ML20205S563
| ML20205S563 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1983 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20205S481 | List: |
| References | |
| FOIA-87-152, REF-QA-99900330, REF-QA-99900831 NUDOCS 8704070058 | |
| Download: ML20205S563 (2) | |
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. f 161953 MEMORANDUM FOR:
C. E. Norelius, Director, Division of Project and Resident Programs, Region III FROM:
U. Potapovs, Chief, Vendor Program Branch, Division of Vendor and Technical Programs, Region IV
SUBJECT:
CLOSE0UT OF AITS NO. F03021783 - POTENTIAL FAILURE OF 05-416 CIRCUIT BREAKER UNDER VOLTAGE TRIP DEVICES (UVTDs)
Vendor Program Branch (VPB) inspections were performed, respectively, at ICO de Puerto Rico on May 16-18, 1983, and at Westinghouse Switchgear Division on August 1-4, 1983, which addressed the subject AITS item.
The results of these inspections are documented in the attached VPB Inspection Report Nos. 99900831/83-01 and 69900330/ Q The results indicate that malfunction of the 05-416 circuit breaker UVTD was the result of the following two types of design deficiency:
1.
Manufacturing drawings allowed a stack-up of tolerances which appears to have resulted in interference in the mechanical linkages.
2.
A change was made to use a thicker retaining ring without making a corresponding increase in the width of the retaining ring slot in the mating part.
Design review activities have established corrective actions for the UVTO problems and were stated to be ongoing with respect to assessing the potential for similar problems in other circuit breaker components; e.g.,
shunt trip devices.
This review of other components will be addressed during a subsequent inspection.
The plant sites affected by the. UVTO problem have been established.
Committed corrective actions were to perform a 100% inspection of certain parts of replacement UVTDs and a dimensional check be made at final assembly.-
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available inspection records, however, it could not be assured that all of these inspections had been performed.
It is accordingly recommended that IE (R. L. Baer) review the inspection findings with respect to determining whether additional verification of UVTO adequacy should be considered.
If there are any questions on this matter or additional information is required, please contact Mr. W. M. McNeill (728-8174).
Uldis Potapovs, Chief Vendor Program Branch Attachments: As Stated cc:
R. F. Heishman, IE R. L. Baer, IE J. T. Collins, RIV R. L. Bangart, RIV R. C. Lewis, RII bec: VPB 7010 File (83-150)
VPB 3060 File W. M. McNeill e
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Westinghouse Switchgear Divisions lll.f.ylgl;L.,.3..;
Electric Corporation October 13, 1983 United States Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 OCT l 71983 Attention: Mr. Uldis Potapovs, Chief Vendor Program Branch
Subject:
Response to Inspection Report Docket No. 99900330/83-01
Dear Mr. Potapovs:
This letter is in response to the subject inspection report, Appendices A and B.
For clarity, th'a Notice of Violation and the three items in the Notice of Nonconformance are repeated in our response.
NOTICE OF VIOLATION As a result of the inspection conducted on August 1-4, 1983, and in accordance with Section 206 of the Energy Reorganization Act of 1974 and its implementing regulation 10 CFR Part 21, the following violation was identified and has been categorized in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987 (March 9,1982):
Section 21.6 of 10 CFR Part 21 dated December 30, 1982, states, in part,
"(a) Each... corporation... subject to the regulations in this part, shall post current copies of the following documents... (1) the regulations in this part Contrary to the above, the copy of 10 CFR Part 21 that was posted was not the current issue dated December 30, 1982.
This is a Severity Level V violation (Supplement VII).
l WESTINGROUSE RESPONSE At the time of your inspection on August 1-4, 1983, the Westinghouse Corporate Council for the Implementation of 10 CFR 21, which provides the posters for
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Mr. Uldis Potapovs October 13, 1983 all the affected Westinghouse Divisions, had completed a revised poster with revisions promulgated up to and including January 10, 1983. However, this revised poster had not yet been distributed by the Corporate Council. The revised poster has now been received and was posted on August 17, 1983.
The Corporate Council advises us that it is their practice to provide us posters with the updated version of 10 CFR 21 as soon as practicable after revisions are promulgated and that they will continue to do so.
I will as-sure that any revised posters will be posted premptly on receipt by me.
In this regard, I have been advised by the Corporate Council that a revision of the poster is currently in preparation to reflect the change in the tele-phone number for Region III which went into effect September 12, 1983.
