ML20154H042
| ML20154H042 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/1988 |
| From: | Baker E, Petrosino J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20154H032 | List: |
| References | |
| REF-QA-99900369 NUDOCS 8809210153 | |
| Download: ML20154H042 (18) | |
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ORGANIZATION: AUTOMATIC SWITCH COMPANY 7l \/ / \ A FLORHAM PARK, NEW JERSEY REPORT INSPECTION INSPECTION h0.: 99900369/88-01 DATE: June 27 July 1, 1988 ON-SITE HOURS: 160 CORRESPONDENCE ADDRESS: Mr. James McConnell Automatic Switch Company 50-56 Hanover Road Florham Park, New Jersey 07932 ORGANIZATIONAL CONTACT: Mr. David Tompsen, QA Director TELEPHONF NUMBER: (201)966-2350 NUCLEAR INDUSTRY ACTIVITY: Automatic Switch Company (ASCO) manufactures a line of electrical three-way and four-way solenoid valves that are used for pilot control of diaphragm and cylinder operated valves.
I l/
ASSIGNED INSPECTOR: bud lhN o'sepfi J 7etrosino Me>Nc86 M88 IMte-~
eactive Inspection Section, VIB:DRIS:NRR OTHER INSPECTORS: S. Alexander, NRC/NRR
. Ornstein, NRC/AEOD T. Tinkel, Brookhaven Na ional Laboratory APPROVED BY:
I Edward T. Baker, Section Chief ae Reactive Inspection Section, VIB:DRIS:NRR INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21 and Appendix B to 10 CFR Part 50 B. SCOPE: The inspection was conducted as a result of solenoid operational problems that have been identified in several nuclear plants which use ASCO three-way and four-way electrical solenoid pilot valves.
PLANT SITE APPLICABILITY: All plants.
E t V C 99900349 PDC
ORGANIZATION: AUTOMATIC SWITCH COMPANY -
FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 2 of 18 A. VIOLATIONS:
Contrary to 10 CFR Part 21, "Reporting of Defects and Noncompliance:"
- 1. ASCO has failed to evaluate numerous deviations, nonconfermances, and omissions for reportability or to inform the applicable licensees so that they may cause an evaluation to be performed. Some of the examples reviewed by the inspectors may be reportable pursuant to 10 CFR Part 21 (88-01-01).
This is a Severity Level III violation (Supplement VII).
- 2. ASCO has failed to establish an adequate procedure to implement the pro-visions of Part 21 in regard to its control and disposition of poten-tially reportable deviations and nonconformances or to notify its end users so they may cause an evaluation to be performed (88-01-02).
This is a Severity Level V violation (Supplement VII).
B. NONCONFORMANCES:
- 1. Contrary to Criterion I, "Organization," of Appendix B to 10 CFR Part 50, the ASCO QA Director does not report to a manacement level which provides adequate independence from cost and schedule when opposed to nuclear plant safety considerations (88-01-03).
- 2. Contrary to Criterion III, "Design Control," of Appendix B to 10 CFR Part 50, the ASCO manufacturing department is allowed to modify its
solenoid valve fabrication procedures and implement the product changes without the requirement of a review of the change for technical ade-quacy being performed by ASCO engineering prior to implementation (88-01-04).
- 3. Contrary to Criterion XVI, "Corrective Action," of Appendix B to 10 CFR Part 50, ASCO has failed to control all of its product nonconformances and deviations to assure that the issues are properly identified, eval-usted, reported to appropriate levels of management, and dispositioned to include corrective action to preclude recurrence and identify poten-tially indeterminate hardware that has been previously installed. ASCO engineering is allowed by its January 3, 1983 "procedure for reporting deviations" (MP-I-081) to make dispositions of nonconformances and deviations that are not in accordance with the intent of NRC regulations with regard to detennining whether an identified deviation affects previously installed hardware, or in the case of a deviation at a specific nuclear facility, whether it potentially affects other licensees (88-01-05).
l ORGANIZATION: AUTOMATIC SWITCH COMPANY -
FLORHAM PARK NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 3 of 18 C. UNRESOLVED ITEMS:
- 1. Unresolved ASCO may have failed to adequately evaluate under 10 CFR Part 21 a potentially reportable extrusion phenomena that was observed during its 1982 environmental qualification testing activities for its "Tri-Point" pressure switches. ASCO did not detemine the applicability of the phenomena to other nuclear plant facilities.
