ML20211D858
| ML20211D858 | |
| Person / Time | |
|---|---|
| Issue date: | 10/17/1986 |
| From: | Merschoff E, Yachimiak E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20211D829 | List: |
| References | |
| REF-QA-99901064 99901064-86-01, 99901064-86-1, NUDOCS 8610220284 | |
| Download: ML20211D858 (7) | |
Text
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ORGANIZATION:
ENERFAB INCORPORATED CINCINNATI, OHIO REPORT INSPECTION INSPECTION NO.: 99901064/86-01 DATES: 09/15-18/86 DN-SITE HOURS:
16 CORRESPONDENCE ADDRESS: Enerfab, Incorporated ATTN: Mr. Dwaine A. Godfrey President 4955 Spring Grove Avenue Cincinnati, Ohio 45232 ORGANIZATIONAL CONTACT: Mr. Kenneth T. Shinkle TELEPHONE flUMRER:
( 5131 641-0E00 NUCLEAR INDUSTRY ACTIVITY:
- 1) Containment airlock spare parts for approximately 40 nuclear plants. 2) Nuclear construction activities at Crystal River nuclear plant.
/o//?!gg, ASSIGNED INSPECTOR:
E. Yachimiak, React /ve Inspection Section (RIS)
'Da te OTHER INSPECTOR (S):
I to/7 g APPROVED BY:
Vendor Program Branch Date E. W. Merschoff, Chief, INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B; 10 CFR Part 21.
B.
SCOPE: As a result of two separate 10 CFR Part 21 notifications to the NRC by Consumers Power, Palisades plant and Indiana and Michigan Electric Company, D.C. Cook nuclear plant, an inspection of the current vendor, Enerfab, Inc., was performed. The most recent notificaticn, by Consumers Power, dealt with the improper design of the pressure equalizing valve j
(<nn+inued nn Pann M l
PLANT SITE APPLICABILITY:
Various.
8610220284 861020 PDR GA999 EMVENFAB 99901064 PDR
5 ORGANIZATION: ENERFAB INC.
CINCINNATI, OHIO REPORT INSPECTION N0.: 99901064/86-01 RESULTS:
PAGE 2 of 6 SCOPE:
(continued) actuation cam in their containment emergency escape air-lock. The second notification, by Indiana and Michigan Electric Company, dealt with the concern that their containment airlock window glass was not qualified to meet LOCA environmental requirements. Both these items were reviewed to ensure that Enerfab's Part 21 evaluations had been adequately performed.
In addition, the Enerfab Cuality Assurance program was reviewed in the areas of procurement, receipt inspection, indoctrination and training, internal and external audits, and measuring and test equipment control.
A.
VIOLATIONS:
Contrary to Section 21.21, " Notification of failure to comply or existence of a defect," of 10 CFR Part 21, Enerfab failed to adopt appropriate proce-dures to provide for (1) evaluating deviations or (ii) informing the customer (licensee) so that the deviations may be evaluated.
(86-01-01)
This is a Severity Level V violation (Supplement VII).
B.
NONCONFORMANCES:
1.
Contrary to Criterion V, " Instructions, Procedures, and Drawings of Appendix B to 10 CFR Part 50, Enerfab failed to establish adequate procedures and instructions for quantitative or qualitative acceptance criteria for receiving inspection activities and handling, shipping, and storage activities.
(86-01-02) 2.
Contrary to Criterion VII, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50, Enerfab failed to ensure that Quality Techniques, Incorporated was on the approved vendors list for the calibration of gage blocks (standards) used to calibrate Enerfab measuring and test equipment.
(86-01-03)
C.
UNRESOLVED ITEMS:
i On April 16, 1986, the D.C. Cook nuclear plant notified the NRC that pursuant to 10 CFR Part 21 and 10 CFR 50.73(a)(2)(v), a potential problem with their containment airlock observation window glass existed.
l Based on test information supplied by Enerfab, a sample of the tempered window glass shattered when exposed to a beta radiation dose of 2.5 megarads over a 10-second period. This beta dose would have been reached in less than one (1) hour during a D.C. Cook design basis loss-of-coolant
(
accident. Because D.C. Cook uses an annealed (untempered) window glass, l
4
's ORGANIZATION:
ENERFAB INC.
CINCINNATI, CHIO REPORT INSPECTION N0.-
99901064/86-01 RESULTS:
PAGE 3 of 6 there was uncertainty as to the applicability of this test information.
As a precautionary measure, 3/8-inch thick steel cover plates were installed as beta shields. Af ter extensive review, D.C. Cook reported the above concern to the NRC.
Discussions with Enerfab personnel and other NRC members were undertaken to determine the significance of the test information.
Since the beta dose was delivered in such a short time, the conclusion was made that the glass shattered from induced thermal stresses, rather than radiation damage.
During the review of information surrounding this concern, the original qualification report for the annealed window glass was located. The minimum test specified parameter for radiation exposure was set at 29.0 megarads from a 1.0 megarad/HR gamma source. Actual exposure was measured a t 33.0-36.3 megarads. All four (4) window glass samples were then pressure tested to 60 psig, the required design test condition; all passed. At elevated pressures one (1) windcw glass failed at 110 psig and two (2) window glasses survived to 120 psig without breaking.
While it appears that the recent beta radiation test information does not directly affect the qualification of containment airlock window glass, the uncertainty as to whether the effects of beta radiation cn the window glass were considered does exist. The original qualification documents do not address the effects of Beta radiation, thus making this an unresolved item.
D.
