ML20199C319
| ML20199C319 | |
| Person / Time | |
|---|---|
| Issue date: | 06/13/1986 |
| From: | Merschoff E, Yachimiak E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20199C316 | List: |
| References | |
| REF-QA-99900248 NUDOCS 8606180069 | |
| Download: ML20199C319 (10) | |
Text
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O ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN INSPECTION INSPECTION REPORT DATE: 1/13-16/86 ON-SITE HOURS: 21 N0.: 99900248/86-01 CORRESPONDENCE ADDRESS: Union Pump Company ATTN: Mr. Peter S. Ordway President 87 Capital Avenue, S.W.
Battle Creek, Michigan 49016 ORGANIZATIONAL CONTACT: Paul Woods - QA Manager TELEPHONE NUMBER: (616) 962-6141 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of centrifugal and reciprocating pumps.
ASSIGNED INSPECTOR: O_
(, /S (o E. Yachimiak, Reactig Inspection Section (RIS) Dyte OTHER INSPECTOR (S): T. Tinkel, Brookhaven Nation Laboratory APPROVED BY: dkM E. Merschoff, Chief, RIS, Tendor Program Branch 06te INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21,10 CFR 50 Appendix B, and ASME NCA-4000.
B. SCOPE: In its letter of November 19, 1985, Union Pump Company expressed a concern to the NRC about Commonwealth Edison Company's (CECO) intention to purchase commercial grade spare parts for components which Union Pump knew to be in safety-related services. The purpose of this inspection was to determine if spare parts supplied to CECO plants were produced in PLANT SITE APPLICABILITY: Beaver Valley 1 & 2, (50-334/412); Big Rock Point, (50-155); Browns Ferry, (50-296); Brunswick, (50-324/325); Callaway,(50-483);
(continued on next page) 8606180069 860613 PDR GA999 EMVUNPU PDR 99900248
l ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION 99900248/86-01 RESULTS: PAGE 2 of 9 NO.-
- 8. SCOPE: (continued) accordance with the requirements of the original customer purchase order specifications and to identify the differences in processing Union Pump components and spare parts as nuclear grade versus commercial grade items.
These processing differences may have an impact on the dedication process at CECO.
PLANT SITE APPLICABILITY: (continued) Catawba,(50-413/414); Clinton,(50-461);
Comanche Peak, (50-445); Cook, (50-315/316); Cooper, (50-298); Dresden 1 & 2, (50-010/237); Duane Arnold, (50-331); Farley, (50-348/364); Fermi 2, (50-341);
Fitzpatrick, (50-417); Grand Gulf, (50-341); Hatch 1 & 2, (50-321/366); Hope Creek, (50-354); Indian Point 2,(50-247); LaSalle 1 & 2, (50-373/374); Limerick 1,(50-352); Millstone 1, 2, & 3, (50-245/336/423); Monticello, (50-263); Nine Mile Point 2, (50-410); Perry, (50-440); Peach Bottom 2 & 3, (50-277/278);
Pilgrim, (50-293); River Bend, (50-458); Salem 1 & 2, (50-272/311); San Onofre 1, 2, & 3, (50-206/361/362); Seabrook, (50-443); Sequoyah 1 & 2, (50-327/328);
Sesquehanna 1 & 2, (50-387/388); Shearon Harris, (50-400); Shoreham, (50-322);
St. Lucie 2, (50-389); Surry 1 & 2, (50-288/281); Turkey Point 3 & 4, (50-250/
251); Vermont Yankee, (50-271); Vogtle, (50-424); Watts Bar, (50-390/391);
Yankee Rowe, (50-29); Zion 1 & 2, (50-295/304).
A. VIOLATIONS:
None.
B. NONCONFORMANCES:
None.
C. UNRESOLVED ITEMS:
None.