Background
On April 26, 1988 the Yankee Atomic Power Company (YAPCO), licensee for the Yankee Atomic Power Station in Rowe Massachusettses (Yankee-Rowe), reported to the NRC under 10CFR21 a potential design defect found in their ASCO "Tri-Point" nuclear pressure switches, Model SB12BMR/TL10A22. Five of twelve of their main steamline isolation valve pressure switches had failed a periodic surveillance. Some were adjusted into tolerance, but others had to be replaced due to their failure to operate properly. The failures were presented as set point drift and deadband widening with the inability to recalibrate.
The NRC inspector examined components of failed pressure switch trans-ducers from Yankee-Rowe (sent to ASCO by YAPC0 for evaluation),
reviewed laboratory photographs and associated records and inter-viewed cognizant personnel. Disassembly of the pressure transducer section of the pressure switches revealed gross deterioration and b deformation of the resilient cast polyurethane disc that acts as a wear and load distribution cushion between the viton diaphragm (pres-sure sensing element) and the switch actuating piston (mechanical interface with the switch assembly actuating rod). The deterioration included apparent loss of material, tearing, flaking, and discoloration.
in addition, the ASCO laboratory had tested samples provided by YAPC0 and determined that they were excessively soft (significantly below the specified durometer reading). It was not clear, however, whether the loss of resilience / softening resulted from in-service degradation or was a pre-existing condition, and thus, a deviation from disc pro-curement specifications. ASCO uses various analytic techniques in the materials laboratory at their Florham Park, New Jersey facility including scanning calorimetry to identify incoming materials and verify certain material properties. However, the durometer is checked by quality control personnePat the stocking location for these parts at ASCO's North Carolina facility on a sampling basis. ASCO's inves-tigation into this issue is to include these questions and also the quality assurance measures employed by the vendor for pertinent
ORGANIZATION: AUTOMATIC SWITCH COMPANY .
- FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 4 of 18 attributes. ASCO's efforts are being followed by this office and will also be reviewed in future inspections.
The deformation mode to which the performance degradation was attri-buteri was the extrusion of part of the polyurethane disc surface into the narrow (a few thousandths of an inch) annulus between the piston and the cylinder in the transducer bonnet in which it is supposed to slide freely in response to pressure fluctuations.
The YAPC0 Part 21 report indicated that ASCO had claimed not to have ooserved this problem with these particular units in the past. How-ever, the NRC inspector learned that while ASCO may not have received identical complaints from the field, the extrusion phenomena had been observed by ASCO in environmental qualification (EQ) test specimens.
The inspector examined an EQ test specimen disc, noting that it had extruded, but to a considerably lesser degree. ASCO stated that it had not included these observations in the EQ test report because the extrusion had not been severe enough to degrade performance outside specified test acceptance criteria in terms of deadband widening and setpoint drift.
ASCO's plans were to continue the evaluation to determine the root cause(s) of the failure. Their course of action was to include further laboratory testing, checking their stock of discs for proper durometer readings (on a sampling basis) and review past QC inspection records. In addition, ASCO was to evaluate the type and extent of customer notification to be made. The issue is being followed by this office of the NRC due to its potential generic implications and is
- t. therefoce classified as an UNRESOLVED item (88-01-06).
- 2. Design change document ER86154 that incorporated a strainer in the inlet flow path of an ASCO NP8320 series does not indicate whether an engineering review for technical adequacy was performed. ASCO has ,
comitted to providing additional information. Therefore this item is classified as UNRESOLVED (88-01-07).
