ML20149J320

Insp Rept 99901281/97-01 on 970514.Violation & Nonconformance Noted.Major Areas Inspected:Review of Records Documenting Refurbishment Svcs on metal-clad,low & Medium Voltage Breakers

ML20149J320
Person / Time
Issue date:	07/23/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20149J311	List: ML20149J307 ML20149J312 ML20149J316 ML20149J320
References
REF-QA-99901281 99901281-97-01, 99901281-97-1, NUDOCS 9707280160
Download: ML20149J320 (12)

Text

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Enclosure 3 INSPECTION REPORT U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF INSPECTION AND SUPPORT' PROGRAMS 4

ORGANIZATION: ABB Service Incorporated

' Cleveland Service Center

' 5311 Commerce Parkway West Cleveland, Ohio 44130 REPORT NO.: 99901281/97-01 l

ORGANIZATIONAL Mr. D.E. Leckey CONTACT

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Quality Assurance (QA) Manager '

(216) 267 2882

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NUCLEAR INDUSTRY Can provide new ABB switchgear, procurement of

. ACTIVITY: replacement parts, maintenance, refurbishment and on-site switchgear services.

j-INSPECTION CONDUCTED: May 14, 1997 l

SUBSEQUENT DISCUSSIONS: June 5 and July 14-22, 1997 4

INSPECTORS: Kamalakar R. Naidu, NRR Virgil L. Beaston, NRR

, Joseph J. Petrosino, NRR I

APPROVED BY: Gregory C. Cwalina, Chief Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation 4

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9707280160 970723 PDR GA999 ENVC-E

, - 99901281 PDR

1 INSPECTION

SUMMARY

i ABB Service Incorporated (ABB Service), is headquartered at its Columbia, 4

Maryland, Service Center. Prior to 1996, ABB Service had approximately 3

17 service center facilities throughout the United States that could have potentially performed engineering, consulting services, or other work on, or related to, safety-related circuit breakers for NRC licensees. However, due to quality concerns, ABB Service modified that policy and currently allows only four of its service centers to process safety-related circuit breaker work. They are: Cleveland, Ohio Service Center; Columbia, Maryland Service Center; Houston, Texas Service Center; and Charlotte, North Carolina Service

, Center.

f The ABB Service Center located in Cleveland, Ohio, has been performing refurbishment services on metal-clad, low and medium voltage, K-Line circuit breakers installed at Centerior Energy's Perry Nuclear Power Plant (PNPP) for several years. The K-Line breakers were originally designed and manufactured by 1.T.E. Imperial Company (ITE), which changed ownership and became known as I.T.E.- Gould, Gould-Brown Boveri, Brown Boveri Electric and finally ASEA Brown Boveri. ABB Power Transmission & Distribution Company, Incorporated (ABB Power) manufactures metal-clad low-voltage and medium-voltage K-Line breakers at Florence, South Carolina. ABB Power at Sanford, Florida assembles complete switchgear installations. The Cleveland Service Center currently services safety-related K-Line breakers only for PNPP.

On May 14, 1997, the inspectors reviewed records documenting the refurbishment work performed on PNPP breakers, reviewed the actions taken to correct nonconformances identified in report 99901281/94-01, and performed subsequent review of records and documents associated with the reversed polarity issue in K-Line circuit breakers. Additionally, the inspectors reviewed an ABB Service Report performed by ABB Service for Public Service Electric and Gas Company's (PSE&G) Salem nuclear generating station (Salem) as discussed in Section 3.2.b.3. The inspection bases were:

Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reaulations (10 CFR Part 50) 10 CFR Part 21, " Reporting of Defects and Noncompliance" During this inspection, the inspectors identified one nonconformance (Section 3.1.b.3 and 3.1.b.5) and one violation (Section 3.2.)

2 STATUS OF PREVIOUS INSPECTION FINDINGS Unresolved Item 94-01-01 (Closed). The previous inspection identified that a (

current organization chart was not available. The team determined that ABB i Service has a current organization chart which depicts the organization.  ;

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. l Unresolved Item 94-01-02 (Closed). The previous inspection identified that job descriptions and qualificationsL of persons performing safety-related activities were not available. The team-identified that ABB Service has identified and delineated job descriptions and qualifications of persons performing safety-related activities.

j Nonconformance 94-01-03A (Closed). .The previous inspection identified that potential deviations were not appropriately dispositioned. Although the team ,

determined that adequate corrective-action was not performed for;this issue,

- similar corrective action will be required as.a result of Violation 99901281/97-01-01..