D. INSPECTION FINDINGS AND OTHER COMMEN'S:
- 1. Dresden Purchase Order Review Six CECO purchase orders (P0s) were reviewed to ensure that the original P0 specification requi-ements were being met. Most of the P0s were for Standby Liquid Conirol (SLC) pump spare parts; all were found to be acceptable. While the original P0 specifications do not make mention of quality assurance requirements for SLC pumps, Union Pump utilized its own nuclear QA program procedures to complete the CECO orders. These procedures are described in Section D.2.c of this report.
ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION N0.- 99900248/86-01 RESULTS: PAGE 3 of 9
- 2. Differences Between Nuclear and Commercial Grade Spare Parts In general, the major difference between a nuclear and a commercial spare parts order is the overall manner by which Union Pump processes the orders. Union's quality assurance program has a set of policies and procedures which are used for nuclear orders, while a different set is used for commercial orders. The substantive result is that nuclear orders are processed with more control and documentation than a commercial. order. These two differences play
.an important role, when one discusses the dedication process as applied to commercial grade material and components. A qualified dedication process is used at Union Pump to dedicate components and materials for nuclear service when they are processed under the commercial quality assurance program. This insures that they are as good as similar components manufactured along the guidelines of the nuclear quality assurance program. A detailed discussion of Union Pump's handling of nuclear and commercial grade orders is included in the following sections.
- a. Policy. Union Pump Company has different policies relative to order processing and quality assurance requirements for nuclear and commercial orders. Of the four pump grades that Union produces: commercial, nuclear non-pressure boundary, nuclear pressure boundary, and nuclear safety related boundary; the three nuclear grades are all processed in accordance with the policies and quality requirements applicable to nuclear orders.
These policies are summarized below:
(1) The quality requirements invoked for a nuclear order will meet or exceed those used on the original order, irrespective of whether the current purchase order requests this level of quality. The customer can add additional cuality requirements to his current order as long as the change does not negate ASME Section III rules or degrade the quality level specified for the original order. On a commercial order, the customer receives the level of quality specified in his current order.
(2) Any customer order invoking the requirements of 10 CFR 50 Appendix B, 10 CFR 21 and/or ANSI N45.2 is classified by Union as nuclear safety related boundary. Any order invoking ASME Section III is processed as a nuclear order.
ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION NO.- 99900248/86-01 RESULTS: PAGE 4 of 9
- b. Purchase Order Preparation and Processing. Union has two different procedures for processing purchase order paperwork.
One is QCR-4423-1, which is a written procedure for nuclear parts order routing. The procedure used for commercial orders is unwritten. The following evaluation shows some of the similarities and differences that exist between the procedures.
For a nuclear order the Nuclear Product Manager (NPM) reviews the customer parts order against the bill of material. for the original component or parts. He ensures that all applicable quality requirements are written into the order so that the new parts order is as good as or better than the original order requirements. He then stamps the order NUCLEAR; identifies which, if any, parts are safety related; and signs the nuclear order route sheet. The Quality Control Manager (QCM) then reviews the NPM's work and signs the nuclear order route sheet.
After the quality requirements have been checked, the QCM reviews the order requirements for certified raw stock and prepares the parts specification sheets. He also reviews and signs for the purchase of ASME Code and certified material and ensures that all vendors for ASME Code parts are approved vendors. Af ter each of the above steps, the QCM signs the nuclear route sheet.
After the order has been filled (manufactured) and shipped, the NPM files the nuclear order route sheet with a copy of the order.
The major differences between the processing of a nuclear order (described above) and a commercial order are as follows:
(1) The NPM identifies safety related parts / components only on nuclear orders.
(2) The Parts Department Manager, not the NPM, prepares the order form for commercial orders. He only imposes the quality requirements of the current purchase order and not what was specified in the original order.
(3) There is no nuclear order route sheet for commercial orders.
e ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION N0.- 99900248/86-01 RESULTS: PAGE 5 of 9 (4) On nuclear orders which originally required certified material, that material is used even if not specified on the current purchase order. Certified material will only be used on a commercial order if specifically i requested.