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
Neither reviewed nor discussed during this inspection.
E. INSPECTICN FINDINGS AND OTHER COMMENTS:
- 1. Entrance and Exit Meetings -
The NRC staff informed the ASCO management representatives of the scope of the inspection during the entrance meeting on June 27, 1980
ORGANIZATION: AUTOMATIC SWITCH COMPANY _
FLORHAM PARK. NEW JERSEY REPORT INSPECTION h0.: 99900369/88-01 RESULTS: PAGE 5 of 18 and sunnarized the significance of the inspection findings, observations and NRC staff concerns during the exit meeting on July 1, 1988.
- 2. Background There have been numerous safety-related system / component failures due to inoperable solenoid pilot valves reported within the past 10 years.
The safety-related systems / components include containment isolation valves for dry well drain systems, main steam isolation valves (MSIV) and other safety-related valves that utilize a pilot valve for its associated actuator operation. One of the more recent failures con-cerned a January 2, 1988 event at Brunswick Unit 2 where two redun-dant containment isolation valves on the dry well drain system failed to close. Neither ASCO nor the licensee were able to subsequently determine the root cause of the failure.
As a result of the recurring problems with solenoid valves, in general, several NRC generic corrnunications have been issued which include:
- Circular 81-14 "Main Steam Isolation Valve Failures to Close" IN 85-15 "Possible Sticking of ASCO Solenoid Valves"
Each of the generic connunication documents and licensee problem reports identify specific solenoid failures due to the specific operating parameters and application at the licensee facility. How-5 ever, the NRC staff.is also concerned with potential generic problems due to vendor design evolvement, manufacturing process control, or identified field problems that could indicate problems with the pro-duct application.
- 3. 10 CFR Part 21 Procedure A review of the ASCO 10 CFR Part 21 Procedure, MP-1-081, dated January 3, 1983, was performed. The review revealed that the pro-cedure has not been adequately established in regard to Section 21.21 of 10 CFR Part 21 which requires, in part, that each corporation or other entity subject to the 10 CFR Part 21 regulations will adopt appropriate procedures to provide for evaluating deviations or inform-ing the purchaser or licensee of the deviation in order that the licen-see may cause the deviation to be evaluated, l
ORGANIZATION: AUTOMATIC SWITCH COMPANY -
FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 6 of 18 It was found that procedure MP-I-081 does not include provisions to ensure that the licensee is notified of deviations so that the licen-see may cause the deviation to be evaluated to determine whether the issue could cause a loss of safety functions to the extent that there is a major reduction in the degree of public health and safety at that specific facility. Nor do the ASCO procedures require that the devia-tion be evaluated to determine whether a particular deviation could create a substantial safety hazard (violations 88-01-01 and 88-01-02 were identified in this area). It was also noted that procedure MP-1-081 does not address the Section 21.51 requirement of maintaining potentially reportable Part 21 evaluation reports.
Furthermore, it was found that procedure MP-1-081 allows at least three different types of internal engineering documents to be used to process identified nonconformances and deviations which includes:
Engineering Department Procedure (EDP)-91 "Valve Troubleshooting Procedure" EDP-13 "Request for Engineering Investigations (Els)"
Change and Issuing of Investigation Reports (irs).
The Els and irs did not include provisions to assure that conditions adverse to quality (such as nonconformances and deviations) are promptly identified, corrected, root cause identified, and appropri-ate measures are taken to preclude recurrence. The engineering docu-ments that were reviewed also did not include any QA/QC department concurrence or review (nonconformance 88-01-05 was identified in this area). . _
- 4. ASCO QA Organization During the performance of the ASCO inspection, the inspector perceived a problem with the involvement of the QA organization in regard to departments other than production. Therefore, discussions were con-ducted with ASCO personnel to deterinine whether or not the QA involve-ment in activities affecting quality were appropriate to the circumstances.