As stated above, I will post this revision as soon as I receive copies.
NOTICE OF NONCONFORMANCE A.
A Westinghouse letter (NS-EPR-2762) dated May 6,1983, to the Nuclear Regulatory Commission (E. P. Rahe to H. Denton) states, in part, regard-ing replacement DS-416 undervoltage trip devices (CVTDs), "Af ter the.
failures at McGuire, replacement units were required to be manufac-tured... Since the.
. problem at McGuire was linked to manufac-turing control of critical dimensions on selected parts,100% quality control checks of the... critical parts were instituted in the new procedure. Those parts were labeled ' critical' meaning only that they would henceforth be subject to 100% dimensional checks.
Contrary to the above, it could not be established from available inspec-tion records that all of the critical parts of 21 replacement UVTDs had received the required 100% quality control checks.
For example, the records on file indicated that only 1 roller (72004CK02E), 4 C-rings (70610DB20C), 5 pins (8058A62H01), and 16 bracket pin assemblies j
(436B787G02) had been inspected for the 21 UVTDs contained in Shop i
Order Nos. 02TN192, 02YN193, and 02YN194.
WESTINGHOUSE RESPONSE We acknowledge that detailed 100% dimensional inspection records are not available for the items identified in the Notice of Nonconformance. However, documentation does exist, and is available for your review, that provides evidence that the 100% dimensional inspection of the selected parts was per-formed. This documentation consists of "G" letters, signed by responsible Switchgear Division personnel, that indicate that the 100% dimensional in-spections were performed.
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s Mr. Uldis Potapovs October 13, 1983 This documentation provides evidence that 100% dimensional inspection was performed, even though this documentation does not provide specific details of the dimensional inspection (i.e., Form QCI 21-1).
Further, 100% of the assembled UVTDs were dimensionally inspected and functionally tested in accordance with documented procedures. The results of these inspections and tests are available for your review.
The inspection of the parts selected for 100% dimensional inspection prior to assembly of the 21 replacement UVTDs was performed using evolving pro-cedures that resulted in incomplete detailed dimensional inspection records.
In order to prevent recurrence of this nonconformance, inspections on future UVTDs will be performed in accordance with documented instructions that require identifiable documentation of the inspection of the UVTD parts se-lected for 100% dimensional inspection.
The above reaffirms that Westinghouse actions taken to date and planned for the future are in full compliance with the commitments made to the NRC in letter #NS-EPR-2762 (from E. P. Rahe, Jr., to H. Denton, dated 5/6/83).
NOTICE OF NONCONFORMANCE B.
Criterion V of Appendix B to 10 CFR Part 50 states, " Activities affect-ing quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be ac-complished in accordance with these instructions, procedures, or draw-ings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisf actorily accomplished."
Paragraph 6.1.1.2 of the switchgear Division Quality Assurance Manual (QAM) states, in part, "hhnufacturing policy is that fabrication and 4
assembly will be done according to the drawing and revision called for on the work order or shop order information.
Contrary to the above, the shop order information issued for replacement UVTDs did not identify the applicable drawing revisions to be used for the required 100% inspection of " critical items." For example, the bulk order for UVTDs destined for nonoperating plants (i.e., Shop Order No.
02YN202) did not ha"e Drawing Nos. 788A594 and 591C656 identified by 9
revision status.
WESTINGHOUQ RESPONSE We acknowledge that revision numbers for Drawings 788A594 and 591C656 were missing from the information issued on Shop Order 02YN202.
Change notices
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have been issued on this shop order to add the applicable revision numbers.
We have determined that the applicable revision numbers were used in the inspection of the critical parts in question.
To prevent recurrence of this nonconformance, responsible Switchgear Division personnel will be instructed to assure that applicable revision levels will be specified in the shop order information for all critical parts identified for 100% inspection.
No future orders for Class lE UVTDs will be released for manufacture before this instruction is completed.
NOTICE OF NONCONFORMANCE C.
Criterion V of Appendix B to 10 CFR Part 50 states, in part, " Activities affecting quality... shall be accomplished in accordance with...
instructions, procedures, or drawings...."
Item 2 of Purchase Order No. 54X470254 (Shop Order No. 02YN192) requires issue of Certificates of Conformance for each UVTD to certify compliance j
with the purchase order technical requirements.
