ML20154B393
| ML20154B393 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1986 |
| From: | Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20154B346 | List: |
| References | |
| REF-QA-99900100 NUDOCS 8603040296 | |
| Download: ML20154B393 (29) | |
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ORGANIZATION: LIMITORQUE CORPORATIGN LYNCHBDRG, VIP.GINTA PEPORT INSPECTION INSPECTION SO.: 99900100/85-01 '
DATE(S): 11/4-E/85 0F-SITE FOURS: 116 CORFESPONDENCE ADDRESS: Limitorque Corporation ATIN: Mr. F. K. Denham Executive Vice Fresident 5114 Wocdall Road
'TELEPH0t!E NUMBER: (804) 528-4400 PRINCIPAL Po000CT: Potor and canual operated valve actuators, NUCLEAR INDUSTFY ACTIVITY: Approximately 5% of sales.
ASSIGhED INSPECTORt .h\Ah%. , 1-l%8(,_ ,
T.~Corway, Pea ive Inspection Section (RIS) Date OTHER INSPECTOR (S): E. Yachimiak Jr. , RIS ,
L. Vaughan, Program Coordination Section G. Hubbard, Equipment Ous11fication Inspection Section T. Tir.kle, Consultant
% s APPROVED BY: , h k . hsh 2 8(.
f, PTS, Vendor Program Branch Date '
E{W. Merschoff, Ch ,
!H5PECTICN BASES AND SCOPE:
A. BASES: 10 CFR Fart 50, Appendix B and 10 CFR Part 21.
B. SCGPE: This inspection was made as a result of the receipt of 10 CFR Part 50.55(e), Licensee Event (10 CFP 50.73), and 10 CFR Part 21 reports from: (1) Gulf States Utility Company and Niagara Mohawk Power
< Corporation relatieg to the loss of torque of Reliance motors containing magnesium rotors, (2) Washington Public Power Supply System pertaining (cortinued on page 2)
PLANT SITE AFPLICABILITY: Loss of torque. River Bend (50-458/459) and Nine Mile Point 2 (50-410); Valve-actuatc? weight discrepancies- 14NP 164 (50-460/513);
(cnntinued on page 2)
' 0603040296 060228 P D14 GA997 EtwL.M1T 99900100 PDR
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 2 of 21 INSPECTION BASES AND SCOPE: (continued)
B. SCOPE:
to valve / actuator weight discrepancies, (3) Public Service Electric and Gas Company on replacement actuators having different spring packs, and (4) Commonwealth Edison and Tennessee Valley Authority on qualification of internal wiring.
PLANT SITE APPLICABILITY: (continued)
Replacement actuators-Salem 2 (50-311); Val /e Operator Wiring Qualification-Sequoyah 1&2 (50-327/328), Zion 1&2 (50-295/304), Dresden 2&3 (50-237/249),
Quad Cities 1&2 (50-254/265) and any other plant with Limitorque operators.
A. VIOLATIONS:
- 1. Contrary to Section 21.21(b) of 10 CFR Part 21, Limitorque did not notify the NRC that unqualified Baldor motors were used in safety related valve actuators installed in the WNP-2 and Salem nuclear power plants as noted by the following (85-01-01).
Limitorque discovered on March 28, 1983 that unqualified Baldor motors were installed in actuators for four Crane valves at the Public Service Electric and Gbs Salem Nuclear Power Plant.
The Limitorque Bill of Material indicates that the actuators were safety related.
Limitoraue was advised by Washington Public Power Supply System (WPPSS) on May 27, 1983 that unqualified Baldor motors were installed in actuators for four Velan valves at the WNP-2 Nuclear Power Plant. The Linitorque Bill of Material indicates the actuators were safety related.
Following the January-February 1984 NRC inspection, .Limitorque initiated a record review to determine the number of actuators shipped with unqualified Baldor~ motors. In August 1984, limitorque discovered unqualified Baldor motors were also installed in actuators for four Borg-Warner valves at WNP-2.
The Limitorque Bill of Material indicates the actuators were safety related.
- 2. Contrary to Section 21.51(b) of 10 CFR Part 21, Limitorque was' unable to provide documented evidence that required reviews and evaluations were performed for possible 10 CFR Part 21 reporting on the following safety related actuators with noted problems (85-01-02).
d
ORGANIZATION: LIMITOROVE CORPORATION LYNCHBURG, VIRGINIA PEFORT INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 3 of 21
- a. Fotor pinion key failures descrited in Section E.4 of NRC Inspection Report No. 99900100/84-01 (ref. Limitorque letter dated September 27, 198? to the NRC).
- b. Worm shaft gear failures (ref. Lim' torque letter dated August 13, 1985 to the NRC).
- c. Potential field naintenance problem on type H3BC actuators (ref. Limitorque letter dated Januarj 10, 1983 to the NRC).