Nonconformance 94-01-03B (Closed). The previous inspection determined that not all contact resistances were delineated for purchaser use. The team l determined that maximum acceptable contact resistance values are now furnishedi

. in the ABB Service test instructions.

4- 3 INSPECTION DETAILS i ,

3.1 K-Line Breaker Refurbishment i

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a. Eq_oag The inspectors reviewed circumstances that led to incorrectly assembled ABB Service K-Line breakers being delivered to.PNPP. During and subsequent to the inspection at ABB Service's Cleveland facility, the inspectors:

a visited PNPP to examine the suspect K-Line circuit. breaker, reviewed the purchase order (P.O.) PNPP issued to ABB Power-

- Florence, for the supply of new ABB K-Line low-voltage metal-clad l K-Line breakers,

• examined the documentation related to the. work performed by ABB

! Service on PNPP breakers to determine if it met the P.O.,

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• observed ABB. Service technicians perform work on selected K-Line breakers at the Cleveland Service Center, i

• discussed K-Line breaker wiring problems identified by PNPP and

, other licensees with representatives of ABB Service, and i

• reviewed associated documentation and conducted discussions regarding identified K-Line polarity problems including PNPP and Salem.

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b. Observations and Findins1 b.1 K-Line Breaker Failure at PNPP On October 4, 1996, while PNPP was operating at 100 percent power, a new ABB K600S K-Line Breaker (Seriui Number 934277-031295) supplying 480-volt power to a motor control center prematurely tripped. PNPP personnel investigated the cause of this incident and determined that ABB Power-Florence, had shipped the K-Line Breaker with two lead wires from one of the breaker's three phase sensors (current transformers) reversed. PNPP shipped the breaker to ABB Power for analysis. On March 26, 1997, ABB Power-Sanford, informed the Nuclear Regulatory Commission in accordance with 10 CFR Part 21 requirements that the two wires on the phase-C phase sensor were crossed on the breaker that was shipped to PNPP. Crossing the phase sensor leads changed the polarity of the phase sensor and caused the K-Line Breaker's Power Shield trip unit to trip at 350 amperes of primary current instead of the Power Shield trip setpoint setting of 660 amperes.

4 Six doughnut-shaped current transformers (cts) are mounted on the lower molding current transformer assembly of the K600S K-Line breakers equipped with trip units. Three of the six cts are referred to as phase sensors, and they are used to detect fault currents. The other three are referred to as power sensors, and they are used to develop a reference signal within the Power Shield trip unit. One phase sensor and one power sensor are installed on each phase of the K-Line Breaker. According to Revision 16 of ABB Power Distribution Inc. Drawing 709551, " Aux Physical Wiring Drawing," the phase sensors are mounted on top of the power sensors and the leads of both the sensers are terminated on a terminal block attached to the lower molding. Two leads emerge from the top of each sensor, and a red dot (a polarity mark) on the top of each sensor distinguishes the polarity of the sensor. The other ends of the lower terminal blocks are connected to the apprcpriate terminals of the Power Shield trip unit using a multiconductor cable.

In the new breaker that tripped prematurely at PNPP, the blue wire from the phase-C phase sensor, which should have been landed on terminal 2 of the lower terminal block, was found fastened to terminal 1; the yellow wire, which should have been fastened on terminal 1, was founded to be fastened to terminal 2. This error caused an errant, phase-shifted signal to be sent from the phase-C phase sensor to the K-Line Breaker's Power Shield solid state trip unit. The errant signal caused the trip unit to sense an abnormally high current value, tripping the breaker.

After learning that an incorrectly wired phase sensor reduces the amount of primary current needed to actuate ABB's Power Shield trip unit, PNPP began conducting secondary wiring checks of ABB K-Line circuit breakers. The wiring checks performed by PNPP identified three refurbished K-Line breakers that had incorrectly wired or installed sensors (Serial Numbers 51817A-107073, 51817C-264135 and 518170-211135). All three of these incorrectly assembled K-Line breakers had been refurbished and tested by ABB Service.

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The inspectors determined that current and phase sensors (sensors) wiring and assembly errors may occur in any of the following manners:

Crossing wires frcm the sensors to the terminal block attached to the lower molding current transformer assembly; Crossing wires from the terminal block on the lower molding to the terminal block on Power Shield Static Trip Unit.

Incorrectly re-connecting selected wires on the Power Shield Static Trip Unit after the wires have been lifted to conduct K-Line Breaker tests.