Criterion I, "Organization," requires, in part, that the persons and urganizations performing quality assurance functions shall have suf-ficient authority and organizational freedom to identify quality pro-blems; to initiate, recomend, or provide solutions; and to verify implementation of solutions.' Such persons and organizations perform-ing OA functions will report to a managenent level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to nuclear pidnt
ORGANIZATION: AUTOMATIC SWITCH COMPANY -
FLORHAM PARK. NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 7 of 18 safety considerations, are provided. Irrespective of the organizational structure, the individuals assigned the responsibility for assuring effective execution of any portion of the quality assur-ance program will have direct access to such levels of management as may be necessary to perform this function.
Contrary to the requirements, it was found that the current ASCO organ-izational structure neither allows direct 0A department access to an appropriate level of management nor ensures that the QA department is sufficiently independent from cost and production schedule when opposed to nuclear plant safety considerations. The ASCO QA manual organiza-tional chart indicates that the QA departrient manager reports to the operations vice president (VP) who also has a plant manager, production control manager and purchasing manager reporting to him. The operations VP reports to the ASCO president. The ASCO president has six other VPs reporting to him on an equal reporting level as the operations VP.
The other six VPs that report to the president, and whether they are involved in nuclear safety-related activities are as follows:
VP Title Safety Related Activities Accounting VP Sales record retention Valve Department VP Engineering (design, etc.),
sales, and services Switch Departrient VP Engineering, sales, and services Industrial Relations VP Training plans and QA indoctrination International VP None Planning and Sta*istical VP Unknown The above departments each appear to function in an autonomous fashion and QA involvement appears to be limited to a periodic audit. The internal audit schedule, in regard to performance frequency, was not reviewed. However, discussions with QA/QC and engineering personnel indicate that other than periodic audits the QA department has no delineated involvement in ASCO nuclear safety-related quality activi-ties (i.e., design change, customer deviation issues) in areas other than production and receiving. honconformance 88-01-03 was identified in the QA area.
- 5. Review of Design Control
Background
The inspectors employed the following methodology to evaluate the ASCO design control process. A typical solenoid valve from ASCO's
ORGANIZATION: AUTOMATIC SWITCH COMPANY _
FLORHAM PARK, NEW JERSEY REPORT INSPECTION N0.: 99900369/88-01 RESULTS: PAGE 8 of 18 nuclear product line was selected and used as a candidate for the review. Based on information obtained from the other members of the NRC inspection team, an ASCO NP8320A184 valve was selected. The NP8329A184 is a three-way solenoid valve that is used in various applications in commercial nuclear power plants. The drawings, bill of material, and assembly procedure for the valve were obtained and examined to identify changes that have been made. The ASCO document used to effect and control drawing changes is called an Engineering Release (EF:). Various ERs that affected the NP8320A184 were selected for review to identify some of the specific technical changes that have been made. For selected technical changes, associated documen-tation was reviewed to evaluate how ASCO assessed the impact that these changes may have had on the design, perfomance characteristics, ano qualification status of the valve. Changes issued from about 1977 to the present were included in the review to envelope the environmental qualification testing conducted in 1978 and in 1981 by ASCO.
- a. Review of JVA-206-385, the NP 8320A184 assembly drawing:
(1) Examples of some of the ERs that were issued which affected this drawing include:
DWG, CHANGE ER N0. REV. DATE HIGHLIGHTS 101631 F July 28, 1982 Kit numbers changed 96867 E April 22, 1981 Kit numbers changed f* 96077 0 February 11, 1981 added viton construction option 87411 C March 9, 1979 Various changes 86154 B November 6, 1978 Various changes including addition of strainers 83902 A December 28, 1977 Various changes 83431 - November 21, 1977 Drawing issued (2) Review comerts:
(a) ER 96077. This change provided an option for using Viton Elastomers in ASCO hP valves. This change was qualified by subjecting various valves with Viton Elastomers to environmental type testing. The qual-ification testing was conducted in 1981 and is reported '
in ASCO report AQR-67368.