- d. Cracked / broken limit switch rotors (ref. Limitorque letter dated February 21, 1984 to the NRC).
- 3. Contrary to Sections 21.6 and 21.21 of 10 CFR Part 21, it was noted that (85-01-03):
- a. Section 206 and a " Notice" were not posted in the shop fabrication area to be read by the manufacturing personnel, and a " Notice" which was posted in an adjacent building did not describe the regulation or state where Part 21 reports could be examined,
- b. Procedure QCP-2? " Reporting Defects for Safety Related Equipment..." did not provide for informing the licensee or purchaser and a responsible officer of a deviation /
defect in a basic component.
B. NONCONFORMANCES:
- 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection A.1 of Section I of the Quality Assurance Manual (QAM), and Section 5 of ANSI N45.2, a review of 13 P0s to vendors (Ryerson Steel-two, Copperweld Steel-one, Walker Machine-two, Southern Centrifugal-two, Lynchburg Foundry-two, Foster Electric-three, and Wesco-one) indicated that quality requirements (e.g., QA Program) were not passed on to these suppliers and manufacturers of components destined for actuators purchased by nuclear customers as safety related items (85-01-04).
- 2. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 2 of ANSI N45.2, a review of the QAM, Revision 2 dated January 4, 1984 indicated that Limitorque did not update the QAM to address training of non QC personnel in disciplines such as engineering, parts and shipping, purchasing, order processing, and field service (85-01-05).
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 4 of 21
- 3. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection B.1.b of Section VI of the QAM, Section 11. A of Procedure No. QCP-11, and Sections 5.2, 9.6.1 and 9.7.3 of SNT-TC-1A, a review of Limitorque's written practice for nondestructive examination (NDE) and qualification. records for three NDE personnel revealed that (85-01-06):
- a. Procedure No. QCP-11 did not describe the responsibility of each level of certification or rules covering the duration of interrupted service requiring re-examination and recertification.
- b. The qualification records af the three NDE personnel did not contain a statement indicating satisfactory completion of training in accordance with Procedure No. QCP-11,
- 4. Contrary to Criterion V o# Appendix B to 10 CFR Part 50, Subsection C.1 of Section I of the QAM, and Section 14.A.2 of Procedure No.
QCP-14, the inspector reviewed checklist form No. qC0019 for internal audits conducted in 1983 and 1984, and i" was noted that the area of QA Records (i.e.,Section XI of the QAM) was not in the checklist and was not audited ( 85-01-07):
- 5. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection B.3 of Section III of the QAM, Section 3.E of Procedure No. QCP-3, and Section 25.A of Procedure No. QCP-25, it was noted (85-01-08):
- a. Vendor Evaluation Reports (VER) were not generated semi-annually for the following vendors:
Vendor VER Period
- Peerless-Winsmith (3)
Reliance Electric Co. (3)
Electric Apparatus Co. (1)(2)(3)
Drever Co. (1)(2)(3)
Wesco (3)
Philadelphia Gear Corp. (2)(3)
Sovereign Metal Corp. (1)(2)(3)
Valley Fasteners (1)(2)(3)
=
s
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 5 of 21 Vendor VER Period
- Tubular Steel Inc. (1)(2)(3)
NES/Selamco (1)(2)(3)
Foster Electric. (1)(2)(3)
- b. Vendors listed below ..th an evaluated rating below Linitorque's quality standard were not removed from the AVL.
Vendor Rating VER Period
- Advance Pressure Casting 20% reject (3) 100% reject (2) 100% reject (1)
Bronze & Plastics Specialty 70% reject (3)
Duer Spring & Manufacturing Co. 45% reject (3)
International Spring 43% reject (3)
Newcomb Spring 56% reject (3) 40% reject (2)
Southwire Machine Div. 95% reject (3)
The Spring Work 56% reject (3)
Guilford Foundry Co. 55% reject (3) 8% reject (2)
Handwheel Inc. 50% reject (3)
American Spring & Wire 91% reject (2)
Rocky Mountain Casting 96% reject (2)
- (1) - 1/84-6/84 (2) - 7/84-12/84 (3) - 1/85-6/85
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 6 of 21
- c. Audits were not performed on Page-Wilson Corporation and Hartzog Granite Company who calibrated the hardness testers and surface plates, r espectively.
- 6. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Procedure No. QCP-22, and Procedure No. QCP-13, Limitorque is not effectively implementing QA program requirements for reporting defects in safety related equipment as noted by the following (85-01-09):
A field service report was prepared in May 1983 when Limitorque field service personnel installed qualified Reliance motors in place of unqualified Baldor motors in safety related actuators for four Crane valves at Public Service Gas and Electric's Salem Nuclear Power Plant. Also in May 1983, a customer problem report was made when WPPSS advised Limitorque service and special project personnel that unqualified Baldor motors were installed in safety related actuators for four Velan valves at WNP-2. The Technical Manager did not see the field service report or the problem report until he reviewed the Order File as part of the record review initiated after the unqualified Baldor motor problem was raised as an issue during the January-February 1984 NRC inspection. The record review was completed in August 1984 which is approximately 15 months after the problem was reported to Limitorque personnel.