Installing a sensor upside down or incorrectly wiring a sensor when the lower molding current transformer assembly of the K-Line Breaker is disassembled (to replace a sensor).

Additionally, as discussed in Section 3.2.b.2 below, the reversed polarity problem in K-Line circuit breakers appears to have been initially identified by ABB Service in the 1992-1993 time period. ABB Service was aware that the polarity problem could have the potential to exist in new or refurbished K-Line breakers and that single phase testing methods typically used by the licensees and ABB Service organization would not identify the problem. The problem could affect safety and non-safety-related K-Line breakers. However, ABB did not take action to assure the circumstances of the problem were affectively disseminated.

b.2 Procurement Documents Purchase Order (P.O.) S137920, Rev. 3, dated June 14, 1996, controlled the work performed on safety related K-Line breakers including S/N 51817D-211135.

Attachment 1, Rev. 002, Section C, " Quality Assurance Program Requirements,"

to P.O. S137920 required certain QA program requirements to apply to all rework, replacement part procurement, inspection, testing, handling, storage and shipping of K-Line breakers returned for refurbishment, including 10 CFR Part 50, Appendix B, and 10 CFR Part 21.

Attachment 1, Section E, " Quality Assurance Records," Item 2 to P.O. S137920 required, in part, the following documentation to be submitted, as applicable:

• ABB Service Certificate of Compliance (CoC).

• Procedural Checklist for Safety-Related Nuclear Switchgear (ABB Service Form QA2).

• Final Inspection / Acceptance Criteria Checklist (ABB Service Form QA6).

Attachment lA, Rev. 000 (01/16/95), " Technical Requirements Safety Related K-Line Breaker 10 Year Refurbishment," to P.O. S137920, Rev. 3, requires in part that:

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A. complete visual inspection of all areas of the K-Line Breaker shall be performed to verify configuration complies with factory approved physical . assembly configuration. . . Any visual inconsistency... shall be further investigated. These activities shall be performed utilizing factory approved design documents...

Any observed discrepancies shall be noted and the K-Line Breaker reworked to comply with the specified configuration-b.3 K-Line' Breaker S/N 51817A-107073 K-Line Breaker _S/N 51817A-107073 is a safety related type ABB K3000S breaker.

PNPP sent this breaker to ABB Service for an inspection, lubrication evaluation, 10-year refurbishment, and repair in accordance with P.O. No.

S137920. ABB' Service refurbished and tested the breaker and returned it to PNPP with a CoC, dated August 23, 1995. The CoC was signed by the Cleveland Service Center QA Manager. On September 1, 1995, PNPP put the breaker in service.

On November 8, 1996, PNPP maintenance personnel discovered that control wires connecting the power sensors on the breaker lower molding to the Power Shield trip unit were incorrectly wired. Based on Perry's information, ABB Service generated Nonconformance Report (NCR) ABB Service Job # 43-02714-26 on November 8, 1996.

The ABB Service NCR stated that during primary current injection testing, Power Shield control wires 11 through 14 are lifted and shorted together.

After testing, the control wires are re-connected to the Power Shield terminal block. The NCR stated that the wiring error discovered by PNPP may have occurred during the re-connection of the control wires following final testing of the breaker. The ABB Service NCR stated that the reversal of the control wires on terminals 12 and 13 of the Power Shield would not have affected proper operation of the breaker, and therefore there was no impact to plant operability. The line item "Petential Part 21 Evaluation Required?" on the NCR was checked "No" and this r :ponse was signed by both the Service Center Manager and the Service Center 5 Manager.

The actions taken by ABB Service to correct this nonconformance and prevent recurrence were to add line items to checklists ABB Service Form QA2,

" Procedural Checklist for Safety Related Switchgear," and ABB Service Form QA6, "ABB Service QA Final Inspection / Acceptance Criteria Checklist," to require point-to-point wiring checks of all controls including Power Shield, power and phase sensors, and on both ends of the Power Shield wiring harness to verify wiring configuration. The inspectors verified that these corrective actions were implemented by ABB Service with the issuance of Rev. 8 of ABB Service Form QA2 and Rev. 3 of ABB Service Form QA6. Both revisions were dated November'14, 1996.

The inspectors informed ABB Service personnel that failure to perform an adequate inspection of K-Line Breaker S/N 51817A-107073 is a nonconformance contrary to Perry's P.O., and Criterion X of Appendix B to 10 CFR Part 50.