s
ORGANIZATION: AUTOMATIC SWITCH COMPANY -
- FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 9 of 18 (b) ER 86154. This change incorporated a strainer in the inlet flow path of the valve. ASCO could not provide any documentation that this change had been evaluated to assure the valve's performance cha acteristics were not adversely affected by the strainer. ASCO stated they believed documentation did exist showing that this evaluation had been performed. ASCO agreed to locate and submit the information to the NRC within Une week following the inspection; however, ASCO did not pro-vide this information therefore, it is classified as UNRESOLVED (88-)1-07).
- b. Review of FVP-206-385, the NP8320A184 bill of material:
(1) Examples of some of the ERs that were issued and affected this bill of material include:
' DWG. CHANGE l ER NO. REV. ,
DATE HIGHLIGHTS 97798 H October 20, 1981 Changes solenoid base upper gasket 96077 G February 11, 1981 Added viton construction option 90736 F November 29, 1979 Identified a specific coil (GV-38-793-17[HSpec])
f for 125V D C battery applications. Invoked
- - - AP-1-026 87411 E March 9, 1979 Various changes 86609 D November 6, 1978 Various changes including addition of strainers 83902 C December 28, 1977 Various changes 83258 B October 27, 1977 Delete manual operator substitution 82965 A September 23, 1977 Corrected typo (2) Review comment:
(a) ER 90736. This change invoked AP-1-026, ASCO's general instruction for assembly and testing of products containing ethylene propylene elastomer parts in con-tact with flew media. This procedure is intended to prevent contamination from hydrocarbons, among other things. Tbv procedure states in part:
l :
ORGANIZA710N: AUTOMATIC SWITCH COMPANY -
FLO$ HAM PARK NEW JERSEY REPORT INSPECTION NO.: 99330369/88-01 RESULTS: PAGE 10 of 18 All parts should be free of oil and grease.
Any ethylene propylene part of sub-assembly visu-ally contaminated with grease or oil shall be discarded (donotcleanethyleneproyleneparts).
No grease or oil shall be used unless specific instructions are given in the product assembly procedure and then only non-hydrocarbon lubri-cants (Dow Corning 111, 200, Wm. F. Nye Fluorogel 852 B, etc.) shall be used.
The test medium shall be clean dry air or inert gas (nitrogen, helium, etc.) e i test positions must be equipped with a Pall filter for oil remeval.
If testing with water is required, the water should be city water or demineralized water which is free of any water-soluble oil.
Since AP-1-026 makes provisions for possible use of non-hydrocarbon lubricants, ASCO's basis for establishing lubricant compatibility was reviewed. ASCO investigated non-hydrocarbon lubricant compatibility for use in ASCO NP-1 valves by perforniing special testing. This testing is reported in ASCO Engiotering Report 191, dated November 21, 1978. Among other things, the compatibility of Nye Experimental Grease (A, B, and C) Dow Corning 200, Dow Corning 550 in contact with Viton and ethylene propolyene elastoners was tested.
- c. Review of HV-27-502, NP8320A184 coil drawing.