The Quality Assurance Administrator could not provide a copy of his letter to the Design Review Committee concerning the unqualified Baldor motor problem nor a copy of any letter from him to the Design Review Committee for any problems for evaluation and investigation as required by Procedure No.
QCP-22.
The Quality Control Manager could not provide copies of any documentation showing that the Material Review Board evaluated tiz circumstance concerning the installation of unqualified Baldor motors in the actuators for four Crane valves at the Salem Nuclear Power Plant. This problem was identified by the QC Manager during a review of QA records for the particular order.
- 7. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 17 of ANSI N45.2, Limitorque discovered on March 28, 1983 that unqualified Baldor motors were installed in four safety related actuators for Crane valves at Public Service Electric and Gas' Salem Nuclear Power Plant. Further, Limitorque was advised by WPPSS on May 27, 1983 that
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 7 of 21 unqualified Baldor motors were installed in four safety-related actuators for Velan valves at WNP-2. For the two cases in point, limitorque could not provide any documented evidence that measures were taken to identify the cause of the condition, the extent of the problem, and necessary corrective action to preclude repetition; or that the condition was reported to appropriate levels of management (85-01-10).
C. UNRESOLVED ITEMS:
Limitorque was requested to provide the Order Files for the blocking valve actuators involved in the " Salem Unit 2 Depressurization Event" discussed in NRC memo AE00/E509 dated July 25, 1985. The 0A Administrator stated that actuator unit (P0 875064, S/N 355494) documentation should be in Order File 3H8897. However, the QA Administrator stated the file could not be found. The QA Administrator further stated the documentation for the actuator unit on P0 927970 could not be identified without either the order file number or the unit serial number and that Limitorque could not retrieve this information. This item will be evaluated during a future NRC inspection.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (Closed) Nonconformance (Item A, 84-01); Limitorque corrective action commitments made in a letter dated November 15, 1982, in response to Item A of the Notice of Nonconformance of NRC Inspection Report No. 99900100/82-02, were found to be inadequate in that the training of non-QC personnel did not include:
- a. All applicable personnel having quality functions (e.g., the managers of Special Processes and Industrial Engineering).
- b. All applicable Quality Control Procedures (QCPs) were not addressed, e.g., QCP-3 for purchasing personnel; QCP-13 for engineering personnel; and QCP-23 for shipping personnel.
- c. Any of the applicable sections of the QA manual for any of the personnel.
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 8 of 21 The NRC inspector reviewed these areas and found that corrective action documented in Limitorque's April 2, 1984 letter was adequately implemented. However, Limitorque has not revised their QAM to address training of non-QC personnel (see Nonconformance 85-05-01).
- a. The Special Processes Manager was certified to his understanding of QCP-12 on April 3, 1984. The Industrial Engineer was not certified because his presence is not quality related,
- b. QCP-3 is written for inspection personnel and defines the Insl.ection Sampling Plan, writing of Variation Peports, etc.
and is not related to purchasing managers. QCP-13 is written for the Quality Control Manager to assist him in preparing the Material Review Board report and has no affect on the functions of the Engineering Department.
QCP-23 is written for shipping personnel thus e Shipping Department Supervisor and the Stockr.sm Supervisor were formally certified to this procedure on April 3, 1984.
- c. Limitorque's response was that the OCPs address "how" quality related functions are accomplished, whereas the QA manual addresses "what" quality related functions are carried out by the company. Fermal training in the QCPs for applicable personnel is conducted.
- 2. (Closed) Nonconformar.ce (Item B, 84-01): Limitorque corrective action commitments made in a letter dated May 23, 1983 stated that key material "...is presently procured with certified material test reports...". Contrary to this statement, AISI 1018 3/32" keys were found in the stock room without their respective certified material test report on file.
The NRC inspector reviewed this' item and found that the certified material test reports for the 1018 3/32" keys are now on file.
- 3. (Closed) Nonconformance (Item C, 84-01): Limitorque 1 corrective action commitments made in a letter dated l November 15, 1982 stated that they would "... revise QA 1 manual with requirements for Quality Control to monitor safety-related material contracts." Contrary to the above, the revisions identified had not been accomplished.
ORGANIZATION: LIMITORQUE COPP0 RATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 9 of 21 Limitorque has been monitoring safety-related contracts since October 2, 1982. The formal inclusion of this into a procedure to insure the monitoring of safety-related material contracts has been done and is documented in Procedure No. QCP-21.
- 4. (0 pen) Nonconformance (Item D, 84-01): Contrary to Criterion XVI of Appendix B to 10 CFR Part 50, measures were not taken to assure conditions adverse to quality were identified and corrected.