(This is one example for Nonconformance 99901281/97-01-02).

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7 b.4 K-Line Breaker S/N 51817C-264135

! K-Line Breaker S/N 51817C-264135 is a non-safety-related type ABB K600S K-Line 4 i Bre aker.- In November 1995, PNPP sent this breaker to ABB Service where it was refurbished and returned to PNPP on September 4, 1996. Upon receipt, the j l breaker was placed in a PNPP warehouse.

j On March 20, 1997, while performing pre-installation checks on the K-Line Breaker, PNPP personnel discovered that the phase-B phase sensor was incorrectly wired. Based on Perry's information, ABB Service generated NCR

ABB Job # 43-02902-3. In this NCR also, the line item " Potential Part 21 Evaluation' Required?" was checked "No" and this response was signed by the .

Service Center Manager. The NCR stated that PNPP was assured that the revised

! ABB Service Forms QA2 and QA6 were being utilized to prevent recurrence of-t future wiring errors.

J From the available documentation, the inspectors could not determine who

! caused _the wiring error. The leads were not reversed at the Power ShieH , as a

in the example above, but at the current sensor terminal block on the lower

{ molding. ABB Service personnel informed the inspectors that these leads are not_ disconnected during routine refurbishing work unless the current sensors

are replaced. The documentation reviewed by the inspector indicated that the i current transformers were not replaced for this breaker.

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ABB Service personnel informed the inspectors that this error was not-identified because the breaker was refurbished and shipped before the issuance of Rev. 8 of ABB Service Form QA2 and Rev. 3.of ABB Service Form QA6. Because this is a non-safety-related breaker, the inspectors _did not identify this -

condition.as a nonconformance. However, the team considered this as an example that should have been evaluated as affecting safety-related breakers since K-Line safety and non-safety-related breakers are identical in this area, b.5 K-Line Breaker S/N 518170-211135 K-Line Breaker S/N 518170-211135 is an ABB K600S type safety-related breaker.

PNPP sent this breaker to ABB Service for an inspection, lubrication evaluation,10-year refurbishment, and repair in accordance with Purchase

-Order Number S137920, Rev. 3. On April 16, 1997, ABB Service tested the .

breaker and returned it to PNPP with a Coc, dated April 16, 1997, signed by t the Cleveland Service Center QA Manager certifying that the breaker met the P.O. requirements. On April 28, 1997, PNPP personnel discovered that one of the breaker's power sensors was inverted (i.e., it was' installed upside down).

PNPP reported this nonconforming condition to Corporate ABB Service and ABB Service documented this condition in'NCR ABB Service Job # 43-02939, dated April 29, 1997. In the NCR, the line item " Potential Part 21 Evaluation Required?" was checked "No" and this response was signed by the Service Center QA Manager.

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The inspectors determined from the available documentation that this nonconforming condition was caused by Ab8 Service during replacement of the lower molding current transformer assembly. The K-Line Breaker repair worksheet (ABB Service Form CBRW, Rev. 4., Dated March 10,1995) for breaker 4

S/N 51817D-211135 indicated that on April 2, 1997, ABB Service replaced the phase-C lower assembly which contained the upside-down power sensor. The ABB j Service Form CBRW for breaker S/N 51817D-211135 was signed and approved by the Service Center QA Manager on April 15, 1997.

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On April 16, 1997,-ABB Service issued a CoC for Breaker S/N 51817D-211135, signed by the QA Manager, which certified that the repairs and final tests on the subject apparatus, as described in Service and Test Reports, complied with the requirements of the subject purchase order, applicable industry standards,

, and the specifications of the original contract.

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' Based on the above, the inspectors informed ABB Service personnel that failure to perform an adequate inspection of K-Line Breaker S/N 518170-211135 is i

another example of a nonconformance contrary to Criterion X, " Inspections," of 10 CFR Part 50, Appendix B, PNPP's purchase order, and Stop 9 of ABB Service Form QA2, Rev. 8, which required that a point to point wiring check be performed on all components, including the power and phase sensors (this is a  !

] second example for Nonconformance 99901281/97-01-02). I

c. Conclusions 1- Based on the above, the inspectors determined that ABB Service had not

' properly developed and implemented an inspection program to assure that refurbished breakers conformed to their original design.