(1; Exan.ples of some of the ERs that were issued and affected this drawing include:
CHANGE ER NO. rey DATE HIGHLIGHTS 125326 OM March 15, 1988 Revised note concerning names of coil suppliers 122732 DK January 21,1.37 Changes coil markings 121844 DH October 27, 1986 Revised note concerning insulation system
4 ORGANIZATION: AUTOMAT!C SWITCH COMPMiY -
. FLORHAM PARK, NEW JERSEY REPORT INSPECTION h0.: 99900369/88-01 RESULTS: PAGE 11 of 18 CHANGE ERN2 REV. DATE HIGHLIGHTS 116839 DB November 18, 1985 Made provisions 'or longer lead length 112962 DA December 11, 1984 Deleted various coil configurations 109726 CW February 3,1984 Deleted a coil marking 108644 CV October 19, 1983 Added coil cross reference information 100565 CT March 19, 1982 Corrected coil resis-tance value 95100 CR December 3, 1980 Updated title block for computerized bill of material 86928 CP December 8, 1978 Updated coil specification information (2) Review Comment:
(a) ER125326 appeared to indicate that ASCO had changed coil suppliers. Since this could affect the quality of the valve, this matter was discussed wiih ASCO's nuclear product manager (E. Plaut). He stated that ASCO did not change coil suppliers. Rath6r, *'e name of the coil supplier changed because of a change in company ownership. Under the new
- t. . . name, the coils were made in the srme facility, by the same people, using the same equipment and procedures.
- d. R6tiew of procedure AP-NPS320A-1, the assembly procedure for NP3320A series nuclear valves.
(1) ASCO asse.nbly procedures are controlled by the nanufactur-ing department. The document used to effece changes to assembly procedures is called a tool change.
(2) Examples of some of the tool changes that were issued and affected in this procedure include:
s t
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ORGANIZATION: AUTOMATIC SWITCH COMPANY -
,FLORHM1 PARK NEW JECSEY REPORT INSPECTION N0 : 99900369/88-01 RESULTS: PAGE 12 of 18 TOOL CHG PROC. CHANGE NO. REV. DATE HIGHLIGHTS 2358 A December 20, 1979 Changes hbricant from Dow Corning valve seal to compound (111 2449 B June 13, 1980 Various changes 2545 C February 6, 1981 Changes lubricants from Dow Corning 200 to 500, and "valve seal" to 111, and Neolube to Neolube !!
2552 0 March 2, 1981 Various changes 2861 E February 23, 1983 Deleted from caution note "Do not oil cores per AP-1-001" 3406 F June 27, 1986 Added provisions to lub-ricate solenoid base gaskets and "non-captive" gaskets with Nyogel 775A instead of Dow Corning 550 3388 G April 16,1985 Various changes 3460 H March 26, 1987 Updated information (3) Review corments:
(a) Some of the assembly procedure changes are technical and have the potential for impacting design, perfor-mance, or qualification of the valve. Examples are the tool changes that changed lubricants (i.e. 2358, 2545,3406). Although some of the above mentioned tool changes were requested by ASCO Engineering, no formal procedure currently exists requiring engineer-ing to perform an advanced review and concur that pro-posed tool changes will not adversely affect design, performance, or qualification of the respective valves.
(b) Among other things, AP-NP8320A-1 states for "E" suffixed (ethylene propylene elastomer) valves:
Inspect and clean all parts per AP-1-026.
- Lubricate the retainer gad et with Dow Corning l 550 fluid.
- Lubricate the body with M 9el 775A,
l ORGANIZATION: AUTOMATIC SWITCH COMPANY .
FLORHAF PARK,, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 13 of 18 It is noted that the non-hydrocarbon lubricants cited in AP-1-026 differ from those specified in AP-NP8320A-1.
This difference could possibly create some confusion and lead to potential inadvertent use of an unspecified lubricant.
- e. Conclusion. Based upon the vertical slice design review performed for the ASCO NP83201A184 solenoid valve, the inspector concludes that ASCO's program for maintaining design control appears satis-facto ry. The review comments noted above are intended to high-light possible areas where the program appears to be weak or could affect the performance of the product for certain applications.
- 6. Review of ASCO response to problems reported by their solenoid valve customers. Several ASCO investigation request memos (irs) and engineering investigation reports (E!s) that discussed ASCO actions to custoner reported problems for ASCO solenoid valves were reviewed,
- a. The following irs were reviewed:
VALVE CATALOG IR NO. DATE SERIES PROBLEM 3954 March 9, 1987 8320B136 Coils failed on six valves due to apparent water damage.