Limitorque corrective action commitments made in a letter dated April 2,1984 in response to the Nonconformance indicates that a review of records would be accomplished to substantiate that the shipment of unqualified motors in actuators for Velan valves for WPPSS was an isolated occurrence. The results of the record review which was completed around August 1984 indicated that the shipment of unqualified motors to WPPSS for Velan valves was not an isolated incident and that two additional occurrences existed.
This item will be reviewed during a future NRC inspection.
- 5. (Closed) Nonconformance (Item A, 83-01): Commitments have not been accomplished for establishment of an inspection procedure to identify the RPM acceptance tolerance, and QA manual revision to include a requirement that inspection procedures identify accept / reject criteria.
Limitorque's response of April 2,1984 stated that Form LP-11 was being revised to include the acceptance criteria for operator motor output speed. This was verified by the NRC inspector as having been completed. A generic reouirement, where applicable, for accept / reject criteria was also included into the QCPs.
- 6. (Closed) Nonconformance (Item F, 83-01): NDE personnel were not qualified in accordance with SNT-TC-1A, the proper liquid penetrant (PT) dwell and development times were not implemented, and the guidance of a minimum 10-minute development time was not followed.
A review of NDE records indicated that one Level III and two Level II personnel were qualified to perform PT examination in June 1983.
Training and examination were performed by Pittsburgh Testing Laboratories in accordance with SNT-TC-1A (1980 Edition). PT examination of components for nuclear actuators was not being
ORGANIZATION: LIMITORQUE c.0RP0 RATION LYNCHBURG, IRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 10 of 21 conducted on two occasions when the inspector witnessed activities performed at final inspection station No. 1. Revision 9 to PT Procedure No. QCP-11 was on file, and a " Flow Chart for PT" was attached near the PT station. The chart, which was signed by the Level III and the QC Manager and dated April 30, 1985, identified penetrant dwell and development times.
- 7. (Closed) Nonconformance (Item G, 83-01): Hardness testers were checked only once every three months and unacceptable readings were obtained when calibration checks were performed at the request of the NRC.
During a walkthrough, calibration checks of three hardness testers were performed at the request of the NRC inspector. Acceptable readings were obtained on the microhardness tester in the Special Process Department (SPD) and two Rockwell testers, one in SPD and the other in Station No. 1.
E. OTHER FINDINGS OR COMMENTS:
- 1. Qualification of Electric Wiring in Limitorque Valve Operators
'The NRC inspector reviewed documentation and held discussions with Limitorque personnel to determine the basis for the environ-mental qualification of internal wiring for Limitorque valve operators. These activities were conducted as a followup to a 10 CFR Part 21 report from Connonwealth Edison, concerning the discovery that four Limitorque valve operators at the Zion nuclear plant had jumper wires different than the wires which Limitorque claimed were qualified for use in their valve operators.
Additionally, the Tennessee Valley Authority (TVA) notified the NRC in October 1985 that they were unable to adequately document the environmental qualification of internal jumper wires on 214 Limitorque valve operators at Sequoyah Nuclear Plant (SNP).
Therefore, TVA was going to repl~ ace all jumper wires in Limitorque valve operators with wires containing documented environmental qualification.
In conjunction with this inspection at Limitorque, a vendor inspector and one NRC Region II inspector visited TVA offices
- in Knoxville, Tennessee on October 29, 1985 and SNP in Daisy,
{ Tennessee on October 30, 1985 to obtain information concerning TVA's valve operator rewiring activities and to followup the
/ l
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 11 of 21 information at Limitorque. As part of the effort at TVA, three valve operators for SNP valves (2-FCV-67-146, 1-FCV-63-175, and 1-FCV-3-87) were selected and physically inspected at SNP to determine what jumper wires were installed in the operators.
The physical inspection determined that Rockbestos.Firewall SIS (switchboard) wire was installed in operators for vcives 2-FCV-67-146 and 1-FCV-3-87 as well as Carolina Wiring Cable Company (CWCC) wire. The wiring in the operator for valve 1-FCV-63-175 was identified as Teledyne Thermatic and AMP.L-79F 125 . Shop order numbers and operator serial numbers for the three operators were recorded to trace through Limitorque's documentation to determine what wiring had been installed in the operators at Limitorque.
At Limitorque, the inspector reviewed Bill of Materials (BMs),
drawings, and final inspection and test reports for the three SNP operators and determined that Rockbestos Firewall SIS wire had been installed by Limitorcue in the operator for SNP valves 2-FCV-67-146 and 1-FCV-3-87. Limitorque stated that the CWCC wires were added by someone else. During the TVA visit, the inspectors determined that TVA had probably installed the CWCC wires. Limitorque had no record of the type of wires they had installed in the operator for valve 1-FCV-63-175 since it had been purchased as a commercial operator (non nuclear) by Walworth Valve Company in mid-1973. Limitorque does not maintain records that would identify the type of wire installed in commercial (non nuclear) operators. Limitorque further stated that they were unfamiliar with the Teledyne Thermatic or AMP wires.