3.2 10 CFR Part 21 Procedure & Evaluations

a. Scope The team reviewed the adequacy of the procedure that ABB Service adopted to implement the provisions of 10 CFR Part 21, Quality Assurance Procedure (QAP) 15.2, " Reporting of Defects and Noncompliance with 10 CFR 21," Revision 2, approved March 24, 1995, and reviewed selected deviations to determine whether

[ they were dispositioned in accordance with the provisions of 10 CFR Part 21.

b. Observations and Findinas i b.1 Procedure The team reviewed QAP 15.2, Revision 2, to assess whether it effectively implemented the provisions of 10 CFR Part 21 and ensured that identified deviations or failures to comply were appropriately evaluated or transmitted to the purchasers. The team noted that revision 2 of QAP 15.2 is eight pages long with an additional seven pages of " supplemental guidance," and has a two i page form, " Potential Noncompliance or Defect Report," to be completed by the ABB Service originator.

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The inspectors reviewed the procedure as if a deviation had been identified, and determined that the procedure was comprehensive and contained useful notes and guidance to assist the evaluator. The team noted that several of the Part 21 definitions were not in accordance with the latest revision of Part 21 and some definitions also contained ABB Service clarifications or interpretations that were integrated into the definition. Although the clarifications appeared to be helpful, the integration of the ABB Service narrative could be misleading. Therefore, the inspectors recommended that ABB Service assure that the clarifications are discernable from the Part 21 definitions (such as, by the use of brackets). Additionally, Section 21.3,

" Interpretations," of Part 21 does not allow interpretations of the meaning of Part 21 verbiage except for written interpretation by the NRC General Counsel.

The definitions that were contained in QAP 15.2 appeared to be from the 1995 revision. 10 CFR Part 21 was modified in 1996, but QAP 15.2 did not reflect the modifications. Consequently, some of the QAP 15.2 definitions are not in accordance with the current revision of 10 CFR Part 21.

The team also reviewed the ABB Service " Potential Noncompliance or Defect Report" form that was an attachment to QAP 15.2 and noted that it contained instructions / guidance that are not appropriate for the audience that would be expected to be use the form. The requirements on the form state:

A. Identification of the basic component or activity which contains a " defect" or " failure to comply."

8. Identification of the Company supplying the basic component or activity which contains the " defect" or " failure to comply."

C. Nature of the " defect" or " failure to comply" and the safety '

hazard which is or could be created.

D. Number and location of all affected components: (include identification of all purchasers to whom component has been supplied)

E. Corrective action, identification of party responsible or action, and schedule for action.

The team determined that these requirements may not be fully understood by the average employee / technician. Additionally, the requirements could tend to have somewhat of a chilling effect. The team believes that an employee would not typically have the expertise to identify whether a " defect" or " failure to comply" exists. Therefore, the team felt it possible that an employee would not complete the form since the employee would be unable to provide the required information. The employee's responsibility should be limited to identifying problems or deviations to their supervision to ensure that all ootential defects are identified and dispositioned in accordance with 10 CFR Part 21. This form, if not understood completely by the ABB Service personnel, may have prevented deviations from being reported in the past.

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After discussing the 10 CFR Part 21 regulation, intent and QAP 15.2, with ABB Service staff,.the team informed ABB Service that it-had determined that it t had not established an adequate procedure to appropriately implement 10 CFR l Part 21. This failure is characterized as a violation of minor. significance and will be treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy. The ABB Service Director of Quality committed to resolving the NRC concerns, b.2 PNPP Evaluations The team reviewed licensee and ABB informatien regarding identified problems with the K-Line low voltage circuit breakers. On three separate occasions, as discussed above, PNPP reported that ABB Service refurbished and-tested K-line low voltage breakers were found by PNPP to contain wiring or assembly errors.

Although some of the errors could cause a breaker to trip prematurely, in each of the NCRs, the line item " Potential Part 21 Evaluation Required?" was checked "No" and signed by an ABB Service Manager.

Premature tripping, or false trips are a concern especially if false trips occur during transient events when the breaker is required to carry its full current rating. Further, because single phase calibration testing does not adequately verify the overcurrent trip set points of some circuit breakers

. equipped with three phase solid state trip units, the potential exists for incorrectly wired or assembled circuit breakers to pass ABB Service and licensee calibration testing, but prematurely trip during a design basis accident, resulting in a loss of safety function.

The team discussed the disposition of these NCRs with the ABB Service Quality Director. The team asked the Quality Director why there were not any 10 CFR Part 21 evaluations performed. The Quality Director stated that in retrospect,.they should have evaluated the issue, regarding breaker S/N l 518170-211135, in accordance with 10 CFR Part 21. The ABB Service personnel also informed the inspectors that they did not evaluate the potential that  !

they may have previously shipped safety related K-Line breakers with errors l

similar to those identified in the NCRs.  !