'- 3880 December 29, 1986 - 8320A105 Air leakage occurred at 250 psi af ter about one hour of energization 3794 April 29, 1985 8320B175 Reported 17-7PH core spring breakage 3783 September 18, 1984 HTX 8320931 Five valves had excessive seat leaka e abcve 15 psi (Teflon Discs 3543 March 2, 1981 8320A90 Core springs detached after ebuilding with kit FV-170-415 3604 March 11, 1982 NP 8314C29E Valves sticking - Ft. Calhoun -
Varnish like residue similar to D-C #805
ORGANIZATION: AUTOMATIC SWITCH COMPANY .
FLORHAM PARK, NEW JERSEY t
?EPORT INSPECTION hJ.: 99900369/88-01 RESULTS: PAGE 14 of 18 YALVE CATALOG IR NO. DATE SERIES PROBLEM 3906 April 24, 1987 8316 Series Valve leaks - involves several Colt /Fairbanks Morse customers
- b. The situation documented in IR 3543 was selected for a more detailed review. This review revealed the following:
(1) Prior to this particular customer report, ASCO had already identified that some core springs would not remain in place.
ASCO traced the problem to a shipment of some 99,000 springs obtained on purchase order PV-73366. ASCO further deter-mined that the discrepant springs had been used in both commercial and nuclear valves and in some parts kits.
(2) Stop work order 459A documents corrective action that was taken by ASCO for valves in process, valves in stock, and valves already shipped.
(3) As a result of finding that some nuclear vales were affected. ASCO issued a 10 CFR Part 21 notification on October 24, 1980 to all customers who had purchased affected NP nuclear valves and kits. The nuclear valve catalog numbers identified by ASCO as possibly containing discrepant springs were NP 8320, NP 8316, and NP 8344,
- t. c. During the revjew of ASCO irs. the following correspondence was examined:
(1) ASCO Service Bulletin, dated May 21, 1982 concerning valves for nuclear servic t, an associated ASCO 10 CFR Part 21 noti-fication (form) letter and a June 4,1982 ASCO letter stat-ing these documents were sent out tc OEMs. engineers, and power plants in the various ASCO district offices.
(2) Two additional ASCO Service Bulletins:
SUBJECT DATE DESCRIPTION ASCO NP-1 Solenoid April 1, 1980 This ASCO Service valves using ethylene '
Bulletin references propylene elastomers NRC IE Notice 80-11, dated March 14, 1980 y . _ _ _ , ___ . _ . _
ORCANIZATION: AUTOMATIC SWITCH COMPANY -
FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 15 of 18
_ SUBJECT DATE DESCRIPTION Certain ASCO corrrnercial May 27, 1988 Concerns some valves valves with diaphragm /di!.c assembly which can loosen under maximum rated operating condi-tions, possibly result-ing in seat leakage,
- d. The following 1Rs that were categorized as Els were reviewed:
VALVE CAT.
IR NO. DATI SERIES PROBLEM 3584 October 8, 1981 220-339 Inadequate erd margin on an electrical coil and manufac-turers use of silcone rubber to mask the problem.
3850 October 8, 1985 8316 Valves not shifting adequately at Hope Creek.
3871 February 26, 1986 8316 Insufficient DP across certain NP valves stuck open at Comarche Peak.
- 3916 July 24, 1984 8321 Pilot orifice drilled in wrong location - resulted in shift hesitation, 9
3643 May 18, 1982 8321 Hole drilled in wrong loca-tion - NP series 3825 March 19, 1985 8316 Diaphragms interchanged between ports causing c'auggish shifting.
3873 July 30, 1986 205-381 Orifice too small - lower disc not operating properly.
3247 July 24, 1985 NP 1eries Ethylene projlene diaphragm wicking probites.
ORGANIZATION: AUTOMATIC SWITCH COMPANY .
FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 16 of 18 VALVE CAT.