Qualification of the operator for valve 1-FCV-63-175 will be reviewed during a future NRC inspection at SNP.
Based on discussions with Limitorque personnel and review of Limitorque test reports, the inspector determined that Limitorque does not specifically address wiring or wiring qualification in their qualification test reports'. They consider their valve operators sold as safety related nuclear to be qualified (including internal wiring), if either Raychem Flametrol or Rockbestos Firewall SIS (Rockbestos specification RSS-4-002) jumper wires are installed in the operators. Qualification of these wires for use in Limitorque operators is based on individual qualification test reports for the wires rather than the Limitorque operator qualification program. The qualification of the Firewall SIS was based on a Rockbestos
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 12 of 21 Qualification Test Report for Firewall III/ SIS dated February 1,1977; however, the validity of all Rockbestos cualification tests conducted prior to June 1983 were questioned in IE Information Notice (IN) 84-44. Based on this information notice, the qualification of Firewall SIS jumper wires is considered unsupporte.d when qualification is based solely on the February 1, 1977 Rockbestos report; however, Rockbestos has recently provided Limitorque with results of its requalification tests conducted during the past year. The Rockbestos requalification tests are being conducted to resolve the qualification concerns identified in IN 84-44. The new test reports provided Limitorque support qualification of Firewall irradiation cross-linked polyethylene (XLPE) and the presently produced chemically XLPE (760-D formula) wires. Both of these XLPEs are covered by the Rockbestos specification RSS-4-002. Analysis of the cable test reports need to be performed and documented to assure that qualifi-cation of the wires is clearly established for specific applications.
The inspector's review of P0s established that Limitorque generally installed Raychem wire in valve operators from 1973 until approximately October 1978 at which time they started using Rockbestos wire.
Additional discussions with Limitorque personne. established that even though Limitorque may provide or reference documentation to support qualification of jumper wires they have installed in their nuclear supplied valve operators, valve manufacturers, licensees, or others may have added additional wires which are not qualified by the Limitorque data. The physical inspection at TVA's Sequoyah nuclear plant verified the above to be true.
- 2. Valve / Actuator Weicht Discrepancies Babcock & Wilcox (B&W) was notified in December 1984 of discrepancies in valve actuator weights listed in the valve vendor's drawings and seismic analyses. This problem, which involved valves manufactured by Anchor / Darling, Rockwell International, Copes-Vulcan, and ACF Industries, was identified by TVA at Bellefonte Units Nos. I and 2.
The NRC inspector reviewed Limitorque records and identified P0 No.
048072LU from B&W to Limitorque to perform actual weight calculations for 18 actuators supplied by the above valve vendors. The calcu-lations identified the valve vendor, Limitorque's order number, total actuator unit weights, motor size, handwheel size and
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 13 of 21 mounting configuration and the actuator type. These calculations were completed March 18, 1985 and supplied to B&W on April 1, 1985. This area will be further reviewed at a future inspection of B&W to obtain the results of their evaluation / investigation.
- 3. Reliance Electric Motors - Magnesium Alloy Rotors During qualification testing by General Electric, a Limitorque AC motor operator exhibited a substantial loss of torque. The failure was traced to the Reliance Electric motor and attributed to the use of a magnesium alloy rotor. This problem was identified by Niagara Mohawk Power Corporation at Nine Mile Point Unit 2 and Gulf States Utility Company at River Bend.
At the request of Stone & Webster Engineering (S&W), Limitorque is currently pursuing a feasibility study on the development of motor designs utilizing alternate materials for the magnesium alloy rotor historically used in the standard, medium, and large frame nuclear notors (i.e., 180 frane and above). Limitorque stated that since the failure was at conditions exceeding the qualification parameters, no further action will be taken by Limitorque.
- 4. 10 CFR Part 21 Limitorque's process for evaluating and reporting Part 21 deficiencies was reviewed. Procedure No. QCP-22, relating to the reporting of defects and failures describes responsibilities for the Design Review Comittee (DRC) but does not identify the chairman or members of the DRC. The procedure does not contain requirements for a committee quorum nor require written minutes to be kept of the committee's evaluations, course of corrective actions, and actions relative to NRC notification for 10 CFR Part 21 reporting. (Note: Procedure No. QCP-15 specifies a composition for a DRC for design control matters.) The procedure assigns the Technical Manager with the responsibility for reviewing all field services and customer problem reports. However, no formal procedure exists that requires personnel who handle these reports to submit them to the Technical Manager so that he may perform the required reviews.