STATUS 0F PREVIOUS INSPECTION FINDINGS:
Enerfab now controls all of the original W. J. Woolley (99900390) nuclear containment personnel airlock documentation, and supplies all replacement parts and engineering services for Woolley components.
This is the first NRC inspection of Enerfab, Incorporated.
E.
OTHER FINDINGS AND COMMENTS:
1.
Emergency Airlock Equalizing Valve Design Discrepancy On August 8,1986 Consumers Power notified the NRC that as a result of an irrproper cam design, the coordination between the containment emergency escape airlock doors and their pressure equalizing valves was not correct. Combining the above defect with the arrangement of the airlock doors actuation mechanism along a common shaf t, the opening of one door through the appropriate handwheel movement caused inadvertent opening of the opposite door's ecualizing valve.
This
4 4
ORGANIZATION: ENERFAB INC.
CINCINNATI, OHIO REPORT INSPECTION NO.-
99901064/86-01 RESULTS:
PAGE 4 of 6 configuration would result in a vent path from the inside of contain-ment to the outside environment during any times that one airlock door was open.
After extensive review of original design drawings and other engineer-ing documents, concurrence with Enerfab's Part 21 design review was established. Based on the available information, it appears that improper cam placement on the common connecting shaft or improper cam profile design caused early equalizing valve actuation at Palisades.
Corrective action recommended by Enerfab for Palisades consisted of the grinding of the cam profile. Depending upon plan specific cam /shaf t arrangements, the below list of affected plants may need to follow the above recommended corrective actions.
Oconee 1, 2, 3 50/269, 270, 287 Arkansas 1, 2 50/313,368 Shoreham 50/322 Shearon. Harris 1 50/400 2.
P_ art 21 Procedures During the review of the above two independent utility Part 21 submittals to the NRC, it was found that Enerfab did not have a procedure to provide for the evaluation of deviations as per 10 CFR Part 21.21.
The evaluations were, however, found to have been performed adequately.
Violation 86-01-01 was identified in this area.
3.
Inadequate Procedures The review of Enerfab's QA program focused on their current business activities in the area of replacement nuclear spare parts. After becoming familiar with their program, it was found that in two aren, handling, shipping and storage, and receiving inspection, none or inadequate procedures existed.
With many spare parts orders requesting shipping and storage requirements meeting ANSI-N45.2.2, a procedure to assure corrpliance with the standard should have been available.
If it was not. CA procedure 10-19-002-100, revision 0, dated October 5, 1984, " Material Receiving" dces not address the current spare parts activities which
v.
ORGANIZATION: ENERFAB INC.
CINCINNATI, OHI0 REPORT INSPECTION NO.: 99901064/86-01 RESULTS:
PAGE 5 of 6 now constitute most of Enerfab's nuclear business. Specifically, receiving inspection criteria for acceptance of spare parts is not mentioned.
Nonconformance 86-01-02 was identified in this area.
4.
Calibration Services While the importance of measuring and test equipment calibration is currently limited to the QC inspector's measuring tools, the calibra-tion of the NBS traceable standards (gage blocks) was not performed by a vendor on the Approved Vendors list. The calibration performed an October 28, 1985 by Quality Techniques, Incorporated was documented appropriately, but did not meet the requirements of Section VII of Appendix B to 10 CFR Part 50.
Nonconformance 86-01-03 was identified in this area.
5.
Audi ts Section 19.0 of the Enerfab QAM covers internal and external audits.
This area was reviewed for conformance to that manual section and no adverse findings were found. Three (3) external audits were performed for companys that did not possess a Quality System Certificate (MM or MS) or an ASME Certificate of Authorization (N-type stamp). Because the Enerfab QAM was issued in November, 1985, the first scheduled internal audit is planned for November, 1986.
6.
Measuring and Test Equipment Controls The only tools which are kept under the control of the QA department are a 0"-1" micrometer, a 0" "6" dial caliper, and a coating thickness measuring tool.
Each had been calibrated to the requirements of QA Procedure 50-19-002-070, " Calibration of Measuring and Test Equipment."
7.
Procurement Document Control A review of the Enerfab procurement process was performed with main emphasis being placed on the activities of the spare parts I
specialist. A sample of six purchase order (P0) documents was taken to verify that the appropriate QA, engineering and material management personnel had reviewed them. No discrepancies were
S.
ORGANIZATION:
ENERFAB INC.
CINCINNATI, OHIO REPORT INSPECTION NO.: 99901064/86-01 RESULTS:
PAGE 6 of 6 found in this area.
It appeared that the majority of the procured items were replacement rubber gaskets and o-rings for personnel air-locks and manways. Whenever quality requirements or 10 CFR Part 21 were specified on the nuclear utility's P0, Enerfab imposed the appropriate sub-vendor quality documents and Part 21 on their P0 to that vendor.
If a commercial item for a safety-related system was to be procured, a Commercial "off-the-shelf" justification was performed by the Engineering department. This was done for the Corning window glass material, which is commercially available, and has been tested and qualified by Enerfab for nuclear use.
F.
PERSONS CONTACTED:
- K. T. Shinkle, Quality A>surance Engineer, Enerfab, Inc.
- R. M. Hulick, Project Manager, Enerfab, Inc.
- D. A. Godfrey, President, Enerfab, Inc.
J. M. Ventura, Senior Engineer / Designer, Enerfab, Inc.
A. E. Davis, Spare Parts Specialist, Enerfab, Inc.
- J. W. Rothel, Senior Vice President, Enerfab, Inc.
- denotes present at exit meeting.
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