1 The inspectors informed ABB Service personnel that failure to identify potential defects and either evaluate or inform the purchasers was a violation of 10 CFR Part 21. Additionally, recurring current sensor errors in safety-related K-Line breakers in previously shipped safety-related K-Line breakers was a potentially generic problem that ABB service did not recognize, evaluate or inform ABB Service customers so its customers could determine if the condition existed at their facilities. Violation 99901281/97-01-01 was identified in this area. )

b.3 ABB Service Evaluation The team also reviewed an ABB Service report performed for Public Service Electric and Gas Company's Salem nuclear generating station (Salem) by the ABB Service Company's Mount Laurel, New Jersey fu'<tv. The report, " Harmonic Measurements and Circuit Breaker Tripping Eva'. M ..," dated December 1992-January 1993, was requested by Salem due to unexplained K-Line circuit breaker 10

1 tripping during starting and normal operating conditions. The report stated the existing circuit breaker had been tested by single-phase fault simulation injection, and all tests indicated proper tripping functions; therefore, the cause of the premature tripping was unidentifiable by the licensee.

The ABB Service report stated in part: Consequently, the licensee co 1 The computer and laboratory simulation identify the effects of i improper current sensor connections to the solid state trip unit.

The results clearly indicate the potential for premature tripping, if improper current sensor polarity wiring exists.

It appears that the error in polarity may have existed prior to shipment from the ABB manufacturing factory....

NOTE: Single-phase overload testing is necessary, but will NOT identify improper polarity of the... current sensor connections.

The (ABB Service] laboratory simulation confirmed that the mathematical results which clearly indicate that the reversal of one phase sensingwill result in an artificially high input into the logic box circuitry. Two times normal. to be specific. This would cause premature tripping....

The comparison of the field measurements and the circuit breaker limitations, with one phase reversed, clearly indicate that having during normal loading and inrush operation.one phase reversed wa In addition, if ABB ty by in-house [ licensee]pe K-Lino circuit breakers have been serviced, personnel... these circuit breakers should be identified and have the polarities of the current sensors checked during the next scheduled outage... If any of the identified circuit breakers supply loads whereby premature tripping is of an operating i or safety concern, then provisions should be made to allow these  !

circuit breakers to have the polarities checked as soon as possible.

The team determined that although AB8 Service personnel were aware of this problem as early as January 1993, ABB Service failed to inform its customers of the potentially generic latent defect that could have existed on any new or  !

refurbished ABS K-Line breakers. l

c. Conclusions c.1 Procedure The team concluded from its review of QAP 15.2, Revision 2, and its attachments that the ABB Service procedure was cumbersome, contained outdated 10 CFR Part 21 definitions, and could have resulted in misleading ABB Service employees into believing that they must perform a review of the circumstances 11

surrounding a deviation to determine the safety-significance and the safety hazard which could be created. Therefore, the team concluded that the current revision of QAP 15.2 would not effectively implement all of the provisions of 10 CFR Part 21, c.2 PNPP Evaluations The team concluded that ABB Service failed to either perform an evaluation of the potential reversed polarity and miswiring or to inform all of its customers so they could determine if a problem existed.

c.3 ABB Service Evaluation The team concluded that although ABB Service was aware of the potential for reversed polarity on new or refurbished K-Line low voltage circuit breakers as early as January 1993, ABB Service failed to act appropriately given the potential problems that could have ensued at operating nuclear power plants as a result of the potentially generic K-Line series matter.

4. PERSONS CONTACTED

'BB Service Company J.J. Connolly, Vice President, Business Development D.E. Leckey, Quality Assurance Manager, Cleveland Service E. Link, Manager, Cleveland Service J.M. Tate, General Manager, North Central Region J.0. Webb, Director of Quality Centerior Enerav Comoany M.R. Fournier, Quality Engineer, PNPP Nuclear Assurance 4

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 99901281/97-01-01 NOV inadequate evaluation / failure to inform 99901281/97-01-02 NON inadequate inspections Closed 99901281/94-01-01 URI unavailability of organization chart 99901281/94-01-02 URI unavailability of job descriptions 99901281/94-01-03A NON inadequate qualitative criteria 99901281/94-01-03B NON acceptable contact resistance not available 12

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