A file of DRC minutes provided by the Technical Manager was reviewed. The general nature of the topics discussed in these minutes was product development or production oriented. No reference was found concerning any items discussed for 10 CFR
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORP INSPECTION NO.: 99900100/85-01 RESULTS: PAGF 14 of 21 Part 21 reporting. The minutes in the file covered meetings which were held on November 11, 1983; January 4, March 8, April 19 and 27, September 4 and 20, and October 18, 1984; and February 21, March 11, and September 13, 1985.
Some confusion apparently exists within Limitorque concernirg what specifically constitutes a 10 CFR Part 21 report. The QA Administrator verbally stated that Limitorque has never submitted a 10 CFR Part 21 report, although they have submitted 10 CFP Part 21 Maintenance Advisories (e.g., Limitorque letter to the NRC dated January 10,1983). Yet, the Limitorque Interoffice memo dated February 10, 1983 that distributed NRC IN 83-02 dated January 28, 1983 referred to the Limitorque January 10, 1983 letter as a Part 21 notification.
Violation 85-01-02 was identified in this area of the inspection.
The content of Procedure No. QCP-22 was reviewed and the implementation of the procedure in regard to 10 CFR Part 21 posting requirerents was assessed by inspecting the engineering-and shop fabrication areas. The procedure does not identify the responsible director or corporate officer per Part 21 requirements and does not assure that such a director is informed if a basic component fails to comply with regulations or contains a defect.
Rather, procedures assign this responsibility to the DRC. Also, the procedure does not provide for informing the licensee or purchaser of a deviation or defect.
A copy of the regulation and a Notice were posted in the engineering areas, but there was no posting in the shop fabrication area. In addition, the Notice did not contain all the information required by the regulations (see Violation 85-01-03).
- 5. Actuator Spring Pack Design Changes NRC memorandum AE0D/E509 dated July 25, 1985 discusses a depres-surization event that occurred at Salem Unit 2. Although unrelated to the cause of the event, the subsequent investigation identified that one of the block valves involved had its Limitorque actuator replaced in April 1984. The replacement actuator contained a spring pack with a slightly higher spring constant than the spring pack on the original actuator. It was determined that Limitorque had incorporated small design changes between the original
ORGANIZATION: LIMIT 0RQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 15 of 21 procurement and the procurement of the replacement actuator. The end result was that the toroue limit switch sett!ng on the replace-ment actuator had to be set at a different value than the one on the original actuator to obtain the same torque valve.
Limitorque's practice relating to changing part nurloers when design changes are made is to assign new part numbers when a design change affects form, fit, or function. According to Limitorque, design change for a spring pack may or may not affect form, fit or function. A design change that modifies the spring constant but not the torque setting range is not considered by Limitorque to affect form, fit, or function, and a part number change is not made in this case.
Further investigation revealed that Limitorque does not routinely advise customers they are receiving an actuator which contains a spring pack with a different spring constant, although Limitorque will provide this information if requested by the customer. One exception to this practice occurs if a customer purchases a replacement spring pack. In this case, a torque limit calibration tag is attached to the replacement spring pack which identifies the torque limit setting and corresponding torque.
The Limitorque practice that permits replacement spring pack changes to be made without either changing part numbers or providing notice of the change to a customer when replacement parts are ordered is of concern. This could lead to confusion by customer maintenance personnel who might set the torque limit switch on a replacement actuator at the same number as the original actuator, believing this will yield the same torque.
- 6. Procurement Document Control The NRC inspector reviewed applicable sections of the QAM, and 22 P0s issued to 9 vendors to assure that quality requirements (e.g., ANSI N45.2 and 10 CFR Part 21) were passed on to suppliers / manufacturers of components for actuators destined for nuclear service. As noted below, 13 of the 22 P0s did not impose ANSI N45.2 and 10 CFR Part 21 requirements on the vendor, and 3 of the P0s did not identify the latest revision of drawings and electrical quality control (EQC) documents (see Nonconformance 85-01-04). It was also noted that quality personnel do not review P0s for inclusicn of quality requirements prior to the issuance of P0s to vendors.
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 16 of 21 P0 Date Vendor I'em DIL-89921 7/12/85 Walker Machine Drive Sleeve DIL-87878 2/22/85 Walker Machine Drive Sleeve BSL-91090-MT 10/3/85 Southern Centrifugal Drive Sleeve &
Gear BSL-90260-MT 8/15/85 Southern Centrifugal Drive Sleeve &
Gear CIL-90997 9/24/85 Lynchburg Foundry Co. Housing DIL-85391 2/5/85 Lynchburg Foundry Co. Housing Cover LS-0726 6/12/84 Foster Electric Rockbestos 14 AWG Wire LS-1046 9/4/84 Foster Electric Rockbestos 14 AWG Wire LS-1540 1/10/85 Foster Electric Rockbestos 14 AWG Wire LS-8034 6/17/82 Wesco Inc. Rockbestos 14 AWG Wire SSL-91312 --
Ryerson Steel Bar Stock SSL-89633 --
Ryerson Steel Bar Stock 10/1/85 Copperweld Steel Bar Stock P0 (Item) Vendor DWG/EQC (Rev) 3P3400 Item A Peerless-Winsmith EQC-1 (F)*
3P3673 Item S Peerless-Winsmith DWG #21-497-0014-1 (B)**
3P3673 Item G Peerless-Winsmith EQC-1 (F)*
3P3673 Item G Peerless-Winsmith DWG #21-497-0014-1 (B)**
Latest revision is "G" dated June 11, 1983
- Latest revision is "C" dated July 10, 1985
- 7. NDE The NRC inspector reviewed the qualification and certification records of NDE personnel (one-Level III and two-Level II) to determine whether the individuals performing PT examinations were certified to SNT-TC-1A. The written practice (Procedure No. QCP-11) of Limitorque for all phases of certifying NDE personnel was also reviewed. The procedure indicated that training and examination was to be in accordance with SNT-TC-1A and also identified the standard methods for PT examination which included cleaning, application of dye, application of developer, and the acceptance / rejection criteria.
