, verifying proper shipping quantity, and checking for visual shipping damage. The following receipt inspection documenta-tion was reviewed:
Receipt P0 Item Inspection Date No. No. Accepted Inspector Note 6/4/87 2573/03 2 Yes AE 1 6/4/87 2537-03 6 No AE 2 6/10/87 2573-03 Various Yes TW -
6/11/87 2573-03 1 Yes TW -
6/24/87 2573-03 5 Yes TW - 1 9/14/87 2573-03 1 Yes AE -
Not Recorded 1759-07 1.2 Yes Not Recorded 1 1/29/86 1759-05 1.2 Yes AE 1 Note 1: The NI control number of the M&TE used for testing was not recorded.
Note 2: Nonconfonnance report NCR 1263 dated 6/4/87 was issued.
- 14. Purchase Order Review The NRC inspection team reviewed several NRC Licensee Purchase Orders (P0's), that resulted in several of the discussed noncon-formances. Some of the NRC Licensee P0's that were reviewed include:
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ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERh0N, ILLIN0IS REPORT INSPECTION Nn . ooonn770/87-01 RESULTS: PAGE 23 of 24 !
NI
- Customer 10CFR21 Ref. No. Plant P0 (Date) Item Invoked Appendix B Environment CVI 1599 Palo Verde P5-5665 Remote Yes 10CFR50 --
(2/4/85) Panel j Control CTI 1037 Palo Verde 11212 Elec- Yes 10CFR50 --
(3/11/81) trical Heater
- CPL 1654 Brunswick 28030 Contact Yes N45.2 Mild (3/18/85) Relay !
l 1654 Brunswick 28031 Micro- Yes N45.2 Mild ;
(3/18/85) switch FLUOR 1868 San Onofre 441207-6 AC/DC Yes Mild (1) -0002-01 Dist.
(11/13/85) Panels COMSIP 1449 Hope Creek E-7922-181 Humidity Yes 10CFR50 Mild (1) (8/10/84) Element N45.2 TVA 1497 Watts Bar 85K-9-835985 Duct -- -- --
(10/12/84) Heater Buffalo Forge l 1618 River 72726 Power Yes --
Bend (1) (1/28/85) Stud Block 1665 Bellefonte 85K5-8369 Bailey Yes Yes --
48 (5/7/85) Power Supply P
1670 Fitzpatrick 6N029 Panels Yes Yes --
(12/9/85) w/BKR's
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l ORGANIZATION: NUTHERM INTERNATIONAL INCORPORATED MOUNT VERNON, ILLINOIS REPORT INSPECTION wn . ooonn77o/97_n1 RESULTS: PAGE 24 of 24 l
NI Customer 10CFR21 Ref. No. Plant P0 (Date) Item Invoked Appendix B Environment 1699 Peach Bottom DE 348898 2 pole / Yes Yes --
(4/29/85) 600 v BKR's j 1701 Millstone 843241 CH Relays Yes Yes --
1 (6/20/85) XFMR, TB's 1 I
BKR's 1708 Oyster Creek PP 0288839 Starter Yes Yes (8/29/85) Unit, j Motor CKT 1 BKR i I
- 15. Quality Assurance Procedures 1 The QA procedures and instructions were not reviewed within the scope of this inspection. However, the NRC inspector perceives that problems will also exist in this area based on the above j findings. Therefore, this area will be reviewed during a future 1 NRC inspection. l F. NI PERSONNEL CONTACTED:
- W. Eckert, Chainnan
- L. Hinson, President
- T. Stomberski, Vice President
- D. Stephens, Engineering Manager
- I. Gunin, EQ Manager
- C. Baker, Lab Manager
- R. Heifner, QA Manager
- M. A. McCann, QA ;
- S. Wade, Admin. l
- J. Winder, Engineering d T. Johnson, EQ S. DeJournett, Engineering G. Pitree, Lab B. Revelle, QA A. Evrard, QA R. Winder, Lab
- Attended exit meeting.