IR NO. DATE SERIES PROBLEM 3902 October 30, 1986 NP Series Several solenoid valves were found to be shifting slowly or not at all,
- e. The situation documented in IR 3584 was selected for an examplc.'.
The document revealed the following:
(1) ASCO-KONAN of Japan identified during a September 0, 1981 receipt inspection of 200 NP Class H coils (ID- N X, 125 VDC, 17.4W) that 90-percent of the ALTRON coils had exposed magnet wire on one end.
(2) ASCO-KONAN determined root cause at manufacturer (ALTR0h) not complying with a procedural one-sixteenth inch minimum end margin.
(3) Two out of eight hypot-tested samples failed.
(4) Manufacturer masked exposed wires with an unacceptable silcone-rubber type of material.
(5) ASCO (New Jersey) sampled 20 stock coils and found some failures during hypot-testing (seven failures at LOCA similar hypot-testing and three failures at initial 9, ,
hypot-testing).
(6) ASCO (N a Jersey) did not address the generic issue of ALTRON coils previously shipped to licensees, if any, both domestic and foreign.
The ASCO review of its Els and irs in general, appears to have adequately evaluated and dispositioned the obvinus in-house or licensee hardware problems that were identified. However, almcst in all cases, ASCO has not evaluated the deviations pur-suant to 10 CFR Part 21 nor have they taken adequate actions to notify licensees of potential _ hardware probicas if the devia-tion could affect installed hardware that was previously shipped or that may be generic to other facilities (violation 88-01-01 was identified in this area).
- 7. Review of ASCO Procedure ECP-111, Rev. D, dated December 12 1983.
X5CO procedure EDP-111. "Qualification of Products for safety-related Nuclear Power Plant applications
- was rrviewed. The document
ORGANIZATION: AUTOMATIC SWITCH COMPANY .
- FLORHAM PARK, NEW JERSEY REPORT INSPECTION NO.: 99900369/88-01 RESULTS: PAGE 17 of 18 establishes methods and procedures to be followed when conducting a qualification program to verify the suitability of ASCO valves, pres-sure switches, for use in safety-related nuclear power plant installations,
- a. EDP-111 states in part: ... All records pertaining to qualifi-cation test results, product design modification, and other important occurrences in connection with the qualification pro-gram shall be maintained indefinitely at ASCO in a fonn suitable for audit..."
- b. As noted in 88-01-07, ASCO could not provide requested documentation during the inspection.
- 8. Licensee Notification of Deviations Discussions were conducted with ASCO management personnel in regard to its responsibilities pursuant to Section 21.21 of 10 CFR Part 21.
ASCO has established a "Field Service Bulletin" (FSB) system for comunicating technical information to its end users but has not utilized its FSB system to any great extent. The inspectors
, reiterated that it is ASCO's responsibility to notify the NRC licen-sees of deviations that need to be evaluated to detennine whether or not they could create a substantiel safety hazard unless ASCO perfortns the evaluations.
It was discussed with ASCO that they need to assure that the licen-
?. sees are notified in some manner so that the licensees can cause the evaluation to be performed. The ASCO FSB system could be one method to accomplish the task.
F. PERSONNEL CONTACTED:
Name Title A. G. Byrne Service Manager J. P. Casciano Personnel Manager R. J. Entwisle Engineering Services Manager T. R. Hays Nuclear Sales J. McConnell President and CEO R. G hosal 0A Engineer G. J. Plechy - 0A Engineer J. R. Shank Engineering Manager - Valve Department K. Thomas Service Engincer D. B. Tompsen QA Manager
ORGANIZATION: AUTOKATIC SWITCH COMPANY .
FLORHAM PARK, NEW JEESEY REPORT INSPECTION h0.: 99900369/88-01 RESULTS: PAGE 18 of 18 2 Name _
Title E. J. Vehnekamp Training Manager D. Vollner Chief Engineer - Valve Department J. F. Weaver Valve Development Vice President H. J. West Operations Vice President
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