Contrary to the abcve, Certificates of Conformance were on file for only five replacement UVTDs of the eight that had been shipped on Purchase Order No. 54X470254 to the McGuire site.
WESTINGHOUSE RESPONSE During the inspection, a Certificate of Conformance dated 4/4/83 for a quan-tity of two UVTDs, and a Certificate of Conformance dated 4/13/83 for a quan-i tity of three were examined. We later found that the original copy of the 4/4/83 Certificate of Conformance had been voided as these two devices were never delivered to the site. The 4/13/83 Certificate of Conformance is valid as will be explained below.
On 4/5/83, two UVTDs were shipped.
On 4/7/83, we learned that both devices l
had incorrect pins, and they were recalled. On 4/11/83, we delivered six devices. On inspection at the site, one was found to have one dimension out of specified tolerance. That device was brought back to East Pittsburgh.
On 4/13/83, we shipped 3 devices.
We have on file-a certificate of conformance dated 4/5/83 for two devices, a Certificate of Conformance dated 4/8-4/9/83 for six devices, and a Certifi-cate of Conformance dated 4/13/83 for three devices.
These Certificates cover a total of eleven devices shipped to McGuire, of which three were returned, leaving eight at the site.
The Certificates of Conformance dated 4/5/83 and 4/8-4/9/83 were located j
subsequent to the inspection of 8/1-8/4/83.
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'Mr.hidisPotapovs October 13, 1983 CLARIFICATION As requested by the inspector at the exit interview conducted at the end of the NRC follow-up inspection on September 22, 1983, we offer the follow-ing clarification of the subject of a possible Westinghouse design review of the circuit breaker shunt trip device:
Westinghouse Water Reactor Division is conducting two separate reviews of the addition of the shunt trip device to the automatic protection system.
One of these reviews is of the electrical interface requirements necessary to add the shunt trip device to the autcmatic protection system, and the second review is of the interface of the shunt trip device with the breaker.
Currently, no detailed review of the shunt trip device itself has been con-ducted.
Very truly yours, Approved:
D. B. Jones, Manager Quality Assurance h, f/t.
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Switchgear Division D. M. Sauter General Manager Switchgear Division
JAN 0 ? 1984 Docket No. 99900330/83-01 Westinghouse Electric Corporation Switchgear Division ATTri: tir. D. M. Sauter General Manager 700 Braddock Avenue East Pittsburgh, PA 15112 Gentlemen:
Thank you for your letter of October 13, 1983, in response to our letter dated September 13, 1983. As a result of our review, we find that additional information is needed. Specifically, please identify the preventive actions you plan to take in regard to item C of the Notice of lionconformance.
Please provide the additional information within 25 days of the date of this letter.
Sincerely, s: ned bn
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.,y Westinghouse Switchgear DMslons roa srace m 4,ene, East Pinscurgh Fennsylvania 15i12 Electric Corporation January 31, 1984 United States Nuclear FEB - 6 ga Regulatory Commission vyt Region IV a
611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Attention:
Mr. Uldis Potapovs, Chief Vendor Program Branch
Subject:
Docket No. 99900330/83-01
Dear Mr. Potapovs:
Your letter of January 9, 1984 requests that we supplement our October 13, 1983 letter by identifying the preventive actions we plan to take in regard to Item C of the Notice of Nonconfor-mance.
Procedures have been instituted under which each UVTD is assigned a unique serial number which is clearly stamped on the device before it is delivered for test.
This serial number must be shown on the Certificate of Conformance at time of shipment.
Procedures directing personnel to file Certificates of Conformance in our shop order folder have also been formalized.
These procedures will prevent a recurrence of the type of situation discovered during your August 1-4, 1983 inspection.
Very truly yours, W
Approved:
D.
B. Jones, Manager Quality Assuralice
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1 ggD Docket'No. 99900330/83-01 Westinghouse Electric Corporation Switchgear Division ATTN: Mr. D. M. Sauter General Manager 700 Braddock Avenue East Pittsburgh, PA 15112 Gentlemen:
Thank you for your letters of October 13, 1983, and January 31, 1984, in response to our letters dated September 13, 1983, and January 9,1984.
We have reviewed your reply and find it responsive to the ccncerns raiseo in our Notice of Violation and Notice of Nonconformance. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, Original Signed Byr.
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