(5) The QCM reviews and signs the purchase order for ASME Code and certified material used in a nuclear order.
He does not do either for a commercial order.
(6) The QCM ensures that all material requiring certification have the proper specif'citions referenced in the purchase order.
- c. Quality Assurance Programs. Union Pump has two different quality assurance programs in place. Nuclear orders are controlled by the Nuclear Quality Assurance Manual (NQAM).
. Commercial orders are controlled by the Commercial Quality Assurance Manual (CQAM). Material Certification Requirements (MCR) procedures and Quality Control Requirement (QCR) procedures are used to amplify a nunber of the subject areas addressed in the NQAM.
(1) Quality Assurance Manuals (QAM). A brief review of tha two QAMs show differences in the amount of documentation and control required by the manuals.
Under Section 2 of the NQAM, " Quality Assurance Program and Indoctrination and Training," specific requirements for inspection and test personnel are set. The CQAM does not contain this requirement.
Section 7 of the NQAM, " Control of Purchased Items and Services," contains provisions for vendor quality control audits and approved vendors. The CQAM does not contain these requirements.
In Section 12 of the NQAM, " Control of Measuring and Test Equipment," requirements for the recording and retention of test equipment serial numbers are set when tests and measure-ments are made on pressure boundary parts. The CQAM does not contain these requirements.
ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION )
NO.- 99900248/86-01 RESULTS: PAGE 6 of 9 i l
In Section 17 of the NQAM, Quality Assurance Records, the l NQAM requires the use of a Final Records Package Index prepared by the QC manager. This document identifies the names and retention category (lifetime or non-permanent) for the particular quality documents. The CQAM does not require the use of this index.
A brief review of the documentation invoked by the two quality assurance manuals shows that the NQAM involves some 50 different exhibits (forms and documents). The CQAM involves some 25 exhibits. Some of the exhibits listed in the NQAM and not the CQAM include:
- Nuclear hold tag
- Nonconforming paperworks flow chart
- Part specification sheet / raw-material inspection log
- Nuclear part tag
- Vendor quality control audit
- Training record
- Final design revision checklist
- Material listing
- Approved vendor list (2) Material Certification Requirements (MCR). MCR-0301-2
" Material Certification Requirements for Heat Treat Certification" and MCR-3001-2 " Material Certification Requirements for Heat Treat Charts" are invoked on vendors for nuclear orders and not commercial orders. These MCRs provide additional documentation upon which Union can evaluate the actual heat treat process against the specification requirements. This additional documentation would not be available for a commercial order.
(3) Quality Control Requirement (OCR).
QCR procedures are used on nuclear orders to assure a required level of control and quality in the performance of a particular requirement. One example of a QCR is QCR-4423. The essential elements of this procedure are described in section D.2.b of this report.
ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION NO.: 99900248/86-01 RESULTS: PAGE 7 of 9
- d. Design and Design Qualification.
The design and design qualification for a pump are specified in the technical specifications referenced in a purchase order.
Union supplies a number of pump models that have both nuclear and commercial (non-nuclear) application. The main difference usually between the two services being the type of materials used. As an example, the TD-50/60 reciprocating pump has been supplied with a stainless steel plunger both with and.without a Colomony coating (for wear resistance). An example of how Union pumps are used in nuclear service can best be shown by the following listing:
Model Nuclear Application
- HHS Centrifugal Pump Diesel Service Water Pump
- Multi-stage Centrifugal Control Rod Drive Water
- Pump Pump
- HTS Centrifugal Pump Reactor Water Cleanup Pump
- TD-50/60 Reciprocating Standby Liquid Control Pump Pump
- QX-300 Reciprocating Charging Pump-Pump
- e. Inspection and Tes"ing.n (1) The difference between inspection provided for nuclear and commercial pumps appears to be the sole result of the QA program being used unless special requirements are identified in the purchase order. One difference between a nuclear and a commercial pump is the involvement of the Authorized Nuclear Inspector (ANI). A nuclear order which requires pump pressure boundary parts in compliance with ASME Section III includes various hold and check points for the independent verification by the ANI. These partic-ular checks are not required for nuclear non-pressure boundary or commercial orders (Note: Union representatives stated they would process a commercial order, invoking ASME Section III, as a nuclear pressure boundary order).