The procedure did not address the responsibility of each level of certification or duration on interrupted service requiring reexamination and re-certification.
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 17 of 21 Training and examination had been given to the three NDE personnel by a Level III examiner fron Pittsburgh Testing Laboratories in June 1983. With the exception of a statement showing satisfactory completion of training in accordance with Procedure No. QCP-11, the qualification records of the three NDE personnel appeared to be in accordance with SNT-TC-1A. Nonconformance 85-01-06 was identified in this area of the inspection.
- 8. Audits The NRC inspector reviewed applicable sections of the QAM, two Quality Control Procedures (QCP), four internal audit reports for 1983 and 1984, five vendor audits, 32 evaluations, and 10 appraisal reports to assure that item and services were being purchased from qualified vendors. It was noted that the area of QA Records was not covered in either the 1983 or 1984 audits (see Nonconformance 85-01-07).
Vendor evaluations are not completed every six months as required by a QCP. It was also noted that vendors who maintained a rating below Limitorque's quality standards were still listed in the AVL (quality standard is based on a 95% acceptance rate of receipt inspection).
Two vendors who performed calibration services were listed in the AVL, but they have not been audited by Limitorque.
Nonconformance 85-01-08 was identified in this area of the inspection.
- 9. Calibration of M&TE The NRC inspector reviewed applicable sections of the QAM, one procedure, records for M&TE, and certifications for reference standards used by service vendors to calibrate M&TE. An observation of M&TE at various work stations was also performed to assure that M&TE are properly identified, controlled and calibrated at specified intervals.
All of the M&TE were identified with a S/N and contained a sticker from Limitorque and/or the outside calibrator. The calibration dates on the sticker were cross-checked against gage record cards in the calibration lab and were found to be satisfactory. The M&TE checked included:
l
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 18 of 21 Station S/N Item Calibrator (date)
No. 1 QC 593 0-1" micrometer L (11/85)
QC 493 2-3" micrometer L (11/85)
QC 760 6" vernier L (10/85)
QC 267 surface plate Hartzog (10/84)
QC 743 hardness tester Page/ Wilson (9/85)
Lathe QC 651 3-4" micrometer L (10/85)
QC 703 inside micrometer L (4/85)
Automatic QC 863 height gage L (9/85)
QC 289 surface plate (3'x6') Hartzog (10/84)
QC 761 depth vernier L (5/85)
Gear QC 610 surface plate (12"x18") Hartzog (10/84)
QC 634 dial depth gage L (11/85)
QC 27 4-5" micrometer L (11/85)
Receipt QC 949 vernier L (10/85)
.nspection QC 750 vernier L (7/85)
Special QC 861 hardness tester Page/ Wilson (9/85)
Process QC 792 micro-hardness taster Page/ Wilson (9/85)
Heat Treat QC 769 chart recorder Honeywell (10/85)
QC 770 temp recorder Honeywell (10/85)
QC 768 chart recorder Honeywell (10/85)
QC 766 chart recorder Honeywell (10/85)
QC 767 chart recorder Honeywell (10/85)
It was noted that the calibration of the three service plates by Hartzog was one month overdue, but the inspector was told that Limitorque was contacted by Hartzog, and the delay was due to a personal problem at Hartzog.
In the Special Process Department, the manager checked out both hardness testers using gage calibration blocks on the 30N scale on the Rockwell tester and KHN 746/750 on the microhardness tester.
It was noted that calibration samples No. 501-506 from Leco Corporation were used to calibrate the " Carbon Determinator - EC 12" instrument just prior to use.
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION N0.: 99900100/85-01 RESULTS: PAGE 19 of 21 At Station No.1, the Level II examiner checked out the hardness tester using two gage calibration blocks (i.e., 3 x w/Rc and 1 x w/Rn.) It was noted that the master setting disc (S/N QC 1038) from REB Ind, was not calibrated, but the QC Manager indicated that
- t was only used for reference purposes.
In the Gage Lab, a list of reference / transfer standards were reviewed, and calibration certifications from a number of service vendors were reviewed as noted:
S/N Item Calibrator QC 610 12" x 18" surface plate Hartzog QC 289 36" x 72" surface plate Hartzog QC 606 gage blocks (reference) L QC 406 gage blocks (master) Webster Gage.
Hardness tester (6) Page Wilson Shinatzo NT-M001 Micro tester Page Wilson All certifications showed traceability to the National Bureau of Standards. The Rockwell hardness testers were certified to ASTM E-18 and the microhardness tester to ASTM E384.
- 10. Motor Operator Failure - Feedwater Isolation Valve During testing in December 1984 at the River Bend job site of a feedwater system valve, the drive sleeve for the valve operator failed. The valve operator was returned to Limitorque for determination of the cause of failure, replacement of damaged parts, specified testing and inspection prior to return to the jcb site. Meetings held at the job site between responsible piping engineers and test engineers failed to identify the cause of the failure. A review of the condition of the operator by Limitorque was documented in an Inter-0ffice Correspondence dated September 25, 1984, but it did not show the cause of the failure.
The inspector reviewed: S&W P0 No. 28530 dated April 13, 1984 issued to Limitorque for repair and retest of one actuator (S/N 321320); letter dated May 24, 1984 from Limitorque to S&W identifying parts replaced (one torque switch, two geared limit switch finger assemblies and one drive sleeve) and test performed; and a letter dated September 27, 1984 from Limitorque to Velan
ORGANIZATION: LIMIT 0RQUE CORPORATION LYNCHBURG, VIRGINIA REPORT -
INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 20 of 21 Engineering (valve manufacturer) stating that the cause of the failure was due to several stall thrust loads. The inspector also reviewed S&W's Certificate of Compliance dated July 3,1984 which indicated the actuator was tested and inspected by S&W representative prior to shipping.
- 11. Documentation Packages The NRC inspector reviewed six documentation packages and-QC-Nuclear files for safety-related actuators ordered in November 1983 to July 1985. The six P0s from Public Service Electric &
Gas, Niagara Mohawk Power Corporation, Velan Valve, Westinghouse, Northeast Utilities, and Iowa Electric Light & Power Company referenced specific technical specifications, 10 CFR Part 21, and IEEE Standards. The documentation packages consisted of calibration sheets, Bill of fiaterials, P0s to motor manufacturers, Certificate of Compliances and test reports and performance curves from motor manufacturers.
The P0s to two motor manufacturers, Reliance Electric and H. K.
Porter, referenced standard EQC-1 and drawing No.21-497 ...
, which documented technical and quality requirements. The QC-Nuclear file for each order consisted of a station No.1 inspection report, final inspection and test report, liquid penetrant examination report and a coating certification.
It was noted that quality requirements (e.g., QA Program and 10 CFR Part 21) were only imposed upon motor manufacturers. The imposition of quality requirements was imposed upon cable manufacturers starting in March 1985. Traceability is maintained only on the motor and the completed actuator to specific tests, but there is no traceability to individual components.
- 12. QA Program Deficiencies In reviewing the previous inspection findings, it was noted that the deficiency in nonconformance (Item A, 84-01) was originally identified by the NRC during an April 1982 inspection. In a letter dated November 15, 1982 to the NRC, Limitorque stated, "Limitorque Corporation to revise QA manual to include training of non-QC personnel." Approximately three years have gone by, and Limitorque has still failed to incorporate this activity into their QA manual (see Nonconformance 85-01-05).
ORGANIZATION: LIMITORQUE CORPORATION LYNCHBURG, VIRGINIA REPORT INSPECTION NO.: 99900100/85-01 RESULTS: PAGE 21 of 21
[
TVA had reported a number of QA program deficiencies in a combined deficiency report (10 CFR Part 50.55(e)) and a defect report (10 CFR Part 21) dated December 15, 1983, for valve operators to be supplied for Watts Bar and Bellefonte Units 1 and 2. Three deficiencies were closed out by TVA in a March 6, 1984 letter (QDBVA-84-5) which was reviewed by the NRC inspector.
- 13. Control of Purchased Material 90s for bar stock to Ryerson Steel called for ASTM A304 heat treatable 8620 steel, but the CMTR specified that ASTM-A-322 heat treatable 8620 steel had been supplied. The QC Manager's explanation of this was that the two specifications were the same if a Jominy test was performed on the material. This test provides hardness values which can be used to determine the heat treatability of the steel. In the CMTR mentioned above and others reviewed, the QC Manager stated that the Jominy values were compared to the required ASTM A304 standard and found to be adequata. When asked as to whether an internal deficiency reported was filed by the receiving inspector, the QC Manager said no because the acceptability of ASTM-A-322-82 standard 8620 steel was verified verbally with the engineering department.
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