(2) Union conducts performance tests on all pumps, nuclear or commercial. Testing in excess of the standard performance test is done to the extent specified in the purchase order.
ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION NO.- 99900248/86-01 RESULTS: PAGE 8 of 9
- f. Records and Record Retention.
(1) Commercial orders to material vendors do not place any requirements on the vendor relative to minimum periods of time for retaining records. Nuclear orders invoke MCR-0201-8 which requires vendors to maintain at their location all quality assurance records pertaining to the
( order for a period of seven years.
(2) A final records package index is used on nuclear orders.
This index is not used on commercial orders. In addition g
to specifying which quality records are to be maintained, i the index also classifies records as indefinite records
- maintained for 10 years after being superseded or invalidated.
- 3. Specification Information Review
- a. Standby Liquid Control Pump specification information.
The original P0 specification for the Dresden Standby Liquid Control Pumps was GE #205-92195, dated 8/17/66. In GE document
- 21A5572, " General Requirements for Standby Liquid Control Pumps," only ASME Section III, Class C is referenced, none other. This standard only applies to the pressure boundary parts of the SLC pump casing,
- b. Charging Pump Specification Information.
The original purchase order specification for CECO charging pumps was Westinghouse specification #676428 dated 11/23/66.
In addition to having ASME Section III, Class C standard specified, a particular Westinghouse Quality Control document was referenced, QCS-1, dated 5/18/67. This Quality Control document established requirements for control of quality during manufacturing. This included inspection plans such as receipt inspection and quality audits.
4 e
ORGANIZATION: UNION PUMP COMPANY BATTLE CREEK, MICHIGAN REPORT INSPECTION NO.- 99900248/86-01 RESULTS: PAGE 9 of 9
- 4. Hope Creek Purchase Order Review During the review of recent Purchase Order file records, a P0 ofspecific interest was located. The order was from Hope Creek Unit 1, Union order #DN2355-E, which requested a number of spiral wound gaskets. These gaskets were identified on the purchase order as safety related. Further, these particular gaskets are normally obtained commercial grade by Union. Because of this, Union invoked the requirements of QCR-4438-2, " Safety Related-Dedicated Parts Procedure". One of the checks ~ required by the dedication procedure was a thickness measurement of each individual gasket. This check revealed that six gaskets pulled from the parts bin were about .010" undersize. The receipt inspection of commercial grade gaskets only involves a sampling procedure for verifying gasket thickness. This illustrates a situation where additional quality checks invoked for this nuclear-safety related order prevented nonconforming material from being delivered. The file contained scrap reports for the
- nonconforming gaskets as well as completed safety history forms for the correct gaskets.
- 5. Licensee Audits Corrective action for six licensee audits of Union Pump company were reviewed and found to have been properly and acceptably handled by Union quality assurance personnel. All nonconformances which were identified were corrected. Two audits were performed recently with only preliminary report findings on record in Union files. Final audit reports are due shortly. It was noted that Union Pump was in the process of correcting deficiencies presented in those preliminary findings reports.
E. PERSONS CONTACTED:
J. F. Stout, QC Coordinator, Union Pump Ccmpany B. Wheeler, QC Engineer, Union Pump Company L. A. Peck, Project Engineer, Union Pump Company T. Norton, Sales Engineer / Manager Nuclear Products, Union Pump Company J. Thompson, QC Manager, Union Pump Company M. Davison, Project Engineer, Union Pump Company G. Law, Product Manager, Union Pump Company P. Woods, QA Manager, Union Pump Company
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